Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 1 of 12
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`LAW OFFICES OF SETH W. WIENER
`Seth W. Wiener (SBN 203747)
`seth@sethwienerlaw.com
`609 Karina Court,
`San Ramon, California 94582
`Telephone: (925) 487-5607
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`DEVLIN LAW FIRM LLC
`Timothy Devlin (pro hac vice to be filed)
`tdevlin@devlinlawfirm.com
`Patrick R. Delaney (pro hac vice to be filed)
`pdelaney@devlinlawfirm.com
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
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`ATTORNEYS FOR PLAINTIFF
`PRINCEPS SECUNDUS LLC
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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`PRINCEPS SECUNDUS LLC,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`and SAMSUNG SEMICONDUCTOR, INC.,
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`Defendants.
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` Case No.: 3:19-cv-6566-EMC
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`fffff
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`Case No.: 5:20-cv-00201
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`ORIGINAL COMPLAINT FOR PATENT
`INFRINGMENT
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`Original Complaint for Patent Infringement
`Page 1
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 2 of 12
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`Plaintiff Princeps Secundus LLC (“Princeps” or “Plaintiff”), for its Complaint against
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`Defendants Samsung Electronics Co., Ltd. (“SEC”); Samsung Electronics America, Inc. (“SEA”) and
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`Samsung Semiconductor, Inc. (“SSI”), (collectively “Samsung” or “Defendants”), alleges the
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`following.
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the Patent Laws of the United
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`States, 35 U.S.C. § 1 et seq.
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`THE PARTIES
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`2.
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`Plaintiff Princeps is a limited liability company organized under the laws of the State of
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`Delaware with a place of business at Princeps Secundus LLC, 261 West 35th Street, Suite No. 1003,
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`New York, New York 10001.
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`3.
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`Defendant Samsung Electronics Co., Ltd. (“SEC”) is a foreign corporation having its
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`principal place of business at 129, Samsung-Ro, Yeongtong-Gu, Suwon, Republic of Korea 16677.
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`SEC produces and sells telecommunications, electronics and mobile phone technologies worldwide,
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`including in the United States.
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`4.
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`Defendant Samsung Electronics America, Inc. (“SEA”) is a corporation organized and
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`existing under the laws of New York having its principal place of business at 85 Challenger Road,
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`Ridgefield Park, New Jersey 07660. Upon information and belief, SEA is a wholly-owned subsidiary
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`of Samsung Electronics Co., Ltd. (SEC). As explained in more detail below, SEA has a regular and
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`established place of business in this District and manufactures, supplies and sells consumer electronics
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`and products throughout the United States, including in this District.
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`5.
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`Samsung Semiconductor, Inc. (“SSI”) is a corporation organized and existing under the
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`laws of California having its principal place of business at 3655 North First Street, San Jose, California
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`95134 or 601 McCarthy Blvd., Milpitas, California 95035. Upon information and belief, SSI is a
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`subsidiary of SEA. Upon information and belief, SSI designs, manufactures, and supplies Samsung’s
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`EXYNOS® mobile processor utilized in several Samsung mobile devices. (See source:
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`https://www.samsung.com/semiconductor/processor/mobile-processor/, and
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`https://news.samsung.com/us/samsungs-exynos-auto-v9-next-generation-platform-audi-vehicle-
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`Original Complaint for Patent Infringement
`Page 1
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 3 of 12
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`infotainment-system//, last accessed and downloaded June 16, 2019, noted on January 9, 2020 as
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`having been removed.) On information and belief, the EXYNOS® mobile processor is an integral and
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`substantial component of the “Accused Instrumentalities”, as set forth in greater detail below and in the
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`attached preliminary and exemplary claim charts provided (Exhibits A-1 and A-2).
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`6.
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`SEA and SSI are both subsidiaries of SEC. All the Defendants (SEC, SEA and SSI) act
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`in concert regarding the allegations set forth in this Complaint and, therefore, the conducts described
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`herein are fairly attributable to either or all entities. More specifically, Defendants work collectively in
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`the designing, manufacturing, importing, distributing and selling of the Accused Instrumentalities
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`described in more detail below and in the attached claim charts (Exhibits A-1 and A-2).
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`JURISDICTION AND VENUE
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`7.
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`8.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
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`Venue with respect to Defendant SEC is proper in this District under 28 U.S.C. §
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`1391(c)(3) because Defendant SEC is not a resident of the United States, and also under 28 U.S.C. §
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`1391(b)(2) because SEC, imports, sells and offers to sell products and services throughout the United
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`States, including in this District, and introduces products and services into the stream of commerce and
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`effectuates these sales knowing that the products and services would be sold in this District and
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`elsewhere in the United States.
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`9.
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`This Court has personal jurisdiction over SEC. SEC is amenable to service of summons
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`for this action. Defendant SEC has sought protection and benefit from the laws of the State of
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`California by maintaining one or more of its United States affiliates (Defendant SSI) in this District
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`and/or by placing infringing products into the stream of commerce through an established distribution
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`channel with the awareness and/or intent that they will be purchased by consumers in this District.
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`10.
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`SEC – directly or through intermediaries (including distributors, retailers, and others),
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`subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sells its products in the
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`United States and this District. SEC has purposefully and voluntarily placed one or more of its
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`infringing products into the stream of commerce with the awareness and/or intent that they will be
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`purchased by consumers in this District. SEC knowingly and purposefully ships infringing products
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`into and within this District through an established distribution channel. These infringing products
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`Original Complaint for Patent Infringement
`Page 2
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 4 of 12
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`have been and continue to be purchased by consumers in this District. Upon information and belief,
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`through those activities, SEC has committed the tort of patent infringement in this District.
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`11.
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`On information and belief, Defendant SEC is subject to this Court’s general and specific
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`personal jurisdiction because SEC has sufficient minimum contacts within California and this District,
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`because Defendant SEC purposefully availed itself of the privileges of conducting business in
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`California and in this District, because Defendant SEC regularly conducts and solicits business within
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`California and within this District, and because Plaintiff’s causes of action arise directly from
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`Defendant SEC’s business contacts and other activities in California and this District. Having
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`purposefully availed itself of the privilege of conducting business within this District, Defendant SEC
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`should reasonably and fairly anticipate being brought into court here.
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`12.
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`Venue with respect to Defendant SEA is proper in this District under 28 U.S.C.
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`§ 1400(b) because, upon information and belief, Defendant SEA maintains a regular and established
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`place of business in this District, the Samsung Device Solutions America campus, also known as
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`“Samsung@First”. Samsung Device Solutions America campus is located at 3655 North 1st Street,
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`San Jose, California 95134, and has committed infringing acts in this District through its sales of the
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`Accused Instrumentalities in this District, and also under 28 U.S.C. § 1391(b)(2) because SEA sells
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`and offers to sell products and services throughout the United States, including in this District, and
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`introduces products and services into the stream of commerce and effectuates these sales knowing that
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`the products and services would be sold in this District and elsewhere in the United States. In addition,
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`on information and belief, Defendant SEA is a wholly owned subsidiary of SEC, a closely related co-
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`defendant in this action over which this Court has venue under 28 U.S.C. § 1391(c)(3) and 28 U.S.C. §
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`1391(b)(2) as noted above. Furthermore, Defendant SEA wholly owns another subsidiary, SSI,
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`another closely related co-defendant in this action and a California corporation over which this Court
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`has venue under 28 U.S.C. § 1400(b), as noted below.
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`13.
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`This Court has personal jurisdiction over SEA. SEA has conducted and regularly
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`conducts business within the United States and this District. SEA has purposefully availed itself of the
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`privileges of conducting business in the United States, and more specifically in California and this
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`District. SEA has sought protection and benefit from the laws of California placing infringing
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`Original Complaint for Patent Infringement
`Page 3
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 5 of 12
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`products into the stream of commerce through an established distribution channel with the awareness
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`and/or intent that they will be purchased by consumers in this District.
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`14.
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`SEA – directly or through intermediaries (including distributors, retailers, and others),
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`subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sells its products in the
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`United States and this District. SEA has purposefully and voluntarily placed one or more of its
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`infringing products into the stream of commerce with the awareness and/or intent that they will be
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`purchased by consumers in this District. SEA knowingly and purposefully ships infringing products
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`into and within this District through an established distribution channel. These infringing products
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`have been and continue to be purchased by consumers in this District. Upon information and belief,
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`through those activities, SEA has committed the tort of patent infringement in this District.
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`15.
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`On information and belief, Defendant SEA is subject to this Court’s general and
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`specific personal jurisdiction because SEA has sufficient minimum contacts within California and this
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`District, because Defendant SEA purposefully availed itself of the privileges of conducting business in
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`California and in this District, because Defendant SEA regularly conducts and solicits business within
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`California and within this District, and because Plaintiff’s causes of action arise directly from
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`Defendant SEA’s business contacts and other activities in California and this District. Having
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`purposefully availed itself of the privilege of conducting business within this District, Defendant SEA
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`should reasonably and fairly anticipate being brought into court here.
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`16.
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`Venue with respect to Defendant SSI is proper in this District under 28 U.S.C. §
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`1400(b) because SSI is a California corporation and therefore resides in this District.
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`17.
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`This Court has personal jurisdiction over SSI. SSI has conducted and regularly
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`conducts business within the United States and this District. SSI has purposefully availed itself of the
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`privileges of conducting business in the United States, and more specifically in California and this
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`District. SSI has sought protection and benefit from the laws of California by incorporating itself in
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`this District and/or by placing infringing products into the stream of commerce through an established
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`distribution channel with the awareness and/or intent that they will be purchased by consumers in this
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`District.
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`18.
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`SSI – directly or through intermediaries (including distributors, retailers, and others),
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`Original Complaint for Patent Infringement
`Page 4
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 6 of 12
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`subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sells its products in the
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`United States and this District. SSI has purposefully and voluntarily placed one or more of its
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`infringing products into the stream of commerce with the awareness and/or intent that they will be
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`purchased by consumers in this District. SSI knowingly and purposefully ships infringing products
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`into and within this District through an established distribution channel. These infringing products
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`have been and continue to be purchased by consumers in this District. Upon information and belief,
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`through those activities, SSI has committed the tort of patent infringement in this District.
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`19.
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`On information and belief, Defendant SSI is subject to this Court’s general and specific
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`personal jurisdiction because SSI has sufficient minimum contacts within California and this District,
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`because Defendant SSI purposefully availed itself of the privileges of conducting business in
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`California and in this District, because Defendant SSI regularly conducts and solicits business within
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`California and within this District, and because Plaintiff’s causes of action arise directly from
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`Defendant SSI’s business contacts and other activities in California and this District. Having
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`purposefully availed itself of the privilege of conducting business within this District, Defendant SSI
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`should reasonably and fairly anticipate being brought into court here.
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`The Inventions
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`BACKGROUND
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`Timothy B. Higginson is the sole inventor (hereinafter “the Inventor”) of U.S. Patent
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`No. 6,703,963 (“the ’963 patent” or “the patent in suit”). A true and correct copy of the ’963 patent is
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`attached hereto as Exhibit A.
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`21.
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`The ’963 patent resulted from the pioneering efforts of the Inventor in the area of small-
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`profile multifunctional input devices. These efforts resulted in the development of novel input devices,
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`and methods for operating them. The input devices utilize one or more functional modes and one or
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`more domain levels associated with entering input values into the devices. A provisional patent
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`application directed to the inventions was filed in the United States in September 2001.
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`22.
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`At the time of the Inventor’s pioneering efforts, the most widely implemented
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`technology used to address keying input data still involved implementing variants of the traditional
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`two-handed QWERTY keyboard. In that type of system, as explained in the ’963 patent:
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`Original Complaint for Patent Infringement
`Page 5
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 7 of 12
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`The QWERTY keyboard has been used as an input means since the development of the
`very first electronic devices. However, with the development of smaller, portable electronic
`devices, use of the QWERTY keyboard with these devices has certain drawbacks. As
`electronic devices have become smaller through advances in integrated circuitry, the traditional
`QWERTY keyboard is simply too large for many of the smaller electronic devices as the
`keyboard must be large enough to accommodate both hands of the user. Moreover, due the
`large size of the traditional keyboard, it is not sufficiently portable for use in conjunction with
`many of these electronic devices.
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`Previous attempts to overcome this short coming of the keyboard have included the use
`of foldable keyboards as shown in U.S. Pat. No. 6,174,097 and the use of keyboards that allow
`for the direct connection of the electronic device to a full-size portable QWERTY keyboard as
`shown in U.S. Pat. No. 6,108,200. However, neither of these approaches reduces the area
`required for the use of the keyboard.
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`…An additional drawback to the QWERTY keyboard is that it was designed to
`accommodate the mechanical components of the first typewriters, as such, the layout of its keys
`does not facilitate the rapid input of data from the keyboard.
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`…Another drawback to the traditional QWERTY keyboard is that it has typically only
`had a single functionality, namely alphanumeric input. However, with the decrease in size of
`many of electronic devices, additional functions are required from a smaller keyboard that
`current keyboards cannot accommodate.
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`(See Exhibit A, ’963 patent at 1:37 to 2:23.)1
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`23.
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`The Inventor conceived of the inventions claimed in the ’963 patent to address the
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`aforementioned drawbacks of the prior art. As explained in the ’963 patent:
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`The miniaturization of many electronic devices has allowed them to be designed such
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`that they can be operated with only a single hand of the user or has made their use incompatible
`with a full-sized QWERTY keyboard. Because the QWERTY keyboard was developed for
`two-handed use with the original typewriter, it cannot be readily adapted for efficient use by
`only a single hand, or one or both thumbs when used in conjunction with many electronic
`devices.
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`…Previous attempts to increase the speed and efficiency of data input into an electronic
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`device have included the development and use of voice-recognition software. However, the
`error rate typically associated with this type of software has thus far prevented its large-scale
`use as an effective input device.
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`…Previous attempts to overcome shortcomings of the QWERTY keyboard have included the
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`1 Citations to patents in this Complaint refer to columns and lines within columns of any cited
`patent. For example, the citation referenced by this footnote refers to column 1, at line 37
`through column 2, at line 23 in the ’963 patent.
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`Original Complaint for Patent Infringement
`Page 6
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 8 of 12
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`use of alternative keyboards, such as the standard 12-key arrangement found on most telephone
`and cellular phones. A drawback of using the standard telephone as a data-input device is the
`slow rate of input due to use of only a single finger or thumb to activate the keys.
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`(See Exhibit A, ’963 patent at 1:56 to 2:30.)
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`The present invention provides a multifunctional input device. The input device
`includes a functional mode which defines the mode of operation of the input device. Each
`functional mode includes one or more domain levels with each domain level containing one or
`more domain-level values. Each domain level-value within each functional mode is assigned to
`one of a plurality of programmable input keys. The domain-level value assigned to each input
`key controls the function of that input key within a given functionality and domain level. The
`present invention also includes a display to indicate the domain-level value associated with
`each of the programmable input keys within a given functionality.
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`(See Exhibit A, ’963 patent at 2:33-45.)
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`Technological Innovation
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`24.
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`The patented inventions disclosed in the ’963 patent resolve technical problems related
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`to data input devices, and particularly, to problems related to the utilization of small-profile data input
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`devices. As the patent explains, there are several limitations of the prior art as regards full-sized
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`QWERTY keyboards in that:
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`[T]he keyboard must be large enough to accommodate both hands of the user.
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`Moreover, due the large size of the traditional keyboard, it is not sufficiently portable for use in
`conjunction with many of these electronic devices.
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`(’963 patent at 1:40-48.)
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`The miniaturization of many electronic devices has allowed them to be designed such
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`that they can be operated with only a single hand of the user or has made their use incompatible
`with a full-sized QWERTY keyboard.
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`(’963 patent at 1:56-59.)
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`Moreover, the size of the standard QWERTY keyboard, which can have in excess of
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`100 keys, often limits its versatility and utility as an input device.
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`(’963 patent at 1:64-66.)
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`25.
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`The claims of the ’963 patent do not merely recite the performance of some well-known
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`business practice from the pre-Internet world along with the requirement to perform it on the Internet.
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`Instead, the claims of the patent in suit recite inventive concepts that are deeply rooted in computerized
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`data input and data processing. They offer technology that overcomes problems specifically arising
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`Original Complaint for Patent Infringement
`Page 7
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`out of how to maximize efficiency and versatility associated with entering data into a small profile data
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`input device.
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`26.
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`In addition, the claims of the patent in suit recite inventive concepts that improve the
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`functioning of electronic data input devices catalogs, particularly as they recite a combination of
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`controls by which a user can dynamically generate user-specific data input interfaces for the devices.
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`27. Moreover, the claims of the ’963 patent recite inventive concepts that are not merely
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`routine or a conventional use of computer technology or transaction processing. Instead, the patented
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`inventions disclosed in the patent in suit provide a new and novel solution to specific problems related
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`to automating and customizing the process of entering data into small profile input devices by
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`dynamically utilizing user specified control combinations. The claims of the patent in suit thus specify
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`how interfaces for entering user data are manipulated to yield a desired result.
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`28.
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`And finally, the patented inventions disclosed in the patent in suit do not preempt all the
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`ways that user-specific interface selections may be used to improve entering data into small profile
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`input devices, nor does the patent in suit preempt a well-known or prior art technology, such as a
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`standard QWERTY keyboard.
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`29.
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`Accordingly, the claims in the ’963 patent recite a combination of elements sufficient to
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`ensure that the claims, in substance and in practice, amount to significantly more than a patent-
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`ineligible abstract idea.
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`COUNT I - INFRINGEMENT OF U.S. PATENT NO. 6,703,963
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`The allegations set forth in the foregoing paragraphs are incorporated herein by
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`reference.
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`31.
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`On March 9, 2004, the ’963 patent was duly and legally issued by the United States
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`Patent and Trademark Office under the title “Universal Keyboard.”
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`32.
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`Princeps is the assignee and owner of the right, title and interest in and to the ’963
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`patent, including the right to assert all causes of action arising under said patent and the right to any
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`remedies for infringement of it.
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`33.
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`Upon information and belief, Defendants have directly infringed and continue to
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`directly infringe at least claims 1, 2, 3, 9, 12 and 60 of the ’963 patent under 35 U.S.C. § 271(a) by
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`Original Complaint for Patent Infringement
`Page 8
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 10 of 12
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`making, using, selling, offering to sell and/or importing information input devices such as Samsung
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`phones with proprietary Samsung Apps and/or third-party Apps with keyboard functionalities and an
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`operating system such as the Android operating system (the “Accused Instrumentalities”), as set forth
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`in detail in the attached preliminary and exemplary claim charts provided in Exhibits A-1 and A-2.
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`(See Princeps’ Claim Charts for claims 1, 2, 3, 9, 12 and 60 of the ’963 patent, Exhibits A-1 and A-2.)
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`34.
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`The Accused Instrumentalities infringed and continue to infringe claims 1, 2, 3, 9, 12
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`and 60 of the ’963 patent during the pendency of the ’963 patent.
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`35.
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`Samsung was made aware of the ’963 patent and its infringement thereof at least as
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`early as June 24, 2019, when it was served a Complaint based on the ’963 patent in an earlier action
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`brought in another District, Del. C.A. No. 1:19-cv-01103-CFC (see Dkt. No. 8 in that case), dismissed
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`without prejudice.
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`36.
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`Users in California and elsewhere in the United States have used and interacted with
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`Defendants’ systems as recited in claims 1, 2, 3, 9, 12 and 60 of the ’963 patent.
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`37.
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`Upon information and belief, since at least the time of receiving this Complaint,
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`Samsung has induced and continues to induce others to infringe at least claims 1, 2, 3, 9, 12 and 60 of
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`the ’963 patent under 35 U.S.C. § 271(b) by, among other things, and with specific intent or willful
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`blindness, actively aiding and abetting others to infringe, including but not limited to Samsung’s
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`partners and customers, whose use of the Accused Instrumentalities constitutes direct infringement of
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`at least claims 1, 2, 3, 9, 12 and 60 of the ’963 patent.
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`38.
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`Samsung’s actions that aid and abet others such as their partners and customers to
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`infringe include distributing the Accused Instrumentalities and providing instructional materials and/or
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`services related to the Accused Instrumentalities. On information and belief, Samsung has engaged in
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`such actions with specific intent to cause infringement and with willful blindness to the resulting
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`infringement because Samsung has had actual knowledge of the ’963 patent and that its acts were
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`inducing infringement of the ’963 patent since at least June 24, 2019, as referenced above.
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`39.
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`Upon information and belief, Samsung is liable as a contributory infringer to at least
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`claims 1, 2, 3, 9, 12 and 60 of the ’963 patent under 35 U.S.C. § 271(c) by offering to sell, selling and
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`importing into the United States input device technology, such as the Samsung phones with proprietary
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`Original Complaint for Patent Infringement
`Page 9
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 11 of 12
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`Samsung Apps and/or third-party Apps with keyboard functionalities which are especially made or
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`adapted for use in an infringement of the ’963 patent. The Accused Instrumentalities are material
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`components for use in practicing the ’963 patent and are specifically made and are not a staple article
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`of commerce suitable for substantial non-infringing use.
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`40.
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`On information and belief, collective Defendant Samsung is a for-profit organization
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`with revenues of approximately $221 billion U.S.D. per year. Moreover, Defendant Samsung,
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`including their employees and/or agents, make, use, sell, offer to sell, import, provide and cause to be
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`used the Accused Instrumentalities for Defendants’ customers, leading to direct and indirect revenues
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`and profit. As one example of indirect profit, entities such as Defendants will frequently offer the
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`Accused Instrumentalities at reduced pricing as an inducement to attract select categories of customers,
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`such as students, who then purchase additional products or services. On information and belief,
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`without the availability of infringing tools such as the Accused Instrumentalities, Defendants would be
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`at a disadvantage in the marketplace and would generate less revenue overall.
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`41.
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`On information and belief, since at least the time it received notice by the earlier
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`Complaint referenced above, Samsung’s infringement has been and continues to be willful.
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`42.
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`43.
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`Princeps has been harmed by Samsung’s infringing activities.
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`Princeps reserves the right to modify its infringement theories as discovery progresses
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`in this case. It shall not be estopped for purposes of its infringement contentions or its claim
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`constructions by the claim charts it provides with this Complaint. Princeps intends the claim charts
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`(Exhibits A-1 and A-2) for the ’963 patent to satisfy the notice requirements of Rule 8(a)(2) of the
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`Federal Rule of Civil Procedure. The claim charts are not Princeps’s preliminary or final infringement
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`contentions or preliminary or final claim construction positions.
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`44.
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`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, and Rule 3-6 of the Civil
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`JURY DEMAND
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`Local Rules, Plaintiff demands a trial by jury on all issues triable as such.
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`45. WHEREFORE, Plaintiff Princeps demands judgment for itself and against the
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`PRAYER FOR RELIEF
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`Defendants as follows:
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`Original Complaint for Patent Infringement
`Page 10
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`Case 3:20-cv-00201-JSC Document 1 Filed 01/09/20 Page 12 of 12
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`A.
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`B.
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`An adjudication that the Defendants have infringed the ’963 patent;
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`An award of damages to be paid by Defendants adequate to compensate Plaintiff for the
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`Defendants’ past infringement of the ’963 patent, and any continuing or future
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`infringement through the date such judgment is entered, including interest, costs,
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`expenses and an accounting of all infringing acts including, but not limited to, those acts
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`not presented at trial;
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`C.
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`A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of
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`Plaintiff’s reasonable attorneys’ fees; and
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`D.
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`An award to Plaintiff of such further relief at law or in equity as the Court deems just
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`and proper.
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`Dated: January 9, 2020
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`Respectfully submitted,
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`LAW OFFICES OF SETH W. WIENER
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` /s/Seth W. Wiener
`Seth W. Wiener
`California State Bar No. 203747
`609 Karina Court
`San Ramon, California 94582
`Telephone: (925) 487-5607
`Email: seth@sethwienerlaw.com
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`DEVLIN LAW FIRM LLC
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`Timothy Devlin (pro hac vice to be filed)
`Patrick R. Delaney (pro hac vice to be filed)
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`Email:
`tdevlin@devlinlawfirm.com
`pdelaney@devlinlawfirm.com
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`Attorneys for Plaintiff,
`Princeps Secundus LLC
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`Original Complaint for Patent Infringement
`Page 11
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