throbber
Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 1 of 10
`
`VENABLE LLP
`Frank C. Cimino, Jr. (pro hac vice)
`FCCimino@venable.com
`Megan S. Woodworth (pro hac vice)
`MSWoodworth@venable.com
`Charles J. Monterio, Jr. (pro hac vice)
`CJMonterio@venable.com
`600 Massachusetts Ave., NW
`Washington, D.C. 20001
`Telephone: (202) 344-4000
`Facsimile: (202) 344-8300
`
`William A. Hector (SBN 298490)
`wahector@venable.com
`101 California Street, Suite 3800
`San Francisco, CA 94111
`Telephone: (415) 653-3750
`Facsimile: (415) 653-3755
`
`Attorneys for Plaintiff
`Viavi Solutions Inc.
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`VIAVI SOLUTIONS INC.,
`
`Case No. 3:19-cv-07578
`
`Plaintiff,
`
`v.
`
`OPTRONTEC INC., LG INNOTEK CO.,
`LTD., LG ELECTRONICS, INC., and LG
`ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`COMPLAINT
`
`DEMAND FOR JURY TRIAL
`
`COMPLAINT
`
`Plaintiff Viavi Solutions Inc. (“Viavi”) hereby makes this complaint against
`
`Defendants Optrontec Inc. (“Optrontec”), LG Innotek Co., Ltd. (“LG Innotek”), LG
`
`Electronics, Inc. (“LG Electronics”), and LG Electronics U.S.A., Inc. (“LG Electronics USA”)
`
`(LG Innotek, LG Electronics and LG Electronics USA will collectively be referred to as the
`
`“LG Defendants” and all defendants will be referred to as “Defendants”) as follows:
`
`CASE NO. 3:19-cv-07578
`
`-1-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`101 CALIFORNIA STREET, SUITE 3800
`
`VENABLE LLP
`
`SAN FRANCISCO, CA94111
`
`415.653.3750
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 2 of 10
`
`NATURE OF ACTION
`
`1.
`
`This is a patent infringement action. Viavi seeks damages and injunctive relief
`
`for Defendants’ infringement of Viavi’s patented technology in the United States.
`
`INTRADISTRICT ASSIGNMENT
`
`2.
`
`This is an Intellectual Property action and shall be assigned on a district-wide
`
`basis pursuant to Civil L.R. 3-2(c) and this Court’s Assignment Plan.
`
`FACTUAL BACKGROUND
`
`3.
`
`Viavi, formerly part of JDS Uniphase Corporation, is a pioneer and world leader
`
`in the fields of three-dimensional (3D) motion sensing technology, light management, and
`
`optical coatings, among others.
`
`4.
`
`The inventions disclosed in U.S. Patent Nos. 9,588,269 (“the ’269 patent”),
`
`9,945,995 (“the ’995 patent”), and 10,222,526 (“the ’526 patent”) (collectively “the Asserted
`
`Patents”) (Exhibits 1-3) and exemplified in Viavi’s state-of the art optical filters are indicative of
`
`Viavi’s status as a world leader in 3D motion sensing technology.
`
`5.
`
`In a typical gesture-recognition system, a light source emits near-infrared light
`
`towards a user. An optical filter is used to transmit the emitted light that is reflected by the user
`
`to the 3D image sensor, while substantially blocking ambient light. A 3D image sensor then
`
`detects the emitted light to provide a 3D image of the user. A processing system then analyzes
`
`the 3D image to recognize a gesture made by the user.
`
`6.
`
`The inventors of the Asserted Patents conceived of a superior optical filter for
`
`such a use. The patented filter design provides a deep suppression of unwanted ambient light, so
`
`that the filters can be used under a wide variety of extreme light conditions. The patented filter
`
`design uses hydrogenated silicon material (which has a relatively high refractive index over the
`
`near-infrared wavelength range) to achieve superior optical performance, a desired reduction in
`
`filter thickness, and a reduced center wavelength shift with a change in incidence angle. Viavi
`
`has invested years of research and development into its 3D motion sensing technology, and has
`
`been awarded several related patents, including the Asserted Patents, for its efforts.
`
`CASE NO. 3:19-cv-07578
`
`-2-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 3 of 10
`
`7.
`
`As described in the Asserted Patents, Viavi’s filter design offers improvements
`
`over those previously known in the art. For example, it uses less layers, has thinner coatings and
`
`therefore costs less to produce and is smaller in size than prior filters. In addition, the reduction
`
`in center wavelength shift helps to reduce light transmission outside of the filter’s designed
`
`passband, thereby increasing signal to noise ratios allowing for better system performance.
`
`8.
`
`Based on these inventions, Viavi was the first company to offer a commercial
`
`optical filter using hydrogenated silicon for 3D motion sensing. Viavi has enjoyed significant
`
`commercial success with its patented filter design, and that success is reflective of the electronic
`
`consumer product industry recognizing and replicating features of Viavi’s patented technology.
`
`In fact, Viavi’s innovative optical filters won the 2017 Fierce Innovation Award for the Telecom
`
`category, which seeks to recognize “groundbreaking solutions” and “the most evolutionary and
`
`revolutionary technologies” in the industry. Exhibit 4. Through multiple generations of
`
`increasing performance and decreasing cost, Viavi has remained the industry’s leading supplier
`
`of high-performance filters for motion sensing systems in consumer electronics.
`
`9.
`
`Mobile device manufacturers like LG Electronics, and its suppliers including LG
`
`Innotek and Optrontec, have incorporated Viavi’s patented filter design into their optical filters
`
`to produce high-end mobile phones featuring facial and gesture recognition technology.
`
`LG DEFENDANTS’ INFRINGING PRODUCTS
`
`10.
`
` On information and belief, LG Electronics and LG Electronics USA makes, uses,
`
`offers for sale, sells, and imports into the United States, mobile phones such as at least the LG
`
`G8 ThinQ mobile phone with 3D motion sensing and gesture recognition modules that include
`
`the patented technology.
`
`11.
`
`On information and belief, LG Electronics’ G8 ThinQ mobile phone contains 3D
`
`camera modules made by LG Innotek, which include optical filters supplied by Optrontec.
`
`12.
`
`LG Innotek has publicly referred to its 3D application in its 3D module as “Time
`
`of Flight” or “ToF,” and has publicly stated that LG Electronics’ G8ThinQ mobile phone would
`
`house its ToF 3D module to implement gesture recognition technology. Exhibit 5.
`
`CASE NO. 3:19-cv-07578
`
`-3-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 4 of 10
`
`OPTRONTEC’S INFRINGING OPTICAL FILTER
`
`13.
`
`On information and belief, LG Innotek sources the optical filters for its 3D
`
`module from Optrontec. Exhibit 6. Optrontec itself has publicly stated it is “the only producer
`
`of bandpass filters for 3D sensing using the ToF method” and it “has the only 3D sensing filter
`
`production technology in Korea,” where LG Electronics’ G8 ThinQ mobile phone and its
`
`components are manufactured. Exhibits 7, 8, and 9. According to Optrontec, its “camera image
`
`sensor filter (IR filter) and optical lenses are sold to global smartphone manufacturers such as
`
`Samsung Electronics and LG Electronics” (Exhibit 7), and it is the “exclusive supplier of the
`
`optical filter to Samsung and LG Electronics.” Exhibit 6.
`
`14.
`
`On information and belief, Defendants knew or were willfully blind to the
`
`Asserted Patents and of the infringing nature of the Optrontec filters discussed in more detail
`
`below, in view of the ongoing litigation between Viavi and Optrontec concerning infringement
`
`of foreign counterparts to the Asserted Patents in the Republic of Korea (Case No. 2019 KaHap
`
`514417).
`
`PARTIES
`
`15.
`
`Viavi is a Delaware corporation with its principal place of business and
`
`headquarters in this District at 6001 America Center Drive, Sixth Floor, San Jose, California
`
`95002. Viavi also maintains its state-of-the-art research and development facility and a major
`
`production facility in this District in Santa Rosa, California.
`
`16.
`
`On information and belief, Optrontec is a company organized under the laws of
`
`the Republic of Korea, with its principal place of business and headquarters located at 19-15
`
`Pyeongsan-ro 8beon-gil, Uichang-gu, Changwon, Gyeongnam, 51398, Republic of Korea.
`
`17.
`
`On information and belief, LG Electronics is a Korean corporation with its
`
`principal place of business and headquarters located at LG Electronics Twin Towers, 128 Yeoui-
`
`daero, Yeongdeungpo-gu, Seoul 07336, Republic of Korea.
`
`18.
`
`On information and belief, LG Electronics USA, which is a wholly owned
`
`subsidiary of LG Electronics, is a Delaware corporation with its principal place of business and
`
`headquarters located at 1000 Sylvan Avenue, Englewood Cliffs, NJ 07632. LG Electronics USA
`
`CASE NO. 3:19-cv-07578
`
`-4-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 5 of 10
`
`is in the business of, among other things, marketing mobile phones including the LG G8 ThinQ
`
`mobile phones in the United States, and providing sales and marketing support for those phones
`
`in the United States on behalf of LG Electronics. To aid with its mission, LG Electronics USA
`
`operates the LG Silicon Valley Lab in this District, which according to LG Electronics USA is
`
`focused on LG Electronics’ next generation of consumer electronic products. Exhibit 10.
`
`19.
`
`On information and belief, LG Innotek is a Korean corporation with its principal
`
`place of business and headquarters located at 17F, LG Seoulstation Bldg., 98 Huam-ro, Jung-gu,
`
`Seoul, 04637 Republic of Korea. On information and belief, LG Electronics is the parent and
`
`majority shareholder of LG Innotek.
`
`JURISDICTION AND VENUE
`
`20.
`
`This action arises under the United States Patent Act, codified at 35 U.S.C. § 1 et
`
`seq., and in particular, 35 U.S.C. §§ 271 and 281-285.
`
`21.
`
`This Court has original jurisdiction over the subject matter of this action under 28
`
`U.S.C. §§ 1331 and 1338(a) because the claims arise under the patent laws of the United States.
`
`22.
`
`This Court has personal jurisdiction over LG Electronics USA because it has the
`
`minimum contacts with this District such that the exercise of jurisdiction over them would not
`
`offend traditional notions of fair play and substantial justice. LG Electronics USA is present
`
`within California and this District, conducts regular and systematic business in California and
`
`this District, has purposefully availed itself of the privileges of conducting business in California
`
`and this District, has transacted and continues to transact business in this District, has committed
`
`acts of infringement in this District, continues to commit acts of infringement in this District, and
`
`Viavi’s cause of action arises directly from LG Electronics USA’s contacts and activities in
`
`California and this District.
`
`23.
`
`Venue is proper for LG Electronics USA under 28 U.S.C. §§ 1391(b), 1391(c),
`
`and 1400(b) because LG Electronics USA has a regular and established place of business in this
`
`District. It also has transacted and continues to transact business in this District, advertise and
`
`solicit business in this District, and has committed and continues to commit acts of infringement
`
`in this District.
`
`CASE NO. 3:19-cv-07578
`
`-5-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 6 of 10
`
`24.
`
`This Court has personal jurisdiction over Optrontec, LG Innotek, and LG
`
`Electronics because they deliver goods (e.g., the optical filters, camera modules and mobile
`
`phones) into the stream of commerce with the expectation that those goods will be offered for
`
`sale and sold in the United States generally and in California and this District specifically. In
`
`other words, Optrontec sold its optical filter to LG Innotek with the expectation that LG Innotek
`
`would combine it into LG Innotek’s 3D module, which would then be incorporated by LG
`
`Electronics into the LG G8 ThinQ mobile phone with the expectation and knowledge – by all of
`
`the foreign Defendants – that the mobile phone would be offered for sale and sold in the United
`
`States generally and in California and this District specifically. By knowingly putting the mobile
`
`phone into the stream of commerce in this District, Optrontec, LG Innotek, and LG Electronics
`
`have purposefully availed themselves of the privileges of conducting business in the United
`
`States, California and this District, and sought the protection and benefits from the laws of the
`
`United States and California and thus have subjected themselves to personal jurisdiction here.
`
`25.
`
`This Court also has personal jurisdiction over LG Electronics because it operates
`
`in concert and exercises such control over the activities of LG Electronics USA that LG
`
`Electronics has purposefully availed itself to California and this District through acting as LG
`
`Electronics USA’s alter ego, who is subject to personal jurisdiction in this District.
`
`26.
`
`This Court has venue over Optrontec, LG Innotek, and LG Electronics under 28
`
`U.S.C. § 1391 because, among other reasons, Optrontec, LG Innotek, and LG Electronics are
`
`foreign corporations that do not reside in the United States and therefore may be sued in any
`
`United States judicial district, including this District.
`
`FIRST CLAIM FOR RELIEF
`
`(Infringement of U.S. Patent No. 9,588,269)
`
`27.
`
`Viavi incorporates by reference the allegations contained in paragraphs 1 through
`
`26 above.
`
`28.
`
`The ’269 patent entitled “Optical Filter and Sensor System” issued on March 7,
`
`2017. A copy of the ’269 patent is attached as Exhibit 1. Viavi is the assignee of all rights, titles
`
`CASE NO. 3:19-cv-07578
`
`-6-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 7 of 10
`
`and interests in and to the ’269 patent, and holds the right to sue and recover for past, present and
`
`future infringement thereof.
`
`29.
`
`On information and belief, in the United States and this District, at least one or
`
`more of the LG Defendants have directly infringed, and continue to directly infringe, by making,
`
`using, selling, offering for sale and/or importing into the United States products that infringe at
`
`least one claim of the ’269 patent, e.g., claim 1, including without limitation, its LG G8 ThinQ
`
`mobile phone. The LG Defendants are liable for their infringement of the ’269 patent in
`
`violation of 35 U.S.C. § 271(a).
`
`30.
`
`On information and belief, Defendants are further liable for actively inducing
`
`infringement of the ’269 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
`
`steps to encourage and facilitate direct infringement by others, including the one or more LG
`
`Defendants and its customers that directly infringe the ’269 patent.
`
`31.
`
`Viavi has been damaged by Defendants’ infringement, and will continue to be
`
`damaged by Defendants’ infringement, of the ’269 patent, and thus is entitled to recover
`
`damages from Defendants to compensate it for the infringement.
`
`32.
`
`Viavi is entitled to damages adequate to compensate it for the infringement but in
`
`no event less than a reasonable royalty.
`
`33.
`
`Defendants intend to continue their unlawful infringing activity, and Viavi
`
`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
`
`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
`
`infringing activities.
`
`34.
`
`Defendants’ past infringement and/or continuing infringement has been deliberate
`
`and willful.
`
`SECOND CLAIM FOR RELIEF
`
`(Infringement of U.S. Patent No. 9,945,995)
`
`35.
`
`Viavi incorporates by reference the allegations contained in paragraphs 1 through
`
`34 above.
`
`CASE NO. 3:19-cv-07578
`
`-7-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 8 of 10
`
`36.
`
`The ’995 patent entitled “Optical Filter and Sensor System” issued on April 17,
`
`2018. A copy of the ’995 patent is attached as Exhibit 2. Viavi is the assignee of all rights, titles
`
`and interests in and to the ’995 patent, and holds the right to sue and recover for past, present and
`
`future infringement thereof.
`
`37.
`
`On information and belief, at least one or more of the LG Defendants in violation
`
`of 35 U.S.C. § 271(g) are and have been directly infringing the ’995 patent by importing into the
`
`United States or offering to sell, selling or using within the United States products which are
`
`made by a process claimed in at least one claim of the ’995 patent, e.g., claim 1, in the United
`
`States, including without limitation, the LG G8 ThinQ mobile phone.
`
`38.
`
`On information and belief, Defendants are liable for actively inducing
`
`infringement of the ’995 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
`
`steps to encourage and facilitate direct infringement by others, including the one or more LG
`
`Defendants that directly infringe the ’995 patent.
`
`39.
`
`Viavi has been damaged by Defendants’ infringement, and will continue to be
`
`damaged by Defendants’ infringement, of the ’995 patent, and thus is entitled to recover
`
`damages from Defendants to compensate it for the infringement.
`
`40.
`
`Viavi is entitled to damages adequate to compensate it for the infringement but in
`
`no event less than a reasonable royalty.
`
`41.
`
`Defendants intend to continue their unlawful infringing activity, and Viavi
`
`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
`
`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
`
`infringing activities.
`
`42.
`
`Defendants’ past infringement and/or continuing infringement has been deliberate
`
`and willful.
`
`THIRD CLAIM FOR RELIEF
`
`(Infringement of U.S. Patent No. 10,222,526)
`
`43.
`
`Viavi incorporates by reference the allegations contained in paragraphs 1 through
`
`42 above.
`
`CASE NO. 3:19-cv-07578
`
`-8-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 9 of 10
`
`44.
`
`The ’526 patent entitled “Optical Filter and Sensor System” issued on March 5,
`
`2019. A copy of the ’526 patent is attached as Exhibit 3. Viavi is the assignee of all rights, titles
`
`and interests in and to the ’526 patent, and holds the right to sue and recover for past, present and
`
`future infringement thereof.
`
`45.
`
`On information and belief, in the United States and this District, at least one or
`
`more of the LG Defendants have directly infringed, and continue to directly infringe, by making,
`
`using, selling, offering for sale and/or importing into the United States products that infringe at
`
`least one claim of the ’526 patent, e.g., claim 27, including without limitation, its LG G8 ThinQ
`
`mobile phone. The LG Defendants are liable for their infringement of the ’526 patent in
`
`violation of 35 U.S.C. § 271(a).
`
`46.
`
`On information and belief, Defendants are further liable for actively inducing
`
`infringement of the ’526 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
`
`steps to encourage and facilitate direct infringement by others, including the one or more LG
`
`Defendants and its customers that directly infringe the ’526 patent.
`
`47.
`
`Viavi has been damaged by Defendants’ infringement, and will continue to be
`
`damaged by Defendants’ infringement, of the ’526 patent, and thus is entitled to recover
`
`damages from Defendants to compensate it for the infringement.
`
`48.
`
`Viavi is entitled to damages adequate to compensate it for the infringement but in
`
`no event less than a reasonable royalty.
`
`49.
`
`Defendants intend to continue their unlawful infringing activity, and Viavi
`
`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
`
`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
`
`infringing activities.
`
`50.
`
`Defendants’ past infringement and/or continuing infringement has been deliberate
`
`and willful.
`
`JURY DEMAND
`
`51.
`
`Pursuant to Fed. R. Civ. P. Rule 38(b), Viavi hereby demands a trial by jury on all
`
`issues and claims so triable.
`
`CASE NO. 3:19-cv-07578
`
`-9-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 10 of 10
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Viavi respectfully prays for the following relief:
`
`1.
`
`Pursuant to 35 U.S.C. § 271, a Judgement that Defendants infringe and have
`
`infringed at least one claim of the ’269 patent, at least one claim of the ’995 patent, and/or at
`
`least one claim of the ’526 patent;
`
`2.
`
`Pursuant to 35 U.S.C. § 283, a permanent injunction prohibiting Defendants from
`
`further acts of infringement of the ’269 patent, the ’995 patent, and the ’526 patent;
`
`3.
`
`Pursuant to 35 U.S.C. § 284, compensatory damages, past and future, amounting
`
`to no less than reasonable royalties, prejudgment interest, and/or any other available damages
`
`based on any form of recoverable economic injury sustained by Viavi as a result of Defendants’
`
`infringement;
`
`4.
`
`Pursuant to 35 U.S.C. § 285, an award of any other supplemental damages
`
`including Viavi’s costs and attorneys’ fees incurred in this action; and
`
`5.
`
`For such other relief as this Court deems just and proper.
`
`Dated: November 18, 2019
`
`VENABLE LLP
`
`By:
`
`/s/ William A. Hector
`Frank C. Cimino, Jr. (pro hac vice)
`FCCimino@venable.com
`Megan S. Woodworth (pro hac vice)
`MSWoodworth@venable.com
`Charles J. Monterio, Jr. (pro hac vice)
`CJMonterio@venable.com
`VENABLE LLP
`600 Massachusetts Avenue, NW
`Washington, D.C. 20001
`Telephone: (202) 344-4569
`Facsimile: (202) 344-8300
`
`William A. Hector
`WAHector@venable.com
`101 California Street, Suite 3800
`San Francisco, CA 94111
`Telephone: (415) 653-3738
`Facsimile: (415) 653-3755
`
`Attorneys for Viavi Solutions Inc.
`
`CASE NO. 3:19-cv-07578
`
`-10-
`
`COMPLAINT
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket