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`BAKER BOTTS L.L.P.
`Wayne O. Stacy (SBN 314579)
`wayne.stacy@bakerbotts.com
`Sarah Guske (SBN 232467)
`sarah.guske@bakerbotts.com
`Jeremy J. Taylor (SBN 249075)
`jeremy.taylor@bakerbotts.com
`BAKER BOTTS L.L.P.
`101 California Street, Suite 3600
`San Francisco, California 94111
`Telephone: (415) 291-6200
`Facsimile: (415) 291-6300
`Kurt M. Pankratz (pro hac vice)
`kurt.pankratz@bakerbotts.com
`BAKER BOTTS L.L.P.
`2001 Ross Avenue
`Dallas, Texas 75201-2980
`Telephone: (214) 953-6584
`Facsimile: (214) 661-4584
`Jake W. Gallau (SBN 319656)
`jake.gallau@bakerbotts.com
`BAKER BOTTS L.L.P.
`1001 Page Mill Road, Bldg. One, Suite 200
`Palo Alto, California 94304
`Telephone: (650) 739-7500
`Facsimile: (650) 739-7699
`
`Attorneys for Plaintiff
`DROPBOX, INC.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`DROPBOX, INC.,
`Plaintiff,
`
`vs.
`SYNCHRONOSS TECHNOLOGIES, INC.,
`Defendant.
`
`Case No.
`
`PLAINTIFF’S COMPLAINT FOR PATENT
`INFRINGEMENT
`DEMAND FOR JURY TRIAL
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`Plaintiff’s Complaint for Patent Infringement
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
`Plaintiff Dropbox, Inc. (“Dropbox” or “Plaintiff”) files this complaint for patent
`infringement against Defendant Synchronoss Technologies, Inc. (“Synchronoss” or
`“Defendant”) and in support thereof alleges as follows:
`THE PARTIES
`Dropbox, Inc. is a corporation organized under the laws of the State of Delaware,
`1.
`with a principal place of business at 333 Brannan Street, San Francisco, California.
`2.
`On information and belief, Synchronoss Technologies, Inc. is a corporation
`organized under the laws of the State of Delaware, with a principal place of business at 200
`Crossing Boulevard, 8th Floor, Bridgewater, New Jersey.
`JURISDICTION AND VENUE
`This is an action for patent infringement arising under the Patent Laws of the
`3.
`United States of America, Title 35, United States Code.
`4.
`This Court has subject-matter jurisdiction over Dropbox’s claims under 28 U.S.C.
`§§ 1331 and 1338(a).
`5.
`This Court has personal jurisdiction over Synchronoss. Synchronoss has
`continuous and systematic business contact with the State of California and has committed acts
`of patent infringement within the Northern District of California. For example, Synchronoss’s
`offices are located at 60 South Market Street in San Jose, California. In addition, Synchronoss
`regularly conducts business in California and attempts to derive benefit from residents of the
`State of California by offering infringing products, such as the Synchronoss Personal Cloud, in
`the Northern District of California.
`6.
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391 and 1400(b).
`Synchronoss resides in the Northern District of California, and Synchronoss has committed acts
`of infringement in this District and has a regular and established place of business in this
`District. Synchronoss conducts business from its permanent physical location located in the
`Northern District of California at 60 South Market Street, San Jose, California. On information
`and belief, at least 36 employees are employed at this Synchronoss location, including
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`employees responsible for engineering, marketing, customer support, and product development.
`As described herein, Synchronoss offers infringing products, including the Personal Cloud
`product in the Northern District of California.
`THE PATENTS-IN-SUIT
`U.S. Patent No. 7,567,541 (“the ’541 Patent”), titled “System and Method for
`7.
`Personal Data Backup for Mobile Customer Premises Equipment,” was issued by the United
`States Patent and Trademark Office (“USPTO”) on Jul. 28, 2009. Dropbox is the owner by
`assignment of the entire right, title and interest in and to the ’541 Patent, including the sole and
`undivided right to sue for infringement. A true and correct copy of the ’541 Patent is attached
`hereto as Exhibit A.
`8.
`U.S. Patent No. 6,058,399 (“the ’399 Patent”), titled “File Upload
`Synchronization,” was issued by the USPTO on May 2, 2000. Dropbox is the owner by
`assignment of the entire right, title and interest in and to the ’399 Patent, including the sole and
`undivided right to sue for infringement. A true and correct copy of the ’399 Patent is attached
`hereto as Exhibit B.
`9.
`U.S. Patent No. 6,178,505 (“the ’505 Patent”), titled “Secure Delivery of
`Information in a Network,” was issued by the USPTO on Jan. 23, 2001. Dropbox is the owner
`by assignment of the entire right, title and interest in and to the ’505 Patent, including the sole
`and undivided right to sue for infringement. A true and correct copy of the ’505 Patent is
`attached hereto as Exhibit C.
`10.
`The ’541 Patent, ’399 Patent, and ’505 Patent are referred to herein collectively
`as the Patents-in-Suit.
`
`BACKGROUND OF THE DISPUTE
`Dropbox Is a Pioneer in Syncing, Sharing, and Backup of User Data
`Dropbox was founded in June 2007 by Drew Houston and Arash Ferdowsi. It
`11.
`launched in September 2008 as a simple way for people to access their files wherever they are
`and share them easily. The simplicity of the product combined with the reliability of the sync
`led consumers to bring Dropbox to work to empower collaboration. Over 300,000 teams have
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`adopted Dropbox Business, and there are over 500 million registered Dropbox users around the
`world.
`
`Dropbox’s global collaboration platform is a market leader where users create,
`12.
`access, and share content. Underlying Dropbox’s success is its tremendous investment in
`research and development, including in the areas of data backup and transfer. Through these
`efforts, Dropbox has obtained valuable intellectual property in these areas.
`Synchronoss’s Infringing Cloud Products
`Synchronoss was founded in 2000 by Stephen G. Waldis but is a relative
`13.
`newcomer to consumer cloud backup, launching its Personal Cloud product more than a decade
`later.
`
`Synchronoss sells its Personal Cloud product as a white-label data backup and
`14.
`transfer solution to network operators or service providers, such as Verizon.
`15.
`Synchronoss has gained momentum in the marketplace through unlawful use of
`the technology claimed in the Patents-in-Suit.
`16.
`On information and belief, Synchronoss’s Cloud products, including without
`limitation its Personal Cloud product, infringes the Patents-in-Suit, as described in more detail
`below.
`
`PATENT INFRINGEMENT CLAIMS
`Count I – Infringement of U.S. Patent No. 7,567,541
`Dropbox incorporates by reference the allegations in Paragraphs 1 through 16
`
`17.
`
`above.
`
`The ’541 Patent was filed on April 20, 2006 and claims priority to U.S.
`18.
`provisional application No. 60/620,543, filed October 20, 2004.
`19.
`At the time that the ’541 Patent was filed, several technological shortcomings
`existed that made data backup and restoration burdensome for users of mobile customer
`premises equipment (“CPE”) such as cell phones. See Ex. A (’541 Patent) at 1:30–60. Those
`shortcomings stem from the absence of a flexible system for backing up data from one device
`such that it could later be easily transmitted back to the same or another device. Then-existing
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`methods for transferring data included manual entry of each address, contact, calendar event,
`etc., or the transfer of data directly from one device to another using a cradle. Manual entry
`bears the disadvantage of being extremely time intensive. Id. at 1:30–34. A specialized cradle,
`meanwhile, suffers from disadvantages including data backup or transfer only occurring when
`the user has all of the required equipment (a first device, a cradle, and, in the case of transfer, a
`second device) at the same physical location at the same time. Id. at 1:42–48. Additionally, the
`necessary cradles were not widely available, and transfers or backups usually needed to be
`performed in-store by an authorized technician. Id. at 1:49–52. Other general problems, not
`directly associated with manual entry or specialized cradles, also prevented effective data
`backup and transfer, including device incompatibility preventing data transfer and irreparable
`loss of data due to the destruction of a device. Id. at 1:49–56.
`20.
`Recognizing the deficiencies associated with existing approaches to data backup
`and transfer, the ’541 Patent describes specific and discrete implementations to flexibly back up
`data stored on customer premises equipment such as mobile phones. These methods were
`significant improvements over prior approaches to data backup in that they provided improved
`accessibility to users who wanted to backup or transfer data to/from their devices without
`professional support or the need to travel to a store with the necessary specialized cradle.
`Further, these methods and systems include a novel approach to data formatting that allows for
`the transfer of data from a device of one make, model, and ecosystem to another device of a
`different make, model, and ecosystem. See, e.g., id. at 1:56–59. This approach to formatting
`data also allows for the backup or transfer of only certain types of data including only that data
`that has changed since a previous data backup. See, e.g., id. at 2:11–33, 2:60–3:34.
`21.
`The ’541 Patent describes and claims a number of novel and inventive
`approaches to data backup. These inventive approaches are captured in independent Claims 1,
`11, 17, 21, and their respective dependent claims. The claimed approaches are tied to computers
`and cannot be performed by a human alone. Claim 1, for example, recites “[a] method for
`backing up data stored on a mobile customer premises equipment” comprising “storing data at
`the mobile customer premises equipment;” “formatting the data . . . into fields by determining
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`data fields, identifying which portions of said data correspond to a respective data field, and
`tagging said data;” “transmitting the data with a user ID . . . to a server for storage;” “retrieving
`said data . . . in response to one of an expiration of time and request;” and “transmitting the data
`in more than one information signal and sequentially numbering each of said information
`signals.”
`Claim 11 recites “[a] method for backing up data stored on a mobile customer
`22.
`premises equipment” comprising “formatting the data at the mobile customer premises
`equipment into fields;” “transmitting only the changes in data which have occurred since a
`previous transmission;” “transmitting only the changes in the data with a user ID . . . to a server
`for storage, by transmitting the data in more than one information signal across the mobile
`network and sequentially numbering each of said information signals, in response to one of an
`expiration of time, request from said server, and change in status of data at said mobile customer
`premises equipment;” and “said server storing said data for retrieval and transmitting said data
`to the mobile premises equipment.”
`23.
` Claim 17, meanwhile, recites “[a] system for backing up data on a mobile
`customer premises equipment” comprising “a mobile customer premises equipment . . . storing
`data thereon, the data being formatted into fields, and selectively sending a request for the data;”
`and “a server in communication with said mobile customer premises equipment across a mobile
`network and storing said data, said mobile customer premises equipment transmitting the data
`with a user ID to said server in more than one information signal and sequentially numbering
`each of said information signals, said server storing said data for retrieval by determining data
`fields, identifying which portions of said data correspond to a respective data field, and tagging
`said data, said data being retrieved from said server in response to one of an expiration of time
`and requests from said mobile customer premises equipment, said server transmitting said data
`to said mobile customer premises equipment.”
`24.
`Claim 21, meanwhile, recites “[a] system for backing up data on a mobile
`customer premises equipment” comprising “a mobile customer premises equipment storing data
`thereon, the data being formatted into fields, and selectively transmitting said data with a user
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`ID;” and “a server in communication with said mobile customer premises equipment across a
`mobile network and storing said data for retrieval by said mobile customer premises equipment,
`said server storing said data in response to transmission of said data from said mobile customer
`premises equipment, said mobile customer premises equipment transmitting only the changes in
`data which have occurred since a previous transmission to said server in response to one of an
`expiration of time and request from said server by transmitting the change in data in more than
`one information signal across a mobile network, and sequentially numbering each of said
`information signals.”
`25.
`These claim elements, individually or in combination, are unconventional, and
`nothing in the specification describes these concepts as well-understood, routine, or
`conventional. To the contrary, as explained previously, the claimed concepts solve problems of
`the prior art described in the patent and provide advantages and improvements to data backup
`and transfer that was unknown in the field before the invention of the ’541 Patent. See, e.g., Ex.
`A at 1:19–60, 2:11–33, 2:60–3:34. Unlike conventional approaches to data backup and transfer,
`the inventions described and claimed in the ’541 Patent require specific formatting and
`transmission parameters that, when used in combination with other claim elements, improve
`data backup and transfer in unconventional ways. See id. For example, as previously described,
`prior to the invention of the ’541 Patent, existing data backup and transfer methods included
`manual entry of each address, contact, calendar event, etc., or the transfer of data directly from
`one device to another using a cradle. Id. at 1:19–60. The inventions described and claimed in
`the ’541 Patent solved these problems and improved data backup and transfer technology when
`implemented. Id. at 2:11–33, 2:60–3:34.
`26.
`The solutions described and claimed in the ’541 Patent represented a significant
`advance over existing approaches and were not well-known, routine, or conventional in the field
`at the time the application leading to the ’541 Patent was filed. See id. at 1:19–60, 2:11–33,
`2:60–3:34. During examination of the application that ultimately issued as the ’541 Patent, the
`patent examiner at the United States Patent and Trademark Office (“USPTO”) considered
`multiple U.S. patent documents. See Ex. A at Cover Page. These include references describing
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`solutions from Panasonic, Nokia, Sony, and NTT Docomo, amongst others. The patent
`examiner determined that none disclosed or rendered obvious the inventions of the ’541 Patent.
`27.
`Synchronoss directly infringed and continues to directly infringe one or more
`claims of the ’541 Patent, either literally or under the doctrine of equivalents, by making, using,
`offering to sell, and selling the Synchronoss Personal Cloud. Non-limiting examples of such
`infringement are provided below, based on the information currently available to Dropbox.
`28.
`Synchronoss’s Personal Cloud, for example, satisfies each and every limitation of
`Claim 1 of the ’541 Patent.
`29.
`Synchronoss’s Personal Cloud is accessible via a mobile application, a desktop
`application running on a personal computer, and a website accessed using a web browser
`running on a personal computer.
`30.
`Synchronoss’s Personal Cloud performs a method for backing up data stored on a
`mobile customer premises equipment. For example, Synchronoss’s Personal Cloud provides
`Personal Cloud to mobile network providers as a “white-label solution” for syncing, backing up,
`and uploading data (e.g., contacts, photographs, videos, music, documents, messages, and/or call
`history) stored on users mobile phones. See http://synchronoss.com/products/cloud/personal-
`cloud-solution.
`31.
`For example, Synchronoss provides the Synchronoss Personal Cloud product to
`Verizon:
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`Synchronoss Personal Cloud mobile application screenshot.
`32.
`Synchronoss’s Personal Cloud stores data at the mobile customer premises
`equipment. For example, Personal Cloud allows syncing, backing up, and uploading data (e.g.,
`contacts, photographs, videos, music, documents, messages, and/or call history) stored at the
`mobile customer premises equipment. See http://synchronoss.com/products/cloud/personal-
`cloud-solution.
`33.
`Synchronoss’s Personal Cloud formats the data stored at the mobile customer
`premises equipment into fields by determining data fields, identifying which portions of said
`data correspond to a respective data field, and tagging said data. For example, data fields are
`used in the Synchronoss Personal Cloud to categorize uploaded data stored at a mobile phone.
`These data fields may include contacts, photographs, videos, music, documents, messages,
`and/or call history:
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`Synchronoss Personal Cloud mobile application screenshot.
`34.
`As another example, Synchronoss’s Personal Cloud formats the data stored on
`mobile phones into data fields specific to each type of data being backed up. Photograph data,
`for example, includes date, time, and geographic location data fields, and contact data includes
`data fields representing a contact’s first name, last name, email address, physical address, phone
`number, and company.
`35.
`Synchronoss’s Personal Cloud transmits the data with a user ID from the mobile
`customer premises equipment across a mobile network to a server for storage. For example, the
`user phone number or user ID is required to access the Synchronoss Personal Cloud:
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`Synchronoss Personal Cloud mobile application screenshot.
`36.
`Data stored on the Synchronoss Personal Cloud is associated with the user ID or
`phone number used to log into the Synchronoss Personal Cloud, and on information and belief,
`these and/or other identifiers, including IP address, account number, device ID, or session ID,
`are transmitted with the data between the mobile customer premises equipment to a server.
`37.
`Synchronoss’s Personal Cloud retrieves said data from said server across a
`mobile network in response to one of an expiration of time and request from said mobile
`customer premises equipment by transmitting said data to said mobile customer premises
`equipment. For example, Synchronoss’s Personal Cloud allows a user to request and download
`data (e.g., contacts, photographs, videos, music, documents, messages, and/or call history) to a
`mobile phone or other device from the server:
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`Synchronoss Personal Cloud mobile application screenshot.
`38.
`Synchronoss’s Personal Cloud transmits said data to said mobile customer
`premises equipment by transmitting the data in more than one information signal and
`sequentially numbering each of said information signals. For example, sequentially-numbered
`TCP/IP packets are used to transmit data between mobile phones and Synchronoss Personal
`Cloud servers. Wi-Fi and LTE technologies also use sequentially-numbered packets to
`wirelessly transmit data between mobile devices and Synchronoss Personal Cloud servers.
`39.
`Synchronoss has been aware of the ’541 Patent since at least filing and service of
`this complaint.
`40.
`Synchronoss has been aware of Dropbox since at least March 27, 2015 when it
`filed a lawsuit against Dropbox.
`41.
`As will likely be shown after a reasonable opportunity for further investigation or
`discovery, Synchronoss investigated Dropbox’s intellectual property before or during its lawsuit
`against Dropbox.
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`As will likely be shown after a reasonable opportunity for further investigation or
`42.
`discovery, Synchronoss was aware of the ’541 Patent prior to the filing of this complaint.
`43.
`As will likely be shown after a reasonable opportunity for further investigation or
`discovery, Synchronoss’s infringement of the ’541 Patent has been willful and deliberate.
`44.
`As will likely be shown after a reasonable opportunity for further investigation or
`discovery, Synchronoss failed to conduct an investigation after learning of the ’541 Patent.
`45.
`As will likely be shown after a reasonable opportunity for further investigation or
`discovery, Synchronoss failed to take any remedial actions upon learning of the ’541 Patent.
`46.
`Synchronoss also indirectly infringed and continues to indirectly infringe the
`’541 Patent by inducing and contributing to infringement of the ’541 Patent in violation of 35
`U.S.C. § 271(b) and (c).
`47.
`Synchronoss induced and continues to induce its customers and end users to
`infringe the ’541 Patent by making, using, offering to sell, and/or selling the Synchronoss
`Personal Cloud. Synchronoss configures the Personal Cloud to operate in a manner that
`Synchronoss knows infringes the ’541 Patent and encourages customers and end users to use
`Synchronoss’s Personal Cloud in a manner that Synchronoss knows infringes the ’541 Patent.
`For example, Synchronoss’s marketing literature touts functionality of the Synchronoss Personal
`Cloud that falls within the scope of the above-identified claims of the ’541 Patent.
`48.
`Synchronoss contributed to and continues to contribute to the infringement of the
`’541 Patent by selling and offering to sell the Synchronoss Personal Cloud to network operators
`or service providers who incorporate the infringing Synchronoss Personal Cloud into branded
`cloud backup products. As described previously, Synchronoss’s Personal Cloud is especially
`made for infringement of the ’541 Patent. Synchronoss’s Personal Cloud is not a staple article
`or commodity of commerce suitable for substantial non-infringing use. The only use of the
`Synchronoss Personal Cloud results in an act of direct infringement.
`49.
`Dropbox has no adequate remedy at law for Synchronoss’s acts of infringement.
`As a direct and proximate result of Synchronoss’s acts of infringement, Dropbox has suffered
`and continues to suffer damages and irreparable harm. Unless Synchronoss’s acts of willful
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`infringement are enjoined by this Court, Dropbox will continue to be damaged and irreparably
`harmed by Synchronoss’s ongoing willful infringement.
`Count II – Infringement of U.S. Patent No. 6,058,399
`Dropbox incorporates by reference the allegations in Paragraphs 1 through 49
`
`50.
`above.
`The ’399 Patent was filed on August 28, 1997.
`51.
`In the mid-1990s, the options available for transferring data to websites and other
`52.
`service providers were limited. Options that did exist ran independently of a web browser,
`required manual file name input, or provided limited security. Ex. B (’399 Patent) at 1:11–27.
`The available file-upload methods were cumbersome, often requiring substantial computer
`literacy. Id. at 1:34–36.
`53.
`The ’399 Patent identified the need to “provide a method of uploading large
`amounts of data . . . [that was] more user friendly than [the existing methods],” and provided
`specific and discrete implementations for solving these problems. Id. at 1:36–39. In an
`improvement over prior art approaches to uploading data files, the invention described and
`claimed in the ’399 Patent “synchroniz[es] the file upload session and the interactive session.”
`Id. at 2:64–67. By associating the uploaded files with the interactive connection, more efficient
`and user-friendly file uploading can be achieved. See id. at 1:41–54. For example, using the
`claimed invention, “the interactive session can determine which files have been uploaded” and
`enable the cancelling of queued uploads through the interactive session. Id. at 3:1–3. A session
`ID can also be used to “differentiate multiple users and/or multiple sessions from a single user . .
`. [and to] breakdown a single session into a plurality of interactive sessions.” Id. at 3:4–9. All
`these improvements granted greater usability and security to website users. See id. at 1:41–3:47.
`54.
`The ’399 Patent describes and claims a number of novel and inventive
`approaches to data uploading, including synchronizing an interactive connection and a non-
`interactive data transfer connection. These inventive approaches are captured in independent
`Claims 1, 11, 25, 32, 36, 43, 46, and their respective dependent claims. The claimed approaches
`are tied to computers and cannot be performed by a human alone. Claim 1, for example, recites
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`“creating an interactive connection;” “creating a data transfer connection;” and “generating a
`single session ID for the two connections, which ID associates between the two connections.”
`55.
`Claim 11 recites “creating an interactive connection between the client and the
`service provider;” “creating a data transfer connection between the client and the service
`provider;” and “automatically uploading data files from the client to the service provider, on the
`data transfer connection, responsive to the interactive connection.”
`56.
`Claim 25 recites “a file upload connection server,” “an interactive connection
`server,” and “a synchronizer which synchronizes the operation of respective connections formed
`by the file upload connection server and by the interactive connection server.”
`57.
`Claim 32 recites “a file upload connection client,” “an interactive connection
`client,” and “a client synchronizer which synchronizes the operation of respective connections
`formed by the file upload connection client and by the interactive connection client.”
`58.
`Claim 36 recites a “file upload monitor, which monitors the operation of a file
`upload server without direct communication with the file upload server;” “an interactive data
`generator, which generates data in a format suitable for an interactive connection server;” and “a
`synchronizer . . . [that] causes said interactive data generator to generate data responsive to input
`from said file upload monitor and which sends the generated data through the interactive
`connections server.”
`59.
`Claim 43 recites “uploading a list of file information for a plurality of local files
`to a remote server;” “generating a data display at the remote server;” and “locally displaying
`said data display, wherein said data display includes local data not downloaded from the remote
`server, responsive to said local file information.”
`60.
`Claim 46 recites “connecting from said client to said server;” “receiving
`information comprising a username at said client from said server;” and “uploading files from
`said client to said server, utilizing said information.”
`61.
`These claim elements, individually or in combination, are unconventional, and
`nothing in the specification describes these concepts as well-understood, routine, or
`conventional. To the contrary, as explained previously, the claimed concepts solve problems of
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`the prior art described in the patent and provide advantages and improvements to data uploading
`that was unknown in the field before the invention of the ’399 Patent. See, e.g., Ex. B at 1:11–
`3:47. Unlike conventional approaches to data uploading, the inventions described and claimed
`in the ’399 Patent require synchronizing or other means of associating interactive and data
`transfer connections that, when used in combination with other claim elements, improve data
`uploading in unconventional ways. See id. For example, prior to the invention of the ’399
`Patent, existing data uploading methods included FTP file transfer that ran independently from a
`WWW session and had limited security, typing a file name into a java applet which is
`cumbersome because of the manual entry, or emailing files separately from the WWW
`connection. See id. at 1:20–27. The inventions described and claimed in the ’399 Patent solved
`these problems and improved data uploading technology when implemented. See, e.g., id. at
`1:41–3:47.
`The solutions described and claimed in the ’399 Patent represented a significant
`62.
`advance over existing approaches and were not well-known, routine, or conventional in the field
`at the time the application leading to the ’399 Patent was filed. See id. at 1:41–3:47. During
`examination of the application that ultimately issued as the ’399 Patent, the patent examiner at
`the USPTO considered multiple U.S. patent documents. See id. at Cover Page. These include
`references describing solutions from Oracle and ICTV, amongst others. The patent examiner
`determined that none disclosed or rendered obvious the inventions of the ’399 Patent.
`63.
`Synchronoss directly infringed one or more claims of the ’399 Patent, either
`literally or under the doctrine of equivalents, by making, using, offering to sell, and selling the
`Synchronoss Personal Cloud. Non-limiting examples of such infringement are provided below,
`based on the information currently available to Dropbox.
`64.
`Synchronoss’s Personal Cloud product, for example, satisfies each and every
`limitation of Claim 25 of the ’399 Patent.
`65.
`Synchronoss’s Personal Cloud is accessible via a mobile application, a desktop
`application running on a personal computer, and a website accessed using a web browser
`running on a personal computer.
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