Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 1 of 14 PageID #: 1
`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 1 of 14 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT _
`FOR THE DISTRICT OF DELAWARE
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`CA. No.
`
`v.
`
`JURY TRIAL DEMANDED
`
`.
`LG ELECTRONICS, INC., LG ELECTRONICS
`USA, INC, LG ELECTONRICS MOBILECOMM :
`U.S.A., }NC.,
`
`Defendants.
`
`comm
`
`Plaintiff Arendi S.A.R.L.
`
`(“Arendi”) for its Complaint against Defendants hereby
`
`demands a jury trial and alleges as follows:
`
`Related Actions
`
`1.
`This case is related to two cases previously consolidated before Judge Stark, 09-
`cv—OOI 19 (D. Del.) (LPS) and 11—cv-00260 (D. Del.) (LPS), both of which settled after extensive
`
`dispositive motion practice. This case is also related to the other actions filed simultaneously by
`
`Arendi today, which involve the same patents—in-suit and common facts.
`
`The Parties and Accused Products
`
`2.
`
`Plaintiff Arendi is a corporation organized under the laws of Luxembourg with its
`
`principal place of business in Luxembourg.
`
`3.
`
`On information and belief, Defendant LG Electronics, Inc. (“LG Electronics”) is a
`
`Korean corporation “with a principal piace of business at LG Twin Towers 20, Yeouido-dong,
`
`Yeongdeunspo-gu, Seoul 150—721, South Korea.
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 2 of 14 PageID #: 2
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`4.
`
`On information and belief, Defendant LG Electronics USA, Inc. (“LG Mobile”) is
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`a wholly owned subsidiary of LG Electronics, Inc. and is a Delaware corporation with its
`
`principal place of business at 1000 Sylvan Avenue, Englewood Cliffs, New Jersey 07632. LG
`
`Mobile’s registered agent for service of process is United States Corporation Company, 2711
`
`Centerville Road, Suite 400, Wilmington, Delaware 19808.
`
`5.
`
`On information and belief, Defendant LG Electronics MobileCornm U.S.A., Inc.
`
`(“LG MobileComm”) is a wholly owned subsidiary of LG Electronics. LG MobileComm is a
`
`California corporation with its principal place of business at 920 Sylvan Avenue, Englewood
`
`Cliffs, New Jersey 07632. LG MobileCornm’s registered agent for service of process in
`
`California is Alan K. Tse, 10101 Old Grove Road, San Diego, California 92131. LG
`
`Mobilecornm’s registered agent for service of process is National Registered Agents, Inc. of
`
`New Jersey, 100 Canal Pointe Blvd, Suite 212, Princeton, New Jersey 08540. Defendants LG
`
`Electronics, LG Mobile, and LG Mobilecornm are collectively referred to herein as “LG.”
`
`6.
`
`7 LG transacts substantial business, either directly or through its agents, on an
`
`ongoing basis in this judicial district and elsewhere in the United States.
`
`7.
`
`LG makes, uses,
`
`imports, offers to sell, and sells (and/or has made, used,
`
`imported, offered to sell, and sold) in the United States and in this judicial district, the LG
`
`Optimus (P769) (Model LG Optimus G) and other mobile phones, smartphones, and tablet
`
`devices containing the same or similar information handling technology disclosed in the asserted
`
`patents described herein (collectively, the “Accused Products”).
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 3 of 14 PageID #: 3
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`MM
`
`8.
`
`This is a civil action for infringement of United States Patents No. 7,917,843 (the
`
`“‘843 Patent”), No. 7,496,854 (the “‘854 Patent”), and No. 8,306,993 (the “‘993 Patent”). This
`
`action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.
`
`Jurisdiction and Venue
`
`9.
`
`This Court has jurisdiction over the subject matter of this action pursuant to 28
`
`U.S.C. §§ 1331 and 1338(a).
`
`10.
`
`Personal jurisdiction is proper in this district because, among other reasons, LG
`
`has a continuous presence in this District, LG committed acts of infringement in this District and
`
`a substantial part of the events or omissions giving rise to this claim occurred in this District. LG
`
`placed, and continues to place, Accused Products into the stream of commerce, through an
`
`established distribution channel, with the knowledge and/or understanding that such products are
`
`used and sold in this District. This causes injury to Arendi in this District. On information and
`
`belief, Defendants derive substantial revenue from the sale of Accused Products distributed
`
`within the District, and derive substantial revenue fiom interstate and international commerce.
`
`11.
`
`Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b) and (c), and
`
`1400(b), because LG committed acts of infringement in this district and a substantial part of the
`
`events or omissions giving rise to this claim occurred in this District.
`
`The Patents-In-Suit
`
`12.
`
`United States Patent No. 7,917,843, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legaiiy
`
`issued on March 29, 2011, by the United States Patent and Trademark Office. A copy of the ‘843
`
`Patent is attached hereto as Exhibit A.
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 4 of 14 PageID #: 4
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`13.
`
`United States Patent 'No. 7,496,854, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legally
`
`issued on February 24, 2009, by the United States Patent and Trademark Office. A copy of the
`
`‘854 Patent is attached hereto as Exhibit B.
`
`14.
`
`United States Patent No. 8,306,993, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from an Operating System,” was duly and legally
`
`issued on November 6, 2012n1 by the United States Patent and Trademark Office. A copy of the
`
`‘993 Patent is attached hereto as Exhibit C.
`
`15.
`
`Arendi is the exclusive owner of all rights, title, and interest in the ‘843 Patent,
`
`‘854 Patent, and ‘993 Patent, including the right to bring this suit for injunctive relief and
`
`damages.
`
`16.
`
`The ‘843 Patent, ‘854 Patent, and ‘993 Patent are valid and enforceable.
`
`BACKGROUND
`
`17.
`
`Arendi filed suit in this District against Microsoft Corporation and Dell Inc. for
`
`infringement of the ‘854 Patent on February 24, 2009. 09—cv-00119 (D. Del.) (LPS). The case
`
`was assigned to the Honorable Leonard P. Stark, who held two Markman Hearings, on February
`
`25, 2011 and November 21, 2011, and denied several summary judgment motions. The case was
`
`resolved by settlement and dismissed on November 29, 2011.
`
`18.
`
`Arendi filed suit in this District against Microsoft Corporation for infringement of
`
`the ‘843 Patent on March 29, 2011. 11—cv—00260 '(D. Del.) (LPS). The case was assigned to the
`
`Honorable Leonard P. Stark, who consolidated the il—cv—260 case with the above-referenced
`
`case on May 10, 2011. After Judge Stark held a Markman Hearing on November 21, 2011, this
`
`case was also resolved by settlement and dismissed on November 29, 201 1.
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 5 of 14 PageID #: 5
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`COUNT I
`
`(Infringement of United States Patent No. 7,917,843)
`
`19.
`
`20.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`LG has infringed and continues to infringe the ‘843 patent under 35 U.S.C. § 271,
`
`including but not limited to claims 1 and 23, literally or under the doctrine of equivalents, by
`
`making, using, selling, and/or offering for sale in the United States, and/or importing into the
`
`United States, Accused Products, Without authorization. On information and belief, LG has also
`
`infringed and continues to infringe at least claims 2, 8, 13, 14, 15, 16, 17, 20, 21, 23, 24, 30, 35,
`36, 37, 38, 39, 42, 43 ofthe ‘843 patent under 35 U.S.C. § 271, literally or under the doctrine of
`
`equivalents, by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization.
`
`21.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants” wrongful acts in an
`
`amount subject to proof at trial. LG’s infringement of Arendi’s exclusive rights under the ‘843
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infiingement is enjoined by this Court.
`
`22.
`
`In addition to the foregoing and/or in the alternative, third parties, including LG’S
`
`customers, have infringed, and continue to infringe, one or more claims of the ‘843 patent under
`
`35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products.
`
`23.
`
`LG has had knowledge of and notice of the “843 patent and its infringement at
`
`least since the filing of this complaint.
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 6 of 14 PageID #: 6
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`24.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is inducing infringement of one or more claims of the ‘843 patent
`
`under 35 U.S.C. § 271(b), including on information and belief at least the claims set forth above.
`
`LG is actively, knowingly, and intentionally inducing infringement of the ‘843 patent by
`
`practicing the methods set forth therein and by selling, offering to sell and/or importing into the
`United States the Accused Products after the filing of this complaint; with the knowledge and
`
`specific intent that third parties, including its customers, will continue to — either alone or in
`
`combination with LG — practice the patented methods, and use, sell, offer for sale, and/or import
`
`the Accused Products supplied by LG to infiinge the ‘843 patent; and with the knowledge and
`
`specific intent to encourage and facilitate the infringement through the dissemination of the
`
`Accused Products and/or the creation and dissemination of promotional and marketing materials,
`
`supporting materials, instructions, product manuals, and/or technical information relating to the
`
`Accused Products and infiinging uses thereof.
`
`25.
`
`LG’s acts of induced infiingement have caused damage to Arendi and Arendi is
`
`entitled to recover from LG the damages it has sustained as a result of Defendants’ wrongful acts
`
`in an amount subject to proof at trial. LG’s induced infringement of Arendi’s exclusive rights
`
`under the ‘843 patent have damaged, and continue to damage, Arendi, causing irreparable harm
`
`for which there is no adequate remedy at law, unless the infiingement is enjoined by this Court.
`
`26.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint, LG has knowingly contributed to the infiingernent of one or more claims of the
`
`‘843 patent under 35 use. § 271(0).
`
`27.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is contributing to the infringement of one or more claims of the “843
`
`patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at least the
`6
`
`

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`claims set forth above. LG is actively, knowingly, and intentionally contributing to the
`
`infringement of the ‘843 patent by selling, offering to sell and/or importing into the United States
`
`Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed 'or adapted to operate in a manner that infringes the “843 Patent;
`
`with the knowledge that third parties, including its customers, will continue to ._ either alone or in
`
`combination with LG — practice the patented methods; and with the knowledge that the infringing
`
`information handling technology in the Accused Products is not a staple article of commerce suitable
`
`for substantial noninfringing use.
`
`28.
`
`LG’s acts of contributory infi'ingernent have caused damage to Arendi and Arendi
`
`is entitled to recover from LG the damages it has sustained as a result of Defendants’ wrongful
`
`acts in an amount subject to proof at trial. LG’s contributory infringement of Arendi’s exclusive
`
`rights under the ‘843 patent have damaged, and continue to damage, Arendi, causing irreparable
`
`harm for which there is no adequate remedy at law, unless the infringement is enjoined by this
`
`Court.
`
`29.
`
`30-.
`
`COUNT II
`
`(Infringement of United States Patent No. 7,496,854)
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`LG has infringed and continues to infringe the ‘854 Patent under 35 U.S.C. § 271,
`
`including but not limited to claims 57, 73, and 79, literally or under the doctrine of equivalents,
`
`by making, using, selling, and/or offering for sale in the United States, and/or importing into the
`
`United States, Accused Products, without authcrizaticn. On information and belief, LG has also
`
`infi'inged and continues to infringe at least claims 19, 20, 22, 23, 24, 25, 26, 28, 29, 30, 31, 32,
`
`34, 35, 60, 61, 62, 63, 64, 65, 72, 76, 77, 78, 82, 83, and 84 ofthe ‘854 patent under 35 U.S.C. §
`
`271, literally or under the doctrine of equivalents, by making, using, selling, and/or offering for
`
`7
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 8 of 14 PageID #: 8
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`sale in the United States, and/or importing into the United States, Accused Products, Without
`
`authorization
`
`31.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover fi'om LG the damages it has sustained as a result of Defendants” wrongful acts in an
`
`amount subject to proof at trial. LG’s infringement of Arendi’s exclusive rights under the ‘854
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infringement is enjoined by this Court.
`
`32.
`
`In addition to the foregoing and/or in the alternative, third parties, including LG’s
`
`customers, have infringed, and continue to infringe, one or more claims of the ‘854 patent under
`
`35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products.
`
`33.
`
`LG has had knowledge of and notice of the ‘854 patent and its infringement at
`
`least since the filing of this complaint.
`
`34.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is inducing infringement of one or more claims of the ‘854 patent
`
`under 35 U.S.C. § 271, including on information and belief at least the claims set forth above.
`
`LG is actively, knowingly, and intentionally inducing infiingernent of the ‘854 patent by
`
`practicing the methods set forth therein and by selling, offering to sell and/or importing into the
`
`United States Accused Products after the filing of this complaint; with the knowledge and
`
`specific intent that third parties, including its customers, will continue to — either alone or in
`
`combination with LG — practice the patented methods, and use, sell, offer for sale, and/or import
`
`the Accused Products supplied by LG to infringe the ‘854 patent; and with the knowledge and
`
`specific intent to encourage and facilitate the infringement through the dissemination of the
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 - Filed 11/29/12 Page 9 of 14 PageID #: 9
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`Accused Products and/or the creation and dissemination of promotional and marketing materials,
`
`supporting materials, instructions, product manuals, and/or technical information relating to the
`
`Accused Products and infiinging uses thereof.
`
`35.
`
`LG’s acts ofinfringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants’ wrongful acts in an
`
`amount subject to proof at trial. LG’s infringement of Arendi’s exclusive rights under the ‘854
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infringement is enjoined by this Court.
`
`36.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this Complaint, LG has knowingiy contributed to the infringement of one or more claims of the
`
`‘854 patent under 35 U.S.C. § 271(0).
`
`37.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is contributing to the infringement of one or more claims of the ‘854
`
`patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at least the
`
`claims set forth above.
`
`LG is actively, knowingly, and intentionally contributing to the
`
`infringement of the ‘854 patent by selling, offering to sell and/or importing into the United States
`
`Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘854 Patent;
`
`with the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with LG ~— practice the patented methods; and with the knowledge that the infringing
`
`information handling technology in the Accused Products is not a stapie article of commerce suitable
`
`for substantial noninfi'inging use.
`
`38.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants’ wrongful acts in an
`
`9
`
`

`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 10 of 14 PageID #: 10
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`amount subject to proof at trial LG’s infringement of Arendi’s exclusive rights under the “854
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infringement is enjoined by this Court.
`
`COUNT III
`
`(Infringement of United States Patent No. 8,306,993)
`
`39.
`
`40.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`LG has infringed and continues to infringe the ‘993 Patent under 35 U.S.C. § 271,
`
`including but not limited to claims 1, 9 and 17, literally or under the doctrine of equivalents, by
`
`making, using, selling, and/0r offering for sale in the United States, and/or importing into the
`
`United States, Accused Products, without authorization. On information and belief, LG has also
`
`infringed and continues to infringe at least claims 2, 4, 5, 6, 7, 8, 10, 12, 13, 14, 15, 16, 18, 20,
`
`21, 24, 22, and 23 of the ‘993 patent under 35 U.S.C. § 271, literally or under the doctrine of
`
`equivalents, by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization.
`
`41.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants’ wrongful acts in an
`
`amount subject to proof at trial. LG’s infringement of Arendi’s exclusive rights under the ‘993
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infiingement is enjoined by this Court.
`
`42.
`
`In addition to the foregoing and/or in the alternative, third parties, including LG’s
`
`customers, have infringed, and continue to infringe, one or more claims of the “993 patent under
`
`35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products.
`
`10
`
`

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`43.
`
`LG has had knowledge of and notice of the ‘993 patent and its infringement at
`
`least since the filing of this complaint.
`
`44.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is inducing infringement of one or more claims of the ‘993 patent
`
`under 35 U.S.C. § 271, including on information and belief at least the claims set forth above.
`
`LG is actively, knowingly, and intentionally inducing infringement of the ‘993 patent by
`
`practicing the methods set forth therein and by selling, offering to sell and/or importing into the
`
`United States Accused Products after the filing of this complaint; with the knowledge and
`
`specific intent that third parties, including its customers, Will continue to — either alone or in
`
`combination with LG — practice the patented methods, and use, sell, offer for sale, and/or import
`
`the Accused Products supplied by LG to infringe the ‘993 patent; and with the knowledge and
`
`specific intent to encourage and facilitate the infringement through the dissemination of the
`
`Accused Products and/or the creation and dissemination of promotional and marketing materials,
`
`supporting materials, instructions, product manuals, and/or technical information relating to the
`
`Accused Products and infringing uses thereof.
`
`45.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants’ wrongfiil acts in an
`
`amount subject to proof at trial. LG’s infringement of Arendi’s exclusive rights under the ‘993
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infringement is enjoined by this Court.
`
`46.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint LG has knowingly contributed to the infringement of one or more claims of the
`
`993 patent under 35 U.S.C. § 271(c).
`
`11
`
`

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`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 12 of 14 PageID #: 12
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`47.
`
`To the extent LG continues to sell or otherwise supply Accused Products after the
`
`filing of this complaint, LG is contributing to the infringement of one or more claims of the ‘993
`
`patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at least the
`
`claims set forth above.
`
`LG is actively, knowingly, and intentionally contributing to the
`
`infringement of the ‘993 patent by selling, offering to sell and/or importing into the United States
`
`Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the “993 Patent;
`
`with the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with LG — practice the patented methods; and with the knowledge that the infringing
`
`information handling technology in the Accused Products is not a staple article of commerce suitable
`
`for substantial noninfiinging use.
`
`48.
`
`LG’s acts of infringement have caused damage to Arendi and Arendi is entitled to
`
`recover from LG the damages it has sustained as a result of Defendants" wrongful acts in an
`
`amount subject to proof at trial. LG’S infringement of Arendi’s exclusive rights under the ‘993
`
`patent have damaged, and continue to damage, Arendi, causing irreparable harm for which there
`
`is no adequate remedy at law, unless the infringement is enjoined by this Court.
`
`Prayer for Relief
`
`WHEREFORE, Arendi prays for judgment as follows:
`
`A.
`
`B.
`
`Declaring that LG has infringed the ‘843, ‘854 and ‘993 Patents;
`
`Awardin the damages arising out of LG’s infiingement of the ‘843, ‘854, and
`
`‘993 Patents, including enhanced damages pursuant to 35 U.S.C. § 284, to Arendi, together with
`
`prejudgment and post-judgment interest, in an amount according to proof;
`
`l2
`
`

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`C.
`
`Permanently enjoining LG, its officers, agents, and employees, and those persons
`
`in active concert or participation with any of them, and its successors and assigns, fiom
`
`infringement, inducement of infringement, and contributory infringement of the ‘843, ‘854 and
`
`‘993 Patents, including but not limited to making, using, selling, and/or offering for sale within
`
`the United States, and/or importing in the United States, any devices, products, software, or
`
`methods that infringe the ‘843, ‘854 and ‘993 Patents before the expiration of these patents;
`
`D,
`
`Awarding attorney’s fees to Arendi pursuant to 35 U.S.C. § 285 or as otherwise
`
`permitted by law;
`
`E.
`
`Awarding such other costs and further relief as the Court may deem just and
`
`proper.
`
`JURY DEMAND
`
`Arendi hereby demands a trial by jury on all issues so triable.
`
`PROCTOR HEYMAN LLP
`
`/S/Neal C. Belgam
`Neal C. Belgam (# 2721)
`E—mail: nbelgam@proctorheyman.com
`Melissa N. Donimirski (# 4701)
`E—mail: mdonimirski@proctorheyman.com
`Dawn Kurtz Crompton (# 5579)
`E—mail: dcrompton@proctorheyman.com
`300 Delaware Avenue, Suite 200
`Wilmington, DE 19801
`(302) 472-7300
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`13
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`

`

`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 14 of 14 PageID #: 14
`Case 1:12-cv-01595-LPS Document 1 Filed 11/29/12 Page 14 of 14 PageID #: 14
`
`OF COUNSEL:
`
`SUSMAN GODFREY, L.L.P‘
`
`Stephen D. Susman
`E—mafl: ssusman@susmangodfiey.com
`Seth D. Al’d
`
`E—mail: sard@susmangodfiey.com
`560 Lexington Avenue, 15tll Floor
`New York, NY 10022
`
`(212) 336-8330
`
`SUSMAN GODFREY, L.L.P.
`
`Harry P. Susman
`E—mafl: hsusman@susmangodfiey. com
`Lexie G. White
`
`E—mail: lwhite@susmangodfi‘ey.com
`1000 Louisanna Street, Suite 5100
`
`Houston, TX 77002
`212-651—9366
`
`Dated: November 29, 2012
`
`14
`
`