throbber
Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 1 of 20 PageID #: 1
`
` 
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Civil Action No. 1:17-cv-753
`
`PATENT CASE
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`
`UNILOC USA, INC. and
`UNILOC LUXEMBOURG, S.A.,
`
`
`
`
`
`
`
`
`Plaintiffs,
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`BLACKBOARD, INC.,
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`Plaintiffs, Uniloc USA, Inc. and Uniloc Luxembourg, S.A. (together “Uniloc”), as and for
`
`their first amended complaint against defendant, Blackboard, Inc. (“Blackboard”), allege as
`
`follows:
`
`THE PARTIES
`
`1.
`
`Uniloc USA, Inc. (“Uniloc USA”) is a Texas corporation having a principal place
`
`of business at Legacy Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024. Uniloc
`
`also maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
`
`2.
`
`Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) is a Luxembourg public limited
`
`liability company having a principal place of business at 15, Rue Edward Steichen, 4th Floor, L-
`
`2540, Luxembourg (R.C.S. Luxembourg B159161).
`
`3.
`
`Uniloc Luxembourg owns a number of patents in the field of application
`
`management in a computer network.
`
`2765551.v1
`
`1
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 2 of 20 PageID #: 2
`
` 
`
`4.
`
`Blackboard is a Delaware corporation and offers its products and services,
`
`including those accused herein of infringement, to customers and/or potential customers located
`
`in Texas and in the judicial Western District of Texas. Blackboard may be served with process
`
`through its registered agent in Texas: CT Corporation System, 1999 Bryan Street, Suite 900,
`
`Dallas, Texas 75201.
`
`JURISDICTION AND VENUE
`
`5.
`
`Uniloc brings this action for patent infringement under the patent laws of the United
`
`States, 35 U.S.C. § 271 et seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§
`
`1331 and 1338(a).
`
`6.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. § 1400(b). Blackboard
`
`has a regular and established place of business at 2000 East 6th Street, Suite 6, Austin, Texas 78702.
`
`7.
`
`Blackboard is subject to this Court’s jurisdiction pursuant to due process and/or the
`
`Texas Long Arm Statute due at least to its substantial business in this State and judicial district,
`
`including: (A) at least part of its past infringing activities, (B) regularly doing or soliciting business
`
`in Austin, Texas and/or (C) engaging in persistent conduct and/or deriving substantial revenue
`
`from goods and services provided to customers in Texas.
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 6,324,578)
`
`Uniloc incorporates paragraphs 1-7 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,324,578
`
`
`
`8.
`
`9.
`
`(“the ’578 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON
`
`A NETWORK that issued on November 27, 2001. A true and correct copy of the ’578 Patent is
`
`attached as Exhibit A hereto.
`
`
`
`2
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 3 of 20 PageID #: 3
`
` 
`
`10.
`
`Uniloc USA is the exclusive licensee of the ’578 Patent with ownership of all
`
`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
`
`sue and recover past damages for the infringement thereof.
`
`11.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`12.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`13.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`3
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 4 of 20 PageID #: 4
`
` 
`
`14.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`15.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`16.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`4
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 5 of 20 PageID #: 5
`
` 
`
`17.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`18.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`19.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`5
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 6 of 20 PageID #: 6
`
` 
`
`20.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`21.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`22.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`6
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 7 of 20 PageID #: 7
`
` 
`
`23.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works
`
`
`
`24.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`7
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 8 of 20 PageID #: 8
`
` 
`
`25.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`26.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`
`
`8
`
`
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 9 of 20 PageID #: 9
`
` 
`
`27.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`28.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`29.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
` 
`
`
`
`
`
`9
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 10 of 20 PageID #: 10
`
` 
`
`30.
`
`Upon information and belief, the following describes, at least in part, how the
`
`Blackboard software distribution and management system works:
`
`
`
`31.
`
`Blackboard has directly infringed, and continues to directly infringe one or more
`
`claims of the ’578 Patent in this judicial district and elsewhere in Texas, including at least claims
`
`1-8, 10-11, 13-39, and 41-46 literally and/or under the doctrine of equivalents, by or through
`
`making, using, importing, offering for sale and/or selling the Blackboard software distribution and
`
`management system during the pendency of the ’578 Patent which software and associated
`
`backend server architecture inter alia allows for installing application programs having a plurality
`
`of configurable preferences and authorized users on a network, distributing an application launcher
`
`program to a user, the user obtaining a set of configurable preferences, obtaining an administrator
`
`set of configurable preferences and executing the application program using the user and
`
`administrator sets of configurable preferences responsive to a request from a user.
`
`32.
`
`In addition, should the Blackboard software distribution and management system
`
`be found to not literally infringe the asserted claims of the ’578 Patent, the Blackboard software
`
`distribution and management system would nevertheless infringe the asserted claims of the ’578
`
`Patent. More specifically, the accused Blackboard software distribution and management system
`
`performs substantially the same function (making computer programs available for digital
`
`
`
`10
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 11 of 20 PageID #: 11
`
` 
`
`download/management by an authorized user), in substantially the same way (via a launcher
`
`program in a client/server environment), to yield substantially the same result (executing the
`
`programs in response to a request from one or more users on a network). Blackboard would thus
`
`be liable for direct infringement under the doctrine of equivalents.
`
`33.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 1-8, 10-11, 13-39, and 41-46 of the ’578 Patent in this judicial district and elsewhere in the
`
`United States by, among other things, actively inducing the using, offering for sale, selling, or
`
`importing the Blackboard software distribution and management system. Blackboard’s customers
`
`who use the Blackboard software distribution and management system in accordance with
`
`Blackboard’s instructions directly infringe one or more of the forgoing claims of the ’578 Patent
`
`in violation of 35 U.S.C. § 271. Blackboard directly and/or indirectly instructs its customers
`
`through training videos, demonstrations, brochures, installation and/or user guides, such as those
`
`located at the following:
`
`•
`
`•
`
`•
`
`www.blackboard.com
`
`https://en-us.help.blackboard.com
`
`www.youtube.com
`
`Blackboard is thereby liable for infringement of the ’578 Patent under 35 U.S.C. § 271(b).
`
`34.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 1-8, 10-11, 13-39, and 41-46 of the ’578 Patent in this judicial district and elsewhere in the
`
`United States by, among other things, contributing to the direct infringement by others including,
`
`without limitation customers using the Blackboard software distribution and management system,
`
`by making, offering to sell, selling and/or importing into the United States, a component of a
`
`patented machine, manufacture or combination, or an apparatus for use in practicing a patented
`
`
`
`11
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 12 of 20 PageID #: 12
`
` 
`
`process, constituting a material part of the invention, knowing the same to be especially made or
`
`especially adapted for use in infringing the ’578 Patent and not a staple article or commodity of
`
`commerce suitable for substantial non-infringing use.
`
`35.
`
`For example, the Blackboard software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Blackboard software distribution and management
`
`system is a material part of the claimed inventions and upon information and belief is not a staple
`
`article or commodity of commerce suitable for substantial non-infringing use. Blackboard is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`36.
`
`Blackboard will have been on notice of the ’578 Patent since, at the latest, the
`
`service of the original complaint filed in the Eastern District of Texas on August 18, 2016. By the
`
`time of trial, Blackboard will have known and intended (since receiving such notice) that its
`
`continued actions would actively induce, and contribute to, the infringement of one or more of
`
`claims 1-8, 10-11, 13-39, and 41-46 of the ’578 Patent.
`
`37.
`
`Blackboard may have infringed the ’578 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional infringing
`
`software.
`
`38.
`
`Uniloc has been damaged, reparably and irreparably, by Blackboard’s infringement
`
`of the ’578 Patent and such damage will continue unless and until Blackboard is enjoined.
`
`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO. 7,069,293)
`
`39.
`
`Uniloc incorporates paragraphs 1-38 above by reference.
`
`12
`
`
`
`
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 13 of 20 PageID #: 13
`
` 
`
`40.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 7,069,293
`
`(“the ’293 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET
`
`STATION ON A NETWORK that issued on June 27, 2006. A true and correct copy of the ’293
`
`Patent is attached as Exhibit B hereto.
`
`41.
`
`Uniloc USA is the exclusive licensee of the ’293 Patent with ownership of all
`
`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
`
`sue and recover past damages for the infringement thereof.
`
`42.
`
`Blackboard has directly infringed, and continues to directly infringe one or more
`
`claims of the ’293 Patent in this judicial district and elsewhere in Texas, including at least claims
`
`1, 12 and 17 literally and/or under the doctrine of equivalents, by or through making, using,
`
`importing, offering for sale and/or selling the Blackboard software distribution and management
`
`system during the pendency of the ’293 Patent which software and associated backend server
`
`architecture inter alia allow for providing an application program for distribution to a network
`
`server, specifying source and target directories for the program to be distributed, preparing a file
`
`packet associated with the program including a segment configured to initiate registration and
`
`distributing the file packet to the target on-demand server to make the program available for use
`
`by a client user.
`
`43.
`
`In addition, should the Blackboard software distribution and management system
`
`be found to not literally infringe the asserted claims of the ’293 Patent, the product would
`
`nevertheless infringe the asserted claims of the ’293 Patent. More specifically, the accused
`
`software/system performs substantially the same function (distributing application programs to a
`
`target on-demand server on a network), in substantially the same way (via a client/server
`
`
`
`13
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 14 of 20 PageID #: 14
`
` 
`
`environment to target on-demand users), to yield substantially the same result (making application
`
`programs available for use by target on-demand users). Blackboard would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`44.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 1, 12 and 17 of the ’293 Patent in this judicial district and elsewhere in the United States
`
`by, among other things, actively inducing the using, offering for sale, selling, or importing the
`
`Blackboard software distribution and management system. Blackboard’s customers who use the
`
`Blackboard software distribution and management system in accordance with Blackboard’s
`
`instructions directly infringe one or more of the forgoing claims of the ’293 Patent in violation of
`
`35 U.S.C. § 271. Blackboard directly and/or indirectly instructs its customers through training
`
`videos, demonstrations, brochures, installation and/or user guides, such as those located at the
`
`following:
`
`•
`
`•
`
`•
`
`www.blackboard.com
`
`https://en-us.help.blackboard.com
`
`www.youtube.com
`
`Blackboard is thereby liable for infringement of the ’293 Patent under 35 U.S.C. § 271(b).
`
`45.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 1, 12 and 17 of the ’293 Patent in this judicial district and elsewhere in the United States
`
`by, among other things, contributing to the direct infringement by others including, without
`
`limitation customers using the Blackboard software distribution and management system, by
`
`making, offering to sell, selling and/or importing into the United States, a component of a patented
`
`machine, manufacture or combination, or an apparatus for use in practicing a patented process,
`
`constituting a material part of the invention, knowing the same to be especially made or especially
`
`
`
`14
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 15 of 20 PageID #: 15
`
` 
`
`adapted for use in infringing the ’293 Patent and not a staple article or commodity of commerce
`
`suitable for substantial non-infringing use.
`
`46.
`
`For example, the Blackboard software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Blackboard software distribution and management
`
`system is a material part of the claimed inventions and upon information and belief is not a staple
`
`article or commodity of commerce suitable for substantial non-infringing use. Blackboard is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`47.
`
`Blackboard will have been on notice of the ’293 Patent since, at the latest, the
`
`service of the original complaint filed in the Eastern District of Texas on August 18, 2016. By the
`
`time of trial, Blackboard will have known and intended (since receiving such notice) that its
`
`continued actions would actively induce, and contribute to, the infringement of one or more of
`
`claims 1, 12 and 17 of the ’293 Patent.
`
`48.
`
`Blackboard may have infringed the ’293 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional infringing
`
`software.
`
`49.
`
`Uniloc has been damaged, reparably and irreparably, by Blackboard’s infringement
`
`of the ’293 Patent and such damage will continue unless and until Blackboard is enjoined.
`
`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO. 6,510,466)
`
`Uniloc incorporates paragraphs 1-49 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,510,466
`
`50.
`
`51.
`
`(“the ’466 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`
`
`15
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 16 of 20 PageID #: 16
`
` 
`
`PRODUCTS FOR CENTRALIZED MANAGEMENT OF APPLICATION PROGRAMS ON A
`
`NETWORK that issued on January 21, 2003. A true and correct copy of the ’466 Patent is attached
`
`as Exhibit C hereto.
`
`52.
`
`Uniloc USA is the exclusive licensee of the ’466 Patent with ownership of all
`
`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
`
`sue and recover past damages for the infringement thereof.
`
`53.
`
`Blackboard has directly infringed, and continues to directly infringe one or more
`
`claims of the ’466 Patent in this judicial district and elsewhere in Texas, including at least claims
`
`15-20, 22-24, 28-33, 35-37, and 41-42 literally and/or under the doctrine of equivalents, by or
`
`through making, using, importing, offering for sale and/or selling the Blackboard software
`
`distribution and management system during the pendency of the ’466 Patent which software and
`
`associated backend server architecture inter alia allow for installing application programs on a
`
`server, receiving a login request, establishing a user desktop, receiving a selection of one or more
`
`programs displayed in the user desktop and providing a program for execution.
`
`54.
`
`In addition, should the Blackboard software distribution and management system
`
`be found to not literally infringe the asserted claims of the ’466 Patent, the Blackboard software
`
`distribution and management system would nevertheless infringe the asserted claims of the ’466
`
`Patent. More specifically, the accused Blackboard software distribution and management system
`
`performs substantially the same function (selection of application programs), in substantially the
`
`same way (via an established user interface), to yield substantially the same result (providing
`
`programs for execution). Blackboard would thus be liable for direct infringement under the
`
`doctrine of equivalents.
`
`
`
`16
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 17 of 20 PageID #: 17
`
` 
`
`55.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 15-20, 22-24, 28-33, 35-37, and 41-42 of the ’466 Patent in this judicial district and
`
`elsewhere in the United States by, among other things, actively inducing the using, offering for
`
`sale, selling, or importing the Blackboard software distribution and management system.
`
`Blackboard’s customers who use the Blackboard software distribution and management system in
`
`accordance with Blackboard’s instructions directly infringe one or more of the forgoing claims of
`
`the ’466 Patent in violation of 35 U.S.C. § 271. Blackboard directly and/or indirectly instructs its
`
`customers through training videos, demonstrations, brochures, installation and/or user guides, such
`
`as those located at the following:
`
`•
`
`•
`
`•
`
`www.blackboard.com
`
`https://en-us.help.blackboard.com
`
`www.youtube.com
`
`Blackboard is thereby liable for infringement of the ’466 Patent under 35 U.S.C. § 271(b).
`
`56.
`
`Blackboard has indirectly infringed and continues to indirectly infringe at least
`
`claims 15-20, 22-24, 28-33, 35-37, and 41-42 of the ’466 Patent in this judicial district and
`
`elsewhere in the United States by, among other things, contributing to the direct infringement by
`
`others including, without limitation customers using the Blackboard software distribution and
`
`management system, by making, offering to sell, selling and/or importing into the United States,
`
`a component of a patented machine, manufacture or combination, or an apparatus for use in
`
`practicing a patented process, constituting a material part of the invention, knowing the same to be
`
`especially made or especially adapted for use in infringing the ’466 Patent and not a staple article
`
`or commodity of commerce suitable for substantial non-infringing use.
`
`
`
`17
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 18 of 20 PageID #: 18
`
` 
`
`57.
`
`For example, the Blackboard software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Blackboard software distribution and management
`
`system is a material part of the claimed inventions and upon information and belief is not a staple
`
`article or commodity of commerce suitable for substantial non-infringing use. Blackboard is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`58.
`
`Blackboard will have been on notice of the ’466 Patent since, at the latest, the
`
`service of the original complaint filed in the Eastern District of Texas on August 18, 2016. By the
`
`time of trial, Blackboard will have known and intended (since receiving such notice) that its
`
`continued actions would actively induce, and contribute to, the infringement of one or more of
`
`claims 15-20, 22-24, 28-33, 35-37, and 41-42 of the ’466 Patent.
`
`59.
`
`Blackboard may have infringed the ’466 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional infringing
`
`software.
`
`60.
`
`Uniloc has been damaged, reparably and irreparably, by Blackboard’s infringement
`
`of the ’466 Patent and such damage will continue unless and until Blackboard is enjoined.
`
`PRAYER FOR RELIEF
`
`
`
`
`
`
`
`Uniloc requests that the Court enter judgment against Blackboard as follows:
`
`(A)
`
`(B)
`
`that Blackboard has infringed the ’578 Patent, the ’293 Patent and the ’466 Patent;
`
`awarding Uniloc its damages suffered as a result of Blackboard’s infringement of
`
`the ’578 Patent, the ’293 Patent and the ’466 Patent;
`
`
`
`18
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 19 of 20 PageID #: 19
`
` 
`
`
`
`(C)
`
`enjoining Blackboard, its officers, directors, agents, servants, affiliates, employees,
`
`divisions, branches, subsidiaries and parents, and all others acting in concert or privity with it from
`
`infringing the ’578 Patent, the ’293 Patent and the ’466 Patent;
`
`awarding Uniloc its costs, attorneys’ fees, expenses and interest, and
`
`granting Uniloc such other and further relief as the Court may deem just and
`
`
`
`
`
`(D)
`
`(E)
`
`proper.
`
`DEMAND FOR JURY TRIAL
`
`
`
`Uniloc hereby demands trial by jury on all issues so triable pursuant to Fed. R. Civ. P. 38.
`
`
`Date: August 11, 2017
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Brent N. Bumgardner
`Paul J. Hayes (Lead Attorney) (Pro Hac to Follow)
`Massachusetts State Bar No. 227000
`Kevin Gannon (Pro Hac to Follow)
`Massachusetts State Bar No. 640931
`Dean G. Bostock (Pro Hac to Follow)
`Massachusetts State Bar No. 549747
`Aaron Jacobs (Pro Hac to Follow)
`Massachusetts State Bar No. 677545
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`Email: phayes@princelobel.com
`Email: kgannon@princelobel.com
`Email: dbostock@princelobel.com
`Email: ajacobs@princelobel.com
`
`Brent N. Bumgardner
`Texas State Bar No. 00795272
`brent@nelbum.com
`Christopher G. Granaghan
`Texas State Bar No. 24078585
`chris@nelbum.com
`NELSON BUMGARDNER PC
`3131 West 7th Street, Suite 300
`Fort Worth, TX 76107
`Tel: (817) 377-9111
`
`
`
`19
`
`

`

`Case 1:20-cv-00665-CFC Document 1 Filed 08/11/17 Page 20 of 20 PageID #: 20
`
`Fax: (817) 377-3485
`
`
`
`
`
`ATTORNEYS FOR THE PLAINTIFFS
`
`20
`
` 
`
`
`
`
`
`

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