Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 1 of 12
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`Bruce L. Campbell, P.C., OSB No. 925377
`bruce.campbell@millernash.com
`MILLER NASH GRAHAM & DUNN LLP
`3400 U.S. Bancorp Tower
`111 S.W. Fifth Avenue
`Portland, Oregon 97204
`Telephone: 503.224.5858
`Facsimile: 503.224.0155
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`Attorneys for Plaintiffs
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`UNITED STATES DISTRICT COURT
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`DISTRICT OF OREGON
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`Portland Division
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`CV No. _______________
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`COMPLAINT FOR PATENT INFRINGEMENT
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`DEMAND FOR JURY TRIAL
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`SAWSTOP, LLC, an Oregon limited
`liability company, and SD3, LLC, an
`Oregon limited liability company,
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`Plaintiffs,
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`v.
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`ROBERT BOSCH TOOL
`CORPORATION, a Delaware
`corporation, and ROBERT BOSCH
`GMBH, a German company,
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`Defendants.
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`Plaintiffs SawStop, LLC ("SawStop") and SD3, LLC ("SD3") (collectively, "Plaintiffs"),
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`bring this Complaint for patent infringement against Defendants Robert Bosch Tool Corporation
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`Page 1 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 1
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`

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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 2 of 12
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`("Bosch Tool") and Robert Bosch GmbH ("Bosch GmbH") (collectively, "Defendants"), and
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`allege as follows:
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`PARTIES
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`1.
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`Plaintiff SawStop is a limited liability company organized and existing
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`under the laws of Oregon. SawStop has a principal place of business at 9564 SW Tualatin Road,
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`Tualatin, Oregon.
`2.
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`Plaintiff SD3 is a limited liability company organized and existing under
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`the laws of Oregon. SD3 has a principal place of business at 9564 SW Tualatin Road, Tualatin,
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`Oregon.
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`3.
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`On information and belief, Defendant Bosch Tool is a Delaware
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`corporation with a principal place of business at 1800 West Central Road, Mount Prospect,
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`Illinois, 60056.
`4.
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`On information and belief, Defendant Bosch GmbH is a company
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`organized under the laws of Germany with a principal place of business at Robert-Bosch-Platz 1,
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`70839 Gerlingen-Schillerhöhe, Baden-Wuerttemberg, Germany.
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`JURISDICTION AND VENUE
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`5.
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`This is an action for patent infringement under 35 U.S.C. §§ 271 and 281.
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`The Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`6.
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`The Court has personal jurisdiction over the Defendants under
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`ORCP 4 A(4), 4 C and 4 D(1) and (2), among other provisions. On information and belief,
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`Defendants have engaged in substantial, continuous, and systematic business within this District.
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`On information and belief, Defendants regularly and deliberately engage in activities that result
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`in using, selling, offering for sale, or importing alleged infringing products in or into this
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`District. On information and belief, Defendants and their retailers maintain Internet websites
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`available to consumers nationwide, including within this District, on which alleged infringing
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`products are advertised and offered for sale in and shipping to this District. On information and
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`Page 2 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 2
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 3 of 12
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`belief, Defendants maintain sales and distribution operations in this District and have marketed
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`and offered for sale alleged infringing products through these operations.
`7.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 (b) & (c) and
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`1400(b).
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`BACKGROUND
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`8.
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`In August 2000, Dr. Stephen F. Gass and his colleagues formed SawStop
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`to develop and commercialize safety systems for woodworking machines such as table saws.
`9.
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`The safety systems that Dr. Gass and his colleagues developed are able to
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`detect contact between a saw blade and an operator of the saw, and react to mitigate injury to the
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`operator from the saw blade.
`10.
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`In August 2000, Dr. Gass and his colleagues formed SD3 to own
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`intellectual property associated with the safety systems they had developed.
`11.
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`Since late 2004, SawStop has sold woodworking machines equipped with
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`these safety systems.
`12.
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`On information and belief, in March 2015, Defendants announced the
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`impending release of the Bosch GTS1041A REAXX, a bench top table saw equipped with a
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`system that detects contact between a saw blade and an operator of the saw and retracts the saw
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`blade in response to detected contact.
`13.
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`On information and belief, Defendants have shown and demonstrated the
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`Bosch GTS1041A REAXX at trade shows in the United States.
`14.
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`On information and belief, Defendants have offered for sale the Bosch
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`GTS1041A REAXX throughout the United States, including in this District.
`15.
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`On information and belief, Defendants have marketed the Bosch
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`GTS1041A REAXX throughout the United States, including in this District.
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`Page 3 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 3
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 4 of 12
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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 7,225,712
`16.
`paragraphs as though fully set forth herein.
`17.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`On June 5, 2007, the United States Patent & Trademark Office duly issued
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`U.S. Patent No. 7,225,712 (the '712 Patent), titled "Motion Detecting System for Use in A Safety
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`System for Power Equipment." A true and correct copy of the '712 Patent is attached as Exhibit
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`A.
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '712 Patent.
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`Plaintiff SawStop is the sole licensee of the '712 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`18.
`19.
`20.
`the '712 Patent pursuant to 35 U.S.C. § 287.
`21.
`United States Patent or Patents.
`22.
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`Defendants have cited the '712 Patent during prosecution of their own
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`On information and belief, Defendants have been on notice of the '712
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`Patent, including by way of Plaintiff SawStop's marking of its products and Defendants' citation
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`of the '712 Patent during prosecution of their own United States Patent or Patents.
`23.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '712 Patent by
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`practicing one or more claims of the '712 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
`24.
`suffered and will continue to suffer damages and irreparable harm.
`25.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`As a result of Defendants' infringement of the '712 Patent, Plaintiffs have
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`sustained as a result of Defendants' infringement of the '712 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`Page 4 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 4
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 5 of 12
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`26.
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`Having been on notice of the '712 Patent, Defendants' infringement of the
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`'712 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`27.
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`Unless Defendants are enjoined from continuing their infringement of the
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`'712 Patent, Plaintiffs will suffer additional irreparable harm, and are therefore entitled to a
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`permanent injunction against further infringement.
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`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 7,600,455
`28.
`paragraphs as though fully set forth herein.
`29.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`On October 13, 2009, the United States Patent & Trademark Office duly
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`issued U.S. Patent No. 7,600,455 (the '455 Patent), titled "Logic Control for Fast-Acting Safety
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '455 Patent.
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`Plaintiff SawStop is the sole licensee of the '455 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`System." A true and correct copy of the '455 Patent is attached as Exhibit B.
`30.
`31.
`32.
`the '455 Patent pursuant to 35 U.S.C. § 287.
`33.
`United States Patent or Patents.
`34.
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`Defendants have cited the '455 Patent during prosecution of their own
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`On information and belief, Defendants have been on notice of the '455
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`Patent, including by way of Plaintiff SawStop's marking of its products and Defendants' citation
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`of the '455 Patent during prosecution of their own United States Patent or Patents.
`35.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '455 Patent by
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`practicing one or more claims of the '455 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
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`Page 5 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
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`SD3 Exhibit 2002 – Page 5
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 6 of 12
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`As a result of Defendants' infringement of the '455 Patent, Plaintiffs have
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`36.
`suffered and will continue to suffer damages and irreparable harm.
`37.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`sustained as a result of Defendants' infringement of the '455 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`38.
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`Having been on notice of the '455 Patent, Defendants' infringement of the
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`'455 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`39.
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`Unless Defendants are enjoined from continuing their infringement of the
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`'455 Patent, Plaintiffs will suffer additional irreparable harm, and are therefore entitled to a
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`permanent injunction against further infringement.
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`COUNT III: INFRINGEMENT OF U.S. PATENT NO. 7,610,836
`40.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`paragraphs as though fully set forth herein.
`41.
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`On November 3, 2009, the United States Patent & Trademark Office duly
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`issued U.S. Patent No. 7,610,836 (the '836 Patent), titled "Replaceable Brake Mechanism for
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '836 Patent.
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`Power Equipment." A true and correct copy of the '836 Patent is attached as Exhibit C.
`42.
`43.
`44.
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`Plaintiff SawStop is the sole licensee of the '836 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`the '836 Patent pursuant to 35 U.S.C. § 287.
`45.
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`On information and belief, Defendants have been on notice of the '836
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`Patent, including by way of Plaintiff SawStop's marking of its products.
`46.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '836 Patent by
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`Page 6 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 6
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 7 of 12
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`practicing one or more claims of the '836 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
`47.
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`As a result of Defendants' infringement of the '836 Patent, Plaintiffs have
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`suffered and will continue to suffer damages and irreparable harm.
`48.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`sustained as a result of Defendants' infringement of the '836 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`49.
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`Having been on notice of the '836 Patent, Defendants' infringement of the
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`'836 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`50.
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`Unless Defendants are enjoined from continuing their infringement of the
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`'836 Patent, Plaintiffs will suffer additional irreparable harm, and are therefore entitled to a
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`permanent injunction against further infringement.
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`COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 7,895,927
`51.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`paragraphs as though fully set forth herein.
`52.
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`On March 1, 2011, the United States Patent & Trademark Office duly
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`issued U.S. Patent No. 7,895,927 (the '927 Patent), titled "Power Equipment with Detection and
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '927 Patent.
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`Reaction Systems." A true and correct copy of the '927 Patent is attached as Exhibit D.
`53.
`54.
`55.
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`Plaintiff SawStop is the sole licensee of the '927 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`the '927 Patent pursuant to 35 U.S.C. § 287.
`56.
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`Defendants have cited the '927 Patent during prosecution of their own
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`United States Patent or Patents.
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`Page 7 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 7
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 8 of 12
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`57.
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`On information and belief, Defendants have been on notice of the '927
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`Patent, including by way of Plaintiff SawStop's marking of its products and Defendants' citation
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`of the '927 Patent during prosecution of their own United States Patent or Patents.
`58.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '927 Patent by
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`practicing one or more claims of the '927 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
`59.
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`Defendants have actively induced, and are continuing to actively induce
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`infringement of the '927 Patent, by causing others to act in a manner that directly infringes one or
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`more claims of the '927 Patent, knowing that these acts would lead to infringement.
`60.
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`As a result of Defendants' infringement of the '927 Patent, Plaintiffs have
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`suffered and will continue to suffer damages and irreparable harm.
`61.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`sustained as a result of Defendants' infringement of the '927 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`62.
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`Having been on notice of the '927 Patent, Defendants' infringement of the
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`'927 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`63.
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`Unless Defendants are enjoined from continuing their infringement of the
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`'927 Patent, Plaintiffs will suffer additional irreparable harm, and are therefore entitled to a
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`permanent injunction against further infringement.
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`COUNT V: INFRINGEMENT OF U.S. PATENT NO. 8,011,279
`64.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`paragraphs as though fully set forth herein.
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`Page 8 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 8
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 9 of 12
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`65.
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`On September 6, 2011, the United States Patent & Trademark Office duly
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`issued U.S. Patent No. 8,011,279 (the '279 Patent), titled "Power Equipment with Systems to
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '279 Patent.
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`Mitigate or Prevent Injury." A true and correct copy of the '279 Patent is attached as Exhibit E.
`66.
`67.
`68.
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`Plaintiff SawStop is the sole licensee of the '279 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`the '279 Patent pursuant to 35 U.S.C. § 287.
`69.
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`On information and belief, Defendants have been on notice of the '279
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`Patent, including by way of Plaintiff SawStop's marking of its products.
`70.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '279 Patent by
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`practicing one or more claims of the '279 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
`71.
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`As a result of Defendants' infringement of the '279 Patent, Plaintiffs have
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`suffered and will continue to suffer damages and irreparable harm.
`72.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`sustained as a result of Defendants' infringement of the '279 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`73.
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`Having been on notice of the '279 Patent, Defendants' infringement of the
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`'279 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`74.
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`Unless Defendants are enjoined from continuing their infringement of the
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`'279 Patent, Plaintiffs will suffer additional irreparable harm, and are therefore entitled to a
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`permanent injunction against further infringement.
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`Page 9 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 9
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 10 of 12
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`COUNT VI: INFRINGEMENT OF U.S. PATENT NO. 8,191,450
`75.
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`Plaintiffs repeat and re-allege each and every allegation of the foregoing
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`paragraphs as though fully set forth herein.
`76.
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`On June 5, 2012, the United States Patent & Trademark Office duly issued
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`U.S. Patent No. 8,191,450 (the '450 Patent), titled "Power Equipment with Detection and
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`Plaintiff SD3 is the owner of all rights, title, and interest in the '450 Patent.
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`Reaction Systems." A true and correct copy of the '450 Patent is attached as Exhibit F.
`77.
`78.
`79.
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`Plaintiff SawStop is the sole licensee of the '450 Patent.
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`Plaintiff SawStop marks, and has continuously marked, its products with
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`the '450 Patent pursuant to 35 U.S.C. § 287.
`80.
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`Defendants have cited the '450 Patent during prosecution of their own
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`United States Patent or Patents.
`81.
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`On information and belief, Defendants have been on notice of the '450
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`Patent, including by way of Plaintiff SawStop's marking of its products and Defendants' citation
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`of the '450 Patent during prosecution of their own United States Patent or Patents.
`82.
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`In violation of 35 U.S.C. § 271, Defendants have infringed, and are
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`continuing to infringe literally and/or under the doctrine of equivalents, the '450 Patent by
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`practicing one or more claims of the '450 Patent in the manufacture, use, offer for sale, sale, or
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`importation of products including, but not limited to, the Bosch GTS1041A REAXX saw.
`83.
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`As a result of Defendants' infringement of the '450 Patent, Plaintiffs have
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`suffered and will continue to suffer damages and irreparable harm.
`84.
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`Plaintiffs are entitled to recover from Defendants the damages they have
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`sustained as a result of Defendants' infringement of the '450 Patent in an amount subject to proof
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`at trial, but in no event less than a reasonable royalty, together with interest and costs as fixed by
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`the Court.
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`Page 10 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 10
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 11 of 12
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`85.
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`Having been on notice of the '450 Patent, Defendants' infringement of the
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`'450 Patent was and continues to be willful, and therefore warrants an increase of damages
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`pursuant to 35 U.S.C. § 284 and an award of attorney fees pursuant to 35 U.S.C. § 285.
`86.
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`Unless Defendants are enjoined by this Court from continuing their
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`infringement of the '450 Patent, Plaintiffs will suffer additional irreparable harm, and are
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`therefore entitled to a permanent injunction against further infringement.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs pray for judgment as follows:
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`A.
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`An entry of judgment that Defendants infringe the '712, '455, '836, '927, '279, and
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`'450 Patents under 35 U.S.C. § 271;
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`B.
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`An entry of judgment that Defendants willfully infringe the '712, '455, '836, '927,
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`'279, and '450 Patents;
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`C.
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`An award of damages adequate to compensate Plaintiffs for Defendants'
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`infringement, in an amount no less than a reasonable royalty, together with interest and costs as
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`fixed by the Court pursuant to 35 U.S.C. § 284.
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`D.
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`Enhancement of the award of damages pursuant to 35 U.S.C. § 284, based on
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`Defendants' willful infringement;
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`E.
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`F.
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`An award of attorney fees pursuant to 35 U.S.C § 285;
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`A permanent injunction against further infringement of the '712, '455, '836, '927,
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`'279, and '450 Patents by Defendants and all persons in active concert or participation with
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`Defendants pursuant to 35 U.S.C. § 283; and
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`G.
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`Such other and further relief as the Court or a jury may deem just and proper.
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`Page 11 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 11
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`Case 3:15-cv-01320-HZ Document 1 Filed 07/16/15 Page 12 of 12
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`DEMAND FOR JURY TRIAL
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`Pursuant to Fed. R. Civ. P. 38(b), Plaintiffs respectfully request a trial by jury of all
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`issues so triable.
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`DATED this 16th day of July, 2015.
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`MILLER NASH GRAHAM & DUNN LLP
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`s/ Bruce L. Campbell
`Bruce L. Campbell, P.C.
`OSB No. 925377
`bruce.campbell@millernash.com
`Phone: 503.224.5858
`Fax: 503.224.0155
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`Attorneys for Plaintiff
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`Page 12 - Complaint for Patent Infringement
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`70038593.1
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`MILLER NASH GRAHAM & DUNN LLP
`ATTORNEYS AT LAW
`TELEPHONE: 503.224.5858
`3400 U.S. BANCORP TOWER
`111 S.W. FIFTH AVENUE
`PORTLAND, OREGON 97204
`
`SD3 Exhibit 2002 – Page 12