Case 1:15-cv-01307-VJW Document 1 Filed 11/02/15 Page 1 of 14
`#9998-3048805
`
`ORIGINAL
`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
`
`CELLCAST TECHNOLOGIES, LLC and
`ENVISIONIT, LLC,
`
`Plaintiffs,
`
`
`
`v.
`
`THE UNITED STATES OF AMERICA,
`
`Defendant.
`
`15-1307 C
`Case No. ________
`
`FILED
`NOV 2 2015
`U.S. COURT OF
`FEDERAL CLAIMS
`
`COMPLAINT
`
`Plaintiffs CellCast Technologies, LLC (“CellCast”) and EnvisionIT, LLC (“EnvisionIT”)
`
`(collectively, CellCast and EnvisionIT referred to as “Plaintiffs”) by their undersigned attorney,
`
`bring this action against Defendant United States of America, and for their complaint allege as
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`follows:
`
`NATURE OF ACTION
`
`1.
`
`This is an action to recover reasonable and entire compensation for the unlicensed
`
`use and manufacture by and for the United States of inventions described in and covered by U.S.
`
`patents 7,693,938; 8,103,719; 8,438,221; 8,438,212; and 9,136,954.
`
`2.
`
`This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1491(a) and
`
`JURISDICTION
`
`1498(a).
`
`PARTIES
`
`3.
`
`Plaintiff CellCast is a limited liability company organized and existing pursuant to
`
`the laws of Delaware.
`
`4.
`
`Plaintiff EnvisionIT limited liability company organized and existing pursuant to
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`the laws of Delaware.
`
`5.
`
`Defendant is the United States of America (“United States”), based upon the
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`actions of its departments and agencies including but not limited to the Federal Emergency
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`Management Agency (“FEMA”); the United States Department of Homeland Security (“DHS”);
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`and the National Oceanic and Atmospheric Administration (“NOAA”).
`
`ASSERTED PATENTS
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`6.
`
`From time to time, governmental agencies need to notify members of the public
`
`of emergencies and other events. The goal is to provide trusted alerts to the members of the
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`public in the affected geographic area quickly and efficiently. Governmental agencies have used
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`various channels for alerts, such as television and radio. But dramatic increases in the
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`availability and functionality of cellular telephones, including for telephone calls, access to the
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`internet, access to online television and radio, and text messaging, have changed how these alerts
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`can best be communicated. Indeed, the average member of the public is more likely to have his
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`or her cellular phone nearby and in operation than to be watching television or listening to a
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`radio.
`
`7.
`
`In addition, in an emergency, it is desirable to deliver textual messages to
`
`members of the public in the geographic area that may be affected by the emergency. One
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`benefit of textual messages is that they can be read more than once. However, traditional Short
`
`Message Service (“SMS”) text messaging has a significant limitation. SMS text messaging
`
`involves a two-way communication between a cellular network and each message recipient.
`
`Each communication utilizes critical bandwidth and other resources. The more recipients, the
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`greater the burden on the cellular network’s resources. If the SMS demand on a network is too
`
`great, the cellular network can become overloaded, and it can even crash as a result. A network
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`overload in the case of an emergency further impedes communications and exacerbates the
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`situation.
`
`8.
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`Often, emergencies are localized (for example, a tornado headed for a specific zip
`
`code). Other times they are broader in scope—such as national emergencies concerning acts of
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`terror. Regardless of scope, the inventors at EnvisionIT recognized two things. First, messages
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`concerning emergencies should be delivered to those who may be impacted by those
`
`emergencies and should not be over-distributed or under-distributed—that is, that the messages
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`should be “geo-targeted.” Second, recognizing that traditional SMS messaging faced the
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`limitations described above, the inventors knew that a much more efficient manner of emergency
`
`messaging could be accomplished through one-way “broadcast” messaging to the proper
`
`recipients. As a result, the inventors developed a novel solution to provide authorized, geo-
`
`targeted emergency alerts to users, whether over traditional media, cell phones, or other
`
`emerging media such as IP broadcast. In the United States, tens of thousands of emergency
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`message originators in town, city, county, state and Federal agencies may be authorized to create
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`and send emergency messages to their respective geo-political jurisdictions. In most cases, these
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`messages are time sensitive. They must be delivered to the relevant public as quickly as possible
`
`to minimize the loss of life and property.
`
`9.
`
`At the heart of the system is the processing technology necessary to both validate
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`senders and their authority to geo-target messages to specific areas as well as to package and
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`route those messages to the proper networks for ultimate delivery to the geo-targeted recipients.
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`The inventors also developed the technology necessary to enable multiple alert originators (such
`
`as emergency management organizations from different governmental entities) to request the
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`delivery of particular alerts, and they invented technology to verify, centralize, aggregate, and
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`deliver geo-targeted broadcast messages.
`
`10.
`
`After applying for the initial patent on their geo-targeted messaging system, the
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`inventors assigned their full rights and interests in the patented invention to EnvisionIT.
`
`11.
`
`EnvisionIT disclosed and claimed these and other inventions in a series of patent
`
`applications resulting in the issuance of nine United States patents and various other patents
`
`worldwide already. EnvisionIT also has additional patent applications pending. The United
`
`States has, without license, used or manufactured products and services covered by at least the
`
`following five U.S. patents: 7,693,938; 8,103,719; 8,438,221; 8,438,212; and 9,136,954
`
`(collectively, the “Asserted Patents”).
`
`12.
`
`On April 6, 2010, the U.S. Patent and Trademark Office duly and lawfully issued
`
`U.S. Patent number 7,693,938 (“the ’938 patent”) entitled “Message broadcasting admission
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`control system and method.” A true and correct copy of the ’938 patent is attached as Exhibit A.
`
`13.
`
`On January 24, 2012, the U.S. Patent and Trademark Office duly and lawfully
`
`issued U.S. Patent number 8,103,719 (“the ’719 patent”) entitled “Message broadcasting control
`
`system and method.” A true and correct copy of the ’719 patent is attached as Exhibit B.
`
`14.
`
`On May 7, 2013, the U.S. Patent and Trademark Office duly and lawfully issued
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`U.S. Patent number 8,438,221 (“the ’221 patent”) entitled “Broadcast alerting message
`
`aggregator/gateway system and method.” A true and correct copy of the ’221 patent is attached
`
`as Exhibit C.
`
`15.
`
`On May 7, 2013, the U.S. Patent and Trademark Office duly and lawfully issued
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`U.S. Patent number 8,438,212 (“the ’212 patent”) entitled “Message broadcasting control system
`
`and method.” A true and correct copy of the ’212 patent is attached as Exhibit D.
`
`16.
`
`On September 15, 2015, the U.S. Patent and Trademark Office duly and lawfully
`
`issued U.S. Patent number 9,136,954 (“the ’954 patent”) entitled “Broadcast alerting message
`
`aggregator/gateway system and method.” A true and correct copy of the ’954 patent is attached
`
`as Exhibit E.
`
`17.
`
`Each of the Asserted Patents is a valid and enforceable United States Patent,
`
`issued after a full and fair examination.
`
`18.
`
`EnvisionIT is the assignee of the entire right, title, and interest in and to each of
`
`the Asserted Patents.
`
`19.
`
`CellCast holds an exclusive license to each of the Asserted Patents, with the right
`
`to sublicense them.
`
`SUMMARY OF GROUNDS FOR RELIEF
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`20.
`
`After years of working with and giving presentations to FEMA and DHS
`
`regarding their geo-targeted messaging system, the CellCast Aggregator/Gateway (“CAG”), the
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`Plaintiffs began to suffer substantial financial harm when FEMA and DHS launched the
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`Integrated Public Alert Warning System (“IPAWS”) to deliver emergency messages throughout
`
`the United States. IPAWS utilizes the inventions claimed in the Asserted Patents. Because the
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`United States has not compensated Plaintiffs for a license to the Asserted Patents, such as a lump
`
`sum license, for example, Plaintiffs have suffered and will continue to suffer substantial financial
`
`harm.
`
`21. Moreover, after working side by side with CellCast and soliciting numerous
`
`presentations and other information from CellCast, the United States took Plaintiffs’ technology
`
`when it built IPAWS, despite CellCast’s significant investment of time and money to innovate
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`the technology and to create an innovative, patented system for delivering emergency alerts.
`
`FEMA knew of both CellCast’s investments and its patents, but FEMA acted without regard for
`
`that knowledge. Two examples demonstrate FEMA’s knowledge and taking: (a) numerous
`
`meetings between FEMA and CellCast predated FEMA’s purported development of IPAWS, and
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`(b) DHS issued requests for information related to its broadcast alert system in 2008 and 2009, to
`
`which CellCast responded and gave notice of its intellectual property rights in the system
`
`described by the RFIs.
`
`22.
`
`The United States’ unlicensed manufacture or use of inventions disclosed and
`
`claimed in CellCast’s patents entitles CellCast to reasonable and entire compensation for the
`
`unlicensed use and manufacture by and for the United States.
`
`KNOWLEDGE OF THE PATENTS-IN-SUIT BY THE UNITED STATES
`
`CellCast gave the United States notice of the Asserted Patents.
`From at least 2006 through 2014, CellCast representatives consistently and
`
`23.
`
`unambiguously informed FEMA officials of the Asserted Patents during their numerous
`
`presentations to and meetings with FEMA representatives.
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`FACTUAL ALLEGATIONS
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`CellCast developed a geo-targeted messaging system.
`24.
`At least as early as 2003, CellCast began developing a geo-targeted messaging
`
`system (“GMS”) to enable national or localized emergency messages to be created, targeted, and
`
`sent through a variety of channels, including efficient broadcast to all enabled mobile devices
`
`within the specified area.
`
`25.
`
`As part of its GMS, CellCast developed technologies including EAGLE Alerts, a
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`community notifications system that enables the creation, geo-targeting, and sending of
`
`emergency and public messages. CellCast also developed the CAG, a message processing
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`system designed to accept, validate, and forward messages from multiple input sources to
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`multiple output sources.
`
`26.
`
`In addition to traditional media outlets such as radio, television, and other
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`message delivery systems, CellCast’s GMS can be used to broadcast messages to all enabled
`
`mobile devices in a geo-targeted area without having to identify specific mobile device numbers,
`
`as would be required by standard SMS text messages. Furthermore, CellCast’s GMS can reach
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`millions of mobile users in a matter of seconds and works even when the cellular networks are
`
`congested. CellCast’s GMS also allows travelers present in an intended geo-targeted area to
`
`receive vital alerts, even if their registered home addresses are outside of the geo-targeted area.
`
`FEMA began working on IPAWS.
`27.
`FEMA initiated its IPAWS program in 2004 with the intention of integrating new
`
`and existing alert systems into a “system of systems.” In developing IPAWS, FEMA served as
`
`the executive agency and worked in partnership with NOAA, the FCC, and other public and
`
`private stakeholders.
`
`28.
`
`In 2006, Congress passed the Warning Alert and Response Network Act (the
`
`“WARN Act”), which required updates to the country’s emergency alert system. In doing so,
`
`Congress recognized that the ability to deliver accurate, timely warnings through cellphones and
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`other mobile services is an important step to delivering public warnings during disasters and
`
`other emergencies.
`
`29.
`
`Following the passage of the WARN Act, President George W. Bush signed
`
`Executive Order 13407 directing the Department of Homeland Security (DHS) to create “an
`
`effective, reliable, integrated, flexible, and comprehensive” public alert and warning system for
`
`the United States. The Order directed FEMA to lead the effort and adopt a set of standards and
`
`protocols to support the system, which was intended to integrate federal, state, territorial, tribal,
`
`and local government alert and warning systems to enable various messaging options and
`
`communications in the event of an emergency.
`
`CellCast repeatedly demonstrated its technology to FEMA.
`30.
`CellCast began its initial geo-targeted emergency broadcast trials in 2006. During
`
`those live-implementation trials, CellCast successfully demonstrated its capability to send geo-
`
`targeted NOAA weather alerts to mobile phone customers via Cell Broadcast technology.
`
`31.
`
`David Webb, then the Program Support Branch Chief of IPAWS, attended a live
`
`demonstration of this technology in Appleton, Wisconsin in July 2006. There, CellCast
`
`successfully demonstrated its CAG on the Einstein Wireless network. Using CellCast’s Eagle
`
`Alerts system, CellCast sent geo-targeted messages to the CAG for processing before they were
`
`delivered to headsets via carriers’ networks using Cell Broadcast.
`
`32.
`
`At a May 2007 demonstration in Houston, CellCast representatives met with
`
`David Webb of DHS and two Sandia Labs representatives, Jeff Jortner and Ronald Glaser. At
`
`the demonstration, CellCast detailed the workings of the aggregator gateway and discussed
`
`potential work for FEMA.
`
`33.
`
`In 2008, following the demonstrations, the Federal Communications Commission
`
`(“FCC”) issued a notice of proposed rulemaking concerning a Commercial Mobile Alert System
`
`(“CMAS”), and DHS issued a Request for Information for purposes of collecting information as
`
`a step in developing its IPAWS system. CellCast responded to the RFI to state that it had
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`already developed and patented a system to provide the functionality required by the request.
`
`CellCast’s response provided clear notice to FEMA of CellCast’s intellectual property rights in
`
`the system described in FEMA’s RFI. A copy of CellCast’s Response is attached hereto as
`
`Exhibit F.
`
`34.
`
`After responding to DHS’s RFI, CellCast received an invitation to conduct a
`
`demonstration at the Joint Interoperability Test Command (“JITC”) in Indian Head, Maryland
`
`for DHS and FEMA officials. CellCast conducted that demonstration and discussion on March
`
`11, 2009, in front of many FEMA and DHS employees and consultants as part of the Digital
`
`Alert Warning System training.
`
`35.
`
`After CellCast’s presentation to JITC, FEMA issued an RFI on August 4, 2009,
`
`seeking information on potential improvements to the FEMA-administered CMAS system.
`
`CellCast responded to that RFI on September 4, 2009. In its response, CellCast both detailed its
`
`capabilities and stated that it had patented the supporting technologies. A copy of CellCast’s
`
`Response is attached hereto as Exhibit G.
`
`36.
`
`Also in September 2009, CellCast representatives presented at the National
`
`Information Exchange Market (NIEM) National Training Conference. CellCast participated in
`
`the OASIS Emergency Interoperability Summit, which was held in coordination with DHS.
`
`Dennis Gusty of DHS Science and Technology (“S&T”) encouraged CellCast to attend the
`
`NIEM event, which was attended by Bill Kalin, a DHS consultant who reported to Dennis Gusty.
`
`At the NIEM Conference, CellCast demonstrated the CAG’s message processing capability and
`
`interoperability and fielded numerous questions from attendees for several DHS divisions.
`
`37.
`
`In November 2009, CellCast demonstrated its solutions and capabilities at the
`
`OASIS Interoperability Demonstration in coordination with DHS S&T. IPAWS staff
`
`participated in this demonstration, and again CellCast representatives talked extensively with
`
`them about CellCast’s system.
`
`38.
`
`CellCast continued to make presentations to FEMA staff through 2011. In
`
`February 2010, CellCast demonstrated its CAG’s capabilities and interoperability by processing
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`Common Alert Protocol (“CAP”) messages from various venders. Tom Ferrentino, then a
`
`Senior Homeland Security Consultant for FEMA who was working on IPAWS, and Wade
`
`Witmer, the Deputy Director of IPAWS, both attended this presentation.
`
`39.
`
`In November 2010, CellCast again demonstrated its CAG’s capabilities to FEMA
`
`staff at the International Association of Emergency Managers (“IAEM”) Trade Show in San
`
`Antonio. FEMA staff also attended a similar demonstration at the November 2011 IAEM Trade
`
`Show in Las Vegas.
`
`40.
`
`At the September 2011 Emergency Interoperability Consortium Webinar,
`
`CellCast demonstrated its polygon-based CAP Emergency Message & State-wide Warning
`
`Aggregation to FEMA representatives and FEMA’s private-sector partners.
`
`FEMA announced IPAWS components that utilize CellCast’s patented technologies
`without a license.
`41.
`After CellCast’s repeated demonstrations and disclosures of its technology to
`
`FEMA, FEMA deployed the IPAWS system, which utilizes inventions disclosed in and covered
`
`by CellCast’s Asserted Patents, without a license from CellCast or EnvisionIT.
`
`CellCast offered to license its technology to the United States.
`42.
`About November 2011, CellCast discussed with FEMA the unauthorized use of
`
`the patents-in-suit. Shortly thereafter, FEMA officials terminated discussions with CellCast.
`
`43.
`
`CellCast continued to attempt to license the Asserted Patents to FEMA, even after
`
`the initial discussions broke down.
`
`44.
`
`On January 6, 2014, FEMA officials, including Ms. Lavanya Ratnam, the
`
`Assistant General Counsel for Intellectual Property at DHS, met with CellCast representatives.
`
`At the meeting, the FEMA officials requested additional information about CellCast’s
`
`technologies, its contacts at DHS, and the basis for its belief that IPAWS practiced inventions
`
`covered by CellCast’s patents.
`
`45.
`
`CellCast provided the requested information to FEMA on May 20, 2014 and July
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`30, 2014. This information included documents detailing FEMA’s unlicensed use of the
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`invention of the Asserted Patents. FEMA responded by requesting a monetary demand, which
`
`CellCast provided on August 13, 2014.
`
`46.
`
`FEMA rejected CellCast’s demand and denied CellCast’s unlicensed use claims
`
`on December 15, 2014.
`
`UNLICENSED USE BY THE UNITED STATES
`
`47.
`
`CellCast and EnvisionIT allege the following unlicensed use of its Asserted
`
`Patents by the United States under 35 U.S.C. § 1498(a).
`
`Count 1: Unlicensed Use of the Invention of U.S. Patent No. 7,693,938
`
`EnvisionIT is the assignee of all right, title, and interest to the ’938 patent.
`
`CellCast is the exclusive licensee of the ’938 patent.
`
`The IPAWS system implemented and/or operated by the United States through its
`
`48.
`
`49.
`
`50.
`
`agents including at least FEMA, DHS, and NOAA, includes the invention described in the '938
`
`patent and covered by at least claim 1 of the ’938 patent. Specifically, based on publicly
`
`available information from FEMA, the IPAWS-Open alert aggregator includes a broadcast
`
`request interface configured to receive broadcast messages in a defined form, a broadcast control
`
`module configured to verify the broadcast messages based on defined parameters, and a
`
`broadcast message distributor module configured for transmitting the broadcast message and a
`
`geographic target area to an output interface.
`
`51.
`
`The United States does not have a license from EnvisionIT or CellCast to practice
`
`the invention of the ’938 patent.
`
`52.
`
`Accordingly, EnvisionIT and CellCast seek
`
`their reasonable and entire
`
`compensation for this unlicensed use of the invention of the ’938 patent pursuant to 35 U.S.C. §
`
`1498(a).
`
`Count 2: Unlicensed Use of the Invention of U.S. Patent No. 8,103,719
`
`53.
`
`EnvisionIT is the assignee of all right, title, and interest to the ’719 patent.
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`54.
`
`55.
`
`CellCast is the exclusive licensee of the ’719 patent.
`
`The IPAWS system implemented and/or operated by the United States through its
`
`agents including at least FEMA, DHS, and NOAA, includes the invention described in the ’719
`
`patent and covered by at least claim 23 of the ’719 patent. Specifically, based on publicly
`
`available information from FEMA, the IPAWS-Open alert aggregator performs the method of
`
`validating the authority of broadcast message originators based on specific parameters,
`
`identifying and validating a broadcast network based on specific parameters, and forwarding the
`
`broadcast message to an output interface associated with the broadcast network.
`
`56.
`
`The United States does not have a license from EnvisionIT or CellCast to practice
`
`the invention of the ’719 patent.
`
`57.
`
`Accordingly, EnvisionIT and CellCast seek
`
`their reasonable and entire
`
`compensation for this unlicensed use of the invention of the ’719 patent pursuant to 35 U.S.C. §
`
`1498(a).
`
`58.
`
`59.
`
`60.
`
`Count 3: Unlicensed Use of the Invention of U.S. Patent No. 8,438,221
`
`EnvisionIT is the assignee of all right, title, and interest to the ’221 patent.
`
`CellCast is the exclusive licensee of the ’221 patent.
`
`The IPAWS system implemented and/or operated by the United States through its
`
`agents including at least FEMA, DHS, and NOAA, includes the invention described in the ’221
`
`patent and covered by at least claim 1 of the ’221 patent. Specifically, based on publicly
`
`available information from FEMA, the IPAWS-Open alert aggregator is a broadcast broker
`
`system comprising a broadcast service bureau communicatively coupled for receiving broadcast
`
`messages from agent access systems, configured for verifying broadcast requests as a function of
`
`the broadcast agent identification and geographic message jurisdictions, and processing the
`
`verified requests for transmission to broadcast message networks.
`
`61.
`
`The United States does not have a license from EnvisionIT or CellCast to practice
`
`the invention of the ’221 patent.
`
`62.
`
`Accordingly, EnvisionIT and CellCast seek
`
`their reasonable and entire
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`compensation for this unlicensed use of the invention of the ’221 patent pursuant to 35 U.S.C. §
`
`1498(a).
`
`63.
`
`64.
`
`65.
`
`Count 4: Unlicensed Use of the Invention of U.S. Patent No. 8,438,212
`
`EnvisionIT is the assignee of all right, title, and interest to the ’212 patent.
`
`CellCast is the exclusive licensee of the ’212 patent.
`
`The IPAWS system implemented and/or operated by the United States through its
`
`agents including at least FEMA, DHS, and NOAA, includes the invention described in the ’212
`
`patent and covered by at least claim 13 of the ’212 patent. Specifically, based on publicly
`
`available information from FEMA, the IPAWS-Open alert aggregator performs the method of
`
`receiving over a data interface a plurality of broadcast message records having a broadcast
`
`message and target area and associated with different originators, validating the message records
`
`as a function of the originator identification and the target area, generating a validated broadcast
`
`message for each validated message, determining which transmission networks provide service
`
`to the geographically defined target area, and transmitting the message to an output interface to
`
`the broadcast network.
`
`66.
`
`The United States does not have a license from EnvisionIT or CellCast to practice
`
`the invention of the ’212 patent.
`
`67.
`
`Accordingly, EnvisionIT and CellCast seek
`
`their reasonable and entire
`
`compensation for this unlicensed use of the invention of the ’212 patent pursuant to 35 U.S.C. §
`
`1498(a).
`
`68.
`
`69.
`
`70.
`
`Count 5: Unlicensed Use of the Invention of U.S. Patent No. 9,136,954
`
`EnvisionIT is the assignee of all right, title, and interest to the ’954 patent.
`
`CellCast is the exclusive licensee of the ’954 patent.
`
`The IPAWS system implemented and/or operated by the United States through its
`
`agents including at least FEMA, DHS, and NOAA, includes the invention described in the ’954
`
`patent and covered by at least claim 17 of the ’954 patent. Specifically, based on publicly
`
`available information from FEMA, the IPAWS-Open alert aggregator performs the method of
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`Case 1:15-cv-01307-VJW Document 1 Filed 11/02/15 Page 13 of 14
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`receiving over an input interface a plurality of broadcast message requests in the specified
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`format, storing a jurisdiction authority for each message originator, verifying each message
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`request by at least ensuring that the message target is within the jurisdiction of the originator,
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`determining two or more message broadcast systems that cover at least a portion of the target
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`area, and transmitting the verified message to the transmission systems over an output interface.
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`71.
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`The United States does not have a license from EnvisionIT or CellCast to practice
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`the invention of the ’954 patent.
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`72.
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`Accordingly, EnvisionIT and CellCast seek
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`their reasonable and entire
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`compensation for this unlicensed use of the invention of the ’954 patent pursuant to 35 U.S.C. §
`
`1498(a).
`
`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs CellCast and EnvisionIT respectfully request judgment in their
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`favor and against the United States granting CellCast and EnvisionIT the following relief:
`
`A.
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`Entry of judgment in favor of Plaintiffs CellCast and EnvisionIT against the
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`United States on all counts;
`
`B.
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`Reasonable and entire compensation pursuant to 28 U.S.C. § 1498 in an amount
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`to be determined at trial;
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`C.
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`D.
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`E.
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`F.
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`Plaintiffs’ reasonable fees for expert witnesses and attorneys;
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`Plaintiffs’ costs;
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`Pre-judgment and post-judgment interest on Plaintiffs’ award; and.
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`All such other and further relief as the Court deems just or equitable.
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`Case 1:15-cv-01307-VJW Document 1 Filed 11/02/15 Page 14 of 14
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`By: /s/ Peter J. Chassman
`Peter J. Chassman
`Texas Bar No. 00787233
` REED SMITH LLP
`811 Main Street
`Suite 1700
`Houston, TX 77002-6110
`Telephone: (713) 469-3885
`Facsimile:
`(713) 469-3899
`Email: PChassman@reedsmith.com
`
`
`
`
`
`
`
`Dated: October 30, 2015
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`
`
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