Case 5:17-cv-02724-JFL Document 23 Filed 11/03/17 Page 1 of 19
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF PENNSYLVANIA
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`BRITAX CHILD SAFETY, INC.,
`
`Plaintiff,
`
`v.
`
`NUNA INTERNATIONAL B.V. and
`NUNA BABY ESSENTIALS, INC.,
`
`Defendants.
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`Civil Action No. 5-17-cv-02724
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`JURY TRIAL DEMANDED
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`AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`Britax Child Safety, Inc. (“Britax”) alleges as follows:
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`NATURE OF ACTION
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`1.
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`This is an action under the patent laws of the United States, 35 U.S.C. § 1, et seq.,
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`for infringement by Defendants Nuna International B.V. and Nuna Baby Essentials, Inc.
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`(collectively “Nuna” or “Defendants”), of U.S. Patent Nos. 9,586,504 (“the ’504 Patent”) and
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`9,499,074 (“the ’074 Patent”) (collectively, the “Asserted Patents”). The Asserted Patents
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`protect Britax products designed and developed by Britax in the U.S.
`
`THE PARTIES
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`2.
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`Britax is a corporation organized and existing under the laws of the State of South
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`Carolina, having its principal place of business at 4140 Pleasant Road, Fort Mill, SC 29708.
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`Britax designs and develops its products and revolutionary technologies, including the innovative
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`ClickTight® technology and products incorporating that technology at its U.S. facilities in Fort
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`Mill, SC.
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`Nuna Exhibit 1009
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`3.
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`Nuna International B.V. (“Nuna International”) is, on information and belief, an
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`entity organized and existing under the laws of the Netherlands with its registered place of
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`business at De Beeke 8, 5469 dw, Erp, the Netherlands.
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`4.
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`Nuna Baby Essentials, Inc. (“Nuna Baby Essentials”) is a corporation organized
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`and existing under the laws of the State of Pennsylvania that, on information and belief, has its
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`principal place of business at 70 Thousand Oaks Blvd., Morgantown, PA 19543. On information
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`and belief, Nuna Baby Essentials, Inc. is a wholly-owned subsidiary of Nuna International B.V.
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`JURISDICTION AND VENUE
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`5.
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`This action arises under the patent laws of the United States, Title 35 of the
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`United States Code. Accordingly, this Court has jurisdiction over the subject matter of this
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`action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over Nuna Baby Essentials because (a) it is
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`incorporated in the State of Pennsylvania and, on information and belief, maintains its principal
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`place of business in Morgantown, Pennsylvania; and (b) on information and belief, it has
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`marketed, distributed, offered for sale, and/or sold the infringing products to persons within the
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`State of Pennsylvania. Thus, and as supported by the further factual allegations below, the
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`exercise of jurisdiction over Nuna Baby Essentials would not offend traditional notions of fair
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`play and substantial justice.
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`7.
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`On information and belief, Nuna Baby Essentials and Nuna International are
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`agents of each other and/or work in concert with each other to design, develop, market, offer for
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`sale, sell, and import into the United States baby and child products. For example, Nuna
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`International owns the website marketing, offering for sale, and selling Nuna’s products in the
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`United States. See Exhibit C (https://www.nuna.eu/usa/privacy-policy) (“The terms ‘Nuna’ or
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`‘we’ or ‘us’ refer to the owner of this website whose registered address is: Nuna International
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`BV, De Beeke 8, 5469 dw, Erp, the Netherlands.”) Nuna International uses this website to offer
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`products to potential customers, including potential customers in the United States. See id. (“We
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`may periodically send promotional emails about new products, special offers or other
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`information which we think you may find interesting using the email address which you have
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`provided.”). Nuna Baby Essentials utilizes the Nuna website, https://www.nuna.eu/usa/, at least
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`for providing information to customers in the United States regarding product recalls. See
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`Exhibit D (https://www.nuna.eu/usa/recallforthezaaz). On information and belief, Nuna Baby
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`Essentials and Nuna International have agreements or act on behalf of one another regarding use
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`of the Nuna website and the marketing, offering for sale, and sale of Nuna products. The
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`Accused Products are sold on Nuna’s website. Further, promotional materials available on the
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`Nuna website, including the electronic brochure, 2017_USA_Consumer_Brochure.pdf, are
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`provided by Nuna International. See Exhibit E
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`(https://www.nuna.eu/media/pdf/stores/1/2017_USA_Consumer_Brochure.pdf).
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`8.
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`This Court has personal jurisdiction over Nuna International because, on
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`information and belief, (a) Nuna International regularly transacts and conducts business within
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`this State, including business with Nuna Baby Essentials; and/or (b) Nuna International has
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`otherwise made or established contacts within this State sufficient to permit the exercise of
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`personal jurisdiction. For example, on information and belief, Nuna International markets, offers
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`for sale, and sells products accused of infringing the Asserted Patents through its website,
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`https://www.nuna.eu/usa/, to potential and actual customers in this State. Thus, and as supported
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`by the further factual allegations below, the exercise of jurisdiction over Nuna International
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`would not offend traditional notions of fair play and substantial justice.
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`9.
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`Alternatively, this Court has jurisdiction over Nuna International under Federal
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`Rule of Civil Procedure 4(k)(2). Nuna International has contacts with the United States,
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`including, on information and belief, its ownership of and business dealings with Nuna Baby
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`Essentials, its development, marketing, offer for sale, and sale of products into the United States
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`market, and its ownership of U.S. intellectual property rights, including patents, patent
`
`applications, and trademarks. For example, on information and belief, Nuna International
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`markets, offers for sale, and sells products accused of infringing the Asserted Patents, including
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`the Nuna RAVATM car seat discussed below, through its website, https://www.nuna.eu/usa/, to
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`potential and actual customers in the United States.
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`10.
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`This District is a proper venue pursuant to 28 U.S.C. § 1400(b) because Nuna
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`Baby Essentials resides in this District and because it has committed acts of infringement and has
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`a regular and established place of business in this District. This District is a proper venue also
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`because Nuna International B.V. may be sued in any judicial district.
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`GENERAL ALLEGATIONS
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`11.
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`Britax has been a leader in child safety technology for more than 70 years.
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`Tracing its roots to Europe’s best-selling car seat brand, Britax has become one of the brands
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`most trusted by American families since establishing its presence in the United States in 1996.
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`Operating from its U.S. headquarters in Fort Mill, South Carolina, Britax proudly designs,
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`develops, tests, and builds its industry-leading child safety restraints, including its child safety
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`car seats, in the United States.
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`12.
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`Britax has a legacy of innovation owing to its significant investment in research
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`and development of child safety technologies. Britax’s technological advancements have
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`revolutionized side impact protection and transformed child safety seat installation.
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`13.
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`Britax has also invested in protecting the innovations it has brought to the child
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`safety industry. Britax currently holds over 50 U.S. utility and design patents and patent
`
`applications. These patents protect inventions embodied in many of the child safety products
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`currently offered by Britax to parents in the United States.
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`THE ASSERTED PATENTS
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`14.
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`Britax is the owner of the ’504 Patent, including the right to enforce and sue for
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`past damages. The ’504 Patent was duly and legally issued by the United States Patent and
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`Trademark Office on March 7, 2017, is active, and is entitled “Forward and Rearward Facing
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`Child Seat with Belt Tensioning Mechanism for Improved Installation.” A true and correct copy
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`of the ’504 Patent is attached hereto as Exhibit A.
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`15.
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`Britax is the owner of the ’074 Patent, including the right to enforce and sue for
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`past damages. The ’074 Patent was duly and legally issued by the United States Patent and
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`Trademark Office on November 22, 2016, is active, and is entitled “Forward and Rearward
`
`Facing Child Seat with Belt Tensioning Mechanism for Improved Installation.” A true and
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`correct copy of the ’074 Patent is attached hereto as Exhibit B.
`
`16.
`
`The Asserted Patents generally relate to a child safety seat that may be used in
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`either a forward or rearward facing orientation and includes a tensioning mechanism to more
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`fully secure the child safety seat to a vehicle seat, thereby allowing for ease in installation of the
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`child safety seat. The products described in the Asserted Patents relate to a child safety seat that
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`is easy install in a secure manner in both a rear-facing or forward-facing orientation. The
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`inventions protected by the Asserted Patents represent a revolutionary advance in the child safety
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`industry.
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`17.
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`Exemplary claim 13 of the ’504 Patent recites:
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`A child seat configured to be secured to a vehicle seat in both a rear-facing and a
`forward-facing orientation by a belt of the vehicle seat, the child seat comprising:
`
` a
`
` seat base comprising a seat portion, a backrest portion, a first belt path generally at a
`middle of the seat portion in a forward and rearward direction, and a second belt path
`generally at an intersection of the seat and backrest portions, first and second lateral
`edges that protrude forwardly and upwardly from opposing sides of the backrest portion
`proximate to the second belt path, third and fourth lateral edges that protrude forwardly
`and upwardly from opposing sides of the seat portion proximate to the first belt path;
`
` a
`
` pivot structure having a first pivot portion comprising a first lateral edge member and a
`second lateral edge member, the pivot structure attached to the backrest portion at an axis
`such that the pivot structure rotates between a first position and a second position
`pivotally about the axis, the first and second lateral edge members extending away from
`the backrest and substantially perpendicular to the axis, wherein in the first position, the
`first pivot portion is substantially adjacent to the seat base, and wherein in the second
`position, the first pivot portion is at least partly displaced from the seat base in order to
`enable the second belt path to receive the belt;
`
`the pivot structure having a second pivot portion comprising a third lateral edge member
`and a fourth lateral edge member, the third and fourth lateral edge members moving
`between a third position proximate to the seat portion and a fourth position at least partly
`displaced from the seat portion in order to enable the first belt path to receive the belt,
`
`wherein the first belt path is configured to allow a user to position the belt to be displaced
`by the third and fourth lateral edge members relative to the third and fourth lateral edges
`to secure the child seat to the vehicle seat when the child seat is in the rear-facing
`orientation, and
`
`wherein the second belt path is configured to allow the user to position the belt to be
`displaced by the first and second lateral edge members relative to the first and second
`lateral edges to secure the child seat to the vehicle seat when the child seat is in the
`forward-facing orientation.
`
`18.
`
`Exemplary claim 1 of the ’074 Patent recites:
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`A child seat configured to be secured to a vehicle seat in both a rear-facing and front-
`facing orientation, the child seat comprising:
`
` seat base defining a seat portion, a backrest portion, and first and second lateral edges
`that protrude forwardly and upwardly from the seat and backrest portions,
`
`wherein the seat base is configured to receive a belt of the vehicle seat in an untensioned
`state to secure the child seat to the vehicle seat in an untensioned configuration;
`
` a
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`and a tensioning mechanism having a proximal end pivotally attached to the backrest
`portion of the seat base and a distal end comprising a sitting surface for an occupant of
`the child seat and an engaging surface facing opposite to the sitting surface,
`
`wherein the tensioning mechanism is movable downwardly and forwardly to a first
`position substantially adjacent to the seat base and upwardly and rearwardly to a second
`position displaced therefrom,
`
`wherein placing the tensioning mechanism in the second position allows the seat base to
`receive the belt, and movement of the tensioning mechanism from the second position to
`the first position presses the belt against the first and second edges and deflects a portion
`of the belt between first and second edges to be closer to the seat or backrest portion than
`portions of the belt that engage the first and second edges and thus applies tension to the
`belt to secure the child seat to the vehicle seat in a tensioned configuration,
`
`wherein the seat base of the child seat is configured to receive the belt when the seat base
`is in both a rear-facing orientation and when the seat base is in a front-facing orientation.
`
`19.
`
`The Asserted Patents protect inventions embodied in Britax’s child car seat
`
`products, including, for example, Britax’s Boulevard ClickTight Convertible Car Seat, Britax’s
`
`Advocate ClickTight Convertible Car Seat, and Britax’s Marathon ClickTight Convertible Car
`
`Seat. The Boulevard ClickTight Convertible Car Seat is depicted below:
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`20.
`
`As just one example, the Boulevard ClickTight Convertible Car Seat, which is
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`protected by the Asserted Patents and incorporates Britax’s ClickTight installation system,
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`represents a revolutionary advance in the child safety industry because of the ease with which it
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`allows parents to securely install the car seat to a vehicle. Incorrect installation of a car seat can
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`compromise the performance of the car seat and the safety of children everywhere. The
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`innovative design of the Boulevard ClickTight Convertible Car Seat allows for safe and secure
`
`installation, in both forward-facing and rear-facing orientations. This advancement has been
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`recognized in the car seat industry, as the Britax Boulevard ClickTight Convertible Car Seat
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`earned a five-star Ease of Use rating from the National Highway Traffic Safety Administration
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`(“NHTSA”) as well as multiple awards from CarSeatBlog.org and online communities such as
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`Parent Tested Parent Approved (“PTPA”).
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`21.
`
`Britax marks its Boulevard ClickTight Convertible Car Seat, and the other car
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`seats protected by the Asserted Patents, through its website. See
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`https://us.britax.com/pages/patents-united-states/.
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`NUNA’S INFRINGING ACTIVITIES
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`22.
`
`Nuna, without authorization from Britax, makes, uses, imports, offers for sale,
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`and sells in the United States child safety seats covered at least by the Asserted Patents
`
`(collectively, the “Accused Products”). For example, Nuna makes, uses, imports, offers for sale,
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`and sells in the United States the Nuna RAVATM car seat, depicted below:
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`23.
`
`The Nuna RAVATM child car seat is covered by at least claim 13 of the ’504
`
`
`
`Patent.
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`24.
`
`The Nuna RAVATM child car seat is a child seat configured to be secured to a
`
`vehicle seat in both a rear-facing and a forward-facing orientation by a belt of the vehicle seat, as
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`depicted in the following figures from the Nuna RAVATM user manual, available online at
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`https://www.nuna.eu/usa/rava.
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`
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`25.
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`The Nuna RAVATM child seat includes a seat base comprising a seat portion, a
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`backrest portion, a first belt path generally at a middle of the seat portion in a forward and
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`rearward direction, and a second belt path generally at an intersection of the seat and backrest
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`portions, first and second lateral edges that protrude forwardly and upwardly from opposing
`
`sides of the backrest portion proximate to the second belt path, third and fourth lateral edges that
`
`protrude forwardly and upwardly from opposing sides of the seat portion proximate to the first
`
`belt path. The seat base of the Nuna RAVATM child seat is depicted above. See paragraph 22
`
`above. The first and second belt paths of the Nuna RAVATM child seat are depicted in the
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`following figures from the user manual:
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`
`
`
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`26.
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`The Nuna RAVATM child seat also includes a pivot structure having a first pivot
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`portion comprising a first lateral edge member and a second lateral edge member, the pivot
`
`structure attached to the backrest portion at an axis such that the pivot structure rotates between a
`
`first position and a second position pivotally about the axis, the first and second lateral edge
`
`members extending away from the backrest and substantially perpendicular to the axis, wherein
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`in the first position, the first pivot portion is substantially adjacent to the seat base, and wherein
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`in the second position, the first pivot portion is at least partly displaced from the seat base in
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`
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`
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`order to enable the second belt path to receive the belt. The first pivot portion of the pivot
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`structure of the Nuna RAVATM child seat is depicted in the following figure from the user
`
`manual:
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`
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`27.
`
`The pivot structure of the Nuna RAVATM child seat has a second pivot portion
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`including a third lateral edge member and a fourth lateral edge member, the third and fourth
`
`lateral edge members moving between a third position proximate to the seat portion and a fourth
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`position at least partly displaced from the seat portion in order to enable the first belt path to
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`receive the belt. The second pivot portion of the pivot structure of the Nuna RAVATM child seat
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`is depicted in the following figure from the user manual:
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`28.
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`The first belt path of the Nuna RAVATM child seat is configured to allow a user to
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`position the belt to be displaced by the third and fourth lateral edge members relative to the third
`
`and fourth lateral edges to secure the child seat to the vehicle seat when the child seat is in the
`
`rear-facing orientation.
`
`29.
`
`The second belt path of the Nuna RAVATM child seat is configured to allow the
`
`user to position the belt to be displaced by the first and second lateral edge members relative to
`
`the first and second lateral edges to secure the child seat to the vehicle seat when the child seat is
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`in the forward-facing orientation.
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`30.
`
`The Nuna RAVATM child car seat is covered by at least claim 1 of the ’074
`
`Patent.
`
`31.
`
`The Nuna RAVATM child car seat is a child seat configured to be secured to a
`
`vehicle seat in both a rear-facing and a forward-facing orientation by a belt of the vehicle seat, as
`
`depicted in the following figures from the Nuna RAVATM user manual:
`
`32.
`
`The Nuna RAVATM child seat includes a seat base defining a seat portion, a
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`backrest portion, and first and second lateral edges that protrude forwardly and upwardly from
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`the seat and backrest portions, wherein the seat base is configured to receive a belt of the vehicle
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`seat in an untensioned state to secure the child seat to the vehicle seat in an untensioned
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`configuration. The seat base of the Nuna RAVATM child seat is depicted above. See paragraph
`
`22.
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`33.
`
`The Nuna RAVATM child seat includes a tensioning mechanism having a
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`proximal end pivotally attached to the backrest portion of the seat base and a distal end
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`comprising a sitting surface for an occupant of the child seat and an engaging surface facing
`
`opposite to the sitting surface. The proximal end and the distal end of the tensioning mechanism
`
`are depicted in the following figures from the user manual:
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`34.
`
`The tensioning mechanism of the Nuna RAVATM child seat is movable
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`downwardly and forwardly to a first position substantially adjacent to the seat base and upwardly
`
`and rearwardly to a second position displaced therefrom. When the tensioning mechanism of
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`the Nuna RAVATM child seat is in the second position the seat base is able to receive a seat belt.
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`Movement of the tensioning mechanism of the Nuna RAVATM child seat from the second
`
`position to the first position presses the belt against the first and second edges and deflects a
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`portion of the belt between first and second edges to be closer to the seat or backrest portion than
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`portions of the belt that engage the first and second edges and thus applies tension to the belt to
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`secure the child seat to the vehicle seat in a tensioned configuration. The tensioning mechanism
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`of the Nuna RAVATM child seat is depicted in the second position in the following figure from
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`the user manual:
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`35.
`
`The seat base of the Nuna RAVATM child seat is configured to receive the belt
`
`when the seat base is in both a rear-facing orientation and when the seat base is in a front-facing
`
`orientation. Figures depicting the seat base of the Nuna RAVATM child seat receiving a belt in
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`both a rear-facing and front-facing orientation are depicted above in paragraphs 24, 25, and 31.
`
`COUNT I
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`(Infringement of United States Patent No. 9,586,504 by Nuna)
`
`36.
`
`Britax realleges and incorporates herein by reference the allegations set forth
`
`above.
`
`37.
`
`Nuna Baby Essentials directly infringes, literally or under the doctrine of
`
`equivalents, one more claims of the ’504 Patent, including at least claim 13, by, without
`
`authority from Britax, making, using, importing, offering for sale, and selling the Accused
`
`Products, including at least the Nuna RAVATM child seat, in violation of 35 U.S.C. § 271(a).
`
`38.
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`Nuna International directly infringes, literally or under the doctrine of equivalents,
`
`one more claims of the ’504 Patent, including at least claim 13, by, without authority from
`
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`
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`Britax, using, importing, offering for sale, and selling the Accused Products, including at least
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`the Nuna RAVATM child seat, in violation of 35 U.S.C. § 271(a).
`
`39.
`
`The Accused Products, including at least the Nuna RAVATM child seat, meet all
`
`the elements of at least claim 13 of the ’504 Patent.
`
`40.
`
`Nuna Baby Essentials and Nuna International have known of the ’504 Patent
`
`since at least the filing of the Complaint in this Action. Nuna Baby Essentials and Nuna
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`International are also on notice of the ’504 Patent at least through Britax’s marking of its
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`products, including at least the Boulevard ClickTight Convertible Car Seat, the Advocate
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`ClickTight Convertible Car Seat, and the Marathon ClickTight Convertible Car Seat.
`
`41.
`
`The acts of infringement of the ’504 Patent by Nuna Baby Essentials and Nuna
`
`International were undertaken without permission or license from Britax.
`
`42.
`
`Britax has suffered monetary damages and other injuries as a result of the past and
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`continuing infringement of the ’504 Patent by Nuna Baby Essentials and Nuna International.
`
`Britax is entitled to recover damages in an amount to be determined at trial, but in no event less
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`than a reasonable royalty.
`
`43.
`
`Britax has been irreparably harmed by the past and continuing infringement of the
`
`’504 Patent by Nuna Baby Essentials and Nuna International, and unless enjoined by this Court,
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`these acts of infringement will continue to damage Britax irreparably.
`
`COUNT II
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`(Infringement of United States Patent No. 9,499,074 by Nuna)
`
`44.
`
`Britax realleges and incorporates herein by reference the allegations set forth
`
`above.
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`45.
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`Nuna Baby Essentials directly infringes, literally or under the doctrine of
`
`equivalents, one more claims of the ’074 Patent, including at least claim 1, by, without authority
`
`from Britax, making, using, importing, offering for sale, and selling the Accused Products,
`
`including at least the Nuna RAVATM child seat, in violation of 35 U.S.C. § 271(a).
`
`46.
`
`Nuna International directly infringes, literally or under the doctrine of equivalents,
`
`one more claims of the ’074 Patent, including at least claim 1, by, without authority from Britax,
`
`using, importing, offering for sale, and selling the Accused Products, including at least the Nuna
`
`RAVATM child seat, in violation of 35 U.S.C. § 271(a).
`
`47.
`
`The Accused Products, including at least the Nuna RAVATM child seat, meet all
`
`the elements of at least claim 1 of the ’074 Patent.
`
`48.
`
`Nuna Baby Essentials and Nuna International have known of the ’074 Patent
`
`since at least the filing of this Amended Complaint. Nuna Baby Essentials and Nuna
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`International are also on notice of the ’074 Patent at least through Britax’s marking of its
`
`products, including at least the Boulevard ClickTight Convertible Car Seat, the Advocate
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`ClickTight Convertible Car Seat, and the Marathon ClickTight Convertible Car Seat.
`
`49.
`
`The acts of infringement of the ’074 Patent by Nuna Baby Essentials and Nuna
`
`International were undertaken without permission or license from Britax.
`
`50.
`
`Britax has suffered monetary damages and other injuries as a result of the past and
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`continuing infringement of the ’074 Patent by Nuna Baby Essentials and Nuna International.
`
`Britax is entitled to recover damages in an amount to be determined at trial, but in no event less
`
`than a reasonable royalty.
`
`
`
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`Page 16 of 19
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`

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`Case 5:17-cv-02724-JFL Document 23 Filed 11/03/17 Page 17 of 19
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`
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`51.
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`Britax has been irreparably harmed by the past and continuing infringement of the
`
`’074 Patent by Nuna Baby Essentials and Nuna International, and unless enjoined by this Court,
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`these acts of infringement will continue to damage Britax irreparably.
`
`
`
`WHEREFORE, Britax respectfully requests that the Court:
`
`PRAYER FOR RELIEF
`
`a.
`
`Enter a judgment that Nuna Baby Essentials and Nuna International have
`
`infringed the ’504 and ’074 Patents;
`
`b.
`
`Grant a permanent injunction restraining and enjoining Nuna Baby Essentials, its
`
`officers, directors, agents, servants, employees, successors, assigns, parents, subsidiaries, and
`
`affiliated or related companies from infringing the ’504 and ’074 Patents;
`
`c.
`
`Grant a permanent injunction restraining and enjoining Nuna International, its
`
`officers, directors, agents, servants, employees, successors, assigns, parents, subsidiaries, and
`
`affiliated or related companies from infringing the ’504 and ’074 Patents;
`
`d.
`
`Award Britax damages in an amount sufficient to compensate Britax for
`
`infringement of the ’504 and ’074 Patents by Nuna Baby Essentials and Nuna International, but
`
`not less than a reasonable royalty, together with interests and costs;
`
`e.
`
`f.
`
`Award prejudgment interest to Britax under 35 U.S.C. § 284;
`
`Declare this case exceptional under 35 U.S.C. § 285 and award Britax its
`
`expenses of litigation, including reasonable attorney’s fees; and
`
`g.
`
`Grant such other and further relief as this Court may deem just and proper.
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`DEMAND FOR JURY TRIAL
`
`Britax hereby demands a jury trial on all issues appropriately triable by a jury.
`
`
`
`
`
`17
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`

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`Case 5:17-cv-02724-JFL Document 23 Filed 11/03/17 Page 18 of 19
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`Dated: November 3, 2017
`
`Respectfully submitted,
`
`__________________________________
`
`KILPATRICK TOWNSEND & STOCKTON LLP
`
`Chris W. Haaf (PA Bar No. 307481)
`N. Dean Powell, Jr.
`Jonathan E. Harris
`1001 West Fourth Street
`Winston-Salem, NC 27101
`(336) 607-7300 (telephone)
`(336) 607-7500 (facsimile)
`chaaf@kilpatricktownsend.com
`dpowell@kilpatricktownsend.com
`jeharris@kilpatricktownsend.com
`
`Steven D. Moore
`Two Embarcadero Center, Eighth Floor
`San Francisco, California 94111
`(415) 576-0200 (telephone)
`(415) 576-0300 (facsimile)
`smoore@kilpatricktownsend.com
`
`Audra A. Dial
`1100 Peachtree Street, NE, Suite 2800
`Atlanta, Georgia 30309
`(404) 815-6500 (telephone)
`(404) 815-6555 (facsimile)
`adial@kilpatricktownsend.com
`
`18
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`Case 5:17-cv-02724-JFL Document 23 Filed 11/03/17 Page 19 of 19
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 3rd day of November 2017, I caused a true and correct copy
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`of the foregoing Amended Complaint for Patent Infringement, to be filed with the Court and
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`served by email and U.S. mail on counsel of record.
`
`______________________________
`Chris W. Haaf
`
`19
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`Page 19 of 19
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