Case 2:20-cv-00401-JRG Document 1 Filed 12/29/20 Page 1 of 17 PageID #: 1
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`VOCALIFE LLC,
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`v.
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`Plaintiff,
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`AMAZON.COM, INC. and
`AMAZON.COM SERVICES, INC.,
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`Defendants.
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`Case No.
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`JURY TRIAL DEMANDED
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Vocalife, LLC (“Vocalife” or “Plaintiff”) files this Complaint against
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`Defendants Amazon.com, Inc. and Amazon.com Services, Inc. (collectively, “Amazon” or
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`“Defendants”), for patent infringement under 35 U.S.C. § 271 and alleges as follows:
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`THE PARTIES
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`1.
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`Vocalife is a limited liability company organized and existing under the laws of
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`the State of Texas, with its principal place of business located at 7300 Lone Star Drive, C200
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`Plano, Texas 75024.
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`2.
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`Upon information and belief, Defendant Amazon.com, Inc. is a corporation
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`organized and existing under the laws of the State of Delaware, with its principal place of business
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`located at 410 Terry Avenue North, Seattle, Washington 98109-5210.
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`3.
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`Upon information and belief, Defendant Amazon.com Services, Inc. is a
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`corporation organized and existing under the laws of the State of Delaware, which is headquartered
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`at 410 Terry Avenue North, Seattle, Washington 98109-5210.
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`4.
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`Upon information and belief, Amazon.com, Inc. is the ultimate parent of
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`Amazon.com Services, Inc.1 Amazon is a leading manufacturing and seller of virtual assistant
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`smart speakers in the world and in the United States.2
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`JURISDICTION
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`5.
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`This is an action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. §§ 1, et seq. This Court has jurisdiction over this action pursuant to 28
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`U.S.C. §§ 1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over Amazon. Amazon regularly conducts
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`business and has committed acts of patent infringement and/or has induced acts of patent
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`infringement by others in this District and/or has contributed to patent infringement by others in
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`this District, the State of Texas, and elsewhere in the United States.
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`7.
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`Venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1391 and 1400(b)
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`because, among other things, upon information and belief Amazon maintains regular and
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`established physical places of business in Texas and in the Eastern District of Texas, directly or
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`through intermediaries.
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`8.
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`Amazon has admitted that it operates an Amazon Fulfillment Center within this
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`District.3
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`9.
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`Amazon has admitted that it employs information technology personnel at its
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`Fulfillment Center in Denton County, which is in this District.4
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`1 See Vocalife, LLC v. Amazon.com, Inc. and Amazon.com, LLC, Case No. 2:19-cv-00123-JRG,
`Dkt. 226 at 2 (E.D. Tex. July 31, 2020) (“Amazon.com, Inc. is the parent company of Amazon.com
`Services, Inc.”).
`2 See id. (“Amazon admits that subsidiaries of Amazon.com, Inc. sell virtual assistant smart
`speakers in the United States and outside the United States.”).
`3 See Exhibit A at ¶¶ 7 and 16; see also Vocalife LLC v. Amazon.com, Inc. and Amazon.com, LLC,
`Case No. 2:19-cv-00123-JRG, Dkt. 226 at 2 (“Amazon admits that subsidiaries of Amazon.com,
`Inc. operate a fulfillment center in this district.”).
`4 Id. at ¶ 20.
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`2
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`10.
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`Upon information and belief, Amazon, by itself and/or through its subsidiaries,
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`operates one or more “Fulfillment Centers” within this Judicial District including, at least, a
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`Fulfillment Center located in Denton County at 15201 Heritage Parkway, Fort Worth, Texas
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`76177.
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`11.
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`Upon information and belief, Amazon has a regular and established place of
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`business in this Judicial District, including, at least, a distribution facility located at 1649 W.
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`Frankford Road, Carrollton, Texas 75007, Amazon “lockers,”5 employees, and other business.
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`12.
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`Upon information and belief, Amazon has a regular and established place of
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`business in this Judicial District, including, at least, a Fulfillment Center located in Denton County
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`at 4121 International Parkway, Carrollton, Texas, 75007.
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`13.
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`Upon information and belief, Amazon has property in Denton County appraised
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`on the property tax rolls by Denton County at $104,448,891.006 and $26,168,603.00.7 Amazon
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`and/or its subsidiaries employ individuals within this Judicial District responsible for the
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`distribution of its products including those accused of infringement below.
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`14.
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`Amazon offers its products and/or services, including those accused of
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`infringement below, to customers and potential customers located in Texas and in this District.
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`15.
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`Amazon offers its products and/or services, including those accused of
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`infringement below, to customers and potential customers located in Texas and in this District.
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`16.
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`Amazon is subject to personal jurisdiction in this District, has a regular and
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`established place of business in this District including Amazon Fulfillment Centers in this District
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`5 Amazon operates “Amazon Hub Lockers” in at least the following locations: Plano, Carrollton,
`The Colony, and Lewisville. See https://www.amazon.com/gp/css/account/address/view.html.
`6 https://www.dentoncad.com/home/details?search=699143&year=2020.
`7 https://www.dentoncad.com/home/details?search=776100&year=2020.
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`3
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`and throughout Texas, has purposely transacted business involving the Accused Products in this
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`District, has purposely transacted business involving the Accused Products in this District,
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`including sales to one or more customers in Texas, has employees in this District, and certain of
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`the acts complained of herein occurred in this District.
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`17.
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`Amazon is subject to this Court’s jurisdiction pursuant to due process and/or the
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`Texas Long Arm Statute due at least to its substantial business in this State and District, including
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`(a) at least part of its past infringing activities, (b) regularly doing or soliciting business in Texas,
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`and/or (c) engaging in persistent conduct and/or deriving substantial revenue from goods and
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`services provided to customers in Texas.
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`PATENT-IN-SUIT
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`18.
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`On October 14, 2014, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 8,861,756 (the “’756 Patent”) entitled “Microphone Array System.”
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`A true and correct copy of the ’756 Patent attached hereto as Exhibit B.
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`19.
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`On August 2, 2018, a reissue application was filed for the ’756 Patent. As a result,
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`on December 29, 2020, the United States Patent and Trademark office duly and legally issued U.S.
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`Patent No. RE48,371 (the “’371 Patent”) entitled “Microphone Array System.” A true and correct
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`copy of the ’371 Patent is attached hereto as Exhibit C.
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`20.
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`Vocalife is the sole and exclusive owner of all right, title, and interest in the ’371
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`Patent, and holds the exclusive right to take all actions necessary to enforce its rights to the ’371
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`Patent, including the filing of this patent infringement lawsuit. Vocalife also has the right to
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`recover all damages for past, present, and future infringement of the ’371 Patent and to seek
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`injunctive relief as appropriate under the law.
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`21.
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`Vocalife has at all times complied with the marking provisions of 35 U.S.C. § 287
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`4
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`with respect to the ’371 Patent. On information and belief, prior assignees and licensees have also
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`complied with the marking provisions of 35 U.S.C. § 287.
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`FACTUAL ALLEGATIONS
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`22.
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`The ’371 Patent was developed at Li Creative Technologies Inc. by Dr. Manli Zhu
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`and Dr. Qi (“Peter”) Li who have been at the forefront of audio processing technology for over
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`two decades. In the late 2000’s Dr. Li and Dr. Zhu worked to develop novel audio, speech, and
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`image processing technology, including circular microphone arrays. Their work resulted in the
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`issuance of the ’371 Patent.
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`23.
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`In 2011, Dr. Li participated in the Consumer Electronics Show (“CES”) where
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`they were awarded the CES Innovations Design and Engineering Award in the Audio Accessories
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`Category.
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`24.
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`On or about September 20, 2011, Jerry Wu from A2Z Development Center, Inc.,
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`d/b/a Lab126 (“Lab126”), the hardware design arm of Defendant Amazon, reached out to Dr. Li
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`expressing interest in the 3D audio, noise and echo cancellation technology and, in particular,
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`adaptive beamforming technology.
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`25.
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`On or about October 17, 2011, Dr. Li accepted an invitation by Lab126 and met
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`with at least Aleksandar Pance, Wei Li,8 and Matthew Holland from Lab126 (the “Meeting”). At
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`the Meeting, Dr. Qi Li performed a confidential demonstration and presented the invention
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`including a circular microphone array, 3D sound, acoustic echo cancellations, and sound source
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`localization, including both hardware and software. Dr. Li’s presentation materials, which were
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`provided to Amazon, referenced Li Creative’s pending and issued patents. Dr. Li also
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`8 Wei Li was a former employee at Li Creative and, while employed by Lab126, had knowledge
`that Li Creative had filed patents on circular microphone array, noise reduction, noise cancellation,
`and sound source localization technologies.
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`5
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`confidentially introduced the concept of using voice and cloud computation to search music as one
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`of the applications of the microphone array technology.
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`26.
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`Dr. Qi Li contacted Lab126 to follow-up on the Meeting on or about June 22, 2012
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`and December 11, 2014; however, Dr. Li did not receive a response to his emails during this
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`timeframe.
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`27.
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`Following the commercialization of the first Amazon Echo product, Dr. Li
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`attended a launch event hosted by Amazon in New York City. After the event, Dr. Li received a
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`message from an Amazon employee in recruiting. Dr. Li responded with a message to be
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`forwarded to Rohit Prasad, currently Vice President and Head Scientist – Alexa Artificial
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`Intelligence, regarding the meeting between Li Creative and Lab126 and Li Creative’s issued and
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`pending patents. On information and belief, Mr. Prasad received Dr. Li’s message.
`
`28.
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`Amazon has a policy or practice of not reviewing the patents of others (including
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`instructing its employees to not review the patents of others). On information and belief, at least
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`the following employees of Amazon and/or its subsidiaries were aware of Vocalife’s patents but
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`adhered to Amazon’s established policy or practice of not reviewing the patents of others:
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`Aleksander Pance, Matthew Holland, Wei Li, Jerry Wu, and Rohit Prasad. Further, Amazon and/or
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`one or more of its subsidiaries have cited the Asserted Patents during prosecution of its own patent
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`applications.
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`29.
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`The ’371 Patent generally covers systems and methods for use in a microphone
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`array system. The invention described in the ’371 Patent was developed by Dr. Manli Zhu and Dr.
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`Qi Li. For example, the invention is implemented by infringing virtual assistant smart speakers
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`utilizing Amazon “Alexa” Technology. Upon information and belief, Amazon makes, uses, sells,
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`and/or imports infringing virtual assistant smart speakers, such as the Amazon Echo products.
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`6
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`30.
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`Amazon has also infringed and is continuing to infringe the ’371 Patent by
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`making, using, selling, offering to sell, and/or importing, and by actively inducing others to make,
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`use, sell, offer to sell, and/or importing, products including microphone array systems technology
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`and associated software that infringes the ’371 Patent. Such products include at least the Amazon
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`Alexa-enabled products including, but not limited to, the Amazon Echo products. Vocalife
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`manufactures and sells the CrispMic II, a smart microphone as a module for voice interactive
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`products. The CrispMic II is a multiple-microphone array module for smart speakers, robotic
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`devices, smart appliances, and other IoT platforms that require far-field voice capture, speech
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`recognition, and voice control. The CrispMic II is powered by Vocalife’s advanced DSP
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`algorithms developed over the past decade to suppress background noise, enhance speech
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`intelligibility, and improve automatic speech recognition accuracy.9
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`31.
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`Vocalife marks the CrispMic II product with the ’371 Patent and has complied
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`with 35 U.S.C. § 287.10
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`32.
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`Amazon’s infringement of the ’371 Patent is willful. Amazon continues to commit
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`acts of infringement despite a high likelihood that its actions constitute infringement, and Amazon
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`knew or should have known that its actions constituted an unjustifiably high risk of infringement.
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`COUNT I
`(Infringement of the ’371 Patent)
`
`33.
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`34.
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`Paragraphs 1 through 32 are incorporated by reference as if fully set forth herein.
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`Vocalife has not licensed or otherwise authorized Amazon to make, use, offer for
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`sale, sell, or import any products that embody the inventions of the ’371 Patent.
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`35.
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`Amazon has directly infringed and continues to directly infringe the ’371 Patent,
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`
`
`9 https://vocalife.com/wp-
`content/uploads/2019/02/Farfield_Mic_Developer_Module_Vocalife_Datasheet_4Feb2019.pdf.
`10 Id.
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`7
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`either literally or under the doctrine of equivalents, without authority and in violation of 35 U.S.C.
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`§ 271, by making, using, offering to sell, selling, and/or importing into the United States products
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`that satisfy each and every limitation of one or more claims of the ’371 Patent. Such products
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`include virtual assistant smart speakers and other hardware and software implementing a
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`microphone array system. On information and belief, infringing products include at least the Alexa
`
`enabled products, such as the Amazon Echo products.
`
`36.
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`For example, Amazon has and continues to directly infringe at least claim 26 of
`
`the ’371 Patent by making, using, offering to sell, selling, and/or importing into the United States
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`virtual assistant smart speakers that utilize a microphone array system.
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`37.
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`Upon information and belief, the Amazon Echo products include a microphone
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`array which is an array of sound sensors positioned in a linear, circular, or other configuration,
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`wherein said sound sensors receive said sound signals from a plurality of disparate sound sources,
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`wherein received sound signals comprise said target sound signal from a target sound source
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`among said disparate sound sources, and ambient noise signals. An image of Amazon’s Echo
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`product is shown below.11
`
`
`11 https://www.ifixit.com/Teardown/Amazon+Echo+Teardown/33953; Annotations in the image
`originate from https://www.ifixit.com/Teardown/Amazon+Echo+Teardown/33953. Green circles
`indicate the microphones located in Amazon’s Echo product.
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`8
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`Upon information and belief, the Amazon Echo products include a digital signal
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`38.
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`processor, such as digital signal processors (“DSP”), manufactured by third parties including
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`Texas Instruments, MediaTek, and AMLogic.
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`39.
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`Upon information and belief, the DSPs included in the Amazon Echo products
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`implement a sound source localization unit that estimates a spatial location of said target sound
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`signal from said received sound signals, by determining a delay between each of said sound sensors
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`and an origin of said array of said sound sensors as a function of distance between each of said
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`sound sensors and said origin, a predefined angle between each of said sound sensors and a
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`reference axis, and an azimuth angle between said reference axis and said target sound signal,
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`when said target sound source that emits said target sound signal is in a two-dimensional plane,
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`wherein said delay is represented in terms of number of samples, and wherein said determination
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`9
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`of said delay enables beamforming for arbitrary numbers of said array of sound sensors and in a
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`plurality of arbitrary configurations of said array of said sound sensors.12
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`40.
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`Upon information and belief, the DSPs included in the Amazon Echo products
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`implement an adaptive beamforming unit that steers directivity pattern of said array of said sound
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`sensors in a direction of said spatial location of said target sound signal, wherein said adaptive
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`beamforming unit enhances said target sound signal and partially suppresses said ambient noise
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`signals.13 An image of Amazon Echo’s sound source localization unit is shown below:14
`
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`Upon information and belief, the DSPs included in the Amazon Echo products
`
`41.
`
`
`12 https://developer.amazon.com/docs/alexa-voice-service/audio-hardware-
`configurations.html#hardware.
`13 Id.
`14 https://thewirecutter.com/reviews/amazon-echo-vs-google-home/; The beamforming
`technology is indicated by the light ring in Amazon Echo products which will turn solid blue
`upon hearing the “wake word” or when it is manually awakened, and a small section of the light
`ring will turn cyan and point in the direction of the sound. See
`https://www.amazon.com/gp/help/customer/display.html?nodeId=201601790; see also
`https://www.cnet.com/how-to/light-ring-colors-amazon-echo-alexa/.
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`10
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`implement a noise reduction unit that suppresses said ambient noise signals for further enhancing
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`said target sound signal.
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`42.
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`Upon information and belief, the DSPs included in the Amazon Echo products
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`implement an echo cancellation unit for performing echo cancellation for further enhancing said
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`target sound signal.
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`43.
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`For example, Amazon has and continues to directly infringe at least claim 34 of
`
`the ’371 Patent by making, using, offering to sell, selling, and/or importing into the United States
`
`virtual assistant smart speakers that utilize a microphone array system.
`
`44.
`
`Upon information and belief, the Amazon Echo products include a microphone
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`array, which is an array of sound sensors positioned in a linear, circular, or other configuration,
`
`wherein said sound sensors receive said sound signals from a plurality of disparate sound sources,
`
`wherein said received sound signals comprise said target sound signal from a target sound source
`
`among said disparate sound sources, and ambient noise signals. An image of Amazon’s Echo
`
`product is shown below:15
`
`
`15 https://www.ifixit.com/Teardown/Amazon+Echo+Teardown/33953; Annotations in the image
`originate from https://www.ifixit.com/Teardown/Amazon+Echo+Teardown/33953. Green circles
`indicate the microphones located in Amazon’s Echo product.
`
`
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`11
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`Upon information and belief, the Amazon Echo products include a digital signal
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`45.
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`processor, such as digital signal processors (“DSP”), manufactured by third parties including
`
`Texas Instruments, MediaTek, and AMLogic.
`
`46.
`
`Upon information and belief, the DSPs included in the Amazon Echo products
`
`comprise a sound source localization unit that estimates a spatial location of said target sound
`
`signal from said received sound signals, by determining a delay between each of said sound sensors
`
`and an origin of said array of said sound sensors as a function of distance between each of said
`
`sound sensors and said origin, a predefined angle between each of said sound sensors and a
`
`reference axis, and an azimuth angle between said reference axis and said target sound signal,
`
`when said target sound source that emits said target sound signal is in a two-dimensional plane,
`
`wherein said delay is represented in terms of number of samples, and wherein said determination
`
`
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`12
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`of said delay enables beamforming for arbitrary numbers of said array of sound sensors and in a
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`plurality of arbitrary configurations of said array of said sound sensors.16
`
`47.
`
`Upon information and belief, the DSPs included in the Amazon Echo products
`
`comprise an adaptive beamforming unit that steers directivity pattern of said array of said sound
`
`sensors in a direction of said spatial location of said target sound signal, wherein said adaptive
`
`beamforming unit enhances said target sound signal and partially suppresses said ambient noise
`
`signals.17 An image of Amazon Echo’s sound source localization unit is shown below:18
`
`48.
`
`Upon information and belief, the DSPs included in the Amazon Echo products
`
`
`
`
`16 https://developer.amazon.com/docs/alexa-voice-service/audio-hardware-
`configurations.html#hardware.
`17 Id.
`18 https://thewirecutter.com/reviews/amazon-echo-vs-google-home/; The beamforming
`technology is indicated by the light ring in Amazon Echo products which will turn solid blue
`upon hearing the “wake word” or when it is manually awakened, and a small section of the light
`ring will turn cyan and point in the direction of the sound. See
`https://www.amazon.com/gp/help/customer/display.html?nodeId=201601790; see also
`https://www.cnet.com/how-to/light-ring-colors-amazon-echo-alexa/.
`
`
`
`13
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`comprise a noise reduction unit that suppresses said ambient noise signals for further enhancing
`
`said target sound signal.
`
`49.
`
`Upon information and belief, the DSPs included in the Amazon Echo products
`
`comprise an echo cancellation unit that performs echo cancellation for further enhancing said
`
`target sound signal.
`
`50.
`
`Amazon has had knowledge and notice of the ’371 Patent at least as of the filing
`
`of the Complaint. On information and belief, Amazon and/or one or more of Amazon’s
`
`subsidiaries have cited the ’756 Patent and/or its application during prosecution of their own patent
`
`applications. Amazon has also had specific knowledge of the ’371 Patent as of the date when it
`
`was notified of the filing of this action.
`
`51.
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`Amazon has a policy or practice of not reviewing the patents of others (including
`
`instructing its employees to not review the patents of others), and thus has been willfully blind to
`
`Vocalife’s patent rights.
`
`52.
`
`On information and belief, Amazon and/or one or more of its subsidiaries19 had
`
`knowledge of the risk of infringement of the Asserted Patents or that said risk was so obvious that
`
`it should have been known.
`
`53.
`
`Amazon has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’371 Patent, as provided by 35 U.S.C. § 271(b), by inducing infringement by others,
`
`such as Amazon’s customers and end-users, in this District and elsewhere in the United States. For
`
`example, Amazon’s customers and end-users directly infringe, either literally or under the doctrine
`
`of equivalents, through their use of the inventions claimed in the ’371 Patent. Amazon induces this
`
`
`19 See Vocalife, LLC v. Amazon.com, Inc. and Amazon.com, LLC, Case No. 2:19-cv-00123-JRG,
`Dkt. 95-24 (E.D. Tex. Apr. 8, 2020) (“Amazon’s Stipulation Regarding Amazon and Lab126”).
`
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`14
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`direct infringement through its affirmative acts of manufacturing, selling, distributing, and/or
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`otherwise making available the Accused Products, and providing instructions, documentation, and
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`other information to customers and end-users suggesting that they use the Accused Products in an
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`infringing manner, including technical support, marketing, product manuals, advertisements, and
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`online documentation. Because of Amazon’s inducement, Amazon’s customers and end-users use
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`Accused Products in a way Amazon intends and directly infringe the ’371 Patent. Amazon
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`performs these affirmative acts with knowledge of the ’371 Patent and with the intent, or willful
`
`blindness, that the induced acts directly infringe the ’371 Patent.
`
`54.
`
`Amazon has indirectly infringed and continues to indirectly infringe one or more
`
`claims of the ’371 Patent, as provided by 35 U.S.C. § 271(c), by contributing to direct infringement
`
`by others, such as customers and end-users, in this District and elsewhere in the United States.
`
`Amazon’s affirmative acts of selling and offering to sell the Accused Products in this District and
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`elsewhere in the United States and causing the Accused Products to be manufactured, used, sold,
`
`and offered for sale contributes to others’ use and manufacture of the Accused Products such that
`
`the ’371 Patent is directly infringed by others. The accused components within the Accused
`
`Products are material to the invention of the ’371 Patent, are not staple articles or commodities of
`
`commerce, have no substantial non-infringing uses, and are known by Amazon to be especially
`
`made or adapted for use in the infringement of the ’371 Patent. Amazon performs these affirmative
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`acts with knowledge of the ’371 Patent and with intent, or willful blindness, that they cause the
`
`direct infringement of the ’371 Patent.
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`55.
`
`Because of Amazon’s direct and indirect infringement of the ’371 Patent, Vocalife
`
`has suffered damages, and will continue to suffer, damages in an amount to be proved at trial.
`
`56.
`
`Because of Amazon’s direct and indirect infringement of the ’371 Patent, Vocalife
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`Case 2:20-cv-00401-JRG Document 1 Filed 12/29/20 Page 16 of 17 PageID #: 16
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`has suffered, and will continue to suffer, irreparable harm for which there is no adequate remedy
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`at law, unless Amazon’s infringement is enjoined by this Court.
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`57.
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`Amazon has committed and continues to commit acts of infringement that
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`Amazon actually knew or should have known constituted an unjustifiably high risk of infringement
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`of at least one valid and enforceable claim of the ʼ371 Patent. Amazon’s direct and indirect
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`infringement of the ʼ371 Patent has been and continues to be willful, intentional, deliberate, and/or
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`in conscious disregard of Vocalife’s rights under the patent. Vocalife is entitled to an award of
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`treble damages, reasonable attorney fees, and costs in bringing this action.
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`DEMAND FOR JURY TRIAL
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`Plaintiff hereby demands a jury for all issues so triable.
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`PRAYER FOR RELIEF
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`WHEREFORE, Vocalife prays for relief against Amazon as follows:
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`a.
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`Entry of judgment declaring that Amazon infringes one or more claims of the
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`’371 Patent;
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`b.
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`Entry of judgment declaring that Amazon’s infringement of the ’371 Patent is
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`willful;
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`c.
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`An order awarding damages sufficient to compensate Vocalife for Amazon’s
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`infringement of the ’371 Patent, but in no event less than a reasonably royalty, including
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`supplemental damages post-verdict, together with pre-judgment and post-judgment interest and
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`costs;
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`d.
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`e.
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`Enhanced damages pursuant to 35 U.S.C. § 284;
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`Entry of judgment declaring that this case is exceptional and awarding Vocalife
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`its costs and reasonable attorney fees under 35 U.S.C. § 285;
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`Case 2:20-cv-00401-JRG Document 1 Filed 12/29/20 Page 17 of 17 PageID #: 17
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`An accounting for acts of infringement;
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`Such other equitable relief which may be requested and to which the Plaintiff is
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`f.
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`g.
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`entitled; and
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`h.
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`Such other and further relief as the Court deems just and proper.
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`Dated: December 29, 2020
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`Respectfully submitted,
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`
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`/s/ Alfred R. Fabricant
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`FABRICANT LLP
`230 Park Avenue, 3rd Floor W.
`New York, NY 10169
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`Email: sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`Email: jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`
`ATTORNEYS FOR PLAINTIFF
`VOCALIFE LLC
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`17
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