`KT IMAGING USA, LLC,
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`
`
`
`
`
`
`
`
`Plaintiff
`
`
`-against-
`
`SAMSUNG ELECTRONICS CO., LTD. and,
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`
`
`
`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 1 of 15 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`
`
`
`
`Civil Action No.: 4:20-cv-339
`
`Jury Trial Demanded
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`
`
`
`
`
`
`Defendants
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff KT Imaging USA, LLC (“KTI” or “Plaintiff”), by way of this Complaint against
`
`Defendants Samsung Electronics Co., Ltd. (“Samsung-Korea”) and Samsung Electronics
`
`America, Inc. (“Samsung-America”) (collectively “Samsung” or “Defendants”), alleges as
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`follows:
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`PARTIES
`
`1.
`
`Plaintiff KT Imaging USA, LLC is a limited liability company organized and existing
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`under the laws of the State of Texas, having its principal place of business at 106 E 6th Street, Suite
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`900, Austin, TX 78701.
`
`2.
`
`On information and belief, Defendant Samsung-Korea is a corporation organized and
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`existing under the laws of the Republic of Korea with its principal place of business at 129
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`Samsung-Ro, Yeongtong-gu, Suwon, Gyeonggi-do, 16677 Korea.
`
`3.
`
`On information and belief, Defendant Samsung-America is a wholly-owned subsidiary of
`
`Samsung-Korea. On information and belief, Samsung-America is a New York corporation, with
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`1
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`

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`its principal place of business at 85 Challenger Road, Ridgefield Park, New Jersey 07660.
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`Samsung-America is registered to do business in the state of Texas and has maintained a regular
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`and established place of business with offices and/or other facilities in this Judicial District at, at
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`least, 6625 Excellence Way, Plano, Texas 75023. On information and belief, Samsung-America
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`can be served with process through its agent CT Corporation System, 1999 Bryan Street, Suite
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`900, Dallas, TX 75201.
`
`JURISDICTION AND VENUE
`
`4.
`
`This is an action under the patent laws of the United States, 35 U.S.C. §§ 1, et seq., for
`
`infringement by Samsung of claims of U.S. Patent No. 6,590,269 and its Ex Parte Reexamination
`
`Certificate; U.S. Patent No. 6,876,544; U.S. Patent No. 7,196,322; U.S. Patent No. 7,511261; U.S.
`
`Patent No. 8,004,602; and U.S. Patent No. 8,314,481 (collectively “the Patents-in-Suit”).
`
`5.
`
`6.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`Samsung-Korea is subject to personal jurisdiction of this Court because, inter alia, on
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`information and belief, (i) Samsung-Korea has committed and continues to commit acts of patent
`
`infringement in the State of Texas, including by making, using, offering to sell, selling, and/or
`
`importing the accused products into Texas; (ii) Samsung-Korea purposefully supplies and directs
`
`the accused products for storage, warehousing, and sales by distributors and resellers in the State
`
`of Texas; and (iii) Samsung-Korea delivers its products into the stream of commerce with the
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`expectation that they will be purchased by consumers in the State of Texas. In addition, or in the
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`alternative, this Court has personal jurisdiction over Samsung-Korea pursuant to Fed. R. Civ. P.
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`4(k)(2).
`
`7.
`
`Samsung-America is subject to personal jurisdiction of this Court because, inter alia, on
`
`information and belief, (i) Samsung-America has committed and continues to commit acts of
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`2
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`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 3 of 15 PageID #: 3
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`patent infringement in the State of Texas, including by making, using, offering to sell, selling,
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`and/or importing the accused products into Texas; (ii) Samsung-America purposefully supplies
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`and directs the accused products for storage, warehousing, and sales by distributors and resellers
`
`in the State of Texas; (iii) Samsung-America delivers its products into the stream of commerce
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`with the expectation that they will be purchased by consumers in the State of Texas; (iv) derives
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`substantial revenue from its activities in this District; and (v) has purposefully established
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`substantial, systematic and continuous contacts with this District such that it should reasonably
`
`expect to be haled into court in this District.
`
`8.
`
`Venue is proper as to Samsung-Korea in this District under 28 U.S.C. § 1391(c) because,
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`inter alia, Samsung-Korea is a foreign corporation.
`
`9.
`
`Venue is proper as to Samsung-America in this District under 28 U.S.C. § 1400(b) because,
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`inter alia, on information and belief, Samsung-America has committed acts of infringement in the
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`District and/or has contributed to or induced acts of patent infringement by others in this District,
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`and has a regular and established place of business within the District. For example, on
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`information and belief, Samsung-America has offices at 6625 Excellence Way, Plano, Texas
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`75023.
`
`BACKGROUND
`
`10.
`
`On July 8, 2003, the United States Patent and Trademark Office duly and lawfully issued
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`U.S. Patent No. 6,590,269 (“the ’269 Patent”), entitled “Package Structure for a Photosensitive
`
`Chip.”
`
`11.
`
`On April 5, 2005, the United States Patent and Trademark Office duly and lawfully issued
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`U.S. Patent No. 6,876,544 (“the ’544 Patent”), entitled “Image Sensor Module and Method for
`
`Manufacturing the Same.”
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`3
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`

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`12.
`
`On March 27, 2007, the United States Patent and Trademark Office duly and lawfully
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`issued U.S. Patent No. 7,196,322 (“the ’322 Patent”), entitled “Image Sensor Package.”
`
`13.
`
`On March 31, 2009, the United States Patent and Trademark Office duly and lawfully
`
`issued U.S. Patent No. 7,511,261 (“the ’261 Patent”), entitled “Image Sensor Module Structure
`
`With Lens Holder Having Vertical Inner and Outer Sidewalls.”
`
`14.
`
`On August 23, 2011, the United States Patent and Trademark Office duly and lawfully
`
`issued U.S. Patent No. 8,004,602 (“the ’602 Patent”), entitled “Image Sensor Structure And
`
`Integrated Lens Module Thereof.”
`
`15.
`
`On November 20, 2012, the United States Patent and Trademark Office duly and lawfully
`
`issued U.S. Patent No. 8,314,481 (“the ’481 Patent”), entitled “Substrate Structure for an Image
`
`Sensor Package and Method for Manufacturing the Same.”
`
`16.
`
`KTI is the assignee and owner of the right, title, and interest in and to the Patents-in-Suit,
`
`including the right to assert all causes of action arising under said patents and the right to any
`
`remedies for infringement of them.
`
`17.
`
`On March 11, 2019, KTI notified Samsung of the existence of the ’544, ’322, ’261,
`
`and ’602 Patents.
`
`18.
`
`Samsung has infringed and continues to infringe the Patents-in-Suit by making, using,
`
`selling, or offering for sale in the United States, or importing into the United States smartphones,
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`tablets, and laptops with front and/or rear image sensor technology claimed in the Patents-in-Suit.
`
`Attachment A to this Complaint provides a non-exhaustive listing of Accused Products.
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`Attachment B to this Complaint provides a listing of Exhibits comprising exemplary teardown
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`images for certain Accused Products.
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`
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`4
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`COUNT I: INFRINGEMENT OF THE ’269 PATENT BY SAMSUNG
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`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’269 Patent pursuant to 35 U.S.C. §
`
`19.
`
`20.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`the United States or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`21.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 2 of the ’269 Patent by including a rear facing package structure including a
`
`photosensitive chip in the Samsung Note 3 product. See Ex.1 (Samsung Note 3 rear facing package
`
`structure). The rear facing package structure in the Accused Products comprises a substrate having
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`an upper surface and a lower surface opposite to the upper surface. See Ex. 2. The rear facing
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`package structure further comprises a frame layer having a first surface and a second surface
`
`opposite to the first surface, the frame layer being formed on the substrate with the first surface
`
`contacting the upper surface of the substrate, so as to form a cavity with the substrate. See Ex. 1.
`
`The rear facing package structure further comprises a photosensitive chip placed on the upper
`
`surface of the substrate and within the cavity. See Ex. 1. The rear facing package structure further
`
`comprises a plurality of wires for electrically connecting the substrate to the photosensitive chip.
`
`See Ex. 3. The rear facing package structure further comprises a transparent layer arranged on the
`
`frame layer to cover the photosensitive chip, wherein the second surface of the frame layer is
`
`formed with a depression in which the transparent layer is placed to cover the photosensitive chip.
`
`See Exs. 1 and 4. The rear facing package further comprises a plurality of projections each having
`
`a suitable height and formed within depression layer of the frame layer. See Ex. 5.
`
`22.
`
`On information and belief, Samsung has induced infringement of the ’269 Patent pursuant
`
`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`5
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`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`23.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`COUNT II: INFRINGEMENT OF THE ’544 PATENT BY SAMSUNG
`
`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’544 Patent pursuant to 35 U.S.C. §
`
`24.
`
`25.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`the United States or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`26.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 1 of the ’544 Patent by including an image sensor module to be mounted to a printed
`
`circuit board in the Samsung Tab A10.1 product. See Ex. 6 (Samsung Tab A10.1” front facing
`
`image sensor). The front facing image sensor module in the Accused Products comprises a
`
`substrate having an upper surface formed with a plurality of first connection points and a lower
`
`surface formed with a plurality of second connection points, which is electrically connected to the
`
`printed circuit board. See Exs. 7-8 (Samsung Tab A10.1” front facing image sensor). The image
`
`sensor module further comprises a photosensitive chip mounted to the upper surface of the
`
`substrate. See Ex. 6 (Samsung Tab A10.1” front facing image sensor). The image sensor module
`
`further comprises a plurality of wires for electrically connecting the photosensitive chip to the first
`
`6
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`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 7 of 15 PageID #: 7
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`connection points on the upper surface of the substrate. See Ex. 8 (Samsung Tab A10.1” front
`
`facing image sensor). The image sensor module further comprises a frame layer mounted to the
`
`upper surface of the substrate to surround the photosensitive chip, an inner edge of the frame layer
`
`being formed with an internal thread from top to bottom, and a transparent layer being fixed by
`
`the frame layer such that the photosensitive chip may receive optical signals passing through the
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`transparent layer. See Exs. 6-7, 9 (Samsung Tab A10.1” front facing image sensor). The image
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`sensor module further comprises a lens barrel formed with a chamber at a center thereof and an
`
`external thread at an outer edge thereof, the external thread being screwed to the internal thread of
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`the frame layer, wherein the lens barrel has a through hole and an aspheric lens from top to bottom.
`
`See Exs. 6, 10-11 (Samsung Tab A10.1” front facing image sensor).
`
`27.
`
`On information and belief, Samsung has induced infringement of the ’544 Patent pursuant
`
`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`28.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`COUNT III: INFRINGEMENT OF THE ’322 PATENT BY SAMSUNG
`
`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’322 Patent pursuant to 35 U.S.C. §
`
`29.
`
`30.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`7
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`the United States or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`31.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 1 of the ’322 Patent by including an image sensor module in the Samsung Note 5
`
`product. See Ex. 12 (front facing image sensor of the Samsung Note 5 model). The image sensor
`
`module in the Accused Products comprises a substrate having an upper surface, and a lower surface
`
`on which second electrodes are formed, and a frame layer arranged on the upper surface of the
`
`substrate, a cavity formed between the frame layer and substrate, and a plurality of first electrodes
`
`are formed on the frame layer. See Exs. 12-13 (front facing image sensor of the Samsung Note 5
`
`model). The image sensor module in the Accused Products further comprises a photosensitive
`
`chip mounted on the upper surface of the substrate and located within the cavity, and electrically
`
`connected to the first electrodes of the frame layer. See Exs. 12, 14-15 (front facing image sensor
`
`of the Samsung Note 5 model). The image sensor module in the Accused Products further
`
`comprises a lens holder having an upper end face, a lower end face, and an opening penetrating
`
`through the lens holder from the upper end face to the lower end face, the upper end of the opening
`
`formed with an internal thread and the lower end of the opening formed with a breach, so that the
`
`internal diameter of the upper end of the opening is smaller than the lower end of the opening, the
`
`lens holder adhered on the upper surface of the substrate by glue, wherein, the frame layer is
`
`located within the breach of the lens holder. See Exs. 12, 15-16 (front facing image sensor of the
`
`Samsung Note 5 model). The image sensor module of the Accused Products further comprises a
`
`lens barrel having an upper end face, a lower end face, and an external thread screwed to the
`
`internal thread of the lens holder. See Exs. 12, 16-17 (front facing image sensor of the Samsung
`
`Note 5 model).
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`8
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`32.
`
`On information and belief, Samsung has induced infringement of the ’322 Patent pursuant
`
`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`33.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`COUNT IV: INFRINGEMENT OF THE ’261 PATENT BY SAMSUNG
`
`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’261 Patent pursuant to 35 U.S.C. §
`
`34.
`
`35.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`the United States, or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`36.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 1 of the ’261 Patent by including an image sensor module structure in the Galaxy A9
`
`product. See Ex. 18 (cross-sectional image of the front facing image sensor in the Samsung Galaxy
`
`A9 model). The image sensor module structure in the Accused Products comprises a substrate
`
`having a horizontal upper surface on which first electrodes are formed, and a lower surface on
`
`which second electrodes are formed, wherein the first electrodes are correspondingly and
`
`electrically connected to the second electrodes. See Exs. 18-20. The image sensor module
`
`structure in the Accused Products comprises a photosensitive chip mounted on the upper surface
`
`9
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`of the substrate, and electrically connected to the first electrodes of the substrate by wires. See
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`Exs. 20-21. The image sensor module further comprises a lens holder having an upper end face,
`
`a lower end face, and an opening penetrating through the lens holder from the upper end face to
`
`the lower end face, wherein an upper end portion of the opening is formed with an internal thread
`
`and a lower end portion of the opening is formed with a breach so that an internal diameter of the
`
`upper end portion of the opening is smaller than an internal diameter of the lower end portion of
`
`the opening, the lens holder is adhered to the upper surface of the substrate by glue, the
`
`photosensitive chip is located within the opening of the lens holder, the glue is filled within the
`
`breach of the lens holder and coated over the wires, the lens holder has a vertical inner sidewall
`
`and a vertical outer sidewall, the vertical inner sidewall is connected to the breach at a portion,
`
`which is located at a level higher than a level of the photosensitive chip, a portion of each of the
`
`wires is located under the breach, and an outer diameter of the lens holder corresponding to the
`
`internal diameter of the upper end portion of the opening is substantially equal to an outer diameter
`
`of the lens holder corresponding to the internal diameter of the lower end portion of the opening.
`
`See Exs. 18-19, 22. The image sensor module further comprises a lens barrel having an upper end
`
`face, a lower end face, and an external thread crewed to the internal thread of the lens holder. See
`
`Ex. 18 and 23.
`
`37.
`
`On information and belief, Samsung has induced infringement of the ’261 Patent pursuant
`
`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`10
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`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`38.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`COUNT V: INFRINGEMENT OF THE ’602 PATENT BY SAMSUNG
`
`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’602 Patent pursuant to 35 U.S.C. §
`
`39.
`
`40.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`the United States, or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`41.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 1 of the ’602 Patent by including an image sensor structure with an integrated lens
`
`module in the Chromebook 3 product. See Ex. 30 (cross-sectional images of the front facing
`
`camera in the Samsung Chromebook 3 model). The image sensor structure in the Accused
`
`Products comprises a chip having a plurality of light-sensing elements arranged on a light sensing
`
`area of a first surface of the chip, a plurality of first conducting pads arranged around the light-
`
`sensing area and electrically connected to the light-sensing elements, and at least one conducting
`
`channel passing through the chip and electrically connected to the first conducting pads at one end
`
`as well as extending along with a second surface of the chip. See Exs.30-33. The image sensor
`
`structure in the Accused Products comprises a lens module comprising a holder having a through
`
`hole and a contact surface on a bottom of the holder, wherein the contact surface is combined with
`
`the first surface, and at least one lens completely embedded inside the through hole and integrated
`
`with the holder. See Ex. 30.
`
`42.
`
`On information and belief, Samsung has induced infringement of the ’602 Patent pursuant
`
`11
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`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 12 of 15 PageID #: 12
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`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`43.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`COUNT VI: INFRINGEMENT OF THE ’481 PATENT BY SAMSUNG
`
`Plaintiff incorporates the preceding paragraphs as if fully set forth herein.
`
`On information and belief, Samsung has infringed the ’481 Patent pursuant to 35 U.S.C. §
`
`44.
`
`45.
`
`271(a), literally or under the doctrine of equivalents, by making, using, offering to sell, selling in
`
`the United States, or importing into the United States the Accused Products and all other products
`
`with substantially similar imaging sensors.
`
`46.
`
`For example, on information and belief, Samsung has infringed and continues to infringe
`
`at least claim 1 of the ’481 Patent by including a substrate structure for an image sensor package
`
`in the Note 4 product. See Ex. 34 (Samsung Note 4 rear facing image sensor). The substrate
`
`structure in the Accused Products comprises a bottom base having an upper surface formed with a
`
`plurality of first electrodes, and a lower surface formed with a plurality of second electrodes,
`
`wherein an insulation layer is coated between first electrodes and in direct surface contact with the
`
`upper surface of the bottom base. See Exs. 35-36 (Samsung Note 4 rear facing image sensor). The
`
`substrate structure in the Accused Products comprises a frame layer arranged on and in direct
`
`surface contact with the first electrodes and the insulation layer to form a cavity together with the
`
`12
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`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 13 of 15 PageID #: 13
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`bottom base, wherein the insulation layer is interposed between the bottom base and the frame
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`layer. See Exs. 35 and 37 (Samsung Note 4 rear facing image sensor).
`
`47.
`
`On information and belief, Samsung has induced infringement of the ’481 Patent pursuant
`
`to 35 U.S.C. § 271(b), by actively and knowingly inducing, directing, causing, and encouraging
`
`others, including, but not limited to, its partners, resellers, distributers, customers, and end users,
`
`to make, use, sell, and/or offer to sell in the United States, and/or import into the United States,
`
`the Accused Products by, among other things, providing the accused products and incorporated
`
`image sensor technology, specifications, instructions, manuals, advertisements, marketing
`
`materials, and technical assistance relating to the installation, set up, use, operation, and
`
`maintenance of said products.
`
`48.
`
`On information and belief, Samsung has committed the foregoing infringing activities
`
`without a license.
`
`
`
`WHEREFORE, KTI prays for judgment in its favor against Samsung for the following
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`PRAYER FOR RELIEF
`
`relief:
`
`A.
`
`B.
`
`C.
`
`D.
`
`Entry of judgment in favor of KTI against Samsung on all counts;
`
`Entry of judgment that Samsung has infringed the Patent-in-Suit;
`
`An order permanently enjoining Samsung from infringing the Patent-in-Suit;
`
`Award of compensatory damages adequate to compensate KTI for Samsung’s
`
`infringement of the Patent-in-Suit, in no event less than a reasonable royalty trebled as provided
`
`by 35 U.S.C. § 284;
`
`E.
`
`Award of reasonable attorneys’ fees and expenses against Samsung pursuant to 35
`
`U.S.C. § 285;
`
`13
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`

`

`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 14 of 15 PageID #: 14
`
`F.
`
`G.
`
`H.
`
`KTI’s costs;
`
`Pre-judgment and post-judgment interest on KTI’s award; and
`
`All such other and further relief as the Court deems just or equitable.
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Rule 38 of the Fed. R. Civ. Proc., Plaintiff hereby demands trial by jury in this
`
`action of all claims so triable.
`
`Dated: April 20, 2020
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Stafford Davis
`Stafford Davis
`State Bar No. 24054605
`sdavis@stafforddavisfirm.com
`Catherine Bartles
`State Bar No. 24104849
`cbartles@stafforddavisfirm.com
`THE STAFFORD DAVIS FIRM, PC
`815 South Broadway
`Tyler, Texas 75702
`Tel: (903) 593-7000
`Fax: (903) 705-7369
`
`Dmitry Kheyfits
`dkheyfits@kblit.com
`KHEYFITS BELENKY LLP
`7500 Rialto Boulevard, Suite 250
`Austin, TX 78735
`Tel: 737-228-1838
`Fax: 737-228-1843
`
`Brandon G. Moore
`KHEYFITS BELENKY LLP
`7500 Rialto Boulevard, Bldg. 1
`Suite 250
`Austin, TX 78735
`Tel: 737-228-1838
`Fax: 737-228-1843
`
`
`14
`
`

`

`Case 4:20-cv-00339-ALM Document 1 Filed 04/20/20 Page 15 of 15 PageID #: 15
`
`Andrey Belenky
`abelenky@kblit.com
`KHEYFITS BELENKY LLP
`1140 Avenue of the Americas, 9th Floor
`New York, NY 10036
`Tel: 212-203-5399
`Fax: 212-203-5399
`
`Attorneys for Plaintiff
`KT Imaging USA, LLC
`
`
`
`15
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`