Case 4:21-cv-00859 Document 1 Filed on 03/16/21 in TXSD Page 1 of 17
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`DISH NETWORK L.L.C.,
`Plaintiff,
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`§
`§ Civil Action No. 4:21-cv-859
`§
`§
`§
`v.
`§
`DINESH VIGNESWARAN, d/b/a ChitramTV §
`§
`Canada and Chitram.ca, and DOES 1-10,
`individually and together d/b/a ChitramTV and §
`Chitram.tv,
`§
`§
`§
`
`Defendants.
`
`COMPLAINT
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`Plaintiff DISH Network L.L.C. (“DISH”) brings this suit against Dinesh Vigneswaran,
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`d/b/a ChitramTV Canada and Chitram.ca (“Vigneswaran”) and DOES 1-10, individually and
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`together d/b/a ChitramTV and Chitram.tv (collectively, “Chitram” and with Vigneswaran,
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`“Defendants”), and states as follows:
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`Nature of the Action
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`1.
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`DISH brings this suit for direct and contributory copyright infringement because
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`Chitram is taking television channels exclusively licensed to DISH and is unlawfully retransmitting
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`these channels throughout the United States on Defendants’ ChitramTV service (the “Chitram
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`Service”) to customers who purchase Defendants’ Chitram set-top boxes and Chitram Service
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`subscriptions (“Chitram Subscriptions”). Vigneswaran is materially contributing to and inducing
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`direct copyright infringement by Chitram. Defendants demonstrated the willfulness of their
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`copyright infringement by Chitram continuing to transmit channels exclusively licensed to DISH,
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`and Defendants continuing to distribute the Chitram Service, despite receiving demands to cease.
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`

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`Parties
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`2.
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`Plaintiff DISH Network L.L.C. is a limited liability company organized under the
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`laws of the State of Colorado, with its principal place of business located at 9601 South Meridian
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`Blvd., Englewood, Colorado 80112.
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`3.
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`Defendants DOES 1-10 are individuals or entities doing business as ChitramTV and
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`Chitram.tv. Chitram transmits television channels to users of the Chitram Service and distributes,
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`sells, and promotes Chitram set-top boxes and Chitram Subscriptions that provide access to the
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`Chitram Service. Chitram owns and operates the Chitram.tv domain and website (“Chitram.tv”)
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`and the Thulsi.net domain. Chitram has been assigned the computer servers identified by the
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`following
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`Internet Protocol (“IP”) addresses: 5.45.75.130; 45.178.7.78; 87.255.35.151;
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`89.248.173.151; 91.224.187.34; 91.230.121.93; 93.125.70.2; 93.125.70.4; 179.43.144.190;
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`185.39.11.72; 185.69.16.139; 185.69.19.21; 185.196.9.182; and 185.216.140.82. Chitram.tv states
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`“[w]e are located in Germany-: Head office, United Kingdom and United States of America.” A
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`Germany based phone number is listed on the Chitram.tv website. DISH believes discovery will
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`identify DOES 1-10 and enable DISH to amend the complaint to list them by name.
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`4.
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`Defendant Dinesh Vigneswaran, also known as Dinesh Vicky, is an individual
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`residing in Toronto, Ontario, Canada. Vigneswaran does business as ChitramTV Canada and
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`Chitram.ca and he owns and operates the Chitram.ca domain and website (“Chitram.ca”).
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`Vigneswaran is Chitram’s “US Manager” in charge of United States resellers of Chitram set-top
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`boxes and Chitram Subscriptions. Vigneswaran distributes, sells, and promotes Chitram set-top
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`boxes and Chitram Subscriptions that provide access to the Chitram Service.
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`2
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`Jurisdiction and Venue
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`5.
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`DISH asserts claims under the Copyright Act, 17 U.S.C. § 101 et seq. This Court
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`has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338.
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`6.
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`Personal jurisdiction is proper against Defendants under Rule 4(k)(2) of the Federal
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`Rules of Civil Procedure. Chitram transmits channels exclusively licensed to DISH to Chitram
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`Service users located in the United States (“Service Users”), including in the State of Texas.
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`Defendants distribute, sell, and promote Chitram set-top boxes and Chitram Subscriptions to
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`Service Users and resellers located in the United States, including in the State of Texas. This
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`Court’s exercise of jurisdiction over Defendants is consistent with the Constitution and laws of the
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`United States, DISH’s claims arise under federal law, and Defendants are not subject to the
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`jurisdiction of the courts of general jurisdiction of any state.
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`7.
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`Chitram promotes the Chitram Service to Service Users on Chitram.tv as offering
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`“Free Worldwide Shipping,” a “Sales & Support” phone number in the USA, and permits Service
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`Users to “Shop Online” and purchase Chitram set-top boxes and Chitram Subscriptions by adding
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`them to a shopping “Cart.”
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`3
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`8.
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`Vigneswaran listed five of his resellers of Chitram set-top boxes and Chitram
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`Subscriptions in the United States on Chitram.ca, including one reseller in Missouri City, Texas.
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`
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`
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`9.
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`Vigneswaran has approximately 60 resellers of Chitram set-top boxes and Chitram
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`Subscriptions in the United States and a warehouse of Chitram set-top boxes in the United States.
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`10.
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`Venue is proper in this Court under 28 U.S.C. § 1391(b)(3) because Defendants are
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`subject to personal jurisdiction in this district and under § 1391(c)(3) because Defendants are
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`nonresidents that may be sued in any judicial district. Venue is also proper in this Court under 28
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`U.S.C. § 1400(a) because the case involves violations of the Copyright Act.
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`DISH’s Copyrights
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`11.
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`DISH is the fourth largest pay-television provider in the United States providing
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`copyrighted programming to millions of subscribers nationwide. DISH is one of the largest
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`providers of international television channels in the United States offering more than 400 channels
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`in 27 different languages.
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`12.
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`DISH contracts for and licenses rights for the international channels distributed on
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`its platform from channel owners and their agents, including ARY Digital USA LLC; B4U U.S.;
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`4
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`Bennett, Coleman and Company Limited; Geo USA Holdings, Inc. d/b/a Geo USA LLC; Hum
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`Network Limited; MSM Asia Limited; National Communications Services (SMC-PVT.) Limited;
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`Television Media Network (Pvt) Ltd; and TV Today Network Ltd. (collectively, the “Networks”).
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`13.
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`The Networks’ channels include Aaj Tak; ARY Digital; ARY News; B4U Movies;
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`B4U Music; Dunya TV; Express Entertainment; Express News; Geo News; Geo TV; Hum Masala;
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`Hum Sitaray; Hum TV; India Today; SAB; SET (a/k/a Sony SET); SET MAX; Times Now; and
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`Zoom (collectively, the “Protected Channels”). The Networks acquire copyrights in the works that
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`air on their respective channels, including by producing the works and by assignment.
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`14.
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`DISH entered into signed, written licensing agreements with the Networks granting
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`DISH the exclusive right to distribute and publicly perform the Protected Channels and works that
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`air on the Protected Channels in the United States by means including satellite, over-the-top
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`(“OTT”), Internet protocol television (“IPTV”), and Internet. DISH’s exclusive rights were in
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`effect at all relevant times and are currently in effect. Many of the works that aired on the Protected
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`Channels and for which DISH holds exclusive distribution and public performance rights are
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`registered with the United States Copyright Office. (See Exhibit 1.) A vast number of additional,
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`unregistered copyrighted works in which DISH holds exclusive distribution and public performance
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`rights also aired on the Protected Channels. (See Exhibit 2.)
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`15.
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`Defendants are not authorized by DISH to transmit, distribute, or publicly perform
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`the Protected Channels or works that air on those channels in the United States, and DISH has
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`received no compensation from Defendants to do so.
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`5
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`Defendants’ Wrongful Conduct
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`16.
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`Chitram distributes, sells, and promotes Chitram set-top boxes and Chitram
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`Subscriptions to Service Users and resellers, including Vigneswaran, with knowledge that those
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`resellers, including Vigneswaran, distribute, sell, and promote them to Service Users.
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`17.
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`Chitram promoted the Chitram Service on Chitram.tv as providing “Over 500
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`Channels and 10,000 Movies,” “more than 200 Channels . . . of Indian Television,” “WATCH ALL
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`THE POPULAR CHANNELS & MOVIES YOU WANT,” and “Watch all your favourite Indian
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`TV Channel Programs.”
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`18.
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`Vigneswaran promotes the Chitram Service on Chitram.ca as having “150+ HD
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`QUALITY CHANNELS.”
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`
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`19.
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`Chitram.tv and Chitram.ca included links to Defendants’ Facebook, Twitter,
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`Google+, and YouTube accounts that Defendants used to promote the Chitram Service.
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`20.
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`Chitram uses their Chitram Service to transmit the Protected Channels to Service
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`Users soon after the original authorized transmission. Chitram takes broadcasts or streams of the
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`Protected Channels, transfers them to one or more computer servers provided, controlled, and
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`maintained by Chitram, and then transmits the Protected Channels to Service Users through OTT
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`delivery to subscribers in the United States.
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`21.
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`Chitram is directly responsible for the transmission of the channels on the Chitram
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`Service, including the Protected Channels, as shown by claims on Chitram.tv that they are “one of
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`the major IPTV service provider worldwide offering content” and “[o]ur team of professionals have
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`many years of experience with IPTV, STB and Middleware, and have the expertise in building and
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`operating complete head-end systems.”
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`7
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`22.
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`Defendants promote their Chitram Service with features including Catchup TV and
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`Timeshift. The Catchup TV feature is described on Chitram.tv and Chitram.ca as “14 days after
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`live broadcasting, you can still watch your missed favourite TV shows & Serials.” Chitram.tv and
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`Chitram.ca state that the Timeshift feature “allows you as a subscriber, living in different time
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`zones, to customize and watch TV shows at your convenience.” The Catchup TV and Timeshift
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`features mean that Chitram saves a copy of the original broadcast of the channels onto their servers
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`and makes them available on-demand or after a delay at different times to appeal to users in different
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`countries and time zones. The Timeshift feature allows Service Users to watch programming from
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`the Protected Channels in the United States during approximately the same time of the day that the
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`programming aired in Pakistan and India.
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`23.
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`Chitram controls the channels that they transmit on the Chitram Service. Chitram.tv
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`states “[w]e reserve the right to change the list of TV channels included in the package. Also, we
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`can add channels to the package.”
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`24.
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`Chitram transmits the Protected Channels to Service Users with its assigned
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`computer servers hosted by content delivery networks (“CDNs) DaNet Service B.V.; Novogara
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`BV; Serverius Holding B.V.; Private Layer Inc.; Swiss Global Services S.A.S.; Owl Protect LLC;
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`8
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`Virtual Systems LLC; Budovit S.R.O.; International Hosting Solutions LLP; Network Dedicated
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`SAS; Simple Carrier LLC; and IP Volume Inc.1
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`25.
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`Any member of the public with Internet access, including Service Users, can receive
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`the Protected Channels by simply: (1) purchasing a Chitram set-top box with a Chitram
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`Subscription; powering on the device; inserting the included Subscription ID into the Chitram set-
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`top box, and selecting the Protected Channels; or (2) purchasing a Chitram Subscription;
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`downloading a Chitram app from Chitram.tv or Chitram.ca to a compatible device such as an
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`Android TV, Android phone or tablet, Firestick, computer with a Windows or Mac operating
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`system, or Linux system; inserting the Chitram Subscription ID into the Chitram app; and selecting
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`the Protected Channels.
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`26.
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`Chitram.tv includes a “BUY NOW” page that permits consumers to “Login and
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`Buy” to add a Chitram set-top box or Chitram Subscription to a shopping cart, where Chitram sells
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`their Chitram set-top box for approximately $149, with a one year Chitram Subscription for
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`accessing the channels. Service Users who want to continue to receive the channels after the initial
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`subscription period must purchase a fourteen month Chitram Subscription renewal for
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`approximately $115. Chitram also sells a six month Chitram Subscription for accessing the
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`channels for approximately $70.
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`27.
`
`On October 19, 2020, DISH’s investigator contacted a Chitram reseller who owns
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`and operates the Chitram.co.uk domain and website, through WhatsApp at +447721380843 to
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`1 The computer servers Chitram is using to transmit the Protected Channels are identified by IP
`addresses: 5.45.75.130; 89.248.173.151; 91.230.121.93; and 179.43.144.190. Other computer
`servers Chitram used to transmit the Protected Channels include those identified by IP addresses:
`45.178.7.78; 87.255.35.151; 91.224.187.34;
` 93.125.70.2; 93.125.70.4; 185.39.11.72;
`185.69.16.139; 185.69.19.21; 185.196.9.182; and 185.216.140.82.
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`9
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`inquire about becoming a reseller of Chitram set-top boxes and Chitram Subscriptions in the United
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`States. The Chitram reseller referred DISH’s investigator to their Chitram supplier in Germany.
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`28.
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`DISH’s investigator received a call from Chitram on the same day from
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`+4915171817123. Chitram introduced themselves stating they were calling because “you spoke to
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`our dealer in the UK.” Chitram explained they are the main Chitram company that is headquartered
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`in Germany, Chitram set-top boxes would be shipped from Canada or the United States, and that
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`Chitram’s “US manager” would call and provide all the information.
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`29.
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`On the same day, DISH’s investigator received a call from Vigneswaran from 647-
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`262-8404. Vigneswaran introduced himself stating “I got your number from ChitramTV in
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`Europe.” Vigneswaran explained Chitram has one subscription package for the United States and
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`Canada and described the pricing for Chitram set-top boxes and Chitram Subscriptions.
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`Vigneswaran offered to sell Chitram set-top boxes with a 12 month Chitram Subscription to the
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`channels, including the Protected Channels, for $109 each with free shipping, and DISH’s
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`investigator was required to resell them for a minimum of $149 each. Vigneswaran offered to sell
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`14 month Chitram Subscription renewals for $89, and DISH’s investigator was required to resell
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`them for a minimum of $129 each.
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`30.
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`Vigneswaran provided DISH’s investigator with information about Chitram and its
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`transmission of the channels. Vigneswaran stated Chitram.tv is the main Chitram website.
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`Vigneswaran stated that he could be contacted if there was an issue with channels not working and
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`he would in turn contact Chitram. Vigneswaran stated that if channels are down they are usually
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`only down for 2-3 hours, and it doesn’t take long for Chitram to get the channels back up as long
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`as it is not during the middle of the night in Germany.
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`31.
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`Vigneswaran also provided DISH’s investigator with information about his business
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`and presence in the United States. Vigneswaran stated he is located in Toronto, but he has
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`approximately 60 Chitram resellers in the United States and a warehouse in the United States.
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`Vigneswaran stated payments to him for Chitram set-top boxes and Chitram Subscriptions could
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`be made to his accounts with PayPal or Toronto Dominion (“TD”) Bank, which has branches in
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`New York. Vigneswaran identified his business as ChitramTV Canada and his PayPal email
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`address is Chitramtvcanada@outlook.com.
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`32.
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`On November 2, 2020, DISH’s investigator purchased four Chitram set-top boxes
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`and six Chitram Subscriptions from Vigneswaran, making payment to his PayPal email address
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`Chitramtvcanada@outlook.com. On November 30, 2020, DISH’s investigator purchased three
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`Chitram set-top boxes and three Chitram Subscriptions from Vigneswaran, making payment to his
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`PayPal email address Chitramtvcanada@outlook.com. On January 22, 2021, DISH’s investigator
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`purchased three Chitram set-top boxes and three Chitram Subscriptions from Vigneswaran, making
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`payment to his PayPal email address Chitramtvcanada@outlook.com.
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`33.
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`The Protected Channels were observed during testing of the Chitram set-top boxes
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`and Chitram Subscriptions purchased from Defendants.
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`34.
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`Chitram has actual knowledge that the transmission of the Protected Channels on
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`the Chitram Service infringes DISH’s copyrights. DISH and Networks sent at least 134 notices of
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`infringement to Chitram between July 25, 2014 and November 25, 2015, demanding that they cease
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`transmitting the Protected Channels identified in the notices. Chitram temporarily ceased
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`transmitting the Protected Channels on the Chitram Service by December 2, 2015.
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`35.
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`Chitram resumed transmitting the Protected Channels on the Chitram Service on or
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`before December 15, 2017. DISH and Networks sent at least 30 additional notices of infringement
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`to Chitram between December 15, 2017 and the filing of this Complaint, demanding that they cease
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`transmitting the Protected Channels identified in the notices. Chitram failed to respond to these
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`notices.
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`36.
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`DISH and Networks sent at least 49 additional notices to CDNs associated with the
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`Chitram Service from April 14, 2018 to the filing of this Complaint, requesting the removal of the
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`Protected Channels. Upon information and belief, at least some of these notices were forwarded to
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`Chitram. Even when these CDNs removed the unauthorized content based on Chitram’s copyright
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`infringement, Chitram intentionally interfered with the takedown efforts by, for example,
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`transmitting the Protected Channels from different CDNs or locations.
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`37.
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`Vigneswaran has actual knowledge that the transmission of the Protected Channels
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`on the Chitram Service infringes DISH’s copyrights. DISH and Networks sent Vigneswaran
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`notices of infringement on November 6, 2020, December 16, 2020, and January 8, 2021, demanding
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`that he cease distributing, selling, and promoting the Chitram Service in the United States.
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`Vigneswaran failed to respond to these notices.
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`CLAIMS FOR RELIEF
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`Count I
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`Direct Copyright Infringement Under 17 U.S.C. § 501
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`DISH repeats and realleges the allegations in paragraphs 1-37.
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`DISH is a copyright owner under 17 U.S.C. § 106 because DISH holds the exclusive
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`38.
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`39.
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`rights to distribute and publicly perform in the United States, by means including satellite, OTT,
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`IPTV, and Internet, the programs that make up the Protected Channels.
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`40.
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`The programs that make up the Protected Channels are original audiovisual works
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`fixed in a tangible medium of expression, and are therefore copyrightable subject matter. DISH’s
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`12
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`copyrights in programs that aired on the Protected Channels arise under laws of nations other than
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`the United States that are parties to copyright treaties with the United States, including Pakistan and
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`India where the programs were authored and first published. Under 17 U.S.C. §§ 101, 411, the
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`programs that make up the Protected Channels are non-United States works and, therefore,
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`registration with the United States Copyright Office is not a prerequisite to filing a copyright
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`infringement action with respect to these works.
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`41.
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`Chitram directly infringed DISH’s copyrights in violation of 17 U.S.C. § 501 by
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`distributing and publicly performing programs that make up the Protected Channels to Service
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`Users, including the works identified in Exhibits 1-2. The copyrighted programs were transmitted
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`from computer servers controlled by Chitram to Service Users who accessed the programs using
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`the Chitram Service.
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`42.
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`DISH has not authorized Chitram to distribute or publicly perform the programs that
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`make up the Protected Channels in any manner.
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`43.
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`The infringement of DISH’s rights in each program constitutes a separate and
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`distinct act of copyright infringement.
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`44.
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`Chitram’s actions are willful, malicious, intentional, purposeful, and in disregard of
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`and with indifference to the rights of DISH.
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`45.
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`Unless enjoined by the Court, Chitram will continue to engage in acts causing
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`substantial and irreparable injury to DISH that includes damage to its reputation, loss of goodwill,
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`and lost sales, for which there is no adequate remedy at law.
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`Count II
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`Inducing and Materially Contributing to Copyright Infringement Under 17 U.S.C. § 501
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`46.
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`DISH repeats and realleges the allegations in paragraphs 1-37 and 39-40.
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`13
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`47.
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`DISH’s exclusive rights to distribute and publicly perform the Protected Channels
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`and programs that make up the Protected Channels are directly infringed by the unauthorized
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`transmission of these programs to Service Users who access the programs using Defendants’
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`Chitram Service.
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`48.
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`Defendants materially contribute to this infringement of DISH’s exclusive
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`distribution and public performance rights by, among other things, providing Service Users access
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`to the Protected Channels and the programs that make up the Protected Channels, despite having
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`the ability to prevent such access. Defendants also induce the infringement of DISH’s exclusive
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`distribution and public performance rights by, among other things, creating the audience for that
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`infringement in the United States.
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`49.
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`Defendants sell the Chitram Service in the United States providing Service Users
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`access to unauthorized streams of the Protected Channels and the programs that make up the
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`Protected Channels. Service Users simply (1) purchase a Chitram set-top box with a Chitram
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`Subscription; power on the device; insert the included Subscription ID into the Chitram set-top box,
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`and select the Protected Channels; or (2) purchase a Chitram Subscription; download a Chitram
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`app from Chitram.tv or Chitram.ca to a compatible device such as an Android TV, Android phone
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`or tablet, Firestick, computer with a Windows or Mac operating system, or Linux system; insert the
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`Chitram Subscription ID into the Chitram app; and select the Protected Channels.
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`50.
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`Defendants advertise the Chitram Service as a means of accessing the Protected
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`Channels. Chitram promotes the Chitram Service as having “Over 500 Channels,” “more than 200
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`Channels . . . of Indian Television,” “WATCH ALL THE POPULAR CHANNELS,” and “Watch
`
`all your favourite Indian TV Channel Programs.” Vigneswaran promotes the Chitram Service as
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`having “150+ HD QUALITY CHANNELS.”
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`14
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`51.
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`Defendants provide material assistance to those directly infringing DISH’s exclusive
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`rights by providing the Chitram Service for the Protected Channels to be viewed. The Protected
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`Channels are presented to Service Users through the Chitram Service.
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`52.
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`Defendants intend that the Chitram Service be used to access the Protected Channels
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`and the programs that make up the Protected Channels, and they promote, encourage, and facilitate
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`using the Chitram Service in this manner.
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`53.
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`Defendants have actual knowledge that the transmission of the Protected Channels
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`and the programs that make up the Protected Channels to Service Users infringes DISH’s exclusive
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`distribution and public performance rights.
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`54.
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`Defendants can take simple measures to prevent further infringement of DISH’s
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`exclusive rights to distribute and publicly perform the programs that make up the Protected
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`Channels, such as removing the Protected Channels from the Chitram Service, blocking the Chitram
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`Service from accessing servers and URLs that are identified to be streaming the Protected Channels,
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`ceasing to buy further Chitram set-top boxes and Chitram Subscriptions until the Protected
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`Channels are removed from the Chitram Service, and ceasing to sell Chitram set-top boxes and
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`Chitram Subscriptions in the United States.
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`55.
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`Defendants’ actions are willful, malicious, intentional, and purposeful, and in
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`disregard of and with indifference to the rights of DISH.
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`56.
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`Unless enjoined by the Court, Defendants will continue to engage in acts causing
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`substantial and irreparable injury to DISH that includes damage to its reputation, loss of goodwill,
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`and lost sales, for which there is no adequate remedy at law.
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`PRAYER FOR RELIEF
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`WHEREFORE, DISH prays for judgment against Defendants as follows:
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`Case 4:21-cv-00859 Document 1 Filed on 03/16/21 in TXSD Page 16 of 17
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`A.
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`For a grant of permanent injunctive relief under 17 U.S.C. § 502 restraining and
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`enjoining Defendants, and any of their agents, servants, employees, attorneys, or other persons
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`acting in active concert or participation with any of the foregoing that receives actual notice of the
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`order (including, without limitation, resellers of the Chitram Service), from:
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` 1.
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`transmitting, streaming, distributing, or publicly performing in the United
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`States, with any Chitram set-top box, Chitram Subscription, Chitram app, or any other device,
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`application, service, or process, any of the Protected Channels or any of the programming that
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`comprises any of the Protected Channels;
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`2.
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`distributing, selling, providing, or promoting any product or service in the
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`United States, including any Chitram set-top box, Chitram Subscription, or Chitram app, that
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`comprises the whole or part of a network or service for the distribution or public performance of
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`any of the Protected Channels or any of the programming that comprises any of the Protected
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`Channels;
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`3.
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`advertising, displaying, or marketing any Chitram set-top box, Chitram
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`Subscription, Chitram app, or other service in connection with the Protected Channels or the
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`programming that comprises the Protected Channels;
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`4.
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`inducing or contributing to another’s conduct that falls within 1, 2, or 3
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`above; and
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`5.
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`selling, leasing, licensing, assigning, conveying, distributing, loaning,
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`encumbering, pledging, or otherwise transferring, whether or not for consideration or
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`compensation, any part of their infringing operations.
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`Case 4:21-cv-00859 Document 1 Filed on 03/16/21 in TXSD Page 17 of 17
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`B.
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`For 207 or more registered works, statutory damages as awarded by the Court up to
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`$150,000 per registered work infringed under 17 U.S.C. § 504(c), or the Defendants’ profits
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`attributable to the infringement of those registered works under 17 U.S.C. § 504(b).
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`C.
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`For unregistered works, an award of Defendants’ profits attributable to the
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`infringement of each unregistered work under 17 U.S.C. § 504(b).
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`D.
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`E.
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`F.
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`For DISH’s attorneys’ fees and costs under 17 U.S.C. § 505.
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`For impoundment and disposition of all infringing articles under 17 U.S.C. § 503.
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`For an order permanently transferring each domain name that Defendants used in
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`connection with the infringement to DISH.
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`G.
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`For pre- and post-judgment interest on all monetary relief, from the earliest date
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`permitted by law at the maximum rate permitted by law.
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`H.
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`For such additional relief as the Court deems just and equitable.
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`Dated: March 16, 2021
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`Respectfully submitted,
`HAGAN NOLL & BOYLE LLC
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`By: /s/ Stephen M. Ferguson
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`Stephen M. Ferguson (attorney-in-charge)
`Texas Bar No. 24035248
`Southern District of Texas Bar No. 614706
`Two Memorial City Plaza
`820 Gessner, Suite 940
`Houston, Texas 77024
`Telephone: (713) 343-0478
`Facsimile: (713) 758-0146
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`Joseph H. Boyle (of counsel)
`Texas Bar No. 24031757
`Southern District of Texas Bar No. 30740
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`Counsel for Plaintiff DISH Network L.L.C.
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