throbber
Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 1 of 14
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`
`
`
`
`
`
`
`JENAM TECH, LLC,
`
`
`
`
`
`Plaintiff
`
`
`
`v.
`
`GOOGLE LLC,
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`Civil Action No.: 6:20-cv-00453
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`PLAINTIFF’S FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Jenam Tech, LLC (“Jenam Tech” or “Plaintiff”), files this Complaint against
`
`Google, LLC ( “Google” or “Defendant”) seeking damages and other relief for patent
`
`infringement, and alleges with knowledge to its own acts, and on information and belief as to other
`
`matters, as follows:
`
`PARTIES
`
`1.
`
`Plaintiff is a limited liability company organized and existing under the laws of the
`
`State of Texas, having its principal place of business at 211 West Tyler Street, Suite C, Longview,
`
`Texas, 75601.
`
`2.
`
`Defendant Google is a Delaware corporation with a physical address at 500 West
`
`2nd Street, Austin, Texas 78701. Google may be served with process through its registered agent,
`
`the Corporation Service Company, at 211 East 7th Street, Suite 620, Austin, Texas 78701. Google
`
`is registered to do business in the State of Texas and has been since at least November 17, 2006.
`
`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 2 of 14
`
`3.
`
`This Court has personal jurisdiction over Google at least because Google regularly
`
`conducts and transacts business, including infringing acts described herein, in this District.
`
`4.
`
`Defendant conducts business in Texas, directly or through intermediaries and offer
`
`products or services, including those accused herein of infringement, to customers, and potential
`
`customers located in Texas, including in the Western District of Texas.
`
`JURISDICTION AND VENUE
`
`5.
`
`This action arises under the patent laws of the United States, 35 U.S.C. §101, et
`
`seq. This Court has subject matter jurisdiction under 28 U.S.C. §§1331 and 1338(a).
`
`6.
`
`As to Google, venue is proper in this judicial district pursuant to 28 U.S.C.
`
`§1400(b). Google maintains an established place of business in the state of Texas and the Western
`
`District of Texas, specifically, including an office at 500 West 2nd Street, Austin, Texas 78701.
`
`7.
`
`Defendants are subject to this Court’s specific and general personal jurisdiction
`
`pursuant to due process or the Texas Long Arm Statute, because Defendants conduct substantial
`
`business in this forum, including: (i) making, using, selling, importing, and/or offering for sale one
`
`or more websites or web addresses including, but not limited to www.google.com, stored and/or
`
`hosted on one or more servers owned or under the control of Google (“Accused
`
`Instrumentalities”); (ii) making, using, selling, importing, and/or offering for sale software for
`
`smartphones and tablets as well as other computing devices (e.g., laptops, desktops, Chromebooks,
`
`etc.) (“Accused Software”); or (iii) regularly doing or soliciting business, engaging in other
`
`persistent courses of conduct, or deriving substantial revenue from goods and services provided to
`
`citizens and residents in Texas and in this District.
`
`
`
`
`
`
`
`2
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`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 3 of 14
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`THE PATENTS-IN-SUIT
`
`8.
`
`On March 7, 2018, Robert Paul Morris filed United States Patent Application No.
`
`15/915,053 (“the ʼ053 Application”). The ʼ053 Application was duly examined and issued as
`
`United States Patent No. 10,069,945 (“the ʼ945 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`September 4, 2018.
`
`9.
`
`Jenam Tech is the owner of the ʼ945 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendants’ infringement of
`
`the ʼ945 patent.
`
`10.
`
`The ʼ945 patent is valid and enforceable. A true and correct copy of the ʼ945 patent
`
`is attached hereto as Exhibit A.
`
`11.
`
`On March 7, 2018, Robert Paul Morris filed United States Patent Application No.
`
`15/915,047 (“the ʼ047 Application”). The ʼ047 Application was duly examined and issued as
`
`United States Patent No. 10,075,564 (“the ʼ564 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`September 11, 2018.
`
`12.
`
`Jenam Tech is the owner of the ʼ564 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendants’ infringement of
`
`the ʼ564 patent.
`
`13.
`
`The ʼ564 patent is valid and enforceable. A true and correct copy of the ʼ564 patent
`
`is attached hereto as Exhibit B.
`
`14.
`
`On March 7, 2018, Robert Paul Morris filed United States patent Application No.
`
`15/915,052 (“the ʼ052 Application”). The ʼ052 Application was duly examined and issued as
`
`
`
`3
`
`

`

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`
`
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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 4 of 14
`
`United States Patent No. 10,075,565 (“the ʼ565 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`September 11, 2018.
`
`15.
`
`Jenam Tech is the owner of the ʼ565 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendants’ infringement of
`
`the ʼ565 patent.
`
`16.
`
`The ʼ565 patent is valid and enforceable. A true and correct copy of the ʼ565 patent
`
`is attached hereto as Exhibit C.
`
`17.
`
`On July 19, 2018, Robert Paul Morris filed United States Patent Application No.
`
`16/040,522 (“the ʼ522 Application”). The ʼ522 Application was duly examined and issued as
`
`United States Patent No. 10,375,215 (“the ʼ215 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`August 6, 2019.
`
`18.
`
`Jenam Tech is the owner of the ʼ215 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendants’ infringement of
`
`the ʼ215 patent.
`
`19.
`
`The ʼ215 patent is valid and enforceable. A true and correct copy of the ʼ215 patent
`
`is attached hereto as Exhibit D.
`
`20.
`
`On July 19, 2018, Robert Paul Morris filed United States Patent Application No.
`
`16/040,517 (“the ʼ517 Application”). The ʼ517 Application was duly examined and issued as
`
`United States Patent No. 10,306,026 (“the ʼ026 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`May 28, 2019.
`
`
`
`4
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`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 5 of 14
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`21.
`
`Jenam Tech is the owner of the ʼ026 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendants’ infringement of
`
`the ʼ026 patent.
`
`22.
`
`The ʼ026 patent is valid and enforceable. A true and correct copy of the ʼ026 patent
`
`is attached hereto as Exhibit E.
`
`23.
`
`On September 3, 2017, Robert Paul Morris filed United States Patent Application
`
`No. 15/694,802 (“the ‘802 Application”). The ‘802 Application was duly examined and issued as
`
`United States Patent No. 9,923,995 (“the ‘995 Patent”) (entitled “Methods, Systems, and Computer
`
`Program Products for Sharing Information for Detecting an Idle TCP Connection”), on March 20,
`
`2018.
`
`24.
`
`Jenam Tech is the owner of the ‘995 Patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendant’s infringement of
`
`the ‘995 Patent.
`
`25.
`
`The ʼ995 Patent is valid and enforceable. A true and correct copy of the ʼ995 Patent
`
`is attached hereto as Exhibit F.
`
`26.
`
`On September 3, 2017, Robert Paul Morris filed United States Patent Application
`
`No. 15/694,803 (“the ‘803 Application”). The ‘803 Application was duly examined and issued as
`
`United States Patent No. 9,923,996 (“the ʼ996 Patent”) (entitled “Methods, Systems, and Computer
`
`Program Products for Sharing Information for Detecting an Idle TCP Connection”), on March 20,
`
`2018.
`
`27.
`
`Jenam Tech is the owner of the ʼ996 Patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendant’s infringement of
`
`the ʼ996 Patent.
`
`
`
`5
`
`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 6 of 14
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`28.
`
`The ʼ996 Patent is valid and enforceable. A true and correct copy of the ʼ996 Patent
`
`is attached hereto as Exhibit G.
`
`29.
`
`On March 28, 2019, Robert Paul Morris filed United States Patent Application No.
`
`16/368,811 (“the ‘811 Application”). The ‘811 Application was duly examined and issued as
`
`United States Patent No. 10,742,774 (“the ʼ774 patent”) (entitled “Methods, Systems, and
`
`Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on
`
`August 11, 2020.
`
`30.
`
`Jenam Tech is the owner of the ʼ774 patent and has the full and exclusive right to
`
`bring actions and recover past, present, and future damages for the Defendant’s infringement of
`
`the ʼ774 patent.
`
`31.
`
`The ʼ774 Patent is valid and enforceable. A true and correct copy of the ʼ774 Patent
`
`is attached hereto as Exhibit O.
`
`32.
`
`The ʼ945, ʼ564, ʼ565, ʼ215, ʼ026, ʼ995, ʼ996, and ’774 patents are collectively
`
`referred to herein as the “patents” or the “patents in suit.”
`
`33.
`
`34.
`
`Jenam Tech has not practiced any claimed invention of the patents in suit.
`
`Defendants infringe the patents at least through making, using, selling, importing,
`
`and/or offering to sell the Accused Instrumentalities and Accused Software.
`
`COUNT I: INFRINGEMENT OF THE ʼ945 PATENT
`
`35.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`36.
`
`37.
`
`The ʼ945 patent includes 144 claims. ʼ945 patent, Ex. A at 24:8-36:65.
`
`Defendants directly infringe one or more claims of the ʼ945 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`
`
`6
`
`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 7 of 14
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`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ945 patent, attached hereto as Exhibit H.
`
`38.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 104 of the ʼ945 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`Claim Chart for the ʼ945 patent, attached hereto as Exhibit H. As demonstrated by the attached
`
`claim chart, each and every element of Claim 104 of the ʼ945 patent is found in the Accused
`
`Instrumentalities.
`
`39.
`
`Defendants have had actual knowledge of the ʼ945 patent at least as early as the
`
`date of service of this Complaint.
`
`40.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT II: INFRINGEMENT OF THE ʼ564 PATENT
`
`41.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`42.
`
`43.
`
`The ʼ564 patent includes 30 claims. ʼ564 patent, Ex. B at 23:5–27:28.
`
`Defendants directly infringe one or more claims of the ʼ564 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ564 patent, attached hereto as Exhibit I.
`
`44.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ564 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`
`
`7
`
`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 8 of 14
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`Claim Chart for the ʼ564 patent, attached hereto as Exhibit I. As demonstrated by the attached
`
`claim chart, each and every element of Claim 1 of the ʼ564 patent is found in the Accused
`
`Instrumentalities.
`
`45.
`
`Defendants have had actual knowledge of the ʼ564 patent at least as early as the
`
`date of service of this Complaint.
`
`46.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT III: INFRINGEMENT OF THE ʼ565 PATENT
`
`47.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`48.
`
`49.
`
`The ʼ565 patent includes 30 claims. ʼ565 patent, Ex. C at 23:48–28:65.
`
`Defendants directly infringe one or more claims of the ʼ565 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ565 patent, attached hereto as Exhibit J.
`
`50.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ565 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`Claim Chart for the ʼ565 patent, attached hereto as Exhibit J. As demonstrated by the attached
`
`claim chart, each and every element of Claim 1 of the ʼ565 patent is found in the Accused
`
`Instrumentalities.
`
`51.
`
`Defendants have had actual knowledge of the ʼ565 patent at least as early as the
`
`date of service of this Complaint.
`
`
`
`8
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`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 9 of 14
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`52.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT IV: INFRINGEMENT OF THE ʼ215 PATENT
`
`53.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`54.
`
`55.
`
`The ʼ215 patent includes 39 claims. ʼ215 patent, Ex. D at 24:15–30:23.
`
`Defendants directly infringe one or more claims of the ʼ215 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ215 patent, attached hereto as Exhibit K.
`
`56.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ215 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`Claim Chart for the ʼ215 patent, attached hereto as Exhibit K. As demonstrated by the attached
`
`claim chart, each and every element of Claim 1 of the ʼ215 patent is found in the Accused
`
`Instrumentalities.
`
`57.
`
`Defendants have had actual knowledge of the ʼ215 patent at least as early as the
`
`date of service of this Complaint.
`
`58.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT V: INFRINGEMENT OF THE ʼ026 PATENT
`
`59.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`
`
`9
`
`

`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 10 of 14
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`60.
`
`61.
`
`The ʼ026 patent includes 98 claims. ʼ026 patent, Ex. E at 24:16–34:30.
`
`Defendants directly infringe one or more claims of the ʼ026 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities and the
`
`Accused Software. See Claim Chart for the ʼ026 patent, attached hereto as Exhibit L.
`
`62.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ026 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities and the
`
`Accused Software. See Claim Chart for the ʼ026 patent, attached hereto as Exhibit L. As
`
`demonstrated by the attached claim chart, each and every element of Claim 1 of the ʼ026 patent is
`
`found in the Accused Instrumentalities and the Accused Software.
`
`63.
`
`Defendants have had actual knowledge of the ʼ026 patent at least as early as the
`
`date of service of this Complaint.
`
`64.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT VI: INFRINGEMENT OF THE ‘995 PATENT
`
`65.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`66.
`
`67.
`
`The ʼ995 patent includes 30 claims. ʼ995 patent, Ex. F at 23:4-28:16.
`
`Defendants directly infringe one or more claims of the ʼ995 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities and the
`
`Accused Software. See Claim Chart for the ʼ995 patent, attached hereto as Exhibit M.
`
`
`
`10
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`

`

`
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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 11 of 14
`
`68.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 29 of the ʼ995 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities and the
`
`Accused Software. See Claim Chart for the ʼ995 patent, attached hereto as Exhibit M. As
`
`demonstrated by the attached claim chart, each and every element of Claim 29 of the ‘995 patent
`
`is found in the Accused Instrumentalities and the Accused Software.
`
`69.
`
`Defendants have had actual knowledge of the ʼ995 patent at least as early as the
`
`date of service of this Complaint.
`
`70.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT VII: INFRINGEMENT OF THE ʼ996 PATENT
`
`71.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`72.
`
`73.
`
`The ʼ996 patent includes 30 claims. ʼ996 patent, Ex. G at 23:27-28:42.
`
`Defendants directly infringe one or more claims of the ʼ996 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ996 patent, attached hereto as Exhibit N.
`
`74.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ996 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`Claim Chart for the ʼ996 patent, attached hereto as Exhibit N. As demonstrated by the attached
`
`
`
`11
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`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 12 of 14
`
`claim chart, each and every element of Claim 1 of the ʼ996 patent is found in the Accused
`
`Instrumentalities.
`
`75.
`
`Defendants have had actual knowledge of the ʼ996 patent at least as early as the
`
`date of service of this Complaint.
`
`76.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`COUNT VIII: INFRINGEMENT OF THE ʼ774 PATENT
`
`77.
`
`Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully
`
`set forth herein.
`
`78.
`
`79.
`
`The ʼ774 patent includes 83 claims. ʼ774 patent, Ex. O at 24:22-34:63.
`
`Defendants directly infringe one or more claims of the ʼ774 patent without authority
`
`by making, using (including without limitation testing), selling, importing, and/or offering to sell
`
`products and systems, including by way of example, the Accused Instrumentalities. See Claim
`
`Chart for the ʼ774 patent, attached hereto as Exhibit P.
`
`80.
`
`Defendants have been and are directly infringing, either literally or under the
`
`doctrine of equivalents, at least Claim 1 of the ʼ774 patent by making, using (including without
`
`limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See
`
`Claim Chart for the ‘774 patent, attached hereto as Exhibit P. As demonstrated by the attached
`
`claim chart, each and every element of Claim 1 of the ʼ774 patent is found in the Accused
`
`Instrumentalities.
`
`81.
`
`Defendants have had actual knowledge of the ʼ774 patent at least as early as the
`
`date of service of this Complaint.
`
`
`
`12
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`

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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 13 of 14
`
`82.
`
`Defendants’ acts of infringement have occurred within this District and elsewhere
`
`throughout the United States.
`
`RELIEF REQUESTED
`
`
`
`WHEREFORE, Plaintiff respectfully requests that the Court:
`
`A.
`
`B.
`
`Declaring that Defendants have infringed the patents in suit;
`
`Awarding damages in an amount to be proven at trial, but in no event less than a
`
`reasonable royalty for Defendants’ infringement including pre-judgment and post-judgment
`
`interest at the maximum rate permitted by law;
`
`C.
`
`Ordering an award of reasonable attorneys’ fees and enhanced damages as
`
`appropriate against Defendant to Jenam Tech as provided by 35 U.S.C. § 285;
`
`D.
`
`Awarding expenses, costs, and disbursements in this action against Defendants,
`
`including prejudgment interest; and
`
`E.
`
`All other relief necessary or appropriate.
`
`JURY DEMAND
`
`Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiff hereby demands a trial by jury
`
`on all issues so triable.
`
`
`
`
`
`13
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`Case 6:20-cv-00453-ADA Document 24 Filed 08/11/20 Page 14 of 14
`
`Dated: August 11, 2020
`
`
`
`
`
`
`
`
`
`
`/s/ James M. Lennon
`James M. Lennon (Bar No. 4570)
`Timothy Devlin (pro hac vice to be filed)
`Derek Dahlgren (pro hac vice to be filed)
`Cory Edwards (pro hac vice to be filed)
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`jlennon@devlinlawfirm.com
`tdevlin@devlinlawfirm.com
`ddahlgren@devlinlawfirm.com
`cedwards@devlinlawfirm.com
`
`Attorneys for Plaintiff,
`Jenam Tech, LLC
`
`14
`
`

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