Case 6:24-cv-00340-AM-DTG Document 1 Filed 06/24/24 Page 1 of 15
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PAYRANGE INC.,
`
`Plaintiff,
`
`v.
`
`NAYAX LTD.,
`
`Defendant.
`
`§
`§
`§
`§ C.A. _____________
`§
`§ JURY TRIAL DEMANDED
`§
`§
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AND DEMAND FOR JURY TRIAL
`
`1.
`
`Pursuant to Section 1338 of Title 28 of the United States Code, Plaintiff
`
`PayRange Inc. (“Plaintiff” or “PayRange”) alleges for its Complaint against Defendant Nayax
`
`Ltd. (“Nayax”) (“Nayax” or “Defendant”), on personal knowledge and information and belief as
`
`noted.
`
`2.
`
`This Complaint arises under the patent laws of the United States, Title 35 of the
`
`United States Code. This Court has subject matter jurisdiction over this action under 35 U.S.C.
`
`§ 271 et seq., 28 U.S.C. §§ 1331 and 1338(a).
`
`THE PARTIES
`
`3.
`
`PayRange is a Tennessee corporation with its principal place of business at 9600
`
`NE Cascades Pkwy, Suite 280, Portland, OR 97220.
`
`4.
`
`On information and belief, Nayax is an Israeli corporation with its principal place
`
`of business at 3 Arik Einstein St., Bldg. B, 1st Floor Herzliya, Israel 4659071.
`
`5.
`
`PayRange’s acclaimed technology enables its customers to upgrade a coin-
`
`operated unattended retail machine into a state-of-the-art mobile payment solution with a small
`
`module, called “BluKey.” PayRange’s mobile app communicates with BluKey to enable mobile
`
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`Case 6:24-cv-00340-AM-DTG Document 1 Filed 06/24/24 Page 2 of 15
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`transactions. The United States Patent & Trademark Office (“USPTO”) awarded PayRange a
`
`portfolio of patents for its innovations.
`
`6.
`
`PayRange’s patent portfolio is prominently identified on its website pursuant to
`
`PayRange’s virtual patent marking practices: https://payrange.com/patents/
`
`7.
`
`PayRange found success in the laundry and vending industries, attracting
`
`significant customers including WASH Multifamily Laundry Systems (“WASH”).
`
`Unfortunately, competitors took notice and improperly copied PayRange’s technology. As a
`
`result, PayRange initiated litigation against a major competitor (KioSoft) and subsequently
`
`against KioSoft’s major customer (CSC). In response, KioSoft and CSC challenged the validity
`
`of PayRange’s patents before the USPTO. PayRange prevailed with confirmed claims in every
`
`USPTO challenge that proceeded to a Final Written Decision.
`
`8.
`
`On January 31, 2024, PayRange and KioSoft issued a press release announcing a
`
`settlement. KioSoft’s President, Charles Lee, is quoted:
`
`“While we had challenged the PayRange patents vigorously, the Patent Trial and
`Appeal Board (PTAB) upheld the PayRange patents and, although we disagreed
`with the result, we must now accept that PayRange has valid claims,” stated
`Charles Lee, President of KioSoft. “We respect the technologies that have helped
`the self-service industry thrive; and we look forward to continuing to lead
`innovation and development by providing best-in-class service to our customers
`with this fully-licensed technology, without any further legal distractions.”
`
`9.
`
`KioSoft agreed to license PayRange’s technology for an amount that could exceed
`
`$62 million over a ten-year period, dependent on outcomes with a base license of $40 million.
`
`10.
`
`In April 2024, on the heels of its settlement with KioSoft, PayRange also resolved
`
`its patent infringement dispute with KioSoft’s customer CSC.
`
`11.
`
`In May 2024, PayRange reached a patent licensing deal with WASH, one of the
`
`largest providers of laundry facilities in the United States. The agreement licenses PayRange’s
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`Case 6:24-cv-00340-AM-DTG Document 1 Filed 06/24/24 Page 3 of 15
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`patents for use with the WASH-Connect Mobile Payment App and will continue for the term of
`
`PayRange’s patents. In the press release, WASH’s CEO, Jim Gimeson stated:
`
`“We’re a privately held company founded in 1947 and we hold dear our reputation
`for integrity and ethical practices,” says WASH CEO Jim Gimeson. “As operators,
`we hold a deep respect for the innovations PayRange has brought to elevate the
`laundry industry.”
`
`12.
`
`PayRange hoped that its other competitors would respect its intellectual property.
`
`PayRange hoped that its competitors would, like KioSoft, accept that PayRange had valid patent
`
`claims. PayRange hoped that its other competitors would, like, WASH, act with integrity and
`
`adhere to ethical practices.
`
`13.
`
`On March 20, 2024, PayRange sent Nayax a letter (See Exhibit 6) providing
`
`notice of its potential infringement and inviting licensing discussions. PayRange provided
`
`detailed claim charts showing that Nayax infringes at least:
`
`a. U.S. Patent Nos. 11,481,772 (the “’772 patent”);
`
`b. Allowed claims of U.S. Patent Application No. 18/197,071, which issued as
`
`U.S. Patent No. 11,972,423 (the “’423 patent”); and
`
`c. Allowed claims of U.S. Patent Application No. 18/197,071, which issues as
`
`U.S. Patent No. 11,966,920 (the “’920 patent”).
`
`14.
`
`Three months later, Nayax finally sent a response with purported defenses, but
`
`those purported defenses were meritless. Moreover, Nayax provided no indication that it would
`
`cease infringement, take a license, or even accept PayRange’s invitation to meet to discuss the
`
`matter. PayRange was, again, compelled to file this action to protect its innovations and stop
`
`Nayax’s patent infringement.
`
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`Case 6:24-cv-00340-AM-DTG Document 1 Filed 06/24/24 Page 4 of 15
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`JURISDICTION AND VENUE
`
`15.
`
`This is a civil action for patent infringement arising under the patent laws of the
`
`United States, 35 U.S.C. §§ 1 et seq.
`
`16.
`
`This Court has subject matter jurisdiction over this patent infringement action
`
`pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`17.
`
`Upon information and belief, Nayax has infringed PayRange’s patents-in-suit in
`
`this District by, among other things, engaging in infringing conduct within and directed at, or
`
`from, this District. Nayax has purposefully and voluntarily placed one or more of its infringing
`
`products, as described below, into the stream of commerce with the expectation that these
`
`infringing products will be used in this District. Nayax’s infringing products have been and
`
`continue to be used in this District.
`
`18.
`
`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(c). Nayax is a
`
`foreign entity and may be sued in any judicial district under 28 U.S.C. § 1391(c)(3).
`
`PAYRANGE’S PATENTS-IN-SUIT
`
`19.
`
`To protect its unique and innovative technologies, PayRange filed a provisional
`
`patent application (No. 61/917,936) on December 18, 2013. Several patents issued based on this
`
`original application, including the patents-in-suit, a summarized below.
`
`20.
`
`On January 12, 2021, the USPTO issued U.S. Patent No. 10,891,608 (the “’608
`
`patent”), titled “METHOD AND SYSTEM FOR AN OFFLINE-PAYMENT OPERATED
`
`MACHINE TO ACCEPT ELECTRONIC PAYMENTS.” A true and correct copy of the ’608
`
`patent is attached hereto as Exhibit 1.
`
`21.
`
`On October 25, 2022, the USPTO issued the ’772 Patent, titled “METHOD AND
`
`SYSTEM FOR PRESENTING REPRESENTATIONS OF PAYMENT ACCEPTING UNIT
`
`EVENTS.” A true and correct copy of the ’772 Patent is attached hereto as Exhibit 2. On
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`November 22, 2023, PayRange filed a disclaimer in the ’772 Patent, which disclaims Claims 1-6,
`
`8-10 and 12-20 of the ’772 Patent. A true and correct copy of the disclaimer is attached hereto as
`
`Exhibit 3.
`
`22.
`
`On April 23, 2024, the USPTO issued the ’920 patent, titled “METHOD AND
`
`SYSTEM FOR PRESENTING REPRESENTATIONS OF PAYMENT ACCEPTING UNIT
`
`EVENTS.” A true and correct copy of the ’920 patent is attached hereto as Exhibit 4.
`
`23.
`
`On April 30, 2024, the USPTO issued the ’423 patent, titled “METHOD AND
`
`SYSTEM FOR PRESENTING REPRESENTATIONS OF PAYMENT ACCEPTING UNIT
`
`EVENTS.” A true and correct copy of the ’423 patent is attached hereto as Exhibit 5.
`
`COUNT I
`INFRINGEMENT OF THE ’608 PATENT
`
`24.
`
`PayRange realleges and incorporates the allegations of the preceding paragraphs
`
`of this complaint as if fully set forth herein.
`
`25.
`
`PayRange is the assignee and owner of all right, title, and interest in and to the
`
`’608 patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`
`embodying the ’608 patent throughout the United States, and to import any product embodying
`
`the ’608 patent into the United States.
`
`26.
`
`A significant advantage of the ’608 patent is the ability to emulate an analog
`
`signal generated by the coin receiving switch of the offline payment-operated machine. Another
`
`advantage was receiving a wireless request via the short-range wireless transceiver from a
`
`mobile device. A further advantage is causing an offline payment-operated machine to initiate
`
`the requested cashless operation by issuing the first number of electrical pulses. These
`
`advantages were not routine, well-understood or conventional.
`
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`27.
`
`Upon information and belief, Nayax has and is infringing at least claim 1 of the
`
`’608 patent in this District and elsewhere in the United States, by, among other things, directly or
`
`through intermediaries, making, using, selling and/or offering for sale payment devices,
`
`including VPOS Touch and Onyx, covered by one or more claims of the ’608 patent to the injury
`
`of PayRange. Nayax is directly infringing, literally infringing, and/or infringing the ’608 patent
`
`under the doctrine of equivalents. Nayax is thus liable for infringement of the ’608 patent
`
`pursuant to 35 U.S.C. § 271(a).
`
`28. When placed into operation by Nayax or Nayax’s users, Nayax’s infringing
`
`products infringe at least claim 1 of the ’608 patent. They include a payment module (VPOS
`
`Touch and Onyx) for an offline payment-operated machine (e.g., vending machine) including a
`
`coin receiving switch, the payment module comprising: a short-range wireless transceiver (e.g.,
`
`NFC) configured to communicate with one or more mobile devices; one or more processors; a
`
`first interface module configured to output to a control unit of the offline payment-operated
`
`machine one or more electrical pulses, each of the one or more electrical pulses emulating an
`
`analog signal generated by the coin receiving switch of the offline payment-operated machine in
`
`response to insertion of a single coin of a predetermined type in the offline payment-operated
`
`machine; and memory (e.g., Flash memory) with one or more programs for execution by the one
`
`or more processors, the one or more programs including instructions for: storing, in the memory
`
`of the payment module, a number of the electrical pulses that must be received by the control
`
`unit to initiate an operation of the offline payment operating machine; receiving a wireless
`
`request via the short-range wireless transceiver from a respective mobile device of the one or
`
`more mobile devices to initiate a cashless operation of the offline-payment operated machine;
`
`and in response to the wireless request: determining a first number of electrical pulses to output
`
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`via the first interface module to the control unit of the offline payment-operated machine in order
`
`to initiate the requested cashless operation of the offline payment-operated machine; causing the
`
`offline payment-operated machine to initiate the requested cashless operation by issuing the first
`
`number of electrical pulses to the control unit via the first interface module; and sending
`
`operation information corresponding to the initiated operation of the offline payment-operated
`
`machine to the respective mobile device via the short-range wireless transceiver.
`
`29.
`
`To the extent Nayax payment devices (including VPOS Touch and Onyx),
`
`without more, do not directly infringe at least claim 1 of the ’608 patent, Nayax actively
`
`encourages their business partners, end-users and/or customers to use Nayax payment devices in
`
`an infringing manner. Nayax encourages infringement with a specific intent to cause its business
`
`partners and customers to infringe. Nayax’s acts thus constitute active inducement of patent
`
`infringement in violation of 35 U.S.C. § 271(b).
`
`30.
`
`In addition, Nayax contributes to infringement of the same under 35 U.S.C.
`
`§ 271(c) inasmuch as the infringing products offered for sale and sold by Nayax are each a
`
`component of a patented machine or an apparatus used in practicing a patented process,
`
`constituting a material part of the invention, knowing the same to be especially made or
`
`especially adapted for use in infringement of the ’608 patent.
`
`31.
`
`Nayax’s direct infringement, contributory infringement, and inducement of
`
`infringement have irreparably harmed PayRange.
`
`32.
`
`Upon information and belief, Nayax will continue to infringe the ’608 patent
`
`unless enjoined.
`
`33.
`
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`
`compensate for the infringement. PayRange has complied with its patent marking obligations
`
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`including by virtually marking its patents through the following URL:
`
`https://payrange.com/patents/
`
`34.
`
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`
`is entitled to an award of attorneys’ fees.
`
`COUNT II
`INFRINGEMENT OF THE ’920 PATENT
`
`35.
`
`PayRange realleges and incorporates the allegations of the preceding paragraphs
`
`of this complaint as if fully set forth herein.
`
`36.
`
`PayRange is the assignee and owner of all right, title, and interest in and to the
`
`’920 patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`
`embodying the ’920 patent throughout the United States, and to import any product embodying
`
`the ’920 patent into the United States.
`
`37.
`
`A significant advantage of the ’920 patent is the ability to identify payment
`
`accepting units based on the location or identifier corresponding to the payment accepting units.
`
`Another significant advantage is displaying a visual indication of the payment accepting units.
`
`Completing a transaction after establishing a wireless communication is another significant
`
`advantage. These advantages were not routine, well-understood or conventional.
`
`38.
`
`Upon information and belief, Nayax has and is infringing at least claim 1 of the
`
`’920 patent in this District and elsewhere in the United States, by, among other things, directly or
`
`through intermediaries, making, using, selling and/or offering for sale products such as Monyx
`
`Wallet app, covered by one or more claims of the ’920 patent to the injury of PayRange. Nayax
`
`is directly infringing, literally infringing, and/or infringing the ’920 patent under the doctrine of
`
`equivalents. Nayax is thus liable for infringement of the ’920 patent pursuant to 35 U.S.C.
`
`§ 271(a).
`
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`39.
`
`Exhibit 6, which is incorporated herein, include a chart providing an element-by-
`
`element comparison between Nayax and claim 1 of the ’920 patent.
`
`40.
`
`Nayax actively encourages their business partners and/or customers to use Monyx
`
`Wallet in an infringing manner. Nayax encourages infringement with a specific intent to cause
`
`its business partners and customers to infringe. Nayax’s acts thus constitute active inducement of
`
`patent infringement in violation of 35 U.S.C. § 271(b).
`
`41.
`
`To the extent Monyx Wallet, without more, does not directly infringe at least
`
`claim 1 of the ’920 patent, Nayax contributes to infringement of the same under 35 U.S.C.
`
`§ 271(c) inasmuch as the infringing products offered for sale and sold by Nayax is a component
`
`of a patented machine or an apparatus used in practicing a patented process, constituting a
`
`material part of PayRange’s invention, knowing the same to be especially made or especially
`
`adapted for use in infringement of the ’920 patent.
`
`42.
`
`Nayax’s direct infringement, contributory infringement, and inducement of
`
`infringement have irreparably harmed PayRange. On information and belief, PayRange has lost
`
`prospective customers and was forced to compete against its own technology, at least in part, due
`
`to Nayax’s infringement. The continued infringement harms PayRange’s reputation in the
`
`marketplace and discourages other potential customers from purchasing PayRange’s solutions.
`
`These reputational and business harms cannot be adequately remedied by monetary
`
`compensation.
`
`43.
`
`Upon information and belief, Nayax will continue to infringe the ’920 patent
`
`unless enjoined.
`
`-9-
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`44.
`
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`
`compensate for the infringement, including a reasonable royalty and/or lost profits. PayRange
`
`notified Nayax of its infringement even prior to issuance of the ’920 patent.
`
`45.
`
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`
`is entitled to an award of attorneys’ fees.
`
`COUNT III
`INFRINGEMENT OF THE ’423 PATENT
`
`46.
`
`PayRange realleges and incorporates the allegations of the preceding paragraphs
`
`of this complaint as if fully set forth herein.
`
`47.
`
`PayRange is the assignee and owner of all right, title, and interest in and to the
`
`’423 patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`
`embodying the ’423 patent throughout the United States, and to import any product embodying
`
`the ’423 patent into the United States.
`
`48.
`
`A significant advantage of the ’423 patent is the ability to identify payment
`
`accepting units based on an identifier corresponding to the payment accepting units. Another
`
`significant advantage is displaying a visual indication of the payment accepting units.
`
`Completing a transaction after establishing a wireless communication was another significant
`
`advantage. These advantages were not routine, well-understood or conventional.
`
`49.
`
`Upon information and belief, Nayax has and is infringing at least claim 1 of the
`
`’423 patent in this District and elsewhere in the United States, by, among other things, directly or
`
`through intermediaries, making, using, selling and/or offering for sale products such as Monyx
`
`Wallet app, covered by one or more claims of the ’423 patent to the injury of PayRange. Nayax
`
`is directly infringing, literally infringing, and/or infringing the ’423 patent under the doctrine of
`
`-10-
`
`

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`equivalents. Nayax is thus liable for infringement of the ’423 patent pursuant to 35 U.S.C.
`
`§ 271(a).
`
`50.
`
`Exhibit 6, which is incorporated herein, includes a chart providing an element-
`
`by-element comparison between Nayax and claim 1 of the ’423 patent.
`
`51.
`
`Nayax actively encourages its business partners, end-users and/or customers to,
`
`for instance, use Monyx Wallet in an infringing manner. Nayax encourages infringement with a
`
`specific intent to cause its business partners and customers to infringe. Nayax’s acts thus
`
`constitute active inducement of patent infringement in violation of 35 U.S.C. § 271(b).
`
`52.
`
`To the extent Monyx Wallet, without more, does not directly infringe at least
`
`claim 1 of the ’423 patent, Nayax contributes to infringement of the same under 35 U.S.C.
`
`§ 271(c) inasmuch as the infringing products offered for sale and sold by Nayax is a component
`
`of a patented machine or an apparatus used in practicing a patented process, constituting a
`
`material part of PayRange’s invention, knowing the same to be especially made or especially
`
`adapted for use in infringement of the ’423 patent.
`
`53.
`
`Nayax’s direct infringement, contributory infringement, and inducement of
`
`infringement have irreparably harmed PayRange. On information and belief, PayRange has lost
`
`prospective customers and was forced to compete against its own technology, at least in part, due
`
`to Nayax’s infringement. The continued infringement harms PayRange’s reputation in the
`
`marketplace and discourages other potential customers from purchasing PayRange’s solutions.
`
`These reputational and business harms cannot be adequately remedied by monetary
`
`compensation.
`
`54.
`
`Upon information and belief, Nayax will continue to infringe the ’423 patent
`
`unless enjoined.
`
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`55.
`
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`
`compensate for the infringement, including a reasonable royalty and/or lost profits. PayRange
`
`notified Nayax of its infringement even prior to issuance of the ’423 patent.
`
`56.
`
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`
`is entitled to an award of attorneys’ fees.
`
`COUNT IV
`INFRINGEMENT OF THE ’772 PATENT
`
`57.
`
`PayRange realleges and incorporates the allegations of the preceding paragraphs
`
`of this complaint as if fully set forth herein.
`
`58.
`
`PayRange is the assignee and owner of all right, title, and interest in and to the
`
`’772 patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`
`embodying the ’772 patent throughout the United States, and to import any product embodying
`
`the ’772 patent into the United States.
`
`59.
`
`A significant advantage of the ’772 patent is the capability to display multiple
`
`payment accepting units on a mobile device. This allows a user to select one of many different
`
`machines and initiate payment to the selected machine using a mobile device.
`
`60.
`
`The ’772 patent was unconventional in several respects. For example, claim 11 of
`
`the ’772 patent was unconventional. Claim 11 is directed to an improved user interface that
`
`contains essential information in requesting products and/or service from a payment accepting
`
`units in a particular manner. Before users request products and/or services, the mobile payment
`
`application shows available payment accepting units and the prepared balance. When users
`
`request products and/or services, the mobile payment application shows an indication of the
`
`initiation of transaction. Conventionally, the information described above was not easily
`
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`accessible to users or the information was shown on the interfaces of the payment accepting
`
`units, which were limited in the amount and the type of information that can be displayed.
`
`61.
`
`Upon information and belief, Nayax has and is infringing claim 11 of the ’772
`
`patent in this District and elsewhere in the United States, by, among other things, directly or
`
`through intermediaries, using products with mobile payment functionality, covered by claim 11
`
`of the ’772 patent to the injury of PayRange. Nayax is directly infringing, literally infringing,
`
`and/or infringing the ’772 patent under the doctrine of equivalents. Nayax is thus liable for
`
`infringement of the ’772 patent pursuant to 35 U.S.C. § 271(a).
`
`62.
`
`Exhibit 6, which is incorporated herein, provides an element-by-element
`
`comparison between Nayax and claim 11 of the ’772 patent.
`
`63.
`
`Nayax actively encourages their business partners and/or customers to use Monyx
`
`Wallet in an infringing manner. Nayax encourages infringement with a specific intent to cause its
`
`business partners and customers to infringe. Nayax’s acts thus constitute active inducement of
`
`patent infringement in violation of 35 U.S.C. § 271(b).
`
`64.
`
`Nayax’s direct infringement and inducement of infringement have irreparably
`
`harmed PayRange. On information and belief, PayRange has lost prospective customers and was
`
`forced to compete against its own technology, at least in part, due to Nayax’s infringement. The
`
`continued infringement harms PayRange’s reputation in the marketplace and discouraging other
`
`potential customers from purchasing PayRange’s solutions. These reputational and business
`
`harms cannot be adequately remedied by monetary compensation.
`
`65.
`
`Upon information and belief, Nayax will continue to infringe the ’772 patent
`
`unless enjoined.
`
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`66.
`
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`
`compensate for the infringement.
`
`67.
`
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`
`is entitled to an award of attorneys’ fees.
`
`REQUEST FOR RELIEF
`
`WHEREFORE, PayRange requests that the Court find in its favor and against Nayax, and
`
`that the Court grant PayRange the following relief:
`
`a.
`
`Judgment that Nayax infringes the patents-in-suit;
`
`b. Judgment that Nayax is jointly and severally liable for infringement of the patents-in-
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`suit.
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`c. That PayRange be granted with injunctive relief against Nayax and its officers,
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`employees, agents, servants, attorneys, instrumentalities, and/or those in privity with
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`them, to prevent the recurrence of the infringing activities complained of herein,
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`including an injunction against further installations of infringing payment modules,
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`disabling service to payment modules that practice infringing technology, and
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`removing all infringing mobile apps from all third party app stores such as the Google
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`Play Store and Apple App Store, and for all further proper injunctive relief pursuant
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`to 35 U.S.C. § 283;
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`d. Judgment that Nayax account for and pay to PayRange all damages and costs
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`incurred by PayRange, caused by Nayax’s infringing activities complained of herein;
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`e.
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`Judgment that Nayax willfully infringed and increase the damages award to
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`PayRange up to three times the amount assessed, pursuant to 35 U.S.C. § 284;
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`f. That PayRange be granted pre-judgment and post-judgment interest on the damages;
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`-14-
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`

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`Case 6:24-cv-00340-AM-DTG Document 1 Filed 06/24/24 Page 15 of 15
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`g. That this Court declare this an exceptional case and award PayRange reasonable
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`attorneys’ fees and costs in accordance with 35 U.S.C. § 285; and
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`h. That PayRange be granted such other and further relief as the Court may deem just
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`and proper under the circumstances.
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`DEMAND FOR JURY TRIAL
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`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff demands a trial
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`by jury of this action.
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`Dated: June 24, 2024
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`Respectfully submitted,
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`By: /s/ Ryan R. Smith
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`James C. Yoon (Admitted to Practice WDTX;
`CA State Bar No. 177155)
`Ryan R. Smith (Admitted to Practice WDTX;
`CA State Bar No. 229323)
`Jamie Y. Otto (PHV forthcoming)
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: (650) 493-9300
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`Attorneys for Plaintiff PayRange Inc.
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`-15-
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