throbber
Case 1:12-cv-00398-GMS Document 1 Filed 03/29/12 Page 1 of 13 PageID #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
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`
`HUMANEYES TECHS., LTD.,
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`9 8
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`JURY TRIAL DEMANDED
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`Defendants.
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`c_<)1~4I*1tJjAINT.
`
`Plaintiff,
`
`V.
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`SONY ELECS., ]NC., SONY CORP., SONY )
`CORP. or AMERICA, SONY MOBILE
`)
`COMMS. AB, SONY MOBILE COMMS.
`)
`(USA), INC.,
`
`Plaintiff HumanEyes Technologies, Ltd., by and through its attorneys, for its Complaint
`
`for Patent Infringement against Defendants Sony Electronics Inc., Sony Corporation, Sony
`
`Corporation of America, Sony Mobile Communications AB, and Sony Mobile Communications
`
`(USA) Inc., alleges as follows, upon personal knowledge with respect to its own acts, and upon
`
`information and belief with respect to the circumstances and fact of others:
`
`PARTIES
`
`1.
`
`HumanEyes Technologies, Ltd. (“HumanEyes”) is a company organized under
`
`the laws of Israel having its principal place of business located at 1-4 High Tech Village,
`
`Edmond Safra Campus, The Hebrew University, Givat Ram, 91390 Jerusalem, Israel.
`
`HumanEyes Technologies, Inc. is controlled by and is a wholly-owned subsidiary of HumanEyes
`
`Technologies, Ltd. and is a corporation organized and existing under the laws of the State of
`
`Delaware, with its principle place of business at 366 North Broadway, Suite 410—C1, Jericho,
`
`New York, 11753.
`
`{006l7962;vl }
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`

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`Case 1:12-cv-00398-GMS Document 1 Filed 03/29/12 Page 2 of 13 PageID #: 2
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`2.
`
`On information and belief, Sony Corporation (“Sony Corp.”) is a corporation
`
`existing and organized under the laws of Japan with its principal place of business at 1-7-1
`
`Konan, Minato-ku, Tokyo 108-0075, Japan.
`
`3.
`
`On information and belief, Sony Corporation of America (“SCA”) is a subsidiary
`
`of Sony Corp. and is a corporation organized and existing under the laws of the State of New
`
`York, with its principal place of business at 550 Madison Avenue, 27"‘ Floor, New York, NY
`
`10022-3211. SCA is registered to do business in Delaware. Its registered agent for service of
`
`process in Delaware is The Corporation Trust Company, Corporation Trust Center, 1209 Orange
`
`Street, Wilmington, DE 19801.
`
`4.
`
`On information and belief, Sony Electronics Inc. (“SEI”) is a wholly-owned
`
`subsidiary of SCA, is an indirect subsidiary of Sony Corp., and is a Delaware corporation with
`
`its principal place of business located at 16530 Via Esprillo, San Diego, CA 92127-1708. SEI’s
`
`registered agent for service of process is Corporation Service Company, 2711 Centerville Road,
`
`Suite 400, Wilmington, DE 19808.
`
`5.
`
`On information and belief, Sony Mobile Communications AB (“Sony Mobile
`
`AB”) is a subsidiary of Sony Corp. and is a company organized and existing under the laws of
`
`Sweden with its principal place of business at 202 Hammersmith Rd, London W6 7DN, United
`
`Kingdom.
`
`6.
`
`On information and belief, Sony Mobile Communications (USA) Inc. (“Sony
`
`Mobile (USA)”) is an indirect subsidiary of Sony Corp. and is a Delaware corporation with its
`
`principal place of business located at 3333 Piedmont Road, Suite 600, Atlanta, Georgia 30305.
`
`Sony Mobile (USA)’s registered agent for service of process is Capitol Services, Inc., 1675
`
`South State Street, Suite B, Dover, DE, 19901.
`
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`7.
`
`On information and belief, Sony Corp., SCA, SEI, Sony Mobile AB, and Sony
`
`Mobile (USA), (collectively, “Sony”) individually and/or collectively and in concert, are
`
`engaged in the design, manufacture, importation into the United States, sale for importation, and
`
`sale after importation of the Accused Products (defined below).
`
`JURISDICTION AND VENUE
`
`8.
`
`This civil action for patent infringement arises under the patent laws of the United
`
`States, 35 U.S.C. § 100 et seq., including in particular under 35 U.S.C. § 271. This Court has
`
`subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and l338(a).
`
`9.
`
`Sony Corp. is subject to personal jurisdiction in this Court because, upon
`
`information and belief, Sony Corp. does and has done substantial business in this district,
`
`including both independently and through and with its subsidiaries and various commercial
`
`arrangements by placing its products, including those that infringe HumanEyes’ patents, into the
`
`stream of commerce, which stream is directed at the State of Delaware and this district, with the
`
`knowledge and/or understanding that such products would be sold in the State of Delaware and
`
`this district.
`
`10.
`
`On information and belief, Sony Corp. has sufficient minimum contacts with the
`
`district that an exercise of personal jurisdiction over Sony Corp. would not offend traditional
`
`notions of fair play and substantial justice and would be appropriate under Delaware Code Title
`
`10, Section 3104.
`
`ll.
`
`SCA is subject to personal jurisdiction in this Court because, upon information
`
`and belief, SCA does and has done substantial business in this district, including both
`
`independently and through and with its subsidiaries and various commercial arrangements by
`
`placing its products, including those that infringe HumanEyes’ patents, into the stream of
`
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`

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`commerce, which stream is directed at the State of Delaware and this district, with the
`
`knowledge and/or understanding that such products would be sold in the State of Delaware and
`
`this district.
`
`12.
`
`On information and belief, SCA has sufficient minimum contacts with the district
`
`that an exercise of personal jurisdiction over SCA would not offend traditional notions of fair
`
`play and substantial justice and would be appropriate under Delaware Code Title 10, Section
`
`3 104.
`
`13.
`
`SE1 is incorporated in Delaware and, therefore, resides in and is subject to
`
`personal jurisdiction in this judicial district.
`
`14.
`
`Sony Mobile AB is subject to personal jurisdiction in this Court because, upon
`
`information and belief, Sony Mobile AB does and has done substantial business in this district,
`
`including both independently and in concert with Sony Corp. and its subsidiaries and through
`
`various commercial arrangements by placing its products, including those that infringe
`
`Humar1Eyes’ patents, into the stream of commerce, which stream is directed at the State of
`
`Delaware and this district, with the knowledge and/or understanding that such products would be
`
`sold in the State of Delaware and this district.
`
`15.
`
`On information and belief, Sony Mobile AB has sufficient minimum contacts
`
`with the district that an exercise of personal jurisdiction over Sony Mobile AB would not offend
`
`traditional notions of fair play and substantial justice and would be appropriate under Delaware
`
`Code Title 10, Section 3104.
`
`16.
`
`Sony Mobile (USA) is incorporated in Delaware and, therefore, resides in and is
`
`subject to personal jurisdiction in this judicial district.
`
`{006l7962;V1 }
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`

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`17.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 139l(b) and (c) and/or
`
`and 1400(b).
`
`BACKGROUND AS TO ALL COUNTS
`
`18.
`
`Conventional methods of generating 3D images require special, expensive double
`
`lens cameras. In 1998, Professor SlunuelPe1eg, a world-renowned figure in Computer Vision,
`
`and members of his research team proposed an innovative, new method for generating 3D
`
`panoramic images by combining portions of multiple images recorded by an ordinary camera.
`
`This breakthrough has made it possible to bring inexpensive 3D photography to standard digital
`
`cameras and mobile devices. Professor Peleg and his co—inventors were awarded patent
`
`protection by the U.S. Patent and Trademark Office for that technology in U.S. Patent Nos.
`
`6,665,003 and 7,477,284 (collectively, the “Asserted Patents”).
`
`19.
`
`In 2000, HumanEyes Technologies, Ltd. (“HumanEyes”) was founded to further
`
`develop and commercialize products that realize the innovative potential of Professor Peleg and
`
`his team’s discoveries in generating and displaying 3D mosaic images and related technologies.
`
`HumanEyes, the exclusive licensee to Professor Peleg’s 3D stereo panoramic patents, applies
`
`that patented vision to provide a complete, end-to-end solution for creating and printing 3D
`
`photographic effects.
`
`20.
`
`Inventor an_d HumanEyes co-founder Shmuel Peleg is widely recognized as a
`
`leading scholar and researcher in the field of Computer Vision, with over 127 publications and
`
`16 U.S. Patents.
`
`21.
`
`Professor Peleg’s prominence in the field of Computer Vision is well-known to
`
`Sony. Sony Corporation Research Engineer Dr. Kenji Tanaka has cited to Professor Peleg’s
`
`work in at least three of his own publications and described Professor Peleg as “one of the most
`
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`famous people in this field” during correspondence between Dr. Tanaka and Professor Peleg in
`
`2004. Professor Peleg’s works have also been cited by Sony and/or the PTO examiner in at least
`
`5 of Sony’s U.S. patents (U.S. Patent Nos. 7,542,606; 7,764,283; 7,831,086; 7,840,095; and
`
`8,086,072) and at least 7 of Sony’s published U.S. Patent Applications (U.S. Patent Application
`
`Pub. Nos. 2011/0122953, 2011/0123131, 2011/0286526, 2011/0293014, 2010/0289881,
`
`2011/0293195, 2012/0019725).
`
`22.
`
`Professor Peleg and others at HumanEyes have discussed Professor Pe1eg’s
`
`breakthrough work on 3D panorama mosaic imaging with employees at Sony—including at least
`
`Dr. Tanaka, Toshiyuki Ogura, and Atsushi Iizuka at Sony Corporation; marketing director Mary
`
`Abram at Sony Electronics Inc.; and Senior Vice President of Sony Corporation of America’s
`
`“Sony 3D Technology Center” Buzz Hays—since at least December, 2004.
`
`THE ASSERTED PATENTS
`
`23.
`
`United States Patent No. 6,665,003 (’003), entitled “System and Method for
`
`Generating and Displaying Panoramic Images and Movies,” issued on December 16, 2003, to
`
`inventors Shmuel Peleg, Moshe Ben—Ezra, and Robert S. Rosenschein. Yissum Research
`
`Development Company of the Hebrew University of Jerusalem was assigned all right, title, and
`
`interest in the ’003 patent by the named inventors and is presently owner. HumanEyes is the
`
`exclusive licensee of the ’003 patent, with all substantial rights and interest in practicing,
`
`sublicensing, and enforcement. A true and correct copy of the ’003 patent is attached to this
`
`Complaint as Exhibit A.
`
`24.
`
`U.S. Patent No. 7,477,284 (’284), entitled “System and Method for Capturing and
`
`Viewing Stereoscopic Panoramic Images,” issued on January 13, 2009, to inventors Shmuel
`
`Peleg, Moshe Ben-Ezra, and Yael Pritch. Yissum Research Development Company of the
`
`{006l7962;vl }
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`

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`Hebrew University of Jerusalem was assigned all right, title, and interest in the ’284 patent by
`
`the named inventors and is presently owner. HumanEyes is the exclusive licensee of the ’284
`
`patent, with all substantial rights and interest in practicing, sublicensing, and enforcement. A
`
`true and correct copy of the ’284 patent is attached to this Complaint as Exhibit B.
`
`25.
`
`HumanEyes is the exclusive licensee of the ’003 and ’284- patents, with all
`
`substantial rights and interest in practicing, sublicensing, and enforcing each.
`
`THE ACCUSED PRODUCTS
`
`26.
`
`The Accused Products are cameras and mobile devices and associated firmware
`
`and/or sofiwarel that, together or independently, are capable of generating 3D panoramic mosaic
`
`images.
`
`27.
`
`On information and belief, Sony’s 3D Sweep Panorama mode and/or Sweep
`
`Multi-Angle mode and those cameras and mobile devices that are sold with or may be adapted
`
`for use with the 3D Sweep Panorama mode and/or Sweep Multi-Angle mode—including but not
`
`limited to Cyber-shot (DSC) models HX7V, HX9V, HXIOV, HX2OV/B, HX30V/B, HXIOOV,
`
`HXZOOV, TX9, TXIO, TX20, TX55, TX66, TXIOOV, TXZOOV, WX5, WX9, WX10, WXSO,
`
`WXl50; DSLR (01 series) models NEX-3, NEX-C3, NEX-5, NEX—5N, NEX-7, 01560, $80,
`
`or33L, 085, 065V, 065V, a65VK, d77V, and o[77VQ; and mobile device (Xperia) models active,
`
`arc, are S, ion, neo, neo V, mini pro, pro, ray, and Live with Walkman—infringe at least one
`
`claim of the Asserted Patents.
`
`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,665,003
`
`28.
`
`HumanEyes incorporates by reference paragraphs 1 through 27 of this Complaint
`
`as if fully set forth herein.
`
`1 The associated firmware and/or software include, for example, operating systems, user
`interfaces, and application software, and the firmware associated with an image sensor.
`
`{0O617962;v1 }
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`29.
`
`Upon information and belief, Sony has infringed and continues to infringe and/or
`
`induce infi-ingement of one or more claims of the ’003 patent in violation of 35 U.S.C. § 271(a),
`
`(b) and/or (c), literally or under the doctrine of equivalents, by making, using, offering for sale,
`
`and selling in the United States and by importing into the United States, without authority, the
`
`Accused Products.
`
`30.
`
`On information and belief, Sony directly infringes and/or will infringe the ’003
`
`patent by making, using, selling, offering for sale, and importing the Accused Products
`
`practicing at least one claim of the ’003 patent.
`
`31.
`
`On information and belief, Sony has knowledge of the ’0O3 patent, at least
`
`because Sony was provided with a copy of this Complaint.
`
`32.
`
`On information and belief, Sony Corp. has had knowledge of the ’003 patent
`
`since at least May 13, 2009 because the ’003 patent is cited and discussed in Sony Corp.’s
`
`Singapore Patent Application No. 200903332-5 and its U.S. counterpart, U.S. Patent Application
`
`No. 12/775,024, which is assigned to Sony Corp.
`
`33.
`
`Upon information and belief, SCA, SE1, Sony Mobile AB, and Sony Mobile
`
`(USA) have had constructive knowledge of the ’003 patent since at least on or around May 13,
`
`2009, at least because Sony Corp. had knowledge of the ’003 patent since then.
`
`34.
`
`Given the prominence of Professor Peleg’s work and Sony’s knowledge of the
`
`patents, upon information and belief, Sony either (a) has knowledge that making, using, selling,
`
`offering for sale, and importing the Accused Products constitute infringement of the ’003 patent,
`
`or (b) subjectively believes that there has been and continues to be a high risk that making, using,
`
`selling, offering for sale, and importing the Accused Products constitute infiingement of the ’003
`
`{006l7962;v1 }
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`

`
`Case 1:12-cv-00398-GMS Document 1 Filed 03/29/12 Page 9 of 13 PageID #: 9
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`patent and has taken deliberate steps to avoid determining whether the acts actually constitute
`
`infringement.
`
`35.
`
`Sony has made, used, sold, offered for sale, and imported and continues to make,
`
`use, sell, offer for sale, and import the Accused Products despite an objectively high likelihood
`
`that its actions, individually and collectively, constitute infringement of the ’OO3 patent.
`
`Moreover, upon information and belief, the risk that its actions constitute infringement of a valid
`
`U.S. patent was either actually known to Sony or, given the prominence of Professor Pe1eg’s
`
`work and Sony’s knowledge of the patents and of HumanEyes’ work back to at least 2004, is and
`
`was so clear that it should have been known to Sony.
`
`36.
`
`On infonnation and belief, Sony indirectly infringes the ’OO3 patent by actively
`
`inducing the infringement of at least one claim of the ’OO3 patent, including without limitation by
`
`knowingly inducing infringement by end users of the Accused Products.
`
`37.
`
`On information and belief, Sony contributes to the infringement of at least one
`
`claim of the ’OO3 patent because Sony knows that the Accused Products are made for use in
`
`infringement and are not staple articles of commerce suitable for substantial non-infringing use.
`
`38.
`
`HumanEyes has been and continues to be damaged by Sony’s infringement of the
`
`’OO3 patent in an amount to be determined at trial.
`
`39.
`
`Upon information and belief, Sony’s infringement of the ’OO3 patent has been and
`
`continues to be willful, entitling HumanEyes to enhanced damages pursuant to 35 U.S.C. § 284.
`
`40.
`
`Upon information and belief, Sony’s actions make this an exceptional case
`
`pursuant to 35 U.S.C. § 285.
`
`{O06l7962;vl }
`
`

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`Case 1:12-cv—00398—GMS Document 1
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`
`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 7 477 284
`
`41.
`
`HumanEyes incorporates by reference paragraphs 1 through 40 of this Complaint
`
`as if fully set forth herein.
`
`42.
`
`Upon information and belief, Sony has infringed and continues to infringe and/or
`
`induce infringement of one or more claims of the ’284 patent in violation of 35 U.S.C. § 271(a),
`
`(b) and/or (c), literally or under the doctrine of equivalents, by making, using, offering for sale,
`
`and selling in the United States and by importing into the United States, without authority, the
`
`Accused Products.
`
`43.
`
`On information and belief, Sony directly infringes and/or will infringe the ’284
`
`patent by making, using, selling, offering for sale, and importing the Accused Products
`
`practicing at least one claim of the ’284 patent.
`
`44.
`
`On information and belief, Sony currently has knowledge of the ’284 patent, at
`
`least because Sony was provided with a copy of this Complaint.
`
`45.
`
`On information and belief, Sony Corp. and SEI have had knowledge of the ’284
`
`patent since at least April 1 1, 2011 because the ’284 patent was cited and discussed by the PTO
`
`examiner in an April 11, 2011 non-final rejection during the prosecution of U.S. Patent No.
`
`8,086,072 assigned to Sony Corp. and SEI.
`
`46.
`
`Upon information and belief, SCA, Sony Mobile AB, and Sony Mobile (USA)
`
`have had constructive knowledge of the ’284 patent since at least on or around April 11, 2011 at
`
`least because Sony Corp. and SE1 had knowledge since then.
`
`47.
`
`Given the prominence of Professor Peleg’s work and Sony’s knowledge of the
`
`patents, upon information and belief, Sony either (a) has knowledge that making, using, selling,
`
`offering for sale, and importing the Accused Products constitute infringement of the ’284 patent,
`
`{00617962;v1 }
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`l0
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`

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`or (b) subjectively believes that there has been and continues to be a high risk that making, using,
`
`selling, offering for sale, and importing the Accused Products constitute infiingement of the ’284
`
`patent and has taken deliberate steps to avoid determining whether the acts actually constitute
`
`infringement.
`
`48.
`
`Sony has made, used, sold, offered for sale, and imported and continues to make,
`
`use, sell, offer for sale, and import the Accused Products despite an objectively high likelihood
`
`that its actions, individually and collectively, constitute infringement of the ’284 patent.
`
`Moreover, upon information and belief, the risk that its actions constitute infringement of a valid
`
`U.S. patent was either actually known to Sony or, given the prominence of Professor Peleg’s
`
`work and Sony’s knowledge of the patents, is and was so clear that it should have been known to
`
`Sony.
`
`49.
`
`On information and belief, Sony indirectly infringes the ’284 patent by actively
`
`inducing the infringement of the ’284 patent, including without limitation by end users of the
`
`Accused Products.
`
`50.
`
`On information and belief, Sony contributes to the infringement of the ’284 patent
`
`because Sony knows that the Accused Products are made for use in infringement and are not
`
`staple articles of commerce suitable for substantial non-infringing use.
`
`51.
`
`HumanEyes has been and continues to be damaged by Sony’s infringement of the
`
`’284 patent in an amount to be determined at trial.
`
`52.
`
`Upon information and belief, Sony’s infringement of the ’284 patent has been and
`
`continues to be Wlllflll, entitling HumanEyes to enhanced damages pursuant to 35 U.S.C. § 284.
`
`53.
`
`Upon information and belief, Sony’s actions make this an exceptional case
`
`pursuant to 35 U.S.C. § 285.
`
`{006l7962;vl }
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`l 1
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`DEMAND FOR JURY TRIAL
`
`54.
`
`Pursuant to Federal Rule of Civil Procedure 38(b), Human]-Eyes demands a trial
`
`by jury.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, HumanEyes respectfully prays that this Court enter judgment in its favor
`
`as follows:
`
`a) declaring that Sony has directly infiinged, induced infringement of, and/or
`
`contributed to the infringement of one or more claims of the Asserted Patents;
`
`b) awarding HumanEyes all damages adequate to compensate for Sony’s
`
`infringement, and in no event less than a reasonably royalty for Sony’s acts of infringement,
`
`including all pre-judgment and post—j udgment interest at the maximum rate allowed by law; and
`
`c) awarding HumanEyes treble damages pursuant to 35 U.S.C. § 284 as a result of
`
`Sony’s willful conduct;
`
`(1) declaring this to be an exceptional case and awarding HumanEyes its attorneys’
`
`fees pursuant to 35 U.S.C. § 285; and
`
`e) awarding HumanEyes any further and additional relief as the Court may deem just
`
`and equitable.
`
`{00617962;v1 }
`
`12
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`

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`Case 1:12-cv-00398-GMS Document 1 Filed 03/29/12 Page 13 of 13 PageID #: 13
`Cas_e 1:12-cv—00398—GMS Document 1
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`
`ASHBY & GEDDES
`
`TJHO»; 9)‘!/41 AK
`
`Steven J. Balick (ID. #2114)
`Tiffany Geyer Lydon (I.D. #3950)
`Andrew C. Mayo (ID. #5207)
`500 Delaware Avenue, 8”‘ Floor
`P.O. Box 1150
`
`Wilmington, Delaware 19899
`(302) 654-1888
`sba1ick@ashby-geddes.com
`tlydon@ashby-geddes.com
`amayo@ashby-geddes.com
`
`Attorneysfor Plaintiff
`
`Of Counsel:
`
`Matthew D. Powers
`
`Steven S. Cherensky
`Paul T. Ehrlich
`Stefani C. Smith
`
`Robert L. Gerrity
`TENSEGRITY LAW GROUP LLP
`
`555 Twin Dolphin Drive, Suite 360
`Redwood Shores, CA 94065
`(650) 802-6000
`
`Dated: March 29, 2012
`
`{00617962;v1 }
`
`1 3

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