`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Civil Action No. 17-585-VAC-MPT
`
`
`UNIVERSAL SECURE REGISTRY, LLC,
`
`
`Plaintiff,
`
`
`
`vs.
`
`APPLE INC., VISA INC., and VISA U.S.A., INC.,
`
`
`Defendants.
`
`
`
`
`DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S COMPLAINT
`
`Pursuant to Federal Rule of Civil Procedure 12(b)(6), Defendants Apple Inc., Visa Inc.,
`
`and Visa U.S.A. Inc. (“Defendants”) respectfully move to dismiss this case with prejudice. The
`
`grounds for this motion are fully set forth in the Defendants’ Opening Brief in support of this
`
`motion, filed contemporaneously herewith, and upon the papers, records, and pleadings on file
`
`with the Court.
`
`
`
`
`
` /s/ Jason J. Rawnsley
`
`Fredrick L. Cottrell, III (#2555)
`Jason J. Rawnsley (#5379)
`RICHARDS LAYTON, & FINGER, P.A.
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`rawnsley@rlf.com
`
`Attorneys for Defendant Apple Inc.
`
`
`
`
`
`
`
`/s/ Bindu Palapura
`
`David E. Moore (#3983)
`Bindu Palapura (#5370)
`POTTER ANDERSON CORROON LLP
`1313 North Market Street 6th Floor
`Wilmington, DE 19801
`(302) 984-6147
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`
`Attorneys for Defendants Visa Inc. and
`Visa U.S.A., Inc.
`
`
`
`
`Case 1:17-cv-00585-JFB-SRF Document 16 Filed 08/25/17 Page 2 of 2 PageID #: 338
`
`OF COUNSEL:
`
`James Yoon
`Jamie Y. Otto
`WILSON SONSINI GOODRICH & ROSATI
`650 Page Mill Road
`Palo Alto CA 94304
`(650) 320-4726
`
`
`
`OF COUNSEL:
`
`Mark D. Selwyn
`WILMER CUTLER PICKERING
` HALE & DORR LLP
`950 Page Mill Road
`Palo Alto, CA 94304
` (650) 8580-6000
`
`Monica Grewal
`WILMER CUTLER PICKERING
` HALE & DORR LLP
`60 State Street
`Boston, MA 02109
`(202) 663-6000
`
`Derek A. Gosma
`WILMER CUTLER PICKERING
` HALE & DORR LLP
`350 South Grand Avenue, Suite 2100
`Los Angeles, CA 90071
`(213) 443-5300
`
`Dated: August 25, 2017
`
`
`
`
`2
`
`
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