`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiff,
`
`C.A. No. 1:19-cv-01410-MN
`
`
`
`
`
`VB ASSETS, LLC,
`
`
`
`
`v.
`
`
`AMAZON.COM, INC., AMAZON.COM LLC,
`AMAZON WEB SERVICES, INC., A2Z
`DEVELOPMENT CENTER, INC. d/b/a LAB126,
`RAWLES LLC, AMZN MOBILE LLC, AMZN
`MOBILE 2 LLC, AMAZON.COM SERVICES, INC.
`f/k/a AMAZON FULFILLMENT SERVICES, INC.,
`and AMAZON DIGITAL SERVICES LLC,
`
`
`Defendants.
`
`
`
`DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT OF INVALIDITY
`
`Defendants Amazon.com, Inc., Amazon.com LLC, Amazon Web Services, Inc., A2Z
`
`Development Center, Inc. d/b/a Lab126, Rawles, LLC, AMZN Mobile LLC, AMZN Mobile 2
`
`LLC, Amazon.com Services, Inc. f/k/a Amazon Fulfillment Services, Inc., and Amazon.com
`
`Services LLC (collectively, “Amazon”) hereby respectfully move, pursuant to Rule 56 of the
`
`Federal Rules of Civil Procedure, for the entry of summary judgment that the asserted claims of
`
`U.S. Patent Nos. 9,626,703, 9,269,097, and 8,073,681 are patent-ineligible and invalid under 35
`
`U.S.C. § 101. The grounds for this motion are set forth in Amazon’s accompanying omnibus
`
`opening brief. A proposed order is attached.
`
`{01879440;v1 }
`
`1
`
`
`
`Case 1:19-cv-01410-MN Document 184 Filed 02/03/23 Page 2 of 2 PageID #: 3098
`
`
`
`
`
`/s/ Andrew C. Mayo
`Steven J. Balick (#2114)
`sbalick@ashbygeddes.com
`Andrew C. Mayo (#5207)
`amayo@ashbygeddes.com
`ASHBY & GEDDES, P.A.
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`
`Counsel for Defendants
`Amazon.com, Inc., Amazon.com LLC, Amazon
`Web Services, Inc., A2Z Development Center,
`Inc. d/b/a Lab126, Rawles, LLC, AMZN
`Mobile LLC, AMZN Mobile 2 LLC,
`Amazon.com Services, Inc. f/k/a Amazon
`Fulfillment Services, Inc., and Amazon.com
`Services LLC
`
`
`
`
`
`
`
`Of counsel:
`
`J. David Hadden, CSB No. 176148
`dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`vsalmastlian@fenwick.com
`Allen Wang, CBS No. 278953
`awang@fenwick.com
`Johnson Kuncheria, CSB No. 335765
`jkuncheria@fenwick.com
`Min Wu, CSB No. 307512
`min.wu@fenwick.com
`Jeffrey A. Ware, CSB No. 271603
`jware@fenwick.com
`Rebecca A.E. Fewkes, CSB No. 209168
`rfewkes@fenwick.com
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`(650) 988-8500
`
`Dated: February 3, 2023
`
`
`{01879440;v1 }
`
`2
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