`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiffs,
`
`
`
`Case No. 1:19-cv-01410-MN
`
`
`
`VB Assets, LLC,
`
`
`
`v.
`
`
`Amazon.com, Inc.; Amazon.com LLC; Amazon
`Web Service, Inc.; A2Z Development Center, Inc.
`d/b/a/ Lab126; Rawles LLC; AMZN Mobile LLC;
`AMZN Mobile 2 LLC; Amazon.com Service, Inc.
`f/k/a Amazon Fulfillment Services, Inc.; and
`Amazon Digital Services LLC,
`
`
`Defendants.
`
`
`
`
`
`
`DEFENDANTS’ MOTION TO DISMISS FIRST AMENDED COMPLAINT
`PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 12(b)(6)
`
`Defendants hereby respectfully move to dismiss the First Amended Complaint in the
`
`above action (D.I. 22) with prejudice, pursuant to Federal Rule of Civil Procedure Rule 12(b)(6).
`
`The grounds for this motion are fully set forth in Defendants’ accompanying opening brief.
`
`Of Counsel:
`
`J. David Hadden, CSB No. 176148
`Email: dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`Email: sshamilov@fenwick.com
`Ravi R. Ranganath
`rranganath@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`Email: vsalmastlian@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.520
`
`October 30, 2019
`
`{01501711;v1 }
`
`
`
`
`
`
`
`ASHBY & GEDDES
`
`
`/s/ Steven J. Balick
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`
`Counsel for Defendants
`Amazon.com, Inc.; Amazon.com LLC;
`Amazon Web Service, Inc.; A2Z Development
`Center, Inc. d/b/a/ Lab126; Rawles LLC;
`AMZN Mobile LLC; AMZN Mobile 2 LLC;
`Amazon.com Service, Inc. f/k/a Amazon
`Fulfillment Services, Inc.; and Amazon
`Digital Services LLC
`
`
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