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Case 1:23-cv-01373-MN Document 11 Filed 02/12/24 Page 1 of 3 PageID #: 467
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`ALMONDNET, INC. and INTENT IQ, LLC,
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`v.
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`Plaintiffs,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 23-1373 (MN)
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`LINKEDIN, CORPORATION,
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`Defendant.
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`DEFENDANT’S RULE 12(B)(6) MOTION TO DISMISS
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`Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, Defendant
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`LinkedIn, Corp. respectfully moves for an order, substantially similar to the proposed order
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`attached hereto, dismissing Plaintiffs’ claims for induced, contributory, and willful infringement
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`of the ʼ139, ʼ146, ʼ398, and ʼ878 patents alleged in Counts VI, VII, VIII, and IX of the Complaint
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`(D.I. 1 at ¶¶ 46–48, 56–58, 66–68, 76–78). The grounds for this motion are set forth in the
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`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
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`/s/ Rodger D. Smith II
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`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19801
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`rsmith@morrisnichols.com
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`Attorneys for Defendant
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`accompanying Opening Brief.
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`OF COUNSEL:
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`David J. Silbert
`Michelle Ybarra
`Erin E. Meyer
`Theresa Dawson
`Amos J. B. Espeland
`Sydnee Joi Robinson
`KEKER, VAN NEST & PETERS LLP
`633 Battery Street
`San Francisco, CA 94111-1809
`(415) 391-5400
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`February 12, 2024
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`

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`Case 1:23-cv-01373-MN Document 11 Filed 02/12/24 Page 2 of 3 PageID #: 468
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`ALMONDNET, INC. and INTENT IQ, LLC,
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`v.
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`Plaintiffs,
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`C.A. No. 23-1373 (MN)
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`[PROPOSED] ORDER
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`LINKEDIN, CORPORATION,
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`Defendant.
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`At Wilmington this _____ day of ______________, 2024, the Court having
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`considered Defendant LinkedIn, Corp.’s Rule 12(b)(6) Motion to Dismiss (the “Motion”), and the
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`papers and argument submitted in connection therewith,
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`IT IS HEREBY ORDERED that:
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`1.
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`2.
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`Defendant’s Motion is GRANTED; and
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`Plaintiffs’ claims for induced, contributory, and willful infringement of the
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`ʼ139, ʼ146, ʼ398, and ʼ878 patents alleged in Counts VI, VII, VIII, and IX of the Complaint (D.I. 1
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`at ¶¶ 46–48, 56–58, 66–68, 76–78) are DISMISSED.
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`____________________________________
`The Honorable Maryellen Noreika
`United States District Judge
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`Case 1:23-cv-01373-MN Document 11 Filed 02/12/24 Page 3 of 3 PageID #: 469
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`CERTIFICATE OF SERVICE
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`I hereby certify that on February 12, 2024, I caused the foregoing to be
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`electronically filed with the Clerk of the Court using CM/ECF, which will send notification of
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`such filing to all registered participants.
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`I further certify that I caused copies of the foregoing document to be served on
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`February 12, 2024, upon the following in the manner indicated:
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`VIA ELECTRONIC MAIL
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`VIA ELECTRONIC MAIL
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`/s/ Rodger D. Smith II
`__________________________
`Rodger D. Smith II (#3778)
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`Brian E. Farnan, Esquire
`Michael J. Farnan, Esquire
`FARNAN LLP
`919 North Market Street, 12th Floor
`Wilmington DE 19801
`Attorneys for Plaintiffs
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`Reza Mirzaie, Esquire
`Ben Wang, Esquire
`James Milkey, Esquire
`Amy Hayden, Esquire
`James Tsuei, Esquire
`Daniel Kolko, Esquire
`Jason Wietholter, Esquire
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Attorneys for Plaintiffs
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