Case 1:24-cv-00376-UNA Document 1 Filed 03/22/24 Page 1 of 15 PageID #: 1
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
`ALMONDNET, INC., INTENT IQ, LLC, and
`DATONICS LLC,
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`
`
`
`
`
`
`Plaintiffs,
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`
`
`Case No.
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`
`
`JURY TRIAL DEMANDED
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`
`
`
`
`
`
`
`
`
`
`v.
`
`LOTAME SOLUTIONS, INC.,
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`
`
`
`
`
`
`Defendant.
`
`COMPLAINT FOR PATENT INFRINGEMENT AGAINST
`LOTAME SOLUTIONS, INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiffs AlmondNet, Inc. (“AlmondNet”), Intent IQ,
`
`LLC (“Intent IQ”), and Datonics, LLC (“Datonics”) (collectively, “Plaintiffs”) make the following
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`allegations against Defendant Lotame Solutions, Inc. (“Defendant” or “Lotame”):
`
`INTRODUCTION AND PARTIES
`
`1.
`
`This complaint arises from Defendant’s unlawful infringement of the following
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`United States patents owned by Plaintiffs, which generally relate to novel internet / network based
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`advertising systems and methods: United States Patent Nos. 8,677,398, 8,589,210, 10,984,445,
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`8,775,249, and 8,494,904 (collectively, the “Asserted Patents”). Plaintiffs own all right, title, and
`
`interest in the Asserted Patents to file this case.
`
`2.
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`AlmondNet, Inc. is a corporation organized and existing under the laws of the state
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`of Delaware, having its place of business at 37-18 Northern Blvd. Suite 404, Long Island City,
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`NY, 11101. Intent IQ, LLC is a Delaware limited liability company, having its place of business
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`
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`1
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`at 37-18 Northern Blvd. Suite 404, Long Island City, NY, 11101. Datonics is a limited liability
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`company organized and existing under the laws of the state of Delaware, having its principal place
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`of business at 37-18 Northern Boulevard, Suite 404, Long Island City, New York 11101.
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`AlmondNet, Inc., Intent IQ, LLC, and Datonics LLC are collectively referred herein as the
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`“Plaintiffs.”
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`3.
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`Founded in 1998, AlmondNet has developed an extensive suite of industry-leading
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`targeted advertising solutions and products, is focused on R&D and the licensing of its extensive
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`portfolio of enabling technology and intellectual property covering numerous areas of the targeting
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`landscape and ecosystem, including profile-based bidding, behavioral targeting, online and offline
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`data monetization, addressable advertising, and multi-platform advertising.
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`4.
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`Intent IQ is a leading company in the field of cross-device-based ad targeting,
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`retargeting, audience extension, and attribution. IIQ’s “Dynamic Device Map” identifies a given
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`user across multiple device types, including laptops, desktops, smartphones, tablets, and
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`televisions, so as to assist advertisers in delivering targeted ads to consumers on all of their screens.
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`Intent IQ can facilitate ad targeting based on profile data aggregated from activity on any of a
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`user’s screens, as well as measure the impact of previously delivered ads on the same or different
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`screen.
`
`5.
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`Datonics is a leading aggregator and distributor of highly granular search, purchase-
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`intent, and life-stage data. Datonics offers data users (including ad networks, ad exchanges,
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`demand side platforms, and publishers) pre-packaged or customized keyword-based “data
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`segments” that can facilitate the delivery of advertisements to consumers wherever they go online,
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`with the ads being focused on subjects relevant to the individual consumer yet delivered in a
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`privacy-sensitive way.
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`2
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`6.
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`On information and belief, Defendant is a Delaware corporation with a principal
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`place of business at 8890 McGaw Road, Suite 250, Columbia, MD 21045. Defendant may be
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`served with process through its registered agent, the Corporation Service Company, at 251 Little
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`Falls Drive Wilmington, Delaware 19808.
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`JURISDICTION AND VENUE
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`7.
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`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a).
`
`8.
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`This Court has personal jurisdiction over Defendant in this action because
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`Defendant is incorporated under the laws of the state of Delaware, has committed acts within this
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`District giving rise to this action, and has established minimum contacts with this forum such that
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`the exercise of jurisdiction over Defendant would not offend traditional notions of fair play and
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`substantial justice. Defendant, directly and through subsidiaries or intermediaries, has committed
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`and continues to commit acts of infringement in this District by, among other things, importing,
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`offering to sell, and selling products and services that infringe the Asserted Patents.
`
`9.
`
`Venue is proper in this District because Defendant is incorporated under the laws
`
`of the State of Delaware.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 8,677,398
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`10.
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`Plaintiffs reallege and incorporate by reference the foregoing paragraphs as if fully
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`set forth herein.
`
`11.
`
`Plaintiffs own all rights, title, and interest in U.S. Patent No. 8,677,398, titled
`
`“systems and methods for taking action with respect to one network-connected device based on
`
`
`
`3
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`

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`activity on another device connected to the same network,” issued on March 18, 2014 (“the ’398
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`patent”). A true and correct copy of the ’398 patent is attached as Exhibit 1.
`
`12.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products and/or services (“Accused Instrumentalities”), such as, e.g., Panorama
`
`Identity and Lotame’s Spherical Platform, that directly infringe, literally and/or under the doctrine
`
`of equivalents, claims of the ’398 patent.
`
`13.
`
`The infringement of the ’398 patent is also attributable to Defendant. Defendant
`
`and/or users of the Accused Instrumentalities directs and controls use of the Accused
`
`Instrumentalities to perform acts that result in infringement the ’398 patent, conditioning benefits
`
`on participation in the infringement and establishing the timing and manner of the infringement.
`
`14.
`
`Defendant also knowingly and intentionally induces infringement of claims of
`
`the ’398 patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendant has had knowledge of the ’398 patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’398 patent, Defendant continues to
`
`make, use, offer for sale, sell, and and/or import the Accused Instrumentalities, and to actively
`
`encourage and instruct customers and other companies to make, use, offer for sale, sell, and/or
`
`import the Accused Instrumentalities in ways that directly infringe the ’398 patent. Defendant does
`
`so intending that its customers and end users will commit these infringing acts.
`
`15.
`
`Defendant has also infringed, and continues to infringe, claims of the ’398 patent
`
`by offering to commercially distribute, commercially distributing, making, and/or importing the
`
`Accused Instrumentalities, which are used in practicing the process, or using the systems, of the
`
`patent, and constitute a material part of the invention. Defendant has knowledge of or is willfully
`
`blind to the components in the Accused Instrumentalities being especially made or especially
`
`
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`4
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`adapted for use in infringement of the patent, not a staple article, and not a commodity of
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`commerce suitable for substantial noninfringing use. Accordingly, Defendant is, contributorily
`
`infringing the ’398 patent, in violation of 35 U.S.C. § 271(c).
`
`16.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims
`
`of the ’398 patent. A claim chart comparing an independent claim of the ’398 patent to
`
`representative Accused Instrumentalities is attached as Exhibit 2, which is hereby incorporated by
`
`reference in its entirety.
`
`17.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Instrumentalities, Defendant has injured Plaintiffs and is liable for infringement of
`
`the ’398 patent pursuant to 35 U.S.C. § 271.
`
`18.
`
`As a result of Defendant’s infringement of the ’398 patent, Plaintiffs are entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`19.
`
`Plaintiffs have suffered and continue to suffer irreparable harm, through its loss of
`
`market share and goodwill, for which there is no adequate remedy at law. For example, Intent IQ
`
`has and will continue to suffer this harm by virtue of Defendant’s infringement of one or more
`
`claims of the ’398 patent. Intent IQ’s bid enhancement product allows for targeted advertising on
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`a different site than where the profile data was collected, i.e., by providing third-party IDs in bid
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`requests. Intent IQ’s graph product associates devices on a household level, personal level, and
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`device level. Lotame’s identity resolution products, such as, e.g., Panorama Identity, directly
`
`compete with Intent IQ’s bid enhancement and graph products. For example, based on household
`
`level device identifier associations Lotame passes its Panorama ID for a particular visitor to active
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`
`
`5
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`
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`SSP bid adapters so that ad exchanges and/or DSPs can more confidently bid on targeted
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`advertisements using profile data collected about a website visitor from that visitor’s visit to a
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`different site. See Ex. 2. Intent IQ’s offering of bid enhancement and device graph services is
`
`prejudiced by Defendant’s actions. For example, Defendant’s actions have interfered with and will
`
`interfere with Plaintiffs’ ability to license technology. The balance of hardships favors Intent IQ’s
`
`ability to commercialize its own ideas and technology. The public interest in allowing Intent IQ to
`
`enforce its right to exclude outweighs other public interests. A permanent injunction would not
`
`result in depriving the public of the patented invention because consumer need for the patented
`
`invention can be met by at least Intent IQ’s product offerings as well as at least one other
`
`advertising platform who has taken a license to the ’398 Patent.
`
`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 8,589,210
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`20.
`
`Plaintiffs reallege and incorporate by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`21.
`
`Plaintiffs own all rights, title, and interest in U.S. Patent No. 8,589,210, titled
`
`“providing collected profiles to media properties having specified interests,” issued on November
`
`19, 2013 (“the ’210 patent”). A true and correct copy of the ’210 patent is attached as Exhibit 3.
`
`22.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products and/or services (“Accused Instrumentalities”), such as, e.g., Lotame Data
`
`Exchange and Lotame Data Stream, that directly infringe, literally and/or under the doctrine of
`
`equivalents, claims of the ’210 patent.
`
`23.
`
`The infringement of the ’210 patent is also attributable to Defendant. Defendant
`
`and/or users of the Accused Instrumentalities directs and controls use of the Accused
`
`
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`6
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`
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`Instrumentalities to perform acts that result in infringement the ’210 patent, conditioning benefits
`
`on participation in the infringement and establishing the timing and manner of the infringement.
`
`24.
`
`Defendant also knowingly and intentionally induces infringement of claims of
`
`the ’210 patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendant has had knowledge of the ’210 patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’210 patent, Defendant continues to
`
`make, use, offer for sale, sell, and and/or import the Accused Instrumentalities, and to actively
`
`encourage and instruct customers and other companies to make, use, offer for sale, sell, and/or
`
`import the Accused Instrumentalities in ways that directly infringe the ’210 patent. Defendant does
`
`so intending that its customers and end users will commit these infringing acts.
`
`25.
`
`Defendant has also infringed, and continues to infringe, claims of the ’210 patent
`
`by offering to commercially distribute, commercially distributing, making, and/or importing the
`
`Accused Instrumentalities, which are used in practicing the process, or using the systems, of the
`
`patent, and constitute a material part of the invention. Defendant has knowledge of or is willfully
`
`blind to the components in the Accused Instrumentalities being especially made or especially
`
`adapted for use in infringement of the patent, not a staple article, and not a commodity of
`
`commerce suitable for substantial noninfringing use. Accordingly, Defendant is, contributorily
`
`infringing the ’210 patent, in violation of 35 U.S.C. § 271(c).
`
`26.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims
`
`of the ’210 patent. A claim chart comparing an independent claim of the ’210 patent to
`
`representative Accused Instrumentalities is attached as Exhibit 4, which is hereby incorporated by
`
`reference in its entirety.
`
`
`
`7
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`27.
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`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Instrumentalities, Defendant has injured Plaintiffs and is liable for infringement of
`
`the ’210 patent pursuant to 35 U.S.C. § 271.
`
`28.
`
`As a result of Defendant’s infringement of the ’210 patent, Plaintiffs are entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`29.
`
`Plaintiffs have suffered and continue to suffer irreparable harm, through its loss of
`
`market share and goodwill, for which there is no adequate remedy at law. For example, Datonics
`
`has and will continue to suffer this harm by virtue of Defendant’s infringement of one or more
`
`claims of the ’210 patent. On information and belief, the majority of Lotame’s revenues originate
`
`from demand-side platforms paying Lotame for data usage by those platforms’ advertisers, and
`
`that service offered by Lotame directly competes with Datonics’ offering of pre-packaged and
`
`customized data segment services. Accordingly, Datonics’ offering of data segmentation is
`
`prejudiced by Defendant’s actions. For example, Defendant’s actions have interfered with and will
`
`interfere with Plaintiffs’ ability to license technology. The balance of hardships favors Datonics’
`
`ability to commercialize its own ideas and technology. The public interest in allowing Datonics to
`
`enforce its right to exclude outweighs other public interests. A permanent injunction would not
`
`result in depriving the public of the patented invention because consumer need for the patented
`
`invention can be met by at least Datonics’ product offerings as well as at least one other advertising
`
`platform who has taken a license to the ’210 Patent.
`
`COUNT III
`
`INFRINGEMENT OF U.S. PATENT NO. 10,984,445
`
`
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`8
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`30.
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`Plaintiffs reallege and incorporate by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`31.
`
`Plaintiffs own all rights, title, and interest in U.S. Patent No. 10,984,445, titled
`
`“providing collected profiles to media properties having specified interests,” issued on April 20,
`
`2021 (“the ’445 patent”). A true and correct copy of the ’445 patent is attached as Exhibit 5.
`
`32.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products and/or services (“Accused Instrumentalities”), such as, e.g., Lotame Data
`
`Exchange and Lotame Data Stream, that directly infringe, literally and/or under the doctrine of
`
`equivalents, claims of the ’445 patent.
`
`33.
`
`The infringement of the ’445 patent is also attributable to Defendant. Defendant
`
`and/or users of the Accused Instrumentalities directs and controls use of the Accused
`
`Instrumentalities to perform acts that result in infringement the ’445 patent, conditioning benefits
`
`on participation in the infringement and establishing the timing and manner of the infringement.
`
`34.
`
`Defendant also knowingly and intentionally induces infringement of claims of
`
`the ’445 patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendant has had knowledge of the ’445 patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’445 patent, Defendant continues to
`
`make, use, offer for sale, sell, and and/or import the Accused Instrumentalities, and to actively
`
`encourage and instruct customers and other companies to make, use, offer for sale, sell, and/or
`
`import the Accused Instrumentalities in ways that directly infringe the ’445 patent. Defendant does
`
`so intending that its customers and end users will commit these infringing acts.
`
`35.
`
`Defendant has also infringed, and continues to infringe, claims of the ’445 patent
`
`by offering to commercially distribute, commercially distributing, making, and/or importing the
`
`
`
`9
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`
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`Accused Instrumentalities, which are used in practicing the process, or using the systems, of the
`
`patent, and constitute a material part of the invention. Defendant has knowledge of or is willfully
`
`blind to the components in the Accused Instrumentalities being especially made or especially
`
`adapted for use in infringement of the patent, not a staple article, and not a commodity of
`
`commerce suitable for substantial noninfringing use. Accordingly, Defendant is, contributorily
`
`infringing the ’445 patent, in violation of 35 U.S.C. § 271(c).
`
`36.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims
`
`of the ’445 patent. A claim chart comparing an independent claim of the ’445 patent to
`
`representative Accused Instrumentalities is attached as Exhibit 6, which is hereby incorporated by
`
`reference in its entirety.
`
`37.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Instrumentalities, Defendant has injured Plaintiffs and is liable for infringement of
`
`the ’445 patent pursuant to 35 U.S.C. § 271.
`
`38.
`
`As a result of Defendant’s infringement of the ’445 patent, Plaintiffs are entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`39.
`
`Plaintiffs have suffered and continue to suffer irreparable harm, through its loss of
`
`market share and goodwill, for which there is no adequate remedy at law. For example, Datonics
`
`has and will continue to suffer this harm by virtue of Defendant’s infringement of one or more
`
`claims of the ’445 patent. In particular, Datonics’ pre-packaged and customized data segment
`
`services, which facilitate the delivery of advertisements to consumers wherever they go online,
`
`directly competes with Lotame’s Data Stream and Data Exchange service offerings. Additionally,
`
`
`
`10
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`Case 1:24-cv-00376-UNA Document 1 Filed 03/22/24 Page 11 of 15 PageID #: 11
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`
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`Defendant’s actions have interfered with and will interfere with Plaintiffs’ ability to license
`
`technology. The balance of hardships favors Datonics’ ability to commercialize its own ideas and
`
`technology. The public interest in allowing Datonics to enforce its right to exclude outweighs other
`
`public interests. A permanent injunction would not result in depriving the public of the patented
`
`invention because consumer need for the patented invention can be met by at least Datonics’
`
`product offerings as well as at least one other advertising platform who has taken a license to
`
`the ’445 Patent.
`
`COUNT IV
`
`INFRINGEMENT OF U.S. PATENT NO. 8,775,249
`
`40.
`
`Plaintiffs reallege and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`41.
`
`Plaintiffs own all rights, title, and interest in U.S. Patent No. 8,775,249, titled
`
`“method, computer system, and stored program for accumulating descriptive profile data along
`
`with source information for use in targeting third-party advertisements,” issued on July 8, 2014
`
`(“the ’249 patent”). A true and correct copy of the ’249 patent is attached as Exhibit 7.
`
`42.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products and/or services (“Accused Instrumentalities”), such as, e.g., Lotame’s
`
`Spherical Platform and Lightning Tag, that directly infringe, literally and/or under the doctrine of
`
`equivalents, claims of the ’249 patent.
`
`43.
`
`The infringement of the ’249 patent is also attributable to Defendant. Defendant
`
`and/or users of the Accused Instrumentalities directs and controls use of the Accused
`
`Instrumentalities to perform acts that result in infringement the ’249 patent, conditioning benefits
`
`on participation in the infringement and establishing the timing and manner of the infringement.
`
`
`
`11
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`44.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims
`
`of the ’249 patent. A claim chart comparing an independent claim of the ’249 patent to
`
`representative Accused Instrumentalities is attached as Exhibit 8, which is hereby incorporated by
`
`reference in its entirety.
`
`45.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Instrumentalities, Defendant has injured AlmondNet and is liable for infringement of
`
`the ’249 patent pursuant to 35 U.S.C. § 271.
`
`46.
`
`As a result of Defendant’s infringement of the ’249 patent, AlmondNet is entitled
`
`to monetary damages in an amount adequate to compensate for Defendant’s infringement, but in
`
`no event less than a reasonable royalty for the use made of the invention by Defendant, together
`
`with interest and costs as fixed by the Court.
`
`COUNT IV
`
`INFRINGEMENT OF U.S. PATENT NO. 8,494,904
`
`47.
`
`Plaintiffs reallege and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`48.
`
`Plaintiffs own all rights, title, and interest in U.S. Patent No. 8,494,904, titled
`
`“method and stored program for accumulating descriptive profile data along with source
`
`information for use in targeting third-party advertisements,” issued on July 23, 2013 (“the ’904
`
`patent”). A true and correct copy of the ’904 patent is attached as Exhibit 9.
`
`49.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products and/or services (“Accused Instrumentalities”), such as, e.g., Lotame’s
`
`Spherical Platform and Lightning Tag, that directly infringe, literally and/or under the doctrine of
`
`equivalents, claims of the ’904 patent.
`
`
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`12
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`50.
`
`The infringement of the ’904 patent is also attributable to Defendant. Defendant
`
`and/or users of the Accused Instrumentalities directs and controls use of the Accused
`
`Instrumentalities to perform acts that result in infringement the ’904 patent, conditioning benefits
`
`on participation in the infringement and establishing the timing and manner of the infringement.
`
`51.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims
`
`of the ’904 patent. A claim chart comparing an independent claim of the ’904 patent to
`
`representative Accused Instrumentalities is attached as Exhibit 10, which is hereby incorporated
`
`by reference in its entirety.
`
`52.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Instrumentalities, Defendant has injured AlmondNet and is liable for infringement of
`
`the ’904 patent pursuant to 35 U.S.C. § 271.
`
`53.
`
`As a result of Defendant’s infringement of the ’904 patent, AlmondNet is entitled
`
`to monetary damages in an amount adequate to compensate for Defendant’s infringement, but in
`
`no event less than a reasonable royalty for the use made of the invention by Defendant, together
`
`with interest and costs as fixed by the Court.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiffs respectfully request that this Court enter:
`
`a.
`
`b.
`
`c.
`
`A judgment in favor of Plaintiffs that Defendant has infringed, either literally and/or
`
`under the doctrine of equivalents, each of the Asserted Patents;
`
`A permanent injunction prohibiting Defendant from further acts of infringement of
`
`the ’398 patent, the ’210 patent, and the ’445 patent;
`
`A judgment and order requiring Defendant to pay Plaintiffs their damages, costs,
`
`expenses, and pre-judgment and post-judgment
`
`interest for Defendant’s
`
`
`
`13
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`
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`infringement of the Asserted Patents;
`
`d.
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`A judgment and order requiring Defendant to provide an accounting and to pay
`
`supplemental damages to Plaintiffs, including without limitation, pre-judgment and
`
`post-judgment interest;
`
`e.
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`A judgment and order finding that this is an exceptional case within the meaning
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`of 35 U.S.C. § 285 and awarding to Plaintiffs their reasonable attorneys’ fees
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`against Defendant; and
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`f.
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`Any and all other relief as the Court may deem appropriate and just under the
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`circumstances.
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`DEMAND FOR JURY TRIAL
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`Plaintiffs, under Rule 38 of the Federal Rules of Civil Procedure, request a trial by jury of
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`any issues so triable by right.
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`Respectfully submitted,
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`FARNAN LLP
`
`/s/ Michael J. Farnan
`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
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`Attorneys for Plaintiffs
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`Dated: March 22, 2024
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`Of Counsel:
`
`Reza Mirzaie
`Ben Wang
`James Milkey
`Amy Hayden
`James Tsuei
`Daniel Kolko
`Jason Wietholter
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Tel: 310-826-7474
`Fax: 310-826-6991
`rmirzaie@raklaw.com
`bwang@raklaw.com
`jmilkey@raklaw.com
`ahayden@raklaw.com
`jtsuei@raklaw.com
`
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`14
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`dkolko@raklaw.com
`jwietholter@raklaw.com
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