`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`SICIS, s.r.l.,
`
`Plaintiff,
`
` v.
`
`SHINEX MOSAICS GLOBAL, SHINEX
`MOSAICS USA, INEX INDUSTRIES,
`LTD, SACHIN PALSOKAR, and JOHN
`DOES 1-5,
`
`Defendants.
`
`Civil Action No.
`
`1:24-cv-1772-TWT
`
`MOTION TO SET ASIDE DEFAULT
`AND FOR LEAVE TO FILE ANSWER
`
`COMES NOW, SHINEX MOSAICS GLOBAL, SHINEX MOSAICS USA,
`
`INEX INDUSTRIES, LTD, and SACHIN PALSOKAR, (hereafter “Defendants”),
`
`and pursuant to Fed. R. Civ. P. 55(c), hereby files this Motion To Set Aside Default
`
`and Motion for Leave to File Defendants’ Answer in this action, on the grounds that
`
`a proper case has been made and that good cause exists to set aside the default based
`
`on the foregoing facts and circumstances. In support of the within Motion,
`
`Defendants show this court as follows:
`
`1. On April 24, 2024, Plaintiff SICIS, s.r.l., filed its Verified Complaint and
`
`request for Injunctive Relief against Defendants for alleged copyright
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`Page 1
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`
`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 2 of 25
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`infringement. [Doc. 1].
`
`2. On April 26, 2024, Plaintiff SICIS, s.r.l., filed its Motion for Temporary
`
`Restraining Order against Defendants. [Doc. 12].
`
`3. On April 29, 2024, Defendants’ counsel filed his Entry of Appearance on
`
`behalf of Defendants Shinex Mosaics Global, Shinex Mosaics USA, Inex
`
`Industries, Ltd, and Sachin Palsokar. [Doc. 13].
`
`4. On April 29, 2024, Defendants’ counsel communicated with Plaintiff’s
`
`counsel regarding the alleged infringement and Defendants’ desire to remove
`
`any allegedly infringing content from its platforms. Further, Defendants’
`
`counsel communicated Defendants’ desire to remove any infringing content
`
`from its platforms.
`
`5. On May 2, 2024, in contemplation of a prompt resolution and dismissal of the
`
`case, the Parties stipulated, agreed, and consented to entry of the Stipulated
`
`Preliminary Injunction to resolve Plaintiff’s Motion for a Temporary
`
`Restraining Order and Preliminary Injunction [Doc. 13].
`
`6. On May 2, 2024, the Court entered an order granting the Parties Consent
`
`motion for Stipulated Preliminary Injunction [Doc. 15].
`
`7. On May 8, 2024, as ordered by the Court, Defendants filed its Certificate of
`
`Page 2
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`
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`
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`
`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 3 of 25
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`Compliance with the terms of the Stipulated Preliminary Injunction. [Doc.
`
`16].
`
`8. From the time of filing of its Certificate of Compliance with the Court on May
`
`8, 2024, Defendants’ counsel and Plaintiff’s counsel have been in regular
`
`communication regarding alleged ongoing infringement by Defendants.
`
`9. Further, Defendants have been actively working to remove any infringing
`
`content from its platforms, and Plaintiff has been aware of Defendants
`
`ongoing efforts to remove any infringing content that Defendants have control
`
`over or have been made aware of by the Plaintiff.
`
`10. At no point throughout the duration of the Parties' communications and their
`
`active efforts to comply with the Stipulated Preliminary Injunction has the
`
`Plaintiff made any request for Defendants to file an Answer to Plaintiff’s
`
`Complaint.
`
`11. Default was not culpable or willful, as Defendants did not file an Answer
`
`due to the sincere belief that the Parties would promptly resolve this
`
`matter outside of the court system.
`
`12. There will be no prejudice to Plaintiff from setting aside the Default given the
`
`relatively short period of time between service of the Verified Complaint upon
`
`Defendants and the filing of Defendants’ Motion to Set Aside Default and
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`Page 3
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`
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`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 4 of 25
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`Answer.
`
`13. Plaintiff filed its Verified Complaint on April 24, 2024, and perfected service
`
`upon Defendants on April 25, 2024. Defendants’ Answer was due on May 16,
`
`2024. Plaintiff moved for entry of Default on May 22, 2024, only Seven (7) days
`
`after the deadline for Defendants’ Answer. Accordingly, Plaintiff will not be
`
`prejudiced from Defendants’ being permitted to set aside Default and file its
`
`Answer to Plaintiff’s Complaint at this time as the time elapsed since the filing
`
`of the Complaint and the service of the action has been relatively brief, thus
`
`minimizing any potential adverse effects on the Plaintiff's case. See Catalina
`
`Worldwide, LLC v. Info. and Infrastructure Techs., Inc., No. 1:22-CV-02757-
`
`JPB, 2023 WL 346656 (N.D. Ga. Jan. 19, 2023). (finding “good cause” to set
`
`aside default where Plaintiff had not been prejudiced by Defendant filing its
`
`answer 12 days after the deadline).
`
`14. Defendant has meritorious defenses to Plaintiff’s Complaint.
`
`15. Defendants’ tiles and mosaics did not infringe on the copyrights held by
`
`Plaintiff because the Defendants’ tiles and mosaics are not substantially similar
`
`to those designed by the Plaintiff. Under the Copyright Act, 17 U.S.C. §§ 101
`
`et seq, the Plaintiff must demonstrate that the Defendants copied the protected
`
`elements of a copyrighted work by showing that the works would be
`
`substantially similar to a lay observer. Architects Collective v. Pucciano &
`
`Page 4
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 5 of 25
`
`Eng., Inc., 247 F. Supp. 3d 1322 (N.D. Ga. 2017).
`
`16. The tiles and mosaics manufactured by Defendants would not be substantially
`
`similar to Plaintiff’s tiles in the eyes of a lay observer. This is because although
`
`the Defendants and Plaintiff’s tiles and mosaics use common elements, the
`
`configuration and arrangement of these elements is not substantially similar,
`
`and thus, the Defendants tiles do not infringe on the copyright held by the
`
`Plaintiffs.
`
`17. To the extent that Defendants are found to be liable for copyright infringement
`
`of the Plaintiff’s works, any and all alleged infringement on the part of
`
`Defendants was not done “willfully” as to enhance the actual damages award
`
`to the Plaintiff based upon the known facts of this case.
`
`18. Defendants’ tiles and mosaics do not violate the Georgia Uniform Deceptive
`
`Trade Practices Act because they sold their own tiles fabricated by them and
`
`did not pass off their tiles or mosaics as those fabricated by Plaintiff, as required
`
`under O.C.G.A. § 10–1–370(a)(1).
`
`19. Defendants did not cause a likelihood of confusion or misunderstanding
`
`concerning the source, sponsorship, approval or certification of their tiles and
`
`mosaics, as required under O.C.G.A. § 10–1–370(a)(2), because they never
`
`actively or passively held out their products as being sourced from, sponsored
`
`by, approved by, or certified by Plaintiff.
`
`Page 5
`
`
`
`
`
`
`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 6 of 25
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`20. Defendants did not cause a likelihood of confusion or of misunderstanding as
`
`to affiliation, connection, or association with certification of another, as under
`
`O.C.G.A. § 10–1–370(a)(3), because they never actively or passively held
`
`themselves out as being affiliated, connected, or associated with Plaintiff.
`
`21. Defendants also did not engage in other conduct which would create a
`
`likelihood of confusion or misunderstanding regarding the nature of their
`
`product with Plaintiff’s products, as required under O.C.G.A. § 10–1–
`
`370(a)(4). Consequently, Plaintiff is not entitled to an injunction on this issue.
`
`22. Plaintiff is also not entitled to attorney’s fees on this issue because Defendants
`
`did not willfully or intentionally engage in any trade practices, they knew to be
`
`deceptive, as required under O.C.G.A. § 10–1–373(b)(2).
`
`23. Defendants have not been unjustly enriched under Georgia common law
`
`because they have not used and sold the designs created by Plaintiff. As a result,
`
`they have not obtained any benefit from Plaintiff’s design and have not been
`
`unjustly enriched.
`
`24. Plaintiff is not entitled to attorney’s fees from Defendants in this matter because
`
`Defendants have not acted in bad faith, been stubbornly litigious, or caused
`
`Plaintiff unnecessary trouble or expense.
`
`25. Defendants announce its readiness to proceed instanter as shown by the
`
`Answer, attached hereto as Exhibit “A,” and moves this Court for Leave to
`
`Page 6
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`
`
`
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 7 of 25
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`file Defendants’ Answer as part of the relief requested herein.
`
`WHEREFORE, Defendants respectfully prays that its Motion To Set Aside
`
`Default be granted and that the Answer, attached hereto as Exhibit “A”, be accepted
`
`for filing as part of the relief requested herein.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`(Signature on Following Page)
`
`Page 7
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`
`
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`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 8 of 25
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`Respectfully submitted this 23rd day of May 2024.
`
`KPPB LAW
`
`
`
`
`/s/ Roy Banerjee
`Roy A. Banerjee, Esq.
`Georgia Bar No. 035917
`
`Kumar, Prabhu, Patel & Banerjee, LLC
`One Lakeside Commons, Suite 800
`990 Hammond Drive
`Atlanta, Georgia 30328
`Phone: (678) 443-2220
`Fax: (678) 443-2230
`rbanerjee@kppblaw.com
`
`Counsel for Defendants Shinex Mosaics
`Global, Shinex Mosaics USA, Inex
`Industries, Ltd, and Sachin Palsokar
`
`
`LR 7.1(D) CERTIFICATE
`
`This is to certify that the within and foregoing has been prepared with one of
`
`the fonts and point selections approved by the Court in LR 5.1(C): Times New
`
`Roman, 14 point.
`
`
`
`KPPB LAW
`
`
`
`
`/s/ Roy Banerjee
`Roy A. Banerjee, Esq.
`Georgia Bar No. 035917
`rbanerjee@kppblaw.com
`
`Counsel for Defendants Shinex
`Mosaics Global, Shinex Mosaics
`USA, Inex Industries, Ltd, and Sachin
`Palsokar
`
`Page 8
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 9 of 25
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`
`
`
`
`SICIS, s.r.l.,
`
`Plaintiff,
`
`
` v.
`
`
`SHINEX MOSAICS GLOBAL, SHINEX
`MOSAICS USA, INEX INDUSTRIES,
`LTD, SACHIN PALSOKAR, and JOHN
`DOES 1-5,
`
`Defendants.
`
`Civil Action No.
`
`1:24-cv-1772-TWT
`
`
`
`
`
`Certificate of Service
`
`I hereby certify that on May 23, 2024, a true and correct copy of the foregoing
`
`was served electronically with the Clerk of the court by using the CM/ECF system,
`
`which will send a notice of electronic filing to all counsel of record.
`
`
`
`
`
`
`
`
`
`KPPB LAW
`
`
`
`
`/s/ Roy Banerjee
`Roy A. Banerjee, Esq.
`Georgia Bar No. 035917
`rbanerjee@kppblaw.com
`
`Counsel for Defendants Shinex
`Mosaics Global, Shinex Mosaics
`USA, Inex Industries, Ltd, and Sachin
`Palsokar
`
`Page 9
`
`
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 10 of 25
`
`EXHIBIT A
`
`
`
`
`
`
`
`
`
`Page 10
`
`
`
`
`
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 11 of 25
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`
`
`
`
`Civil Action No.
`
`1:24-cv-1772-TWT
`
`SICIS, s.r.l.,
`
`Plaintiff,
`
`
` v.
`
`
`SHINEX MOSAICS GLOBAL, SHINEX
`MOSAICS USA, INEX INDUSTRIES,
`LTD, SACHIN PALSOKAR, and JOHN
`DOES 1-5,
`
`Defendants.
`
`
`ANSWER AND DEFENSES
`
`
`
`COMES NOW, DEFENDANTS SHINEX MOSAICS GLOBAL, SHINEX
`
`MOSAICS USA, INEX INDUSTRIES LTD., and SACHIN PALSOKAR, and for
`
`their answer show the court as follows:
`
`FIRST DEFENSE
`
`Defendants’ tiles and mosaics did not infringe on the copyrights held by
`
`Plaintiff because the Defendants’ tiles and mosaics are not substantially similar to
`
`those designed by the Plaintiff. Under the Copyright Act, 17 U.S.C. §§ 101 et seq,
`
`the Plaintiff must demonstrate that the Defendants copied the protected elements of
`
`
`
`Page 1
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 12 of 25
`
`a copyrighted work by showing that the works would be substantially similar to a
`
`lay observer. Architects Collective v. Pucciano & Eng., Inc., 247 F. Supp. 3d 1322
`
`(N.D. Ga. 2017). The tiles and mosaics manufactured by Defendants would not be
`
`substantially similar to Plaintiff’s tiles in the eyes of a lay observer. This is because
`
`although the Defendants and Plaintiff’s tiles and mosaics use common elements, the
`
`configuration and arrangement of these elements is not substantially similar, and
`
`thus, the Defendants tiles do not infringe on the copyright held by the Plaintiffs.
`
`SECOND DEFENSE
`
`Defendants’ tiles and mosaics do not violate the Georgia Uniform Deceptive
`
`Trade Practices Act because they sold their own tiles fabricated by them and did not
`
`pass off their tiles or mosaics as those fabricated by Plaintiff, as required under
`
`O.C.G.A. § 10–1–370(a)(1). Defendants did not cause a likelihood of confusion or
`
`misunderstanding concerning the source, sponsorship, approval or certification of
`
`their tiles and mosaics, as required under O.C.G.A. § 10–1–370(a)(2), because they
`
`never actively or passively held out their products as being sourced from, sponsored
`
`by, approved by, or certified by Plaintiff. Defendants did not cause a likelihood of
`
`confusion or of misunderstanding as to affiliation, connection, or association with
`
`certification of another, as under O.C.G.A. § 10–1–370(a)(3), because they never
`
`actively or passively held themselves out as being affiliated, connected, or associated
`
`with Plaintiff. Defendants also did not engage in other conduct which would create
`Page 2
`
`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 13 of 25
`
`a likelihood of confusion or misunderstanding regarding the nature of their product
`
`with Plaintiff’s products, as required under O.C.G.A. § 10–1–370(a)(4).
`
`Consequently, Plaintiff is not entitled to an injunction on this issue. Plaintiff is also
`
`not entitled to attorney’s fees on this issue because Defendants did not willfully or
`
`intentionally engage in any trade practices, they knew to be deceptive, as required
`
`under O.C.G.A. § 10–1–373(b)(2).
`
`THIRD DEFENSE
`
`Defendants have not been unjustly enriched under Georgia common law
`
`because they have not used and sold the designs created by Plaintiff. As a result,
`
`they have not obtained any benefit from Plaintiff’s design and have not been unjustly
`
`enriched.
`
`FOURTH DEFENSE
`
`Plaintiff is not entitled to attorney’s fees from Defendants in this matter
`
`because Defendants have not acted in bad faith, been stubbornly litigious, or caused
`
`Plaintiff unnecessary trouble or expense. In fact, Defendants’ counsel proactively
`
`reached out to Plaintiff’s counsel on multiple occasions to negotiate a settlement
`
`related to this issue or to otherwise solve this issue outside the justice system. As a
`
`result, Plaintiff is not entitled to, and should not be awarded, attorney’s fees in this
`
`matter.
`
`
`
`Page 3
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 14 of 25
`
`FIFTH DEFENSE
`
`To the extent that Defendants are found to be liable for copyright infringement
`
`of the Plaintiff’s works, any and all alleged infringement on the part of Defendants
`
`was not done “willfully” as to enhance the actual damages award to the Plaintiff
`
`based upon the known facts of this case.
`
`NATURE OF THE ACTION, PARTIES, JURISDICTION AND VENUE
`
`1.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`2.
`
`Defendants admit that two companies in this case are Indian but deny the
`
`remaining allegations in this paragraph.
`
`Denied.
`
`3.
`
`4.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`Admit.
`
`
`
`5.
`
`Page 4
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 15 of 25
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`Denied.
`
`Admit.
`
`Admit.
`
`Denied.
`
`Denied.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`Defendants admit that the Plaintiffs have alleged claims for violation of the
`
`Copyright Act which arise under federal law but deny the remaining allegations
`
`contained in this paragraph.
`
`
`
`
`
`12.
`
`Page 5
`
`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 16 of 25
`
`Defendants admit that they conduct some business in Georgia but deny the
`
`remaining allegations contained in this paragraph.
`
`13.
`
`Denied.
`
`
`
`Page 6
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 17 of 25
`
`FACTUAL BACKGROUND
`
`A.
`
`Plaintiff SICIS and its copyrighted mosaic designs
`
`14.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`15.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`16.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`17.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`18.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`19.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`20.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`
`
`Page 7
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 18 of 25
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`
`
`B. The Shinex Defendants and their wrongful copying
`
`21.
`
`Defendants admit that Shinex Global and Inex are based out of Nagpur,
`
`India, and that they manufacture tiles and glass mosaics. Defendants deny the
`
`remaining allegations in this paragraph.
`
`Admit.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`
`
`22.
`
`23.
`
`24.
`
`25.
`
`26.
`
`27.
`
`Page 8
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 19 of 25
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`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`28.
`
`29.
`
`30.
`
`31.
`
`32.
`
`Defendants admit that Plaintiff’s counsel sent a letter to Defendants
`
`notifying them of the alleged infringement, but deny the remaining allegations
`
`contained in this paragraph.
`
`33.
`
`Defendants admit that some portions of their websites are down, but deny
`
`the remaining allegations contained in this paragraph.
`
`
`
`
`
`Page 9
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`
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 20 of 25
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`COUNT 1: COPYRIGHT INFRINGEMENT
`
`Denied.
`
`34.
`
`35.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`36.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`
`
`37.
`
`38.
`
`39.
`
`40.
`
`
`
`Page 10
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 21 of 25
`
`41.
`
`42.
`
`Denied.
`
`Denied.
`
`COUNT II: VIOLATION OF GEORGIA UNIFORM DECEPTIVE TRADE
`PRACTICES ACT (O.C.G.A. § 10–1–370)
`43.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`
`
`44.
`
`45.
`
`46.
`
`47.
`
`48.
`
`Page 11
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 22 of 25
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`Denied.
`
`Denied.
`
`Denied.
`
`49.
`
`50.
`
`COUNT III: UNJUST ENRICHMENT UNDER GEORGIA COMMON LAW
`
`Denied.
`
`Denied.
`
`51.
`
`52.
`
`53.
`
`Defendants are without knowledge sufficient to admit or deny this allegation.
`
`Denied.
`
`54.
`
`55.
`
`Defendants admit they have provided no benefit to SICIS but deny that they were
`
`
`
`Page 12
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`
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`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 23 of 25
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`under any obligation to do so.
`
`56.
`
`57.
`
`COUNT IV: ATTORNEY FEES UNDER O.C.G.A. § 13–6–11
`
`58.
`
`59.
`
`60.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`PRAYER FOR RELIEF
`
`All Paragraphs not otherwise admitted by Defendant are hereby denied by
`
`Defendant.
`
`
`
`Page 13
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 24 of 25
`
`WHEREFORE, Defendant prays as follows:
`
`a) That each of Plaintiff’s counts against Defendants be dismissed with
`
`prejudice;
`
`b) That judgment be entered in favor of Defendants and against Plaintiff
`
`on each of Plaintiff’s counts against Defendants;
`
`c) That all costs of this action be taxed against Plaintiff;
`
`d) That all attorneys’ fees incurred by Defendants in defending against
`
`this action be taxed against Plaintiff; and
`
`That this Court award such other relief as this Court deems just and proper.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`(Signature on Following Page)
`
`Page 14
`
`
`
`Case 1:24-cv-01772-TWT Document 18 Filed 05/23/24 Page 25 of 25
`
`Respectfully submitted this 23rd day of May 2024.
`
`KPPB LAW
`
`
`
`
`/s/ Roy Banerjee
`Roy A. Banerjee, Esq.
`Georgia Bar No. 035917
`
`Kumar, Prabhu, Patel & Banerjee, LLC
`One Lakeside Commons, Suite 800
`990 Hammond Drive
`Atlanta, Georgia 30328
`Phone: (678) 443-2220
`Fax: (678) 443-2230
`rbanerjee@kppblaw.com
`
`Counsel for Defendants Shinex Mosaics
`Global, Shinex Mosaics USA, Inex
`Industries, Ltd, and Sachin Palsokar
`
`LR 7.1(D) CERTIFICATE
`
`This is to certify that the within and foregoing has been prepared with one of
`
`
`
`
`
`
`
`
`the fonts and point selections approved by the Court in LR 5.1(C): Times New
`
`Roman, 14 point.
`
`
`
`
`
`
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`KPPB LAW
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`/s/ Roy Banerjee
`Roy A. Banerjee, Esq.
`Georgia Bar No. 035917
`rbanerjee@kppblaw.com
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`Counsel for Defendants Shinex Mosaics
`Global, Shinex Mosaics USA, Inex
`Industries, Ltd, and Sachin Palsokar
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`Page 15
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