throbber
Case 2:22-md-03034-TGB ECF No. 209, PageID.11826 Filed 12/29/23 Page 1 of 18
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`JURY TRIAL DEMANDED
`
`
`PLAINTIFF NEO WIRELESS, LLC’S MOTION TO STRIKE
`DEFENDANTS’ UNTIMELY PRIOR ART ELECTIONS
`
`Plaintiff Neo Wireless, LLC (“Plaintiff” or “Neo”) respectfully requests this
`
`
`
`Court to strike Defendants’ recently disclosed invalidity theories based on the
`
`“Project Angel” reference, including striking the Project Angel reference from
`
`Defendants’ final prior art elections and precluding Defendants from future
`
`reliance on the belatedly disclosed invalidity theories based on Project Angel. The
`
`complete bases for Plaintiff’s motion are set forth in the accompanying brief in
`
`support of this Motion to Strike.
`
`
`
`Counsel for Neo conferred with counsel for Ford (on behalf of Defendants)
`
`by telephone on December 28, 2023. Counsel explained the basis for this motion
`
`but was unable to obtain concurrence on the relief sought.
`
`A proposed order is being submitted herewith via email.
`
`
`
`
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11827 Filed 12/29/23 Page 2 of 18
`
`DATED: December 29, 2023
`
`Respectfully submitted,
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`Jaye Quadrozzi (P71646)
`Email: quadrozzi@youngpc.com
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, Michigan 48334
`Telephone: (248) 353-8620
`
`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on December 29, 2023, the foregoing document
`
`was filed electronically with the Clerk of Court using the CM/ECF system, which
`
`will send notification of such filing to all attorneys of record.
`
`
`
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`
`
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11828 Filed 12/29/23 Page 3 of 18
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`JURY TRIAL DEMANDED
`
`
`
`
`
`PLAINTIFF NEO WIRELESS, LLC’S BRIEF IN SUPPORT OF MOTION
`TO STRIKE DEFENDANTS’ UNTIMELY PRIOR ART ELECTIONS
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11829 Filed 12/29/23 Page 4 of 18
`
`TABLE OF CONTENTS
`
`
`
`INTRODUCTION ............................................................................................ 1
`I.
`II. BACKGROUND .............................................................................................. 2
`III. ARGUMENT .................................................................................................... 6
`IV. CONCLUSION ...............................................................................................10
`
`
`
`
`
`
`
`
`i
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11830 Filed 12/29/23 Page 5 of 18
`
`TABLE OF AUTHORITIES
`
`
`Cases
`
`ChemFree Corp. v. J. Walter, Inc.
` 250 F.R.D. 570 (N.D. Ga. 2007) .........................................................................8, 9
`
`Kimberly-Clark Worldwide, Inc. v. First Quality Baby Prods., LLC
` No. 09-C-0916, 2011 WL 13077073 (E.D. Wis. Aug. 26, 2011) ........................... 7
`
`O2 Micro Intern. Ltd. v. Monolithic Power Systems, Inc.
` 467 F.3d 1355 (Fed. Cir. 2006) .............................................................................10
`
`Webasto Thermo & Comfort N. Am., Inc. v. BesTop, Inc.
` No. 16-cv-13456, 2019 WL 2171262 (E.D. Mich. May 20, 2019) ..................7, 10
`
`
`
`
`
`
`
`ii
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11831 Filed 12/29/23 Page 6 of 18
`
`1.
`
`STATEMENTS OF ISSUES PRESENTED
`
`Should Defendants, having demanded that the Parties narrow claims and prior
`art on a fixed schedule (over Neo’s objection), be allowed to add new prior
`art references to their prior art elections with a month of discovery remaining,
`when they were meant to narrow the scope of prior art, and have shown no
`good cause to do otherwise?
`Answer: No.
`
`
`
`
`
`
`iii
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11832 Filed 12/29/23 Page 7 of 18
`
`MOST APPROPRIATE AND CONTROLLING AUTHORITIES
`
`Webasto Thermo & Comfort N. Am., Inc. v. BesTop, Inc., No. 16-cv-13456, 2019
`WL 2171262, at *3 (E.D. Mich. May 20, 2019)
`
`
`
`
`iv
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11833 Filed 12/29/23 Page 8 of 18
`
`I.
`
`INTRODUCTION
`Pursuant to the Court’s Order on Further Prior Art and Claim Narrowing,
`
`Defendants, having already elected 48 prior art references back in December 2022,
`
`were supposed to reduce those 48 prior art references to no more than 16 (4 per
`
`patent) by December 18, 2023.1 See Dkt. 102 at 4. But rather than choose from
`
`among the 48 prior art references they had previously elected, Defendants’ final
`
`elections included new references that had not been previously elected, and for
`
`which Defendants had not even produced invalidity contentions in the case.
`
`Defendants’ invalidity contentions were due on November 16, 2022—over a year
`
`prior to this final election of prior art. Defendants later provided invalidity
`
`contentions and claim charts for these new references, for the very first time, on
`
`December 20, 2023. Defendants at no point explained (1) why they could not have
`
`located this prior art and developed these contentions when they were due over a
`
`year ago; (2) why they failed to diligently pursue these new prior art references in
`
`the 13 months since (and seasonably amend their contentions per the Court’s
`
`rules); or (3) why they have good cause to elect these brand new references in
`
`contravention of the Court’s narrowing order.
`
`With one month of fact discovery remaining (and only two weeks until the
`
`
`1 At Defendants’ request, and to avoid a dispute, Neo agreed to allow Defendants
`to elect 18, rather than 16, per the stipulation submitted on December 15, 2023.
`1
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11834 Filed 12/29/23 Page 9 of 18
`
`Parties are scheduled to exchange responsive non-burden contentions), it is too late
`
`for Defendants to introduce brand new prior art over a year and a half into this
`
`case, particularly when they could and should have diligently pursued it months
`
`earlier. Requiring Neo to evaluate brand new art and pursue potential third-party
`
`discovery in the midst of the frenetic final days of fact discovery would severely
`
`prejudice Neo’s ability to defend against these new invalidity attacks. Neo
`
`therefore requests that the Court strike the “Project Angel” reference from
`
`Defendants’ final prior art elections and invalidity contentions. 2
`
`II. BACKGROUND
`The Court’s Order on Further Prior Art and Claim Narrowing (Dkt. 102) was
`
`ordered in response to Defendants’ motion (Dkt. 96) demanding—over Neo’s
`
`objection—that Neo narrow its claims as soon as possible. The Court ultimately
`
`agreed to impose claim narrowing, but made this narrowing reciprocal, requiring
`
`Defendants to narrow their prior art references as well. Dkt. 102 at 3.
`
`In demanding this scheduled narrowing, Defendants argued that, absent a
`
`requirement that Neo make a definite claim election at the outset of the case, Neo
`
`
`2 Defendants’ new references also include U.S. Patent No. 5,521,937 (“Kondo”).
`However, unlike with Project Angel, Defendants at least represent that their new
`election of Kondo is based on the Court’s November claim construction order. This
`basis is suspect, given that the relevant claim construction (relating to “direct
`sequence spread spectrum signals”)
`tracked Defendants’ own proposals.
`Nevertheless, in an effort to reduce disputes, this Motion does not seek to strike
`Defendants’ otherwise untimely election of Kondo.
`2
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11835 Filed 12/29/23 Page 10 of 18
`
`would wait for the Court’s claim construction order, and then pivot to entirely new
`
`claims to replace the originally asserted ones, requiring additional discovery and
`
`new claim construction proceedings. Dkt. 96 at 8. While Neo never had any
`
`intention of engaging in this tactic, this is exactly what Defendants have now done.
`
`They have waited for Neo to narrow its infringement case, for claim construction
`
`proceedings to conclude, for fact discovery to reach its end, and for their myriad of
`
`Patent Office actions to play out, only to now pivot to brand new prior art
`
`references in view of all of that information.
`
` In their Motion for aggressive narrowing, Defendants also downplayed the
`
`prejudice to Neo specifically because “Neo will already have received Defendants’
`
`invalidity contentions” and “Neo will have a full opportunity to evaluate the scope
`
`and strength of its triable case prior to engaging in the claim construction process.”
`
`Dkt. 96 at 13–14. Yet, as explained further below, those initial invalidity
`
`contentions did not contain charted theories based on the newly elected Project
`
`Angel reference. Allowing Defendants’ new theories would cause exactly the
`
`prejudice Defendants assured the Court would not befall Neo.
`
`While “Project Angel”—a wireless system/product allegedly operated by
`
`AT&T in the late 90s—was identified in Defendants’ initial invalidity contentions
`
`in November 2022, as one among hundreds in an indiscriminate laundry list of
`
`prior art, see Ex. A, it was not among the 63 claim charts provided by Defendants,
`
`
`
`3
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11836 Filed 12/29/23 Page 11 of 18
`
`wherein they set forth their actual invalidity contentions as required by the Court’s
`
`Discovery Order.3 Defendants will contend that they needed third-party discovery
`
`to be able to evaluate and chart this reference, but that excuse ignores the case
`
`schedule. Fact discovery opened on August 10, 2022. Defendants had over three
`
`months to conduct the necessary third-party discovery to complete their invalidity
`
`contentions by the November 16, 2022 deadline. Yet Defendants did not even
`
`serve a subpoena on AT&T in those three months.
`
`Accordingly, when Defendants narrowed their prior art to 48 references on
`
`December 16, 2022, see Ex. B, Defendants still did not provide a claim chart for
`
`Project Angel and did not elect it as one of their 48 references. Notably, at this
`
`same time, Defendants did concoct lengthy (and meritless) defenses of unclean
`
`hands and inequitable conduct premised on certain of the inventors of the patents-
`
`in-suit having worked on Project Angel years before they invented the patents-in-
`
`suit. See, e.g., Dkt. 104 (Tesla’s Am. Answer) at 32–46. Yet even while baselessly
`
`accusing these inventors of fraud, Defendants still had not bothered to serve a
`
`subpoena or develop any actual discovery supporting a connection between Project
`
`Angel and the patents in suit.4
`
`
`3 Dkt. 84 ¶ IV.E.d. (requiring “a chart identifying where specifically in each alleged
`item of prior art each limitation of each asserted claim is found . . . ”)
`4 While not the subject of this motion, it is worth noting that these defenses are very
`troubling. They contain charged accusations that the inventors essentially stole their
`inventions from their former employers, simply because they (like all engineers)
`4
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11837 Filed 12/29/23 Page 12 of 18
`
`More months went by, and Neo observed that, while Defendants had
`
`“reserved the right” to supplement their invalidity contentions or add additional
`
`prior art references to their claim elections, they still had not made any efforts
`
`toward pursuing any additional references through discovery. So, to make clear its
`
`position, Neo wrote Defendants on March 1st explaining that they had waived,
`
`through their utter lack of diligence, any ability to belatedly add new references.
`
`Ex. C at 3–4. Only then, a week after Neo’s letter and seven months into fact
`
`discovery, did Defendants first serve a subpoena relating to Project Angel. See Ex.
`
`D. Neo immediately objected, informing Defendants that it was too late to
`
`belatedly add new prior art references after months of failing to conduct timely
`
`discovery to seasonably amend their contentions. Ex. E.
`
`But Defendants’ delay did not end there. Over the course of the next several
`
`months, beginning in May, AT&T produced documents pursuant to Defendants’
`
`subpoena. The last such production occurred on September 13, 2023. Yet despite
`
`all of Neo’s prior warnings regarding Defendants’ delay, Defendants still failed to
`
`
`worked in the same technical field earlier in their career, and without even alleging
`that any material component of the inventions was found in the earlier system. The
`newly served contentions (which are largely conclusory and vague) do not change
`that, which likely explains their last-minute inclusion. Project Angel has almost no
`value for invalidity (being trivial and, at best, cumulative of other art). But
`Defendants may hope that, by providing even the most tenuous claim mapping at the
`last minute, they can at least avoid a clear summary judgment against their salacious
`fraud-based unenforceability theories.
`
`
`
`5
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11838 Filed 12/29/23 Page 13 of 18
`
`supplement their contentions, identify Project Angel as elected prior art, or provide
`
`any notice to Neo that Project Angel actually discloses or embodies any of the
`
`claim elements of the asserted patents. Neo assumed that Defendants had
`
`abandoned any (already waived) plans to assert Project Angel as prior art. Only
`
`another three months later, at the absolute last minute, did Defendants for the very
`
`first time elect Project Angel and chart it against the asserted claims the third-party
`
`discovery they had sluggishly obtained. See Ex. F. And those December 20, 2023
`
`charts rely (for the technical mapping of Project Angel to the asserted claims)
`
`heavily on documents obtained from AT&T in May—seven months before
`
`Defendants served the updated contentions.
`
`III. ARGUMENT
`The parties’ Joint Scheduling Order, consistent with this Court’s default
`
`rules, requires that
`
`[e]ach party shall seasonably amend any . . . invalidity contention . . .
`upon learning that the contention is incomplete or incorrect. The
`parties should conduct timely discovery so that these contentions can
`be updated as soon as possible. Any amendment to a party’s . . .
`invalidity contentions must be timely made but in no event later than
`one month after the Court’s claim construction ruling.
`
`Dkt. 84 ¶ F (emphases added). In other words, while December 20, 2023 (one
`
`month after the Court’s Markman order) was an absolute deadline, it did not
`
`absolve Defendants from seeking timely discovery and seasonably amending
`
`contentions in the many months beforehand.
`
`
`
`6
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11839 Filed 12/29/23 Page 14 of 18
`
`“Regardless of the rule invoked, the heart of the inquiry is whether a party
`
`should be barred from relying on certain theories first proffered late in the
`
`litigation, of which the opposing party has not fairly been apprised. The analysis
`
`invariably has both a good cause/diligence and a prejudice component.” Webasto
`
`Thermo & Comfort N. Am., Inc. v. BesTop, Inc., No. 16-cv-13456, 2019 WL
`
`2171262, at *3 (E.D. Mich. May 20, 2019). This good cause/diligence requirement
`
`applies to both “timely discovery” and “seasonable amendment.” See, e.g.,
`
`Kimberly-Clark Worldwide, Inc. v. First Quality Baby Prods., LLC, No. 09-C-
`
`0916, 2011 WL 13077073, at *1 (E.D. Wis. Aug. 26, 2011) (“Accused infringers
`
`must be ‘diligent’ in at least two respects with regard to their invalidity
`
`contentions: (1) in inquiring into potential invalidity evidence upon which to base
`
`their contentions, and (2) in amending their invalidity contentions to inform the
`
`patentee.”).5 Defendants have failed both prongs of this test with respect to the
`
`Project Angel reference.
`
`Defendants’ efforts to conduct third-party discovery on Project Angel have
`
`been anything but timely and diligent. This is not a case where Defendants blindly
`
`sought wide-ranging discovery on a host of potential prior art, and only happened
`
`
`5 See Webasto, 2019 WL 2171262, at *4 (“In the absence of local patent rules, as is
`the case in this District, the Court may look to case law in other districts that have
`adopted such rules that contain language similar to that adopted by the parties and
`the Court to govern the litigation[.]”)
`
`
`
`7
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11840 Filed 12/29/23 Page 15 of 18
`
`upon the Project Angel reference towards the end of discovery in an unanticipated
`
`way. On the contrary, Defendants knew about it from the outset of the case, made
`
`it a focal point of several charged unenforceability theories, but simply opted not to
`
`diligently seek any discovery to prove that it anticipated any of the asserted claim
`
`elements. They did not even begin “inquiring into potential invalidity evidence
`
`upon which to base their contentions” until seven months into fact discovery, and
`
`four months after their initial invalidity contentions were due. This alone justifies
`
`striking this belatedly investigated reference.
`
`Defendants continued their dilatory behavior once they finally decided to
`
`seek third-party discovery from AT&T (only after Neo’s letter prompted them to
`
`do so). Despite receiving the bulk of the technical discovery needed to set forth
`
`their theories in May, they waited seven months to provide any contentions based
`
`on that information, a length of time that is indisputably not seasonable. In
`
`ChemFree Corp. v. J. Walter, Inc., the court cited as an example of diligent
`
`amendment a case in which the defendant amended its contentions “four days after
`
`discovery of the additional information.” 250 F.R.D. 570, 573 (N.D. Ga. 2007)
`
`(emphasis in original). The court contrasted that with the case at hand, in which
`
`“Defendants waited at least six months from discovering the evidence before
`
`amending their invalidity contentions.” Id. (emphasis in original). The court struck
`
`the untimely contentions, and this Court should do the same here.
`
`
`
`8
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11841 Filed 12/29/23 Page 16 of 18
`
`Defendants will contend that, because they at least identified Project Angel
`
`by name in their November 2022 contentions, and provided claim charts by the
`
`December 2023 deadline, Neo has not been prejudiced. But in the words of the
`
`ChemFree court:
`
`Defendants overlook an important aspect of infringement and invalidity
`contentions. . . . [I]invalidity contentions serve a function far more
`important than the mere identity and disclosure of potentially relevant
`evidence: they explain exactly how the opposing party will use that
`evidence to invalidate the patents.
`
` .
`
` . . The [Local] Rules were adopted in order to ‘facilitate the speedy,
`fair and efficient resolution of patent disputes.’ N.D. Ga. Patent L.R.
`1.2(a). This purpose is undermined when parties are permitted to make
`initial ‘place holder’ disclosures regarding infringement or invalidity,
`then makes substantial changes or additions to those contentions
`immediately prior to or after the close of fact discovery.
`
`ChemFree, 250 F.R.D. at 573 (emphasis in original). Indeed, the fact that
`
`Defendants have known of this reference for so long, but simply chose not to
`
`pursue it, is all the more reason to find a lack of diligence and strike it.
`
`This is compounded by the fact that Defendants did not even include the
`
`reference among their forty-eight December 2022 prior art elections (required
`
`pursuant to their own motion). It would defy reason to suggest that Neo had
`
`sufficient notice of Defendants’ contentions by these early disclosures when
`
`Defendants themselves were not even sufficiently on notice of Project Angel’s
`
`relevance to include it as one of their forty-eight elected references.
`
`Nor does the fact that Defendants served contentions by the December 20,
`9
`
`
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11842 Filed 12/29/23 Page 17 of 18
`
`2023 post-claim construction deadline save them. That deadline is intended to
`
`allow last-minute changes to contentions prompted by the Court’s claim
`
`construction. But Defendants can make no case that their belated Project Angel
`
`contentions have anything to do with any claim construction ruling. Courts in this
`
`district have demanded, consistent with the words of the Scheduling Order in this
`
`case, that parties must have good cause to make any post-claim construction
`
`amendment that is not expressly mandated by the Court’s claim construction itself.
`
`See Webasto, 2019 WL 2171262, at *5 (“Apart from amendments designed to take
`
`account of the district court’s claim construction, amendments are permitted only
`
`for ‘good cause’ even though the period allowed for discovery typically will not
`
`have expired.” (quoting O2 Micro Intern. Ltd. v. Monolithic Power Systems, Inc.,
`
`467 F.3d 1355, 1360 (Fed. Cir. 2006)). Defendants have no good cause for their
`
`dilatory discovery or their seven-month-late amendment.
`
`IV. CONCLUSION
`For the foregoing reasons, Neo requests the Court strike Defendants’ belated
`
`invalidity contentions for the Project Angel reference, strike Project Angel from
`
`Defendants’ final prior art elections, and prohibit Defendants from relying on these
`
`belated contentions in their case.
`
`
`
`10
`
`

`

`Case 2:22-md-03034-TGB ECF No. 209, PageID.11843 Filed 12/29/23 Page 18 of 18
`
`DATED: December 29, 2023
`
`Respectfully submitted,
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`Jaye Quadrozzi (P71646)
`Email: quadrozzi@youngpc.com
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, Michigan 48334
`Telephone: (248) 353-8620
`
`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on December 29, 2023, the foregoing
`
`document was filed electronically with the Clerk of Court using the CM/ECF
`
`system, which will send notification of such filing to all attorneys of record.
`
`
`
`
`
`/s/ Christopher S. Stewart
`Christopher S. Stewart
`
`
`
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket