throbber
Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 1 of 12
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`CROSSROADS SYSTEMS, INC.,
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`Plaintiff,
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`v.
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`NETAPP, INC.,
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`
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`Defendant.
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`CIVIL ACTION NO. 1:14-cv-00149
`
`JURY DEMANDED
`
`
`
`
` §
` §
` §
` §
` §
` §
` §
` §
` §
`
`PLAINTIFF CROSSROADS SYSTEMS, INC.’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`THE PARTIES
`
`1.
`
`Pursuant to Federal Rule of Civil Procedure 15(a)(1)(B), Plaintiff Crossroads
`
`Systems, Inc. (“Crossroads”) hereby submits its First Amended Complaint for Patent
`
`Infringement as a matter of course within 21 days after service of NetApp, Inc.’s Answer and
`
`Affirmative Defenses (Dkt. No. 21).
`
`2.
`
`Crossroads is a corporation incorporated under the laws of the State of Delaware
`
`and has its principal place of business at 11000 North MoPac Expressway, Austin, Texas 78759.
`
`3.
`
`Upon information and belief, Defendant NetApp, Inc. (“Defendant” or “NetApp”)
`
`is a California corporation with a principal place of business of 495 East Java Drive, Sunnyvale,
`
`California 94089.
`
`JURISDICTION AND VENUE
`
`3.
`
`This action arises under the laws of the United States, more specifically under 35
`
`U.S.C. § 100, et seq. Subject matter jurisdiction is proper in this Court pursuant to 28 U.S.C. §§
`
`1331 and 1338.
`
`1
`
`Oracle Ex. 1036, pg. 1
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 2 of 12
`
`4.
`
`Personal jurisdiction and venue are proper in this district under 28 U.S.C. §§ 1391
`
`and 1400(b). Upon information and belief, Defendant NetApp has established minimum
`
`contacts with this forum such that the exercise of jurisdiction over Defendant would not offend
`
`traditional notions of fair play and substantial justice.
`
`5.
`
`This Court has personal jurisdiction over NetApp. Upon information and belief,
`
`NetApp regularly conducts business in the State of Texas and in this judicial district and is
`
`subject to the jurisdiction of this Court. Upon information and belief, NetApp has been doing
`
`business in Texas and this judicial district by distributing, marketing, selling and/or offering for
`
`sale its products, including, but not limited to, products that practice the subject matter claimed
`
`in United States Patent Nos. 6,425,035 (“the ’035 Patent”), 7,934,041 (“the ’041 Patent”),
`
`7,051,147 (“the ’147 Patent”), and 7,987,311 (“the ’311 Patent) (collectively “the Patents-In-
`
`Suit”), and/or regularly doing or soliciting business and/or engaging in other persistent courses of
`
`conduct in and/or directed to Texas and this judicial district.
`
`COUNT 1: INFRINGEMENT OF U.S. PATENT NO. 6,425,035
`
`6.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`7.
`
`On July 23, 2002, the ’035 Patent was duly and legally issued. A true and correct
`
`copy of the ’035 Patent is attached hereto as Exhibit A. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’035 Patent. The ’035 Patent is entitled to a
`
`presumption of validity.
`
`8.
`
`On information and belief, Defendant has directly infringed the ’035 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’035 Patent.
`
`2
`
`Oracle Ex. 1036, pg. 2
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 3 of 12
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`9.
`
`Specifically, on information and belief, Defendant has directly infringed the ’035
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the following: NetApp E5400 Series Storage Arrays (including
`
`but not limited to the E5460, E5424, and E5412), E5500 Series Storage Arrays with FC, iSCSI
`
`and InfiniBand interfaces (including but not limited to the E5560, E5524, and E5512), E2700
`
`Storage Systems with FC and iSCSI interfaces (including but not limited to the E2760, E2724,
`
`E2712), E2600 Storage Systems with FC and iSCSI interfaces (including but not limited to the
`
`E2600-60, E2600-24, E2600-12), EF550 Flash Arrays with FC, iSCSI and InfiniBand Host
`
`interfaces, EF540 Flash Arrays, FAS2200 Series (including but not limited to FAS2220 and
`
`FAS2240), FAS3200 Series (including but not limited to FAS3270, FAS3250, FAS3240,
`
`FAS3220, FAS3210), FAS6200 Series (including but not limited to FAS6210, FAS6220,
`
`FAS6240, FAS6250, FAS6280, FAS6290), FAS8000 Series (including but not limited to
`
`FAS8060, FAS8040, FAS8020), V3200 Series Storage Controllers (including but not limited to
`
`V3220, V3240, V3250, V3270), V6200 Series Storage Controllers (including but not limited to
`
`V6210, V6220, V6240, V6250, V6280, V6290) and the Data ONTAP Operating System
`
`(including but not limited to Data ONTAP 8.2), hereinafter “the Accused Products”.
`
`10.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’035 Patent with knowledge of the ’035 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ‘035
`
`Patent.
`
`3
`
`Oracle Ex. 1036, pg. 3
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 4 of 12
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`11.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’035 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’035 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`12.
`
`Defendant has been on constructive and/or actual notice of the ’035 Patent since
`
`at least as early as October 2002, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’035 Patent by Defendant has been and continues to be willful and deliberate.
`
`13.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’035 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`14.
`
`As a result of the acts of infringement of the ’035 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 2: INFRINGEMENT OF U.S. PATENT NO. 7,934,041
`
`15.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`16.
`
`On April 26, 2011, the ’041 Patent was duly and legally issued. A true and
`
`correct copy of the ’041 Patent is attached hereto as Exhibit B. Crossroads is the assignee and
`
`the owner of all right, title, and interest in and to the ’041 Patent. The ’041 Patent is entitled to a
`
`presumption of validity.
`
`17.
`
`On information and belief, Defendant has directly infringed the ’041 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’041 Patent.
`
`4
`
`Oracle Ex. 1036, pg. 4
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 5 of 12
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`18.
`
`Specifically, on information and belief, Defendant has directly infringed the ’041
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the Accused Products.
`
`19.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’041 Patent with knowledge of the ’041 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ’041
`
`Patent.
`
`20.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’041 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’041 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`21.
`
`Defendant has been on constructive and/or actual notice of the ’041 Patent since
`
`at least as early as May 2011, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’041 Patent by Defendant has been and continues to be willful and deliberate.
`
`22.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’041 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`23.
`
`As a result of the acts of infringement of the ’041 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`5
`
`Oracle Ex. 1036, pg. 5
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 6 of 12
`
`COUNT 3: INFRINGEMENT OF U.S. PATENT NO. 7,051,147
`
`24.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`25.
`
`On May 23, 2006, the ’147 Patent was duly and legally issued. A true and correct
`
`copy of the ’147 Patent is attached hereto as Exhibit C. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’147 Patent. The ’147 Patent is entitled to a
`
`presumption of validity.
`
`26.
`
`On information and belief, Defendant has directly infringed the ’147 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’147 Patent.
`
`27.
`
`Specifically, on information and belief, Defendant has directly infringed the ’147
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the V3200 Series Storage Controllers (including but not limited
`
`to V3220, V3240, V3250, V3270) and V6200 Series Storage Controllers (including but not
`
`limited to V6210, V6220, V6240, V6250, V6280 and V6290) and the Data ONTAP operating
`
`system, hereinafter “the Accused Fibre-to-Fibre Products”.
`
`28.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’147 Patent with knowledge of the ’147 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Fibre-to-Fibre Products, and Defendant knew that its actions were inducing end users to infringe
`
`the ’147 Patent.
`
`29.
`
`Further, upon information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’147 Patent by selling,
`
`6
`
`Oracle Ex. 1036, pg. 6
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 7 of 12
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`offering to sell and/or importing into the United States components, including the Accused Fibre-
`
`to-Fibre Products, knowing the components to be especially made or especially adapted for use
`
`in the infringement of the ’147 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`30.
`
`Defendant has been on constructive and/or actual notice of the ’147 Patent since
`
`at least as early as August 2006, and Defendant has not ceased its infringing activities. The
`
`infringement of the ’147 Patent by Defendant has been and continues to be willful and deliberate.
`
`31.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’147 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`32.
`
`As a result of the acts of infringement of the ’147 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`COUNT 4: INFRINGEMENT OF U.S. PATENT NO. 7,987,311
`
`33.
`
`Crossroads incorporates by reference the allegations set forth in the preceding
`
`paragraphs.
`
`34.
`
`On July 26, 2011, the ’311 Patent was duly and legally issued. A true and correct
`
`copy of the ’311 Patent is attached hereto as Exhibit D. Crossroads is the assignee and the owner
`
`of all right, title, and interest in and to the ’311 Patent. The ’311 Patent is entitled to a
`
`presumption of validity.
`
`35.
`
`On information and belief, Defendant has directly infringed the ’311 Patent. On
`
`information and belief, Defendant continues to directly infringe the ’311 Patent.
`
`7
`
`Oracle Ex. 1036, pg. 7
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 8 of 12
`
`36.
`
`Specifically, on information and belief, Defendant has directly infringed the ’311
`
`Patent by making, using, offering for sale, selling and/or importing into the United States certain
`
`of its products including at least the Accused Products.
`
`37.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of inducing infringement of the ’311 Patent with knowledge of the ’311 Patent
`
`by making, offering for sale, selling, importing into the United States, marketing, supporting,
`
`providing product instruction and/or advertising certain of its products, including the Accused
`
`Products, and Defendant knew that its actions were inducing end users to infringe the ’311
`
`Patent.
`
`38.
`
`Further, on information and belief, Defendant has been and now is indirectly
`
`infringing by way of contributing to the infringement by end users of the ’311 Patent by selling,
`
`offering to sell and/or importing into the United States components, including the Accused
`
`Products, knowing the components to be especially made or especially adapted for use in the
`
`infringement of the ’311 Patent. Such components are not a staple article or commodity of
`
`commerce suitable for substantial non-infringing uses.
`
`39.
`
`On information and belief, Defendant has been on constructive and/or actual
`
`notice of the ’311 Patent. Thus, the infringement of the ’311 Patent by Defendant has been and
`
`continues to be willful and deliberate.
`
`40.
`
`Crossroads has been irreparably harmed by Defendant’s acts of infringement of
`
`the ’311 Patent, and will continue to be harmed unless and until Defendant’s acts of infringement
`
`are enjoined and restrained by order of this Court.
`
`41.
`
`As a result of the acts of infringement of the ’311 Patent by Defendant,
`
`Crossroads has suffered and will continue to suffer damages in an amount to be proven at trial.
`
`8
`
`Oracle Ex. 1036, pg. 8
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 9 of 12
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`DEMAND FOR JURY TRIAL
`
`Crossroads hereby demands a trial by jury on all issues.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Crossroads requests this Court enter judgment as follows:
`
`A.
`
`B.
`
`C.
`
`That Defendant has infringed the ’035 Patent;
`
`That such infringement of the ’035 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’035 Patent;
`
`D.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’035 Patent;
`
`E.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’035 Patent, including pre-judgment and post-judgment interest on any
`
`F.
`
`G.
`
`H.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’041 Patent;
`
`That such infringement of the ’041 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’041 Patent;
`
`I.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’041 Patent;
`
`9
`
`Oracle Ex. 1036, pg. 9
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 10 of 12
`
`J.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’041 Patent, including pre-judgment and post-judgment interest on any
`
`K.
`
`L.
`
`M.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’147 Patent;
`
`That such infringement of the ’147 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’147 Patent;
`
`N.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’147 Patent;
`
`O.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’147 Patent, including pre-judgment and post-judgment interest on any
`
`P.
`
`Q.
`
`R.
`
`enhanced damages or attorneys’ fees award;
`
`That Defendant has infringed the ’311 Patent;
`
`That such infringement of the ’311 Patent by Defendant has been willful;
`
`That Defendant accounts for and pays to Crossroads all damages caused
`
`by the infringement of the ’311 Patent;
`
`S.
`
`That Crossroads receive enhanced damages from Defendant in the form of
`
`treble damages, pursuant to 35 U.S.C. § 284 based on Defendant’s willful
`
`infringement of the ’311 Patent;
`
`10
`
`Oracle Ex. 1036, pg. 10
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 11 of 12
`
`T.
`
`That Crossroads be granted pre-judgment and post-judgment interest on
`
`the damages caused to it by reason of Defendant’s infringement of the
`
`’311 Patent, including pre-judgment and post-judgment interest on any
`
`enhanced damages or attorneys’ fees award;
`
`U.
`
`That Defendant pay Crossroads all of Crossroads’ reasonable attorneys’
`
`V.
`
`W.
`
`fees and expenses;
`
`That costs be awarded to Crossroads;
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’035 Patent;
`
`X.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’041 Patent;
`
`Y.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’147 Patent;
`
`Z.
`
`That Defendant, its agents, employees, representatives, successors and
`
`assigns, and those acting in privity or in concert with it, be preliminarily
`
`and permanently enjoined from further infringement of the ’311 Patent;
`
`AA.
`
`That this is an exceptional case under 35 U.S.C. § 285; and
`
`BB.
`
`That Crossroads be granted such other and further relief as the Court may
`
`deem just and proper under the circumstances.
`
`11
`
`Oracle Ex. 1036, pg. 11
`
`

`

`Case 1:14-cv-00149-SS Document 26 Filed 04/15/14 Page 12 of 12
`
`Dated: April 15, 2014
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /s/ Susan K. Knoll
` Steven Sprinkle
` Texas Bar No. 00794962
` Elizabeth J. Brown Fore
` Texas Bar No. 24001795
` Sprinkle IP Law Group, PC
` 1301 W. 25th Street, Suite 408
` Austin, Texas 78705
` Tel: 512-637-9220
` Fax: 512-371-9088
` ssprinkle@sprinklelaw.com
` ebrownfore@sprinklelaw.com
`
`Susan K. Knoll
`Texas Bar No. 11616900
`Russell T. Wong
`Texas Bar No. 21884235
`James H. Hall
`Texas Bar No. 24041040
`Stephen D. Zinda
`Texas Bar No. 24084147
`WONG, CABELLO, LUTSCH,
`RUTHERFORD & BRUCCULERI, L.L.P.
`20333 SH 249, Suite 600
`Houston, TX 77070
`Tel: 832-446-2400
`Fax: 832-446-2424
`sknoll@counselip.com
`rwong@counselip.com
`jhall@counselip.com
`szinda@counselip.com
`
`ATTORNEYS FOR PLAINTIFF
`CROSSROADS SYSTEMS, INC.
`
`CERTIFICATE OF SERVICE
`
`I certify that on April 15, 2014, I electronically filed the foregoing with the Clerk of
`Court using the CM/ECF system, which will send notification of such filing to all CM/ECF
`participants.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Lynn Marlin
`Lynn Marlin
`
`
`
`12
`
`Oracle Ex. 1036, pg. 12
`
`

`

`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 1 of 15
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`EXHIBIT A
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`Oracle Ex. 1036, pg. 13
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`

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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 2 of 15
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`Oracle Ex. 1036, pg. 14
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 3 of 15
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`Oracle Ex. 1036, pg. 15
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`

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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 4 of 15
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`Oracle Ex. 1036, pg. 16
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 5 of 15
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`Oracle Ex. 1036, pg. 17
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 6 of 15
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`Oracle Ex. 1036, pg. 18
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 7 of 15
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`Oracle Ex. 1036, pg. 19
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 8 of 15
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`Oracle Ex. 1036, pg. 20
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 9 of 15
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`Oracle Ex. 1036, pg. 21
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 10 of 15
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`Oracle Ex. 1036, pg. 22
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 11 of 15
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`Oracle Ex. 1036, pg. 23
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 12 of 15
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`Oracle Ex. 1036, pg. 24
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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 13 of 15
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`Oracle Ex. 1036, pg. 25
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`

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`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 14 of 15
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`Oracle Ex. 1036, pg. 26
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`

`

`Case 1:14-cv-00149-SS Document 26-1 Filed 04/15/14 Page 15 of 15
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`Oracle Ex. 1036, pg. 27
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 1 of 17
`
`EXHIBIT B
`
`(cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3) (cid:3)
`
`Oracle Ex. 1036, pg. 28
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 2 of 17
`
`Oracle Ex. 1036, pg. 29
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 3 of 17
`
`Oracle Ex. 1036, pg. 30
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 4 of 17
`
`Oracle Ex. 1036, pg. 31
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 5 of 17
`
`Oracle Ex. 1036, pg. 32
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 6 of 17
`
`Oracle Ex. 1036, pg. 33
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 7 of 17
`
`Oracle Ex. 1036, pg. 34
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 8 of 17
`
`Oracle Ex. 1036, pg. 35
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 9 of 17
`
`Oracle Ex. 1036, pg. 36
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 10 of 17
`
`Oracle Ex. 1036, pg. 37
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 11 of 17
`
`Oracle Ex. 1036, pg. 38
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 12 of 17
`
`Oracle Ex. 1036, pg. 39
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 13 of 17
`
`Oracle Ex. 1036, pg. 40
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 14 of 17
`
`Oracle Ex. 1036, pg. 41
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 15 of 17
`
`Oracle Ex. 1036, pg. 42
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 16 of 17
`
`Oracle Ex. 1036, pg. 43
`
`

`

`Case 1:14-cv-00149-SS Document 26-2 Filed 04/15/14 Page 17 of 17
`
`Oracle Ex. 1036, pg. 44
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 1 of 15
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
`EXHIBIT C
`
`Oracle Ex. 1036, pg. 45
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 2 of 15
`
`Oracle Ex. 1036, pg. 46
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 3 of 15
`
`Oracle Ex. 1036, pg. 47
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 4 of 15
`
`Oracle Ex. 1036, pg. 48
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 5 of 15
`
`Oracle Ex. 1036, pg. 49
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 6 of 15
`
`Oracle Ex. 1036, pg. 50
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 7 of 15
`
`Oracle Ex. 1036, pg. 51
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 8 of 15
`
`Oracle Ex. 1036, pg. 52
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 9 of 15
`
`Oracle Ex. 1036, pg. 53
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 10 of 15
`
`Oracle Ex. 1036, pg. 54
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 11 of 15
`
`Oracle Ex. 1036, pg. 55
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 12 of 15
`
`Oracle Ex. 1036, pg. 56
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 13 of 15
`
`Oracle Ex. 1036, pg. 57
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 14 of 15
`
`Oracle Ex. 1036, pg. 58
`
`

`

`Case 1:14-cv-00149-SS Document 26-3 Filed 04/15/14 Page 15 of 15
`
`Oracle Ex. 1036, pg. 59
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 1 of 15
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
`
` 
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` 
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` 
`
`EXHIBIT D
`
`Oracle Ex. 1036, pg. 60
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 2 of 15
`
`Oracle Ex. 1036, pg. 61
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 3 of 15
`
`Oracle Ex. 1036, pg. 62
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 4 of 15
`
`Oracle Ex. 1036, pg. 63
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 5 of 15
`
`Oracle Ex. 1036, pg. 64
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 6 of 15
`
`Oracle Ex. 1036, pg. 65
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 7 of 15
`
`Oracle Ex. 1036, pg. 66
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 8 of 15
`
`Oracle Ex. 1036, pg. 67
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 9 of 15
`
`Oracle Ex. 1036, pg. 68
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 10 of 15
`
`Oracle Ex. 1036, pg. 69
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 11 of 15
`
`Oracle Ex. 1036, pg. 70
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 12 of 15
`
`Oracle Ex. 1036, pg. 71
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 13 of 15
`
`Oracle Ex. 1036, pg. 72
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 14 of 15
`
`Oracle Ex. 1036, pg. 73
`
`

`

`Case 1:14-cv-00149-SS Document 26-4 Filed 04/15/14 Page 15 of 15
`
`Oracle Ex. 1036, pg. 74
`
`

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