Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 1 of 14 PageID #: 750
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`LIFEPORT SCIENCES LLC,
`
`
`
`
`Plaintiff,
`
`C.A. No. 12-cv-01791 GMS
`
`
`
`Defendant.
`
`
`
`AMENDED COMPLAINT
`
`
`
`
`
`v.
`
`
`ENDOLOGIX, INC.,
`
`
`
`
`
`1.
`
`Plaintiff LifePort Sciences LLC (“LifePort” or “Plaintiff”), for its Complaint
`
`against Defendant Endologix, Inc., (“Endologix” or “Defendant”) hereby alleges as follows:
`
`PARTIES
`
`2.
`
`Plaintiff LifePort is a Texas Limited Liability Company with its principal place of
`
`business at 6136 Frisco Square Blvd., Suite 385, Frisco, TX 75034.
`
`3.
`
`Defendant Endologix, is a corporation organized and existing under the laws of
`
`the State of Delaware, with its principal place of business located at 11 Studebaker, Irvine,
`
`California 92618. Endologix is in the business of developing, manufacturing, and selling medical
`
`devices. Such devices include, but are not limited to, endovascular stents, grafts, and delivery
`
`systems.
`
`NATURE OF THE ACTION
`
`4.
`
`This is a civil action for the infringement of United States Patent No. 5,489,295
`
`(the “’295 Patent”) (attached as Exhibit A) entitled “Endovascular Graft Having Bifurcation and
`
`Apparatus and Method for Deploying the Same,” United States Patent No. 6,117,167 (the “’167
`
`Patent”) (attached as Exhibit B) entitled “Endoluminal Prosthesis and System for Joining,”
`
`United States Patent No. 6,302,906 (the “’906 Patent”) (attached as Exhibit C) entitled “System
`
`
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 2 of 14 PageID #: 751
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`for Delivering a Prosthesis,” United States Patent No. 5,993,481 (the “’481 Patent”) (attached as
`
`Exhibit D) entitled “Modular Bifurcated Intraluminal Grafts and Methods for Delivering and
`
`Assembling Same,” United States Patent No. 5,676,696 (the “’696 Patent”) (attached as Exhibit
`
`E) entitled “ Modular Bifurcated Intraluminal Grafts and Methods for Delivering and
`
`Assembling Same,” and United States Patent No. 8,192,482 (the “’482 Patent”) (attached as
`
`Exhibit F) entitled “Endoluminal Stent,” (collectively, the “Patents-in-Suit”) under the patent
`
`laws of the United States, 35 U.S.C. § 1, et seq.
`
`5.
`
`Plaintiff LifePort is the lawful assignee of all right, title and interest in and to the
`
`Patents-in-Suit.
`
`JURISDICTION AND VENUE
`
`6.
`
`This Court has original jurisdiction over the subject matter of this Complaint
`
`under 28 U.S.C. § 1338(a) because this action arises under the patent laws of the United States,
`
`including 35 U.S.C. § 271, et seq.
`
`7.
`
`Defendant is subject to personal jurisdiction in the State of Delaware because it is
`
`incorporated in this judicial district. In addition, the Defendant has committed acts of
`
`infringement of one or more of the claims of the Patents-in-Suit in this judicial district.
`
`8.
`
`Venue in this district is proper under 28 U.S.C. §§ 1400(b) and 1391(b) and (c),
`
`because the Defendant is subject to personal jurisdiction in this district and has committed acts of
`
`infringement in this district.
`
`COUNT I
`
`(Endologix’s Infringement of the ’295 Patent)
`
`9.
`
`10.
`
`Paragraphs 1 through 8 are incorporated by reference as if fully restated herein.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’295 Patent.
`
`2
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 3 of 14 PageID #: 752
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`11.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’295 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`12.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’295 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`knowledge of the ’295 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`13.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`knowing that those products constitute a material part of the inventions of the ’295 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’295 Patent, and
`
`3
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 4 of 14 PageID #: 753
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`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`14.
`
`Defendant has had knowledge of and notice of the ’295 Patent and its
`
`infringement since at least, and through, the filing and service of the Complaint. Moreover, by
`
`way of prosecution of patent applications assigned to Endologix, Endologix had notice of the
`
`’295 Patent prior to the filing of the Complaint. Despite this knowledge and notice, Endologix
`
`continues to commit tortious conduct by way of patent infringement. Accordingly, Endologix
`
`has willfully infringed the ’295 Patent.
`
`15.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’295 Patent through the aforesaid acts.
`
`16.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement, including enhanced damages for Endologix’s willful infringement.
`
`COUNT II
`
`(Endologix’s Infringement of the ’167 Patent)
`
`17.
`
`18.
`
`Paragraphs 1 through 16 are incorporated by reference as if fully restated herein.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’167 Patent.
`
`19.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’167 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`4
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 5 of 14 PageID #: 754
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`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`20.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’167 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`knowledge of the ’167 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`21.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`knowing that those products constitute a material part of the inventions of the ’167 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’167 Patent, and
`
`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`22.
`
`Defendant has had knowledge of and notice of the ’167 Patent and its
`
`infringement since at least, and through, the filing and service of the Complaint. Moreover, by
`
`way of prosecution of patent applications assigned to Endologix, Endologix had notice of the
`
`’167 Patent prior to the filing of the Complaint. Despite this knowledge and notice, Endologix
`
`5
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 6 of 14 PageID #: 755
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`continues to commit tortious conduct by way of patent infringement. Accordingly, Endologix
`
`has willfully infringed the ’167 Patent.
`
`23.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’167 Patent through the aforesaid acts.
`
`24.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement, including enhanced damages for Endologix’s willful infringement.
`
`COUNT III
`
`(Endologix’s Infringement of the ’906 Patent)
`
`25.
`
`26.
`
`Paragraphs 1 through 24 are incorporated by reference as if fully restated herein.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’906 Patent.
`
`27.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’906 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`28.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’906 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`6
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 7 of 14 PageID #: 756
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`knowledge of the ’906 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`29.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`knowing that those products constitute a material part of the inventions of the ’906 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’906 Patent, and
`
`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`30.
`
`Defendant has had knowledge of and notice of the ’906 Patent and its
`
`infringement since at least, and through, the filing and service of the Complaint. Despite this
`
`knowledge and notice, Endologix continues to commit tortious conduct by way of patent
`
`infringement.
`
`31.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’906 Patent through the aforesaid acts.
`
`32.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement.
`
`COUNT IV
`
`(Endologix’s Infringement of the ’481 Patent)
`
`33.
`
`Paragraphs 1 through 32 are incorporated by reference as if fully restated herein.
`
`7
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 8 of 14 PageID #: 757
`
`34.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’481 Patent.
`
`35.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’481 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`36.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’481 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`knowledge of the ’481 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`37.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`8
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 9 of 14 PageID #: 758
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`knowing that those products constitute a material part of the inventions of the ’481 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’481 Patent, and
`
`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`38.
`
`Defendant has had knowledge of and notice of the ’481 Patent and its
`
`infringement since at least, and through, the filing and service of the Complaint. Despite this
`
`knowledge and notice, Endologix continues to commit tortious conduct by way of patent
`
`infringement.
`
`39.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’481 Patent through the aforesaid acts.
`
`40.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement.
`
`COUNT V
`
`(Endologix’s Infringement of the ’696 Patent)
`
`41.
`
`42.
`
`Paragraphs 1 through 40 are incorporated by reference as if fully restated herein.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’696 Patent.
`
`43.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’696 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`9
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 10 of 14 PageID #: 759
`
`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`44.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’696 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`knowledge of the ’696 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`45.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`knowing that those products constitute a material part of the inventions of the ’696 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’696 Patent, and
`
`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`46.
`
`Defendant has had knowledge of and notice of the ’696 Patent and its
`
`infringement since at least, and through, the filing and service of the Complaint. Moreover, by
`
`way of prosecution of patent applications assigned to Endologix, Endologix had notice of the
`
`’696 Patent prior to the filing of the Complaint. Despite this knowledge and notice, Endologix
`
`10
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 11 of 14 PageID #: 760
`
`continues to commit tortious conduct by way of patent infringement. Accordingly, Endologix
`
`has willfully infringed the ’696 Patent.
`
`47.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’696 Patent through the aforesaid acts.
`
`48.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement, including enhanced damages for Endologix’s willful infringement.
`
`COUNT VI
`
`(Endologix’s Infringement of the ’482 Patent)
`
`49.
`
`50.
`
`Paragraphs 1 through 48 are incorporated by reference as if fully restated herein.
`
`Plaintiff LifePort is the assignee and lawful owner of all right, title and interest in
`
`and to the ’482 Patent.
`
`51.
`
`Defendant makes, uses, sells, offers to sell and/or imports into the United States
`
`for subsequent sale or use products, services, methods or processes that directly and/or indirectly
`
`infringe, literally and/or under the doctrine of equivalents, or which employ systems,
`
`components and/or processes that make use of systems or processes that directly and/or
`
`indirectly infringe, literally and/or under the doctrine of equivalents, one or more of the claims of
`
`the ’482 Patent. Such devices are medical devices, including but not limited to endovascular
`
`grafts and delivery systems, such as, but not limited to the Endologix AFX Endovascular AAA
`
`System, the Endologix IntuiTrak Endovascular AAA System, various accessories for
`
`Endologix’s endovascular graft products, and other similar devices.
`
`52.
`
`Defendant actively, knowingly, and intentionally induced, and continues to
`
`actively, knowingly, and intentionally induce, infringement of the ’482 Patent by making, using,
`
`offering for sale, importing, and selling infringing medical devices, as well as by contracting
`
`with others to use, market, sell, offer to sell, and import infringing medical devices, all with
`
`11
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 12 of 14 PageID #: 761
`
`knowledge of the ’482 Patent and its claims; with knowledge that its customers and end users
`
`will use, market, sell, offer to sell, and import infringing medical devices; and with the
`
`knowledge and the specific intent to encourage and facilitate those infringing sales and uses of
`
`infringing medical devices through the creation and dissemination of promotional and marketing
`
`materials, instructional materials, product manuals, and technical materials.
`
`53.
`
`Defendant has also contributed to the infringement by others, including the end
`
`users of infringing medical devices, and continues to contribute to infringement by others, by
`
`selling, offering to sell, and importing the infringing medical devices into the United States,
`
`knowing that those products constitute a material part of the inventions of the ’482 Patent,
`
`knowing those products to be especially made or adapted to infringe the ’482 Patent, and
`
`knowing that those products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
`
`54.
`
`Defendant has had knowledge of and notice of the ’482 Patent and its
`
`infringement since at least, and through, the filing and service of this Amended Complaint.
`
`Despite this knowledge and notice, Endologix continues to commit tortious conduct by way of
`
`patent infringement.
`
`55.
`
`Defendant has been and continues to be infringing one or more of the claims of
`
`the ’482 Patent through the aforesaid acts.
`
`56.
`
`Plaintiff is entitled to recover damages adequate to compensate for the
`
`infringement, including enhanced damages for Endologix’s willful infringement.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, LifePort, respectfully requests the following relief:
`
`(a)
`
`A judgment that U.S. Patent Nos. United States Patent Nos. 5,489,295; 6,117,167;
`
`6,302,906; 5,993,481; 5,676,696 and 8,192,482 are valid and enforceable.
`
`12
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 13 of 14 PageID #: 762
`
`(b)
`
`(c)
`
`(d)
`
`(e)
`
`(f)
`
`(g)
`
`(h)
`
`A judgment that Endologix, Inc., has infringed the ’295 Patent;
`
`A judgment that Endologix, Inc., has infringed the ’167 Patent;
`
`A judgment that Endologix, Inc., has infringed the ’906 Patent;
`
`A judgment that Endologix, Inc., has infringed the ’481 Patent;
`
`A judgment that Endologix, Inc., has infringed the ’696 Patent;
`
`A judgment that Endologix, Inc. has infringed the ’482 Patent,
`
`A judgment that LifePort be awarded all appropriate damages (including
`
`enhanced damages for willful infringement) under 35 U.S.C. § 284 for the Defendant’s past
`
`infringement, and any continuing or future infringement of the Patents-in-Suit, up until the date
`
`such judgment is entered, including pre and post judgment interest, costs, and disbursements as
`
`justified under 35 U.S.C. § 284 and, if necessary, to adequately compensate LifePort for
`
`Defendant’s infringement, an accounting:
`
`i.
`
`that this case be declared exceptional within the meaning of 35 U.S.C. §
`
`285 and that LifePort be awarded its reasonable attorneys’ fees against Endologix that it
`
`incurs in prosecuting this action;
`
`ii.
`
`that LifePort be awarded costs, and expenses that it incurs in prosecuting
`
`this action; and
`
`iii.
`
`that LifePort be awarded such further relief at law or in equity as the Court
`
`deems just and proper.
`
`13
`
`

`
`Case 1:12-cv-01791-GMS Document 34 Filed 08/12/14 Page 14 of 14 PageID #: 763
`
`DEMAND FOR JURY TRIAL
`
`LifePort hereby demands trial by jury on all claims and issues so triable.
`
`DATED:
`
`August 12, 2014
`
`Respectfully submitted,
`
`FARNAN LLP
`
`
`
`
`
` /s/ Brian E. Farnan
`Joseph J. Farnan, III (Bar No. 3945)
`Brian E. Farnan (Bar No. 4089)
`919 North Market Street, 12th Floor
`Wilmington, Delaware 19801
`(302) 777-0300
`(302) 777-0301 (Fax)
`bfarnan@farnanlaw.com
`
`Philip C. Ducker (pro hac vice)
`DECHERT LLP
`2440 W. El Camino Real Suite 700
`Mountain View, CA 94040-1499
`Tel. (650) 813-4800
`Fax (650) 813-4848
`
`Derek J. Brader (pro hac vice)
`DECHERT LLP
`Cira Centre
`2929 Arch Street
`Philadelphia, PA 19104-2808
`Tel. (215) 994-4000
`Fax (215) 994-2222
`
`OF COUNSEL:
`Martin J. Black—LEAD ATTORNEY
`Kevin M. Flannery
`DECHERT LLP
`Cira Centre
`2929 Arch Street
`Philadelphia, PA 19104-2808
`Tel. (215) 994-4000
`martin.black@dechert.com
`kevin.flannery@dechert.com
`
`15282031
`
`Counsel for Plaintiff LifePort Sciences LLC
`
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