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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`Civil Action No. ____
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`
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`JURY TRIAL DEMANDED
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`
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`INTELLECTUAL VENTURES I, LLC;
`INTELLECTUAL VENTURES II, LLC
`Plaintiffs,
`
`
`
`
`Defendant.
`
`v.
`
`
`NETAPP, INC.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`This is an action for patent infringement arising under the Patent Laws of the United
`
`States of America, 35 U.S.C. § 1 et seq. in which Plaintiffs Intellectual Ventures LLC I (“IV I”)
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`and Intellectual Ventures LLC II (“IV II”) (collectively “IV” or “Plaintiff”) makes the following
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`allegations against Defendant NetApp, Inc. (“Defendant”).
`
`PARTIES
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`1.
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`IV I and IV II are Washington limited liability companies, and have a place of
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`business at 3150 139th Ave SE, Building 4, Bellevue, Washington 98005.
`2.
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`On information and belief, NetApp is a Delaware corporation with its principal
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`place of business at 495 East Java Drive, Sunnyvale, CA 94089. NetApp, Inc. can be served
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`through its registered agent, Corporate Service Company, 2711 Centerville Road, Suite 400,
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`Wilmington, DE 19808.
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`JURISDICTION AND VENUE
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`3.
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`This action arises under the patent laws of the United States, Title 35 of the
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`United States Code. Accordingly, this Court has subject matter jurisdiction under 28 U.S.C.
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`§§ 1331 and 1338(a).
`4.
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`This Court has personal jurisdiction over Defendant in this action because, among
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`other reasons, Defendant has committed acts within the District of Massachusetts giving rise to
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`this action and has established minimum contacts with the forum state of Massachusetts.
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`Defendant maintains a place of business within the state at Reservoir Place, South Building 1601
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`Trapelo Road, Suite 16, Waltham, MA 02451. Defendant, directly and/or through subsidiaries or
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`intermediaries (including distributors, retailers, and others), has committed and continues to
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`commit acts of infringement in this District by, among other things, making, using, importing,
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`offering for sale, and/or selling products and/or services that infringe the patents-in-suit. Thus,
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`Defendant purposefully availed itself of the benefits of doing business in the Commonwealth of
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`Massachusetts and the exercise of jurisdiction over Defendant would not offend traditional
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`notions of fair play and substantial justice. Defendant is registered to do business in the
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`Commonwealth of Massachusetts, and has appointed Corporate Service Company, 2711
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`Centerville Road, Suite 400, Wilmington, DE 19808 as its agent for service of process.
`5.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 (b)-(c) and 1400(b)
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`because Defendant is subject to personal jurisdiction in this District, has transacted business in
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`this District and has committed acts of patent infringement in this District.
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`BACKGROUND
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`6.
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`Intellectual Ventures I and II are part of a broader Intellectual Ventures
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`organization that was founded in 2000 on the fundamental premise that inventions are valuable.
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`Since its founding, IV has built on this premise by working to ensure that a market for invention
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`continues to thrive. IV has been deeply involved in the business of invention by creating and
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`filing patent applications covering its own inventions, and collaborating with others to develop
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`and patent inventions. IV also acquires and licenses patents from individual inventors,
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`universities and other institutions. A significant aspect of IV’s business is managing the
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`plaintiffs in this case.
`7.
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`IV’s business includes purchasing important inventions from individual inventors
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`and institutions and then licensing the inventions to those who need them. Through this
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`business, IV allows inventors to reap a financial reward from their innovations, which is
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`frequently difficult for individual inventors to do. To date, IV has acquired more than 70,000
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`2
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`assets and, in the process, has paid individual inventors hundreds of millions of dollars for their
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`inventions. IV, in turn, has earned more than $3 billion by licensing these patents to some of the
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`world's most innovative and successful technology companies, which continue to use them to
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`make computer equipment, software, semiconductor devices, and a host of other products.
`8.
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`IV also creates inventions. IV has a staff of scientists and engineers who develop
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`ideas in a broad range of fields, including agriculture, computer hardware, life sciences, medical
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`devices, semiconductors, and software. IV has invested millions of dollars developing such
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`inventions and has filed hundreds of patent applications on its inventions every year, making it
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`one of the top patent filers in the world. IV has also invested in laboratory facilities to assist with
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`the development and testing of new inventions.
`9.
`
`This cause of action asserts infringement of patents that IV acquired as part of its
`
`effort to create an efficient market for inventions, and involves the patents described below and
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`attached to this complaint as Exhibits A-E (collectively, “Asserted Patents”).
`10.
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`IV II is the owner by assignment of United States Patent No. 6,516,442 (“the ’442
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`Patent”) entitled “Channel interface and protocols for cache coherency in a scalable symmetric
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`multiprocessor system.” The ’442 Patent was duly and legally issued by the United States Patent
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`and Trademark Office on February 4, 2003. A true and correct copy of the ’442 Patent is
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`included as Exhibit A.
`11.
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`IV I is the owner by assignment of United States Patent No. 6,775,745 (“the ’745
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`Patent”) entitled “Method and apparatus for hybrid data caching system.” The ’745 Patent was
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`duly and legally issued by the United States Patent and Trademark Office on August 10, 2004.
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`A true and correct copy of the ’745 Patent is included as Exhibit B.
`12.
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`IV II is the owner by assignment of United States Patent No. 6,968,459 (“the ’459
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`Patent”) entitled “Computing environment having secure storage device.” The ’459 Patent was
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`duly and legally issued by the United States Patent and Trademark Office on November 22,
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`2005. A true and correct copy of the ’459 Patent is included as Exhibit C.
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`3
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`13.
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`IV I is the owner by assignment of United States Patent No. 8,275,827 (“the ’827
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`Patent”) entitled “Software-based network attached storage services hosted on massively
`
`distributed parallel computing networks.” The ’827 Patent was duly and legally issued by the
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`United States Patent and Trademark Office on September 25, 2012. A true and correct copy of
`
`the ’827 Patent is included as Exhibit D.
`14.
`
`IV II is the owner by assignment of United States Patent No. 6,633,945 (“the ’945
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`Patent”) entitled “Fully connected cache coherent multiprocessing systems.” The ’945 Patent
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`was duly and legally issued by the United States Patent and Trademark Office on October 14,
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`2003. A true and correct copy of the ’945 Patent is included as Exhibit E.
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`COUNT I
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`INFRINGEMENT OF THE ’442 PATENT
`
`15.
`16.
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`IV incorporates by reference paragraphs 1 through 14 of this Complaint.
`
`On information and belief, Defendant makes, uses, offers for sale and/or sells in
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`the United States products and/or services that infringe various claims of the ’442 Patent, and
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`continues to do so. By way of illustrative example, Defendant’s infringing products include
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`without limitation, all versions and variations of NetApp’s FAS series products.1 Defendant’s
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`infringing products are referred to hereinafter as “the ’442 Accused Instrumentalities.”
`17.
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`On information and belief, the ’442 Accused Instrumentalities are shared-memory
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`multiprocessor systems comprising a switch fabric configured to switch packets containing data.2
`18.
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`On information and belief, the ’442 Accused Instrumentalities comprise a
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`plurality of channels configured to transfer packets.
`19.
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`On information and belief, the ’442 Accused Instrumentalities comprise a
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`plurality of switch interfaces configured to exchange the packets with the switch fabric,
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`1 See, e.g., http://www.netapp.com/us/products/storage-systems/fas8000/.
`2 See generally, e.g., http://www.netapp.com/us/media/ds-3546.pdf. (“The FAS8000 features a
`multiprocessor … chip set and leverages high-performance memory modules”) (emphasis
`added).
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`4
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`exchange the packets over channels, and perform error correction of the data in the packets
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`exchanged over the channels.
`20.
`
`On information and belief, the ’442 Accused Instrumentalities comprise a
`
`plurality of microprocessor interfaces configured to exchange the data with a plurality of
`
`microprocessors, exchange the packets with the switch interfaces over the channels, and perform
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`error correction of the packets exchanged over the channels.
`21.
`
`On information and belief, the ’442 Accused Instrumentalities comprise a
`
`memory interface configured to exchange the data with a memory device, exchange the packets
`
`with the switch interfaces over the channels, and perform error correction of the data in the
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`packets exchanged over the channels.
`22.
`
`On information and belief, Defendant has directly infringed and continues to
`
`directly infringe the ’442 Patent by, among other things, making, using, offering for sale, and/or
`
`selling the ’442 Accused Instrumentalities. On information and belief, such products and/or
`
`services are covered by one or more claims of the ’442 Patent including at least claim 1.
`23.
`
`By making, using, offering for sale, and/or selling the ’442 Accused
`
`Instrumentalities infringing the ’442 Patent, Defendant has injured IV and is liable to IV for
`
`infringement of the ’442 Patent pursuant to 35 U.S.C. § 271.
`24.
`
`To the extent facts learned in discovery show that Defendant’s infringement of the
`
`’442 Patent is or has been willful, IV reserves the right to request such a finding at time of trial.
`25.
`
`To the extent applicable, the requirements of 35 U.S.C. § 287(a) have been met
`
`with respect to the ’442 Patent.
`26.
`
`As a result of Defendant’s infringement of the ’442 Patent, IV has suffered
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together
`
`with interest and costs as fixed by the Court, and IV will continue to suffer damages in the future
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`unless Defendant’s infringing activities are enjoined by this Court.
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`5
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`27.
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`Unless a permanent injunction is issued enjoining Defendant and its agents,
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`servants, employees, representatives, affiliates, and all others acting or in active concert
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`therewith from infringing the ’442 Patent, IV will be greatly and irreparably harmed.
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`COUNT II
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`INFRINGEMENT OF THE ’745 PATENT
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`28.
`
`IV references and incorporates by reference paragraphs 1 through 27 of this
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`Complaint.
`29.
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`On information and belief, Defendant makes, uses, offers for sale and/or sells in
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`the United States products and/or services that infringe various claims of the ’745 Patent, and
`
`continues to do so. By way of illustrative example, Defendant’s infringing products include
`
`without limitation, all versions and variations of NetApp’s FlashPool technology, and all
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`products that utilize it, including without limitation FAS, E-, and DS series products.3
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`Defendant’s infringing products are referred to collectively hereinafter as “the ’745 Accused
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`Instrumentalities.”
`30.
`
`On information and belief, the ’745 Accused Instrumentalities perform a caching
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`method for enhancing system performance for a computer.4
`31.
`
`On information and belief, the ’745 Accused Instrumentalities read an extended
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`segment of data in response to a request from an operating system.
`32.
`
`On information and belief, the ’745 Accused Instrumentalities store copies of
`
`associated with the extended segment in a cache.
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`
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`3 See, generally e.g., http://www.netapp.com/ca/products/platform-os/flashpool.aspx;
`http://www.netapp.com/ca/media/ds-3345.pdf.
`4 See, e.g., id. (“Enable automated storage tiering by using NetApp® Flash Pool™ intelligent
`caching, an integral component of the NetApp® Virtual Storage Tier.”) (emphasis added).
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`33.
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`On information and belief, the ’745 Accused Instrumentalities assign frequency
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`factors to each of the files stored in the cache, the frequency factor indicating how often each of
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`the corresponding files are requested by the operating system.5
`34.
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`On information and belief, the ’745 Accused Instrumentalities scan the frequency
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`factors, the scanning being performed in response to a target capacity of the cache being attained.
`35.
`
`On information and belief, the ’745 Accused Instrumentalities identify a least
`
`frequently and least recently used file.
`36.
`
`On information and belief, the ’745 Accused Instrumentalities eliminate the least
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`frequently and least recently used file to liberate capacity of the cache.
`37.
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`On information and belief, Defendant has directly infringed and continues to
`
`directly infringe the ’745 Patent by, among other things, making, using, offering for sale, and/or
`
`selling the ’745 Accused Instrumentalities. On information and belief, such products and/or
`
`services are covered by one or more claims of the ’745 Patent including at least claim 4.
`38.
`
`By making, using, offering for sale, and/or selling the ’745 Accused
`
`Instrumentalities infringing the ’745 Patent, Defendant has injured IV and is liable to IV for
`
`infringement of the ’745 Patent pursuant to 35 U.S.C. § 271.
`39.
`
`To the extent facts learned in discovery show that Defendant’s infringement of the
`
`’745 Patent is or has been willful, IV reserves the right to request such a finding at time of trial.
`40.
`
`To the extent applicable, the requirements of 35 U.S.C. § 287(a) have been met
`
`with respect to the ’745 Patent.
`41.
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`As a result of Defendant’s infringement of the ’745 Patent, IV has suffered
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`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
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`event less than a reasonable royalty for the use made of the invention by Defendant, together
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`5 See, e.g., http://www.netapp.com/ca/media/ds-3345.pdf (“[E]nterprise workloads have a small
`subset of the overall dataset that accounts for most of the performance needs of the workload.
`This subset is called the working set, active data, or hot data.”) (internal quotation marks
`omitted).
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`with interest and costs as fixed by the Court, and IV will continue to suffer damages in the future
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`unless Defendant’s infringing activities are enjoined by this Court.
`42.
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`Unless a permanent injunction is issued enjoining Defendant and its agents,
`
`servants, employees, representatives, affiliates, and all others acting or in active concert
`
`therewith from infringing the ’745 Patent, IV will be greatly and irreparably harmed.
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`COUNT III
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`INFRINGEMENT OF THE ’459 PATENT
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`43.
`
`IV references and incorporates by reference paragraphs 1 through 42 of this
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`Complaint.
`44.
`
`On information and belief, Defendant makes, uses, offers for sale and/or sells in
`
`the United States products and/or services that infringe various claims of the ’459 Patent, and
`
`continues to do so. By way of illustrative example, Defendant’s infringing products include
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`without limitation all versions and variations of NetApp’s Storage Encryption, and all NetApp
`
`products that utilize it.6 Defendant’s infringing products are referred to collectively hereinafter
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`as “the ’459 Accused Instrumentalities.”
`45.
`
`On information and belief, the ’459 Accused Instrumentalities perform a method
`
`of sensing whether a storage device has device-specific security information stored thereon.
`46.
`
`On information and belief, the ’459 Accused Instrumentalities operate in a full-
`
`access mode when the storage device has the device-specific security information.
`47.
`
`On information and belief, the ’459 Accused Instrumentalities operate in a
`
`restricted-access mode when the storage device does not have the device-specific security
`
`information.
`48.
`
`On information and belief, Defendant has directly infringed and continues to
`
`directly infringe the ’459 Patent by, among other things, making, using, offering for sale, and/or
`
`selling the ’459 Accused Instrumentalities. On information and belief, such products and/or
`
`6 See, generally e.g., http://www.netapp.com/us/products/storage-security-systems/netapp-
`storage-encryption.aspx.
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`services are covered by one or more claims of the ’459 Patent including at least claims 18 and
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`39.
`
`49.
`
`By making, using, offering for sale, and/or selling the ’459 Accused
`
`Instrumentalities infringing the ’459 Patent, Defendant has injured IV and is liable to IV for
`
`infringement of the ’459 Patent pursuant to 35 U.S.C. § 271.
`50.
`
`To the extent facts learned in discovery show that Defendant’s infringement of the
`
`’459 Patent is or has been willful, IV reserves the right to request such a finding at time of trial.
`51.
`
`To the extent applicable, the requirements of 35 U.S.C. § 287(a) have been met
`
`with respect to the ’459 Patent.
`52.
`
`As a result of Defendant’s infringement of the ’459 Patent, IV has suffered
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together
`
`with interest and costs as fixed by the Court, and IV will continue to suffer damages in the future
`
`unless Defendant’s infringing activities are enjoined by this Court.
`53.
`
`Unless a permanent injunction is issued enjoining Defendant and its agents,
`
`servants, employees, representatives, affiliates, and all others acting or in active concert
`
`therewith from infringing the ’459 Patent, IV will be greatly and irreparably harmed.
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`COUNT IV
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`INFRINGEMENT OF THE ’827 PATENT
`
`54.
`
`IV references and incorporates by reference paragraphs 1 through 53 of this
`
`Complaint.
`55.
`
`On information and belief, Defendant makes, uses, offers for sale and/or sells in
`
`the United States products and/or services that infringe various claims of the ’827 Patent, and
`
`continues to do so. By way of illustrative example, Defendant’s infringing products include
`
`without limitation all versions and variations of its FAS and E-series products.7 Defendant’s
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`7 See, e.g., http://www.netapp.com/us/media/ds-3582.pdf;
`http://www.netapp.com/us/products/storage-systems/e5500/index.aspx.
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`infringing products are referred to collectively hereinafter as “the ’827 Accused
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`Instrumentalities.”
`56.
`
`On information and belief, the ’827 Accused Instrumentalities configure a
`
`distributed processing system comprising several distributed devices coupled to a network,
`
`wherein these several distributed devices include respective client agents configured to process
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`respective portions of a workload for the distributed processing system, wherein the respective
`
`client agents for particular distributed devices of these several distributed devices have
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`corresponding software-based network attached storage (NAS) components configured to assess
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`unused or under-utilized storage resources in selected distributed devices of the plurality of
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`distributed devices.
`57.
`
`On information and belief, the ’827 Accused Instrumentalities represent with a
`
`corresponding software-based NAS component that the selected distributed devices respectively
`
`comprise NAS devices having an available amount of storage resources related to the unused and
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`under-utilized storage resources for the selected distributed devices.
`58.
`
`On information and belief, the ’827 Accused Instrumentalities process one or
`
`more of data storage or access workloads for the distributed processing system by accessing data
`
`from or storing data to at least a portion of the available amount of storage resources to provide
`
`NAS service to a client device coupled to the network.
`59.
`
`On information and belief, the ’827 Accused Instrumentalities enable at least one
`
`of the selected distributed devices to function as a location distributed device to store location
`
`information associated with data stored by the selected distributed devices through use of the
`
`respective client agents for the particular distributed device.
`60.
`
`On information and belief, Defendant has directly infringed and continues to
`
`directly infringe the ’827 Patent by, among other things, making, using, offering for sale, and/or
`
`selling the ’827 Accused Instrumentalities. On information and belief, such products and/or
`
`services are covered by one or more claims of the ’827 Patent including at least claims 1 and 13.
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`61.
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`By making, using, offering for sale, and/or selling the ’827 Accused
`
`Instrumentalities infringing the ’827 Patent, Defendant has injured IV and is liable to IV for
`
`infringement of the ’827 Patent pursuant to 35 U.S.C. § 271.
`62.
`
`To the extent facts learned in discovery show that Defendant’s infringement of the
`
`’827 Patent is or has been willful, IV reserves the right to request such a finding at time of trial.
`63.
`
`To the extent applicable, the requirements of 35 U.S.C. § 287(a) have been met
`
`with respect to the ’827 Patent.
`64.
`
`As a result of Defendant’s infringement of the ’827 Patent, IV has suffered
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together
`
`with interest and costs as fixed by the Court, and IV will continue to suffer damages in the future
`
`unless Defendant’s infringing activities are enjoined by this Court.
`65.
`
`Unless a permanent injunction is issued enjoining Defendant and its agents,
`
`servants, employees, representatives, affiliates, and all others acting or in active concert
`
`therewith from infringing the ’827 Patent, IV will be greatly and irreparably harmed.
`
`COUNT V
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`INFRINGEMENT OF THE ’945 PATENT
`
`66.
`
`IV references and incorporates by reference paragraphs 1 through 65 of this
`
`Complaint.
`67.
`
`On information and belief, Defendant makes, uses, offers for sale and/or sells in
`
`the United States products and/or services that infringe various claims of the ’945 Patent, and
`
`continue to do so. By way of illustrative example, Defendant’s infringing products include
`
`without limitation all versions and variations of NetApp’s Metrocluster technology, and all
`
`products that utilize it.8 Defendant’s infringing products are referred to collectively hereinafter
`
`as “the ’945 Accused Instrumentalities.”
`
`
`8 See, e.g., http://www.netapp.com/us/media/tr-3548.pdf.
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`68.
`
`On information and belief, the ’945 Accused Instrumentalities are multi-processor
`
`shared memory systems.
`69.
`
`On information and belief, the ’945 Accused Instrumentalities comprise a first set
`
`of point-to-point connections, with a first set of processors and a first memory coupled to that
`
`first set of connections, and a flow control unit that includes a first data switch coupled to the
`
`first set of point-to-point connections wherein that data switch is configured to interconnect the
`
`first set of point-to-point connections to provide data paths between the first coupled memory
`
`and the first set of coupled processors.
`70.
`
`On information and belief, the ’945 Accused Instrumentalities comprise a second
`
`set of point-to-point connections, with a second set of processors and a second memory coupled
`
`to that second set of connections, and a flow control unit that includes a second data switch
`
`coupled to the second set of point-to-point connections wherein that data switch is configured to
`
`interconnect the second set of point-to-point connections to provide data paths between the
`
`second coupled memory and the second set of coupled processors.
`71.
`
`On information and belief, the ’945 Accused Instrumentalities comprise a third
`
`point-to-point connection coupled to the first data switch and to the second data switch wherein
`
`the first data switch is configured to interconnect the first set of point-to-point connections to the
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`third point-to-point connection and the second data switch is configured to interconnect the
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`second set of point-to-point connections to the third point-to-point connection to provide third
`
`data paths between the second memory and the first set of processors and between the first
`
`memory and the second set of processors.
`72.
`
`On information and belief, Defendant has directly infringed and continues to
`
`directly infringe the ’945 Patent by, among other things, making, using, offering for sale, and/or
`
`selling the ’945 Accused Instrumentalities. On information and belief, such products and/or
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`services are covered by one or more claims of the ’945 Patent including at least claim 1.
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`73.
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`By making, using, offering for sale, and/or selling the ’945 Accused
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`Instrumentalities infringing the ’945 Patent, Defendant has injured IV and is liable to IV for
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`infringement of the ’945 Patent pursuant to 35 U.S.C. § 271.
`74.
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`To the extent facts learned in discovery show that Defendant’s infringement of the
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`’945 Patent is or has been willful, IV reserves the right to request such a finding at time of trial.
`75.
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`To the extent applicable, the requirements of 35 U.S.C. § 287(a) have been met
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`with respect to the ’945 Patent.
`76.
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`As a result of Defendant’s infringement of the ’945 Patent, IV has suffered
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`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
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`event less than a reasonable royalty for the use made of the invention by Defendant, together
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`with interest and costs as fixed by the Court, and IV will continue to suffer damages in the future
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`unless Defendant’s infringing activities are enjoined by this Court.
`77.
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`Unless a permanent injunction is issued enjoining Defendant and its agents,
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`servants, employees, representatives, affiliates, and all others acting or in active concert
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`therewith from infringing the ’945 Patent, IV will be greatly and irreparably harmed.
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`PRAYER FOR RELIEF
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`Plaintiff respectfully requests the following relief from this Court:
`A.
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`A judgment that Defendant has infringed one or more claims of the ’442, ’745,
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`’459, ’827, and/or ’945 Patents;
`B.
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`A permanent injunction enjoining Defendant and its officers, directors, agents,
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`servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in
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`active concert or participation with Defendant, from infringing the ’442, ’745, ’459, ’827, and/or
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`’945 Patents;
`C.
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`A judgment and order requiring Defendant to pay IV its damages, costs, expenses,
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`and prejudgment and post-judgment interest for Defendant’s acts of infringement in accordance
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`with 35 U.S.C. § 284;
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`
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`D.
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`A judgment and order requiring Defendant to provide accountings and to pay
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`supplemental damages to IV, including, without limitation, prejudgment and post-judgment
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`interest;
`E.
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`A judgment and order finding that this is an exceptional case within the meaning
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`of 35 U.S.C. § 285 and awarding to IV its reasonable attorneys’ fees against Defendant; and
`F.
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`Any and all other relief to which IV may show itself to be entitled.
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`JURY TRIAL DEMANDED
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`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, IV requests a trial by jury of
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`Respectfully submitted,
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`INTELLECTUAL VENTURES I, LLC and
`INTELLECTUAL VENTURES II, LLC,
`By their attorneys,
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`
`
`/s/ David S. Godkin
`David S. Godkin (BBO#196530)
`Andrew A. Caffrey, III (BBO#660481)
`BIRNBAUM & GODKIN, LLP
`280 Summer Street
`Boston, MA 02210
`Tel: (617) 307-6100
`Fax: (617) 307-6101
`godkin@birnbaumgodkin.com
`caffrey@birnbaumgodkin.com
`
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`any issues so triable by right.
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`
`DATED: May 11, 2016
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`OF COUNSEL:
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`Brian D. Ledahl
`Marc A. Fenster
`Adam Hoffman
`Arka D. Chatterjee
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Tel: 310-826-7474
`Fax: 310-826-6991
`bledahl@raklaw.com
`mfenster@raklaw.com
`ahoffman@raklaw.com
`achatterjee@raklaw.com
`
`
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