Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 1 of 18 PageID #: 4444
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`ALACRITECH, INC.,
`
`
`
`Plaintiff,
`
`Case No. 2:16-cv-693-JRG-RSP
`
`v.
`
`CENTURYLINK, INC., et al.,
`
`
`
`
`LEAD CASE
`
`Defendants,
`
`JURY TRIAL DEMANDED
`
`and
`
`INTEL CORPORATION, et al.,
`
`Intervenors.
`
`
`
`PLAINTIFF, DEFENDANT IN INTERVENTION, AND COUNTERCLAIM-
`PLAINTIFF’S ANSWER AND COUNTER-COUNTERCLAIMS TO INTERVENOR
`AND COUNTERCLAIM-DEFENDANT INTEL CORPORATION’S COUNTERCLAIMS
`FOR DECLARATORY JUDGMENT OF PATENT INVALIDITY
`
`Plaintiff, Defendant
`
`in Intervention, and Counterclaim-Plaintiff Alacritech, Inc.
`
`(“Alacritech”) responds to Intervenor and Counterclaim-Defendant Intel Corporation’s (“Intel”)
`
`Answer and Counterclaims for Declaratory Judgment of Patent Invalidity (Dkt. No. 120). Any
`
`allegation Alacritech does not expressly admit should be deemed denied.
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`COUNTERCLAIMS FOR INVALIDITY
`
`1.
`
`Alacritech admits that Intel purports to seek declaratory judgment of invalidity of
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`U.S. Patent Nos. 7,124,205 (“the ‘205 Patent”); 7,237,036 (“the ‘036 Patent”); 7,337,241 (“the
`
`‘241 Patent”); 7,673,072 (“the ‘072 Patent”); 7,945,699 (“the ‘699 Patent”); 8,131,880 (“the ‘880
`
`Patent”); 8,805,948 (“the ‘948 Patent”); and 9,055,104 (“the ‘104 Patent”) (together, “the
`
`Asserted Patents”) in Intel’s Answer to Alacritech’s Counterclaims. Alacritech denies the
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`remaining allegations in Paragraph 1.
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`
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`1
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`INTEL EX.1112.001
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 6 of 18 PageID #: 4449
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`
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`COUNTERCLAIMS FOR PATENT INFRINGEMENT
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`In these counterclaims for patent infringement under 35 U.S.C. § 271 in response to both
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`Intel Corporation’s (“Intel”) intervention in Case No. 2:16-cv-00692 to defend Dell, and Intel’s
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`Answer and Counterclaims (Dkt. 120) filed in the same matter, Plaintiff Alacritech, Inc.
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`(“Alacritech”), by and through its undersigned counsel, complains and alleges as follows against
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`Intervenor Intel, based on Alacritech’s own personal knowledge and upon information and belief
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`with respect to Intel’s actions:
`
`THE PARTIES
`
`1.
`
`Alacritech incorporates by reference Paragraphs 1 and 2 of its Counterclaims for
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`Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully herein.
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`NATURE OF THE ACTION
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`2.
`
`Alacritech incorporates by reference Paragraphs 3 and 4 of its Counterclaims for
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`Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully herein.
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`JURISDICTION AND VENUE
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`3.
`
`Alacritech incorporates by reference Paragraphs 5 through 8 of its Counterclaims
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`for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully herein.
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`FACTUAL BACKGROUND
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`4.
`
`Alacritech incorporates by reference Paragraphs 9 through 29 of its Counterclaims
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`for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully herein.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 7,124,205
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`5.
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`Alacritech
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`incorporates by reference Paragraphs 30
`
`through 43 of
`
`its
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`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
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`
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`6
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`INTEL EX.1112.002
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 7 of 18 PageID #: 4450
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`6.
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`Intel has additionally directly infringed and is currently directly infringing the
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`‘205 patent by making, using, selling, offering for sale, and/or importing into the United States,
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`without authority, products, methods, equipment, and/or services that practice one or more
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`claims of the ‘205 patent in connection with infringing RSC, InfiniBand, RoCE and/or RoCEv2
`
`functionality, including but not limited to the Intel Ethernet Converged Network Adapter X520-
`
`DA1, Intel QLE 7340 Host Channel Adapter, QLE 7342 Host Channel Adapter, QMX 7342
`
`Host Channel Adapter, FDR InfiniBand ConnectX-3 I/O Module (Single Port) (Product No.
`
`AXX1FDRIBIOM) with Mellanox Connect X-3 FDR/10GbE Controller, FDR InfiniBand
`
`ConnectX-3 I/O Module (Dual Port) (Product No. AXX2FDRIBIOM) with Mellanox Connect
`
`X-3 FDR/10GbE Controller, Single Port QDR InfiniBand I/O Expansion Module (Product No.
`
`AXXIBQDRIOMOD) based on the Mellanox InfiniHost MT25408, Single Port QDR Infiniband
`
`I/O Expansion Module (Product No. AXXIBQDRIOMV) based on the Mellanox InfiniHost
`
`MT25408, and I/O Expansion Module (Product No. AXXIBQDRSR169X) based on the
`
`Mellanox InfiniHost MT25408; any other activities, products and/or services involving the
`
`products identified above; and any other activities, products and/or services that practice and/or
`
`support similarly infringing RSC, InfiniBand, RoCE, and/or RoCEv2 functionality (incorporated,
`
`collectively, as additional products previously defined as “the ‘205 Accused Products” in
`
`Paragraph 33 of Alacritech’s Counterclaims for Patent Infringement filed on December 13, 2016
`
`(Dkt. 94)).
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`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 7,237,036
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`7.
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`Alacritech
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`incorporates by reference Paragraphs 44
`
`through 57 of
`
`its
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`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
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`
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`7
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`INTEL EX.1112.003
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 8 of 18 PageID #: 4451
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`8.
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`Intel has additionally directly infringed and is currently directly infringing the
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`‘036 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`without authority, products, methods, equipment, and/or services that practice one or more
`
`claims of the ‘036 patent in connection with infringing RSC functionality, including but not
`
`limited to the Intel Ethernet Converged Network Adapter X520-DA1; any other activities,
`
`products and/or services involving the products identified above; and any other activities,
`
`products and/or services that practice and/or support similarly infringing RSC functionality
`
`(incorporated, collectively, as additional products previously defined as “the ‘036 Accused
`
`Products” in Paragraph 47 of Alacritech’s Counterclaims for Patent Infringement filed on
`
`December 13, 2016 (Dkt. 94)).
`
`COUNT III
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`INFRINGEMENT OF U.S. PATENT NO. 7,337,241
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`9.
`
`Alacritech
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`incorporates by reference Paragraphs 58
`
`through 71 of
`
`its
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
`
`10.
`
`Intel has additionally directly infringed and is currently directly infringing the
`
`‘241 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`without authority, products, methods, equipment, and/or services that practice one or more
`
`claims of the ‘241 patent in connection with infringing RSC, LSO, RoCE and/or RoCEv2
`
`functionality, including but not limited to the Intel 82541PR Gigabit Ethernet Controller, Intel
`
`82572GI Gigabit Ethernet Controller, Intel 82576GB Gigabit Ethernet Controller, Intel 82580EK
`
`Gigabit Ethernet Controller, Ethernet Converged Network Adapter X520-DA1, FDR InfiniBand
`
`ConnectX-3 I/O Module (Single Port) (Product No. AXX1FDRIBIOM) with Mellanox Connect
`
`X-3 FDR/10GbE Controller, and FDR InfiniBand ConnectX-3 I/O Module (Dual Port) (Product
`
`
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`8
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`INTEL EX.1112.004
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 9 of 18 PageID #: 4452
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`
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`No. AXX2FDRIBIOM) with Mellanox Connect X-3 FDR/10GbE Controller; any other
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`activities, products and/or services involving the products identified above; and any other
`
`activities, products and/or services that practice and/or support similarly infringing RSC, LSO,
`
`RoCE, and/or RoCEv2 functionality (incorporated, collectively, as additional products
`
`previously defined as “the ‘241 Accused Products” in Paragraph 61 of Alacritech’s
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94)). The ‘241
`
`Accused Products are non-limiting examples that were identified based on publicly available
`
`information, and Alacritech reserves the right to identify additional infringing activities, products
`
`and services, including, for example, on the basis of information obtained during discovery.
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`COUNT IV
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`INFRINGEMENT OF U.S. PATENT NO. 7,673,072
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`11. Alacritech
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`incorporates by reference Paragraphs 72
`
`through 85 of
`
`its
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
`
`12.
`
`Intel has additionally directly infringed and is currently directly infringing the
`
`‘072 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`without authority, products, methods, equipment, and/or services that practice one or more
`
`claims of the ‘072 patent in connection with infringing LSO functionality, including but not
`
`limited to the Intel 82541PR Gigabit Ethernet Controller, Intel 82572GI Gigabit Ethernet
`
`Controller, Intel 82576GB Gigabit Ethernet Controller, Intel 82580EK Gigabit Ethernet
`
`Controller, and Intel Ethernet Converged Network Adapter X520-DA1; any other activities,
`
`products and/or services involving the products identified above; and any other activities,
`
`products and/or services that practice and/or support similarly infringing LSO functionality
`
`(incorporated, collectively, as additional products previously defined as “the ‘072 Accused
`
`
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`9
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`INTEL EX.1112.005
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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 10 of 18 PageID #: 4453
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`
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`Products” in Paragraph 75 of Alacritech’s Counterclaims for Patent Infringement filed on
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`December 13, 2016 (Dkt. 94)).
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`COUNT V
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`INFRINGEMENT OF U.S. PATENT NO. 8,131,880
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`13. Alacritech
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`incorporates by reference Paragraphs 86
`
`through 99 of
`
`its
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
`
`14.
`
`Intel has additionally directly infringed and is currently directly infringing the
`
`‘880 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`without authority, products, methods, equipment, and/or services that practice one or more
`
`claims of the ‘880 patent in connection with infringing RSC functionality, including but not
`
`limited to the Intel Ethernet Converged Network Adapter X520-DA1; any other activities,
`
`products and/or services involving the products identified above; and any other activities,
`
`products and/or services that practice and/or support similarly infringing RSC functionality
`
`(incorporated, collectively, as additional products previously defined as “the ‘880 Accused
`
`Products” in Paragraph 89 of Alacritech’s Counterclaims for Patent Infringement filed on
`
`December 13, 2016 (Dkt. 94)).
`
`COUNT VI
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`INFRINGEMENT OF U.S. PATENT NO. 8,805,948
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`15. Alacritech incorporates by reference Paragraphs 100 through 113 of its
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
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`16.
`
`Intel has additionally directly infringed and is currently directly infringing the
`
`‘948 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`
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`10
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`INTEL EX.1112.006
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 11 of 18 PageID #: 4454
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`
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`without authority, products, methods, equipment, and/or services that practice one or more
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`claims of the ‘948 patent in connection with infringing RSC functionality, including but not
`
`limited to the Intel Ethernet Converged Network Adapter X520-DA1; any other activities,
`
`products and/or services involving the products identified above; and any other activities,
`
`products and/or services that practice and/or support similarly infringing RSC functionality
`
`(incorporated, collectively, as additional products previously defined as “the ‘948 Accused
`
`Products” in Paragraph 103 of Alacritech’s Counterclaims for Patent Infringement filed on
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`December 13, 2016 (Dkt. 94)).
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`COUNT VII
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`INFRINGEMENT OF U.S. PATENT NO. 9,055,104
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`17. Alacritech incorporates by reference Paragraphs 114 through 127 of its
`
`Counterclaims for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully
`
`herein.
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`18.
`
`Intel has additionally directly infringed and is currently directly infringing the
`
`‘104 patent by making, using, selling, offering for sale, and/or importing into the United States,
`
`without authority, products, methods, equipment, and/or services that practice one or more
`
`claims of the ‘104 patent in connection with infringing LSO functionality, including but not
`
`limited to the Intel 82541PR Gigabit Ethernet Controller, Intel 82572GI Gigabit Ethernet
`
`Controller, Intel 82576GB Gigabit Ethernet Controller, Intel 82580EK Gigabit Ethernet
`
`Controller, and Intel Ethernet Converged Network Adapter X520-DA1; any other activities,
`
`products and/or services involving the products identified above; and any other activities,
`
`products and/or services that practice and/or support similarly infringing LSO functionality
`
`(incorporated, collectively, as additional products previously defined as “the ‘104 Accused
`
`
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`11
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`INTEL EX.1112.007
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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 12 of 18 PageID #: 4455
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`
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`Products” in Paragraph 117 of Alacritech’s Counterclaims for Patent Infringement filed on
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`December 13, 2016 (Dkt. 94)).
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`COUNT VIII
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`INFRINGEMENT OF U.S. PATENT NO. 7,945,699
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`19. Alacritech incorporates by reference Paragraphs 1 through 29 of its Counterclaims
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`for Patent Infringement filed on December 13, 2016 (Dkt. 94) as if set forth fully herein.
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`20. Alacritech is the current exclusive owner and assignee of all right, title, and
`
`interest in and to U.S. Patent No. 7,945,699 (the “‘699 patent”), titled “Obtaining a Destination
`
`Address so that a Network Interface Device Can Write Network Data without Headers Directly
`
`into Host Memory,” duly and legally issued by the United States Patent and Trademark Office on
`
`May 17, 2011, including the right to bring this suit for injunctive relief and damages. A true and
`
`correct copy of the ‘699 patent is attached hereto as Exhibit A.
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`21. The ‘699 patent is valid and enforceable.
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`22.
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`Intel has directly infringed and is currently directly infringing the ‘699 patent by
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`making, using, selling, offering for sale, and/or importing into the United States, without
`
`authority, products, methods, equipment, and/or services that practice one or more claims of the
`
`‘699 patent in connection with InfiniBand, RoCE and/or RoCEv2 functionality, including but not
`
`limited to the Intel QLE 7340 Host Channel Adapter, QLE 7342 Host Channel Adapter, QMX
`
`7342 Host Channel Adapter, FDR InfiniBand ConnectX-3 I/O Module (Single Port) (Product
`
`No. AXX1FDRIBIOM) with Mellanox Connect X-3 FDR/10GbE Controller, FDR InfiniBand
`
`ConnectX-3 I/O Module (Dual Port) (Product No. AXX2FDRIBIOM) with Mellanox Connect
`
`X-3 FDR/10GbE Controller, Single Port QDR InfiniBand I/O Expansion Module (Product No.
`
`AXXIBQDRIOMOD) based on the Mellanox InfiniHost MT25408, Single Port QDR Infiniband
`
`I/O Expansion Module (Product No. AXXIBQDRIOMV) based on the Mellanox InfiniHost
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`
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`12
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`INTEL EX.1112.008
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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 13 of 18 PageID #: 4456
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`
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`MT25408, and I/O Expansion Module (Product No. AXXIBQDRSR169X) based on the
`
`Mellanox InfiniHost MT25408; any other activities, products and/or services involving the
`
`products identified above; and any other activities, products and/or services that practice and/or
`
`support InfiniBand, RoCE and/or RoCEv2 functionality (collectively, “the ‘699 Accused
`
`Products”). The ‘699 Accused Products are non-limiting examples that were identified based on
`
`publicly available information, and Alacritech reserves the right to identify additional infringing
`
`activities, products and services, including, for example, on the basis of information obtained
`
`during discovery.
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`23. As just one non-limiting example, the ‘699 Accused products infringe claim 1 of
`
`the ‘699 patent for at least the reasons set forth in Exhibit B. This description is based on
`
`publicly available information. Alacritech reserves the right to modify this description,
`
`including, for example, on the basis of information about the ‘699 Accused Products that it
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`obtains during discovery.
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`24.
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`25.
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`Intel has also indirectly infringed and is indirectly infringing the ‘699 patent.
`
`Intel has actual knowledge of Alacritech’s rights in the ‘699 patent and details of
`
`Intel’s infringement of the ‘699 patent based on the filing and service of Alacritech’s complaint
`
`against Dell on June 30, 2016. Intel also acknowledges, in its Motion to Intervene, that it has
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`agreed to defend and partially indemnify Dell as to Alacritech’s claims. As such it has actual
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`knowledge of Alacritech’s rights in the ‘699 patent as of the date Dell approached Intel about
`
`indemnification. Finally, Intel at least has actual knowledge of Alacritech’s rights in the ‘699
`
`patent and details of Intel’s infringement of the ‘699 patent based on the filing and service of this
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`Answer and Counterclaim.
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`13
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`INTEL EX.1112.009
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`26.
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`Intel makes, uses, imports, offers for sale, and/or sells the ‘699 Accused Products
`
`(including, for example, the products described above) with knowledge of or willful blindness to
`
`the fact that its actions will induce Intel’s customers to infringe the ‘699 patent. Intel induces
`
`others to infringe the ‘699 patent in violation of 35 U.S.C. § 271 by encouraging and facilitating
`
`others to practice the ‘699 patent’s inventions for accelerated network communications with
`
`intent that those performing the acts infringe the ‘699 patent. For example, Intel sells ‘699
`
`Accused Products that perform infringing InfiniBand, RoCE and/or RoCEv2 functionality by
`
`default. When Intel’s customers use the ‘699 Accused Products for their intended purpose, they
`
`practice one or more claims of the ‘699 patent. Intel advertises and instructs its customers how
`
`to set up the ‘699 Accused Products. Once they have been set up, Intel’s customers infringe one
`
`or more claims of the ‘699 patent simply by using the ‘699 Accused Products. By selling its
`
`customers ‘699 Accused Products that that infringe by default when used for their intended
`
`purpose, and by setting up for its customers and/or instructing its customers how to set up and
`
`use those products, Intel induces those customers to infringe the ‘699 patent.
`
`27.
`
`Intel also contributes to the infringement of the ‘699 patent in violation of 35
`
`U.S.C. § 271. Intel knows that the ‘699 Accused Products or infringing components thereof are
`
`especially made or especially adapted for use in the infringement of the ‘699 patent. These
`
`infringing products or components are not staple articles or commodities of commerce suitable
`
`for substantial non-infringing use, and the infringing products or components are a material part
`
`of the invention of the ‘699 patent. The ‘699 Accused Products constitute or contain infringing
`
`components such as specialized hardware and/or software for performing infringing InfiniBand,
`
`RoCE and/or RoCEv2 functionality, which are material to practicing the ‘699 patent’s inventions
`
`for accelerated network communications, and have no substantial non-infringing use.
`
`
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`14
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`INTEL EX.1112.010
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`

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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 15 of 18 PageID #: 4458
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`Accordingly, Intel is also contributing to the direct infringement of the ‘699 patent by its
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`customers.
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`28.
`
`Intel is not licensed or otherwise authorized by Alacritech to practice,
`
`contributorily practice and/or induce third parties to practice the claims of the ‘699 patent.
`
`29. By reason of Intel’s infringing activities, Alacritech has suffered, and will
`
`continue to suffer, substantial damages in an amount to be proven at trial. Alacritech is entitled
`
`to a money judgment in an amount adequate to compensate for Intel’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Intel, together with
`
`interest and costs as fixed by the Court.
`
`30.
`
`Intel’s continuing acts of infringement have caused and will continue to cause
`
`Alacritech irreparable harm, for which Alacritech has no adequate remedy at law, unless Intel’s
`
`continuing acts of infringement are enjoined by the Court. The hardships that an injunction
`
`would impose are less than those faced by Alacritech should an injunction not issue. The public
`
`interest would be served by issuance of an injunction.
`
`31.
`
`Intel’s infringement of the ‘699 patent has been and continues to be willful and
`
`deliberate, justifying a trebling of damages under 35 U.S.C. § 284.
`
`32.
`
`Intel’s infringement of the ‘699 patent is exceptional and entitles Alacritech to
`
`attorneys’ fees and costs incurred in prosecuting this action under 35 U.S.C. § 285.
`
`PRAYER FOR RELIEF
`
`Alacritech respectfully requests the following relief from this Court:
`
`A.
`
`A judgment that Intel has infringed each and every one of the Asserted Patents;
`
`B.
`
`A preliminary and permanent injunction against Intel, its respective officers,
`
`agents, servants, employees, attorneys, parent and subsidiary corporations, assigns and
`
`successors in interest, and those persons in active concert or participation with them, enjoining
`
`
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`15
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`INTEL EX.1112.011
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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 16 of 18 PageID #: 4459
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`
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`them from infringement, inducement of infringement, and contributory infringement of each and
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`every one of the Asserted Patents, including but not limited to an injunction against making,
`
`using, selling, and/or offering for sale within the United States, and/or importing into the United
`
`States, any products and/or services that infringe the Asserted Patents;
`
`C.
`
`Damages adequate to compensate Alacritech for Intel’s infringement of the
`
`Asserted Patents pursuant to 35 U.S.C. § 284;
`
`D.
`
`Prejudgment interest;
`
`E.
`
`F.
`
`Post-judgment interest;
`
`A judgment and order holding Intel’s infringement each and every one of the
`
`Asserted Patents ‘to be willful, and a trebling of damages pursuant to 35 U.S.C. § 284;
`
`G.
`
`A judgment and order finding that this is an exceptional case within the meaning
`
`of 35 U.S.C. § 285, and an award to Alacritech of its attorneys’ fees, costs and expenses incurred
`
`in connection with this Action; and
`
`H.
`
`Such other relief as the Court deems just and equitable.
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Alacritech demands a trial
`
`by jury on all matters and issues triable by jury.
`
`
`Dated: February 23, 2017
`
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`
`/s/ Claude M. Stern with permission Joseph M.
`Paunovich
`
`Claude M. Stern
`California State Bar No. 96737
`claudestern@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`555 Twin Dolphin Drive, 5th Floor
`
`
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`16
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`INTEL EX.1112.012
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`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 17 of 18 PageID #: 4460
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`Redwood Shores, CA 94065
`Telephone: (650) 801-5000
`Facsimile: (650) 801-5100
`
`Joseph M. Paunovich
`joepaunovich@quinnemanuel.com
`California State Bar No. 228222
`Jordan Brock Kaericher
`California State Bar No. 265953
`jordankaericher@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017
`Telephone: (213) 443-3000
`Facsimile: (213) 443-3100
`
`T. John Ward, Jr.
`Texas State Bar No. 00794818
`jw@wsfirm.com
`Claire Abernathy Henry
`Texas State Bar No. 24053063
`claire@wsfirm.com
`WARD & SMITH LAW FIRM
`1507 Bill Owens Parkway
`Longview, Texas 75604
`Telephone: (903) 757-6400
`Facsimile: (903) 757-2323
`
`
`ATTORNEYS FOR PLAINTIFF
`ALACRITECH, INC.
`
`17
`
`INTEL EX.1112.013
`
`

`

`Case 2:16-cv-00693-JRG-RSP Document 136 Filed 02/23/17 Page 18 of 18 PageID #: 4461
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a). As such, this document was served on all counsel who
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`have consented to electronic service on this 23rd day of February, 2017. Local Rule CV-
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`5(a)(3)(A).
`
`/s/ Joseph M. Paunovich
`Joseph M. Paunovich
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`
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`
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`18
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`INTEL EX.1112.014
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`