Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 1 of 17 PageID #: 5350
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`UNILOC 2017 LLC,
`
`Plaintiff
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`Civil Action No. 2:18-cv-551-JRG
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`
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`JURY TRIAL DEMANDED
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`DEFENDANT GOOGLE LLC’S RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`Page 1 of 17
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`GOOGLE EXHIBIT 1012
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 2 of 17 PageID #: 5351
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`TABLE OF CONTENTS
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`Page
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`I.
`II.
`III.
`IV.
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`V.
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`INTRODUCTION ............................................................................................................. 1
`LAW OF CLAIM CONSTRUCTION AND INDEFINITENESS .................................... 1
`BACKGROUND OF THE TECHNOLOGY .................................................................... 1
`DISPUTED CLAIM TERMS ............................................................................................ 3
`A.
`Claim 1 Is Invalid for Indefiniteness ..................................................................... 3
`1.
`“wherein the recursive filtering step is intended to use a recursive
`filter such as: Rf[i]=(1— .alpha.[i]) (R1[i]+Rmc[i]), where Rf[i],
`R1[i] and Rmc[i] are transformed coefficients comprised in the
`transformed signals (Rf,R1,Rmc) and .alpha.[i] is a filter
`coefficient comprised between 0 and 1” .................................................... 3
`Google Has Not Waived Its Indefiniteness Argument .............................. 6
`2.
`“transformed coefficients” (claim 1) “transformed signal[s]” (claims 1, 4) .......... 7
`B.
`“transformed motion-compensated signal” (claims 1, 4) .................................... 10
`C.
`CONCLUSION ................................................................................................................ 10
`
`i
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 3 of 17 PageID #: 5352
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`TABLE OF AUTHORITIES
`
`
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`Page(s)
`
`Cases
`
`Callicrate v. Wadsworth Mfg., Inc.,
`427 F.3d 1361 (Fed. Cir. 2005)..................................................................................................4
`
`Centricut, LLC v. Esab Group, Inc.,
`390 F.3d 1361 (Fed. Cir. 2004)..................................................................................................7
`
`Elcommerce.com, Inc. v. SAP AG,
`564 F. App’x 599 (Fed. Cir. 2014) ............................................................................................7
`
`Elcommerce.com, Inc. v. SAP AG,
`745 F.3d 490 (Fed. Cir. 2014)....................................................................................................7
`
`Ex Parte Hall,
`83 U.S.P.Q. 38 (Bd. App. 1949) ................................................................................................4
`
`Harcol Research, LLC v. Europea Sports Prods., Inc.,
`No. 2:13-cv-228-JRG-RSP, 2014 WL 5603653 (E.D. Tex. Nov. 3, 2014) ...............................6
`
`Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc.,
`381 F.3d 1111 (Fed. Cir. 2004)..................................................................................................6
`
`Innovative Display Techs. LLC v. Hyundai Motor Co.,
`No. 2:14-cv-201-JRG, 2015 WL 2090651 (E.D. Tex. May 4, 2015) ........................................6
`
`Mobile Telecommc’ns Techs., LLC v. Sprint Nextel Corp.,
`No. 2:12-CV-832-JRG-RSP, 2014 WL 10726788 (E.D. Tex. May 2, 2014) ............................7
`
`Nautilus, Inc. v. Biosig Instruments, Inc.,
`572 U.S. 898 (2014) ...............................................................................................................1, 6
`
`Schumer v. Lab. Comput. Sys., Inc.,
`308 F.3d 1304 (Fed. Cir. 2002)..................................................................................................7
`
`Sonix Tech. Co. v. Publ’ns Int’l, Ltd.,
`844 F.3d 1370 (Fed. Cir. 2017)..................................................................................................7
`
`Teva Pharm. USA, Inc. v. Sandoz, Inc.,
`789 F.3d 1335 (Fed. Cir. 2015)..................................................................................................6
`
`Statutes
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`35 U.S.C. § 112 ¶ 2 ......................................................................................................................1, 4
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`35 U.S.C. § 112 ¶ 6 ..........................................................................................................................7
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`ii
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 4 of 17 PageID #: 5353
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`TABLE OF AUTHORITIES
`(continued)
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`Other Authorities
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`MPEP § 2173.05(d) .........................................................................................................................4
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`Page(s)
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`iii
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 5 of 17 PageID #: 5354
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`I.
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`INTRODUCTION
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`Plaintiff Uniloc 2017 LLC (“Plaintiff” or “Uniloc”) alleges that Defendant Google LLC
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`(“Defendant” or “Google”) infringes claims 1, 4, and 5 of U.S. Patent No. 7,012,960 (“the ’960
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`Patent”). Claim 1 fails to satisfy the definiteness requirements of 35 U.S.C. § 112 ¶ 2. It includes
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`a facially ambiguous limitation containing the phrases “intended to” and “such as.” The
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`uncertain language of that limitation results in the absence of reasonable certainty regarding the
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`scope of the invention. This renders claim 1 invalid for indefiniteness.
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`Claims 1 and 4 include multiple terms requiring construction: “transformed coefficients,”
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`“transformed signal[s],” and “transformed motion-compensated signal.” The plain and ordinary
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`meaning of those terms, when read in light of the surrounding claim language and specification,
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`encompasses video data that has been discrete cosine transformed and inverse quantized. Those
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`terms must be construed accordingly.
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`II.
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`LAW OF CLAIM CONSTRUCTION AND INDEFINITENESS
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`In view of the Court’s familiarity with the applicable law for claim construction,
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`Defendant cites pertinent cases in the context of disputed issues. Patent claims must point out
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`and distinctly claim the subject matter that the applicant regards as the invention. 35 U.S.C.
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`§ 112 ¶ 2. A patent is invalid for indefiniteness “if its claims, read in light of the specification
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`delineating the patent, and the prosecution history, fail to inform, with reasonable certainty, those
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`skilled in the art about the scope of the invention.” Nautilus, Inc. v. Biosig Instruments, Inc., 572
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`U.S. 898, 901 (2014). The definiteness requirement “mandates clarity.” Id. at 910. Patent claims
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`“must be precise enough to afford clear notice of what is claimed.” Id. at 909.
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`III. BACKGROUND OF THE TECHNOLOGY
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`The ’960 Patent is directed to transcoding a video stream from a higher bitrate to a lower
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`bitrate with a filtering step to improve picture quality. ’960 Patent at Abstract, 1:24–29. The ’960
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`1
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`Patent claims that it differs from the prior art (as shown in Figure 1) by the inclusion of the
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`filtering step. Id. at 1:64–67 (“[T]he transcoding method in accordance with the invention is
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`characterized in that it further comprises a filtering step between the dequantizing sub-step and
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`the quantizing sub-step.”). Figure 2, which depicts a transcoding device in accordance with the
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`invention, includes the allegedly distinguishing filter:
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`Id. at Figure 2 (emphasis added). Asserted independent claim 1 includes a recursive temporal
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`filter, id. at 9:39, while asserted independent claim 4 includes a spatial filter. Id. at 10:14.
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`2
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 7 of 17 PageID #: 5356
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`IV. DISPUTED CLAIM TERMS
`A.
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`Claim 1 Is Invalid for Indefiniteness
`1.
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`“wherein the recursive filtering step is intended to use a recursive
`filter such as: Rf[i]=(1— .alpha.[i]) (R1[i]+Rmc[i]), where Rf[i], R1[i]
`and Rmc[i] are transformed coefficients comprised in the transformed
`signals (Rf,R1,Rmc) and .alpha.[i] is a filter coefficient comprised
`between 0 and 1”
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`The phrases “intended to” and “such as” in the “wherein the recursive filtering step . . .”
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`limitation render claim 1 invalid for indefiniteness.1 These phrases are ambiguous and thereby
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`fail to afford clear notice of what is claimed. Claim 1 requires that the “filtering step” use a
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`“recursive filter,” ’960 Patent at 9:39, but it fails to clarify whether the recursive filter used must
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`be the specific example recited in the claim (i.e., “Rf[i]=(1— .alpha.[i]) (R1[i]+Rmc[i]), where
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`Rf[i], R1[i] and Rmc[i] are transformed coefficients comprised in the transformed signals
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`(Rf,R1,Rmc) and .alpha.[i] is a filter coefficient comprised between 0 and 1”) and, if not, what
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`other recursive filters would be encompassed by claim 1.
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`Claim 1 includes at least two levels of ambiguity. It delineates “a recursive filter such
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`as: . . .” and then precedes that phrase with “is intended to use.” The former leaves unclear the
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`scope of the recursive filter. Only one filter is provided following “such as.” See ’960 Patent at
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`9:41–45. One possible interpretation is that claim 1 only encompasses that single enumerated
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`filter. Another possible interpretation, at the other end of the spectrum, is that “such as”
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`encompasses all recursive filters. But that interpretation would render the “wherein the recursive
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`filtering step . . .” limitation superfluous because the previous limitation already requires “said
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`1 In an effort to limit the terms in dispute, Google hereby withdraws its separate indefiniteness
`arguments for the terms “comprised in the transformed signals (Rf,R1,Rmc)” and “predicting a
`transformed motion-compensated signal from a transformed encoding error derived from the
`encoding step, said prediction step being situated between the encoding and decoding steps.” The
`former term is a component of the broader claim 1 limitation that is indefinite for the reasons
`explained in this section.
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`3
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`filtering step using a recursive filter.” Id. at 9:39. Constructions that read out claim language are
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`generally disfavored. See, e.g., Callicrate v. Wadsworth Mfg., Inc., 427 F.3d 1361, 1369 (Fed.
`
`Cir. 2005). Moreover, the applicant specifically amended claim 1 during prosecution to add this
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`limitation and thereby overcome the examiner’s rejection. Ex. A at 2, 9. It follows that “such as”
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`provides some restriction on which recursive filters are encompassed by claim 1.
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`Between the first interpretation of “such as” encompassing only the single enumerated
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`filter and the rejected second interpretation of “such as” encompassing all recursive filters lies a
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`third interpretation of “such as” encompassing a subset of recursive filters with some level of
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`relationship to the enumerated filter. This third interpretation treats the enumerated filter as an
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`example that other filters must resemble to fall within claim 1’s scope. But the claim language
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`provides no guidance regarding the scope of “such as.” It gives no indication as to which
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`recursive filters it encompasses. Such exemplary claim language that leaves unclear the intended
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`scope of the claim should be held indefinite. Ex Parte Hall, 83 U.S.P.Q. 38 (Bd. App. 1949)
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`(sustaining indefiniteness rejection of claims including the term “such as”); see also MPEP
`
`§ 2173.05(d) (“If stated in the claims, examples and preferences may lead to confusion over the
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`intended scope of a claim. In those instances where it is not clear whether the claimed narrower
`
`range is a limitation, a rejection under [35 U.S.C. § 112 ¶ 2] should be made.”). Accordingly,
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`even if the ambiguity could be resolved between the applicability of the first and third
`
`interpretations of the “such as” clause, claim 1 must be held indefinite under the third
`
`interpretation because it leaves unanswered the manner and level of similarity other recursive
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`filters must have to the enumerated filter.
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`The specification similarly fails to provide any standard for determining which recursive
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`filters are sufficiently akin to the enumerated filter to read on claim 1. The filter from claim 1
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`4
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`appears as Equation 10 in the specification. ’960 Patent at 5:47. The specification states that this
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`is “an advantageous variant of the invention” in which “the strength of the motion-compensated
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`recursive temporal filter is adjusted separately for each transformed coefficient.” Id. at 5:41–43.
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`The term “such as” appears in this portion of the specification, just as it does in claim 1. Id. at
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`5:44–47 (“The transformed coefficient of rank i is multiplied by W[i]=1-α[i] such as: [Equation
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`10]” (emphasis added)). However, this use of “such as” in the specification does not clarify the
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`meaning of that phrase. Just like in claim 1, it precedes a single equation with no further
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`explanation regarding other equations (if any) that might fit within its scope. Because neither the
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`claim language nor the specification provide a standard for determining the scope denoted by
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`“such as,” that term renders claim 1 invalid for indefiniteness. 2
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`Claim 1’s inclusion of the phrase “intended to” before “use a recursive filter such as”
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`compounds the ambiguity and uncertainty. Claim 1 leaves unclear whether “intended to” means
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`that use of the specified filter (or similar filters) is optional or required. In light of the two levels
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`of ambiguity, there are at least four inconsistent, equally plausible interpretations of the “wherein
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`the recursive filtering step is intended to use a recursive filter such as” limitation of claim 1: (1)
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`the recursive filter is optionally equivalent to the identified filter; (2) the recursive filter is
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`optionally similar in some manner and level of degree to the identified filter; (3) the recursive
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`filter must be equivalent to the identified filter; and (4) the recursive filter must be similar in
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`some manner and level of degree to the intended filter. Because a person of ordinary skill in the
`
`art would be left to choose among at least these four interpretations, claim 1 fails to inform those
`
`
`2 Because of the absence of any guidance regarding the scope of “such as,” the only possible
`interpretation that could avoid indefiniteness is to read that phrase as requiring the lone
`enumerated equation. This would mean that claim 1 could not be satisfied by any recursive filter
`other than the enumerated filter. However, the presence of “intended to” still renders claim 1
`indefinite, regardless of how “such as” is construed.
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`5
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`skilled in the art about the scope of the claimed invention with reasonable certainty. It is
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`therefore invalid for indefiniteness. See, e.g., Innovative Display Techs. LLC v. Hyundai Motor
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`Co., No. 2:14-cv-201-JRG, 2015 WL 2090651, at *22–23 (E.D. Tex. May 4, 2015) (holding a
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`claim
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`indefinite where
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`it had multiple “equally plausible but materially dissimilar”
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`interpretations); Harcol Research, LLC v. Europea Sports Prods., Inc., No. 2:13-cv-228-JRG-
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`RSP, 2014 WL 5603653, at *7 (E.D. Tex. Nov. 3, 2014) (same).
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`2.
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`Google Has Not Waived Its Indefiniteness Argument
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`The only argument raised in Uniloc’s opening brief with respect to indefiniteness is that
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`Google has failed to meet its burden of proof because of the absence of expert testimony.
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`Opening Br. at 7–8. Not so. No blanket requirement exists that necessitates expert testimony to
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`prove indefiniteness. See Teva Pharm. USA, Inc. v. Sandoz, Inc., 789 F.3d 1335, 1342 (Fed. Cir.
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`2015) (“The internal coherence and context assessment of the patent, and whether it conveys
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`claim meaning with reasonable certainty, are questions of law.”). None of the cases cited by
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`Uniloc mandate expert testimony to support any and all indefiniteness arguments. Uniloc first
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`cites to the statement from Nautilus that “[d]efiniteness is measured from the viewpoint of a
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`person skilled in [the] art at the time the patent was filed,” but that same standard applies to all
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`claim construction issues. See Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381
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`F.3d 1111, 1116 (Fed. Cir. 2004) (“A court construing a patent claim seeks to accord a claim the
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`meaning it would have to a person of ordinary skill in the art at the time of the invention.”).
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`Uniloc cannot contend that all claim construction positions require expert support, otherwise its
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`own claim construction briefing in this case and related cases, where it has offered no expert
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`testimony to support any of its claim construction positions, would be deficient. See, e.g., Case
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`No. 2:18-cv-00492-JRG-RSP, Dkt. No. 139 at 2 (arguing for a particular construction of a
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`disputed term without any supporting expert testimony).
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`6
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 11 of 17 PageID #: 5360
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`Uniloc next points to two cases addressing the adequacy of a specification’s disclosure of
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`corresponding structure for means-plus-function terms governed by 35 U.S.C. § 112 ¶ 6. See
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`Elcommerce.com, Inc. v. SAP AG, 745 F.3d 490, 505–06 (Fed. Cir. 2014)3; Mobile
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`Telecommc’ns Techs., LLC v. Sprint Nextel Corp., No. 2:12-CV-832-JRG-RSP, 2014 WL
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`10726788, at *28–29 (E.D. Tex. May 2, 2014). Those cases involved an entirely different
`
`situation than the term at issue here, which is not a means-plus-function term. The Federal
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`Circuit specifically noted in Elcommerce.com that “[w]e do not of course hold that expert
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`testimony will always be needed for every situation.” 745 F.3d at 506.
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`The remaining cases cited by Uniloc are similarly inapplicable. Centricut, LLC v. Esab
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`Group, Inc., 390 F.3d 1361, 1369 (Fed. Cir. 2004), dealt with a plaintiff’s burden to prove
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`infringement, while Schumer v. Laboratory Computer Systems, Inc., 308 F.3d 1304, 1315 (Fed.
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`Cir. 2002), involved the burden of proof for anticipation. Neither case compares to the situation
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`here where claims 1 contains a facially ambiguous limitation. Finally, the requirement that
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`indefiniteness be proven by clear and convincing evidence does not mandate that it be proven by
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`expert testimony. See Sonix Tech. Co. v. Publ’ns Int’l, Ltd., 844 F.3d 1370, 1377 (Fed. Cir.
`
`2017). The Federal Circuit noted in Sonix that “the internal coherence and context assessment”
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`of a patent is a question of law that cannot be converted into a question of fact based on expert
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`testimony. Id. at 1376. Because applicable case law does not require expert testimony to prove
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`indefiniteness, Uniloc’s waiver argument with respect to indefiniteness lacks any merit.
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`B.
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`“transformed coefficients” (claim 1)
`“transformed signal[s]” (claims 1, 4)
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`The terms “transformed coefficients” and “transformed signal[s]” are properly construed
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`as “data concerning video that has been discrete cosine transformed and inverse quantized.” This
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`3 The Federal Circuit’s decision in Elcommerce.com has since been vacated. Elcommerce.com,
`Inc. v. SAP AG, 564 F. App’x 599, 600 (Fed. Cir. 2014).
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`7
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`construction reflects the plain and ordinary meaning of these terms as used in the asserted claims
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`and specification. In the video encoding context applicable to the ’960 Patent, the word
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`“coefficients” reflects data resulting from a discrete cosine transform, which transforms picture
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`pixels into coefficients. Ex. B at 25–27. The term “transformed coefficients” therefore denotes
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`video data that has been discrete cosine transformed. That definition equally applies to the term
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`“transformed signals” based on its usage in claim 1. The only coherent interpretation is that
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`“transformed signals” include sets of “transformed coefficients” at multiple index locations, as
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`denoted by the “[i]” following “Rf,” “R1,” and “Rmc.” See ’960 Patent at 9:42–44. Accordingly,
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`“transformed signals” is just a superset of “transformed coefficients.” The same construction,
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`“data concerning video” that has been discrete cosine transformed, is therefore equally
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`appropriate for both. The claim language further makes clear that such data results from inverse
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`quantization. See ’960 Patent at 9:32–33 (claiming a “dequantizing sub-step (12) for producing a
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`first transformed signal (R1)”), 10:2–3 (same). The correct construction therefore also
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`incorporates this inverse quantization (or “dequantization”) requirement.
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`Uniloc’s only dispute with Google’s proposed construction concerns the requirement that
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`the data has been discrete cosine transformed. See Opening Br. at 8–9. Uniloc contends that the
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`“transcoder 200” in Figure 2 does not use a discrete cosine transform step to generate the
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`“transformed signal[s].” Id. But Uniloc misapprehends Google’s proposed construction.
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`Google’s construction does not require that the discrete cosine transformation occur during the
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`transcoding process. Instead, the discrete cosine transformation has already occurred before the
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`initiation of the transcoding process. The “Background of the Invention” explains that “[b]itrate
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`transcoding is a technique which allows a primary video stream encoded at a bitrate BR1 to be
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`converted into a secondary video stream encoded at a bitrate BR2, lower than BR1.” ’960 Patent
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`8
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`at 1:24–27 (emphasis added). Because transcoding involves a video stream that has already been
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`encoded, the video data has already passed through the standard encoding steps: motion
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`estimation, discrete cosine transform, quantization, and variable-length coding. See Ex. B at 25–
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`30. The preambles of claims 1 and 4 both state that they involve “[a] method of transcoding a
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`primary encoded signal,” thus requiring that the original video signal already be encoded before
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`the transcoding method can occur. ’960 Patent at 9:27, 9:64 (emphasis added). This means that
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`the video signal entering the transcoding method has already been discrete cosine transformed.
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`When the “primary encoded signal” is inverse quantized (or “dequantiz[ed]”) in claims 1 and 4,
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`id. at 9:32–33, 10:2–3, the resulting “first transformed signal” consists of discrete cosine
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`transform coefficients because the inverse quantization does not reverse the discrete cosine
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`transformation that occurred during the initial encoding.
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`Figure 2 and the corresponding portions of the specification further support the
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`construction of “transformed signal[s]” as having been discrete cosine transformed and inverse
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`quantized. Consistent with the preambles of claims 1 and 4, the “primary encoded signal (S1)”
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`enters the transcoding device in Figure 2. Id. at Fig. 2, 5:20. That encoded signal is then variable-
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`length decoded and inverse quantized in the “VLD” and “IQ” blocks, respectively. Id. at 5:18–
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`20. This effectively reverses the final two encoding steps of quantization and variable-length
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`coding, leaving discrete cosine transformed coefficients as the outputted “first transformed signal
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`(R1).” Id. at Fig. 2, 5:21. Because the discrete cosine transformation has not been reversed, the
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`“first transformed signal (R1)” contains video data that has been discrete cosine transformed and
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`inverse quantized, consistent with Google’s proposed construction.
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`The same holds true for the other two “transformed signals” of claims 1 and 4: the
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`“filtered transformed signal” and the “transformed motion-compensated signal.” Id. at 9:43,
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`9
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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 14 of 17 PageID #: 5363
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`9:46, 9:50–52, 10:10, 10:15–17. The “filtered transformed signal (Rf)” in Figure 2 represents the
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`filtered sum of the “first transformed signal” and the “transformed motion-compensated signal.”
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`Id. at Fig. 2, 5:35–40. Because the “filtered transformed signal” appears immediately before the
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`“quantizer Q,” it represents video data about to be quantized that has already been discrete cosine
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`transformed. Id. at Figure 2, 5:38–40. The “transformed motion-compensated signal (Rmc)” in
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`Figure 2 represents the output of the prediction channel. Id. at Figure 2, 5:33–34. Just like the
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`“first transformed signal” and “filtered transformed signal,” the “transformed motion-
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`compensated signal” has been discrete cosine transformed (at box 19) but not quantized. Id. The
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`claim language and specification consistently use “transformed coefficients” and “transformed
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`signal[s]” to refer to video data that has been discrete cosine transformed and inverse quantized.
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`C.
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`“transformed motion-compensated signal” (claims 1, 4)
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`The term “transformed motion-compensated signal” should be construed consistent with
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`its plain and ordinary meaning as “motion-compensated data that has been discrete cosine
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`transformed and inverse quantized.” This aligns with the preceding section’s construction of
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`“transformed signal[s].” The only change reflects the “motion-compensated” phrase added to the
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`present term. Claims 1 and 4 require that the “transformed motion-compensated signal” result
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`from a “prediction step.” ’960 Patent at 9:46–49, 10:10–13. Figure 2 and the corresponding
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`portions of the specification explain that the “prediction step” (or “channel”) involves motion
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`compensation. ’960 Patent at Figure 2, 5:26–34. Uniloc does not dispute the evidence from the
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`claims and specification regarding the “transformed motion-compensated signal” consisting of
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`data that has been motion compensated.
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`V.
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`CONCLUSION
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`Google respectfully requests that the Court find claim 1 of the ’960 Patent invalid for
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`indefiniteness. Claim 1 contains a facially ambiguous limitation that fails to provide reasonable
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`10
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`certainty regarding the scope of the claimed invention. Google further respectfully requests that
`
`the Court construe the other disputed claim terms consistent with their plain and ordinary
`
`meaning as follows:
`
`Term(s)
`“transformed coefficients” (claim 1)
`“transformed signal[s]” (claims 1, 4)
`“transformed motion-compensated
`signal” (claims 1, 4)
`
`Construction
`“data concerning video that has been discrete cosine
`transformed and inverse quantized”
`
`“motion-compensated data that has been discrete
`cosine transformed and inverse quantized”
`
`11
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`Page 15 of 17
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`

`

`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 16 of 17 PageID #: 5365
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`
`DATED: January 23, 2020
`
`
`
`
`Respectfully submitted,
`
`By: /s/ Robert Unikel
`Robert Unikel
`robertunikel@paulhastings.com
`Michelle Marek Figueiredo (IL Bar #6297112)
`michellemarek@paulhastings.com
`Matthew Richard Lind (IL Bar #6327241)
`mattlind@paulhastings.com
`John A. Cotiguala (IL Bar #6311056)
`johncotiguala@paulhastings.com
`PAUL HASTINGS LLP
`71 South Wacker Dr., 45th Floor
`Chicago, IL 60606
`Telephone: (312) 499-6000
`Facsimile: (312) 499-6100
`
`Elizabeth L. Brann (CA Bar #222873)
`elizabethbrann@paulhastings.com
`Ariell Nicole Bratton (CA Bar #317587)
`ariellbratton@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`
`Robert Laurenzi (NY Bar #3024676)
`robertlaurenzi@paulhastings.com
`PAUL HASTINGS LLP
`200 Park Avenue, 26th Floor
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 318-6100
`
`Michael E. Jones
`State Bar No. 10929400
`mikejones@potterminton.com
`E. Glenn Thames, Jr.
`State Bar No.00785097
`glennthames@potterminton.com
`Patrick C. Clutter
`State Bar No. 24036374
`patrickclutter@potterminton.com
`POTTER MINTON, P.C.
`110 N. College Ave., Suite 500
`Tyler, Texas 75702
`
`12
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`Page 16 of 17
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`

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`Case 2:18-cv-00551-JRG Document 130 Filed 01/23/20 Page 17 of 17 PageID #: 5366
`
`
`Telephone: (903) 597-8311
`Facsimile: (903) 593-0846
`
`Attorneys for Defendant Google LLC
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing document was filed
`
`
`
`
`
`
`
`electronically in compliance with Local Rule CV-5 on this 23rd day of January, 2020. As of this
`
`date, all counsel of record had consented to electronic service and are being served with a copy
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`of this document through the Court’s CM/ECF system under Local Rule CV-5(a)(3)(A).
`
` /s/ Robert Unikel
`Robert Unikel
`
`
`
`13
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`Page 17 of 17
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