Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 1 of 17 Page ID #:1
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`
`
`Douglas G. Muehlhauser (SBN 179495)
`doug.muehlhauser@knobbe.com
`Payson LeMeilleur (SBN 205690)
`payson.lemeilleur@knobbe.com
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, Fourteenth Floor
`Irvine, CA 92614
`Telephone: 949-760-0404
`Facsimile: 949-760-9502
`
`Attorneys for Plaintiff
`ONE-E-WAY, INC.
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`
`ONE-E-WAY, INC., a California
`corporation,
`
`Plaintiff,
`
`v.
`APPLE INC., a California corporation,
`Defendant.
`
` Case No. 2:20-CV-06339
`COMPLAINT FOR PATENT
`INFRINGMENT
`
`DEMAND FOR JURY TRIAL
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`Petitioner's Exhibit 1022
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 2 of 17 Page ID #:2
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`Plaintiff One-E-Way, Inc. (“One-E-Way”) hereby complains of Defendant
`Apple Inc. (“Apple”), including infringement of One-E-Way’s rights in U.S. Patent
`Nos. 8,131,391 and 10,468,047 (collectively, the “Asserted Patents”), and alleges as
`follows:
`
`I. THE PARTIES
`1.
`Plaintiff One-E-Way is a California corporation that, as of the date of
`this Complaint, has its principal place of business at 3016 E. Colorado Blvd.,
`#70848, Pasadena, California 91107.
`2.
`Upon information and belief, Defendant Apple is a California
`corporation having a principal place of business at One Apple Park Way, Cupertino,
`California, 95014.
`
`II. JURISDICTION AND VENUE
`This Court has subject-matter jurisdiction under 28 U.S.C. §§ 1331 and
`
`3.
`1338(a).
`4.
`This civil action includes claims for patent infringement arising under
`the patent laws of the United States, 35 U.S.C. § 100 et seq., and, more particularly,
`35 U.S.C. §§ 271 and 281.
`5.
`Defendant Apple is subject to personal jurisdiction in this Judicial
`District.
`6.
`Defendant Apple conducts business throughout the United States,
`including in this Judicial District, and operates Apple Stores in this Judicial District.
`7.
`For example, through its websites and Apple Stores in this Judicial
`District, Defendant Apple has advertised, offered to sell, sold, and/or distributed
`infringing products, and/or induced and/or contributed to the sale and use of
`infringing products in the United States, including in this Judicial District.
`Defendant Apple has, directly or through its distribution network, purposefully
`placed infringing products into the stream of commerce knowing and expecting them
`to be purchased and used by consumers in the United States, including in this Judicial
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 3 of 17 Page ID #:3
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`District, and such infringing products actually have been purchased and used in the
`United States and in this Judicial District.
`8.
`Venue is proper in the Central District of California pursuant to 28
`U.S.C. § 1391 and 28 U.S.C. § 1400(b).
`9.
`One-E-Way resides in this Juridical District.
`10. Defendant Apple has regular and established places of business in this
`Judicial District, including its operation of Apple Stores throughout this Judicial
`District.
`11. Defendant Apple has committed acts of infringement within this
`Judicial District.
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`III. STATEMENT OF THE CASE
`12. This action seeks relief for the infringement of One-E-Way’s patents
`by Defendant Apple.
`
`IV. STATEMENT OF FACTS
`13. One-E-Way is a minority-owned small business founded in Pasadena,
`California, by C. Earl Woolfork, the named inventor on the patents asserted herein.
`Mr. Woolfork obtained his electrical engineering degree from the University of
`Southern California in Los Angeles.
`14. Mr. Woolfork first conceived of the wireless audio inventions at issue
`in the late 1990s while exercising outdoors at the popular Santa Monica Steps in Los
`Angeles. Mr. Woolfork noticed that many people were having trouble with the wires
`connecting their audio players to their headsets, which interrupted their exercise
`routines. Mr. Woolfork set out to create a solution that allowed people to exercise
`free of wires, while still enjoying high quality music. Mr. Woolfork conceived of
`an audio system that could wirelessly communicate high quality audio data. Mr.
`Woolfork filed a patent application to protect his high quality wireless audio
`inventions, and later founded One-E-Way to commercialize those inventions.
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 4 of 17 Page ID #:4
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`Today, One-E-Way sells its patented wireless audio products through at least its
`online retail outlet, available at https://shop.wayvz.com/.
`15. Mr. Woolfork obtained and assigned to One-E-Way the Asserted
`Patents. The inventions address several problems, including reducing interference
`so that each wireless user can enjoy high quality private listening, even in the
`proximity of other such wireless users. The common specification of the Asserted
`Patents explains the use of code division multiple access technology (CDMA) with
`unique coding to provide private listening despite other wireless audio systems
`operating nearby in the same frequency band. The patented inventions address
`interference from other device transmissions in the wireless audio spectrum by
`using, for example, differential phase shift keying and processing for reduction of
`intersymbol interference. Techniques in the patented inventions for achieving
`private listening and for addressing interference are, among other techniques and for
`example, used by devices compliant with the Bluetooth wireless communication
`standard, from version 2.0 and all subsequent versions up through and including the
`current version, version 5.2.
`16.
`In August 2014, Apple received written notice from One-E-Way
`regarding One-E-Way’s U.S. Patent Nos. 7,865,258 and 8,131,391 (respectively, the
`“’258 and ’391 patents”), as well as One-E-Way’s U.S. Patent Nos. 7,412,294 and
`7,684,885. In particular, One-E-Way identified certain wireless headphone,
`earphone and speaker products by Beats Electronics, LLC that infringed at least
`One-E-Way’s ’258 and ’391 patents. In August and November, 2014, Apple
`responded to One-E-Way’s written notice.
`17.
`In its November 2014 letter responding to One-E-Way, Apple
`represented that “Apple acquired Beats Electronics earlier this year,” and
`acknowledged Apple’s “investigation” and “careful review of the ’258 and ’391
`patents” for the purpose of Beats or Apple potentially licensing One-E-Way’s
`patents.
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 5 of 17 Page ID #:5
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`18. On information and belief, Defendant Apple is a provider of Bluetooth-
`compatible wireless audio products. Specifically, Defendant Apple offers for sale
`and sells in the United States wireless earbud products including, at least, its AirPods
`and AirPods Pro, which were commercially released in the United States in 2016
`and 2019, respectively. Defendant Apple also offers for sale and sells in the United
`States a wireless speaker product called the HomePod.
`19. Apple has advertised its AirPods, AirPods Pro and HomePod (the
`“Apple Accused Products”) as having Bluetooth connectivity, and has advertised the
`benefits
`of
`their
`Bluetooth
`connectivity,
`for
`example,
`at
`https://www.apple.com/airpods/, https://www.apple.com/airpods-2nd-generation/,
`https://www.apple.com/airpods-pro/,
`https://www.apple.com/homepod/
`and
`https://www.apple.com/shop/buy-homepod/homepod/white.
`20. Apple has advertised the Apple Accused Products as having
`connectivity using Bluetooth version 4.0 or later.
`21. Apple offers for sale and sells in the United States the Apple Accused
`Products, including in this Judicial District.
`22. On information and belief, Apple advertises and sells Beats wireless
`audio products, including Powerbeats Wireless Earphones, Powerbeats Pro Wireless
`Earphones, Powerbeats3 Wireless Earphones, Beats Solo Pro Wireless Noise
`Cancelling Headphones, Beats Solo3 Wireless Headphones, Beats Studio3 Wireless
`Headphones, BeatsX Wireless Earphones, and Beats Pill+ Portable Speaker
`(collectively, the “Beats Accused Products”).
`23. Apple has advertised the Beats Accused Products as having Bluetooth
`connectivity, and has advertised the benefits of their Bluetooth connectivity, for
`example, at
` https://www.apple.com/shop/product/MWNV2LL/A/powerbeats-
`high-performance-wireless-earphones-black,
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 6 of 17 Page ID #:6
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` https://www.apple.com/shop/product/MRJA2LL/A/beats-solo-pro-
`wireless-noise-cancelling-headphones-more-matte-collection-dark-
`blue,
` https://www.apple.com/shop/product/MX452LL/A/beats-solo3-
`wireless-headphones-the-beats-icon-collection-satin-silver,
` https://www.apple.com/shop/product/MV702LL/A/powerbeats-pro-
`totally-wireless-earphones-navy,
` https://www.apple.com/shop/product/MXJA2LL/A/beats-studio3-
`wireless-headphones-the-beats-skyline-collection-midnight-black,
` https://www.apple.com/shop/product/MX7X2LL/A/beatsx-earphones-
`the-beats-decade-collection-defiant-black-red, and
` https://www.apple.com/shop/product/ML4M2LL/A/beats-pill-
`portable-speaker-black.
`24. Apple has advertised
`the Beats Accused Products as having
`connectivity for Bluetooth version 4.0 or later.
`25. Apple offers for sale and sells in the United States the Beats Accused
`Products, including in this Judicial District.
`26. The Apple and Beats Accused Products are compatible with prior
`versions of Bluetooth, including back to Bluetooth version 2.0.
`V. THE PATENTS-IN-SUIT
`27. One-E-Way is the owner by assignment of the ’391 patent, titled
`“Wireless Digital Audio Music System,” which the United States Patent and
`Trademark Office duly issued on March 6, 2012. A true and correct copy of the ’391
`patent is attached hereto as Exhibit 1.
`28. One-E-Way is the owner by assignment of the ’047 patent, titled
`“Wireless Digital Audio Music System,” which the United States Patent and
`Trademark Office duly issued on November 5, 2019. A true and correct copy of the
`’047 patent is attached hereto as Exhibit 2.
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`29. The ’391 and ’047 patents are family members in the same chain of
`patents, and both claim priority back to the original patent application in the chain,
`U.S. Patent Application No. 10/027,391, filed on December 21, 2001.
`30. One-E-Way manufactures and sells wireless audio devices covered by
`the Asserted Patents.
`
`VI. COUNT I:
`INFRINGEMENT OF U.S. PATENT NO. 8,131,391
`31. Plaintiff hereby realleges and incorporates by reference the allegations
`set forth in paragraphs 1 through 30.
`32. Defendant Apple’s products, including at least the Apple and Beats
`Accused Products, infringe at least Claim 5 of the ’391 patent under 35 U.S.C.
`§ 271(a), (b) and (c).
`33. Defendant Apple has directly infringed one or more claims of the ’391
`patent through its making, using, importing, offering for sale and/or selling in the
`United States its Apple and Beats Accused Products.
`34. For example, on information and belief, Defendant’s Apple and Beats
`Accused Products include all of the limitations of Claim 5 of the ’391 patent. More
`particularly, the Apple and Beats Accused Products are Bluetooth compatible
`products that comprise a wireless audio receiver. They receive a unique user code
`and original audio signal representation from a mobile digital audio transmitter, for
`example as indicated in the Bluetooth specification, by receiving and using a
`Bluetooth access code and device address in frequency-hopping communication to
`receive packets that include data representing audio information. They also have a
`direct conversion module that receives the packets, as generally indicated by the low
`power consumption characteristics that Apple advertises for its Apple and Beats
`Accused Products. They decode reduced intersymbol interference coding, for
`example and again as indicated in the Bluetooth specification, by applying pulse
`shaping. They also have independent code division multiple access communication,
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 8 of 17 Page ID #:8
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`for example, by using piconet-based, frequency-hopping spread spectrum
`communication as indicated in the Bluetooth specification. And they use digital-to-
`analog conversion and generate audio output, for example, by creating an analog
`audio signal from received digital representation of the audio signal where the
`representation is communicated wirelessly in access-coded packets, again as
`indicated by the Bluetooth specification. They also generate audio output that does
`not include audible audio content originating from other device transmissions
`operating in the digital wireless audio receiver spectrum, for example as indicated
`in the Bluetooth specification, by using unique addressing to receive the access-
`coded packets transmitted by the digital audio transmitter.
`35. Upon information and belief, Defendant Apple has knowledge of One-
`E-Way’s patents, including the ’391 patent, at least based on receiving actual notice
`of the ’391 patent.
`36. For example, Defendant Apple had knowledge of the ’391 patent prior
`to the filing of this Complaint. In 2014, Apple represented that it had conducted a
`“careful review” of the ’391 patent for the purpose of Beats or Apple potentially
`licensing One-E-Way’s patents.
`37. Upon information and belief, Defendant Apple has indirectly infringed
`the ’391 patent under 35 U.S.C. § 271(b) by actively inducing the use of, offering
`for sale, selling, or importing the above-mentioned Apple and Beats Accused
`Products in the United States, knowing and intending that such products would be
`used by customers and end users in a manner that infringes the ’391 patent.
`38. For example, Defendant Apple provides instructions and manuals to its
`customers and end users on how to pair the Apple and Beats Accused Products with
`audio transmission devices using a Bluetooth connection.
`39. By way of example only, the following excerpt from Apple’s website
`(https://support.apple.com/en-us/HT208718) provides the following instructions
`regarding Apple’s AirPods devices:
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 9 of 17 Page ID #:9
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`40. Apple provides similar instructions in its customer manuals on how to
`pair the Apple Accused Products with audio transmission devices using a Bluetooth
`connection, as shown at the following websites:
` https://manuals.info.apple.com/MANUALS/1000/MA1852/en_US/air
`pods-2gen-qsg.pdf,
` https://manuals.info.apple.com/MANUALS/1000/MA1919/en_US/air
`pods-pro-qsg.pdf, and
` https://manuals.info.apple.com/MANUALS/1000/MA1821/en_US/ho
`mepod-ios13-qsg.pdf.
`41. By way of additional example, the following instructions are provided
`for Apple’s BeatsX product (https://www.beatsbydre.com/support/how-to/set-up-
`and-use-beatsx-earphones):
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 10 of 17 Page ID #:10
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`42. Defendant Apple’s customers and end users who use the Apple and
`Beats Accused Products in accordance with Apple’s instructions directly infringe
`one or more claims of the ’391 patent.
`43. Upon information and belief, Defendant Apple knew and intended that
`these activities, including providing instructions to users of the Apple and Beats
`Accused Products to pair those products with a Bluetooth transmitter, would cause
`direct infringement. Upon information and belief, Defendant Apple knew and
`intended that these activities, including providing instructions to users of the Apple
`and Beats Accused Products to pair those products with a Bluetooth transmitter,
`would cause direct infringement. For example, Defendant Apple knew that
`engaging in these activities would cause users of the Apple and Beats Accused
`Products to establish independent code division multiple access communication with
`a transmitter device, to establish a unique user code for wireless packet-based
`communications, to process the packet-based communications for reduction of
`intersymbol interference, to use digital-to-analog conversion to generate audio
`output, and to reproduce the audio output without content originating from other
`device transmitted signals operating in the digital wireless audio receiver spectrum.
`Defendant Apple’s acts therefore constitute infringement of the ’391 patent under
`35 U.S.C. § 271(b).
`44. Defendant Apple has also indirectly infringed the ’391 patent under 35
`U.S.C. § 271(c) by contributing to the direct infringement of Apple’s customers and
`end users by making, using, importing, offering for sale and/or selling in the United
`States its Apple and Beats Accused Products. For example, the Apple and Beats
`Accused Products are not staple articles of commerce and are not suitable for any
`substantial non-infringing use. To the contrary, their sole substantial use is to be
`used in an infringing manner by receiving wireless audio from a transmission device
`through a Bluetooth connection. Furthermore, as Apple’s instructions and manuals
`referenced above demonstrate, the Apple and Beats Accused Products constitute a
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`material part of the invention that Defendant Apple knows to be especially made
`and/or adapted for use in infringing the ’391 patent.
`45. Having been on notice of the ’391 patent since at least August 2014,
`Apple has known and intended that its continued actions actively induce and
`contribute to actual direct infringement of the ’391 patent.
`46. Because of Defendant Apple’s infringement of the ’391 patent, One-E-
`Way has suffered and will continue to suffer harm and injury, including monetary
`damages in an amount to be determined at trial.
`VII. COUNT II:
`INFRINGEMENT OF U.S. PATENT NO. 10,468,047
`47. Plaintiff hereby realleges and incorporates by reference the allegations
`set forth in paragraphs 1 through 46.
`48. Defendant Apple’s products, including at least the Apple and Beats
`Accused Products, infringe at least Claim 1 of the ’047 patent under 35 U.S.C.
`§ 271(a), (b) and (c).
`49. Defendant Apple has directly infringed one or more claims of the ’047
`patent through its making, using, importing, offering for sale and/or selling in the
`United States its Apple and Beats Accused Products.
`50. For example, on information and belief, Defendant’s Apple and Beats
`Accused Products include all of the limitations of Claim 1 of the ’047 patent. More
`particularly, the Apple and Beats Accused Products are Bluetooth compatible
`products that comprise a portable spread spectrum audio receiver. They receive and
`store a unique user code and receive wireless modulation transmissions from a
`spread spectrum transmitter, for example as indicated in the Bluetooth specification,
`by receiving and using a Bluetooth access code and device address in frequency-
`hopping communication to receive packets that include data representing audio
`information. They have a direct conversion module that receives wireless
`modulation transmissions, as generally indicated by the low power consumption
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`characteristics that Apple advertises for its Apple and Beats Accused Products. They
`receive wireless modulation transmissions that have been processed to reduce
`intersymbol interference and also further process the transmissions for intersymbol
`interference reduction, for example as indicated in the Bluetooth specification, by
`applying pulse shaping. As also indicated in the Bluetooth specification, they use a
`digital-to-analog converter to provide an analog audio output that corresponds to a
`digital audio representation, for example, by creating an analog audio signal from
`received digital representation of the audio signal where the representation is
`communicated wirelessly in access-coded packets. They also use a speaker to
`generate an audio signal where the audio signal does not include audible audio
`content originating from any audio signals transmitted in a spectrum used by the
`spread spectrum transmitter that do not originate from the spread spectrum
`transmitter, for example as indicated in the Bluetooth specification, by using unique
`addressing to receive the access-coded packets transmitted by the spread spectrum
`transmitter.
` They also use
`independent code division multiple access
`communication,
`for example, by using piconet-based,
`frequency-hopping
`communication as indicated in the Bluetooth specification, which likewise indicates
`the use of unique addressing to communicate with only the spread spectrum
`transmitter during a wireless connection. They also perform at least one of a
`plurality of demodulations, for example as indicated in the Bluetooth specification,
`by using differential phase shift keying.
`51. Upon information and belief, Defendant Apple has knowledge the ’047
`patent, at least based on receiving actual notice through this Complaint.
`52. Upon information and belief, Defendant Apple has indirectly infringed
`the ’047 patent under 35 U.S.C. § 271(b) by actively inducing the use of, offering
`for sale, selling, or importing the above-mentioned Apple and Beats Accused
`Products in the United States, knowing and intending that such products would be
`used by customers and end users in a manner that infringes the ’047 patent.
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`53. For example, Defendant Apple provides instructions and manuals to its
`customers and end users on how to pair the Apple and Beats Accused Products with
`audio transmission devices using a Bluetooth connection.
`54. By way of example only, the following excerpt from Apple’s website
`(https://support.apple.com/en-us/HT208718) provides the following instructions
`regarding Apple’s AirPods devices:
`
`
`
`
`
`
`
`
`
`55. Apple provides similar instructions in its customer manuals on how to
`pair the Apple Accused Products with audio transmission devices using a Bluetooth
`connection, as shown at the following websites:
` https://manuals.info.apple.com/MANUALS/1000/MA1852/en_US/air
`pods-2gen-qsg.pdf,
` https://manuals.info.apple.com/MANUALS/1000/MA1919/en_US/air
`pods-pro-qsg.pdf, and
` https://manuals.info.apple.com/MANUALS/1000/MA1821/en_US/ho
`mepod-ios13-qsg.pdf.
`56. By way of additional example, the following instructions are provided
`for Apple’s BeatsX product (https://www.beatsbydre.com/support/how-to/set-up-
`and-use-beatsx-earphones):
`/ / /
`/ / /
`/ / /
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 14 of 17 Page ID #:14
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`57. Defendant Apple’s customers and end users who use the Apple and
`Beats Accused Products in accordance with Apple’s instructions directly infringe
`one or more claims of the ’047 patent.
`58. Upon information and belief, Defendant Apple knew and intended that
`these activities, including providing instructions to users of the Apple and Beats
`Accused Products to pair those products with a Bluetooth transmitter, would cause
`direct infringement. For example, Defendant Apple knew that engaging in these
`activities would cause users of the Apple and Beats Accused Products to establish
`independent code division multiple access communication with a spread spectrum
`transmitter device, to receive and store a unique user code for wireless packet-based
`communications, to process received wireless modulation transmissions for
`reduction of intersymbol interference, to use digital-to-analog conversion to provide
`an analog audio output, to use a speaker to generate an audio signal that does not
`include audible audio content originating from any audio signals transmitted in a
`spectrum used by the spread spectrum transmitter that do not originate from the
`spread spectrum transmitter, and to perform at least one of a plurality of
`demodulations. Defendant Apple’s acts therefore constitute infringement of the
`’047 patent under 35 U.S.C. § 271(b).
`/ / /
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 15 of 17 Page ID #:15
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`59. Defendant Apple has also indirectly infringed the ’047 patent under 35
`U.S.C. § 271(c) by contributing to the direct infringement of Apple’s customers and
`end users by making, using, importing, offering for sale and/or selling in the United
`States its Apple and Beats Accused Products. For example, the Apple and Beats
`Accused Products are not staple articles of commerce and are not suitable for any
`substantial non-infringing use. To the contrary, their sole substantial use is to be
`used in an infringing manner by receiving wireless audio from a transmission device
`through a Bluetooth connection. Furthermore, as Apple’s instructions and manuals
`referenced above demonstrate, the Apple and Beats Accused Products constitute a
`material part of the invention that Defendant Apple knows to be especially made
`and/or adapted for use in practicing the inventions of the ’047 patent.
`60. By at least the time of trial, Apple will have known and intended that
`its continued actions would actively induce and contribute to actual direct
`infringement of the ’047 patent.
`61. Because of Defendant Apple’s infringement of the ’047 patent, One-E-
`Way has suffered and will continue to suffer harm and injury, including monetary
`damages in an amount to be determined at trial.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff prays for judgment in its favor against Defendant
`Apple for the following relief:
`A.
`Pursuant to 35 U.S.C. § 271, a determination that Defendant Apple and
`their officers, agents, servants, employees, attorneys and all others in active concert
`and/or participation with them have infringed the ’391 and ’047 patents through the
`manufacture, use, importation, offer for sale, and/or sale of infringing products
`and/or any of the other acts prohibited by 35 U.S.C. § 271;
`B.
`Pursuant to 35 U.S.C. § 284, an award compensating Plaintiff for
`Defendant Apple’s infringement of the ’391 and ’047 patents through payment of
`not less than a reasonable royalty on Defendant Apple’s sales of infringing products;
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 16 of 17 Page ID #:16
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`C.
`Pursuant to 35 U.S.C. § 285, a finding that this is an exceptional case,
`and an award of reasonable attorneys’ fees and non-taxable costs;
`D. An assessment of prejudgment and post-judgment interest and costs
`against Defendant, together with an award of such interest and costs, pursuant to 35
`U.S.C. § 284; and
`E.
`Such other and further relief as this Court may deem just.
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`Respectfully submitted,
`KNOBBE, MARTENS, OLSON & BEAR, LLP
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` /s/ Douglas G. Muehlhauser
`Douglas G. Muehlhauser
`Payson LeMeilleur
`Attorneys for Plaintiff
`ONE-E-WAY, INC.
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`Dated: July 16, 2020
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`Case 2:20-cv-06339 Document 1 Filed 07/16/20 Page 17 of 17 Page ID #:17
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`DEMAND FOR JURY TRIAL
`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff One-
`E-Way hereby demands a trial by jury on all issues so triable.
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`Respectfully submitted,
`KNOBBE, MARTENS, OLSON & BEAR, LLP
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` /s/ Douglas G. Muehlhauser
`Douglas G. Muehlhauser
`Payson LeMeilleur
`Attorneys for Plaintiff
`ONE-E-WAY, INC.
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`Dated: July 16, 2020
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