Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 1 of 14 PageID #: 1334
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`
`
`Case No. 2:19-cv-396-JRG
`
`
`LUMINATI NETWORKS LTD.
`
`
`
`
`
`Plaintiff,
`
`v.
`
`CODE200, UAB; OXYSALES, UAB;
`METACLUSTER LT, UAB;
`
`
`Defendants.
`
`
`
`
`LUMINATI’S CLAIM CONSTRUCTION REPLY BRIEF
`(LOCAL PATENT RULE 4-5(c))
`
`
`
`Data Co Exhibit 1102
`Data Co v. Bright Data
`IPR2022-00135
`
`

`

`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 2 of 14 PageID #: 1335
`
`III.
`
`I.
`II.
`
`TABLE OF CONTENTS
`INTRODUCTION............................................................................................................. 1
`DISPUTED TERMS FOR CLAIM CONSTRUCTION ............................................... 1
`A. “Client Device” ................................................................................................................ 1
`B. “First Server” (’511 Patent) and “Second Server” (’968 Patent) ..................................... 3
`THE CLAIM TERMS ARE NOT INDEFINITE .......................................................... 5
`A. Not Indefinite: “Sending…the First Content Identifier to the Web Server Using the
`Selected IP Address” / “Sending…to the Web Server Using the Selected IP Address”
`(’511 Patent Claim 1) ..................................................................................................... 6
`B. Not Indefinite: “A Response Time When Communicating” (’511 Patent Claim 17 &
`’968 Patent Claim 2) ....................................................................................................... 7
`C. Not Indefinite: “Source Address” (’511 Patent Claim 25) .............................................. 8
`D. Not Indefinite: “For Use With A Web Server That Is A HTTP Or HTTPS Server That
`Respectively Responds To HTTP Or HTTPS Requests And Stores A First Content
`Identified By A First Content Identifier” (’968 Patent Claim 1) ................................... 8
`E. Not Indefinite: “Receiving … From The Second Server Using The Selected IP
`Address” (’968 Patent Claim 1) ..................................................................................... 9
`F. Not Indefinite: “Determining … That The Received Part Of, Or The Whole Of, The
`First Content, Is Valid” & “The Determining Is Based On A Received HTTP Header
`According To, Or Based On IETF RFC 2616” (’968 Patent Claims 8 and 9) ............... 9
`G. Not Indefinite: “Periodically Communicating” (’968 Patent Claim 15) ....................... 10
`IV. CONCLUSION ............................................................................................................... 10
`
`
`
`
`
`
`i
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 3 of 14 PageID #: 1336
`
`TABLE OF AUTHORITIES
`
`
`
`Cases
`
`BASF Corp.v. Johnson Matthey Inc., 875 F.3d 1360 (Fed. Cir. 2017) ................................... 7, 8, 9
`
`Energizer Holdings, Inc. v. Int’l Trade Comm’n, 435 F.3d 1366 (Fed. Cir. 2006) ...................... 10
`
`Integrated Claims Sys., LLC v. Old Glory Ins. Co., No. 2:15-cv-00412-JRG, 2020 U.S. Dist.
`LEXIS 214425 (E.D. Tex. Nov. 17, 2020) ............................................................................... 10
`
`Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898 (2014) ..................................................... 5
`
`Optimum Imaging Techs. LLC v. Canon Inc., No. 2:19-CV-00246-JRG, 2020 U.S. Dist. LEXIS
`102126 (E.D. Tex. June 11, 2020) .............................................................................................. 6
`
`Slimfold Manufacturing Co. v. Kinkead Industries, Inc., 810 F.2d 1113 (Fed. Cir. 1987) .......... 10
`
`Traxxas LP v. Hobby Prods. Int’l, No. 2:14-CV-945-JRG-RSP, 2015 U.S. Dist. LEXIS 114148
`(E.D. Tex. Aug. 27, 2015) ........................................................................................................... 6
`
`
`
`ii
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 4 of 14 PageID #: 1337
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`I.
`
`INTRODUCTION
`
`There are very few disputes on claim construction other than indefiniteness in this case,
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`and they involve the basic components of the network architecture established in the patents-in-
`
`suit: client device, first server [or second server], and web server [or first web server]. Defendants’
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`version of “plain meaning” is not the plain meaning, it is a redefinition that improperly treats the
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`distinct elements of the claimed client device – server - web server architecture as
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`interchangeable, effectively reducing the claims to a computer – computer – computer
`
`architecture. Defendants’ version is clearly not what the patentee invented or claimed. Otherwise,
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`the rest of Defendants’ positions are attempts to see if the Court is willing to override the Patent
`
`Office’s determination that the clams are definite. These arguments do not and cannot prove
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`invalidity by clear and convincing evidence as they must, and all such attempts should be denied.
`
`II.
`
`DISPUTED TERMS FOR CLAIM CONSTRUCTION
`A.
`
`“Client Device”
`
`Apparently, Defendants have now changed their position and decided that instead of plain
`
`and ordinary meaning, it is appropriate for the Court to find the term “client device” to mean
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`“communication device that is operating in the role of a client” as it did in the Teso case. As
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`Luminati pointed out in the Teso case, this Court properly found that a client device is a
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`communication device and that the patent specification distinguishes such communication devices
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`from servers. Defendants seek to have the Court enter the same construction by apparently
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`ignoring the Court’s finding regarding the term “communication device” in order to assert that
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`there is no difference between a client device and a server. But the Court never held that. By
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`arguing that a ‘communication device’ contains the general components of a computer, Defendants
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`attempt to draw the improper inference that anything with a processor, memory and a storage
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`device is a communication device. This is wrong. The patent specification defines “client device”
`
`1
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 5 of 14 PageID #: 1338
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`as a “consumer computer.” ECF 126-2 at 2:44-46 (“In the network 50, files are stored on computers
`
`of consumers, referred to herein as client devices 60”). The specification distinguishes
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`“communication devices” from servers (ECF 86-2 at 4:41-5:10), which was recognized by this
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`Court with the same substantive parties (Luminati and Oxylabs) and same counsel in the Teso
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`Case (ECF 86-4) (“The patents do not include servers as a type of ‘communication device’”). The
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`claims themselves clearly distinguish between the client device, server, and web server utilizing
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`the claimed client device – server - web server architecture.
`
`Defendants mischaracterize the Teso Case Claim Construction Order to confuse a proxy
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`“client device” which may “act as a server” (ECF 86-4 at 12 (emphasis added)) with a server itself.
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`Similarly, in this case, the above proxy server must act as a client to the extent that it necessarily
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`sends requests to the web server, but that does not mean that the claimed server is interchangeable
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`with a “client device.” Despite representing that they would not treat client devices and servers as
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`interchangeable (ECF 86-4 at 12), Defendants have done just that in the Teso case, asserting that
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`the claims may cover anything with three computers, that is, a computer – computer – computer
`
`network architecture. But that completely disregards the specification and the clear claim
`
`language. Based on Defendants’ invalidity contentions, they clearly intend to argue the same here.
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`The patentee did not obtain the patents by setting forth communications among any three
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`computers, and to so construe them would discredit the work of the Patent Office in analyzing and
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`approving of the patent claims that issued. Instead of addressing Luminati’s opening claim
`
`construction brief, Defendants repeatedly misrepresent filings from the Teso Case to argue
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`incorrectly that Luminati had admitted that a client device can be a server. Defendants’ Brief at 5.
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`This is false. Luminati took the opposite position throughout its briefing, arguing that the terms
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`“client device” and “server” require construction because they are not interchangeable. Teso Case,
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`2
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 6 of 14 PageID #: 1339
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`ECF 24 at 4; ECF 28 at 24; ECF 47 at 4-8; Ex. F at 9:18-15:17. The claims clearly distinguish
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`between a client device and a server, and Luminati never argued or admitted otherwise. Similarly,
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`Defendants’ reliance on the claim construction order from Luminati Networks, Ltd. v. Tesonet UAB
`
`(ECF 88-2), which construed claims from patents in a different family from the patents at issue in
`
`this case, is misplaced. Oxylabs is fully aware that the term “client device” in the later ’614 patent
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`specification in the Teso case, for example, received a different construction from the term “client
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`device” based on the specification at issue here.
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`Consistent with the claim language, the definition provided by the specification and the
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`detailed discussion therein, a “client device” should be construed to mean “consumer computer.”
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`In the alternative, both sides appear to agree that an appropriate construction could be
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`“communication device that is operating in the role of a client,” but Luminati does so with the caveat
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`that such a construction does not give Defendants carte blanche to ignore the meaning of
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`“communication device” as they appear to do in their claim construction brief.
`
`B.
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`“First Server” (’511 Patent) and “Second Server” (’968 Patent)
`
`After further consideration and review of the Court’s Claim Construction Order that issued
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`the same day of Luminati’s opening brief, Luminati revises its proposed construction:
`
`Claim Term
`“second server” (’968 patent)
`
`“first server” (’511 patent)
`
`Plaintiff’s Proposal
`server that is not the client
`device or the web server
`
`server that is not the client
`device or the web server
`
`Defendants’ Proposal
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`In the prior Teso case, the Court considered the same specification with the same
`
`components but with a different layout, holding that “second server” means “server that is not the
`
`client device.” (ECF 86-4, at 16, 23) There the components with terms laid out as follows:
`
`
`
`3
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 7 of 14 PageID #: 1340
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`Second
`Server
`
`Client
`Device
`
`First
`Web
`Server
`
`Once it was clear that the “second server” there was different from the “client device” there
`
`was no need for further clarification. Here, however, especially given Defendants’ claim
`
`construction argument inappropriately conflating the first/second server with the web server
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`despite them being expressly set out as separate components in the specification and claims,
`
`Luminati asks for the additional clarification that the non-web server is also not the web server.
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`Otherwise, there is no dispute that the term “first server” in the ’510 patent points to and
`
`should be construed consistently with the “second server” in the ’968 patent:
`
`Client
`Device
`
`Second Server ‘968
`
`First Server ‘511
`
`First Web Server
`‘968
`Web Server ‘511
`
`It is unclear from Defendants’ brief how they plan to wield their “plain and ordinary
`
`meaning” as to the server terms, but it is notable that, unlike the term “client device,” here
`
`Defendants do not adopt the Court’s construction of “second server” from the Teso case.
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`Nevertheless, they also do not dispute that the server is a different component from the “client
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`device” as set forth in the Court’s claim construction order in Teso. Furthermore, they recognize
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`regarding the ’511 patent that the server must be separate from the web server (arguing only that
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`the distinction is unnecessary) (See Def. Brf. at 8.) They also concede that as to the ’968 patent,
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`“Claim 1 recites that the ‘second server’ is ‘distinct’ from the first web server.” (Id., at 9.) But
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`then they make a strange argument that “distinct” is somehow different from “separate,” which is
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`4
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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 8 of 14 PageID #: 1341
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`incorrect1, and no such difference is discussed in the patents-in-suit.2 The claims require three
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`distinct components and it is appropriate to construe the “second server” (’968 patent) / “first
`
`server” (’511 patent) to make that clear similar to what was done in the Teso case.
`
`Defendants do not dispute that the first server of the ’511 Patent must be separate from the
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`web server. For the same reasons provided above, a server, including the “first server” is not a
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`“client device” or a “communication device.” The first server is not interchangeable with a client
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`device and it would be improper for Defendants to argue that they are interchangeable under the
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`guise of plain and ordinary meaning.
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`The term “second server” in the ’968 patent denotes the same server as the term “first
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`server” in the ’511 patent. Defendants agree that the second server in the ’968 patent is distinct
`
`from the “first web server,” but then appear to take the position that they need not be separate.
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`Such an interpretation is contrary to the clear preamble, of claim 1 which requires the “first web
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`server” to be a HTTP or HTTPS server that respectively responds to HTTP or HTTPS requests
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`and stores a first content” and “a second server distinct from the first web server and identified in
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`the Internet by a second IP address.” Thus, the preamble makes absolutely clear that the second
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`server distinct is distinct from the first web server in contravention to Defendants’ position.
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`III. THE CLAIM TERMS ARE NOT INDEFINITE
`
`The volume of Defendants’ indefiniteness arguments evinces their weakness. Section 112
`
`requires only that “a patent’s claims, viewed in light of the specification and prosecution history,
`
`inform those skilled in the art about the scope of the invention with reasonable certainty.” Nautilus,
`
`
`1 Definition of Distinct as “Distinguishable to the eye or mind as being discrete (see DISCRETE
`sense 1) or not the same: SEPARATE.” https://www.merriam-webster.com/dictionary/distinct
`2 As to the remainder of Defendants’ argument regarding Luminati’s proposal for the server’s
`handling of IP addresses, Luminati disagrees with Defendants’ position but will not argue the
`specifics here given that Luminati has revised its proposed constructions to remove the reference
`to IP addresses as to these terms.
`
`5
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 9 of 14 PageID #: 1342
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`Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 910 (2014). A patent claim is not indefinite if
`
`“someone working in the relevant technical field could understand the bounds of a claim.” Traxxas
`
`LP v. Hobby Prods. Int’l, No. 2:14-CV-945-JRG-RSP, 2015 U.S. Dist. LEXIS 114148, at *8 (E.D.
`
`Tex. Aug. 27, 2015). Lack of antecedent basis “does not constitute per se grounds for invalidity;
`
`instead … the law requires a clear and convincing showing that one of ordinary skill cannot
`
`reasonably ascertain claim scope.” Optimum Imaging Techs. LLC v. Canon Inc., No. 2:19-CV-
`
`00246-JRG, 2020 U.S. Dist. LEXIS 102126, *25 (E.D. Tex. June 11, 2020) (citing Nautilus).
`
`A.
`Not Indefinite: “Sending…the First Content Identifier to the Web Server
`Using the Selected IP Address” / “Sending…to the Web Server Using the Selected
`IP Address” (’511 Patent Claim 1)
`
`Consistent with Dr. Rhyne’s opinion, the step of “sending, in response to the selecting, the
`
`first content identifier to the web server using the selected IP address” should be construed as “the
`
`first server sending the Uniform Resource Locator for the first content to the web server using the
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`selected IP address from the stored group of IP addresses.” And the term “the selected IP address”
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`has an antecedent basis in the claim, which is the “IP address from the group” selected in the
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`“selecting” limitation. There is nothing unclear about that. The “method by the first server”
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`comprises the first server using the address it selected in response to receiving the request in order
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`to in turn request content from the web server.
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`Defendants do not dispute that a POSA would understand what an IP address is, but
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`Defendants wrongly assert that a POSA would not understand what “using the selected IP address”
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`means, applying an inapplicable analogy of “using light” to drive to a store, whereas the apt and
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`obvious analogy is “using the address” from where the driver will leave to drive to the store. A
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`communication over the Internet can (and generally is) sent from the IP address of one component
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`to the IP address of a second. In this claim the first server has the option of which IP address to
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`use, and it uses the one it selected.
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`6
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 10 of 14 PageID #: 1343
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`Defendants propose nonsensical and unsupported interpretations that ignore the context of
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`the claims. There is, for example, no example in the patent nor would it make any sense for the
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`first server to select the client’s IP address to use to make the request—that would undermine the
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`entire purpose of the claim. For the same reason, a POSA would not understand the first server as
`
`selecting the IP address of the web server from the group. Defendants’ DNS scenario also makes
`
`no sense—a Domain Name System server merely translates a URL into the web server IP address.
`
`These are all red herrings. Regardless, “breadth is not indefiniteness.” BASF Corp.v. Johnson
`
`Matthey Inc., 875 F.3d 1360, 1367 (Fed. Cir. 2017). The claim clearly states that the first server
`
`“stores a group of IP addresses” and selects from that stored group at a time when it is not aware
`
`of the client IP or the web server IP.
`
`B.
`Not Indefinite: “A Response Time When Communicating” (’511 Patent
`Claim 17 & ’968 Patent Claim 2)
`
`Defendants conceded that “a response time when communicating” is the criterion for
`
`selecting the IP address in the relevant dependent claims. Their argument here appears to build on
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`(and require) the prior indefiniteness argument regarding the use of a selected IP to argue if the IP
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`is not known then the response time is not, either. But the IP address is known, and Defendants
`
`provide no basis for asserting that the response time could be understood by a POSA to refer to a
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`communication that does not use the “selected IP address.”
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`Beyond that, Defendant’s attempts to add further limitations to “response time” are
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`improper. The claims are not limited to “one-way latency” or “round trip time latency.”
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`Defendants raise a number of hypothetical questions, all of which point to scope rather than
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`definiteness. Similarly, regarding ’968 Patent claim 2 (“wherein the selecting is further based on
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`a response time when communicating with the requesting client device”), Defendants are
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`improperly adding limitations regarding the how and when the response time is calculated.
`
`7
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 11 of 14 PageID #: 1344
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`However, “breadth is not indefiniteness.” BASF Corp. 875 F.3d at 1367. If response time is the
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`criterion used to select the IP address, the claim is met. This term is not indefinite.
`
`C.
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`Not Indefinite: “Source Address” (’511 Patent Claim 25)
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`Defendants argue that a POSA would not understand the term “source address” in
`
`dependent claim 25 (“wherein the sending of the first content identifier to the web server comprises
`
`using the selected IP address as a source address”). According to Dr. Rhyne, “a POSA would
`
`understand using the selected IP address to appear as the source IP address in sending the first
`
`content identifier to the web server.” Defendants again ignore the claim context by arguing
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`(wrongly) that the “source address” could be the client device or web server itself. As discussed
`
`above, such interpretations make no sense in the context of the claims. Regardless, “breadth is not
`
`indefiniteness.” BASF Corp. 875 F.3d at 1367. This term should be found not indefinite.
`
`D.
`Not Indefinite: “For Use With A Web Server That Is A HTTP Or HTTPS
`Server That Respectively Responds To HTTP Or HTTPS Requests And Stores A
`First Content Identified By A First Content Identifier” (’968 Patent Claim 1)
`
`’968 patent claim 1’s method is for use with various components, but the method itself is
`
`performed by the requesting client device, which is clear from every limitation that expressly states
`
`that it is performed “by the requesting client device.” While a POSA would know the second
`
`server is distinct from the web server, the claim does not recite any limitations to be performed by
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`the second server or any device other than the requesting client device.
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`Defendants ignore the context of the claimed steps to argue that a web server could be used
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`for any purpose. However, Dr. Rhyne’s opined that “a POSA would understand from the preamble
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`that the “first content is stored on the web server” and is identified by a ‘first content identifier’
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`and that the web server ‘responds to HTTP or HTTPS requests.’” ECF 86-3 at ¶ 26. “[A] POSA
`
`would understand that the recited step of “identifying … an HTTP or HTTPS request for the first
`
`content,” refers to the first content stored on the web server, and that the recited steps of “sending,
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`8
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 12 of 14 PageID #: 1345
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`by the requesting client device, to the second server … the first content identifier and the selected
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`IP address” and “receiving, by the requesting client device, over the Internet in response to the
`
`sending, from the second server using the selected IP address, the first content” refer to the client
`
`device sending the first content identifier permitting the first content to be fetched from the web
`
`server using the selected IP address and returned to the client device.” Id. at ¶ 27. This is consistent
`
`with the specification as well. Beyond that, Defendants’ attempt to write the web server out of the
`
`preamble is improper. Similarly, Defendants may not read additional limitations into independent
`
`claim 1. Additional claims could add limitations regarding the performance of other steps by the
`
`second server or first web server, but “breadth is not indefiniteness.” BASF Corp. 875 F.3d at 1367.
`
`E.
`Not Indefinite: “Receiving … From The Second Server Using The Selected
`IP Address” (’968 Patent Claim 1)
`
`For the same reasons provided above with regard to “for use with a web server…” this term
`
`is similarly not indefinite. Understanding that all the steps are performed “by the requesting client
`
`device,” a POSA would understand the last step of the client device receiving the first content “in
`
`response to the sending, from the second server using the selected IP address” to mean that the
`
`selected IP address was used by the second server in fetching the first content from the web server.
`
`F.
`Not Indefinite: “Determining … That The Received Part Of, Or The Whole
`Of, The First Content, Is Valid” & “The Determining Is Based On A Received
`HTTP Header According To, Or Based On IETF RFC 2616” (’968 Patent Claims 8
`and 9)
`
`Defendants argue that “the received part of, or the whole of, the first content” lacks
`
`antecedent basis. However, “[A]n antecedent basis can be present by implication.” Energizer
`
`Holdings, Inc. v. Int’l Trade Comm’n, 435 F.3d 1366, 1371 (Fed. Cir. 2006); see also Slimfold
`
`Manufacturing Co. v. Kinkead Industries, Inc., 810 F.2d 1113, 1116 (Fed. Cir. 1987); Integrated
`
`Claims Sys., LLC v. Old Glory Ins. Co., No. 2:15-cv-00412-JRG, 2020 U.S. Dist. LEXIS 214425,
`
`at *19 (E.D. Tex. Nov. 17, 2020) (citing Energizer). In Dr. Rhyne’s opinion, “[a] POSA would
`
`9
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`

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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 13 of 14 PageID #: 1346
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`understand understand that the requesting client device is determining whether the received first
`
`content is valid.” Further, “A POSA would further understand from the specification that the
`
`content may be received in parts such as “chunks.” ECF 86-2 at 8:31-37 (“Chunks in the present
`
`description are defined as equally sized pieces of data that together form the whole content of the
`
`URL. It should be noted that while the pieces of data, in accordance with an alternative
`
`embodiment of the invention, the chunks may instead be of different size.”).” Consequently, in
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`Dr. Rhyne’s opinion “a POSA would not understand the term ‘part of, or whole of, the first content’
`
`to be indefinite.” Defendants arguments’ that the terms “valid” and “the determining is based on
`
`the received HTTP header according to, or based on, IETF RFC 2616” were already rejected by
`
`this Court. Defendants offer no new arguments. ECF 86-4 at 17-19. These terms are not indefinite.
`
`G.
`
`Not Indefinite: “Periodically Communicating” (’968 Patent Claim 15)
`
`Defendants do not dispute that the Court found the identical term from the same patent
`
`family not indefinite in the Teso Case. Defendants appear to intentionally misinterpret the Claim
`
`Construction Order from the Teso Case as finding that “periodically communicating” excludes
`
`“regular intervals.” It does not. Defendants also argue that “periodically communicating” is
`
`indefinite to the extent it refers to “occasional communication.” Def. Brief at 28-29. However,
`
`Defendants provide no support for these positions, and the term should be found not indefinite.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Plaintiff respectfully requests that the Court enter its proposed
`
`constructions as set forth above, and find that none of the claims is indefinite.
`
`Dated: January 8, 2021
`
`
`
`Respectfully submitted,
`
`By: /s/Robert Harkins__
`
`S. Calvin Capshaw
`State Bar No. 03783900
`
`10
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`Case 2:19-cv-00396-JRG Document 89 Filed 01/08/21 Page 14 of 14 PageID #: 1347
`
`Elizabeth L. DeRieux
`State Bar No. 05770585
`Capshaw DeRieux, LLP
`114 E. Commerce Ave.
`Gladewater, TX 75647
`Telephone: 903-845-5770
`ccapshaw@capshawlaw.com
`ederieux@capshawlaw.com
`
`Mark Mann
`Mann | Tindel | Thompson
`300 West Main
`Henderson, TX 75652
`Telephone: 903-657-8540
`mark@themannfirm.com
`
`Robert Ruyak
`Corrine Saylor Davis
`Ronald Wielkopolski
`RuyakCherian LLP
`1901 L St. NW, Suite 700
`Washington, DC 20036
`robertr@ruyakcherian.com
`ronw@ruyakcherian.com
`corrinesd@ruyakcherian.com
`
`Korula T. Cherian
`Robert Harkins
`RuyakCherian LLP
`1936 University Ave, Ste. 350
`Berkeley, CA 94702
`sunnyc@ruyakcherian.com
`bobh@ruyakcherian.com
`
`Attorneys for Plaintiff
`Luminati Networks Ltd.
`
`11
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