`
```UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`LUMINATI NETWORKS LTD.
`
`
`
`
`
`Plaintiff,
`
`v.
`
`IP NINJA LTD.
`
`
`Defendant.
`
`
`
`
`
`
`
`
`
`Case No.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff, Luminati Networks Ltd. (“Luminati”) brings this action under the patent laws of
`
`the United States, Title 35 of the United States Code, and makes the following allegations against
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`IP Ninja Ltd. (“IP Ninja” or “Defendant”):
`
`THE PARTIES
`
`1.
`
`Plaintiff Luminati is an Israeli company having a principal place of business at 3
`
`Hamahshev St., Netanya 42507, ISRAEL.
`
`2.
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`Upon information and belief, Defendant IP Ninja is an Israeli corporation
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`headquartered at BSR Tower #4, Floor 24, Metzada 7, Bney Brak, Israel.
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`JURISDICTION AND VENUE
`
`3.
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`This is an action for patent infringement under the patent laws of the United States
`
`of America, 35 U.S.C. § 1, et seq.
`
`4.
`
`This Court has jurisdiction over the subject matter of this action under 28 U.S.C.
`
`§§ 1331 and 1338(a).
`
`Data Co Exhibit 1114
`Data Co v. Bright Data
`IPR2022-00135
`
`

`

`
`
`5.
`
`This Court has personal jurisdiction over IP Ninja because it, directly or through its
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`subsidiaries, divisions, groups, or distributors, has sufficient minimum contacts with this forum as
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`a result of business conducted within the State of Texas, and/or pursuant to Fed. R. Civ. P. 4(k)(2).
`
`On information and belief, IP Ninja transacts substantial business in the State of Texas, directly or
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`through agents, including: (i) at least some of the infringement alleged herein in the United States
`
`occurring in Texas, and (ii) regularly does or solicits business in Texas, engages in other persistent
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`courses of conduct, maintains continuous and systematic contacts within this Judicial District,
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`purposefully avails itself of the privilege of doing business in Texas, and/or derives substantial
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`revenue from services provided in Texas. For example, on information and belief, IP Ninja utilizes
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`software, which is, inter alia, the subject of the infringement alleged herein, that routes internet
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`communications through user devices having IP addresses serving as residential proxies located
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`in the State of Texas, as well as this Judicial District, permitting IP Ninja to include user devices
`
`in this Judicial District as part of IP Ninja’s residential proxy service. This Court has at least
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`specific personal jurisdiction over IP Ninja for all asserted claims.
`
`6.
`
`Following Brunette Machine Works v. Kockum Industries, Inc., 406 U.S. 706
`
`1972), venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) at least because,
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`upon information and belief, IP Ninja is a foreign entity.
`
`FACTUAL ALLEGATIONS
`
`7.
`
`Derry Shribman and Ofer Vilenski are the named inventors of a number of patents,
`
`including U.S. Patent Nos. 9,241,044 (“’044 Patent”) and divisional 9,742,866 (“’866 Patent”)
`
`(collectively the “Asserted Patents”).
`
`8.
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`The Asserted Patents are directed toward methods for fetching content over the
`
`Internet through the use of intermediary tunneling devices. Luminati identifies its patents on its
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`2
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`website at https://luminati.io/patent-marking#system-and-method-for-streaming-content-from-
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`multiple-servers.
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`9.
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`The Asserted Patents were assigned to Hola Networks Ltd. (“Hola”). Hola has
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`subsequently changed its name to Luminati Ltd., before changing its name to Luminati Networks
`
`Ltd., the Plaintiff in this action.
`
`10.
`
`Luminati, formerly known as Hola, provides a cloud service connecting tens of
`
`millions of devices over the Internet through a proxy-based network. Each participating device
`
`allows the network to utilize a small fraction of that device’s idle time for the network. Luminati
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`utilizes this network to provide proxy-based services to businesses.
`
`11.
`
`Since 2014, Luminati has offered proxy-based services relying on its “Residential
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`Proxy Network” that practice one or more claims of the Asserted Patents. Luminati permits its
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`business customers to utilize its residential proxy network to access data over the Internet using
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`residential IP addresses from various localities as required by the customers. These residential IP
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`addresses provide businesses with a number of advantages. For example, Luminati’s customers
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`may use this network to anonymously compare prices leading to more transparency and lower
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`prices for consumers. Luminati’s customers may also use residential proxy addresses to test their
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`web sites from any city in the world. Prior to and separate from the technology at issue in this
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`case, Hola provided a Virtual Private Network (“VPN”) service called HolaVPN.
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`12.
`
`Upon information and belief, IP Ninja has provided a residential proxy service,
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`since at least May 2018 when Luminati became aware of it. On May 15, 2018, current Luminati
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`Chief Executive Officer Or Lenchner sent a letter to Nadav Moshe, a partner at IP Ninja, notifying
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`IP Ninja that Luminati is aware that Defendant is offering a residential proxy service, Luminati
`
`has intellectual property, including the ’866 Patent, Luminati guards its intellectual property and
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`3
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`would be harmed by unauthorized activities covered by these patents, and Luminati is willing to
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`discuss licensing. On June 11, 2018, Mr. Lenchner had a meeting with Mr. Moshe and Idan
`
`Sharon, vice president of business development and sales at IP Ninja, at Luminati’s office to
`
`discuss IP Ninja’s residential proxy service. In a subsequent email sent from Mr. Lenchner to Mr.
`
`Moshe and Mr. Sharon the next day, IP Ninja was provided with copies of the Asserted Patents.
`
`Upon information and belief, IP Ninja was aware of the Asserted Patents and Luminati’s
`
`allegations of infringement at least as early as May 2018.
`
`13.
`
`Upon information and belief, IP Ninja offers residential
`
`IP proxy services,
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`advertised as useful for price comparison, advertisement verification, brand protection, and
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`geographic testing. https://ipninja.io/. Upon information and belief, this includes a residential
`
`proxy network with millions of residential IP addresses from more than 100 countries. Id.,
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`https://ipninja.io/blogs/why-is-ip-ninja-the-best-residential-ip-proxy-service-provider/.
`
`Upon
`
`information and belief, the IP addresses of these residential proxies are assigned by a standard
`
`Internet Service Provider
`
`(ISP)
`
`to a homeowner or other residential or mobile user.
`
`https://ipninja.io/blogs/residential-ip-proxies-vs-datacentre-proxies/.
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` Upon
`
`information and
`
`belief, this residential proxy network is used to access content over the Internet, wherein that
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`content may be divided into portions, each of which includes part of the content and its own content
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`identifier. IP Ninja touts this service as permitting its customers to harvest data over the web via
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`millions of IPs from all over the world touted as “real residential IPs.” https://ipninja.io/sdk. IP
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`Ninja also advertises this service as permitting its customers to select the proxy devices based on
`
`their location in specific countries, states and cities. https://ipninja.io/blogs/mobile-ips-for-ad-
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`verification/. Upon information and belief, IP Ninja pays a premium to its development partners
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`4
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`for proxy devices located in the United States. https://ipninja.io/blogs/monetizing-desktop-
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`software-and-uwp-apps-with-ip-ninjas-sdk/.
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`
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`https://ipninja.io/
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`https://ipninja.io/
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`5
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`https://ipninja.io/
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`https://ipninja.io/
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`6
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`https://ipninja.io/blogs/mobile-ips-for-ad-verification/
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`https://ipninja.io/blogs/why-is-ip-ninja-the-best-residential-ip-proxy-service-provider/
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`7
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`https://ipninja.io/blogs/why-is-ip-ninja-the-best-residential-ip-proxy-service-provider/
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`Upon information and belief, some of these user devices serving as residential proxies (and
`
`associated with respective IP addresses) are located in the Eastern District of Texas. Upon
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`information and belief, on a given day a hundred or more user devices belonging to residents in
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`the Eastern District of Texas are available for use as proxy devices for IP Ninja’s residential proxy
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`service.
`
`14.
`
`Upon information and belief, the residential proxy network used as part of the IP
`
`Ninja service is based upon numerous user devices, each of which is a client device identifiable
`
`over the Internet by an IP address. Upon information and belief, a server (“First Server”) is
`
`operated by IP Ninja and/or a third party having a contractual obligation to IP Ninja to implement
`
`residential proxy network requests sent by IP Ninja. Upon information and belief, whether IP
`
`Ninja owns the First Server and/or contracts with a third-party to operate the First Server, IP Ninja
`
`directs and controls the First Server to implement the IP Ninja residential proxy service.
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`15.
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`Upon information and belief, software (“Server Software”)
`
`is executed that
`
`implements the IP Ninja service. Upon information and belief, IP Ninja directs and controls the
`
`operation of the Server Software to the extent that the Server Software implements the IP Ninja
`
`service. For example, upon information and belief, IP Ninja can direct and control the IP Ninja
`
`service to select residential proxy devices located within a specific country, state or city.
`
`
`
`https://ipninja.io/blogs/mobile-ips-for-ad-verification/
`
`16.
`
`Upon information and belief, each user device in the residential proxy network
`
`sends its respective identifier to the First Server, which stores these identifiers. Upon information
`
`and belief, IP Ninja uses their own servers, but to the extent that IP Ninja has contractual
`
`relationship(s) with one or more third parties that provide server services, IP Ninja directs and/or
`
`controls these third-party servers to implement its residential proxy network for the IP Ninja
`
`service through the third-party servers and user devices included in the residential proxy network.
`
`Upon information and belief, as part of the IP Ninja service, IP Ninja provides a First Server, which
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`9
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`authenticates the user devices of IP Ninja customers and controls the access and operation of
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`requests and responses through the one or more third-party proxy residential networks directed
`
`and controlled by IP Ninja, and is in continuous communication with the Server Software. Upon
`
`information and belief, IP Ninja’s customers directly practice at least claim 81 of the ’044 Patent
`
`and claim 15 of the ’866 Patent by utilizing the IP Ninja’s residential proxy service through their
`
`client devices. IP Ninja also directly practices these claims by implementing customer requests
`
`through its Server Software as part of its IP Ninja service. In addition, upon information and belief,
`
`as IP Ninja knew of the Asserted Patents and had notice that its residential proxy service infringed
`
`these patents, but continued to advertise IP Ninja’s infringing features and enter into contracts with
`
`its customers to provide this service, and IP Ninja intended its customers to implement this
`
`infringing service.
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`https://ipninja.io/
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`10
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`https://ipninja.io/
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`https://ipninja.io/blogs/why-is-ip-ninja-the-best-residential-ip-proxy-service-provider/
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`17.
`
`Upon information and belief, IP Ninja has developed and/or is developing the
`
`software to be used in the user devices as part of the IP Ninja service by integration with different
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`third-party software applications, including at least Aydin Adventure Mobile Apps Love, Girly,
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`Fun Stickers for Wapp WAStickerApps, Pasquale Piccolo Opus Player – WhatsApp Audio Search
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`and Organize, and Sinemus Free Video Dowloader.
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`https://ipninja.io/blogs/app-monetization-ip-ninja-sdk/
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`18.
`
`Upon information and belief, a IP Ninja customer may utilize
`
`the IP Ninja
`
`residential proxy network by sending a request (“First Request”) from the IP Ninja customer’s
`
`device (“First Device”), to the above First Server, which responds by sending the IP address
`
`(“Second Identifier”) corresponding to one of a group of client devices in the proxy network, any
`
`one of which may serve as a proxy device (“Second Device”), back to the First Device.
`
`19.
`
`Upon information and belief, having received the Second Identifier,
`
`the First
`
`Device may then send a request (“Second Request”) to the Second Device for specific Internet
`
`data (“First Content”) identified by an identifier (“Content Identifier”) from a target server
`
`(“Second Server”) identified by its own identifier (“Third Identifier”), which is forwarded by the
`
`Second Device to the Second Server. Upon information and belief, the target Second Server
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`12
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`responds to the forwarded Second Request by sending the First Content to the Second Device,
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`which is then forwarded back to the First Device. Upon information and belief, to the extent that
`
`the requested content may be divided into portions or slices, the IP Ninja customer’s device, which
`
`is a First Device, can construct the content from the plurality of Content Slices. Upon information
`
`and belief, IP Ninja advertises the infringing IP Ninja service, including the specific use of proxy
`
`devices or proxy IPs with the intent that its customers will implement the IP Ninja service to
`
`operate as advertised.
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`https://ipninja.io/
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`13
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`https://ipninja.io/
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`20.
`
`The use of the residential proxy network permits anonymity to IP Ninja customers,
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`for example for engaging in activities such as web crawling without disclosing the customer’s
`
`identity to the targeted web sites.
`
`COUNT I
`(Infringement of the ’044 Patent)
`
`Luminati repeats and re-alleges the allegations contained in paragraphs 1-20 of this
`
`21.
`
`Complaint as if fully set forth herein.
`
`22.
`
`The
`
`’044 Patent entitled
`
`“System and Method
`
`for
`
`Improving
`
`Internet
`
`Communication by Using Intermediate Nodes” was duly and legally issued by the U.S. Patent and
`
`Trademark Office on January 19, 2016, from Application No. 14/468,836 filed on August 26,
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`14
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`
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`2014, claiming priority to provisional applications 61/870,815 filed on August 28, 2013. A true
`
`and accurate copy of the ’044 Patent is attached hereto as Exhibit A.
`
`23.
`
`Each and every claim of the ’044 Patent is valid and enforceable, and each enjoys
`
`a statutory presumption of validity under 35 U.S.C. § 282.
`
`24.
`
`Luminati exclusively owns all rights, title, and interest in and to the ’044 Patent and
`
`possesses the exclusive right of recovery, including
`
`the exclusive right to recover for past
`
`infringement.
`
`25.
`
`Claim 81 of the ’044 Patent recites:
`
`Claim 81. A method for fetching over the Internet a first content, identified by a
`first content identifier, by a first device, identified in the Internet by a first
`identifier, from a second server identified in the Internet by a third identifier
`via a second device identified in the Internet by a second identifier, using a
`first server, the method comprising the steps of:
`(a) sending the first identifier to the first server;
`(b) sending a first request to the first server;
`(c) receiving the second identifier from the first server;
`the second
`(d) sending a second request to the second device using
`identifier, the second request includes the first content identifier and the
`third identifier; and
`(e) receiving the first content from the second device.
`
`
`26.
`
`As described above, upon information and belief, IP Ninja’s proxy residential
`
`network used for the IP Ninja service comprises numerous devices each of which is identifiable
`
`by its own IP address (“identifier”), which are stored on servers through the execution of Server
`
`Software under the control and/or direction of IP Ninja. Consequently, IP Ninja’s IP Ninja proxy
`
`residential network would comprise at least a First Device and a Second Device with their
`
`corresponding First Identifier and Second Identifier and a First Server.
`
`27.
`
`As described, upon information and belief, this network would permit a user to
`
`access Internet content (“First Content”), identifiable by a content identifier such as a URL (“First
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`15
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`Content Identifier”) from a target server (“Second Server”), identifiable by its own corresponding
`
`IP address (“Third Identifier”).
`
`28.
`
`As described, upon information and belief, the IP Ninja customer sends a request
`
`with its corresponding IP address to the “First Server.” At least the IP Ninja customer device can
`
`serve as a “First Device” with the First Server storing the corresponding IP address (“First
`
`Identifier”) of that “First Device.”
`
`29.
`
`As described above, upon information and belief, an IP Ninja customer can utilize
`
`its device to send a request (“First Request”), with at least the IP Ninja customer device serving as
`
`the first device (“First Device”), to the First Server, causing the First Server to respond by sending
`
`the Second Identifier back to the First Device. Upon information and belief, a second request
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`(“Second Request”), comprising a First Content Identifier and a Third Identifier to the Second
`
`Device, is then sent from the First Device to the Second Server using the Second Identifier. Upon
`
`information and belief, the Second Server responds by sending the requested First Content to the
`
`Second Device, which is forwarded back to the First Device.
`
`30.
`
`Upon information and belief, IP Ninja has had actual notice of the ’044 Patent since
`
`at least June 12, 2018, and has known, including by way of communications before and since that
`
`date and this lawsuit, that implementation of its IP Ninja residential proxy service would infringe
`
`at least claim 81 of the ’044 Patent. Despite this knowledge, IP Ninja has advertised these features
`
`of its IP Ninja residential proxy service and entered into service agreements with its customers
`
`with the intent that the customers would implement this service as described above.
`
`31.
`
`IP Ninja has been and is now directly infringing, literally and/or under the doctrine
`
`of equivalents, one or more claims, including at least claim 81 of the ’044 Patent, by implementing
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`its residential proxy service in the United States without authority and/or license from Luminati
`
`and is liable to Luminati under 35 U.S.C. § 271(a).
`
`32.
`
`IP Ninja has been and is now indirectly
`
`infringing, literally and/or under the
`
`doctrine of equivalents, one or more claims, including at least claim 81 of the ’044 Patent, by
`
`providing this residential proxy service to its customers knowing that the use of such service
`
`infringes these claims in the United States without authority and/or license from Luminati and is
`
`liable to Luminati under 35 U.S.C. § 271(b).
`
`33.
`
`As a result of IP Ninja’s infringement of the ’044 Patent, Luminati has suffered and
`
`continues to suffer damages. Thus, Luminati is entitled to recover from IP Ninja the damages
`
`Luminati sustained as a result of IP Ninja’s wrongful and infringing acts in an amount no less than
`
`its lost profits and/or a reasonable royalty, together with interest and costs fixed by this Court under
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`35 U.S.C. § 284.
`
`34.
`
`Luminati has suffered damage because of the infringing activities of IP Ninja, its
`
`officers, agents, servants, employees, associates, partners, and other persons who are in active
`
`concert or participation therewith, and Luminati will continue to suffer irreparable harm for which
`
`there is no adequate remedy at law unless IP Ninja’s infringing activities are preliminarily and
`
`permanently enjoined by this Court.
`
`35.
`
`IP Ninja’s infringement of the ’044 Patent was, is, and continues to be deliberate
`
`and willful because IP Ninja was and is on notice of the ’044 Patent at least as early as June 12,
`
`2018, yet it continued and continues to infringe the ’044 Patent.
`
`COUNT II
`(Infringement of the ’866 Patent)
`
`Luminati repeats and re-alleges the allegations contained in paragraphs 1-35 of this
`
`36.
`
`Complaint as if fully set forth herein.
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`17
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`37.
`
`The
`
`’866 Patent entitled
`
`“System and Method
`
`for
`
`Improving
`
`Internet
`
`Communication by Using Intermediate Nodes” was duly and legally issued by the U.S. Patent and
`
`Trademark Office on August 22, 2017 from Application No. 14/930,894 filed on August 22, 2017,
`
`a divisional of Application No. 14/468,836 that issued as the ’044 Patent, both of which claim
`
`priority to provisional applications 61/870,815 filed on August 28, 2013. A true and accurate copy
`
`of the ’866 Patent is attached hereto as Exhibit B.
`
`38.
`
`Each and every claim of the ’866 Patent is valid and enforceable, and each enjoys
`
`a statutory presumption of validity under 35 U.S.C. § 282.
`
`39.
`
`Luminati exclusively owns all rights, title, and interest in and to the ’866 Patent and
`
`possesses the exclusive right of recovery, including
`
`the exclusive right to recover for past
`
`infringement.
`
`40.
`
`Claim 15 of the ’866 Patent recites:
`
`Claim 15. A method for fetching a content over the Internet from a first server
`identified in the Internet by a second identifier via a group of multiple
`devices, each identified
`in the Internet by an associated group device
`identifier, the method comprising the step of partitioning the content into a
`plurality of content slices, each content slice containing at least part of the
`content, and identified using a content slice identifier, and for each of the
`content slices, comprising the steps of:
`(a) selecting a device from the group;
`(b) sending over the Internet a first request to the selected device using the
`group device identifier of the selected device, the first request including the
`content slice identifier and the second identifier;
`(c) in response to receiving the sent first request by the selected device,
`receiving over the Internet the content slice from the selected device; and
`wherein the method further comprising the step of constructing the content
`from the received plurality of content slices, and
`wherein each of the devices in the group is a client device.
`
`
`41.
`
`As described above, upon information and belief, IP Ninja’s proxy residential
`
`network comprises numerous devices, each of which is a client device identifiable by its own
`
`identifier. Upon information and belief, IP Ninja’s proxy residential network permits IP Ninja’s
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`customers to request content from the customer’s device through the IP Ninja residential proxy
`
`service, which forwards such requests through a proxy residential user device (“Selected Device”)
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`to a target server (“First Server”), which is identifiable by its own IP address (“Second Identifier”).
`
`The Selected Device is selected from a group of client devices (“Group”), each of which has its
`
`own IP address (“Group Device Identifier”). As further described above, this content may be
`
`divided into portions (“Content Slices”) identifiable by their own identifiers (“Content Slice
`
`Identifier”).
`
`42.
`
`As described, upon information and belief, the IP Ninja service permits the IP Ninja
`
`customer to select a proxy user device from the Group and send a request (“First Request”) over
`
`the Internet to the Selected Device using the selected device IP address (“Group Device Identifier
`
`of the Selected Device”). This First Request includes the Content Slice Identifier and Second
`
`Identifier.
`
`43.
`
`As described, upon information and belief, the above Selected Device responds to
`
`the First Request by sending the request to the First Server with the Content Slice Identifier. The
`
`First Server responds by sending the requested Content Slice to the Selected Device, which
`
`forwards the Content Slice through the IP Ninja Gateway to the device of the IP Ninja customer,
`
`which is a client device. The client device of the IP Ninja customer then constructs the content
`
`from the plurality of Content Slices.
`
`44.
`
`IP Ninja has had actual notice of the ’866 Patent since at least May 2018, and has
`
`known, including by way of communications on and since that date and this lawsuit,
`
`that
`
`implementation of its IP Ninja residential proxy service would infringe at least claim 15 of the
`
`’866 Patent. Despite this knowledge, IP Ninja has advertised these features of its IP Ninja
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`residential proxy service and entered into service agreements with its customers with the intent
`
`that the customers would implement this service as described above.
`
`45.
`
`IP Ninja has been and is now directly infringing, literally and/or under the doctrine
`
`of equivalents, one or more claims, including at least claim 15 of the ’866 Patent, by implementing
`
`its residential proxy service in the United States without authority and/or license from Luminati
`
`and is liable to Luminati under 35 U.S.C. § 271(a).
`
`46.
`
`IP Ninja has been and is now indirectly
`
`infringing, literally and/or under the
`
`doctrine of equivalents, one or more claims, including at least claim 15 of the ’866 Patent, by
`
`providing this residential proxy service to its customers knowing that the use of such service
`
`infringes these claims in the United States without authority and/or license from Luminati and is
`
`liable to Luminati under 35 U.S.C. § 271(b).
`
`47.
`
`As a result of IP Ninja’s infringement of the ’866 Patent, Luminati has suffered and
`
`continues to suffer damages. Thus, Luminati is entitled to recover from IP Ninja the damages
`
`Luminati sustained as a result of IP Ninja’s wrongful and infringing acts in an amount no less than
`
`its lost profits and/or a reasonable royalty, together with interest and costs fixed by this Court under
`
`35 U.S.C. § 284.
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`48.
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`Luminati has suffered damage because of the infringing activities of IP Ninja, its
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`officers, agents, servants, employees, associates, partners, and other persons who are in active
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`concert or participation therewith, and Luminati will continue to suffer irreparable harm for which
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`there is no adequate remedy at law unless IP Ninja’s infringing activities are preliminarily and
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`permanently enjoined by this Court.
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`49.
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`IP Ninja’s infringement of the ’866 Patent was, is, and continues to be deliberate
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`and wilfull because IP Ninja was and is on notice of the ’866 Patent at least as early as May 2018,
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`yet it continued and continues to infringe the ’866 Patent.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff Luminati respectfully requests that this Court enter:
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`A. A judgment that each of the Asserted Patents is valid and enforceable.
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`B. A judgment in favor of Luminati that the Defendant has and is infringing the Asserted
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`Patents;
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`C. A judgment declaring Defendant’s infringement to be willful.
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`D. A judgment declaring that this case is exceptional within the meaning of 35 U.S.C. §
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`285;
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`E. A permanent injunction enjoining Defendant, its officers, directors, agents, servants,
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`employees, associates, partners, customers, server owners and/or operators, and other
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`persons who are in active concert or participation with IP Ninja, from infringing the
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`Asserted Patents and/or such other equitable relief the Court determines is warranted
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`in this case;
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`F. A judgment and order requiring
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`the Defendant
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`to pay to Luminati
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`its damages,
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`enhanced damages, costs, expenses, prejudgment and post-judgment
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`interest, and
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`attorneys’ fees, if applicable, for the Defendant’s infringement of the Asserted Patents
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`as provided under 35 U.S.C. §284 and/or §285, and an accounting of ongoing post-
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`judgment infringement; and
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`21
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`G. Any and all other relief, at law or in equity, that this Court deems just or proper.
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`DEMAND FOR JURY TRIAL
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`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Luminati hereby demands
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`a trial by jury of all issues so triable.
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`Dated: May 24, 2019
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`Respectfully submitted,
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`By: /s/ Korula T. Cherian__
`Elizabeth L. DeRieux
`State Bar No. 05770585
`Capshaw DeRieux, LLP
`114 E. Commerce Ave.
`Gladewater, TX 75647
`Telephone: 903-845-5770
`ederieux@capshawlaw.com
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`Korula T. Cherian
`RuyakCherian LLP
`1936 University Ave, Ste. 350
`Berkeley, CA 94702
`(510) 944-0190
`Email: sunnyc@ruyakcherian.com
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`Attorneys for Plaintiff
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`22
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