Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 1 of 14
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`SCRAMOGE TECHNOLOGY LTD.,
`
`Plaintiff,
`
`Case No. 6:21-cv-00454-ADA
`
`v.
`
`JURY TRIAL DEMANDED
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Defendants.
`
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST SAMSUNG ELECTRONICS CO., LTD AND SAMSUNG ELECTRONICS
`AMERICA, INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiff Scramoge Technology Limited (“Plaintiff” or
`
`“Scramoge”) makes the following allegations against Defendants Samsung Electronics Co., Ltd.
`
`and Samsung Electronics America, Inc. (collectively, “Defendants” or “Samsung”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Samsung’s unlawful infringement of the following
`
`United States patents owned by Plaintiff, which relate to improvements in wireless charging of
`
`mobile devices: United States Patent Nos. 9,553,476 (“the ’476 Patent”), 9,825,482 (“the ’482
`
`Patent”), 9,997,962 (“the ’962 Patent”), 9,843,215 (“the ’215 Patent”), 10,367,370 (“the ’370
`
`Patent”), and 10,424,941 (“the ’941 Patent”) (collectively, the “Asserted Patents”).
`
`PARTIES
`
`2.
`
`Plaintiff Scramoge Technology Limited is a limited liability company organized
`
`and existing under the law of Ireland, with its principal place of business at The Hyde Building,
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 1
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`

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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 2 of 14
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`Suite 23, The Park, Carrickmines, Dublin 18, Ireland. Scramoge is the sole owner by assignment
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`of all right, title, and interest in the Asserted Patents, including the right to recover damages for
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`past, present, and future infringement.
`
`3.
`
`On information and belief, Defendant Samsung Electronics Co., Ltd. is a
`
`corporation organized under the laws of South Korea, with its principal place of business at 129
`
`Samsung-Ro, Maetan-3dong, Yeongtong-gu, Suwon-si, Gyeonggi-do, 443-742, South Korea.
`
`4.
`
`On information and belief, Defendant Samsung Electronics America, Inc., a wholly
`
`owned subsidiary of Samsung Electronics Co., Ltd., is a corporation organized under the laws of
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`the State of New York, with its principal place of business at 85 Challenger Rd., Ridgefield Park,
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`New Jersey 07660.
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`JURISDICTION AND VENUE
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`5.
`
`This action arises under the patent laws of the United States, Title 35 of the United
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`States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a).
`
`6.
`
`This Court has personal jurisdiction over Samsung in this action because Samsung
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`has committed acts within this District giving rise to this action and has established minimum
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`contacts with this forum such that the exercise of jurisdiction over Samsung would not offend
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`traditional notions of fair play and substantial justice. Samsung, directly and through subsidiaries
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`or intermediaries, has committed and continues to commit acts of infringement in this District by,
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`among other things, importing, offering to sell, and selling products that infringe the Asserted
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`Patents.
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`7.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). Defendant
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`Samsung Electronics America, Inc. is registered to do business in Texas. Additionally, upon
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`
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`2
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 2
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 3 of 14
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`information and belief, Defendants have transacted business in this District and have committed
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`acts of direct and indirect infringement in this District by, among other things, making, using,
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`offering to sell, selling, and importing products that infringe the Asserted Patents. Defendants
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`have regular and established places of businesses in this District, including at 12100 Samsung
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`Boulevard, Austin, Texas 78754; 7300 Ranch Road 2222, Austin, Texas 78730; and 1700 Scenic
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`Loop, Round Rock, Texas 78681. See Exhibits 1-3. Additionally, venue is proper as to a foreign
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`defendant in any district. 28 U.S.C. § 1391(c)(3); In re HTC Corp., 889 F.3d 1349 (Fed. Cir. 2018).
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`Defendant Samsung Electronics Co., Ltd. is a foreign corporation organized under the laws of
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`Korea, with a principal place of business in Korea.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 9,553,476
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`8.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
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`9.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 9,553,476, entitled
`
`“Antenna assembly and method for manufacturing same.” The ’476 Patent was duly and legally
`
`issued by the United States Patent and Trademark Office on January 24, 2017. A true and correct
`
`copy of the ’476 Patent is attached as Exhibit 4.
`
`10.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation the Samsung Galaxy sub-models S6 Edge,
`
`S7, S7 Edge, S8, Note 8, S9, Note 9, S9+, S10e, S10, S10+, S10 5G, Note 10, Note 10+, Note 10+
`
`5G, S20, S20 5G, S20+, S20+ 5G, S20 Ultra LTE/5G, Note 20, Note 20 5G, Note 20 Ultra 5G,
`
`S21, S21+, S21 Ultra, Fold, and Z Fold2 5G (“Accused Products”), that directly infringe, literally
`
`
`
`3
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 3
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 4 of 14
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`and/or under the doctrine of equivalents, one or more claims of the ’476 Patent. Identification of
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`the accused products will be provided in Plaintiff’s infringement contentions pursuant to the
`
`Court’s scheduling order.
`
`11.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’476
`
`Patent. A claim chart comparing exemplary independent claim 1 of the ’476 Patent to
`
`representative Accused Products is attached as Exhibit 5.
`
`12.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’476
`
`Patent pursuant to 35 U.S.C. § 271.
`
`13.
`
`As a result of Samsung’s infringement of the ’476 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`14.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’476 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 9,825,482
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`15.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`16.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 9,825,482, entitled
`
`
`
`4
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 4
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 5 of 14
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`“Electromagnetic booster for wireless charging and method of manufacturing the same.” The ’482
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`Patent was duly and legally issued by the United States Patent and Trademark Office on November
`
`21, 2017. A true and correct copy of the ’482 Patent is attached as Exhibit 6.
`
`17.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation Samsung Galaxy sub-models S8, Note 8,
`
`S9, Note 9, S9+, S10e, S10, S10+, S10 5G, Note 10, Note 10+, Note 10+ 5G, S20, S20 5G, S20+,
`
`S20+ 5G, S20 Ultra LTE/5G, Note 20, Note 20 5G, Note 20 Ultra 5G, S21, S21+, S21 Ultra, Fold,
`
`and Z Fold2 5G (“Accused Products”), that directly infringe, literally and/or under the doctrine of
`
`equivalents, one or more claims of the ’482 Patent. Identification of the accused products will be
`
`provided in Plaintiff’s infringement contentions pursuant to the Court’s scheduling order.
`
`18.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’482
`
`Patent. A claim chart comparing exemplary independent claim 16 of the ’482 Patent to
`
`representative Accused Products is attached as Exhibit 7.
`
`19.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’482
`
`Patent pursuant to 35 U.S.C. § 271.
`
`20.
`
`As a result of Samsung’s infringement of the ’482 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`21.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’482 Patent,
`
`
`
`5
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 5
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 6 of 14
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`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`COUNT III
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`INFRINGEMENT OF U.S. PATENT NO. 9,997,962
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`22.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`23.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 9,997,962, entitled
`
`“Receiving antenna and wireless power receiving device including the same.” The ’962 Patent
`
`was duly and legally issued by the United States Patent and Trademark Office on June 12, 2018.
`
`A true and correct copy of the ’962 Patent is attached as Exhibit 8.
`
`24.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation the Samsung Galaxy sub-models S6 Edge,
`
`S7, S7 Edge, S8, Note 8, S9, Note 9, S9+, S10e, S10, S10+, S10 5G, Note 10, Note 10+, Note 10+
`
`5G, S20, S20 5G, S20+, S20+ 5G, S20 Ultra LTE/5G, Note 20, Note 20 5G, Note 20 Ultra 5G,
`
`S21, S21+, S21 Ultra, Fold, and Z Fold2 5G (“Accused Products”), that directly infringe, literally
`
`and/or under the doctrine of equivalents, one or more claims of the ’962 Patent. Identification of
`
`the accused products will be provided in Plaintiff’s infringement contentions pursuant to the
`
`Court’s scheduling order.
`
`25.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’962
`
`Patent. A claim chart comparing exemplary independent claim 1 of the ’962 Patent to
`
`representative Accused Products is attached as Exhibit 9.
`
`
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`6
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 6
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 7 of 14
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`26.
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`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’962
`
`Patent pursuant to 35 U.S.C. § 271.
`
`27.
`
`As a result of Samsung’s infringement of the ’962 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`28.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’962 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`COUNT IV
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`INFRINGEMENT OF U.S. PATENT NO. 9,843,215
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`29.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`30.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 9,843,215, entitled
`
`“Wireless charging and communication board and wireless charging and communication device.”
`
`The ’215 Patent was duly and legally issued by the United States Patent and Trademark Office on
`
`December 12, 2017. A true and correct copy of the ’215 Patent is attached as Exhibit 10.
`
`31.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation the Samsung Galaxy sub-models S6 Edge,
`
`S7, S7 Edge, S8, Note 8, S9, Note 9, S9+, S10e, S10, S10+, S10 5G, Note 10, Note 10+, Note 10+
`
`
`
`7
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 7
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 8 of 14
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`5G, S20, S20 5G, S20+, S20+ 5G, S20 Ultra LTE/5G, Note 20, Note 20 5G, Note 20 Ultra 5G,
`
`S21, S21+, S21 Ultra, Fold, and Z Fold2 5G (“Accused Products”), that directly infringe, literally
`
`and/or under the doctrine of equivalents, one or more claims of the ’215 Patent. Identification of
`
`the accused products will be provided in Plaintiff’s infringement contentions pursuant to the
`
`Court’s scheduling order.
`
`32.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’215
`
`Patent. A claim chart comparing exemplary independent claim 1 of the ’215 Patent to
`
`representative Accused Products is attached as Exhibit 11.
`
`33.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’215
`
`Patent pursuant to 35 U.S.C. § 271.
`
`34.
`
`As a result of Samsung’s infringement of the ’215 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`35.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’215 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
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`COUNT V
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`INFRINGEMENT OF U.S. PATENT NO. 10,367,370
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`36.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`
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`8
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 8
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 9 of 14
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`37.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 10,367,370, entitled
`
`“Wireless charging and communication board and wireless charging and communication device.”
`
`The ’370 Patent was duly and legally issued by the United States Patent and Trademark Office on
`
`July 30, 2019. A true and correct copy of the ’370 Patent is attached as Exhibit 12.
`
`38.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation the Samsung Galaxy sub-models S6 Edge,
`
`S7, S7 Edge, S8, Note 8, S9, Note 9, S9+, S10e, S10, S10+, S10 5G, Note 10, Note 10+, Note 10+
`
`5G, S20, S20 5G, S20+, S20+ 5G, S20 Ultra LTE/5G, Note 20, Note 20 5G, Note 20 Ultra 5G,
`
`S21, S21+, S21 Ultra, Fold, and Z Fold2 5G (“Accused Products”), that directly infringe, literally
`
`and/or under the doctrine of equivalents, one or more claims of the ’370 Patent. Identification of
`
`the accused products will be provided in Plaintiff’s infringement contentions pursuant to the
`
`Court’s scheduling order.
`
`39.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’370
`
`Patent. A claim chart comparing exemplary independent claim 1 of the ’370 Patent to
`
`representative Accused Products is attached as Exhibit 13.
`
`40.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’370
`
`Patent pursuant to 35 U.S.C. § 271.
`
`41.
`
`As a result of Samsung’s infringement of the ’370 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`
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`9
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 9
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 10 of 14
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`42.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’370 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`COUNT VI
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`INFRINGEMENT OF U.S. PATENT NO. 10,424,941
`
`43.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`44.
`
`Plaintiff owns by assignment all rights, title, and interest, including the right to
`
`recover damages for past, present, and future infringement, in U.S. Patent No. 10,424,941, entitled
`
`“Wireless power transmitting apparatus and wireless power receiving apparatus.” The ’941 Patent
`
`was duly and legally issued by the United States Patent and Trademark Office on September 24,
`
`2019. A true and correct copy of the ’941 Patent is attached as Exhibit 14.
`
`45.
`
`On information and belief, Samsung makes, uses, offers for sale, sells, and/or
`
`imports certain products, including without limitation the Samsung Galaxy Watch, Watch Active,
`
`Watch Active 2, and Watch 3 (“Accused Products”), that directly infringe, literally and/or under
`
`the doctrine of equivalents, one or more claims of the ’941 Patent. Identification of the accused
`
`products will be provided in Plaintiff’s infringement contentions pursuant to the Court’s
`
`scheduling order.
`
`46.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’941
`
`Patent. A claim chart comparing exemplary independent claims 1 and 4 of the ’941 Patent to
`
`representative Accused Products is attached as Exhibit 15.
`
`
`
`10
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 10
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`47.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Samsung has injured Plaintiff and is liable for infringement of the ’941
`
`Patent pursuant to 35 U.S.C. § 271.
`
`48.
`
`As a result of Samsung’s infringement of the ’941 Patent, Plaintiff is entitled to
`
`monetary damages (past, present, and future) in an amount adequate to compensate for Samsung’s
`
`infringement, but in no event less than a reasonable royalty for the use made of the invention by
`
`Samsung, together with interest and costs as fixed by the Court.
`
`49.
`
`Samsung’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’941 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff respectfully requests that this Court enter:
`
`a.
`
`A judgment in favor of Plaintiff that Samsung has infringed, either literally and/or
`
`under the doctrine of equivalents, the ’476, ’482, ’962, ’215, ’370, and ’941 Patents;
`
`b.
`
`A permanent injunction prohibiting Samsung from further acts of infringement of
`
`the ’476, ’482, ’962, ’215, ’370, and ’941 Patents;
`
`c.
`
`A judgment and order requiring Samsung to pay Plaintiff its damages (past, present,
`
`and future), costs, expenses, and pre-judgment and post-judgment interest for Samsung’s
`
`infringement of the ’476, ’482, ’962, ’215, ’370, and ’941 Patents;
`
`d.
`
`A judgment and order requiring Samsung to pay Plaintiff compulsory ongoing
`
`licensing fees, as determined by the Court in equity.
`
`e.
`
`A judgment and order requiring Samsung to provide an accounting and to pay
`
`
`
`11
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 11
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 12 of 14
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`supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment
`
`interest and compensation for infringing products released after the filing of this case that are not
`
`colorably different from the accused products;
`
`f.
`
`A judgment and order finding that this is an exceptional case within the meaning
`
`of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against Samsung; and
`
`g.
`
`Any and all other relief as the Court may deem appropriate and just under the
`
`circumstances.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
`
`any issues so triable by right.
`
`
`
`
`Dated: June 22, 2021
`
`
`
`
`
`Respectfully submitted,
`
`/s/Reza Mirzaie
`
`
`
`
`
`
`
`
`
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`bledahl@raklaw.com
`James A. Milkey (CA SBN 281213)
`jmilkey@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`cconkle@raklaw.com
`Jonathan Ma (CA SBN 312773)
`jma@raklaw.com
`Brett E. Cooper (NY SBN 4011011)
`bcooper@raklaw.com
`Drew B. Hollander (NY SBN 5378096)
`dhollander@raklaw.com
`Seth Hasenour (TX SBN 24059910)
`shasenour@raklaw.com
`RUSS AUGUST & KABAT
`
`
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`12
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 12
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 13 of 14
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`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`
`Attorneys for Plaintiff Scramoge Technology
`Limited
`
`
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`13
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 13
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`Case 6:21-cv-00454-ADA Document 18 Filed 06/22/21 Page 14 of 14
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`was electronically filed with the CM/ECF system per LR 5, and that all interested parties are being
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`served with a true and correct copy of these documents via the CM/ECF system.
`
`/s/ Reza Mirzaie
` Reza Mirzaie
`
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`14
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`Scramoge Technology Ltd.
`Ex. 2022 - Page 14
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