Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 1 of 13 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`
`
`
`§
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`§
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`PARTHENON UNIFIED MEMORY
`ARCHITECTURE LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`HUAWEI TECHNOLOGIES CO., LTD,
`HUAWEI TECHNOLOGIES USA, INC.,
`AND HUAWEI DEVICE USA, INC.
`
`
`Defendants.
`
`
`Case No. 2:14-cv-00687
`
`
`JURY TRIAL REQUESTED
`
`
`
`
`
`
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC’S
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`PARTHENON UNIFIED MEMORY
`ARCHITECTURE LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`HUAWEI TECHNOLOGIES CO., LTD,
`HUAWEI TECHNOLOGIES USA, INC.,
`AND HUAWEI DEVICE USA, INC.
`
`
`Defendants.
`
`
`Case No. 2:14-cv-00687
`
`
`JURY TRIAL REQUESTED
`
`
`
`
`
`
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC’S
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 2 of 13 PageID #: 2
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`Plaintiff Parthenon Unified Memory Architecture LLC (“PUMA” or “Plaintiff”) hereby
`
`submits
`
`this Complaint against Defendants Huawei Technologies Co., LTD, Huawei
`
`Technologies USA, Inc., and Huawei Device USA, Inc. (collectively “Huawei” or “Defendants”)
`
`and states as follows:
`
`THE PARTIES
`
`1.
`
`PUMA is a Texas limited liability company, having a principal place of business
`
`at 2400 Dallas Parkway, Suite 200, Plano, Texas 75093.
`
`2.
`
`On information and belief, Defendant Huawei Technologies Co., LTD is a
`
`corporation organized and existing under the laws of the People’s Republic of China, having a
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`principal place of business at Huawei Industrial Base, Bantian, Longgang, Shenzhen,
`
`Guangdong, People’s Republic of China, 518129.
`
`3.
`
`On information and belief, Defendant Huawei Technologies USA, Inc. is
`
`incorporated under the laws of Texas, having a principal place of business at 5700 Tennyson
`
`Parkway, Suite 500, Plano, Texas 75024.
`
`4.
`
`On information and belief, Defendant Huawei Device USA, Inc. is incorporated
`
`under the laws of Texas, having a principal place of business at 5700 Tennyson Parkway, Suite
`
`500, Plano, Texas 75024.
`
`JURISDICTION AND VENUE
`
`5.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a) because this action arises under the patent laws of the United States, 35 U.S.C. §§ 101 et
`
`seq.
`
`6.
`
`Venue is proper in this federal district pursuant to 28 U.S.C. §§1391(b)–(c) and
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`1400(b) in that Defendants have done business in this District, have committed acts of
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`1
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 3 of 13 PageID #: 3
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`infringement in this District, and continue to commit acts of infringement in this District,
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`entitling PUMA to relief.
`
`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 5,812,789
`
`7.
`
`On September 22, 1998, the United States Patent and Trademark Office
`
`(“USPTO”) duly and legally issued United States Patent No. 5,812,789 (“the ’789 Patent”),
`
`entitled “Video And/Or Audio Decompression And/Or Compression Device That Shares a
`
`Memory Interface.” PUMA holds all rights, title, and interest in and to the ’789 Patent. Huawei
`
`is not licensed to the ’789 Patent, yet Huawei knowingly, actively, and lucratively practices the
`
`patents.
`
`8.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’789 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’789 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`9.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’789 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`10.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’789 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`2
`
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 4 of 13 PageID #: 4
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 5,960,464
`
`11.
`
`On September 28, 1999, the USPTO duly and legally issued United States Patent
`
`No. 5,960,464 (“the ’464 Patent”), entitled “Memory Sharing Architecture For A Decoding In A
`
`Computer System.” PUMA holds all rights, title, and interest in and to the ’464 Patent. Huawei
`
`is not licensed to the ’464 Patent, yet Huawei knowingly, actively, and lucratively practices the
`
`patents.
`
`12.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’464 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’464 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`13.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’464 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`14.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’464 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`3
`
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 5 of 13 PageID #: 5
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT III: INFRINGEMENT OF U.S. PATENT NO. 6,058,459
`
`15.
`
`On May 2, 2000, the USPTO duly and legally issued United States Patent No.
`
`6,058,459 (“the ’459 Patent”), entitled “Video/Audio Decompression/Compression Device
`
`Including An Arbiter And Method For Accessing A Shared Memory.” PUMA holds all rights,
`
`title, and interest in and to the ’459 Patent. Huawei is not licensed to the ’459 Patent, yet Huawei
`
`knowingly, actively, and lucratively practices the patents.
`
`16.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’459 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’459 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`17.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’459 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`18.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’459 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`4
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 6 of 13 PageID #: 6
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 6,427,194
`
`19.
`
`On July 30, 2002, the USPTO duly and legally issued United States Patent No.
`
`6,427,194 (“the ’194 Patent”), entitled “Electronic System And Method For Display Using A
`
`Decoder And Arbiter To Selectively Allow Access To A Shared Memory.” PUMA holds all
`
`rights, title, and interest in and to the ’194 Patent. Huawei is not licensed to the ’194 Patent, yet
`
`Huawei knowingly, actively, and lucratively practices the patents.
`
`20.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’194 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’194 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`21.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’194 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`22.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’194 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`5
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 7 of 13 PageID #: 7
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT V: INFRINGEMENT OF U.S. PATENT NO. 7,321,368
`
`23.
`
`On January 22, 2008, the USPTO duly and legally issued United States Patent No.
`
`7,321,368 (“the ’368 Patent”), entitled “Electronic System And Method For Display Using A
`
`Decoder And Arbiter To Selectively Allow Access To A Shared Memory.” PUMA holds all
`
`rights, title, and interest in and to the ’368 Patent. Huawei is not licensed to the ’368 Patent, yet
`
`Huawei knowingly, actively, and lucratively practices the patents.
`
`24.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’368 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’368 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`25.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’368 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`26.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’368 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`6
`
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 8 of 13 PageID #: 8
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT VI: INFRINGEMENT OF U.S. PATENT NO. 7,542,045
`
`27.
`
`On June 2, 2009, the USPTO duly and legally issued United States Patent No.
`
`7,542,045 (“the ’045 Patent”), entitled “Electronic System And Method For Display Using A
`
`Decoder And Arbiter To Selectively Allow Access To A Shared Memory.” PUMA holds all
`
`rights, title, and interest in and to the ’045 Patent. Huawei is not licensed to the ’045 Patent, yet
`
`Huawei knowingly, actively, and lucratively practices the patents.
`
`28.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’045 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’045 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`29.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’045 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`30.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’045 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`7
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 9 of 13 PageID #: 9
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT VII: INFRINGEMENT OF U.S. PATENT NO. 7,777,753
`
`31.
`
`On August 17, 2010, the USPTO duly and legally issued United States Patent No.
`
`7,777,753 (“the ’753 Patent”), entitled “Electronic System And Method For Selectively
`
`Allowing Access To A Shared Memory.” PUMA holds all rights, title, and interest in and to the
`
`’753 Patent. Huawei is not licensed to the ’753 Patent, yet Huawei knowingly, actively, and
`
`lucratively practices the patents.
`
`32.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’753 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’753 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`33.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’753 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`34.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’753 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`8
`
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 10 of 13 PageID #: 10
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT VIII: INFRINGEMENT OF U.S. PATENT NO. 8,054,315
`
`35.
`
`On November 8, 2011, the USPTO duly and legally issued United States Patent
`
`No. 8,054,315 (“the ’315 Patent”), entitled “Electronic System And Method For Selectively
`
`Allowing Access To A Shared Memory.” PUMA holds all rights, title, and interest in and to the
`
`’315 Patent. Huawei is not licensed to the ’315 Patent, yet Huawei knowingly, actively, and
`
`lucratively practices the patents.
`
`36.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’315 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’315 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`37.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’315 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`38.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’315 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`9
`
`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 11 of 13 PageID #: 11
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`COUNT IX: INFRINGEMENT OF U.S. PATENT NO. 8,681,164
`
`39.
`
`On March 25, 2014, the USPTO duly and legally issued United States Patent No.
`
`8,681,164 (“the ’164 Patent”), entitled “Electronic System And Method For Selectively
`
`Allowing Access To A Shared Memory.” PUMA holds all rights, title, and interest in and to the
`
`’164 Patent. Huawei is not licensed to the ’164 Patent, yet Huawei knowingly, actively, and
`
`lucratively practices the patents.
`
`40.
`
`Upon information and belief, Huawei has infringed directly and continues to
`
`infringe directly the ’164 Patent. The infringing acts include, but are not limited to, the
`
`manufacture, use, sale, importation, and/or offer for sale of products and/or methods
`
`encompassed by the claims of the ’164 Patent. Huawei’s infringing products include, but are not
`
`limited to, at least the Huawei Ascend, Huawei Mercury, Huawei Mercury Ice, Huawei
`
`myTouch, Huawei P1, Huawei Unite, Huawei Valiant, Huawei Vitria, and Huawei Comet.
`
`41.
`
`The acts of infringement by Huawei have caused damage to PUMA, and PUMA
`
`is entitled to recover from Huawei the damages sustained by PUMA as a result of Huawei’s
`
`wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive
`
`rights under the ’164 Patent by Huawei has damaged and will continue to damage PUMA,
`
`causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this
`
`Court.
`
`42.
`
`At least as early as its receipt of this Complaint, Huawei has had knowledge of the
`
`’164 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue
`
`
`
`10
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`
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 12 of 13 PageID #: 12
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`of willfulness and reserves the right to seek a willfulness finding and increased damages under
`
`35 U.S.C. § 284 and to attorneys’ fees and costs incurred in prosecuting this action under 35
`
`U.S.C. § 285.
`
`JURY DEMAND
`
`43.
`
`PUMA hereby demands a trial by jury on all issues.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, PUMA requests entry of judgment in its favor and against Huawei as
`
`follows:
`
`a. A declaration that Huawei has infringed and is infringing the ’789, ’464, ’459, ’194,
`
`’368, ’045, ’753, ’315, and ’164 Patents;
`
`b. An Order permanently enjoining Huawei, its officers, agents, employees, and those
`
`acting in privity with it, from further direct and/or indirect infringement of the ’789,
`
`’464, ’459, ’194, ’368, ’045, ’753, ’315, and ’164 Patents;
`
`c. An award of damages to PUMA arising out of Huawei’s infringement of the ’789,
`
`’464, ’459, ’194, ’368, ’045, ’753, ’315, and ’164 Patents, including enhanced
`
`damages pursuant to 35 U.S.C. § 284, together with prejudgment and post-judgment
`
`interest, in an amount according to proof;
`
`d. An award of attorneys’ fees pursuant to 35 U.S.C. § 285 or as otherwise permitted by
`
`law; and,
`
`e. Granting PUMA its costs and further relief as the Court may deem just and proper.
`
`
`
`
`
`
`
`
`11
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`Case 2:14-cv-00687-JRG-RSP Document 1 Filed 06/12/14 Page 13 of 13 PageID #: 13
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`Dated: June 12, 2014
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Demetrios Anaipakos
`Demetrios Anaipakos
`Texas Bar No. 00793258
`danaipakos@azalaw.com
`Amir Alavi
`Texas Bar No. 00793239
`aalavi@azalaw.com
`Michael McBride
`Texas Bar No. 24065700
`mmcbride@azalaw.com
`Alisa A. Lipski
`Texas Bar No. 24141345
`alipski@azalaw.com
`Justin Chen
`Texas Bar No. 24074204
`jchen@azalaw.com
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI & MENSING P.C.
`1221 McKinney Street, Suite 3460
`Houston, TX 77010
`Telephone: 713-655-1101
`Facsimile: 713-655-0062
`
`T. John Ward, Jr.
`Texas Bar No. 00794818
`jw@wsfirm.com
`WARD & SMITH LAW FIRM
`P.O. Box 1231
`Longview, TX 75606-1231
`Telephone: 909-757-6400
`Facsimile: 909-757-2323
`
`ATTORNEYS FOR PLAINTIFF
`PARTHENON UNIFIED MEMORY
`ARCHITECTURE LLC
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`12
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