Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 1 of 20 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Civil Action No. 2:16-cv-741
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`PATENT CASE
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`JURY TRIAL DEMANDED
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`UNILOC USA, INC. and
`UNILOC LUXEMBOURG, S.A.,
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`Plaintiffs,
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`v.
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`ADP, LLC,
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`Defendant.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiffs, Uniloc USA, Inc. and Uniloc Luxembourg, S.A. (together “Uniloc”), as and
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`for their complaint against defendant, ADP, LLC (“ADP”), allege as follows:
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`THE PARTIES
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`1.
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`Uniloc USA, Inc. (“Uniloc USA”) is a Texas corporation having a principal place
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`of business at Legacy Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024.
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`Uniloc also maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
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`2.
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`Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) is a Luxembourg public limited
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`liability company having a principal place of business at 15, Rue Edward Steichen, 4th Floor, L-
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`2540, Luxembourg (R.C.S. Luxembourg B159161).
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`3.
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`Uniloc Luxembourg owns a number of patents in the field of application
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`management in a computer network.
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`4.
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`Upon information and belief, ADP is a Delaware corporation having a principal
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`place of business in Roseland, New Jersey and offering its products, including those accused
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`06096768
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 2 of 20 PageID #: 2
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`herein of infringement, to customers and/or potential customers located in Texas and in the
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`judicial Eastern District of Texas. ADP may be served with process through its registered agent
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`in Texas: CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`JURISDICTION AND VENUE
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`5.
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`Uniloc brings this action for patent infringement under the patent laws of the
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`United States, 35 U.S.C. § 271 et seq. This Court has subject matter jurisdiction pursuant to 28
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`U.S.C. §§ 1331, 1338(a) and 1367
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`6.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(c) and
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`1400(b). Upon information and belief, ADP is deemed to reside in this judicial district, has
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`committed acts of infringement in this judicial district, and/or has purposely transacted business
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`involving the accused products in this judicial district, including sales to one or more customers
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`in Texas.
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`7.
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`ADP is subject to this Court’s jurisdiction pursuant to due process and/or the
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`Texas Long Arm Statute due at least to its substantial business in this State and judicial district,
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`including: (A) at least part of its past infringing activities, (B) regularly doing or soliciting
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`business in Austin, Dallas, El Paso, Houston and San Antonio, Texas and/or (C) engaging in
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`persistent conduct and/or deriving substantial revenue from goods and services provided to
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`customers in Texas.
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`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 6,324,578)
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`Uniloc incorporates paragraphs 1-7 above by reference.
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`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,324,578
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`8.
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`9.
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`(“the ’578 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
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`PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON
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`2
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`

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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 3 of 20 PageID #: 3
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`A NETWORK that issued on November 27, 2001. A true and correct copy of the ’578 Patent is
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`attached as Exhibit A hereto.
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`10.
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`Uniloc USA is the exclusive licensee of the ’578 Patent with ownership of all
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to
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`enforce, sue and recover past damages for the infringement thereof.
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`11.
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`Upon information and belief, the following describes, at least in part, how ADP’s
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`portal works:
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`12.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`13.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`3
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`14.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`15.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`4
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`16.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`17.
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`Upon information and belief, the following describes, at least in part, how the
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`
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`ADP portal works:
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`18.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`5
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`19.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`20.
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`Upon information and belief, the following describes, at least in part, how the
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`
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`ADP portal works:
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`21.
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`Upon information and belief, the following describes, at least in part, how the
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`
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`ADP portal works:
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`6
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`22.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`23.
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`Upon information and belief, the following describes, at least in part, how the
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`
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`ADP portal works:
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`24.
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`Upon information and belief, the following describes, at least in part, how the
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`
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`ADP portal works:
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`25.
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`Upon information and belief, the following describes, at least in part, how the
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`ADP portal works:
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`7
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 8 of 20 PageID #: 8
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`26.
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`Upon information and belief, the following describes, at least in part, the ADP
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`portal license:
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`27.
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`ADP has directly infringed, and continues to directly infringe one or more claims
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`of the ’578 Patent in this judicial district and elsewhere in Texas, including at least claims 1-8,
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`10-13, 15, 17-24, 26-29, 31-39, 41-42, and 46 literally and/or under the doctrine of equivalents,
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`by or through making, using, importing, offering for sale and/or selling the ADP portal during
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`the pendency of the ’578 Patent which software and associated backend server architecture inter
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`alia allows for installing application programs having a plurality of configurable preferences and
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`authorized users on a network, distributing an application launcher program to a user, the user
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`obtaining a set of configurable preferences, obtaining an administrator set of configurable
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`preferences and executing the application program using the user and administrator sets of
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`configurable preferences responsive to a request from a user.
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`8
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`28.
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`In addition, should the ADP portal be found to not literally infringe the asserted
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`claims of the ’578 Patent, the product would nevertheless infringe the asserted claims of the ’578
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`Patent. More specifically, the accused software/system performs substantially the same function
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`(making computer games available for digital download/management), in substantially the same
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`way (via a client/server environment), to yield substantially the same result (distributing
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`application programs to a target on-demand server on a network). ADP would thus be liable for
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`direct infringement under the doctrine of equivalents.
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`29.
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`ADP has indirectly infringed and continues to indirectly infringe at least claims 1-
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`8, 10-13, 15, 17-24, 26-29, 31-39, 41-42, and 46 of the ’578 Patent in this judicial district and
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`elsewhere in the United States by, among other things, actively inducing the using, offering for
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`sale, selling, or importing Workforce Now. ADP’s customers who use the ADP portal in
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`accordance with ADP’s instructions directly infringe one or more of the forgoing claims of the
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`’578 Patent in violation of 35 U.S.C. § 271. ADP directly and/or indirectly instructs its
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`customers through training videos, demonstrations, brochures, installation and/or user guides,
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`such as those located at the following:
`
`•
`
`•
`
`•
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`•
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`www.adp.com
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`www.my.adp.com
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`https://portal.adp.com
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`www.youtube.com
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`ADP is thereby liable for infringement of the ’578 Patent under 35 U.S.C. § 271(b).
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`30.
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`ADP has indirectly infringed and continues to indirectly infringe at least claims 1-
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`8, 10-13, 15, 17-24, 26-29, 31-39, 41-42, and 46 of the ’578 Patent in this judicial district and
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`elsewhere in the United States by, among other things, contributing to the direct infringement by
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`9
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`

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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 10 of 20 PageID #: 10
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`others including, without limitation customers using the ADP portal, by making, offering to sell,
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`selling and/or importing into the United States, a component of a patented machine, manufacture
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`or combination, or an apparatus for use in practicing a patented process, constituting a material
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`part of the invention, knowing the same to be especially made or especially adapted for use in
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`infringing the ’578 Patent and not a staple article or commodity of commerce suitable for
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`substantial non-infringing use.
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`31.
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`For example, the ADP portal is a component of a patented machine, manufacture,
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`or combination, or an apparatus for use in practicing a patent process. Furthermore, the ADP
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`portal is a material part of the claimed inventions and upon information and belief is not a staple
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`article or commodity of commerce suitable for substantial non-infringing use. ADP is, therefore,
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`liable for infringement under 35 U.S.C. § 271(c).
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`32.
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`ADP will have been on notice of the ’578 Patent since, at the latest, the service of
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`this complaint upon ADP. By the time of trial, ADP will have known and intended (since
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`receiving such notice) that its continued actions would actively induce, and contribute to, the
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`infringement of one or more of claims 1-8, 10-13, 15, 17-24, 26-29, 31-39, 41-42, and 46 of the
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`’578 Patent.
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`33.
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`ADP may have infringed the ’578 Patent through other software utilizing the
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`same or reasonably similar functionality, including other versions of the ADP portal. Uniloc
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`reserves the right to discover and pursue all such additional infringing software.
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`34.
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`Uniloc has been damaged, reparably and irreparably, by ADP’s infringement of
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`the ’578 Patent and such damage will continue unless and until ADP is enjoined.
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`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO. 7,069,293)
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`35.
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`Uniloc incorporates paragraphs 1-34 above by reference.
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`10
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 11 of 20 PageID #: 11
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`36.
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`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 7,069,293
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`(“the ’293 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
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`PRODUCTS FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET
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`STATION ON A NETWORK that issued on June 27, 2006. A true and correct copy of the ’293
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`Patent is attached as Exhibit B hereto.
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`37.
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`Uniloc USA is the exclusive licensee of the ’293 Patent with ownership of all
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to
`
`enforce, sue and recover past damages for the infringement thereof.
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`38.
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`ADP has directly infringed, and continues to directly infringe one or more claims
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`of the ’293 Patent in this judicial district and elsewhere in Texas, including at least claims 1, 12
`
`and 17, literally and/or under the doctrine of equivalents, by or through making, using,
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`importing, offering for sale and/or selling the ADP portal during the pendency of the ’293 Patent
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`which software and associated backend server architecture inter alia allow for providing an
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`application program for distribution to a network server, specifying source and target directories
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`for the program to be distributed, preparing a file packet associated with the program including a
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`segment configured to initiate registration and distributing the file packet to the target on-
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`demand server to make the program available for use by a client user.
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`39.
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`In addition, should the ADP portal be found to not literally infringe the asserted
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`claims of the ’293 Patent, the product would nevertheless infringe the asserted claims of the ’293
`
`Patent. More specifically, the accused ADP portal performs substantially the same function
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`(distributing application programs to a target on-demand server on a network), in substantially
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`the same way (via a client/server environment to target on-demand users), to yield substantially
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`11
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`

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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 12 of 20 PageID #: 12
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`the same result (making application programs available for use by target on-demand users).
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`ADP would thus be liable for direct infringement under the doctrine of equivalents.
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`40.
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`ADP has indirectly infringed and continues to indirectly infringe at least claims 1,
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`12 and 17 of the ’293 Patent in this judicial district and elsewhere in the United States by, among
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`other things, actively inducing the using, offering for sale, selling, or importing the ADP portal.
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`ADP’s customers who use the ADP portal in accordance with ADP’s instructions directly
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`infringe one or more of the forgoing claims of the ’293 Patent in violation of 35 U.S.C. § 271.
`
`ADP directly and/or indirectly instructs its customers through training videos, demonstrations,
`
`brochures, installation and/or user guides, such as those located at the following:
`
`•
`
`•
`
`•
`
`•
`
`www.adp.com
`
`www.my.adp.com
`
`https://portal.adp.com
`
`www.youtube.com
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`ADP is thereby liable for infringement of the ’293 Patent under 35 U.S.C. § 271(b).
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`41.
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`ADP has indirectly infringed and continues to indirectly infringe at least claims 1,
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`12 and 17 of the ’293 Patent in this judicial district and elsewhere in the United States by, among
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`other things, contributing to the direct infringement by others including, without limitation
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`customers using the ADP portal, by making, offering to sell, selling and/or importing into the
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`United States, a component of a patented machine, manufacture or combination, or an apparatus
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`for use in practicing a patented process, constituting a material part of the invention, knowing the
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`same to be especially made or especially adapted for use in infringing the ’293 Patent and not a
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`staple article or commodity of commerce suitable for substantial non-infringing use.
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`12
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`42.
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`For example, the ADP portal is a component of a patented machine, manufacture,
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`or combination, or an apparatus for use in practicing a patent process. Furthermore, the ADP
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`portal is a material part of the claimed inventions and upon information and belief is not a staple
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`article or commodity of commerce suitable for substantial non-infringing use. ADP is, therefore,
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`liable for infringement under 35 U.S.C. § 271(c).
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`43.
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`ADP will have been on notice of the ’293 Patent since, at the latest, the service of
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`this complaint upon ADP. By the time of trial, ADP will have known and intended (since
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`receiving such notice) that its continued actions would actively induce, and contribute to, the
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`infringement of one or more of claims 1, 12 and 17 of the ’293 Patent.
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`44.
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`ADP may have infringed the ’293 Patent through other software utilizing the
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`same or reasonably similar functionality, including other versions of the ADP portal. Uniloc
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`reserves the right to discover and pursue all such additional infringing software.
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`45.
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`Uniloc has been damaged, reparably and irreparably, by ADP’s infringement of
`
`the ’293 Patent and such damage will continue unless and until ADP is enjoined.
`
`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO. 6,510,466)
`
`Uniloc incorporates paragraphs 1-45 above by reference.
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`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,510,466
`
`46.
`
`47.
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`(“the ’466 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
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`PRODUCTS FOR CENTRALIZED MANAGEMENT OF APPLICATION PROGRAMS ON A
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`NETWORK that issued on January 21, 2003. A true and correct copy of the ’466 Patent is
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`attached as Exhibit C hereto.
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`13
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`48.
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`Uniloc USA is the exclusive licensee of the ’466 Patent with ownership of all
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to
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`enforce, sue and recover past damages for the infringement thereof.
`
`49.
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`ADP has directly infringed, and continues to directly infringe one or more claims
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`of the ’466 Patent in this judicial district and elsewhere in Texas, including at least claims 1-2, 7,
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`15-17, 22, 30 and 35, literally and/or under the doctrine of equivalents, by or through making,
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`using, importing, offering for sale and/or selling the ADP portal during the pendency of the ’466
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`Patent which software and associated backend server architecture inter alia allow for installing
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`application programs on a server, receiving a login request, establishing a user desktop, receiving
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`a selection of one or more programs displayed in the user desktop and providing a program for
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`execution.
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`50.
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`In addition, should the ADP portal be found to not literally infringe the asserted
`
`claims of the ’466 Patent, the product would nevertheless infringe the asserted claims of the ’466
`
`Patent. More specifically, the accused ADP portal performs substantially the same function
`
`(making computer games/software available for digital download/management), in substantially
`
`the same way (via a client/server environment), to yield substantially the same result (providing
`
`authorized games/software to a client for execution). ADP would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`51.
`
`ADP has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`2, 7, 15-17, 22, 30 and 35 of the ’466 Patent in this judicial district and elsewhere in the United
`
`States by, among other things, actively inducing the using, offering for sale, selling, or importing
`
`the ADP portal. ADP’s customers who use the ADP portal in accordance with ADP’s
`
`instructions directly infringe one or more of the forgoing claims of the ’466 Patent in violation of
`
`
`
`14
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`

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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 15 of 20 PageID #: 15
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`35 U.S.C. § 271. ADP directly and/or indirectly instructs its customers through training videos,
`
`demonstrations, brochures, installation and/or user guides, such as those located at the following:
`
`•
`
`•
`
`•
`
`•
`
`www.adp.com
`
`www.my.adp.com
`
`https://portal.adp.com
`
`www.youtube.com
`
`ADP is thereby liable for infringement of the ’466 Patent under 35 U.S.C. § 271(b).
`
`52.
`
`ADP has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`2, 7, 15-17, 22, 30 and 35 of the ’466 Patent in this judicial district and elsewhere in the United
`
`States by, among other things, contributing to the direct infringement by others including,
`
`without limitation customers using the ADP portal, by making, offering to sell, selling and/or
`
`importing into the United States, a component of a patented machine, manufacture or
`
`combination, or an apparatus for use in practicing a patented process, constituting a material part
`
`of the invention, knowing the same to be especially made or especially adapted for use in
`
`infringing the ’466 Patent and not a staple article or commodity of commerce suitable for
`
`substantial non-infringing use.
`
`53.
`
`For example, the ADP portal is a component of a patented machine, manufacture,
`
`or combination, or an apparatus for use in practicing a patent process. Furthermore, the ADP
`
`portal is a material part of the claimed inventions and upon information and belief is not a staple
`
`article or commodity of commerce suitable for substantial non-infringing use. ADP is, therefore,
`
`liable for infringement under 35 U.S.C. § 271(c).
`
`54.
`
`ADP will have been on notice of the ’466 Patent since, at the latest, the service of
`
`this complaint upon ADP. By the time of trial, ADP will have known and intended (since
`
`
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`15
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`

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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 16 of 20 PageID #: 16
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`receiving such notice) that its continued actions would actively induce, and contribute to, the
`
`infringement of one or more of claims 1-2, 7, 15-17, 22, 30 and 35 of the ’466 Patent.
`
`55.
`
`ADP may have infringed the ’466 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of the ADP portal. Uniloc
`
`reserves the right to discover and pursue all such additional infringing software.
`
`56.
`
`Uniloc has been damaged, reparably and irreparably, by ADP’s infringement of
`
`the ’466 Patent and such damage will continue unless and until ADP is enjoined.
`
`COUNT IV
`(INFRINGEMENT OF U.S. PATENT NO. 6,728,766)
`
`Uniloc incorporates paragraphs 1-56 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,728,766
`
`57.
`
`58.
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`(“the ’766 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR LICENSE USE MANAGEMENT ON A NETWORK that issued on April 27,
`
`2004. A true and correct copy of the ’766 Patent is attached as Exhibit D hereto.
`
`59.
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`Uniloc USA is the exclusive licensee of the ’766 Patent with ownership of all
`
`substantial rights therein, including the right to grant sublicenses, to exclude others, and to
`
`enforce, sue and recover past damages for the infringement thereof.
`
`60.
`
`ADP has directly infringed, and continues to directly infringe one or more claims
`
`of the ’766 Patent in this judicial district and elsewhere in Texas, including at least claims 1, 3, 5,
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`7, 9, 11, 13, 15 and 17, literally and/or under the doctrine of equivalents, by or through making,
`
`using, importing, offering for sale and/or selling the ADP portal during the pendency of the ’766
`
`Patent which software and associated backend server architecture inter alia allow for
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`maintaining user policy based license management information for application programs at a
`
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`16
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`server, receiving a request for a license at the server, determining license availability based on
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`the policy information, and providing an indication of availability or unavailability.
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`61.
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`In addition, should the ADP portal be found to not literally infringe the asserted
`
`claims of the ’766 Patent, the product would nevertheless infringe the asserted claims of the ’766
`
`Patent. More specifically, the accused ADP portal performs substantially the same function
`
`(managing licenses for authorized computer games/software based on user policy information),
`
`in substantially the same way (via a client/server environment), to yield substantially the same
`
`result (providing authorized games/software to a client). ADP would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`62.
`
`ADP has indirectly infringed and continues to indirectly infringe at least claims 1,
`
`3, 5, 7, 9, 11, 13, 15 and 17 of the ’766 Patent in this judicial district and elsewhere in the United
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`States by, among other things, actively inducing the using, offering for sale, selling, or importing
`
`the ADP portal. ADP’s customers who use the ADP portal in accordance with ADP’s
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`instructions directly infringe one or more of the forgoing claims of the ’766 Patent in violation of
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`35 U.S.C. § 271. ADP directly and/or indirectly instructs its customers through training videos,
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`demonstrations, brochures, installation and/or user guides, such as those located at the following:
`
`•
`
`•
`
`•
`
`•
`
`www.adp.com
`
`www.my.adp.com
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`https://portal.adp.com
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`www.youtube.com
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`ADP is thereby liable for infringement of the ’766 Patent under 35 U.S.C. § 271(b).
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`63.
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`ADP has indirectly infringed and continues to indirectly infringe at least claims 1,
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`3, 5, 7, 9, 11, 13, 15 and 17 of the ’766 Patent in this judicial district and elsewhere in the United
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`
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`17
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 18 of 20 PageID #: 18
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`States by, among other things, contributing to the direct infringement by others including,
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`without limitation customers using the ADP portal, by making, offering to sell, selling and/or
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`importing into the United States, a component of a patented machine, manufacture or
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`combination, or an apparatus for use in practicing a patented process, constituting a material part
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`of the invention, knowing the same to be especially made or especially adapted for use in
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`infringing the ’766 Patent and not a staple article or commodity of commerce suitable for
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`substantial non-infringing use.
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`64.
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`For example, the ADP portal is a component of a patented machine, manufacture,
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`or combination, or an apparatus for use in practicing a patent process. Furthermore, the ADP
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`portal is a material part of the claimed inventions and upon information and belief is not a staple
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`article or commodity of commerce suitable for substantial non-infringing use. ADP is, therefore,
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`liable for infringement under 35 U.S.C. § 271(c).
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`65.
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`ADP will have been on notice of the ’766 Patent since, at the latest, the service of
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`this complaint upon ADP. By the time of trial, ADP will have known and intended (since
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`receiving such notice) that its continued actions would actively induce, and contribute to, the
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`infringement of one or more of claims 1, 3, 5, 7, 9, 11, 13, 15 and 17 of the ’766 Patent.
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`66.
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`ADP may have infringed the ’766 Patent through other software utilizing the
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`same or reasonably similar functionality, including other versions of the ADP portal. Uniloc
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`reserves the right to discover and pursue all such additional infringing software.
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`67.
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`Uniloc has been damaged, reparably and irreparably, by ADP’s infringement of
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`the ’766 Patent and such damage will continue unless and until ADP is enjoined.
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`PRAYER FOR RELIEF
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`Uniloc requests that the Court enter judgment against ADP as follows:
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`18
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 19 of 20 PageID #: 19
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`
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`(A)
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`that ADP has infringed the ’578 Patent, the ’293 Patent, the ’466 Patent and the
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`’766 Patent;
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`
`
`(B)
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`awarding Uniloc its damages suffered as a result of ADP’s infringement of the
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`’578 Patent, the ’293 Patent, the ’466 Patent and the ’766 Patent;
`
`
`
`(C)
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`enjoining ADP, its officers, directors, agents, servants, affiliates, employees,
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`divisions, branches, subsidiaries and parents, and all others acting in concert or privity with it
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`from infringing the ’578 Patent, the ’293 Patent, the ’466 Patent and the ’766 Patent;
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`awarding Uniloc its costs, attorneys’ fees, expenses and interest, and
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`granting Uniloc such other and further relief as the Court may deem just and
`
`
`
`
`
`(D)
`
`(E)
`
`proper.
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`DEMAND FOR JURY TRIAL
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`
`
`Uniloc hereby demands trial by jury on all issues so triable pursuant to Fed. R. Civ. P. 38.
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`
`Dated: July 8, 2016
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`
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`Respectfully submitted,
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`
`
`
`
`
`
`
`
` /s/ Craig Tadlock
`Craig Tadlock
`Texas State Bar No. 00791766
`Keith Smiley
`Texas State Bar No. 24067869
`TADLOCK LAW FIRM PLLC
`2701 Dallas Parkway, Suite 360
`Plano, TX 75093
`Tel: (903) 730-6789
`Email: craig@tadlocklawfirm.com
`Email: keith@tadlocklawfirm.com
`
`Paul J. Hayes
`Kevin Gannon
`CESARI AND MCKENNA, LLP
`88 Black Falcon Ave
`Suite 271
`Boston, MA 02110
`Telephone: (617) 951-2500
`
`
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`19
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`Case 2:16-cv-00741-RWS Document 1 Filed 07/08/16 Page 20 of 20 PageID #: 20
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`Facsimile: (617) 951-3927
`Email: pjh@c-m.com
`Email: kgannon@c-m.com
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`
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`
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`ATTORNEYS FOR THE PLAINTIFFS
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`20
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