Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 1 of 19 PageID #: 467
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`§
`§
`§ Case No. 2:16-cv-00741-JRG
`§
`
`LEAD CASE
`§
`JURY TRIAL DEMANDED
`§
`§ Case No. 2:16-cv-00860-JRG
`
`
`
`UNILOC USA, INC., et al,
`
`Plaintiffs,
`
`
`v.
`
`
`
`ADP, LLC,
`BOX, INC.,
`
`Defendants.
`
`
`
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`Plaintiffs, Uniloc USA, Inc. and Uniloc Luxembourg, S.A. (together “Uniloc”), as and
`
`for their first amended complaint against defendant, Box, Inc. (“Box”), allege as follows:
`
`THE PARTIES
`
`1.
`
`Uniloc USA, Inc. (“Uniloc USA”) is a Texas corporation having a principal place
`
`of business at Legacy Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024.
`
`Uniloc also maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
`
`2.
`
`Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) is a Luxembourg public limited
`
`liability company having a principal place of business at 15, Rue Edward Steichen, 4th Floor, L-
`
`2540, Luxembourg (R.C.S. Luxembourg B159161).
`
`3.
`
`Uniloc Luxembourg owns a number of patents in the field of application
`
`management in a computer network.
`
`4.
`
`Upon information and belief, Box is a Delaware corporation having a principal
`
`place of business in Redwood City, California and offering its products, including those accused
`
`herein of infringement, to customers and/or potential customers located in Texas and in the
`
`06096768 
`
` 
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 2 of 19 PageID #: 468
`
`judicial Eastern District of Texas. Box may be served with process through its registered agent:
`
`Corporation Service Company, 1560 Broadway, Suite 2090, Denver, Colorado 80202-5180.
`
`JURISDICTION AND VENUE
`
`5.
`
`Uniloc brings this action for patent infringement under the patent laws of the
`
`United States, 35 U.S.C. § 271 et seq. This Court has subject matter jurisdiction pursuant to 28
`
`U.S.C. §§ 1331, 1338(a) and 1367.
`
`6.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(c) and
`
`1400(b). Upon information and belief, Box is deemed to reside in this judicial district, has
`
`committed acts of infringement in this judicial district, and/or has purposely transacted business
`
`involving the accused products in this judicial district, including sales to one or more customers
`
`in Texas.
`
`7.
`
`Box is subject to this Court’s jurisdiction pursuant to due process and/or the
`
`Texas Long Arm Statute due at least to its substantial business in this State and judicial district,
`
`including: (A) at least part of its past infringing activities, (B) according to its March 2016 Form
`
`10-K, regularly doing or soliciting business in Austin, Texas and/or (C) engaging in persistent
`
`conduct and/or deriving substantial revenue from goods and services provided to customers in
`
`Texas.
`
`
`
`8.
`
`9.
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 6,324,578)
`
`Uniloc incorporates paragraphs 1-7 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,324,578
`
`(“the ’578 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON
`
` 
`
`2
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 3 of 19 PageID #: 469
`
`A NETWORK that issued on November 27, 2001. A true and correct copy of the ’578 Patent is
`
`attached as Exhibit A hereto.
`
`10.
`
`Uniloc USA is the exclusive licensee of the ’578 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.
`
`11.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`12.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`13.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
` 
`
`3
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 4 of 19 PageID #: 470
`
`14.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`15.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`16.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
` 
`
`4
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 5 of 19 PageID #: 471
`
`17.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`18.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`19.
`
`Upon information and belief, the following describes, at least in part, Box’s login
`
`
`
`process:
`
` 
`
`5
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 6 of 19 PageID #: 472
`
`20.
`
`Upon information and belief, the following describes, at least in part, Box’s
`
`
`
`Server Farms:
`
`21.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`
`
` 
`
`6
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 7 of 19 PageID #: 473
`
`22.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`23.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`24.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
` 
`
`7
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 8 of 19 PageID #: 474
`
`25.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`26.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`
`
` 
`
`8
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 9 of 19 PageID #: 475
`
`27.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`28.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
`29.
`
`Upon information and belief, the following describes, at least in part, how the Box
`
`content management and collaboration system works:
`
`
`
` 
`
`9
`
`
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 10 of 19 PageID #: 476
`
`30.
`
`Box has directly infringed, and continues to directly infringe one or more claims
`
`of the ’578 Patent in this judicial district and elsewhere in Texas, including at least claims 1-8,
`
`10-11, 13-39, and 41-46 literally and/or under the doctrine of equivalents, by or through making,
`
`using, importing, offering for sale and/or selling the Box content management and collaboration
`
`system during the pendency of the ’578 Patent which software and associated backend server
`
`architecture inter alia allows for installing an application program having a plurality of
`
`configurable preferences and authorized users on a server coupled to a network, distributing an
`
`application launcher program to a client, obtaining a user set of the configurable preferences,
`
`obtaining an administrator set of configurable preferences and executing the application program
`
`using the user and administrator sets of configurable preferences responsive to a request from a
`
`user.
`
`31.
`
`In addition, should the Box content management and collaboration system be
`
`found to not literally infringe the asserted claims of the ’578 Patent, the product would
`
`nevertheless infringe the asserted claims of the ’578 Patent. More specifically, the accused
`
`system performs substantially the same function (obtaining user and administrator sets of
`
`configurable preferences), in substantially the same way (via a user and administrator), to yield
`
`substantially the same result (executing an application program using the configurable
`
`preferences in response to a request from a user on a network). Box would thus be liable for
`
`direct infringement under the doctrine of equivalents.
`
`32.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`8, 10-11, 13-39, and 41-46 of the ’578 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 Box content management and collaboration system. Box’s customers who use the Box
`
` 
`
`10
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 11 of 19 PageID #: 477
`
`content management and collaboration system in accordance with Box’s instructions directly
`
`infringe one or more of the forgoing claims of the ’578 Patent in violation of 35 U.S.C. § 271.
`
`Box 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.box.com
`
`https://app.box.com
`
`https://account.box.com
`
`www.youtube.com
`
`Box is thereby liable for infringement of the ’578 Patent under 35 U.S.C. § 271(b).
`
`33.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`8, 10-11, 13-39, and 41-46 of the ’578 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 Box content management and collaboration system, 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 ’578 Patent and not a staple article or commodity of
`
`commerce suitable for substantial non-infringing use.
`
`34.
`
`For example, the Box content management and collaboration system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Box content management and collaboration system
`
`is a material part of the claimed inventions and upon information and belief is not a staple article
`
` 
`
`11
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 12 of 19 PageID #: 478
`
`or commodity of commerce suitable for substantial non-infringing use. Box is, therefore, liable
`
`for infringement under 35 U.S.C. § 271(c).
`
`35.
`
`Box will have been on notice of the ’578 Patent since, at the latest, the service of
`
`the original complaint upon Box. By the time of trial, Box will have known and intended (since
`
`receiving such notice) that its continued actions would actively induce, and contribute to, the
`
`infringement of one or more of claims 1-8, 10-11, 13-39, and 41-46 of the ’578 Patent.
`
`36.
`
`Box may have infringed the ’578 Patent through other software utilizing the same
`
`or reasonably similar functionality, including other versions of its content management and
`
`collaboration system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`37.
`
`Uniloc has been damaged, reparably and irreparably, by Box’s infringement of
`
`the ’578 Patent and such damage will continue unless and until Box is enjoined.
`
`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO. 7,069,293)
`
`Uniloc incorporates paragraphs 1-37 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 7,069,293
`
`
`
`38.
`
`39.
`
`(“the ’293 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET
`
`STATION ON A NETWORK that issued on June 27, 2006. A true and correct copy of the ’293
`
`Patent is attached as Exhibit B hereto.
`
`40.
`
`Uniloc USA is the exclusive licensee of the ’293 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.
`
` 
`
`12
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 13 of 19 PageID #: 479
`
`41.
`
`Box has directly infringed, and continues to directly infringe one or more claims
`
`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, importing,
`
`offering for sale and/or selling the Box content management and collaboration system during the
`
`pendency of the ’293 Patent which software and associated backend server architecture inter alia
`
`allow for providing an application program for distribution to a network server, specifying
`
`source and target directories for the program to be distributed, preparing a file packet associated
`
`with the program including a segment configured to initiate registration operations for the
`
`application program at a target on-demand server and distributing the file packet to the target on-
`
`demand server to make the program available for use by a client user.
`
`42.
`
`In addition, should the Box content management and collaboration system be
`
`found to not literally infringe the asserted claims of the ’293 Patent, the product would
`
`nevertheless infringe the asserted claims of the ’293 Patent. More specifically, the accused
`
`system performs substantially the same function (distributing an application program to a target
`
`on-demand server on a network), in substantially the same way (via initiation of registration
`
`operations for the application program at the target on-demand server), to yield substantially the
`
`same result (making the application program available for use by a user at a client). Box would
`
`thus be liable for direct infringement under the doctrine of equivalents.
`
`43.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1,
`
`12 and 17 of the ’293 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 Box
`
`content management and collaboration system. Box’s customers who use the Box content
`
`management and collaboration system in accordance with Box’s instructions directly infringe
`
` 
`
`13
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 14 of 19 PageID #: 480
`
`one or more of the forgoing claims of the ’293 Patent in violation of 35 U.S.C. § 271. Box
`
`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.box.com
`
`https://app.box.com
`
`https://account.box.com
`
`www.youtube.com
`
`Box is thereby liable for infringement of the ’293 Patent under 35 U.S.C. § 271(b).
`
`44.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1,
`
`12 and 17 of the ’293 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 Box content management and collaboration system, 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 ’293 Patent and not a staple article or commodity of
`
`commerce suitable for substantial non-infringing use.
`
`45.
`
`For example, the Box content management and collaboration system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Box content management and collaboration system
`
`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. Box is, therefore, liable
`
`for infringement under 35 U.S.C. § 271(c).
`
` 
`
`14
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 15 of 19 PageID #: 481
`
`46.
`
`Box will have been on notice of the ’293 Patent since, at the latest, the service of
`
`the original complaint upon Box. By the time of trial, Box will have known and intended (since
`
`receiving such notice) that its continued actions would actively induce, and contribute to, the
`
`infringement of one or more of claims 1, 12 and 17 of the ’293 Patent.
`
`47.
`
`Box may have infringed the ’293 Patent through other software utilizing the same
`
`or reasonably similar functionality, including other versions of its content management and
`
`collaboration system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`48.
`
`Uniloc has been damaged, reparably and irreparably, by Box’s infringement of
`
`the ’293 Patent and such damage will continue unless and until Box is enjoined.
`
`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO. 6,510,466)
`
`Uniloc incorporates paragraphs 1-48 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,510,466
`
`49.
`
`50.
`
`(“the ’466 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR CENTRALIZED MANAGEMENT OF APPLICATION PROGRAMS ON A
`
`NETWORK that issued on January 21, 2003. A true and correct copy of the ’466 Patent is
`
`attached as Exhibit C hereto.
`
`51.
`
`Uniloc USA is the exclusive licensee of the ’466 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.
`
`52.
`
`Box has directly infringed, and continues to directly infringe one or more claims
`
`of the ’466 Patent in this judicial district and elsewhere in Texas, including at least claims 1-5, 7-
`
`9, 13, 15-20, 22-24, 28-33, 35-37, and 41-42 literally and/or under the doctrine of equivalents,
`
` 
`
`15
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 16 of 19 PageID #: 482
`
`by or through making, using, importing, offering for sale and/or selling the Box content
`
`management and collaboration system during the pendency of the ’466 Patent which software
`
`and associated backend server architecture inter alia allows for installing application programs
`
`on a server, receiving a login request, establishing a user desktop interface, receiving a selection
`
`of one of the programs displayed in the user desktop interface and providing an instance of the
`
`selected program for execution.
`
`53.
`
`In addition, should the Box content management and collaboration system 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
`
`system performs substantially the same function (selection of an application program), in
`
`substantially the same way (via an established user desktop interface), to yield substantially the
`
`same result (providing the program for execution). Box would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`54.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`5, 7-9, 13, 15-20, 22-24, 28-33, 35-37, and 41-42 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 Box content management and collaboration system. Box’s
`
`customers who use the Box content management and collaboration system in accordance with
`
`Box’s instructions directly infringe one or more of the forgoing claims of the ’466 Patent in
`
`violation of 35 U.S.C. § 271. Box 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.box.com
`
` 
`
`16
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 17 of 19 PageID #: 483
`
`•
`
`•
`
`•
`
`https://app.box.com
`
`https://account.box.com
`
`www.youtube.com
`
`Box is thereby liable for infringement of the ’466 Patent under 35 U.S.C. § 271(b).
`
`55.
`
`Box has indirectly infringed and continues to indirectly infringe at least claims 1-
`
`5, 7-9, 13, 15-20, 22-24, 28-33, 35-37, and 41-42 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 Box content management and
`
`collaboration system, 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.
`
`56.
`
`For example, the Box content management and collaboration system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Box content management and collaboration system
`
`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. Box is, therefore, liable
`
`for infringement under 35 U.S.C. § 271(c).
`
`57.
`
`Box will have been on notice of the ’466 Patent since, at the latest, the service of
`
`the original complaint upon Box. By the time of trial, Box will have known and intended (since
`
`receiving such notice) that its continued actions would actively induce, and contribute to, the
`
` 
`
`17
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 18 of 19 PageID #: 484
`
`infringement of one or more of claims 1-5, 7-9, 13, 15-20, 22-24, 28-33, 35-37, and 41-42 of the
`
`’466 Patent.
`
`58.
`
`Box may have infringed the ’466 Patent through other software utilizing the same
`
`or reasonably similar functionality, including other versions of its content management and
`
`collaboration system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`59.
`
`Uniloc has been damaged, reparably and irreparably, by Box’s infringement of
`
`the ’466 Patent and such damage will continue unless and until Box is enjoined.
`
`PRAYER FOR RELIEF
`
`
`
`
`
`
`
`Uniloc requests that the Court enter judgment against Box as follows:
`
`(A)
`
`(B)
`
`that Box has infringed the ’578 Patent, the ’293 Patent and the ’466 Patent;
`
`awarding Uniloc its damages suffered as a result of Box’s infringement of the
`
`’578 Patent, the ’293 Patent and the ’466 Patent;
`
`
`
`(C)
`
`enjoining Box, its officers, directors, agents, servants, affiliates, employees,
`
`divisions, branches, subsidiaries and parents, and all others acting in concert or privity with it
`
`from infringing the ’578 Patent, the ’293 Patent and the ’466 Patent;
`
`awarding Uniloc its costs, attorneys’ fees, expenses and interest, and
`
`granting Uniloc such other and further relief as the Court may deem just and
`
`
`
`
`
`(D)
`
`(E)
`
`proper.
`
`DEMAND FOR JURY TRIAL
`
`Uniloc hereby demands trial by jury on all issues so triable pursuant to Fed. R. Civ. P. 38.
`
`
`
`18
`
`
`
`
`
` 
`
`

`

`Case 2:16-cv-00741-RWS Document 51 Filed 10/21/16 Page 19 of 19 PageID #: 485
`
`
`Dated: October 21, 2016
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
` /s/ Craig Tadlock
`Craig Tadlock
`Texas State Bar No. 00791766
`TADLOCK LAW FIRM PLLC
`2701 Dallas Parkway, Suite 360
`Plano, TX 75093
`Tel: (903) 730-6789
`Email: craig@tadlocklawfirm.com
`
`Paul J. Hayes
`Kevin Gannon
`CESARI AND MCKENNA, LLP
`88 Black Falcon Ave
`Suite 271
`Boston, MA 02110
`Telephone: (617) 951-2500
`Facsimile: (617) 951-3927
`Email: pjh@c-m.com
`Email: kgannon@c-m.com
`
`
`
`
`
`ATTORNEYS FOR THE PLAINTIFFS
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that all counsel of record who are deemed to have
`
`consented to electronic service are being served with a copy of this document via the Court’s
`CM/ECF system per Local Rule CV-5(a)(3) on October 21, 2016.
`
`
`
`
`
`
`
`/s/ Kevin Gannon
`Kevin Gannon
`
`
` 
`
`19
`
`