`
`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-00858-JRG
`
`
`
`UNILOC USA, INC., et al,
`
`Plaintiffs,
`
`
`v.
`
`
`
`ADP, LLC,
`BIG FISH GAMES, 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, Big Fish Games, Inc. (“Big Fish”), allege as
`
`follows:
`
`THE PARTIES
`
`1.
`
`Uniloc USA, Inc. 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. 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, Big Fish is a Washington corporation having a
`
`principal place of business in Seattle, Washington and offering its products, including those
`
`accused herein of infringement, to customers and/or potential customers located in Texas and in
`
`the judicial Eastern District of Texas. Big Fish may be served with process through its registered
`
`06096768
`
`
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 2 of 21 PageID #: 568
`
`agent in Texas: CT Corporation System, 505 Union Ave SE, Suite 120, Olympia, Washington
`
`98501.
`
`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, Big Fish 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.
`
`Big Fish 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) regularly doing or soliciting
`
`business in Texas and/or (C) engaging in persistent conduct and/or deriving substantial revenue
`
`from goods and services provided to customers in Texas.
`
`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
`
`
`
`8.
`
`9.
`
`(“the ’578 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM
`
`PRODUCTS FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON
`
`A NETWORK that issued on November 27, 2001. A true and correct copy of the ’578 Patent is
`
`attached as Exhibit A hereto.
`
`
`
`2
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 3 of 21 PageID #: 569
`
`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 Big
`
`Fish software distribution and management system works:
`
`12.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`13.
`
`Upon information and belief, the following describes, at least in part, how a Big
`
`Fish software distribution and management system sign in/create account works:
`
`
`
`
`
`3
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 4 of 21 PageID #: 570
`
`14.
`
`Upon information and belief, the following describes, at least in part, the Big Fish
`
`software distribution and management system:
`
`
`
`15.
`
`Upon information and belief, the following describes, at least in part, the Big Fish
`
`software distribution and management system:
`
`
`
`16.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`4
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 5 of 21 PageID #: 571
`
`17.
`
`Upon information and belief, the following describes, at least in part, network
`
`information relating to the Big Fish software distribution and management system:
`
`
`
`18.
`
`Upon information and belief, the following describes, at least in part, a Big Fish
`
`software distribution and management system server:
`
`
`
`
`
`
`
`5
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 6 of 21 PageID #: 572
`
`19.
`
`Upon information and belief, the following describes, at least in part, Big Fish
`
`software distribution and management system sever IP addresses:
`
`20.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`21.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`6
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 7 of 21 PageID #: 573
`
`22.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`23.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`7
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 8 of 21 PageID #: 574
`
`24.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system game download works:
`
`
`
`25.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system game download works:
`
`
`
`26.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`8
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 9 of 21 PageID #: 575
`
`27.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`28.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`9
`
`
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 10 of 21 PageID #: 576
`
`29.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`30.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works
`
`
`
`31.
`
`Upon information and belief, the following describes, at least in part, how the Big
`
`Fish software distribution and management system works:
`
`
`
`
`
`10
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 11 of 21 PageID #: 577
`
`
`
`32.
`
`Big Fish 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 Big Fish software distribution and
`
`management 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 the configurable preferences and executing the
`
`application program using the user and administrator sets of configurable preferences responsive
`
`to a request from a user.
`
`33.
`
`In addition, should the Big Fish software distribution and management system be
`
`found to not literally infringe the asserted claims of the ’578 Patent, the Big Fish software
`
`distribution and management system would nevertheless infringe the asserted claims of the ’578
`
`Patent. More specifically, the accused Big Fish software distribution and management system
`
`
`
`11
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 12 of 21 PageID #: 578
`
`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 the application program using the configurable preferences in
`
`response to a request from a user on a network). Big Fish would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`34.
`
`Big Fish 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 Big Fish software distribution and management system. Big Fish’s customers
`
`who use the Big Fish software distribution and management system in accordance with Big
`
`Fish’s instructions directly infringe one or more of the forgoing claims of the ’578 Patent in
`
`violation of 35 U.S.C. § 271. Big Fish 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.bigfishgames.com
`
`www.susi.bigfishgames.com
`
`https://itunes.apple.com.us.app
`
`https://play.google.com/store/apps
`
`www.youtube.com
`
`Big Fish is thereby liable for infringement of the ’578 Patent under 35 U.S.C. § 271(b).
`
`35.
`
`Big Fish 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
`
`
`
`12
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 13 of 21 PageID #: 579
`
`including, without limitation customers using the Big Fish software distribution and management
`
`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.
`
`36.
`
`For example, the Big Fish software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Big Fish software distribution and management
`
`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. Big Fish is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`37.
`
`Big Fish will have been on notice of the ’578 Patent since, at the latest, the service
`
`of the original complaint upon Big Fish. By the time of trial, Big Fish 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.
`
`38.
`
`Big Fish may have infringed the ’578 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`39.
`
`Uniloc has been damaged, reparably and irreparably, by Big Fish’s infringement
`
`of the ’578 Patent and such damage will continue unless and until Big Fish is enjoined.
`
`
`
`13
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 14 of 21 PageID #: 580
`
`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO. 7,069,293)
`
`Uniloc incorporates paragraphs 1-39 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 7,069,293
`
`
`
`40.
`
`41.
`
`(“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.
`
`42.
`
`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.
`
`43.
`
`Big Fish 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 Big Fish software distribution and management
`
`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 the 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.
`
`44.
`
`In addition, should the Big Fish software distribution and management 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
`
`
`
`14
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 15 of 21 PageID #: 581
`
`software/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 registration
`
`of operations for the application program at the target on-demand server to target on-demand
`
`users), to yield substantially the same result (making the application program available for use by
`
`a user at a client). Big Fish would thus be liable for direct infringement under the doctrine of
`
`equivalents.
`
`45.
`
`Big Fish 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
`
`Big Fish software distribution and management system. Big Fish’s customers who use the Big
`
`Fish software distribution and management system in accordance with Big Fish’s instructions
`
`directly infringe one or more of the forgoing claims of the ’293 Patent in violation of 35 U.S.C. §
`
`271. Big Fish 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.bigfishgames.com
`
`www.susi.bigfishgames.com
`
`https://itunes.apple.com.us.app
`
`https://play.google.com/store/apps
`
`www.youtube.com
`
`Big Fish is thereby liable for infringement of the ’293 Patent under 35 U.S.C. § 271(b).
`
`46.
`
`Big Fish 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
`
`
`
`15
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 16 of 21 PageID #: 582
`
`limitation customers using the Big Fish software distribution and management 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.
`
`47.
`
`For example, the Big Fish software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Big Fish software distribution and management
`
`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. Big Fish is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`48.
`
`Big Fish will have been on notice of the ’293 Patent since, at the latest, the service
`
`of the original complaint upon Big Fish. By the time of trial, Big Fish 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.
`
`49.
`
`Big Fish may have infringed the ’293 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`50.
`
`Uniloc has been damaged, reparably and irreparably, by Big Fish’s infringement
`
`of the ’293 Patent and such damage will continue unless and until Big Fish is enjoined.
`
`
`
`
`
`
`
`16
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 17 of 21 PageID #: 583
`
`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO. 6,510,466)
`
`Uniloc incorporates paragraphs 1-50 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,510,466
`
`51.
`
`52.
`
`(“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.
`
`53.
`
`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.
`
`54.
`
`Big Fish 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, by or through making, using, importing, offering for sale and/or selling the Big Fish
`
`software distribution and management 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.
`
`55.
`
`In addition, should the Big Fish software distribution and management system be
`
`found to not literally infringe the asserted claims of the ’466 Patent, the Big Fish software
`
`distribution and management system would nevertheless infringe the asserted claims of the ’466
`
`Patent. More specifically, the accused Big Fish software distribution and management system
`
`
`
`17
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 18 of 21 PageID #: 584
`
`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). Big Fish would thus be liable for direct infringement
`
`under the doctrine of equivalents.
`
`56.
`
`Big Fish 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 Big Fish software distribution and management
`
`system. Big Fish’s customers who use the Big Fish software distribution and management
`
`system in accordance with Big Fish’s instructions directly infringe one or more of the forgoing
`
`claims of the ’466 Patent in violation of 35 U.S.C. § 271. Big Fish 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.bigfishgames.com
`
`www.susi.bigfishgames.com
`
`https://itunes.apple.com.us.app
`
`https://play.google.com/store/apps
`
`www.youtube.com
`
`Big Fish is thereby liable for infringement of the ’466 Patent under 35 U.S.C. § 271(b).
`
`57.
`
`Big Fish 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 Big Fish software
`
`
`
`18
`
`
`
`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 19 of 21 PageID #: 585
`
`distribution and management 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.
`
`58.
`
`For example, the Big Fish software distribution and management system is a
`
`component of a patented machine, manufacture, or combination, or an apparatus for use in
`
`practicing a patent process. Furthermore, the Big Fish software distribution and management
`
`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. Big Fish is,
`
`therefore, liable for infringement under 35 U.S.C. § 271(c).
`
`59.
`
`Big Fish will have been on notice of the ’466 Patent since, at the latest, the service
`
`of the original complaint upon Big Fish. By the time of trial, Big Fish 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 1-5, 7-9, 13, 15-20, 22-24, 28-33, 35-37,
`
`and 41-42 of the ’466 Patent.
`
`60.
`
`Big Fish may have infringed the ’466 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software distribution and
`
`management system. Uniloc reserves the right to discover and pursue all such additional
`
`infringing software.
`
`61.
`
`Uniloc has been damaged, reparably and irreparably, by Big Fish’s infringement
`
`of the ’466 Patent and such damage will continue unless and until Big Fish is enjoined.
`
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`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 20 of 21 PageID #: 586
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`PRAYER FOR RELIEF
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`Uniloc requests that the Court enter judgment against Big Fish as follows:
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`(A)
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`(B)
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`that Big Fish has infringed the ’578 Patent, the ’293 Patent and the ’466 Patent;
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`awarding Uniloc its damages suffered as a result of Big Fish’s infringement of the
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`’578 Patent, the ’293 Patent and the ’466 Patent;
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`(C)
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`enjoining Big Fish, 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 and the ’466 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
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`(D)
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`(E)
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`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: October 25, 2016
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`Respectfully submitted,
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` /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
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`Case 2:16-cv-00741-RWS Document 57 Filed 10/25/16 Page 21 of 21 PageID #: 587
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`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
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`ATTORNEYS FOR THE PLAINTIFFS
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to have
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`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 25, 2016.
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`/s/ Kevin Gannon
`Kevin Gannon
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