Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 1 of 15
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`ANCORA TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`CIVIL ACTION NO. 1:20-CV-00034-ADA
`
`v.
`
`LG ELECTRONICS INC. and LG
`ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`ANCORA TECHNOLOGIES, INC.,
`
`JURY TRIAL DEMANDED
`
`Plaintiff,
`
`CIVIL ACTION NO. 1:20-CV-00034-ADA
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`JURY TRIAL DEMANDED
`
`DEFENDANTS LG ELECTRONICS INC. AND LG ELECTRONICS U.S.A., INC.’S
`REPLY IN SUPPORT OF THEIR MOTIONS FOR SUMMARY JUDGMENT
`
`Public Version
`
`

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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 2 of 15
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`TABLE OF CONTENTS
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`Page
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`I.
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`II.
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`III.
`IV.
`V.
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`VI.
`VII.
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`C.
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`B.
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`LGE CANNOT BE LIABLE FOR PERFORMANCE OF ALL STEPS IN
`CLAIM 1 ............................................................................................................................ 1
`A.
`There Is No Evidence That LGE Directed or Controlled
`for the Group 1 Mobile Devices .............. 1
`There Is No Evidence That LGE Has Formed a “Joint Enterprise” with
` for the Group 1
`Devices ................................................................................................................... 4
`Ancora Offers No Evidence of LGE Directing or Controlling Any End-
`User ........................................................................................................................ 5
`THE ACCUSED DEVICES DO NOT “CONFIRM[] WHETHER A PROGRAM
`IS LICENSED” USING AT LEAST THE VERIFICATION STRUCTURE ................... 7
`THE ACCUSED DEVICES DO NOT USE A “PSEUDO-UNIQUE KEY” .................... 7
`THE “
`ANALYSIS HAS NO OS-LEVEL AGENT ............................. 8
`THE ACCUSED DEVICES DO NOT PERFORM THE STEP OF “ACTING ON
`THE PROGRAM ACCORDING TO THE VERIFICATION” IN CLAIM 1 .................. 9
`THE “REPRESENTATIVE CODE” IS NOT REPRESENTATIVE .............................. 10
`CONCLUSION ................................................................................................................ 10
`
`-i-
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`

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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 3 of 15
`
`TABLE OF AUTHORITIES
`
`
`
`Page(s)
`
`Cases
`
`Akamai Tech., Inc. v. Limelight Networks, Inc.,
`797 F.3d 1020,1023 (Fed. Cir. 2015).........................................................................................2
`
`Confident Techs. Inc. v. Fandango Media, LLC,
`No. 18-cv-3035, 2018 WL 6430539 (C.D. Cal. Aug. 20, 2018) ...............................................1
`
`Costal Bridge Co., LLC v. Heatec, Inc.,
`833 Fed. Appx. 565 (5th Cir. 2020) ...........................................................................................9
`
`ESW Holdings, Inc. v. Roku, Inc.,
`No. 19-cv-044, 2021 WL 1069047 (W.D. Tex. Mar. 18, 2021) ....................................1, 3, 6, 7
`
`LBS Innovations, LLC v. Nokia USA Inc.,
`15-cv-1972, 2016 WL 3407611 (E.D. Tex. June 21, 2016) ..................................................4, 5
`
`Lone Star Tech Innovations v. Asustek Comput.,
`No. 6:19-CV-00059-RWS, 2020 WL 6803249 (E.D.Tex. Jan. 14, 2020).................................6
`
`Perdiemco, LLC v. Industrack LLC,
`No. 15-cv-727, 2016 WL 8135379 (E.D. Tex. Nov. 8, 2016) ...................................................2
`
`Sapphire Crossing LLC v. Abbyy USA Software House, Inc.,
`No. 20-cv-3590, 2020 WL 6318716 (N.D. Cal. 2020) ..............................................................3
`
`SiRF Tech., Inc. v. ITC,
`601 F.3d 1319 (Fed. Cir. 2010)..................................................................................................6
`
`Travel Sentry, Inc. v. Tropp,
`877 F.3d 1370 (Fed. Cir. 2017)..................................................................................................1
`
`ii
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 4 of 15
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`In the interest of brevity and compliance with the page limit, LGE rests on its Motion for
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`Summary Judgment (Dkt. 199) (“MSJ”) for all arguments not addressed herein. LGE replies
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`herein to the most misleading positions proffered in Ancora’s opposition (Dkt. 222) (“Opp.”).
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`I.
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`LGE CANNOT BE LIABLE FOR PERFORMANCE OF ALL STEPS IN CLAIM 1
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`The non-infringement issue before the Court is not the red herring Ancora raises regarding
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`“blaming third parties.” Opp. at 4. The “key issue” is whether performance of claimed steps by
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`unidentified third parties is attributable to LGE such that LGE is responsible for directly infringing
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`the claim. Confident Techs. Inc. v. Fandango Media, LLC, No. 18-cv-3035, 2018 WL 6430539,
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`at *3 (C.D. Cal. Aug. 20, 2018); see also Travel Sentry, Inc. v. Tropp, 877 F.3d 1370, 1377 (Fed.
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`Cir. 2017). In its motion, LGE explained that it does not perform the “using an agent” step in
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`claim 1. MSJ at 11. Notably, Ancora does not contest that LGE does not perform this step. Ancora
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`instead contends that LGE directed, controlled, or formed a joint enterprise with a “third party” to
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`perform the method step. Opp. at 4. However, Ancora failed to identify what third party is bound
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`up in the alleged infringement or demonstrate how any infringing acts are attributable to LGE.
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`Despite Ancora’s criticisms,1 id. at 5, controlling law is not in question: “[a]n entity is only
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`responsible for another’s “performance of method steps in two sets of circumstances: (1) where
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`that entity directs or controls others’ performance, and (2) where the actors form a joint enterprise.”
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`ESW Holdings, Inc. v. Roku, Inc., No. 19-cv-044, 2021 WL 1069047, at *2 (W.D. Tex. Mar. 18,
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`2021) (internal citation omitted). Ancora’s arguments fail under either set of circumstances.
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`A.
`
`There Is No Evidence That LGE Directed or Controlled
` for the Group 1 Mobile Devices
`
`
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`Ancora’s “direction or control” framework, requiring little more than any agreement or any
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`1 BMC’s “single-actor rule” was reaffirmed in Travel Sentry, 877 F. 3d at 1378 (quoting Akamai
`V, 797 F.3d at 1022) (“[d]irect infringement under § 271(a) occurs where all steps of a claimed
`method are performed by or attributable to a single entity.”).
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`1
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 5 of 15
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`business partnership to survive summary judgment, invites legal error. Ancora must show that
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`LGE: (1) “conditions participation in an activity or receipt of a benefit upon performance of a steps
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`or steps of a patented method” and (2) “establishes the manner or timing of that performance.”
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`Akamai Tech., Inc. v. Limelight Networks, Inc., 797 F.3d 1020,1023 (Fed. Cir. 2015).
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`For the Group 1 devices, Ancora does not identify a single carrier or a single CDN (hired
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`by carriers or LGE) that allegedly performed the claimed steps LGE did not (allegedly) perform.2
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`Importantly, Ancora subpoenaed carriers
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`
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` Dkt. 199-10, Att. E. Indeed, Ancora also subpoenaed
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` Presumably if there were any evidence of LGE control over this CDN,
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`Ancora would have raised it. Instead, Ancora never mentions
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`
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`for the Group 1 devices. Meanwhile, LGE’s interrogatory responses confirm that for the Group 1
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`devices,
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`. Ex. B at 19-20, 29 (LGE final Resp. to Rog. Nos. 3, 4).
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`Ancora does not refute that LGE has no visibility into
`
`
`
`
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` the accused Group 1 devices. MSJ at 13-15; Ex. B at 19-20, 29. In
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`the absence of identifying whose “participation in an activity or receipt of a benefit” performed the
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`claimed steps, Ancora cannot survive summary judgment. See Perdiemco, LLC v. Industrack LLC,
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`No. 15-cv-727, 2016 WL 8135379, at *3 (E.D. Tex. Nov. 8, 2016) (granting summary judgment
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`where plaintiff could not identify a specific customer or how a customer’s participation in the
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`accused system was directed by defendant). Because Ancora offers no evidence as to who carried
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`out the claimed step and under what circumstances, Ancora cannot show that some unidentified
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`2 Ancora
`offers no evidence that
`were hired for Group 1 devices. Opp. at 4. The record is clear that they were instead hired for
`Group 2 mobile devices
` Dkt. 199-3 [Barber RRpt.], ¶¶ 70-71, 79, 82.
`3 All Exhibits (“Ex.”) herein are attached to the April 26, 2021 Declaration of Thomas R. Davis.
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`2
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 6 of 15
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`third party acted pursuant to LGE’s direction or control.
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`Ancora’s lone effort to rely on “LGE’s internal documents” fails miserably. See Opp. at 6
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`(depicting LGE_ANCORA00256874 at 14). Ancora relies on an excerpted image, that generically
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`references
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`, to maintain that LGE directed and controlled
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`the entire OTA update process. Id. Not only does the cited image fail to show the role of
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` in the OTA update process, Ancora excerpted out the title “
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`” and the timeline directly above the image, showing that
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` long after the asserted patent
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`expired in 2018.4 Dkt. 223-6 at 14 (emphasis added). In sum, Ancora’s best evidence of LGE’s
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`purported direction and control has nothing to do with the products accused in this case.
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`Ancora next contends that LGE exerts control because there is contractual language with
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` that LGE will make software updates available to
`
`. Opp. at 6. But “mere
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`instruction” relating to an “optional feature” that “may be used in a non-infringing manner” is not
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`sufficient to prove direction and control of a third party for purposes of divided infringement.
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`ESW, 2021 WL 1069047, at *4. Software functionality is no more than “instructions” that direct
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`a device to perform specified functions or operations. Sapphire Crossing LLC v. Abbyy USA
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`Software House, Inc., No. 20-cv-3590, 2020 WL 6318716, at *4 (N.D. Cal. 2020) (collecting
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`Federal Circuit cases). There is no evidence that LGE conditioned the benefit of using the software
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`updates upon
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` (or any other party’s) performance of claimed method steps, ESW, 2021
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`WL 1069047, at *4, and there are no cases that have found that “software functionality alone
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`satisfied the ‘conditioned benefit test.’” Sapphire Crossing, 2020 WL 6318716, at *4.
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`4 The 5G technology was not available until after the patent expired. See Ex. K (Announcement
`by Verizon that “On April 3, 2019, of we introduced 5G mobile service in [various cities].
`Customers in those cities were the first in the world to have a 5G-enabled smartphone connected
`to a 5G network.”); Ex. N (similar T-Mobile announcement dated December 2, 2019).
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`3
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`

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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 7 of 15
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`Not only do the “carrier contracts” (attached as Exhibits 6 through 11 to the opposition,
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`Dkt. 223-7 through 223-12) show there is lack of evidence that LGE exerts control over the
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`carriers, Ancora again excerpted relevant portions of the contracts. Each agreement Ancora cited
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`is attached hereto in full, illustrating that the carriers are setting the product requirements that LGE
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`must adhere to.
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`
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`When viewed in context, the evidence demonstrates that the carriers exert direction and
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`control over LGE, the supplier, and not the other way around.5
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`B.
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`There Is No Evidence That LGE Has Formed a “Joint Enterprise” with
` for the Group 1 Devices
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`LGE did not previously appreciate that Ancora was pursuing joint enterprise arguments
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`because Ancora has never pointed to evidence in support of such a position in expert reports or
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`otherwise. However, a joint enterprise theory also fails to establish direct infringement attributable
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`to LGE. First, Ancora incorrectly argues that the hiring of CDNs weighs in favor of a joint
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`enterprise. Opp. 7. Contrary to Ancora’s insinuation that LGE hired CDNs,
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`
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` for Group 1 devices. See MSJ at 11; Ex. A; Dkt. 199-10, Att.
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`E. Even setting that misstatement aside, to prove the existence of a joint enterprise, Ancora must
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`show (among three other factors), “an equal right to a voice in the direction of the enterprise, which
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`gives an equal right of control.” LBS Innovations, LLC v. Nokia USA Inc., 15-cv-1972, 2016 WL
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`5 By way of example:
`
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`4
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 8 of 15
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`3407611, at *2 (E.D. Tex. June 21, 2016). Because Ancora fails to satisfy the factor relating to an
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`equal voice and equal control for the all the same reasons Ancora cannot establish that LGE
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`exercises direction and control, the Court need not reach the remaining joint enterprise factors.
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`For the fourth prong of the joint enterprise test, Ancora relies on “the same evidence
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`showing LGE’s direction and control over the OTA update process.” Opp. at 8. Yet, as before,
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`Ancora has not identified any carrier or CDN that LGE is allegedly in a joint enterprise with, or
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`any evidence of a relationship between LGE and any specific third party where the two sides
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`enjoyed “an equal right of control” based on the language of an agreement or any other evidence.
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`This lack of a specific showing is fatal here as it was in LBS where the Court rejected the generic
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`suggestion that an agreement as to “overall business operations” between a parent and subsidiary
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`would establish a joint enterprise. Ancora has not meaningfully endeavored to satisfy the joint
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`enterprise standard. Finding that LGE does not direct and control third parties in performing the
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`claimed steps compels a finding that LGE has not entered into a joint enterprise.
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`C.
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`Ancora Offers No Evidence of LGE Directing or Controlling Any End-User
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`Ancora attempts to escape summary judgment based on three arguments – (1) LGE devices
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`“automatically install OTA updates without user intervention”; (2) “LGE’s end users do not
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`perform any claimed step”; and (3) if the end users perform any method step, “LGE directs or
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`controls that performance.” Opp. at 11-14. Ancora is wrong on each point.
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`First, Ancora does not dispute that the end-users of LGE devices had a choice to install
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`OTA updates and some declined to do so. That is, the OTA updates
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`
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`that the LGE devices may or can automatically update, Opp. at 12, but Ancora presents no
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`evidence that the LGE devices did in fact automatically update without user intervention. Id.
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` Ancora’s rebuttal evidence at best shows
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`5
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 9 of 15
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`Second, although end-users take part in alleged performance of the method steps, Ancora
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`presents a baseless new theory carving out end-user actions. Ancora’s expert opined that every
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`step of claim 1 is performed “by providing OTA Updates to the accused devices and configuring
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`the accused devices to receive, install, verify, and apply OTA Updates.” Dkt. 199-7 [Martin Phone
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`App’x], ¶¶ 44, 51, 64, 118, 141 (emphasis added); Dkt. 199-8 [Martin TV App’x], ¶¶ 19, 27, 32,
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`46, 52 (same). Ancora does not dispute that end-users commanded the accused devices to receive
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`and install OTA updates.6 Thus, the end-users here, like those in ESW and unlike those in SiRF,
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`did take part in allegedly performing the method steps, according to Ancora’s own expert. ESW,
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`2021 WL 1069047, at *3; SiRF Tech., Inc. v. ITC, 601 F.3d 1319, 1331 (Fed. Cir. 2010).
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`Finally, LGE did not direct or control the end-users to receive and install the OTA updates.
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`Ancora argues that LGE (1) “conditioned its end user’s participation in an activity or receipt of a
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`benefit” and (2) “established the manner and timing of performance.” Opp. at 15-17. LGE did
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`neither. First, LGE did not condition the benefit of updated software upon the users installing an
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`OTA update. For example,
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` Second, the end-users had control over when to install OTA updates (i.e., the timing
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`of performance), if ever. Dkt. 199-7 [Martin Phone App’x], ¶ 32 (at step 8, “
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` Like the end users in ESW, the end-users here had a choice of using the allegedly
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`6 Dkt. 199-7 [Martin Phone App’x], ¶ 29 (in step 2,
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`
`.
`7 Moreover, if LGE’s instructions to the users to use its devices in an infringing way, “combined
`with some benefit achieved through infringement, were enough, every claim of induced
`infringement would also state a claim of divided infringement.” ESW, 2021 WL 1069047, at * 4
`(quoting Lone Star Tech Innovations v. Asustek Comput., No. 6:19-CV-00059-RWS, 2020 WL
`6803249, *7 (E.D.Tex. Jan. 14, 2020)). Ancora does not and cannot allege inducement.
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`6
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 10 of 15
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`infringing feature or not (i.e., install OTA updates or not). ESW, 2021 WL 1069047, at *3. Like
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`Roku in ESW, LGE cannot be attributed with the end-users’ performance of the method steps. Id.
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`at 4. Thus, Ancora’s argument fails, and summary judgment of non-infringement is proper.
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`II.
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`THE ACCUSED DEVICES DO NOT “CONFIRM[] WHETHER A PROGRAM IS
`LICENSED” USING AT LEAST THE VERIFICATION STRUCTURE
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`The parties present competing interpretations of “verifying the program using at least the
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`verification structure,” which was construed to mean “confirming whether a program is licensed.”
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`The Court confirmed “that the time for [the Court] to resolve this [issue] is at summary judgment.”
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`MSJ at 23. Thus, the Court’s guidance is necessary to clarify that “confirming whether a program
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`is licensed” requires checking if the user has a legal right to use the software, (Dkt. 202-1 [’941
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`Patent] at 1:12-18 (directed to restricting “illegally copied software”)), and not merely whether
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`software originates from a trusted source and is not corrupted (Opp. at 19, 22, 25).8 See MSJ at
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`23-24. If LGE’s understanding of “licensed” is correct, there is no infringement, and Ancora does
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`not meaningfully dispute this. Ancora’s reliance on End-User License Agreement (“EULA”) is
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`an irrelevant distraction. Opp. at 20. Ancora offers no evidence that the LGE devices
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`satisfies the “verifying” step “using at least the verification structure.” MSJ at 28.
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`III.
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`THE ACCUSED DEVICES DO NOT USE A “PSEUDO-UNIQUE KEY”
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`Ancora’s pseudo-unique key arguments sweep aside the meaning of “unique.” Indeed,
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`Ancora does not dispute that
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` exist on numerous LGE devices and do not uniquely
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`identify any of them. Ancora misconstrues Dr. Barber’s testimony on this point, carefully omitting
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`8 No other court has decided this issue, including in the TCT Mobile case. Opp. at 24-25. The
`TCT Mobile court ruled on what information is within a “license record.” Dkt. 223-43 at 9-11.
`However, that court did not interpret “confirming whether a program is licensed,” which is an
`issue only in the present case as part of this Court’s construction for the “verifying” step.
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`7
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 11 of 15
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`portions of her opinion. Opp. at 33, n. 24 (citing Dkt. 223-44 [Barber Rpt], ¶163). In her report,
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`Dr. Barber sets out a detailed analysis regarding the domain of “uniqueness,” concluding that
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`uniqueness of a device is only relevant for a particular vendor. Dkt. 223-44, ¶163. That is, the
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`key must still uniquely identify a device, but that uniqueness is only relevant to
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`. Id. (“uniqueness [of a device] need only be guaranteed for a given vendor”).
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`Lastly, Ancora relies heavily on statements in a later-filed IPR petition to assert that LGE
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`agrees that a public key would be a pseudo-unique key. MSJ at 27-28. Ancora’s position is based
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`on yet another creatively selected quotation. When viewed in context, Dr. Wolfe confirms that the
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`public key disclosed in the prior art can actually be used to identify a particular device, unlike the
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`public keys at issue in this case, which are re-used across numerous devices.9 In other words, a
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`public key identifying a particular computer can be a pseudo-unique key, but a public key used
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`across numerous devices and models (as in the accused LGE devices) is not a pseudo-unique key.
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`IV.
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`THE
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` ANALYSIS HAS NO OS-LEVEL AGENT
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`Ancora concedes that certain devices use
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` Opp. at 40. Ancora apparently limits
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`this to
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` This unfortunate
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`similarity should not be confused with LGE’s reference to
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`”
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` As Ancora admits, some devices use
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`confirms that all non-A/B devices use
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`Phone App’x.], ¶ 114
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` Opp. at 40. Dr. Marin
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`. Dkt. 199-6 [Martin
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`
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`9 Dkt. 223-47 [Wolfe Decl.], ¶ 225 (“Schneck disclosed that “System IDs/Public keys” can be
`used to identify a device. … Based on this disclosure of Schneck and the knowledge of public
`key cryptography in the art as of May 1998, a POSA would have recognized that the public key
`would be able to identify a particular base unit 12.”) (emphasis added).
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`8
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 12 of 15
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` Thus,
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`. Ancora now argues that its two separate
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`
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`and independent theories overlap and
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`” relies on the OS-level agent in the
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` Opp. at 40; Dkt. 227 at 4. This confirms that no OS-level agent is used within
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`the “
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` Thus, none of the non-
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`A/B devices can infringe under Ancora’s
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`analysis, and summary judgment is proper.
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`V.
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`THE ACCUSED DEVICES DO NOT PERFORM THE STEP OF “ACTING ON
`THE PROGRAM ACCORDING TO THE VERIFICATION” IN CLAIM 1
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`The Court made clear that the “acting” step included only negative actions and excluded
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`positive actions. Dkt. 93 at 27-28. Ancora offers no evidence that the LGE devices performed
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`any such negative actions. Instead, Ancora relies entirely on “successfully installed” updates,
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`which are excluded from the “acting” step. Dkt. 199-17, ¶ 210. Ancora’s failure to prove that the
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`LGE devices performed the “acting” step warrants summary judgment of non-infringement.
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`Ancora makes inflammatory and baseless assertion that its inability to “show the exact
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`extent to which negative actions actually took place” is due to
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`
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` This argument is untenable because
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`Ancora bases its entire liability and damages theories on completed updates. Dkt. 199-17, ¶ 210.
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`Further, Ancora’s assertions
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`are meritless. Ancora conducts no analysis under
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`the applicable tests
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`. See
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`Costal Bridge Co., LLC v. Heatec, Inc., 833 Fed. Appx. 565, 573–74 (5th Cir. 2020). First, the
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`information Ancora sought was “from June 21, 2013, to October 1, 2018” (Dkt. No. 212-15 at 8;
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`see also Ex. B, p. 7, 22), whereas the cited email was from 2020. Dkt. No. 212-16 at 41–42.
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`Further, the email concerned
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`9
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 13 of 15
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`Thus, Ancora should not be relieved of its burden to prove infringement or be permitted to make
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`an extraordinarily prejudicial and incorrect statement to the jury that
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`.
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`Ancora insinuates without basis that LGE made false representations about the scope of its
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`discovery productions and what documents were in LGE’s possession, custody, or control. Opp.
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`at 44. In numerous discovery hearings, LGE explained that it was producing—and did produce—
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`all responsive information it could locate within its possession, custody, or control. See, e.g., Dkt.
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`120 at 12:17–25 [Nov. 2, 2020 Hr’g Tr.]. LGE also produced its document retention policy and
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`explained repeatedly that information sought from 2013 to 2018 was old, but LGE would (and did)
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`produce what it could find. See Ex. M at LGE_ANCORA00215943-48. Ancora has simply
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`refused accept that many documents from 2013 to 2018 were no longer in LGE’s possession at the
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`time this lawsuit was filed, or never existed in the first place. Dkt. No. 120 at 12:17–25.
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`VI.
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`THE “REPRESENTATIVE CODE” IS NOT REPRESENTATIVE
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`The lack of mapping between accused products and “representative” code is fatal.
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`
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`). Of the 200+ accused products, Dr. Martin’s “representative code” reflects less
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`than 10 devices
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`Stone”
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`. Despite having a “Rosetta
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` he failed to identify any mapping
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`between the accused devices and the allegedly representative code. Ancora provides no way for
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`LGE, the Court, or the jury to discern which products are represented by which code.
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`VII. CONCLUSION
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`LGE respectfully requests that the Court grant summary judgment of non-infringement.
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 14 of 15
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`Date: April 26, 2021
`
`Respectfully submitted,
`
`/s/ Elizabeth M. Chiaviello
`
`
`
`Winstol D. Carter, Jr.
`Texas Bar No. 03932950
`winn.carter@morganlewis.com
`Thomas R. Davis
`Texas Bar No. 24055384
`thomas.davis@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1000 Louisiana Street, Suite 4000
`Houston, Texas 77002-5006
`T. 713.890.5000
`F. 713.890.5001
`
`Collin W. Park
`collin.park@morganlewis.com
`District of Columbia Bar No. 470486
`Natalie A. Bennett
`natalie.bennett@morganlewis.com
`Illinois Bar No. 6304611
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, D.C. 20004-2541
`T. 202.739.3000
`F. 202.739.3001
`
`Elizabeth M. Chiaviello
`Texas Bar No. 24088913
`elizabeth.chiaviello@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1717 Main Street, Suite 3200
`Dallas, Texas 75201-7347
`T. 214.466.4000
`F. 214.466.4001
`
`Attorneys for Defendants LG Electronics
`Inc. and LG Electronics U.S.A., Inc.
`
`11
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`Case 1:20-cv-00034-ADA Document 243 Filed 05/04/21 Page 15 of 15
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`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who have consented to electronic
`
`service are being notified of the filing of this document via the Court’s CM/ECF system per
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`Local Rule CV-5(b)(1). I also hereby certify that Plaintiff’s counsel of record are being served
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`with a copy of the foregoing document via electronic mail on this 26th day of April, 2021.
`
`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
`
`12
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