Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 1 of 16
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
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`CASE NO. 6:20-cv-00267-ADA
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`JURY TRIAL DEMANDED
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`CASE NO. 6:20-cv-00269-ADA
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`JURY TRIAL DEMANDED
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`CASE NO. 6:20-cv-00272-ADA
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`JURY TRIAL DEMANDED
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`VOIP-PAL.COM, INC.,
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`Plaintiff,
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`v.
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`META PLATFORMS, INC. and
`WHATSAPP LLC,
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`Defendants.
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`VOIP-PAL.COM, INC.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`VOIP-PAL.COM, INC.,
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`Plaintiff,
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`v.
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`AMAZON.COM, INC., et al.,
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`Defendants.
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`DEFENDANTS’ REPLY CLAIM CONSTRUCTION BRIEF
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 2 of 16
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`TABLE OF CONTENTS
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`Page
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`“network element[s]” ......................................................................................................... 1
`I.
`“identifier[s]” ..................................................................................................................... 3
`II.
`“first participant profile” .................................................................................................... 4
`III.
`“routing message” .............................................................................................................. 6
`IV.
`“private network” ............................................................................................................... 7
`V.
`“gateway” ........................................................................................................................... 9
`VI.
`VII. Conclusion ....................................................................................................................... 10
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`-i-
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 3 of 16
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`Bd. of Regents of the Univ. of Tex. Sys. v. BENQ Am. Corp.,
`533 F.3d 1362 (Fed. Cir. 2008)..................................................................................................3
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`Bell Atl. Network Servs., Inc. v. Covad Commc’ns Grp., Inc.,
`262 F.3d 1258 (Fed. Cir. 2001)..................................................................................................4
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`Mirror Imaging, LLC v. Bank of Am., N.A.,
` Case No. 6:21-cv-00463-ADA, Dkt. No. 29 (W.D. Tex. Feb. 22, 2022) .................................1
`
`Thorner v. Sony Comput. Ent. Am. LLC,
`669 F.3d 1362 (Fed. Cir. 2012)..................................................................................................7
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`-ii-
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 4 of 16
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`I.
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`“network element[s]”
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`The term “network element” is indefinite because a POSITA would not understand its
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`meaning with reasonable certainty. As Dr. Vijay Madisetti confirms, a POSITA would not know
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`whether the claimed “network element” is limited to a single device or could comprise multiple
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`devices, or if “network element” refers to a logical structure in software and does not encompass
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`any specific physical devices at all. See Dkt. No. 73-11 ¶ 34.
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`Unable to resolve these ambiguities, VoIP-Pal and its expert (Dr. Mangione-Smith2)
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`sidestep the question. Rather than affirmatively state a POSITA would understand the term to
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`comprise multiple devices and logical structures, Dr. Mangione-Smith states (the legal conclusion)
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`that the term is not indefinite “even if” it is so broad.3 See Dkt. No. 84-4 ¶ 25 (“Even if the term
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`‘network element’ is broad enough to cover multiple devices that work together to implement a
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`network function, that does not make the term indefinite.”). Thus, the principal questions remain
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`unanswered: Does the term “network element” refer to one device or multiple devices, and does
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`the term “network element” instead refer to mere logical structures?
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`1 Unless otherwise noted, all docket numbers identified herein refer to entries in Case No. 6:20-
`cv-00267-ADA. Equivalent entries, albeit with different docket numbers, appear in all other cases
`identified on the caption page of this brief.
`2 VoIP-Pal circumvents the Court’s page limits by citing five pages of Dr. Mangione-Smith’s
`declaration without any explanation at all. See Dkt. No. 84 (“Resp. Br.”), 9–10, n.28, 32. The
`Court should therefore disregard Dr. Mangione-Smith’s unexplained testimony that is only
`improperly incorporated by reference, and not linked to the issues presented in VoIP-Pal’s brief.
`3 To be clear, Defendants are not arguing that the term is indefinite merely because it may be broad;
`rather, Defendants are pointing out that the patent fails to provide reasonable clarity on just how
`broad the term is in this context. This Court has found a claim term indefinite under similar
`circumstances. See Mirror Imaging, LLC v. Bank of Am., N.A., Case No. 6:21-cv-00463-ADA,
`Dkt. No. 29, 2 (W.D. Tex. Feb. 22, 2022) (finding “wherein the first entity and the second entity
`are distinct or related” indefinite); see also id., Dkt. No. 20, 15 (arguing for the indefiniteness of
`that term because it “can have many different meanings” in light of the absence of “explanation or
`guidance in the specification”).
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`1
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 5 of 16
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`In their effort to avoid resolving the ambiguities in “network element,” VoIP-Pal and Dr.
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`Mangione-Smith argue that “[i]t is not necessary to answer any of these implementation questions
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`to understand the bounds of the claims with reasonable certainty.” Resp. Br., 8; Dkt. No. 84-4 ¶
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`25. But these are more than mere “implementation questions”—they are essential to determining
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`the scope of the claims. By way of example, an “implementation question” for a claim directed to
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`a “car” could include whether the implementation is an SUV or sedan. But that is not the issue
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`here. Instead, an analog to the issue here is whether the term “car” is itself limited to one car or is
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`broad enough to encompass a fleet of cars, or whether a “car” could be a purely logical
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`representation of a car (such as a picture). This goes to the heart of determining claim scope and
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`is precisely the issue left unresolved by the ’606 patent.
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`Reworking its proposed construction from prior litigation, VoIP-Pal now contends that a
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`“network element” is “a device or component of the communication network associated with at
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`least one IP address.”4 Compare Resp. Br., 8, with Dkt. No. 73-14, 189 (construing “network
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`element” as “a network device associated with a network address.”). But VoIP-Pal’s new
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`construction still fails to resolve the uncertainty in claim scope because it is unclear whether the
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`“component” (a term never used in the patent’s specification nor in VoIP-Pal’s construction from
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`a previous matter) is physical or logical in nature, and the construction provides no guidance
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`regarding whether “network element” refers to one device or multiple devices. VoIP-Pal’s
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`construction is also internally inconsistent. VoIP-Pal and Dr. Mangione-Smith rely on a text that
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`identifies as “network elements” things that do not have an IP address, including “cables,
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`multiplexors, [and] line systems” (Dkt. No. 84-2, 295), while simultaneously insisting that an
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`assigned IP address is the defining characteristic of a network element. See Resp. Br., 8. This
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`4 All emphasis is added unless indicated otherwise.
`2
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 6 of 16
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`incompatibility further highlights the impossibility of identifying the term’s outer limits and the
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`issues with VoIP-Pals’ newest proposed construction.
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`VoIP-Pal’s construction also lacks intrinsic support. Since the term “network element”
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`never appears in the patent’s written description, VoIP-Pal first points to the three instances where
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`the patent’s description uses the term “elements.” See Resp. Br., 7 n.21 (citing ’606 patent, 14:2-
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`63). But in the first two instances, the patent merely teaches that those specific examples of
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`“elements” have IP/UDP addresses—it never resolves the two core ambiguities at issue here. See
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`Dkt. No. 73-3 (“’606 patent”), 14:1-7, 18-21. In the third instance discussing an “element,” VoIP-
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`Pal points to FIG. 7 as purported support, but that figure shows a “routing controller,” and does
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`not define the bounds of “network elements” generally. See Resp. Br., 8. Similarly, VoIP-Pal
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`points to the specification’s discussion of “nodes” as purported support for its construction. See
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`Resp. Br., 9 (“The specification even gives examples of routing messages identifying specific
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`network elements (‘sp.yvr.digifonica.com’, ‘sp.lhr.digifonica.com’) to set up a communication to
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`either the ‘same node’ or to a ‘different node’”). But “node” and “network elements” are different
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`claim terms and therefore presumed to have different meanings5 and VoIP-Pal does not explain
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`how the specification’s discussion of “nodes” informs the plain meaning of “network element.”
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`The term “network element” is indefinite because a POSITA would not understand the
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`term’s outer bounds with reasonable certainty, particularly whether “network element” is broad
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`enough to also include multiple devices or purely logical structures in software.
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`II.
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`“identifier[s]”
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`VoIP-Pal argues that Defendants only point to one example “identifier” from a preferred
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`embodiment to support their construction. Resp. Br., 10. But the specification discloses only one
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`5 See Bd. of Regents of the Univ. of Tex. Sys. v. BENQ Am. Corp., 533 F.3d 1362, 1371 (Fed. Cir.
`2008) (“Different claim terms are presumed to have different meanings.”) (citation omitted).
`3
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`algorithm to produce the claimed new second participant “identifier,” and that algorithm is based
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`on a requirement that the participant identifier must comply with a “predefined username
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`format.” ’606 patent, 2:61-64; see also 20:38-44 (requiring that participant “identifier” complies
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`with “a predefined digit format.”). The specification thus requires that an “identifier” be a value
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`with a pre-defined format because the only disclosed invention cannot operate without it. See Bell
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`Atl. Network Servs., Inc. v. Covad Commc’ns Grp., Inc., 262 F.3d 1258, 1269–70 (Fed. Cir. 2001)
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`(relying on specification usage when “the ordinary meaning of the non-technical term . . . is
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`sufficiently broad and amorphous that the scope of the claim language can be reconciled only with
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`recourse to the written description”) (citation omitted). Indeed, VoIP-Pal does not even attempt
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`to argue that the claims are functional without using a pre-defined format for the claimed identifier.
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`VoIP-Pal argues that “identifier” “does not require any particular predefined format” by
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`listing as examples “a phone number or a username or even an IP address.” Resp. Br., 10–11.
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`Yet, the patent itself requires a predefined format for every example that VoIP-Pal lists. See,
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`e.g., ’606 patent, 19:5–9 (referencing “the International Telecommunications Union (ITU)
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`Telecommunications Standards Sector (ITU-T) E.164 Recommendation” for telephone number
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`formatting), 23:44–46 (“classify[ing] the call as a private network call when the callee identifier
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`complies with a pre-defined format, i.e. is a valid user name”).
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`III.
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`“first participant profile”
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`VoIP-Pal makes two arguments against Defendants’ proposed construction, neither of
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`which comport with the specification’s plain language. First, VoIP-Pal contends that including
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`information relating to a call participant in a PSTN system is just a preferred embodiment in the
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`specification. Not so. The specification specifically states, without reference to any particular
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`4
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`embodiment, that a “dialing profile [i.e., participant profile]6 is a record identifying calling
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`attributes of the caller identified by the caller identifier” and “dialing profiles represent calling
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`attributes of respective subscribers.” ’606 patent, 18:49–52. VoIP-Pal admits that “[g]enerally
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`speaking, ‘dialing profiles represent calling attributes of respective subscribers.’” Resp. Br., 12.
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`The specification uses this term “calling attributes” to refer to PSTN system information.
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`It differentiates these PSTN “calling attributes” from information used to make connections on
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`other networks (e.g., IP). For example, in connection with FIG. 9 (and FIGs. 10–12), the
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`specification identifies a “user name field 258” and “domain field 260” separate from “calling
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`attributes comprising a national dialing digits (NDD) field 262, an international dialing digits
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`(IDD) field 264, a country code field 266, a local area codes field 267 . . .” ’606 patent, 18:41–49.
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`VoIP-Pal acknowledges that at least “NDD 262 and IDD 264 codes are used on the PSTN.” Resp.
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`Br., 12; see also ’606 patent, 19:4–18 (defining the “calling attributes” fields with respect to the
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`ITU-T E.164 standard for PSTNs). The Summary of the Invention similarly states “[t]he calling
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`attributes may include an international dialing digit,” “national dialing digit,” “area code,” or
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`“number length range.” ’606 patent, 4:32–47. Here again, the specification uses “calling
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`attributes” only to refer to PSTN system information, not IP network information (such as an IP
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`address). VoIP-Pal’s attempt to construe “first participant profile” to allow exclusion of PSTN
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`system information must be rejected. The specification requires participant profiles (i.e., “dialing
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`profiles”) to “identify[]” or “represent[]” PSTN system information (i.e., “calling attributes”).
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`VoIP-Pal’s second argument fares no better. VoIP-Pal claims that because “the preferred
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`embodiment allows ‘private network’ (non-PSTN) destinations to be called by using callee
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`identifiers with [PSTN] codes,” the participant need not be in a PSTN system. Resp. Br., 12–13.
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`6 The specification directly ties the claimed “participant profile” to a “dialing profile.” See Dkt.
`No. 73 (“Op. Br.”), 9.
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`5
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`But VoIP-Pal commits the very error that it (incorrectly) accuses Defendants of committing,
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`namely relying on a preferred embodiment to contort the meaning of the claims. The fact that
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`certain calls may be completed on the private network without interfacing with a PSTN does not
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`mean the system can be completely untethered from a PSTN and its concomitant calling attributes.
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`Rather, VoIP itself contends that the purpose of the claimed system is to interface with and decide
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`between the two networks (i.e. PSTN and IP) on a case-by-case basis. See Resp. Br., 1 (asserting
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`that the ’606 patent was allegedly capable of “seamlessly integrating a private voice-over-internet
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`protocol (‘VOIP’) communication network” with a “public switched telephone network
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`(‘PSTN’)”). VoIP-Pal’s attempt to rely on a preferred embodiment to exclude information about
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`a PSTN system participant from the first participant profile must be rejected as contrary to VoIP-
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`Pal’s (and the patent’s) own description of the alleged invention.
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`IV.
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`“routing message”
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`The term “routing message” is defined by FIG. 15 and its accompanying text (’606 patent,
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`21:47–60), which identifies the “routing message format” used in the patent and contains specific
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`fields that are required and others that are optional. Contrary to VoIP-Pal’s assertions, nothing in
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`the patent identifies FIG. 15 as limited to a particular embodiment.
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`VoIP-Pal points to the fact that FIG. 32 is identified as “an exemplary routing message”
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`(id., 12:19–20), but this is only because it, and FIGs. 16 and 25, contain specific messages
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`containing example data. FIG. 15, by contrast, is never identified as merely exemplary. In fact, it
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`is identified as a “generic” prototype for routing messages, which reflects that it is a template for
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`all the routing messages used elsewhere in the patent. Indeed, each of the messages that VoIP-Pal
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`identifies in FIGs. 16, 25, and 32 contain all the required parts of the routing message format and
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`are therefore consistent with Defendants’ construction.
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`6
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 10 of 16
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`VoIP-Pal claims that the text identified by call-out 656 in FIG. 32 is a routing message, but
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`the patent identifies this as the “IP address of the current node” (id., 27:31–34)—only a part of a
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`complete routing message when combined with the data identified in the remainder of FIG. 32,
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`which is transmitted as a single message. Id., FIGs. 8A, 8C; 26:24–29, 26:57–61, 27:21–25,
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`27:34–36.) As assembled, the resulting message includes all elements identified in Defendants’
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`construction, in accordance with what the patent teaches is required of a “routing message.”
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`V.
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`“private network”7
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`Though it alleges that most of the claims presently in dispute have their plain and ordinary
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`meaning and do not require construction, VoIP-Pal argues for a vague and confusing definition of
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`the simple term “private network” that the specification does not support.
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`VoIP-Pal argues that the ’606 patent uses the term “private network” in a manner that is
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`“not conventional” (Resp. Br., 15), yet fails to point out any instance where the ’606 patent defines
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`private network in an unconventional way or in any manner that diverges from the term’s plain
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`and ordinary meaning. If a patentee wishes to redefine a common term, they must clearly state
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`that intention and set forth a definition for it. Thorner v. Sony Comput. Ent. Am. LLC, 669 F.3d
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`1362, 1365-1366 (Fed. Cir. 2012). VoIP-Pal does not identify any portion of the specification
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`where the patentee acted as its own lexicographer, nor does VoIP-Pal point out any prosecution
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`history necessitating its proposed construction. VoIP-Pal cites to embodiments in which privately
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`owned components communicate over the Internet, but these are not a clear manifestation of the
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`patentee’s desire to confine “private network” to something other than its conventional meaning.
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`7 Although Defendants Meta Platforms, Inc. and WhatsApp LLC (collectively, “Meta”) had agreed
`to VoIP-Pal’s proposed construction, Meta does not agree with VoIP-Pal’s apparent interpretation
`of that construction as manifested in VoIP-Pal’s responsive brief. Meta therefore joins the
`remaining defendants in clarifying that the plain and ordinary meaning of a “private network” does
`not span the public Internet (as it would otherwise not be “private”).
`7
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 11 of 16
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`VoIP-Pal ignores the clear distinction that the patent draws between private networks and
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`the public Internet, consistent with the ordinary meaning of “private network.” See ’606 patent,
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`1:29-31 (“an IP network, such as the public Internet, or a private network”), 14:5-6 (“the [public]
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`Internet or a private network”). VoIP-Pal points to the places in the specification where the public
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`Internet is used, but this has no relevance to whether the expressly distinguished “private network”
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`carries its ordinary meaning. The patent identifies uses of a public network like the Internet as an
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`alternative to use of a private network, while claim 8 is explicitly limited to uses of only a private
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`network. See, e.g., ’606 patent, Abstract, 2:2-5, 14:64-15:9.
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`VoIP-Pal’s proposed construction would introduce uncertainty because it does not address
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`how much control the private elements must exert for the network to be “private.” It argues that:
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`the “private network” is private in the sense that the network elements that establish
`a call are privately controlled by an entity (e.g., by a system operator, such as
`previous predecessor-in-title “Digifonica”), but this does not require that each
`machine along the communication path must be controlled by the system
`operator—e.g., every intervening machine on the Internet need not be controlled by
`the system operator. If the operation of the overall communication network is
`privately controlled by a system operator, the network can fall within the scope of
`“private network” as this term is used in the specification.
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`Resp. Br., 15-16. VoIP-Pal’s construction fails to provide clear boundaries for its definition and
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`struggles to explain its definition using unbounded examples evidenced by the use of qualifiers
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`such as “in the sense that.” Further, VoIP-Pal argues that “each machine along the communication
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`path” need not be controlled by a system operator to be considered private, but does not explain
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`how many or what percentage of machines must be privately controlled to fall within “private
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`network.” VoIP-Pal’s proposed construction does not clarify if one or ten or ninety-nine out of
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`one hundred machines privately controlled along the communications path would render a network
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`private under VoIP-Pal’s construction. VoIP-Pal further amplifies this confusion when it states
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`that if the “overall” communication network is privately controlled by a system operator then the
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`8
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 12 of 16
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`network “can” fall within the scope of “private network.” Again, VoIP-Pal’s construction would
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`introduce unclear bounds by using the qualifier “overall” with respect to the network in question,
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`as even VoIP-Pal seems to realize when it states that in such a situation the network “can” (not
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`“must”) be a private network. VoIP-Pal’s proposed construction would cause confusion for a jury
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`deciding if an accused system included a claimed private network. VoIP-Pal advocates a sliding
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`scale for defining a public network with no markers delineating it from a private network.
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`VI.
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`“gateway”
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`The plain and ordinary meaning of “gateway” is “a device that connects networks that use
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`different communication protocols.” By contrast, VoIP-Pal’s construction of “gateway” as simply
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`“a device that connects at least two networks” is impermissibly overbroad because it does not
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`require any difference in the two networks being connected. If two networks were not dissimilar,
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`then they would require no “gateway” between them; rather, they would be connected by the
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`standard switches and routers that transfer information between any two network points. See Dkt.
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`No. 73-16, 232 (“A gateway both transfers information and converts it to a form compatible with
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`the protocols used by the receiving network”). A “gateway” is used to connect dissimilar
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`networks, but VoIP-Pal’s proposal omits this fundamental requirement.
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`VoIP-Pal points to US Patent App. No. 2014/0024367A1 (“Björsell”)8 and its description
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`of a “call controller’s” functionality, not a gateway’s functionality, to argue that, just because a
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`gateway is assigned an IP address, that necessarily means a gateway can connect two IP networks
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`(which use the same communication protocol). See Resp. Br., 18–19, n.78. But VoIP-Pal’s
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`argument is not actually supported by Björsell because providing a gateway with an IP address so
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`that it can connect to IP devices on one side does not indicate anything about the type of network
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`8 Björsell matured into U.S. Patent No. 10,880,721 (the “’721 patent”).
`9
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`on the gateway’s other side.9 VoIP-Pal also incorrectly argues Björsell discloses a gateway
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`connecting two IP networks to perform network address translation (NAT), but that portion of the
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`specification describes the operation of a router, not a gateway, performing NAT. See Resp. Br.,
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`17, n.72 (citing ’721 patent, 24:63, “a device performing NAT, typically a router”).
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`VoIP-Pal also cites U.S. Patent No. 7,486,684 (“Chu”) to incorrectly argue that gateways
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`use the same protocol on both sides. Resp. Br., 18, n.73. But Chu’s invention is of “packet
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`switches (or special gateway),” which Chu labels an “Inter-Net” or “Inter-VPN” gateway. Dkt.
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`No. 84-3, FIG. 14a, 2:47-48, 14:3. Chu’s “special gateway,” which is actually a “packet switch,”
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`would not be understood as the plain and ordinary meaning of “gateway” because Chu acted as his
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`own lexicographer in disclosing a “special gateway” from the “packet switch” he invented.
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`Tellingly, VoIP-Pal avoids Chu’s descriptions of a “traditional packet-to-TDM gateway,” which
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`connects networks that use different protocols. See id., 4:15; see also id., 1:36-38 (“[A] gateway
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`is needed to convert the IP … traffic to the traditional … (TDM) format.”).
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`VII. Conclusion
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`VoIP-Pal’s constructions are untethered from the patent’s disclosure, fail to resolve
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`fundamental ambiguities in the claim terms, and improperly shift the claims of the ’606 patent
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`from technology that addresses interoperability of VoIP and traditional PSTNs to technology that
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`addresses purely IP-based services that are not compatible with PSTNs. Defendants respectfully
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`request that the Court adopts their proposed claim constructions, which, unlike VoIP-Pal’s
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`constructions, are actually consistent with both the intrinsic and extrinsic record.
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`9 Notably, the ’721 patent (which issued from the Björsell application) claims support that a
`“gateway” is a device that connects networks that use different communication protocols. For
`example, dependent claim 133 introduces the term “gateway” specifically “if the destination node
`is a PSTN telephone,” while claim 130 on which it depends requires that the call is initiated on an
`“IP network;” thus, the “gateway” of claim 133 is only added to connect an IP network to a PSTN.
`Case No. 6:21-cv-00665-ADA, Dkt. 41-3 (“’721 patent”) 47:39-48:4, 48:10-15.
`10
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`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 14 of 16
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`Dated: April 22, 2022
`
`/s/ Joshua Glucoft
`Michael E. Jones
`Texas Bar No. 10929400
`mikejones@potterminton.com
`POTTER MINTON
`110 N. College Ave., Suite 500
`Tyler, Texas 75702
`Tel: (903) 597-8311
`Fax: (903) 593-0846
`
`Ellisen Shelton Turner (Pro Hac Vice)
`ellisen.turner@kirkland.com
`Joshua Popik Glucoft (Pro Hac Vice)
`josh.glucoft@kirkland.com
`KIRKLAND & ELLIS LLP
`2049 Century Park East, Suite 3700
`Los Angeles, CA 90067
`Tel: (310) 552-4220
`Fax: (310) 552-5900
`
`Kristina R. Cary (Pro Hac Vice)
`kristina.cary@kirkland.com
`KIRKLAND & ELLIS LLP
`200 Clarendon Street
`Boston, MA 02116
`Tel: (617) 385-7500
`Fax: (617) 385-7501
`
`Jeanne M. Heffernan
`jheffernan@kirkland.com
`KIRKLAND & ELLIS LLP
`401 Congress Avenue
`Austin, TX 78701
`Tel: (512) 678-9123
`Fax: (512) 678-9101
`
`ATTORNEYS FOR DEFENDANTS
`META PLATFORMS, INC. AND
`WHATSAPP, INC.
`
`
`
`
`
`
`/s/ Robert W. Unikel
` Robert W. Unikel (Pro Hac Vice)
`robertunikel@paulhastings.com
`John A. Cotiguala (Pro Hac Vice)
`johncotiguala@paulhastings.com
`Matthew Lind (Pro Hac Vice)
`mattlind@paulhastings.com
`Grayson S. Cornwell (Pro Hac Vice)
`graysoncornwell@paulhastings.com
`PAUL HASTINGS LLP
`71 South Wacker Drive, 45th Floor
`Chicago, IL 60606
`Tel: (312) 499-6000
`Fax: (312) 499-6100
`
`Robert R. Laurenzi (Pro Hac Vice)
`robertlaurenzi@paulhastings.com
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Tel: (212) 318-6000
`Fax: (212) 319-4090
`
`Matthias A. Kamber (Pro Hac Vice)
`matthiaskamber@paulhastings.com
`PAUL HASTINGS LLP
`101 California Street, 48th Floor
`San Francisco, CA 94111
`Tel: (415) 856-7000
`Fax: (415) 856-7100
`
`Ariell N. Bratton (Pro Hac Vice)
`ariellbratton@paulhastings.com
`Cole D. Malmberg (Pro Hac Vice)
`colemalmberg@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Tel: (858) 458-3000
`Fax: (858) 458-3005
`
`Paige Arnette Amstutz
`State Bar No.: 00796136
`pamstutz@scottdoug.com
`Steve McConnico
`
`
`
`11
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`

`

`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 15 of 16
`
`
`Texas Bar No. 13450300
`smcconnico@scottdoug.com
`SCOTT, DOUGLASS & MCCONNICO, LLP
`303 Colorado Street, Suite 2400
`Austin, TX 78701
`Tel: (512) 495-6300
`Fax: (512) 495-6399
`
`ATTORNEYS FOR DEFENDANT
`GOOGLE LLC
`
`
`/s/ Daniel T. Shvodian
` M. Craig Tyler
`Texas Bar No. 00794762
`CTyler@perkinscoie.com
`PERKINS COIE LLP
`500 W 2nd St, Suite 1900
`Austin, TX 78701-4687
`Tel: (737) 256-6113
`Fax: (737) 256-6300
`
`Daniel T. Shvodian, (Pro Hac Vice)
`dshvodian@perkinscoie.com
`Christopher L. Kelley (Pro Hac Vice)
`ckelley@perkinscoie.com
`PERKINS COIE LLP
`3150 Porter Drive
`Palo Alto, CA 94304-1212
`Tel: 650.838.4300
`Fax: 650.838.4350
`
`ATTORNEYS FOR DEFENDANTS
`AMAZON.COM, INC.;
`AMAZON.COM SERVICES LLC; AND
`AMAZON WEB SERVICES, INC.
`
`12
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`

`

`Case 6:20-cv-00272-ADA Document 71 Filed 04/22/22 Page 16 of 16
`
`CERTIFICATE OF SERVICE
`
`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
`
`that, on April 22, 2022, all counsel of record who have appeared in this case are being served with
`
`a copy of the foregoing via the Court’s CM/ECF system.
`
`/s/ Daniel T. Shvodian
`Daniel T. Shvodian
`
`