Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 1 of 14
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`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`FUTURE LINK SYSTEMS, LLC,
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Case No.
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`APPLE INC.,
`
`
`
`
`
`
`
`Defendant.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`AGAINST APPLE INC.
`
`This is an action for patent infringement arising under the Patent Laws of the United States
`
`of America, 35 U.S.C. § 1 et seq., in which Plaintiff Future Link Systems, LLC (“Plaintiff” or
`
`“Future Link”) makes the following allegations against Defendant Apple Inc. (“Defendant”):
`
`INTRODUCTION
`
`1.
`
`This complaint arises from Defendant’s unlawful infringement of the following
`
`United States patents owned by Plaintiff, each of which relates to improvements in electronic
`
`circuitry in computing devices and processors: United States Patent Nos. 6,317,804 (“’804
`
`Patent”); 6,622,108 (“’108 Patent”); 6,807,505 (“’505 Patent”); and 7,917,680 (“’680 Patent”)
`
`(collectively, the “Asserted Patents”).
`
`PARTIES
`
`2.
`
`Plaintiff Future Link Systems, LLC is a Delaware limited liability company
`
`organized and existing under the law of the State of Delaware, with its principal place of business
`
`at 3945 Freedom Circle, Suite 900, Santa Clara, California 95054. Future Link is the sole owner
`
`by assignment of all right, title, and interest in each Asserted Patent.
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`
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`1
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`6:21-cv-00263
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`

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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 2 of 14
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`3.
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`On information and belief, Defendant Apple Inc. is a publicly traded corporation
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`organized under the laws of the State of California, with its principal place of business at One
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`Apple Park Way, Cupertino, CA 95014. Apple Inc. may be served with process through its
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`registered agent, CT Corporation System, at 818 West Seventh Street, Suite 930, Los Angeles, CA
`
`90017.
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`JURISDICTION AND VENUE
`
`4.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a).
`
`5.
`
`This Court has personal jurisdiction over Defendant in this action because
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`Defendant has committed acts within this District giving rise to this action and has established
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`minimum contacts with this forum such that the exercise of jurisdiction over Defendant would not
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`offend traditional notions of fair play and substantial justice. Defendant, directly and through
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`subsidiaries or intermediaries, has committed and continues to commit acts of infringement in this
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`District by, among other things, importing, offering to sell, and selling products that infringe the
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`asserted patents.
`
`6.
`
`Venue is proper in this District under 28 U.S.C. § 1400 (b). Defendant is registered
`
`to do business in Texas, and upon information and belief, Defendant has transacted business in
`
`this District and has committed acts of direct and indirect infringement in this District by, among
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`other things, importing, offering to sell, and selling products that infringe the asserted patents.
`
`Defendant has regular and established places of businesses in this District, including at 12545
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`
`
`2
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`

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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 3 of 14
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`Riata Vista Cir., Austin, Texas 78727; 12801 Delcour Dr., Austin, Texas 78727; and 3121 Palm
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`Way, Austin, Texas 78758.1
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`FACTUAL ALLEGATIONS
`
`7.
`
`On April 3, 2018, Future Link sent a notice letter to Apple asserting the
`
`infringement of Future Link patents, including the ’804 Patent, ’108 Patent, and ’505 Patent.
`
`8.
`
`On May 15, 2018, Future Link and Apple held an initial meeting where Future Link
`
`presented an overview of its portfolio and claim charts for various Future Link patents, including
`
`the ’804 Patent, ’108 Patent, ’505 Patent and ’680 Patent.
`
`9.
`
`On August 1, 2018, Apple presented non-infringement arguments with respect to
`
`Future Link patents, including the ’804 Patent, ’108 Patent, ’505 Patent and ’680 Patent.
`
`10.
`
`On October 4, 2018, Future Link responded to Apple’s non-infringement
`
`arguments with respect to Future Link patents, including the ’804 Patent, ’108 Patent, ’505 Patent
`
`and ’680 Patent.
`
`11.
`
`On November 29, 2018, Apple presented invalidity arguments with respect to
`
`Future Link patents, including the ’804 Patent, ’108 Patent, ’505 Patent and ’680 Patent.
`
`12.
`
`On March 14, 2019, Future Link responded to Apple’s prior art contentions for
`
`Future Link patents, including the ’804 Patent, ’108 Patent, ’505 Patent and ’680 Patent are
`
`provided.
`
`
`1 See, e.g., https://www.apple.com/newsroom/2019/11/apple-expands-in-austin/;
`https://goo.gl/maps/8Cr3zaxvwpePsWwL6; https://goo.gl/maps/UWFYdgUfZVFr8FG26;
`https://www.apple.com/retail/domainnorthside/.
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`
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`
`3
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 4 of 14
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`13.
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`Despite these efforts, Apple refused to discuss appropriate terms for a license to
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`Plaintiff’s patents. Thus, Plaintiff was left with no recourse but to file this lawsuit to protect its
`
`valuable assets.
`
`COUNT I
`
`INFRINGEMENT OF U.S. PATENT NO. 6,317,804
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`14.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`15.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`6,317,804, entitled “Concurrent Serial Interconnect for Integrating Functional Blocks in an
`
`Integrated Circuit Device.” The ’804 Patent was duly and legally issued by the United States Patent
`
`and Trademark Office on November 13, 2001. A true and correct copy of the ’804 Patent is
`
`attached as Exhibit 1.
`
`16.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products (“Accused Products”), including smartphones, tablets, and computers
`
`incorporating Apple Ax and Mx processors, that directly infringe, literally and/or under the
`
`doctrine of equivalents, at least Claim 1 of the ’804 Patent.
`
`17.
`
`Defendant also knowingly and intentionally induces infringement of at least claim
`
`1 of the ’804 Patent in violation of 35 U.S.C. § 271(b). On or about April 3, 2018, Future Link
`
`sent letters to Apple’s General Counsel and its Legal Counsel, IP Transactions Group, specifically
`
`identifying the ’804 Patent and Apple’s infringement in connection with the Accused Products.
`
`Through at least that communication, and the interactions as detailed in Future Link’s Factual
`
`Allegations, Defendant has had knowledge of the ’804 Patent and the infringing nature of the
`
`Accused Products. Despite this knowledge of the ’804 Patent, Defendant continues to actively
`
`
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`4
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 5 of 14
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`
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`encourage and instruct its customers and end users (for example, through user manuals and online
`
`instruction materials on its website) to use the Accused Products in ways that directly infringe the
`
`’804 Patent. Defendant does so knowing and intending that its customers and end users will
`
`commit these infringing acts. Defendant also continues to make, use, offer for sale, sell, and/or
`
`import the Accused Products, despite its knowledge of the ’804 Patent, thereby specifically
`
`intending for and inducing its customers to infringe the ’804 Patent through the customers’ normal
`
`and customary use of the Accused Products.
`
`18.
`
`Defendant has also infringed, and continues to infringe, at least Claim 1 of the ’804
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’804
`
`Patent, are especially made or adapted to infringe the ’804 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Defendant has been, and currently is,
`
`contributorily infringing the ’804 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`19.
`
`The Accused Products satisfy all claim limitations of one or more claims of the
`
`’804 Patent. A claim chart comparing independent claim 1 of the ’804 Patent to representative
`
`Accused Products is attached as Exhibit 2.
`
`20.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Defendant has injured Plaintiff and is liable for infringement of the ’804
`
`Patent pursuant to 35 U.S.C. § 271.
`
`21.
`
`As a result of Defendant’s infringement of the ’804 Patent, Plaintiff is entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`
`
`5
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`

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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 6 of 14
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`22.
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`Defendant also had knowledge of or has been willfully blind to its infringement of
`
`the ’804 Patent, and based on that knowledge or willful blindness, it has willfully infringed the ’804
`
`Patent.
`
`23.
`
`Defendant also had actual or constructive knowledge of Future Link’s rights in
`
`the ’804 Patent due to, for example, Future Link’s communications with Defendant, as detailed in
`
`the Factual Allegations.
`
`COUNT II
`
`INFRINGEMENT OF U.S. PATENT NO. 6,622,108
`
`24.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`25.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`6,622,108 (the “’108 Patent”), entitled “Circuit With Interconnect Test Unit and a Method of
`
`Testing Interconnects Between a First and a Second Electronic Circuit.” The ’108 Patent was duly
`
`and legally issued by the United States Patent and Trademark Office on September 16, 2003. A
`
`true and correct copy of the ’108 Patent is attached as Exhibit 3.
`
`26.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products (“Accused Products”), including laptop and desktop computers including
`
`GDDR5 RAM and similar or subsequent GDDR RAM, such as the Apple MacBook Pro 15”, that
`
`directly infringe, literally and/or under the doctrine of equivalents, at least Claim 11 of the ’108
`
`Patent.
`
`27.
`
`Defendant also knowingly and intentionally induces infringement of at least Claim
`
`11 of the ’108 Patent in violation of 35 U.S.C. § 271 (b). On or about April 3, 2018, Future Link
`
`sent letters to Apple’s General Counsel and its Legal Counsel, IP Transactions Group, specifically
`
`
`
`6
`
`

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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 7 of 14
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`
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`identifying the ’108 Patent and Apple’s infringement in connection with the Accused Products.
`
`Through at least that communication, the interactions as detailed in Plaintiff’s Factual Allegations,
`
`and the filing and service of this Complaint, Defendant has had knowledge of the ’108 Patent and
`
`the infringing nature of the Accused Products. Despite this knowledge of the ’108 Patent,
`
`Defendant continues to actively encourage and instruct its customers and end users (for example,
`
`through user manuals and online instruction materials on its website) to use the Accused Products
`
`in ways that directly infringe the ’108 Patent. Defendant does so knowing and intending that its
`
`customers and end users will commit these infringing acts. Defendant also continues to make, use,
`
`offer for sale, sell, and/or import the Accused Products, despite its knowledge of the ’108 Patent,
`
`thereby specifically intending for and inducing its customers to infringe the ’108 Patent through
`
`the customers’ normal and customary use of the Accused Products.
`
`28.
`
`Defendant has also infringed, and continues to infringe, at least Claim 11 of the
`
`’108 Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’108
`
`Patent, are especially made or adapted to infringe the ’108 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Defendant has been, and currently is,
`
`contributorily infringing the ’108 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`29.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’108
`
`Patent. A claim chart comparing independent claim 11 of the ’108 Patent to representative Accused
`
`Products is attached as Exhibit 4.
`
`30.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Defendant has injured Plaintiff and is liable for infringement of the ’108
`
`Patent pursuant to 35 U.S.C. § 271.
`
`
`
`7
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 8 of 14
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`31.
`
`As a result of Defendant’s infringement of the ’108 Patent, Plaintiff is entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`32.
`
`Defendant also had knowledge of or has been willfully blind to its infringement of
`
`the ’108 Patent, and based on that knowledge or willful blindness, it has willfully infringed the ’108
`
`Patent.
`
`33.
`
`Defendant also had actual or constructive knowledge of Plaintiff’s rights in the ’108
`
`Patent due to, for example, Future Link’s communications with Defendant, as detailed in the
`
`Factual Allegations.
`
`34.
`
`Defendant’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’108 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`COUNT III
`
`INFRINGEMENT OF U.S. PATENT NO. 6,807,505
`
`35.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`36.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`6,807,505 (the “’505 Patent”), entitled “Circuit With Interconnect Test Unit.” The ’505 Patent was
`
`duly and legally issued by the United States Patent and Trademark Office on October 19, 2004. A
`
`true and correct copy of the ’505 Patent is attached as Exhibit 5.
`
`
`
`8
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 9 of 14
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`37.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products (“Accused Products”), including computers containing JEDEC DDR4
`
`SDRAM such as the Apple Mac Pro, that directly infringe, literally and/or under the doctrine of
`
`equivalents, at least Claim 1 of the ’505 Patent.
`
`38.
`
`Defendant also knowingly and intentionally induces infringement of at least Claim
`
`1 of the ’505 Patent in violation of 35 U.S.C. § 271(b). On or about April 3, 2018, Future Link
`
`sent letters to Apple’s General Counsel and its Legal Counsel, IP Transactions Group, specifically
`
`identifying the ’505 Patent and Apple’s infringement in connection with the Accused Products.
`
`Through at least that communication, the interactions as detailed in Plaintiff’s Factual Allegations,
`
`and the filing and service of this Complaint, Defendant has had knowledge of the ’505 Patent and
`
`the infringing nature of the Accused Products. Despite this knowledge of the ’505 Patent,
`
`Defendant continues to actively encourage and instruct its customers and end users (for example,
`
`through user manuals and online instruction materials on its website) to use the Accused Products
`
`in ways that directly infringe the ’505 Patent. Defendant does so knowing and intending that its
`
`customers and end users will commit these infringing acts. Defendant also continues to make, use,
`
`offer for sale, sell, and/or import the Accused Products, despite its knowledge of the ’505 Patent,
`
`thereby specifically intending for and inducing its customers to infringe the ’505 Patent through
`
`the customers’ normal and customary use of the Accused Products.
`
`39.
`
`Defendant has also infringed, and continues to infringe, at least Claim 1 of the ’505
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’505
`
`Patent, are especially made or adapted to infringe the ’505 Patent, and are not staple articles or
`
`
`
`9
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 10 of 14
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`
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`commodities of commerce suitable for non-infringing use. Defendant has been, and currently is,
`
`contributorily infringing the ’505 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`40.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’505
`
`Patent. A claim chart comparing independent claims 1 of the ’505 Patent to representative Accused
`
`Products is attached as Exhibit 6.
`
`41.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Defendant has injured Plaintiff and is liable for infringement of the ’505
`
`Patent pursuant to 35 U.S.C. § 271.
`
`42.
`
`As a result of Defendant’s infringement of the ’505 Patent, Plaintiff is entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`43.
`
`Defendant also had knowledge of or has been willfully blind to its infringement of
`
`the ’505 Patent, and based on that knowledge or willful blindness, it has willfully infringed the ’505
`
`Patent.
`
`44.
`
`Defendant also had actual or constructive knowledge of Future Link’s rights in
`
`the ’505 Patent due to, for example, Plaintiff’s communications with Defendant, as detailed in the
`
`Factual Allegations.
`
`45.
`
`Defendant’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’505 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`
`
`10
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 11 of 14
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`COUNT IV
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`INFRINGEMENT OF U.S. PATENT NO. 7,917,680
`
`46.
`
`Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully
`
`set forth herein.
`
`47.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No.
`
`7,917,680 (the “’680 Patent”), entitled “Performance Based Packet Ordering in a PCI Express Bus.”
`
`The ’680 Patent was duly and legally issued by the United States Patent and Trademark Office on
`
`March 29, 2011. A true and correct copy of the ’680 Patent is attached as Exhibit 7.
`
`48.
`
`On information and belief, Defendant makes, uses, offers for sale, sells, and/or
`
`imports certain products (“Accused Products”), including smartphones, tablets, and computers
`
`with A-Series or M-Series processors, that directly infringe, literally and/or under the doctrine of
`
`equivalents, at least Claim 1 of the ’680 Patent.
`
`49.
`
`Defendant also knowingly and intentionally induces infringement of at least Claim
`
`1 of the ’680 Patent in violation of 35 U.S.C. § 271(b). Through the filing and service of this
`
`Complaint, and through pre-filing communications with Plaintiff and/or its predecessors-in-
`
`interest, including as detailed in Future Link’s Factual Allegations, Defendant has had knowledge
`
`of the ’680 Patent and the infringing nature of the Accused Products. Despite this knowledge of
`
`the ’680 Patent, Defendant continues to actively encourage and instruct its customers and end users
`
`(for example, through user manuals and online instruction materials on its website) to use the
`
`Accused Products in ways that directly infringe the ’680 Patent. Defendant does so knowing and
`
`intending that its customers and end users will commit these infringing acts. Defendant also
`
`continues to make, use, offer for sale, sell, and/or import the Accused Products, despite its
`
`knowledge of the ’680 Patent, thereby specifically intending for and inducing its customers to
`
`
`
`11
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 12 of 14
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`
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`infringe the ’680 Patent through the customers’ normal and customary use of the Accused
`
`Products.
`
`50.
`
`Defendant has also infringed, and continues to infringe, at least Claim 1 of the ’680
`
`Patent by selling, offering for sale, or importing into the United States, the Accused Products,
`
`knowing that the Accused Products constitute a material part of the inventions claimed in the ’680
`
`Patent, are especially made or adapted to infringe the ’680 Patent, and are not staple articles or
`
`commodities of commerce suitable for non-infringing use. Defendant has been, and currently is,
`
`contributorily infringing the ’680 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`51.
`
`The Accused Products satisfy all claim limitations of one or more claims of the ’680
`
`Patent. A claim chart comparing independent claim 1 of the ’680 Patent to representative Accused
`
`Products is attached as Exhibit 8.
`
`52.
`
`By making, using, offering for sale, selling and/or importing into the United States
`
`the Accused Products, Defendant has injured Plaintiff and is liable for infringement of the ’680
`
`Patent pursuant to 35 U.S.C. § 271.
`
`53.
`
`As a result of Defendant’s infringement of the ’680 Patent, Plaintiff is entitled to
`
`monetary damages in an amount adequate to compensate for Defendant’s infringement, but in no
`
`event less than a reasonable royalty for the use made of the invention by Defendant, together with
`
`interest and costs as fixed by the Court.
`
`54.
`
`Defendant also had knowledge of or has been willfully blind to its infringement of
`
`the ’680 Patent, and based on that knowledge or willful blindness, it has willfully infringed the ’680
`
`Patent.
`
`
`
`12
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 13 of 14
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`55.
`
`Defendant also had actual or constructive knowledge of Future Link’s rights in
`
`the ’680 Patent due to, for example, Future Link’s communications with Defendant, as detailed in
`
`the Factual Allegations.
`
`56.
`
`Defendant’s infringing activities have injured and will continue to injure Plaintiff,
`
`unless and until this Court enters an injunction prohibiting further infringement of the ’680 Patent,
`
`and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that
`
`come within the scope of the patent claims.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff respectfully requests that this Court enter:
`
`a.
`
`A judgment in favor of Plaintiff that Defendant has infringed, either literally and/or
`
`under the doctrine of equivalents, the ’804 Patent, the ’108 Patent, the ’505 Patent, and the ’680
`
`Patent;
`
`b.
`
`A permanent injunction prohibiting Defendant from further acts of infringement of
`
`the ’108 Patent, the ’505 Patent, and the ’680 Patent;
`
`c.
`
`A judgment and order requiring Defendant to pay Plaintiff its damages, costs,
`
`expenses, and pre-judgment and post-judgment interest for Defendant’s infringement of the ’804
`
`Patent, the ’108 Patent, the ’505 Patent, and the ’680 Patent; and
`
`d.
`
`A judgment and order requiring Defendant to provide an accounting and to pay
`
`supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment
`
`interest;
`
`e.
`
`A judgment and order finding that this is an exceptional case within the meaning
`
`of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against Defendant;
`
`
`
`13
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`Case 6:21-cv-00263-ADA Document 1 Filed 03/16/21 Page 14 of 14
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`
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`f.
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`An award of enhanced damages to Plaintiff as a result of Defendant’s willful
`
`infringement; and
`
`g.
`
`Any and all other relief as the Court may deem appropriate and just under the
`
`circumstances.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
`
`any issues so triable by right.
`
`
`
`
`Dated: March 16, 2021
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Reza Mirzaie
` Reza Mirzaie
`
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`bledahl@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`cconkle@raklaw.com
`Minna Y. Chan (CA SBN 305941)
`mchan@raklaw.com
`Jonathan Ma (CA SBN 312773)
`jma@raklaw.com
`James Milkey (CA SBN 281213)
`jmilkey@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd., 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`Future Link Systems, LLC
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