Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 1 of 19
`
`Western District of Texas
`Waco Division
`
`§ § § § § § § § § § § § §
`
`No. 6:21-cv-816
`Patent Case
`Jury Trial Demanded
`
`United States District Court
` WAG ACQUISITION, L.L.C.,
`
`Plaintiff,
`
`– against –
` GOOGLE LLC and
`YOUTUBE, INC.,
`
`Defendants.
`
`
`
`Plaintiff WAG Acquisition, L.L.C., for its complaint against Defendants,
`alleges as follows:
`1.
`Plaintiff’s predecessor, known as SurferNETWORK, developed
`technology to improve the process of delivering streaming media over the
`Internet, reflected in a family of United States patents including without
`limitation U.S. Patent Nos. 9,742,824; 9,729,594; and 9,762,636 (the “patents-
`in-suit”).
`Page 1 of 19
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`INTRODUCTION
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Western District of Texas
`Waco Division
`
`§ § § § § § § § § § § § §
`
`No. 6:21-cv-816
`Patent Case
`Jury Trial Demanded
`
`United States District Court
` WAG ACQUISITION, L.L.C.,
`
`Plaintiff,
`
`– against –
` GOOGLE LLC and
`YOUTUBE, INC.,
`
`Defendants.
`
`
`
`Plaintiff WAG Acquisition, L.L.C., for its complaint against Defendants,
`alleges as follows:
`1.
`Plaintiff’s predecessor, known as SurferNETWORK, developed
`technology to improve the process of delivering streaming media over the
`Internet, reflected in a family of United States patents including without
`limitation U.S. Patent Nos. 9,742,824; 9,729,594; and 9,762,636 (the “patents-
`in-suit”).
`Page 1 of 19
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`INTRODUCTION
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 2 of 19
`
`Defendants have used the technology taught and claimed in the
`2.
`patents-in-suit to their substantial financial benefit, to achieve responsive and
`stable delivery of media, including without limitation video-on-demand and
`live streaming programming, which Defendants provide via the Internet in the
`United States and worldwide, for pre-recorded and live programming,
`delivered to desktop, tablet, smartphone, smart TV, streaming stick, and other
`streaming device and media player platforms, by way of their streaming
`services (the “YouTube Streaming Services”).
`3.
`Plaintiff alleges that Defendants’ Internet delivery of streaming
`video via the YouTube Streaming Services have infringed the patents-in-suit, as
`more particularly specified herein.
`4. WAG Acquisition, L.L.C. is a New Jersey limited liability company
`with its principal place of business at 275 Route 10 East, Suite 220-313,
`Succasunna, New Jersey 07876.
`5.
`Defendant Google LLC (“Google”) is a Delaware limited liability
`company with its principal place of business at 1600 Amphitheatre Parkway,
`Mountain View, California 94043, and an address in this District at 500 West
`2nd Street, Austin, Texas 78701. On information and belief, based upon
`Page 2 of 19
`
`THE PARTIES
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 3 of 19
`
`YouTube’s published terms of service, in recent years, Google has taken over
`the operation of the YouTube website.
`6.
`Defendant YouTube, Inc. (“YouTube”) is a Delaware corporation
`with its principal place of business at 901 Cherry Avenue, San Bruno, California
`94066, and an address in this District at 500 West 2nd Street, Austin, Texas
`78701. On information and belief, YouTube has been responsible for the
`operation of the YouTube website for some portion of the term of the patents-
`in-suit.
`7.
`The Court has subject matter jurisdiction pursuant to 28 U.S.C.
`§§ 1331 and 1338(a), in that this action arises under the patent laws of the
`United States, 35 U.S.C. §§ 1 et seq.
`8.
`This Court has personal jurisdiction over Defendants because they
`have engaged in systematic and continuous business activities in this District,
`including acts of patent infringement within this District giving rise to the
`claims asserted herein.
`9.
`Defendants have established minimum contacts with this forum
`such that the exercise of jurisdiction over Defendants would not offend
`traditional notions of fair play and substantial justice. Defendants offer
`products and services in this District. Defendant Google LLC is registered to do
`Page 3 of 19
`
`JURISDICTION AND VENUE
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 4 of 19
`
`business in the State of Texas. Defendants have a substantial number of
`technical employees at their facilities in Austin, Texas. On information and
`belief, a substantial portion of those employees in this District are engineers
`who work on streaming media development and related technology. On
`information and belief, Defendants’ technical employees within this District
`have committed acts of infringement on behalf of Defendants in this District, by
`conduct including configuring and managing YouTube servers and software for
`media player devices, and testing and/or using media player devices, to infringe
`the patents-in-suit as hereinafter alleged.
`10. Further as part of said activities, on information and belief,
`Defendants operate in this District, at locations including Midland, El Paso,
`Austin, and San Antonio, “edge” distribution servers known as Google Global
`Cache (“GGC”) servers, which are operated by Defendants’ employees and
`stream YouTube videos in a manner alleged to be infringing hereunder, and use
`and distribute media player software on computer-readable media also in a
`manner alleged to be infringing.
`11. Venue is proper in this District pursuant to 28 U.S.C. § 1400(b)
`because Defendants have regular and established places of business in this
`District and have committed acts of infringement in this District by reason, inter
`alia, of having acted in this District to configure and manage YouTube servers
`Page 4 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 5 of 19
`
`for distributing streaming video, and software for media player devices, and to
`test and/or use media player devices, in a manner that infringes the patents-in-
`suit as hereinafter alleged. Defendants have further committed acts of
`infringement in this District by reason on their making and using GGC servers
`situated in this District.
`12. The patents-in-suit comprise the following United States patents,
`which were duly and legally issued on the dates indicated:
` U.S. Patent No. 9,742,824 (the “’824 patent”), Issue Date: August 22, 2017,
`Title: Streaming Media Delivery System. A copy of the ’824 patent is
`attached hereto as Exhibit A and incorporated herein by reference.
` U.S. Patent No. 9,729,594 (the “’594 patent”), Issue Date: August 8, 2017,
`Title: Streaming Media Delivery System. A copy of the ’594 patent is
`attached hereto as Exhibit B and incorporated herein by reference.
` U.S. Patent No. 9,762,636 (the “’636 patent”), Issue Date: September 12,
`2017, Title: Streaming Media Delivery System. A copy of the ’636 patent
`is attached hereto as Exhibit C and incorporated herein by reference.
` 13. The patents-in-suit were developed in the course of Surfer-
`NETWORK’s business and were assigned by Harold Price (the inventor) to
`SurferNETWORK. Plaintiff now owns all rights to the patents-in-suit, including
`without limitation all rights to recover for infringement of the patents-in-suit.
`Page 5 of 19
`
`THE PATENTS‐IN‐SUIT
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 6 of 19
`
`14. Plaintiff has complied with the marking provisions of 35 U.S.C.
`§ 287(a), and also required those persons authorized to operate for or under
`Plaintiff to comply therewith.
`15. The patents-in-suit concern technological solutions to two
`problems that SurferNETWORK perceived in the early streaming media
`implementations that characterized the prior art. First, the beginning of
`playback, when a user clicked on a program, would entail a significant period
`of “buffering,” during which the user would typically only see an hourglass.
`16. During this period, the user would have to wait until the player
`accumulated sufficient content over its Internet connection for the program to
`start. Second, even after having been started, if the program stream became
`interrupted, a repeat of the long and frustrating “buffering”/hourglass
`sequence would be necessary, and this uneven stuttering behavior could occur
`repeatedly. These problems resulted in a poor user experience and greatly
`disadvantaged Internet streaming media as compared competitively against
`other forms of audio and/or video media, such as radio and TV.
`17. SurferNETWORK sought a solution that would jump start Internet
`media playback to achieve the perception of “Instant On,” so as to provide a user
`experience akin to what ordinarily happened when turning on a transistor
`radio. The patents-in-suit address the identified shortcomings in the prior art
`Page 6 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 7 of 19
`
`by changing the manner of use of computer facilities and the sequence of
`operations by which streaming media is delivered over an Internet connection,
`to provide an Internet streaming user experience that would then be
`comparable to the immediacy and continuity that the user enjoyed with
`ordinary radio and television.
`18. The advances that the patents-in-suit assert improve over the prior
`art include achieving the twin and simultaneous objects of (1) fast streaming
`startup after a user requests a stream, and (2) avoiding interruptions once the
`streaming starts, for the duration of the streamed program. The claims of the
`patents-in-suit spell out not only these functional twin objectives, but also
`recite how to implement a process that achieves both objectives—i.e., making
`the data constituting the program stream available as discrete chunks
`identified by serial ID, responding to client requests made for the chunks by
`their serial IDs, and sending each requested chunk comprising the entire
`stream at a higher-than-playback transmission rate. By doing these things, the
`patented mechanism ensures that each chunk can be transferred to the client
`before it is needed for playback, so the streaming client will have the latitude it
`needs to control the timing of its chunk requests so as to maintain its input
`buffer at a desired level for the entire transmission of the stream, thereby
`achieving the desired advance over the prior art. The claims are thus directed
`Page 7 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 8 of 19
`
`at specific technological measures that improve the speed and reliability of how
`the client and server computers communicate. They utilize the computer
`components in each such computer to function in a different way than those
`components were used in prior approaches, thereby improving how computers
`communicate.
`19.
`Inventive concepts in the patents-in-suit lie in the ability to satisfy
`the requirements for fast streaming startup and uninterrupted delivery by
`switching to a “pull” model, where the flow is regulated by the pace of client
`requests, rather than trying to have the server pace its own delivery, and in
`making the pull mechanism workable, by (i) pre-collecting quantities of the
`program in time-sequenced chunks, (ii) using serial identifiers to ensure
`proper ordering of the chunks (even if some chunks are sent more quickly than
`others), (iii) making the server responsive to requests for chunks by their serial
`identifiers, and (iv) ensuring that the server will send each chunk faster than
`the playback rate.
`20. With regard to the claims concerning receiving the streams (as in
`the ’594 patent), further inventive concepts lie in the client’s ability to monitor
`the state of its buffer and rate of consumption of media to determine when to
`request chunks, and how many to request. The claims at issue make clear that
`not only the startup but the entire duration of the program is streamed in this
`Page 8 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 9 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`COUNT I: INFRINGEMENT OF THE ’824 PATENT
`
`manner, and using this combination of steps for sustained media streaming was
`not conventional at the time of the invention.
`21. Defendants’ accused systems avoid the delays and stuttering that
`characterized the prior art by using the technology claimed in Plaintiff’s
`patents.
`22. Plaintiff repeats and realleges the averments of paragraphs 1-21
`above as if fully set forth at length herein.
`23. Defendants have each infringed the ’824 patent under 35 U.S.C.
`§ 271(a) by making and using server systems in accordance with one or more
`claims thereof, without authorization and in the United States, by conduct as
`hereinafter more particularly alleged.
`24.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’824 patent, from
`and before the date that patent issued through the remainder of its term.
`25. With regard to claim 1, the YouTube Streaming Services distribute
`(and for a long time prior hereto and, during the term of the ’824 patent, have
`distributed) pre-recorded video programs that are digitally stored in and read
`from its server systems, located in, or controlled from, the United States. Media
`data elements representing a program as distributed by the YouTube
`Page 9 of 19
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 10 of 19
`
`Streaming Services each comprise a digitally encoded portion of the program,
`for example, in video/mp4 or audio/webm encoding at a playback rate
`corresponding to the encoding. The media data elements are serially identified,
`for example by “rn” identifiers, which indicate a time sequence of the media
`data elements:
`
`
`YouTube streaming request/response, showing serial ID
`The above shows a request captured in mid-stream for a video segment having
`the rn identifier 102 specified in the client request. The next following
`requests/responses are identical, except that the rn numbers are incremented
`for each request, with audio segments for the stream interleaved with video
`segments, in a repetitive pattern that continues until the end of the program.
`26. The media data elements are stored in a data structure under the
`control of the server system. The server system receives “GET” requests (as
`Page 10 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 11 of 19
`
`shown in the figure above) from user systems via data connections over the
`Internet, for media data elements identified by an rn number. Responsive to
`those requests, the server system sends to the requesting user system the
`media data elements having those serial identifiers corresponding to the
`request. The data connection of the server to the user system, used for so
`responding, has a data rate more rapid than the playback rate of the media data
`elements that are being sent via that connection, and each sending is at a
`transmission rate that is as fast as that data connection will allow. The media
`data elements being sent are selected without depending on the server system
`maintaining a record of the last media data element that had been sent to the
`requesting user system. All of the media data elements that are so sent by the
`server system to the one or more user systems are sent in response to the user
`system requests, and all of the media data elements that are sent by the server
`system to the requesting user systems are sent from the data structure under
`the control of the server system as the media data elements were first stored
`therein. 27. Furthermore, with regard to the dependent claims, as reflected in
`the above example, the aforementioned identifiers, in addition to being serial,
`may also be sequential, and the sending is via a reliable transmission protocol,
`which in many cases is TCP.
`Page 11 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 12 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`28. Defendants also make and use systems that incorporate and
`execute instructions that carry out the foregoing streaming media distribution,
`as well as computer-readable media (computer program products) that
`incorporate such
`instructions.
`29. Defendants, by performing the above-described processes, and
`making and using the above-described systems and computer program
`products, have each thereby infringed one or more claims of the ’824 patent
`during its term, in the United States.
`30. The foregoing allegations encompass all servers used for
`distributing YouTube Streaming Services in, or controlled from, the United
`States (regardless of where the users were located).
`31. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’824 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`32. Plaintiff repeats and realleges the averments of paragraphs 1-31
`above as if fully set forth at length herein.
`Page 12 of 19
`
`COUNT II: INFRINGEMENT OF THE ’594 PATENT
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 13 of 19
`
`33. Defendants have each infringed the ’594 patent under 35 U.S.C. §
`271(a) by making and using computer recorded media for a streaming media
`player in accordance with one or more claims thereof, without authorization
`and in the United States, by conduct as hereinafter more particularly alleged.
`34.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’594 patent, from
`and before the date that patent issued through the remainder of its term.
`35. With regard to claim 1, the YouTube Streaming Services utilize
`software provided by Defendants and put into the hands of the user, which
`causes the user’s media consuming device (e.g., computer, smartphone, tablet,
`smart TV, streaming stick, or other streaming devices, referred to as the “media
`player”) to make requests for streaming media data elements that are handled
`by YouTube servers as described above in connection with the ’824 patent. This
`software is embodied in JavaScript files, which Defendants create and maintain
`on computer-readable media on their server systems, and which they use (and
`have used for a long time prior hereto and during the term of the ’594 patent),
`through servers located in and/or controlled from, the United States, by
`accessing such media to send users electronic copies of said software, so that
`said software may then be operated on the user’s media player device to make
`Page 13 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 14 of 19
`
`the above-described requests to the servers deployed by the YouTube
`Streaming Services and work correctly with those servers.
`36. The JavaScript software instructions are executable to cause the
`media player (via its processor) to send requests (HTTP GET requests) via an
`Internet connection for a media data element that is part of a desired
`audio/video stream, identified by a serial identifier. The requested media data
`elements have a playback rate. The instructions also cause the media player to
`receive the requested media data elements over a data connection having a data
`rate more rapid than the playback rate, receiving the requested media data
`elements as fast as the data connection allows. The instructions further cause
`the media player to store the received media data elements in its memory, and
`play the received media data elements back in series from the memory. The
`instructions are further executable to cause the media player, as the received
`media data elements are played, to automatically send additional requests for
`subsequent media data elements for storage in the memory of the media player,
`as required to maintain about a predetermined number of media data elements
`in the memory of the media
`player during playing.
`37. Furthermore, with regard to the dependent claims, the instructions
`cause the media player to maintain in its memory a record identifying the last
`Page 14 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 15 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`media data element received and stored by the media player. As reflected in the
`above example, the serial identifiers, in addition to being serial, may also be
`sequential. The media data elements are received via a reliable transmission
`protocol, which in many cases is TCP. In addition, as noted above, the JavaScript
`software is provided as a software application for the media player.
`38. Defendants, by making and using the systems and computer
`program products described above, have each thereby infringed one or more
`claims of the ’594 patent, during its term, in the United States.
`39. The foregoing allegations encompass all servers used for
`distributing YouTube Streaming Services in, or controlled from, the United
`States (regardless of where the users were located).
`40. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’594 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`41. Plaintiff repeats and realleges the averments of paragraphs 1-40
`above as if fully set forth at length herein.
`42. Defendants have each infringed the ’636 patent under 35 U.S.C.
`§ 271(a) by making and using server systems in accordance with one or more
`Page 15 of 19
`
`COUNT III: INFRINGEMENT OF THE ’636 PATENT
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 16 of 19
`
`claims thereof, without authorization and in the United States, by conduct as
`hereinafter more particularly alleged.
`43.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’636 patent, from
`and before the date that patent issued through the remainder of its term.
`44. With regard to claim 1, the YouTube Streaming Services distribute
`(and for a long time prior hereto and during the term of the ’636 patent have
`distributed) live video programs over the Internet, where each live program is
`transmitted to a plurality of user systems. To do this, Defendants receive at
`their server systems a continuous digitally encoded stream for the audio or
`video program, via a data connection from a live source, in real time. Upon
`receipt of the stream, the server supplies media data elements representing the
`program, in which each comprises a digitally encoded portion of the program,
`for example, in video/mp4 or audio/webm encoding, at a playback rate
`corresponding to the encoding. The media data elements are serially identified,
`for example by “sq” identifiers, which indicate a time sequence of the media
`data elements. The media data elements are stored in a data structure under
`the control of the server system. The server system receives “GET” requests
`from user systems via data connections over the Internet, for media data
`elements identified by an sq number. Responsive to those requests, the server
`Page 16 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 17 of 19
`
`system sends to the requesting user systems the media data elements having
`those serial identifiers corresponding to the requests. In observed streaming
`sessions, the data connection of the server to the user system, used for so
`responding, has consistently had a data rate more rapid than the playback rate
`of the media data elements that are being sent via that connection, and each
`sending is at a transmission rate as fast as that data connection will allow. The
`media data elements being sent are selected without depending on the server
`system maintaining a record of the last media data element that had been sent
`to the requesting user system. Such observations also reflect that all of the
`media data elements that are so sent by the server system to the one or more
`user systems are sent in response to the user system requests, and all of the
`media data elements that are sent by the server system to the requesting user
`systems are sent from the data structure under the control of the server system
`as the media data elements were first stored therein.
`45. Furthermore, with regard to the dependent claims, as reflected in
`the above example, the aforementioned serial identifiers, in addition to being
`serial, may also be sequential, and the sending is via a reliable transmission
`protocol, which in many cases is TCP.
`46. Defendants also make and use systems that incorporate and
`execute instructions that carry out the foregoing streaming media distribution,
`Page 17 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 18 of 19
`
`as well as computer-readable media (computer program products) that
`incorporate such instructions.
`47. Defendants, by performing the above-described processes, and
`making and using the above-described systems and computer program
`products, have each thereby infringed one or more claims of the ’636 patent
`during its term, in the United States.
`48. The foregoing allegations encompass all servers used for
`distributing live video in, or controlled from, the United States (regardless of
`where the users were located).
`49. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’636 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`Plaintiff demands trial by jury on all issues.
`WHEREFORE, Plaintiff WAG ACQUISITION, L.L.C. requests an entry of
`judgment in its favor and against Defendants as follows:
`i. Declaring that each Defendant has infringed one of more claims of United
`States Patent Nos. 9,742,824; 9,729,594; and 9,762,636;
`Page 18 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`DEMAND FOR JURY TRIAL
`
`PRAYER FOR RELIEF
`
`
`
`Case 6:21-cv-00816 Document 1 Filed 08/06/21 Page 19 of 19
`
`HALEY & OLSON, P.C.
`
`ii. Awarding to Plaintiff the damages arising out of said infringement of
`United States Patent Nos. 9,742,824; 9,729,594; and 9,762,636;
`iii. Awarding attorneys’ fees, costs, or other damages pursuant to 35 U.S.C.
`§§ 284 or 285 or as otherwise permitted by law, jointly and severally
`against the Defendants;
`iv. Awarding costs in this action to Plaintiff; and
`v. For such other and further relief as the Court may deem just and proper.
` Dated:
`August 6, 2021
`100 North Ritchie Road, Suite 200
`Waco, Texas 76712
`Tel: (254) 776-3336
`Fax: (254) 776-6823
`By: /s/ Brandon R. Oates
`Brandon R. Oates (State Bar No. 24032921)
`Email: boates@haleyolson.com
`
`Attorneys for Plaintiff WAG Acquisition, L.L.C.
`
`LISTON ABRAMSON LLP
`
` OF COUNSEL:
`The Chrysler Building
`405 Lexington Ave, 46th Floor
`New York, New York 10174
`Tel: (212) 257-1630
`Ronald Abramson
`David G. Liston
`Ari J. Jaffess
`Alex G. Patchen
`M. Michael Lewis
`Gina K. Kim
`Email: docket@listonabramson.com
`
`Original Complaint for Patent Infringement (Google)
`
`Page 19 of 19
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
