Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 1 of 24
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Civil Action No.
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`JURY TRIAL DEMANDED
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`§§§§
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`§§§
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`§§§§§
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`MATCH GROUP, LLC,
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`Plaintiff,
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`v.
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`MUZZ LIMITED
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`Defendant.
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`PLAINTIFF MATCH GROUP, LLC’S COMPLAINT
`I.
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`INTRODUCTION
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`Match Group, Inc. is the worldwide leader in online dating with multiple popular brands
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`of matchmaking services offered by subsidiaries, including Tinder®, Match®, PlentyofFish®,
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`OkCupid®, and more. Plaintiff Match Group, LLC (“Match Group”), a wholly owned indirect
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`subsidiary of Match Group, Inc., owns the Match® and Tinder® services and their related
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`intellectual property. When the Match service launched as Match.com in 1995, it pioneered the
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`online-dating market. Today, Tinder is one of Match Group’s flagship brands. When the Tinder
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`service was released, it launched a cultural revolution in social networking and online dating. The
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`Tinder service is famously characterized by a stack of cards containing photographs of potential
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`connections nearby. If a user is interested in the person shown, the user drags a card to the right.
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`If not, the user drags the card to the left. If two users are interested in each other, a connection has
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`been made, and the users are permitted to communicate with one another through the app. The
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`app has become so well-known that an entire generation is often described as the “Tinder
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`generation.”
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`Match Group and its predecessors spent significant time and effort developing and
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`implementing the inventions embodied in versions of the Tinder service and claimed in the utility
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`patents at issue here. Match Group and predecessors have spent significant time and money
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`advertising the Tinder brand, including the unique draggable-card-based design. As a result of all
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`these efforts, Match Group has significant intellectual-property rights related to the Tinder service
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`and the Tinder brand. This is a case about infringement of that intellectual property.
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`Muzz Limited, formerly known as Muzmatch Limited (“Muzz”), incorporated in January
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`2015, originally launched as a web-based dating service in 2011, but later copied the Tinder
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`service’s world changing, draggable-card-based, mutual opt-in app interface. As acknowledged
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`by third-party publications upon its release, Muzz’s mobile dating app is considered “the
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`Tinder-like app for Muslims,” being that it is virtually identical to Tinder in its functionality and
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`general look and feel. The competitive reason is obvious. Muzz sought to mimic the Tinder
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`service’s functionality, trade on Match Group’s name, brand, and general look and feel, meet user
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`expectations that Match Group created, and build a business entirely on a Tinder clone,
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`distinguished only by Muzz’s Muslim-cultural-specific marketing strategy. All these actions
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`infringe on Match Group’s valid and enforceable intellectual property rights. Match Group thus
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`brings this Complaint to stop Muzz’s unlawful use of its intellectual property.
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`II. THE PARTIES
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`1.
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`Match Group is a Delaware limited liability company with a principal place of
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`business in Dallas, Texas at 8750 N. Central Expressway, Suite 1400.
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`2.
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`Muzz is a company existing under the laws of the United Kingdom with a principal
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`place of business in Ilford, United Kingdom.
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 3 of 24
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`III. JURISDICTION AND VENUE
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`3.
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`This Court has personal jurisdiction over Muzz consistent with the requirements of
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`the Due Process Clause of the United States Constitution and the Texas Long Arm Statute. Muzz
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`conducts business and has committed acts of patent infringement and has induced and has
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`contributed to acts of patent infringement by others in the Western District of Texas, and elsewhere
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`in the United States. This Court has original subject matter jurisdiction over Match Group’s claims
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`for patent infringement pursuant to the Federal Patent Act, 35 U.S.C. § 101 et seq. and 28 U.S.C.
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`§§ 1331 and 1338(a).
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`4.
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`Venue is proper in this District for Muzz because it is a foreign corporation that is
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`not subject to the patent venue statute in 35 U.S.C. § 1400(b), and thus “may be sued in any judicial
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`district.” 28 U.S.C. § 1391(c)(3); see also In re HTC Corp., 889 F.3d 1349 (Fed. Cir. 2018).
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`IV. FACTUAL ALLEGATIONS
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`A. The Creation of the Tinder Service
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`5.
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`The Tinder service was first conceived at and created by “Hatch Labs,” a
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`technology
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`incubator
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`then owned by Match Group’s
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`then ultimate parent company,
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`IAC/InterActive Corp.
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`6.
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`First officially released in September 2012 for iPhone devices, the Tinder service
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`revolutionized online dating services. From its earliest days, the premise of the Tinder service has
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`been fundamentally the same. Users are shown other users (“potential match(es)”) based on
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`certain parameters, including age range and geographic location. These potential matches are
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`shown on a virtual card with a photo of the nearby potential match. The user is then given a choice
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`to indicate interest (or lack thereof) in the potential match merely by dragging the photo off the
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`screen to the right or tapping a heart (if interested) or dragging left or tapping an ‘X’ (if not). The
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`earliest iteration of the Tinder service did not include the ability to gesture left or right, rather it
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 4 of 24
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`only had the heart and ‘X’ buttons, once implemented, the Tinder Swipe® feature became a
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`cultural sensation uniquely associated with the app.
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`7.
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`Tinder is now one of the most popular apps in the world.
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`B. Match Group’s Tinder-Related Intellectual Property
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`8.
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`Match Group has been awarded many patents on its inventions, including U.S.
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`Patent No. 11,513,666 (the “’666 Patent”), entitled “Matching Process System and Method,” in
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`connection with the functional innovations embodied in versions of the Tinder service. The ’666
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`Patent is attached as Exhibit A.
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`9.
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`Match Group has been awarded several other utility patents related to the ’666
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`Patent, including U.S. Patent Nos. 9,733,811; 9,959,023; and 10,203,854 (collectively, “Related
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`Patents”). The Related Patents were at issue in Match Group, LLC v. Muzmatch Limited, 6:21-cv-
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`00147 (W.D. Tex.), Match Group, LLC v. Bumble Trading Inc., 6:18-cv-00080 (W.D. Tex.), and
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`Match Group, LLC v. Tantan Ltd., 6:18-cv-00081 (W.D. Tex.) (collectively, “Related Actions”).
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`C. Muzz Created and Marketed as a Tinder Copycat
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`10. Muzz was incorporated on or about January 7, 2015, and developed an online
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`Muslim dating application (the “Muzz App”) for iOS and Android users where single Muslims
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`can search for a partner.
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`11.
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`Like the Tinder service, the Muzz App is a dating app that relies on a card-stack
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`interface and a mutual opt-in premise before users communicate.
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 5 of 24
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`12. Muzz’s creator, Shahzad Younas, has even been quoted admitting that, in creating
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`Muzz, “[he] took what was good from Tinder, which is kind of the swipe aspect, then added a lot
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`more features to make it more conducive to the Muslim market.”1
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`13.
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`An article by TechCrunch recognized that “Muzmatch’s feature-set has some basic
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`mechanisms that would be familiar to any Tinder user, like the ability to ‘like’ or ‘pass’ on a
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`possible match, and the ability to chat in-app with mutual matches.”2
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`14.
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`Like users of the Tinder service, users of the Muzz app interact with “cards”
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`containing photos of other users as shown below:
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`15.
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`Like Tinder service users, Muzz users make a gesture on cards containing user
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`photos to indicate whether or not the user is interested in the person shown.
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`1 See Tinder For Muslims Lets Users Hide Their Photos, Appoint Guardian, available at:
`https://www.vice.com/en/article/4x353b/tinder-for-muslims-lets-users-hide-their-photos-appoint-a-
`guardian.
`2 See YC-Backed Muzmatch Definitely Doesn’t Want To Be Tinder for Muslims, available at:
`https://techcrunch.com/2017/08/03/yc-backed-muzmatch-definitely-doesnt-want-to-be-tinder-for-
`muslims/
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`16.
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`As on the Tinder service, on Muzz, tapping “X” indicates a user is not interested in
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`the person shown, while tapping the heart indicates that the user is interested in the person.
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`17.
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`Like on the Tinder service, two users cannot communicate over Muzz until they
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`both indicate interest in one another.
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`18.
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`Like on the Tinder service, if two users on Muzz both indicate interest, a screen is
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`shown indicating a connection.
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`19. Moreover, as mentioned above, Muzz’s creator, Shahzad Younas, has even been
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`quoted stating that, in creating Muzz, “[he] took what was good from Tinder, which is kind of the
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`swipe aspect, then added a lot more features to make it more conducive to the Muslim market.”3
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`3 See Tinder For Muslims Lets Users Hide Their Photos, Appoint Guardian, available at:
`https://www.vice.com/en/article/4x353b/tinder-for-muslim-lets-users-hide-their-photos-appoint-a-
`guardian.
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 7 of 24
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`V. CAUSES OF ACTION
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`A. COUNT ONE: INFRINGEMENT OF THE ’666 PATENT BY MUZZ
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`20. Match Group incorporates by reference the preceding paragraphs as if fully set forth
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`herein.
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`21. Muzz directly infringes the ’666 Patent by making and using a system that practices
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`one or more claim of the ’666 Patent.
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`22.
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`For example, independent claim 1 of the ’666 Patent recites:
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`A non-transitory computer-readable medium comprising instructions that, when executed
`by a processor, are configured to perform a method for allowing two users of a matching
`system to communicate with one another based on each user expressing approval for the
`other, the method comprising the following steps:
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`electronically receive a plurality of user online-dating profiles, each profile
`comprising traits of a respective user;
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`electronically receive from a first user a first request for matching;
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`transmit a set of potential matches comprising one or more potential matches from
`the plurality of online-dating user profiles to the first user;
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`cause the display of a graphical representation of a first potential match on a
`graphical user interface of an electronic device of the first user, the first potential
`match corresponding to a second user, wherein the graphical representation of the
`first potential match is displayed as a first card of a stack of cards such that, from
`among the set of potential matches, only the graphical representation of the first
`potential match is displayed;
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`receive from the electronic device of the first user a first positive preference
`indication associated with the graphical representation of the second user on the
`graphical user interface, the first positive preference indication associated with a
`first gesture performed on the graphical user interface, the first gesture comprising
`a dragging gesture or a tapping gesture indicating a positive preference for the
`second user, wherein the first user’s positive preference for the second user is
`anonymous, such that the second user is not made aware that the first user expressed
`the positive preference for the second user until after a determination that the first
`user and the second user are mutually interested in each other based on the second
`user indicating a positive preference for the first user, and the first user's positive
`preference for the second user is not communicated to the second user before the
`second user indicates a positive preference for the first user;
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`in response to the first positive preference indication associated with the graphical
`representation of the second user on the graphical user interface, automatically
`cause the graphical user interface to display a graphical representation of a second
`potential match instead of the graphical representation of the first potential match,
`wherein the graphical representation of the second potential match is displayed as
`a second card of the stack of cards;
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`receive from an electronic device of the second user a positive preference indication
`regarding the first user;
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`in response to receiving from the electronic device of the first user the first positive
`preference indication regarding the second user and receiving from the electronic
`device of the second user the positive preference indication regarding the first user,
`allow the first user and the second user to send messages to each other;
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`receive from the electronic device of the first user a negative preference indication
`associated with a graphical representation of a third potential match on the
`graphical user interface, the negative preference indication associated with a second
`gesture performed on the graphical user interface, the third potential match
`corresponding to a third user, the second gesture comprising a dragging gesture or
`a tapping gesture indicating a negative preference for the third user, wherein the
`negative preference is not communicated to the third user;
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`without allowing communication between the first user and the third user, receive
`from the electronic device of the first user a second positive preference indication
`associated with a graphical representation of a fourth potential match on the
`graphical user interface, the fourth potential match corresponding to a fourth user,
`the second positive preference indication associated with the first gesture
`performed on the graphical user interface and indicating a second positive
`preference for the fourth user, wherein the second positive preference is not
`communicated to the fourth user before the fourth user indicates a positive
`preference for the first user;
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`receive from an electronic device of the fourth user a second negative preference
`indication associated with a graphical representation of the first user and indicating
`a second negative preference for the first user, wherein the second negative
`preference is not communicated to the first user; and
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`without allowing communication between the first user and the fourth user, cause
`the graphical user interface to display a graphical representation of a fifth potential
`match.
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`23. Muzz is the listed distributing company for the Muzz App on the Apple App Store
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`and the Google Play Store. Thus, Muzz directly infringes at least claims 1, 8, 15, and 22 of the
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`’666 Patent by making and/or using the Muzz system.
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`24. Muzz’s servers practice all of the limitations of claim 1, which is representative of
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`claims 8, 15, and 22. For example, Muzz’s servers electronically receive a plurality of user online-
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`dating profiles, each profile comprising traits of a respective user. When a Muzz App user
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`downloads and initially accesses the application, the user can sign up using Email, Google, or
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`Facebook.
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`25.
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`Through the account setup process, Muzz receives from each user an online profile
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`comprising traits of respective users, as described below in Muzz’s “Help” section.
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`4
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`26. Muzz’s servers also perform the step of electronically receiving from a first user a
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`first request for matching. For example, after authorizing his or her account, the Muzz user can
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`indicate positive and negative preferences for various potential matches. At a point before those
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`potential matches are shown, Muzz has received a request for matching.
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`4 https://muzz.com/en-US/help/getting-started/how-do-i-sign-up-for-muzz.
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`27.
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`One way that the Muzz App meets this limitation is when Muzz’s servers
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`electronically receive a first request for matching, as shown above. Muzz’s servers receive the
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`request from a Muzz user’s device operating the Muzz App.
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`28.
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`Another way that the Muzz App meets this limitation is when the Muzz App
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`electronically receives a first request for matching, as shown above. The Muzz App receives the
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`request from a user.
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`29. Muzz’s servers also perform the step of transmitting a set of potential matches
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`comprising one or more potential matches from the plurality of online-dating user profiles to the
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`first user. In response to receiving the parameters set forth in the request for matching contained
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`in the Muzz App user request, Muzz determines a set of potential matches for the requesting user
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`based on parameters such as location, age, and gender:
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`30.
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`The Muzz App meets this limitation when Muzz’s servers transmit a set of potential
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`matches comprising one or more potential matches from the plurality of online-dating user profiles
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`to the first user, as shown above. Another way that the Muzz App meets this limitation is when
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`the Muzz App transmits a set of potential matches comprising one or more potential matches from
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`the plurality of online-dating user profiles to the first user, as shown above. The Muzz App makes
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`the determination by querying or polling the Muzz servers for and receiving a set of potential
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`matches.
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`31. Muzz’s servers also perform the step of causing the display of a graphical
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`representation of a first potential match on a graphical user interface of an electronic device of the
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`first user, the first potential match corresponding to a second user, wherein the graphical
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`representation of the first potential match is displayed as a first card of a stack of cards such that,
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`from among the set of potential matches, only the graphical representation of the first potential
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`match is displayed. Muzz causes the display of potential matches of other Muzz App users to
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`appear on the first Muzz App user’s graphical user interface. The potential matches shown
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`correspond with the determination of potential matches described in ¶ 30 above:
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`32. Muzz’s servers also perform the step of receiving from the electronic device of the
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`first user a first positive preference indication associated with the graphical representation of the
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`second user on the graphical user interface, the first positive preference indication associated with
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`a first gesture performed on the graphical user interface, the first gesture comprising a dragging
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`gesture or a tapping gesture indicating a positive preference for the second user, wherein the first
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`user’s positive preference for the second user is anonymous, such that the second user is not made
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`aware that the first user expressed the positive preference for the second user until after a
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`determination that the first user and the second user are mutually interested in each other based on
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`the second user indicating a positive preference for the first user, and the first user’s positive
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`preference for the second user is not communicated to the second user before the second user
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`indicates a positive preference for the first user. A Muzz user may affirmatively select (or reject)
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`another Muzz user by using tapping gestures. Muzz makes a determination based on this user
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`indication:
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`33. Muzz’s servers also perform the step of, in response to determining that the first
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`user expressed the positive preference indication regarding the first potential match, automatically
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`causes the graphical user interface to display a graphical representation of a second potential match
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`of the set of potential matches instead of the graphical representation of the first potential match.
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`After determining that the first Muzz App user has expressed a positive preference via a gesture,
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`Muzz automatically presents a second potential match:
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`34. Muzz’s servers also perform the step of receiving from an electronic device of the
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`second user a positive preference indication regarding the first user. Muzz compares the selected
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`preference of each potential match (i.e., of a first Muzz App user and a second Muzz App user),
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`including making a determination whether the first Muzz App user and the second Muzz App user
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`each expressed a positive preference for each other.
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`35. Muzz’s servers also perform the step of in response to receiving from the electronic
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`device of the first user the first positive preference indication regarding the second user and
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`receiving from the electronic device of the second user the positive preference indication regarding
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`the first user, allow the first user and the second user to send messages to each other.
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`36. Muzz’s servers also perform the step of receiving from the electronic device of the
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`first user a negative preference indication associated with a graphical representation of a third
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`potential match on the graphical user interface, the negative preference indication associated with
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`a second gesture performed on the graphical user interface, the third potential match corresponding
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`to a third user, the second gesture comprising a dragging gesture or a tapping gesture indicating a
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`negative preference for the third user, wherein the negative preference is not communicated to the
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`third user. Muzz determines whether the first Muzz user expressed a negative preference for a
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`third Muzz user by determining whether the first Muzz user gestured by, e.g., tapping “X”:
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`37. Muzz’s servers also perform the step of without allowing communication between
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`the first user and the third user, receive from the electronic device of the first user a second positive
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`preference indication associated with a graphical representation of a fourth potential match on the
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`graphical user interface, the fourth potential match corresponding to a fourth user, the second
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`positive preference indication associated with the first gesture performed on the graphical user
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`interface and indicating a second positive preference for the fourth user, wherein the second
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`positive preference is not communicated to the fourth user before the fourth user indicates a
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`positive preference for the first user. If the first Muzz user expressed a negative preference for a
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`third Muzz user, the Muzz App will not allow the first and third users to communicate through the
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`Muzz App. By default, the Muzz App only allows users to message other users who they have
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`matched with. Muzz users may only overcome this limitation once per month, or by purchasing a
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`subscription. Thus, Muzz’s infringement of the ’666 Patent is directly responsible for its revenue.
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`38. Muzz’s servers also perform the step of receiving from an electronic device of the
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`fourth user a second negative preference indication associated with a graphical representation of
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`the first user and indicating a second negative preference for the first user, wherein the second
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`negative preference is not communicated to the first user. A Muzz user may affirmatively select
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`(or reject) another Muzz user by gestures. Muzz makes a determination based on this Muzz user
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`indication and a negative preference is not communicated to the first user.
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`39.
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`Finally, Muzz’s servers perform the step of without allowing communication
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`between the first user and the fourth user, cause the graphical user interface to display a graphical
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`representation of a fifth potential match because by default, the Muzz App only allows
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`communication between users who have matched and profits from allowing users to overcome this
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`behavior for a fee.
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`40.
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`On information and belief, at least some of Muzz’s servers perform this method in
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`the United States.5
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`41.
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`On information and belief, Muzz was aware of the ’666 Patent once it issued, at
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`least because of the Related Actions. The ’666 Patent issued from a continuation application of
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`5 See, e.g., https://muzz.com/en-US/privacy-policy (“When you provide personal information through our
`Service, the information may be sent to servers located in the United States . . . ,” “While our primary data
`centres are in the United States, we may transfer personal information or other information to our offices
`outside of the United States.”)
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`the ’854 Patent, which Muzz had previously redesigned around to attempt to avoid infringement.
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`Muzz was aware that other patent applications were pending in that family at that time.
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`42.
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`On information and belief, since at least the time Muzz became aware of the ’666
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`Patent, it induced and continues to induce infringement of the ’666 Patent under 35 U.S.C. § 271(b)
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`by, among other things, and with specific intent or willful blindness, actively aiding and abetting
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`others, including, but not limited to, Muzz’s partners, clients, customers, and end users to infringe
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`at least claims 1, 8, 15, and 22 of the ’666 Patent.
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`43. Muzz’s actions that aid and abet others, such as its partners, customers, clients, and
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`end users, to infringe include advertising and distributing the Muzz App, providing instruction
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`materials, training, and services regarding the Muzz App, including user guides and the like,6 and
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`providing the Muzz App for download. On information and belief, Muzz has engaged in such
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`actions with specific intent to cause infringement or with willful blindness to resulting
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`infringement because Muzz had knowledge of the ’666 Patent and knowledge that its acts induce
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`infringement of the ’666 Patent.
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`44. Muzz’s acts of induced infringement of the ’666 Patent are committed with
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`knowledge of Match Group’s rights in the ’666 Patent. On information and belief, Muzz continues
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`to act with knowledge that its actions constitute induced infringement of a valid patent. Muzz’s
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`infringement is willful and deliberate, entitling Match Group to enhanced damages under 35
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`U.S.C. § 284 and reasonable attorneys’ fees and costs.
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`45.
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`On information and belief, Muzz also indirectly infringes the ’666 Patent by
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`contributing to infringement by others under 35 U.S.C. § 271 (c), such as end-users, by providing
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`6 See, e.g., https://muzz.com/en-US/help;
`https://www.youtube.com/channel/UC9yQZDtBeZgu3btlE1EW3EA.
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 20 of 24
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`within the United States software components for operating the Muzz App and interacting with
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`the servers associated with the Muzz App. These software components are, for example, the Muzz
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`App, and the download package that contains the Muzz App for interacting with Muzz’s servers.
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`Muzz’s end-users directly infringed the ’666 Patent by, for example, installing and using the Muzz
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`App in the United States to use the Muzz system in the United States and Muzz servers in the
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`United States. These software components are known by Muzz to be especially made or adapted
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`for use in Muzz’s infringing system.
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`46. Muzz has known these components to be especially made or especially adapted for
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`use in infringement of the ’666 Patent and that these components are not a staple article or
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`commodity of commerce suitable for substantial non-infringing use. Alternatively, Muzz
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`subjectively believed there was a high probability that these components were especially made or
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`especially adapted for use in an infringement of the ’666 Patent and that these components are not
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`a staple article or commodity of commerce suitable for substantial non-infringing use but took
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`deliberate steps to avoid confirming the same.
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`47. Muzz’s infringement of the ’666 Patent is and has been willful. Muzz at a minimum
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`knew or had reason to know of certain facts which would lead a reasonable person to realize their
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`actions were unreasonably risky with respect to infringement of the ’666 Patent. For example, as
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`discussed above, Muzz is and has been aware of the ’666 Patent. To Match Group’s knowledge,
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`Muzz has not attempted to avoid infringement of the patent or to design around it. Muzz designed
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`the Muzz App to mirror the Tinder service and its functionality specifically to compete with the
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`Tinder service and avoid a barrier to entry in the market by mimicking the Tinder service’s
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`functionality in connection with an online matchmaking app.
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 21 of 24
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`48.
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`The inventions claimed in the ’666 Patent are not directed to an abstract idea.
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`Instead, the claims are directed to an improvement in computer and user interface functionality as
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`well as in online social networking.
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`49.
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`Specifically, the inventors of the ’666 Patent set out to improve the user interface
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`functionality in dating and other matchmaking apps. Gesturing on a graphical representation of a
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`user to denote positive, and a different gesture to denote negative, in connection with a mutual
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`opt-in matchmaking app, was a non-conventional, concrete improvement in how touchscreen user
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`interfaces interact with users sifting through and making binary choices, such as indicating positive
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`or negative preferences related to potential matches. Although the general gestures may have been
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`known in the prior art, the specific application to a graphical representation of a user in the specific
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`matchmaking context claimed, in order to make binary choices expressing a preference or lack
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`thereof regarding potential matches, was unknown and unconventional.
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`50.
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`This interface improvement allows users to sift through more information, more
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`quickly than previous interfaces addressing similar binary choice user decisions. These
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`efficiencies to user interaction revolutionized the world of online dating.
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`51.
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`That the inventions are directed toward new computer-specific user interface
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`technology is confirmed by the surrounding limitations. The inventions claim a specific computer
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`method, system, and computer-readable medium of matchmaking where parties are not permitted
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`to communicate unless and until a match is made, user profiles are specifically “online-dating
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`profiles” and those profiles must be “associated with a social networking platform,” a type of
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`platform that is itself computer specific. The claims further describe various actions of a graphical
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`user interface that provide certain information at certain times in response to certain types of inputs.
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`This is not conventional post-solution activity in order to monopolize an abstract idea of
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`Case 6:23-cv-00213-DC-DTG Document 1 Filed 03/23/23 Page 22 of 24
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`matchmaking or even mutual opt-in matchmaking. Instead, these limitations recite a particularly
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`advantageous computer embodiment of a matchmaking process that also solves computer-specific
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`problems related to the ease of creating fake accounts and profiles, the inconvenience of filling out
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`profiles, and the problem of certain online dating users being inundated with messages. This
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`particularly advantageous online matchmaking method may have been known prior to the
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`inventions claimed. However, this method was not so pervasive as to be “conventional.”
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`52. Moreover, even if that matchmaking method was conventional, the inventions are
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`directed to an improved interface for that method.
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`53.
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`The ’666 Patent was granted issuance in view of all the prior art references
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`presented in the Related Actions and IPR proceeding