Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 1 of 17 PageID# 15461
`Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 1 of 17 PageID# 15461
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`EXHIBIT 5
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`EXHIBIT 5
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`Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 2 of 17 PageID# 15462
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`SAMSUNG ELECTRONICS CO., LTD.
`et al.,
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`Plaintiffs,
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`v.
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`NVIDIA CORPORATION,
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`et al.,
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`Defendants.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Richmond Division
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`Civil Action No. 3:14CV757-REP
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`DEFENDANT’S SECOND SET OF INTERROGATORIES TO SAMSUNG (NOS. 3-6)
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`Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant NVIDIA Corporation
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`requests that Plaintiffs Samsung Electronics Company, Ltd. and Samsung Electronics America,
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`Inc. answer each interrogatory set forth below separately and fully, in writing and under oath, in
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`accordance with the definitions and instructions contained herein, within thirty (30) days after
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`service of the interrogatories. Defendant requests that Samsung make any production of
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`documents in connection with answers to these interrogatories at the office of Latham & Watkins
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`LLP, 555 11th Street NW, Suite 1000, Washington, DC 20004, or at such other time and place as
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`the parties may agree upon.
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`DEFINITIONS
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`As used herein and in all further Interrogatories, unless specified otherwise, the following
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`definitions apply:
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`1.
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`“Samsung,” “Plaintiff,” “You,” or “Your” means Samsung Electronics Company,
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`Ltd. and Samsung Electronics America, Inc. and all parents, subsidiaries, and affiliates thereof,
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`all divisions, predecessors-in-interest, successors, and assigns of each of the foregoing, and all
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`principals, officers, investors, employees, directors, agents, consultants, attorneys, and all other
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`persons acting or purporting to act on behalf of or under the control of any of the foregoing.
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`2.
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`“Defendants” means NVIDIA Corporation, Velocity Micro, Inc., and Velocity
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`Holdings, LLC and their officers, directors, agents, representatives, employees, attorneys, and
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`investigators, and others acting on their behalf.
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`3.
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`References to this “lawsuit,” “case,” or “action” mean the above-captioned action
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`brought by Samsung.
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`4.
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`“The
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`’158 Patent” means U.S. Patent No. 5,860,158—including any
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`reexamination certificate and certificate of correction.
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`5.
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`“The
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`’938 Patent” means U.S. Patent No. 6,262,938—including any
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`reexamination certificate and certificate of correction.
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`6.
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`“The
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`’902 Patent” means U.S. Patent No. 6,287,902—including any
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`reexamination certificate and certificate of correction.
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`7.
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`“The
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`’602 Patent” means U.S. Patent No. 6,819,602—including any
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`reexamination certificate and certificate of correction.
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`8.
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`“The
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`’675 Patent” means U.S. Patent No. 8,252,675—including any
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`reexamination certificate and certificate of correction.
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`9.
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`“The
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`’724 Patent” means U.S. Patent No. 6,804,724—including any
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`reexamination certificate and certificate of correction.
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`10.
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`“The
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`’054 Patent” means U.S. Patent No. 7,073,054—including any
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`reexamination certificate and certificate of correction.
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`11.
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`“The
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`’854 Patent” means U.S. Patent No. 5,777,854—including any
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`reexamination certificate and certificate of correction.
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`12.
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` “Samsung-Patents-In-Suit” means the ’158 Patent, the ’938 Patent, the ’902
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`2
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`Patent, the ’602 Patent, the ’675 Patent, the ’724 Patent, the ’054 Patent, and the ’854 Patent,
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`collectively, any other patent that may be added to this litigation by Samsung in amended
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`pleadings, and the applications that lead to any of the foregoing patents. Any Interrogatory
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`referring to “Patent-In-Suit” or “Patents-In-Suit” seeks information as to each and every one of
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`the Samsung-Patents-In-Suit.
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`13.
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` “Asserted Samsung Claim(s)” means each claim of the Samsung-Patents-In-Suit
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`that Samsung asserts one or more Defendants infringe, either directly or indirectly, literally or by
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`the doctrine of equivalents.
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`14.
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`“Named Samsung Inventors” refers to the persons named as inventors on the face
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`of the Patents-In-Suit, including Jung-bae Lee, Choong-sun Shin, Dong-yang Lee, Du-hyung
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`Kim, Seong-young Seo, Jung-bae Lee, Byong-mo Moon, Jongwon Lee, Boun Yoon, Sang Yeob
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`Han, Chae Lyoung Kim, Randall S. Welch, Bao Gia Le, Yet-Ping Pai, Le T. Nguyen, Seung-Gi
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`Shin, In-soo Kim, and Kyung-young Kim.
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`15.
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`“Samsung File history” means the United States Patent and Trademark Office
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`(“PTO”) records of all communications and all documents and things sent between the PTO and
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`the patent applicant(s) in connection with the prosecution of the Samsung-Patents-In-Suit.
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`16.
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`“Samsung Foreign Counterpart Application” means any patent application filed
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`anywhere in the world outside the United States (i) that claims priority in whole or in part from
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`an application that resulted in a given patent; (ii) that is the basis for the claim of priority in
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`whole or part (including without limitation claims of benefits under 35 U.S.C. §§ 119(e) or 120)
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`for a given patent; or (iii) that discloses the same subject matter as a given patent.
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`17.
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`“Related Samsung Application” means any parent or ancestral application related
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`in any way to a given patent and any continuing application, continuation-in-part application,
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`3
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`divisional application, file-wrapper continuation, reexamination proceeding, reissue application,
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`abandoned application or foreign counterpart application for that patent.
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`18.
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`“Related Samsung Patent” means any patent that issued from any Related
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`Samsung Application.
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`19.
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`“The
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`’590 Patent” means U.S. Patent No. 7,339,590—including any
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`reexamination certificate and certificate of correction.
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`20.
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`“The
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`’414 Patent” means U.S. Patent No. 7,095,414—including any
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`reexamination certificate and certificate of correction.
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`21.
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`“The
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`’013 Patent” means U.S. Patent No. 6,532,013—including any
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`reexamination certificate and certificate of correction.
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`22.
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`“The
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`’531 Patent” means U.S. Patent No. 8,174,531—including any
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`reexamination certificate and certificate of correction.
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`23.
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`“NVIDIA-Patents-In-Suit” means the ’590 Patent, ’414 Patent, ’013 Patent and
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`’531 patent, collectively, any other patent that may be added to this litigation by NVIDIA in
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`amended pleadings, and the applications that lead to any of the foregoing patents. Any
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`Interrogatory referring to “NVIDIA-Patent-In-Suit” seeks information as to each and every one
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`of the NVIDIA-Patents-In-Suit.
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`24.
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` “Asserted NVIDIA Claim(s)” means each claim of the NVIDIA-Patents-In-Suit
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`that NVIDIA asserts Samsung infringes, either directly or indirectly, literally or by the doctrine
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`of equivalents.
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`25.
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`“Named NVIDIA Inventors” refers to the persons named as inventors on the face
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`of the NVIDIA-Patents-In-Suit, including Jeffrey B. Moskal, David C. Tannenbaum, Andrew D.
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`Bowen, Jakob Nebeker, John Erik Lindholm, Simon Moy, David B. Kirk, Paolo E. Sabella,
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`4
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`Matthew N. Papakipos, Liang Peng, Brett W. Coon, Stuart F. Oberman, Ming Y. Siu, Matthew
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`P. Gerlach and Harold Robert Feldman Zatz.
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`26.
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`“NVIDIA File history” means the United States Patent and Trademark Office
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`(“PTO”) records of all communications and all documents and things sent between the PTO and
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`the patent applicant(s) in connection with the prosecution of the NVIDIA-Patents-In-Suit.
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`27.
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`“NVIDIA Foreign Counterpart Application” means any patent application filed
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`anywhere in the world outside the United States (i) that claims priority in whole or in part from
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`an application that resulted in a given patent; (ii) that is the basis for the claim of priority in
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`whole or part (including without limitation claims of benefits under 35 U.S.C. §§ 119(e) or 120)
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`for a given patent; or (iii) that discloses the same subject matter as a given patent.
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`28.
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`“Related NVIDIA Application” means any parent or ancestral application related
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`in any way to a given patent and any continuing application, continuation-in-part application,
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`divisional application, file-wrapper continuation, reexamination proceeding, reissue application,
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`abandoned application or foreign counterpart application for that patent.
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`29.
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`“Related NVIDIA Patent” means any patent that issued from any Related
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`NVIDIA Application.
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`30.
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`“Infringe,”
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`“infringing,”
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`“infringed,” or
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`“infringement” means direct
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`infringement, indirect infringement, contributory infringement, induced infringement, literal
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`infringement and/or infringement under the doctrine of equivalents.
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`31.
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`“Prior Art” is used in these Interrogatories in the same sense that it is used in 35
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`U.S.C. §§ 102 or 103 and includes without limitation, any patent, publication, physical device,
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`prototype, knowledge, use, sale, offer for sale, any documents or other items evidencing any of
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`the foregoing, and/or any other act or event defined in 35 U.S.C. § 102, taken singly or in
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`5
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`combination, and having or occurring at a date such as to be potentially relevant under any
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`subsection of 35 U.S.C. §§ 102 or 103.
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`32.
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`“Person” or “individual” means any natural person or any business, legal or
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`government entity, or association—including, but not limited to, any proprietorship, partnership,
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`firm, company, or corporation.
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`33.
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`“Third party” means and includes any person or persons other than Samsung and
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`Defendants.
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`34.
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`“Accused NVIDIA Products” means and includes any system, method, product,
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`component, and/or service made, used, sold, offered for sale, or imported by Defendants that
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`Samsung contends infringes any claim of the Samsung-Patents-In-Suit. In referring to any
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`product as an “Accused NVIDIA Product,” Defendants in no way communicate their agreement
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`that the Accused NVIDIA Products infringe any claim of the Samsung-Patents-In-Suit or are
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`rightfully the subject of suit in this action.
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`35.
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`“Accused Samsung Products” means collectively and individually, each and every
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`product accused of infringement in NVIDIA’s Counterclaims and in any infringement
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`contentions served by NVIDIA, and any subsequent amendments to either, that (1) was made,
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`used, sold, offered for sale, or sold by Samsung or on Samsung’s behalf at any time from April
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`14, 2009 to the present anywhere in the world, or (2) was imported into the United States by
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`Samsung or on Samsung’s behalf at any time from April 14, 2009 to the present. The term
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`“Accused Samsung Product(s)” also includes products under development by Samsung, that you
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`may or intend to make, use, sell or offer for sale in the future, anywhere in the world. For
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`avoidance of doubt, the phrase “any Accused Samsung Product” relates to each and every
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`Accused Samsung Product and to any group of products that includes any Accused Samsung
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`6
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`Product (e.g., an analysis of Samsung’s SoCs in general would be responsive to a request for
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`analyses of any Accused Samsung Product).
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`36.
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`“SoC(s)” and “System(s)-on-a-Chip” means, for
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`the purposes of
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`these
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`Interrogatories only, any integrated circuit that that integrates multiple components of a
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`computer (including processing) and other electronic circuits onto a single chip, which includes
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`both a CPU and GPU.
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`37.
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` “GPU(s)” and “Graphics Processing Unit(s)” means, for the purposes of these
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`Interrogatories only, any specialized processor, electronic circuit within a chip, or semiconductor
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`intellectual property core that is designed, at least in part, to process graphics data for the
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`purpose of rendering images, animations, video and other content for a visual display. “GPU(s)”
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`also includes without limitation GPU elements within an SoC.
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`38.
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`“Date” means the exact day, month and year if so ascertainable or, if not, the best
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`approximation (e.g., relationship to seasons or other events).
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`39.
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`The terms “identify,” “identity,” and “identification” shall mean, as the context
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`shall make appropriate:
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`a. With respect to a person, the person’s full name, present or last known address,
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`telephone number, occupation, and employer. Once a person has been identified
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`in accordance with this subparagraph, only the name of that person need be listed
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`in response to subsequent discovery requesting the identification of that person;
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`b. With respect to a document, the (i) type of document; (ii) general subject matter;
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`(iii) date of the document; and (iv) author(s), addressee(s) and recipient(s). In the
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`alternative, the responding party may produce the documents, together with
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`identifying information sufficient to satisfy Fed. R. Civ. P. 33(d);
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`7
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`c. With respect to a telephone conversation, the full name, occupation, telephone
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`number, and address of each party to the telephone conversation, the date of the
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`conversation, and the subject matter discussed;
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`d. With respect to an oral conversation other than a telephone conversation, the full
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`name, occupation, telephone number, and address of each party to such
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`conversation, the date of the conversation, and the subject matter discussed;
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`e. With respect to a corporation, partnership, association, or other entity, its full
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`name, form of organization, present or last known address, and telephone number;
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`and
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`f. With respect to any event or action, the dates or approximate dates thereof, a
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`description of what occurred, and all persons involved.
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`40.
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`“Communicate” or “communication” means, without limitation, any manner or
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`means of disclosure, transfer, transmission, conveyance, or exchange of information whether by
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`written, oral, or other means (such as person-to-person, in a group, by telephone, letter,
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`facsimile, electronic or computer mail, voicemail, telex, telecopy, or any other process, electric,
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`electronic or otherwise).
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`41.
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`“Document” is synonymous in meaning and equal in scope to the usage of the
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`term “documents or electronically stored information” in Rule 34(a)(1)(A) of the Federal Rules
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`of Civil Procedure. A draft or non-identical copy is a separate document within the meaning of
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`this term. By way of illustration, and without limitation, documents include at least the
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`following: originals, drafts, and all non-identical copies of memoranda, reports, notes, graphs,
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`laboratory notebooks, correspondence, interoffice communications, letters, diaries, calendars,
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`photographs, motion pictures, sketches, drawings, promotional material, technical papers, printed
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`8
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`publications, patents, records, reports, and all other writings, as well as all non-paper information
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`storage means such as sound reproductions, computer inputs and outputs, tape, film and
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`computer memory devices, as well as tangible things such as models, modules, prototypes, and
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`commercially saleable products.
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`42.
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`“Thing” shall mean any tangible item, including without limitation, models,
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`prototypes and samples of any device or apparatus or product.
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`43.
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`“Reflect,” “reflecting,” “concern,” “concerning,” “related,” “relating,” “relate,”
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`“refer,” or “referring” and other variations thereof, as used herein shall be construed in their
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`broadest possible sense, and mean without limitation and whether in whole or in part: referring
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`to, constituting, bearing upon, commenting upon, reflecting, evidencing, pertaining to,
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`describing, depicting, consisting of, containing, comprising, embodying, identifying, stating,
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`discussing, analyzing, studying, summarizing, dealing with, relating to, or having any logical or
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`factual connection whatsoever with the subject addressed, regardless whether the factual
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`connection is favorable to or adverse to you.
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`44.
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`“Product” means any machine, manufacture, apparatus, device, system, process,
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`service, method, or instrumentality which is designed to function together electrically,
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`mechanically, chemically, or otherwise, to achieve a particular function or purpose, including
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`those offered for sale, sold, imported, or under development.
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`45.
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`“Covered Samsung Product” means any product that Samsung contends practices
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`or embodies (or has at any time practiced or embodied) any alleged invention described or
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`claimed in any of the Samsung-Patents-In-Suit, including any products made by Samsung or
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`third parties, but excluding Defendants products.
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`46.
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`“Your predecessors-in-interest” means any former interest holder in any of the
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`Samsung-Patents-In-Suit, including without limitation any employers of Named Samsung
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`Inventors, assignees of any of the Samsung-Patents-In-Suit, and security interest holders in any
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`of the Samsung-Patents-In-Suit.
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`47.
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`As used herein, the term “facts” shall have its ordinary meaning and, pursuant to
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`Federal Rule of Civil Procedure 33(a)(2), also shall mean related opinions, related contentions,
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`and the application of law to fact.
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`INSTRUCTIONS
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`1.
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`The following shall apply to all Interrogatories:
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`a. The singular of any word includes its plural, and vice versa, to bring within the
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`scope of these Interrogatories any information that might otherwise be deemed
`
`outside their scope;
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`b. The terms “and” and “or” shall be construed either conjunctively or disjunctively,
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`to bring within the scope of these Interrogatories any information that might
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`otherwise be deemed outside their scope;
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`c. The terms “all,” “any,” and “each” shall be construed as encompassing any and
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`all to bring within the scope of these Interrogatories any information that might
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`otherwise be deemed outside their scope;
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`d. “Including” shall not be used to limit any general category or description that
`
`precedes it and shall mean “including without limitation” so as to be inclusive;
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`and
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`e. The present tense shall be construed to include the past tense and vice versa.
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`2.
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`Each Interrogatory shall operate and be responded to independently and, unless
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`otherwise indicated, no Interrogatory limits the scope of any other Interrogatory.
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`3.
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`All Interrogatories are to be understood as requesting information in Your
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`possession, custody, or control, and the request extends to knowledge or information in the
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`possession of your predecessors-in-interest and/or successors.
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`4.
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`In answering the following Interrogatories, You shall furnish all available
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`information, including information in the possession, custody, or control of any of Your
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`attorneys, directors, officers, agents, employees, representatives, associates, investigators or
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`division affiliates, partnerships, parents or subsidiaries, and persons under Your control, who
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`have the best knowledge, not merely information known to You based on Your own personal
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`knowledge. If You cannot fully respond to the following Interrogatories after exercising due
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`diligence to secure the information requested thereby, so state, and specify the portion of each
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`Interrogatories that cannot be responded to fully and completely. In the latter event, state what
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`efforts were made to obtain the requested information and the Facts relied upon that support any
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`contention that the Interrogatories cannot be answered fully and completely, and state what
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`knowledge, information or belief You have concerning the unanswered portion of any such
`
`Interrogatories.
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`5.
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`If any information requested is claimed to be privileged or otherwise immune
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`from discovery, please provide all information falling within the scope of the Interrogatory
`
`which is not privileged, and for each item of information contained in a document or
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`communication to which a claim of privilege is made, identify such document or communication
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`with sufficient particularity for purposes of a motion to compel in accordance with Federal Rule
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`of Civil Procedure 26(b)(5).
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`6.
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`If any Interrogatory is ambiguous or unclear to You, please contact undersigned
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`counsel as soon as possible so that the Interrogatory can be clarified to avoid unnecessary delays
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`in discovery.
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`7.
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`Your obligation to respond to these Interrogatories is continuing and Your
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`responses are to be supplemented to include subsequently acquired information in accordance
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`with the requirements of Rule 26(e) of the Federal Rules of Civil Procedure.
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`8.
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`To the extent You contend that any Interrogatory consists of multiple discrete
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`subparts, You are to state in Your objections to that Interrogatory Your contention as to the
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`number of subparts for that Interrogatory and the basis for Your contention.
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`9.
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`If You elect to specify and produce business records in answer to any
`
`Interrogatory, the specification shall be in sufficient detail to permit Defendants to locate and
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`identify, as readily as You can enable, the business records from which the answer may be
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`ascertained.
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`10.
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`If in answering any Interrogatory, You seek to invoke the procedures of Rule
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`33(d) of the Federal Rules of Civil Procedure, state fully all facts which support your contention
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`that the burden of ascertaining the answer to the Interrogatory is substantially the same for
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`Defendants as it is for you, and specify those business records from which You contend
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`Defendants may ascertain or derive the answer.
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`11.
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`If any objection is made to any Interrogatory herein, the objection shall state with
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`particularity the basis therefore, and the Interrogatory shall be answered to the extent not
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`objected to.
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`12.
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`If You do not agree with any definition of the terms provided herein, You are
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`instructed to provide a reasonable, alternative definition for that term, consistent with industry
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`custom and usage.
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`13.
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`Each of the definitions and instructions contained herein shall be fully applicable
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`to each Interrogatory notwithstanding that a definition or instruction above may, in whole or in
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`12
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`part, be reiterated in a particular Interrogatory and notwithstanding that a particular Interrogatory
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`may incorporate supplemental instructions or definitions. If, however, You provided any
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`alternate definitions in accordance with these instructions, indicate whether and how, any answer
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`to any Interrogatory would differ if You relied on Your alternate definition in responding to that
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`Interrogatory instead of the definitions provided.
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`SECOND SET OF INTERROGATORIES
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`INTERROGATORY NO. 3:
`
`Provide, in chart form, a complete identification of each Accused Samsung Product. In
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`the context only of this interrogatory, “identification” means, for each Accused Samsung
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`Product, all known product names, product numbers, part numbers, code names, SKUs, any
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`other similar identification systems used for internal or external identification. In the context
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`only of this interrogatory, “identification” also means, for each SoC used in each Accused
`
`Samsung Product, identifying the name and model number of the SoC, the manufacturer of the
`
`SoC, each entity that directly or indirectly supplies the SoC to Samsung, the name and model
`
`number of the GPU in the SoC, and each entity that supplies or licenses the GPU to Samsung.
`
`INTERROGATORY NO. 4:
`
`For each Accused Samsung Product, describe the technical design and operation of the
`
`SoC and GPU in the Accused Samsung Product, by specifically Identifying for each Accused
`
`Samsung Product high level block diagrams for the SoC and GPU; the instruction set and
`
`instruction set architecture for the SoC and GPU; internal architecture specifications for the SoC
`
`and GPU; programming guides for the Soc and GPU; driver software used with the SoC and/or
`
`GPU, including OpenGL drivers, and specifications for the drivers used with the GPU;
`
`functional descriptions and specifications for the SoC and GPU; register transfer language (RTL)
`
`
`
`13
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 15 of 17 PageID# 15475
`
`
`for the SoC and/or GPU; and timing specifications for the graphics pipeline in the GPU.
`
`INTERROGATORY NO. 5:
`
`For each Accused Samsung Product, describe each graphics application program
`
`interface (“API”) (e.g., OpenGL or OpenGL ES) implemented or supported by the Accused
`
`Samsung Product, including any optional extensions implemented or supported by the Accused
`
`Samsung Product, by Identifying by name and version number the API and each such extension,
`
`documents that describe and identify the testing performed to determine compliance with each
`
`API or extensions thereof, and any documentation or logs supplied to the Khronos Group or any
`
`other Third Party, whether by You or by a Third Party, to demonstrate such compliance.
`
`INTERROGATORY NO. 6:
`
`For each Asserted NVIDIA Patent, state in detail the circumstances surrounding your
`
`first awareness of the patent. Include in your answer the date when you first became aware of
`
`the patent, the circumstances and events surrounding how you first became aware of the patent,
`
`all actions taken by you as a result of your awareness of the patent, and identify the three persons
`
`most knowledgeable regarding your awareness of the Asserted NVIDIA Patents.
`
`
`
`April 15, 2015
`
`NVIDIA Corporation
`
`
`
`
`
`/s/
`
`By:
`Clement J. Naples (admitted pro hac vice)
`clement.naples@lw.com
`LATHAM & WATKINS LLP
`885 Third Avenue
`New York, NY 10022-4834
`Tel: (212) 906-1200; Fax: (212) 751-4864
`
`
`
`
`
`
`
`14
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 16 of 17 PageID# 15476
`
`
`Dabney J. Carr, IV, VSB No. 28679
`dabney.carr@troutmansanders.com
`Robert A. Angle, VSB No. 37691
`robert.angle@troutmansanders.com
`TROUTMAN SANDERS LLP
`1001 Haxall Point
`Richmond, VA 23219
`T: (804) 697-1200
`F: (804) 697-1339
`
`Maximilian A. Grant (admitted pro hac vice)
`max.grant@lw.com
`LATHAM & WATKINS LLP
`555 Eleventh Street, NW, Suite 1000
`Washington, DC 20004-1304
`T: (202) 637-2200; F: (202) 637-2201
`
`
`Counsel for Defendant NVIDIA Corporation
`
`
`
`15
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 106-5 Filed 04/24/15 Page 17 of 17 PageID# 15477
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 14th day of April, 2015, I served the foregoing by overnight
`
`mail on the following:
`
`Vision L. Winter
`vwinter@omm.com
`Ryan K. Yagura
`ryagura@omm.com
`Michael A. Koplow
`Connor T. Lynch
`clynch@omm.com
`O'Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`
`Mishima Alam
`malam@omm.com
`O'Melveny & Myers LLP
`1625 Eye Street NW
`Washington, DC 20006
`
`Sean F. Murphy
`sfmurphy@mcguirewoods.com
`McGuireWoods LLp
`1750 Tysons Boulevard, Suite 1800
`Tysons Corner, VA 22102-4215
`
`Counsel for Samsung Electronics Co., Ltd. and
`Samsung Electronics America, Inc.
`
`Darin W. Snyder
`dsnyder@omm.com
`Alexander B. Parker
`aparker@omm.com
`Elysa Q. Wan
`ewan@omm.com
`O'Melveny & Myers LLP
`Two Embarcadero Center, 28th Floor
`San Francisco, CA 94111
`
`Brian C. Riopelle
`McGuireWoods LLP
`One James Center
`901 E. Cary Street
`Richmond, VA 23219
`briopelle@mcguirewoods.com
`
`
`
`
`
`
`/s/
`
`By:
`Clement J. Naples (admitted pro hac vice)
`clement.naples@lw.com
`LATHAM & WATKINS LLP
`885 Third Avenue
`New York, NY 10022-4834
`Tel: (212) 906-1200
`Fax: (212) 751-4864
`
`
`
`
`
`