Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 1 of 16
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`
`
`IDENTITY SECURITY LLC,
`
`
`Plaintiff,
`
`
`Civil Action No. 1:22:CV-00058-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`v.
`
`
`
`
`APPLE INC.,
`
`
`
`
`
`
`Defendant.
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`
`
`
`
`
`
`
`
`
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`DEFENDANT APPLE INC.’S OPPOSITION TO PLAINTIFF’S MOTION FOR
`PARTIAL SUMMARY JUDGMENT OF NO INVALIDITY
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 2 of 16
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`TABLE OF CONTENT
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`Page
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`INTRODUCTION ...............................................................................................................1
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`ARGUMENT .......................................................................................................................1
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`A.
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`B.
`
`C.
`
`D.
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`Apple Has Provided A Thorough Analysis Of A Motivation To Combine
`And A Reasonable Expectation Of Success In Combining The Crypto
`iButton With Klein. ..................................................................................................1
`
`Dr. Wicker Explained How Gerard Discloses Or Renders Obvious
`“Encoding” and “Encrypting” “Using The Microprocessor.” .................................4
`
`The Feasibility Of “Dehashing” Is Irrelevant To Any Obviousness Analysis
`Apple Has Provided Regarding Gullman and Padgett. ............................................6
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`Apple Has Thoroughly Explained How The Lewis Combinations Render
`Claim 4 Of The ’497 Patent And Claim 3 Of The ’008 Patent Obvious. ................8
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`CONCLUSION ..................................................................................................................10
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`
`
`I.
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`II.
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`III.
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`
`i
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 3 of 16
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`TABLE OF AUTHORITIES
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`
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`Page(s)
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`
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`Cases
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`Commonwealth Sci. & Indus. Rsch. Organisation v. Buffalo Tech. (USA), Inc.,
` 542 F.3d 1363 (Fed. Cir. 2008).......................................................................................... 3
`
`Keynetik, Inc. v. Samsung Elecs. Co., Ltd.,
`2023 WL 2003932 (Fed. Cir. 2023).................................................................................... 4
`
`
`
`
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`
`
`ii
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 4 of 16
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`TABLE OF EXHIBITS
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`Exhibit No.
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`Description
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`
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`A.
`
`B.
`
`C.
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`D.
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`E.
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`Dallas Semiconductor, Application Note 97, Features, Advantages, and
`Benefits of Button Based Security [APL-IDENTITY_00673467]
`
`Expert Report of Samuel H. Russ,Ph.D., dated November 29, 2023
`(highlighted)
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`Excerpted Deposition Transcript of Aureliano Tan, Jr., dated August 17,
`2023 (highlighted)
`
`Excerpted Deposition Transcript of Samuel Russ, dated January 24, 2024
`(highlighted)
`
`Automatic Identification Data Book, Dallas Semiconductor, (1995-1996),
`[APL-IDENTITY_01931581]
`
`iii
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 5 of 16
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`I.
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`INTRODUCTION
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`Plaintiff’s motions for partial summary judgment should be denied because they
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`mischaracterize the record and ignore disputed questions of material fact.
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`II.
`
`ARGUMENT
`
`A.
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`Apple Has Provided A Thorough Analysis Of A Motivation To Combine And
`A Reasonable Expectation Of Success In Combining The Crypto iButton With
`Klein.
`The Court should reject Plaintiff’s motion because there is a genuine dispute of material
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`fact as to the motivation to combine the Crypto iButton and Klein. As explained in Apple’s
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`opposition (“Wicker Daubert Opp.”) (filed concurrently) to Plaintiff’s Daubert motion (D.I. 168),
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`Dr. Wicker performed a robust analysis of the motivation to combine the Crypto iButton and Klein.
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`Wicker Daubert Opp. at 7-13. Plaintiff’s motion is predicated primarily on its motion to strike Dr.
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`Wicker’s opinions under Daubert and should be rejected for the same reasons set forth in Apple’s
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`Daubert opposition. In particular, Dr. Wicker explains that both the Crypto iButton and Klein are
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`directed to the same technological field, seek to address the same problems, and employ strikingly
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`similar technological approaches to solving those problems. Ex. 9 [Wicker Open. Rpt.] ¶¶ 785-
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`795.
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`For example, Dr. Wicker explained that both the Crypto iButton and Klein use unique
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`hardware identifiers in cryptographic operations. Ex. A [APL-IDENTITY_ 00673467] (“Each
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`Button contains a unique and unalterable 64-bit identification number that is lasered into each
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`silicon chip contained inside the Button’s tamperproof case. The identification number can be used
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`for registration, audit and security purposes.”); Ex. 7 [Klein] at 3:38-41 (“In the application of
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`FIG. 1, this memory location 18 may advantageously store an identification code. The stored
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`identification code may be used to derive, at least 40 in part, the key 16 which is used in the
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`encryption process.”). As Dr. Wicker explained, Klein states that its “encryption system [can] be
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`1
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 6 of 16
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`created with relatively minor modifications to currently existing integrated circuits,” and identifies
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`
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`integrated circuits from Dallas Semiconductor—the maker of the iButton—based on their unique
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`identification numbers. Ex. 9 [Wicker Open. Rpt.] ¶ 792 (citing Ex. 7 [Klein] at 6:31-44 (“
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`individual EPROM, EEPROM and ROM memories which include pre-programmed identification
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`codes are available commercially from Dallas Semiconductor . . . . These devices include a unique
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`48 bit serial number in a ROM storage location which may be utilized as the memory location
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`which stores the hardware identifier 64.”)). Klein further describes that Dallas Semiconductor
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`chips have “a serial I/O interface for reading the identification code,” and the “encryption logic”
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`of his invention “may interface over [such] a serial bus to [access] the hardware identifier.” Ex. 7
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`[Klein] at 6:48-54. As one example, the iButton serial number may be used to “seed an encryption
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`algorithm.” See Ex. 9 [Wicker Open. Rpt.] ¶ 791 (citing Ex. E [APL-IDENTITY_01931581 at
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`_01931614]).1 Thus, Klein’s own disclosure establishes a motivation to combine its encryption
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`system with Dallas Semiconductor’s iButton hardware identifier and is evidence in the record that
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`creates a genuine dispute of material fact.
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`Dr. Wicker also describes the advantages a POSITA would look to gain by incorporating
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`the teachings of Klein into an existing system having the iButton’s hardware number, which
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`include improving the security of a system by requiring both user input and the hardware identifier
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`to derive an encryption key. Ex. 9 [Wicker Open. Rpt.] ¶¶ 489-90 (incorporated by reference at ¶
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`794) (discussing motivation to modify Gerard and Curry with Klein); see also Wicker Daubert
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`Opp. at 8-9.2 Dr. Wicker explains that Klein’s solution improves security by preventing a
`
`
`1 Apple’s Daubert opposition addresses additional support for Dr. Wicker’s statement that the
`Crypto iButton’s serial number can be used to “seed an encryption algorithm.” Wicker Daubert
`Opp. at 19, n.5.
`2 Dr. Wicker also describes that Curry is a Dallas Semiconductor iButton patent disclosing its
`unique serial number or hardware identifier. Ex. 9 [Wicker Open. Rpt.] ¶¶ 232-233, 266-272.
`
`2
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 7 of 16
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`malicious actor with physical access to a device—and the hardware identifier alone—from
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`
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`decrypting device contents. Id. Rather, determining the encryption key would also require the
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`user input used to derive the key. Id.
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`Thus, contrary to Plaintiff’s allegations, Dr. Wicker has reviewed and analyzed substantial
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`evidence in support of his motivation to combine analysis and obviousness conclusions with
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`respect to Crypto iButton and Klein. Because Dr. Wicker's opinions are admissible for the reasons
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`explained in Apple's Wicker Daubert opposition (Opp. at 7-13), that evidence creates a genuine
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`dispute of material fact, such that summary judgment is inappropriate. Commonwealth Sci. &
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`Indus. Rsch. Organisation v. Buffalo Tech. (USA), Inc., 542 F.3d 1363, 1376 (Fed. Cir. 2008)
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`(reversing summary judgment of non-obviousness where there was “a factual issue as to the
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`motivation to combine prior art references”). Accordingly, because the Court should deny
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`Plaintiff’s Daubert motion, the Court should also deny this motion.
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`Furthermore, Dr. Wicker cites disclosures from Klein that establish a reasonable
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`expectation of success. As Dr. Wicker states Klein “teaches that its encryption system can readily
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`b[e] combined with a Dallas Semiconductor pre-programmed serial number or hardware
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`identifier.” Ex. 9 [Wicker Open. Rpt.] ¶ 792. Indeed, Klein specifically notes that an advantage
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`of its system “is that it may be created with relatively minor modifications to currently existing
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`integrated circuits.” Ex. 7 [Klein] at 6:31-33. Those “currently existing integrated circuits”
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`include “individual EPROM, EEPROM and ROM memories which include pre-programmed
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`identification codes [that] are available commercially from Dallas Semiconductor.” Id. at 6:40-
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`43. Dr. Wicker explains that Klein’s encryption system could be “readily combined” with Dallas
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`Semiconductor hardware including a pre-programmed serial number, like the Crypto iButton, and
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`quotes the specific disclosures from Klein that state such a combination could be created “with
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`3
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 8 of 16
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`relatively minor modifications.” Ex. 9 [Wicker Open Rpt.] ¶ 792. That shows that a POSITA
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`
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`would reasonably expect to succeed based on Klein’s disclosure. See Keynetik, Inc. v. Samsung
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`Elecs. Co., Ltd., 2023 WL 2003932, at *2 (Fed. Cir. 2023) (finding expert testimony “detailing the
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`modified function of the code and that implementing such a modification would be ‘simple’ and
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`‘straightforward’ was sufficient to establish a reasonable expectation of success.”). As such, Dr.
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`Wicker set forth sufficient evidence to materially dispute Plaintiff’s allegation that there is no
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`reasonable expectation of success in combining the Crypto iButton with Klein.
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`The Court should deny Plaintiff’s motion for partial summary judgment.
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`B.
`
`Dr. Wicker Explained How Gerard Discloses Or Renders Obvious “Encoding”
`and “Encrypting” “Using The Microprocessor.”
`The Court should deny Plaintiff’s motion for partial summary judgment because Gerard
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`anticipates the ’008 and ’948 patents, including the limitations directed to “using the
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`microprocessor.” As Dr. Wicker opines, Gerard discloses “using the microprocessor” to provide a
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`chip serial number used as the encryption key. Ex. 9 [Wicker Open. Rpt.] ¶¶ 361-366; 397-401.
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`The ’008 and ’948 patents each include a claim limitation that states “wherein the digital
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`identity data is bound to the microprocessor identity device by [encoding/encrypting], using the
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`microprocessor, the digital identity data using an algorithm that uses the microprocessor identity
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`information.” ’008 patent at claim 1; ’948 patent at claim 1. The Court has construed these terms
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`to have their plain and ordinary meaning. D.I. 77 at 12. Plaintiff argues that Gerard does not
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`disclose these limitations because the process of encrypting digital identity data with the
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`microprocessor identity occurs on a separate computer. Mot. at 5. However, Gerard discloses that
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`encrypting digital identity data requires the step of using the microprocessor to retrieve and
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`transmit the chip serial number used as the encryption key. Ex. 11 [Gerard] at 9:36-10:3 (“The
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`method as claimed in claim 1 or 2, wherein, prior to the identification information being encrypted
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`4
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 9 of 16
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`(14), it comprises a step of reading a serial number of the chip stored inalterably by the storage
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`means (34) [of electronic chip (30)], this serial number being unique, and using this serial number
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`as an encryption key.”) (emphasis added); see also id. at 4:7-9 (“transponder chip . . . comprising
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`computing means such as a microprocessor core”); 9:10-12 (“electronic chip (30), comprising
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`storage means (34) and contactless transmission and reception means (32) for transmitting the
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`stored information."); 9:24-27 (“chip (30) comprises computing means which authorize access to
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`all or some of the storage means (34)”). In short, Gerard discloses that the encryption process
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`includes using the microprocessor for access to the chip serial number used to generate an
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`encryption key.
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`Similarly, in its infringement analysis, Plaintiff asserts that these claim terms are broad
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`enough to encompass using the accused microprocessor as a precursor to the encryption of digital
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`identity data. For example, Plaintiff alleges that the Secure Enclave Processor (“SEP”) meets the
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`claimed “microprocessor.” Ex. B [Russ Open Rpt.] ¶ 411. And Plaintiff asserts that the Accused
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`Products infringe the asserted patents when the SEP generates encryption keys using the accused
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`microprocessor identity—apart from any encryption of digital identity data using those keys. See,
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`e.g., Ex. B [Russ Open. Rpt.] ¶¶ 608 (describing processes outside of the encryption of alleged
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`digital identity data), 664 (same).
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`Thus, under Plaintiff’s broad interpretation —where “using the microprocessor” can
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`include processes involved in generating an encryption key—Gerard discloses the ’008 and ’948
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`claim limitations by using its microprocessor to provide the serial number to the computer for
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`generating an encryption key.3 Such analysis of Gerard under Plaintiff’s interpretation is
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`3 For the same reason, Plaintiff’s citation to the Patent Office’s December 22, 2023 Notice of Intent
`to Issue Reexamination Certificate—which came out after Dr. Wicker served his opening report
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`5
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 10 of 16
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`admissible expert testimony, as discussed in the Wicker Daubert opposition (Opp. at 19-22). As
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`
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`such, a genuine dispute of material fact remains as to whether Gerard discloses this limitation.
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`The Court should deny Plaintiff’s motion for partial summary judgment.
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`C.
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`The Feasibility Of “Dehashing” Is Irrelevant To Any Obviousness Analysis
`Apple Has Provided Regarding Gullman and Padgett.
`Dr. Wicker opines that a combination of Gullman, Padgett, and Klein renders each asserted
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`claim obvious. In his report, Dr. Wicker describes why a POSITA would have been motivated to
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`combine the references and how they disclose each claim limitation. Whether or not “dehashing”
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`is possible is entirely irrelevant to Dr. Wicker’s obviousness opinion. Plaintiff’s motion
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`misinterprets Dr. Wicker’s invalidity opinion with respect to Padgett and should be denied.
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`Dr. Wicker explains that all Asserted Claims are rendered obvious by Gullman in view of
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`Padgett and Klein. Gullman describes a method of biometric authentication. Ex. 12 [Gullman] at
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`Abstract. In Gullman’s system, a user can enroll with a device through a sensor that captures
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`biometric data, such as a fingerprint, and stores it as a “template.” Id. at 5:57-60; Ex. 9 [Wicker
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`Open. Rpt.] ¶ 259. When the user would like to authenticate him- or herself, the user can reenter
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`the biometric data, such as a fingerprint. Ex. 12 [Gullman] at 6:9-13; Ex. 9 [Wicker Open. Rpt.]
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`¶ 259. The device then compares the entered data to the template to generate a correlation factor
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`(a number indicating the level of similarity between the entered and previously stored data). Ex.
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`12 [Gullman] at 6:13-17; Ex. 9 [Wicker Open. Rpt.] ¶ 259. The device then generates a token that
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`includes the correlation factor, a fixed code, and a timestamp, and encrypts them. Ex. 12
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`on November 29, 2023—is misplaced. The Patent Office noted that while Gerard taught the
`“actual encryption being performed by an external computer,” Gerard also taught that the
`microprocessor “teaches pre-encryption activity by reading out the serial number used for the
`encryption.” Ex. 18 at 6-7. If, as Plaintiff alleges, pre-encryption activity such as using a
`microprocessor identity as a seed for generating an encryption key satisfies the claims for
`infringement, so too does pre-encryption activity such as reading out the serial number used for
`the encryption. In any event, that is a material factual dispute that should go to the jury.
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`6
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 11 of 16
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`[Gullman] at 6:30-34; Ex. 9 [Wicker Open. Rpt.] ¶ 259. The user can then input the token into an
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`
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`external device, such as an ATM, which can decrypt the token and use the correlation factor and
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`the fixed code to determine whether to grant the user access. Ex. 12 [Gullman] at 6:35-42; Ex. 9
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`[Wicker Open. Rpt.] ¶ 259.
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`Padgett similarly describes a method of authenticating a user based on biometric data. Ex.
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`13 [Padgett] at Abstract; Ex. 9 [Wicker Open. Rpt.] ¶ 285. In Padgett’s system, a user can enroll
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`biometric data into a terminal that transmits the data in the form of an encrypted message to a
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`certificate authority that stores the data. Ex. 13 [Padgett] at 2:52-65; Ex. 9 [Wicker Open. Rpt.] ¶
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`285. Later, when the user would like to authenticate a transaction, the user can retransmit his or
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`her biometric data to the certificate authority who compares the newly entered data to the enrolled
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`data and determines whether there is a match. Ex. 13 [Padgett] at 2:65-3:10; Ex. 9 [Wicker Open.
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`Rpt.] ¶ 285.
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`Dr. Wicker explained that a POSITA would have been motivated to modify Gullman in
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`view of Padgett. In particular, Gullman discloses that its security token is computed from—but
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`does not actually include—the biometric input, like a fingerprint image. Ex. 12 [Gullman] at 6:30-
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`34. Padgett teaches an encrypted message that in fact includes the biometric input. Ex. 13
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`[Padgett] at 2:52-65. Thus, Dr. Wicker opined that a POSITA would have been motivated to
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`modify Gullman such that Gullman’s security token would include the biometric input itself (rather
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`than only a value derived from the biometric input), just like Padgett’s encrypted message. Ex. 9
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`[Wicker Open Rpt.] ¶ 1389 (“A POSITA would have been motivated to modify the security
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`apparatus of Gullman with the teachings of Padgett to include the biometric input in its security
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`token to allow the recipient of the security token to verify the accuracy of the authentication
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`process.”).
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`7
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 12 of 16
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`Plaintiff’s discussion of dehashing is irrelevant to whether there is a genuine dispute of
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`material fact regarding obviousness over Gullman in view of Padgett and Klein. The proposed
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`combination does not rely on any dehashing. Dr. Wicker explained that for this combination two
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`modifications to Gullman would need to be made. “First, the encrypted security token” disclosed
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`in Gullman “would include the owner’s biometric input,” like the encrypted message in Padgett.
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`Id. ¶ 1390. “Second, the security apparatus would transfer the owner’s biometric template for use
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`in the comparison/authentication operation.” Id. ¶ 1390. Nothing in this process relies on any
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`dehashing or depends on the feasibility of dehashing. Even if one were to credit Plaintiff’s
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`argument that Padgett describes a dehashing process that is not technically feasible, that bears no
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`relation to Dr. Wicker’s obviousness analysis because Dr. Wicker does not propose using the
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`dehashing process in the combination with Gullman. Dr. Wicker has provided a thorough analysis
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`of a system combining Gullman with certain techniques in Padgett (i.e., including the biometric
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`data itself in the data that is to be encrypted and transmitted) and explains why a POSITA would
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`have been motivated to combine the two. His proposed combination discloses each limitation of
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`the Asserted Patents. Thus, there remains a genuine dispute of material fact as to the validity of
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`the Asserted Patents.
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`The Court should deny Plaintiff’s motion for partial summary judgment.
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`D.
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`Apple Has Thoroughly Explained How The Lewis Combinations Render
`Claim 4 Of The ’497 Patent And Claim 3 Of The ’008 Patent Obvious.
`Plaintiff ignores the substance of Dr. Wicker’s invalidity analysis to make its argument that
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`Apple has not provided evidence that the Lewis Combinations4 render claim 4 of the ’497 patent
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`and claim 3 of the ’008 patent obvious. Plaintiff argues that Dr. Wicker fails to explain how the
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`4 The “Lewis Combinations” refer to two grounds of invalidity analyzed by Dr. Wicker: Gerard in
`view of Lewis, and Gerard in view of Curry, Klein, and Lewis. Ex. 9 [Wicker Open. Rpt.] at
`Sections VI.B.2, VI.B.5.
`
`8
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`

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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 13 of 16
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`“hardware of Lewis” satisfies the various claim limitations. As set forth in the Wicker Daubert
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`
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`opposition (Opp. at 1-4), Dr. Wicker provided detailed analysis of the Lewis Combinations satisfy
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`each claim limitation, including how Lewis itself satisfies the “input/output port” limitation.
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`Dependent claim 4 of the ’497 patent and claim 3 of the ’008 patent each recite “an
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`input/output port.” ’497 patent claim 4 depends on claims 1 and 3 of the ’497 patent, and ’008
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`patent claim 3 depends on claims 1 and 2 of the ’008 patent.
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`Dr. Wicker outlined a complete theory of invalidity of claim 4 of the ’497 patent and claim
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`3 of the ’008 patent. First, Dr. Wicker opined that both Gerard and Gerard in view of Curry and
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`Klein rendered claims 1 and 3 of the ’497 patent and claims 1 and 2 of the ’008 patent obvious.
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`Ex. 9 [Wicker Open. Rpt.] at Section VI.B.4. Dr. Wicker provided a detailed analysis explaining
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`how each limitation of those claims were disclosed by the references and explained why a POSITA
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`would have been motivated to combine Gerard, Curry, and Klein. Id. To address the input/output
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`port limitation, Dr. Wicker further opined that it would have been obvious to combine Gerard and
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`Lewis as well as Gerard, Curry, Klein, and Lewis and that these combinations render claim 4 of
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`the ’497 patent and claim 3 of the ’008 patent obvious. Id. at Section VI.B.5. Dr. Wicker then
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`explained how Lewis discloses the use of an input/output port. Id. ¶¶ 690-700. This testimony
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`from Dr. Wicker creates a genuine dispute of material fact.
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`Plaintiff’s fixation on the “hardware of Lewis” is misplaced. The only “hardware of
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`Lewis” relevant to and addressed by Dr. Wicker’s analysis is the input/output port. Dr. Wicker
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`explained that the devices described by Gerard, Curry, and Klein could have been modified to use
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`input/output ports—a component both Mr. Tan and Dr. Russ admitted were conventional at the
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`time of the alleged invention. Ex. C [Tan Tr.] at 142:21-23 (“Q. You didn’t invent the idea of an
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`input/output port? A. Agree.”); Ex. D [Russ Tr.] at 279:10-15 (“Q. Mr. Tan didn't invent the idea
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`9
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 14 of 16
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`of an input/output port, correct? A. He did not invent an input/output port. Q. Input/output ports
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`
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`were known before the alleged invention, correct? A. Input/output ports were known.”). In
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`particular, Dr. Wicker explained that “implementing Lewis’s input/output port retains the security
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`benefits of Gerard while expanding the possible applications.” Ex. 9 [Wicker Open. Rpt.] ¶¶ 418,
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`685. He explained that “[a] POSITA would have further found it obvious to combine the method
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`encryption of Gerard with Lewis’s hardware to include input/output ports because it combines
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`known elements,” and that it would have been “a simple substitution” to swap Gerard’s “antenna”
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`with Lewis’s “input/output port” as a way to interface with external devices. Ex. 9 [Wicker Open.
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`Rpt.] ¶¶ 420, 688. Thus, Dr. Wicker provided the rationale for modifying Gerard or the
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`Gerard/Curry/Klein combination to use an input/output port (like in Lewis) for communicating
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`with external devices rather than Gerard’s antenna. This is routine obviousness analysis. That Dr.
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`Wicker did not copy-paste his analysis of the independent claim limitation under the Lewis
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`subheading does not mean that he did not conduct that analysis.
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`The Court should deny Plaintiff’s motion for partial summary judgment.
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`III. CONCLUSION
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`For the foregoing reasons, Apple respectfully requests that this Court deny Plaintiff’s
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`motions for summary judgment of no invalidity.
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`
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`10
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 15 of 16
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`Dated: March 8, 2024
`
`By:
`
`
`
`
`
`/s/ Regan J. Rundio
`Brian C. Nash (TX Bar No. 24051103)
`Regan J. Rundio (TX Bar No. 24122087)
`300 Colorado Street, Suite 1800
`Austin, TX 78701
`Telephone: 512.617.0650
`BNash@mofo.com
`RRundio@mofo.com
`
`John M. Desmarais (pro hac vice)
`Cosmin Maier (pro hac vice)
`Leslie M. Spencer (pro hac vice)
`Michael Wueste (pro hac vice)
`Joze Welsh (pro hac vice)
`Eli Balsam (pro hac vice)
`Amy Wann (pro hac vice)
`Asim Zaidi (pro hac vice)
`
`Desmarais LLP
`230 Park Avenue
`New York, NY 10169
`Tel: 212-351-3400
`Fax: 212-351-3401
`jdesmarais@desmaraisllp.com
`cmaier@desmaraisllp.com
`lspencer@desmaraisllp.com
`mwueste@desmaraisllp.com
`jwelsh@desmaraisllp.com
`ebalsam@desmaraisllp.com
`awann@desmaraisllp.com
`azaidi@desmaraisllp.com
`
`Jeffrey T. Quilici
`TX State Bar No. 24083696
`ORRICK, HERRINGTON &
`SUTCLIFFE LLP
`300 W. 6th Street, Suite 1850
`Austin, TX 78701
`Tel: (512) 582-6950
`Fax: (512) 582-6949
`jquilici@orrick.com
`
`Attorneys for Defendant Apple Inc.
`
`
`
`11
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`Case 1:22-cv-00058-ADA Document 200 Filed 03/15/24 Page 16 of 16
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`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing sealed document and all attachments
`
`thereto are being served via email on all counsel of record on this March 8, 2024.
`
`/s/ Regan J. Rundio
`Regan J. Rundio
`
`12
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`