West View Research, LLC v. Tesla Motors, Inc.

Filing 1

COMPLAINT with Jury Demand against Tesla Motors, Inc. (Filing fee $ 400 receipt number 0974-7545851) filed by West View Research, LLC. (Attachments: # 1 Civil Case Cover Sheet, # 2 Exhibit A - "778" Patent, # 3 Exhibit B - "146" Patent, # 4 Exhibit C - "673" Patent, # 5 Exhibit D - "504" Patent, # 6 Exhibit E - "037" Patent, # 7 Exhibit F - "839" Patent, # 8 Exhibit G - "777" Patent, # 9 Exhibit H - "038" Patent)The new case number is 3:14-cv-2679-LAB-WVG. Judge Larry Alan Burns and Magistrate Judge William V. Gallo are assigned to the case. (Garson, Adam)(kcm) Modified on 11/24/2014-to correct exhibit name (aef).

1
2
3
4
5
6
7

ADAM GARSON (Bar No. 240440)
[e-mail]
JOSH EMORY (Bar No. 247398)
[e-mail]
GAZDZINSKI & ASSOCIATES, PC
16644 West Bernardo Drive, Suite 201
San Diego, CA 92127
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
WEST VIEW RESEARCH, LLC

8

UNITED STATES DISTRICT COURT

9

SOUTHERN DISTRICT OF CALIFORNIA

10
11
12

WEST VIEW RESEARCH, LLC, a
California corporation,
Plaintiff,

13

15

v.
TESLA MOTORS, INC., a Delaware
corporation,

16

Defendant.

14

'14CV2679 LAB WVG
CASE NO. _______________________
COMPLAINT FOR PATENT
INFRINGEMENT

JURY TRIAL DEMANDED

17
18
19
20
21

This is an action for patent infringement in which Plaintiff West View
Research, LLC (“West View Research” or “Plaintiff”) makes the following
allegations against Defendant TESLA MOTORS, INC. (“TESLA” or “Defendant”)
as follows:

22
23
24
25
26
27
28
COMPLAINT FOR PATENT INFRINGEMENT

THE PARTIES

1
2

1.

Plaintiff West View Research is a limited liability company organized

3

under the laws of the State of California with a principal place of business at 16644

4

West Bernardo Drive, Suite 201-A, San Diego, California 92127.

5

2.

Upon information and belief, Defendant TESLA is a corporation

6

organized under the laws of Delaware, with its principal place of business at 3500

7

Deer Creek Road, Palo Alto, California 94304 and a registered agent at CT

8

Corporation System, 818 West Seventh Street, Second Floor, Los Angeles, CA

9

90017.
JURISDICTION AND VENUE

10
11

3.

This is an action for patent infringement arising under the patent laws

12

of the United States, 35 U.S.C. §1, et seq., including 35 U.S.C. § 271. This Court

13

has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).

14

4.

This Court has personal jurisdiction over Defendant at least because

15

Defendant is present within or has ongoing and systematic contacts with the United

16

States, the State of California, and the Southern District of California. Defendant

17

has purposefully and regularly availed itself of the privileges of conducting

18

business in the State of California and in the Southern District of California.

19

Plaintiff’s causes of action arise directly from Defendant’s business contacts and

20

other activities in the State of California and in the Southern District of California.

21

Defendant has committed acts of patent infringement in this District, and has

22

harmed and continues to harm West View Research in this District, by, among

23

other things, using, selling, offering for sale, and/or importing infringing products

24

and/or services into this District.
BACKGROUND

25
26

5.

West View Research owns all right, title and interest in U.S. Patent

27

No. 8,290,778 (the “’778 patent”), U.S. Patent No. 8,296,146 (the “’146 patent”),

28

U.S. Patent No. 8,682,673 (the “’673 patent”), U.S. Patent No. 8,706,504 (the “’504
-1-

COMPLAINT FOR PATENT INFRINGEMENT

1

patent”), U.S. Patent No. 8,719,037 (the “’037 patent”), U.S. Patent No. 8,781,839

2

(the “’839 patent”), U.S. Patent No. 8,712,777 (the “’777 patent”) and U.S. Patent

3

No. 8,719,038 (the “’038 patent”) (collectively, the “Patents-in-Suit”).

4

6.

Each of the Patents-in-Suit are valid and enforceable.

5

7.

West View Research is in compliance with the marking requirements

6

under 35 U.S.C. § 287 in that it has no duty to mark or to give notice in lieu thereof

7

because has no products to mark.

8

8.

The ’778 patent, entitled “Computerized Information Presentation

9

Apparatus,” was duly and legally issued by the United States Patent and Trademark

10

Office on October 16, 2012, after a full and fair examination. A copy of the ’778

11

patent is attached hereto as Exhibit A.

12

9.

The ’146 patent, entitled “Computerized Information Presentation

13

Apparatus,” was duly and legally issued by the United States Patent and Trademark

14

Office on October 23, 2012, after a full and fair examination. A copy of the ’146

15

patent is attached hereto as Exhibit B.

16

10.

The ’673 patent, entitled “Computerized Information and Display

17

Apparatus,” was duly and legally issued by the United States Patent and Trademark

18

Office on March 25, 2014, after a full and fair examination. A copy of the ’673

19

patent is attached hereto as Exhibit C.

20

11.

The ’504 patent, entitled “Computerized Information and Display

21

Apparatus,” was duly and legally issued by the United States Patent and Trademark

22

Office on April 22, 2014, after a full and fair examination. A copy of the ’504

23

patent is attached hereto as Exhibit D.

24

12.

The ’037 patent, entitled “Transport Apparatus with Computerized

25

Information and Display Apparatus,” was duly and legally issued by the United

26

States Patent and Trademark Office on May 6, 2014, after a full and fair

27

examination. A copy of the ’037 patent is attached hereto as Exhibit E.

28

13.

The ’839 patent, entitled “Computerized Information and Display
-2COMPLAINT FOR PATENT INFRINGEMENT

1

Apparatus,” was duly and legally issued by the United States Patent and Trademark

2

Office on July 15, 2014, after a full and fair examination. A copy of the ’839 patent

3

is attached hereto as Exhibit F.

4

14.

The ’777 patent, entitled “Computerized Information and Display

5

Methods,” was duly and legally issued by the United States Patent and Trademark

6

Office on April 29, 2014, after a full and fair examination. A copy of the ’777

7

patent is attached hereto as Exhibit G.

8

15.

The ’038 patent, entitled “Computerized Information and Display

9

Apparatus,” was duly and legally issued by the United States Patent and Trademark

10

Office on May 6, 2014, after a full and fair examination. A copy of the ’038 patent

11

is attached hereto as Exhibit H.

12

COUNT I

13

INFRINGEMENT OF THE ’778 PATENT

14
15
16

16.

West View Research incorporates paragraphs 1 through 15 by

reference as if fully stated herein.
17.

Defendant has been and is directly infringing literally and/or under the

17

doctrine of equivalents, at least claims 1, 2, 8, 9, 10, 11, 17, 21, 22, 23, 24, 25, 26,

18

28 and 30 of the ’778 patent.

19

18.

Defendant has directly infringed, and continues to directly infringe,

20

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

21

271(a), by making, using, selling, offering for sale, and/or importing in or into the

22

United States, without authority products that infringe at least claims 1, 2, 8, 9, 10,

23

11, 17, 21, 22, 23, 24, 25, 26, 28 and 30 of the ’778 patent, including but not

24

limited to Model S (including all “D” and non-D variants) and, based on

25

information and belief, Model X vehicles, sold or offered for sale on or after

26

October 16, 2012.

27
28

19.

West View Research has no adequate remedy at law against these acts

of patent infringement. Defendant’s actions complained of herein are causing
-3COMPLAINT FOR PATENT INFRINGEMENT

1

irreparable harm and damages to West View Research and will continue to do so

2

unless and until Defendant is permanently enjoined by the Court.

3

20.

As a direct and proximate result of the acts of patent infringement by

4

Defendant, West View Research has been damaged and continues to be damaged in

5

an amount not presently known.

6

21.

West View Research has incurred and will incur attorneys’ fees, costs,

7

and expenses in the prosecution of this action. The circumstances of this dispute

8

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

9

Research is entitled to recover its reasonable and necessary fees and expenses.

10

COUNT II

11

INFRINGEMENT OF THE ’146 PATENT

12
13
14

22.

West View Research incorporates paragraphs 1 through 21 by

reference as if fully stated herein.
23.

Defendant has been and is directly infringing literally and/or under the

15

doctrine of equivalents, at least claims 1, 2, 3, 4, 5, 7, 8, 10, 11, 12, 15, 16, 19, 20,

16

21, 27, 28, 29, 31 and 32 of the ’146 patent.

17

24.

Defendant has directly infringed, and continues to directly infringe,

18

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

19

271(a), by making, using, selling, offering for sale, and/or importing in or into the

20

United States, without authority products that infringe at least claims 1, 2, 3, 4, 5, 7,

21

8, 10, 11, 12, 15, 16, 19, 20, 21, 27, 28, 29, 31 and 32 of the ’146 patent, including

22

but not limited to Model S (including all “D” and non-D variants) and, based on

23

information and belief, Model X vehicles, sold on or after October 23, 2012.

24

25.

West View Research has no adequate remedy at law against these acts

25

of patent infringement. Defendant’s actions complained of herein are causing

26

irreparable harm and damages to West View Research and will continue to do so

27

unless and until Defendant is permanently enjoined by the Court.

28

26.

As a direct and proximate result of the acts of patent infringement by
-4COMPLAINT FOR PATENT INFRINGEMENT

1

Defendant, West View Research has been damaged and continues to be damaged in

2

an amount not presently known.

3

27.

West View Research has incurred and will incur attorneys’ fees, costs,

4

and expenses in the prosecution of this action. The circumstances of this dispute

5

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

6

Research is entitled to recover its reasonable and necessary fees and expenses.

7

COUNT III

8

FOR INFRINGEMENT OF THE ’673 PATENT

9
10
11

28.

West View Research incorporates paragraphs 1 through 27 by

reference as if fully stated herein.
29.

Defendant has been and is directly infringing literally and/or under the

12

doctrine of equivalents, at least claims 1, 4, 6, 7, 8, 10, 12, 15, 16, 17, 18, 20, 21, 22

13

and 24 of the ’673 patent.

14

30.

Defendant has directly infringed, and continues to directly infringe,

15

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

16

271(a), by making, using, selling, offering for sale, and/or importing in or into the

17

United States, without authority products that infringe at least claims 1, 4, 6, 7, 8,

18

10, 12, 15, 16, 17, 18, 20, 21, 22 and 24 of the ’673 patent, including but not

19

limited to Model S (including all “D” and non-D variants) and, based on

20

information and belief, Model X vehicles, sold or offered for sale on or after March

21

25, 2014.

22

31.

West View Research has no adequate remedy at law against these acts

23

of patent infringement. Defendant’s actions complained of herein are causing

24

irreparable harm and damages to West View Research and will continue to do so

25

unless and until Defendant is permanently enjoined by the Court.

26

32.

As a direct and proximate result of the acts of patent infringement by

27

Defendant, West View Research has been damaged and continues to be damaged in

28

an amount not presently known.
-5COMPLAINT FOR PATENT INFRINGEMENT

1

33.

West View Research has incurred and will incur attorneys’ fees, costs,

2

and expenses in the prosecution of this action. The circumstances of this dispute

3

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

4

Research is entitled to recover its reasonable and necessary fees and expenses.

5

COUNT IV

6

FOR INFRINGEMENT OF THE ’504 PATENT

7
8
9
10
11

34.

West View Research incorporates paragraphs 1 through 33 by

reference as if fully stated herein.
35.

Defendant has been and is directly infringing literally and/or under the

doctrine of equivalents, at least claims 43, 44, 45, 46 and 48 of the ’504 patent.
36.

Defendant has directly infringed, and continues to directly infringe,

12

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

13

271(a), by making, using, selling, offering for sale, and/or importing in or into the

14

United States, without authority products that infringe at least claims 43, 44, 45, 46

15

and 48 of the ’504 patent, including but not limited to Model S (including all “D”

16

and non-D variants) and, based on information and belief, Model X vehicles, sold

17

or offered for sale on or after April 22, 2014.

18

37.

West View Research has no adequate remedy at law against these acts

19

of patent infringement. Defendant’s actions complained of herein are causing

20

irreparable harm and damages to West View Research and will continue to do so

21

unless and until Defendant is permanently enjoined by the Court.

22

38.

As a direct and proximate result of the acts of patent infringement by

23

Defendant, West View Research has been damaged and continues to be damaged in

24

an amount not presently known.

25

39.

West View Research has incurred and will incur attorneys’ fees, costs,

26

and expenses in the prosecution of this action. The circumstances of this dispute

27

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

28

Research is entitled to recover its reasonable and necessary fees and expenses.
-6COMPLAINT FOR PATENT INFRINGEMENT

1

COUNT V

2

FOR INFRINGEMENT OF THE ’037 PATENT

3
4
5

40.

West View Research incorporates paragraphs 1 through 39 by

reference as if fully stated herein.
41.

Defendant has been and is directly infringing literally and/or under the

6

doctrine of equivalents, at least claims 22, 24, 27, 32, 33, 35, 37, 38, 39, 40, 42, 43,

7

44, 48, 49, 50, 51, 54, 55, 58, 59, 66, 67, 68, 70, 71, 72 and 73 of the ’037 patent.

8

42.

Defendant has directly infringed, and continues to directly infringe,

9

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

10

271(a), by making, using, selling, offering for sale, and/or importing in or into the

11

United States, without authority products that infringe at least claims 22, 24, 27, 32,

12

33, 35, 37, 38, 39, 40, 42, 43, 44, 48, 49, 50, 51, 54, 55, 58, 59, 66, 67, 68, 70, 71,

13

72 and 73 of the ’037 patent, including but not limited to Model S (including all

14

“D” and non-D variants) and, based on information and belief, Model X vehicles,

15

sold or offered for sale on or after May 6, 2014.

16

43.

West View Research has no adequate remedy at law against these acts

17

of patent infringement. Defendant’s actions complained of herein are causing

18

irreparable harm and damages to West View Research and will continue to do so

19

unless and until Defendant is permanently enjoined by the Court.

20

44.

As a direct and proximate result of the acts of patent infringement by

21

Defendant, West View Research has been damaged and continues to be damaged in

22

an amount not presently known.

23

45.

West View Research has incurred and will incur attorneys’ fees, costs,

24

and expenses in the prosecution of this action. The circumstances of this dispute

25

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

26

Research is entitled to recover its reasonable and necessary fees and expenses.

27
28
-7COMPLAINT FOR PATENT INFRINGEMENT

1

COUNT VI

2

FOR INFRINGEMENT OF THE ’839 PATENT

3
4
5

46.

West View Research incorporates paragraphs 1 through 45 by

reference as if fully stated herein.
47.

Defendant has been and is directly infringing literally and/or under the

6

doctrine of equivalents, at least claims 1, 8, 9, 10, 11, 13, 18, 22, 23, 24, 29, 37, 38,

7

39, 40, 41, 43 and 47 of the ’839 patent.

8

48.

Defendant has directly infringed, and continues to directly infringe,

9

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

10

271(a), by making, using, selling, offering for sale, and/or importing in or into the

11

United States, without authority products that infringe at least claims 1, 8, 9, 10, 11,

12

13, 18, 22, 23, 24, 29, 37, 38, 39, 40, 41, 43 and 47 of the ’839 patent, including but

13

not limited to Model S (including all “D” and non-D variants) and, based on

14

information and belief, Model X vehicles, sold or offered for sale on or after July

15

15, 2014.

16

49.

West View Research has no adequate remedy at law against these acts

17

of patent infringement. Defendant’s actions complained of herein are causing

18

irreparable harm and damages to West View Research and will continue to do so

19

unless and until Defendant is permanently enjoined by the Court.

20

50.

As a direct and proximate result of the acts of patent infringement by

21

Defendant, West View Research has been damaged and continues to be damaged in

22

an amount not presently known.

23

51.

West View Research has incurred and will incur attorneys’ fees, costs,

24

and expenses in the prosecution of this action. The circumstances of this dispute

25

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

26

Research is entitled to recover its reasonable and necessary fees and expenses.

27
28
-8COMPLAINT FOR PATENT INFRINGEMENT

1

COUNT VII

2

FOR INFRINGEMENT OF THE ’777 PATENT

3
4
5

52.

West View Research incorporates paragraphs 1 through 51 by

reference as if fully stated herein.
53.

Defendant has been and is directly infringing literally and/or under the

6

doctrine of equivalents, or indirectly infringing by inducement, at least claims 1, 8,

7

9, 10, 11, 12, 14, 19, 21, 22, 23, 24, 25, 28, 29, 35, 60, 61, 62 and 65 of the ’777

8

patent.

9

54.

Defendant has directly infringed, and continues to directly infringe,

10

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

11

271(a), by making, using, selling, offering for sale, and/or importing in or into the

12

United States, without authority products that infringe at least claims 1, 8, 9, 10, 11,

13

12, 14, 19, 21, 22, 23, 24, 25, 28, 29, 35, 60, 61, 62 and 65 of the ’777 patent,

14

including but not limited to Model S (including all “D” and non-D variants) and,

15

based on information and belief, Model X vehicles, sold or offered for sale on or

16

after April 29, 2014.

17

55.

Third parties, including Defendant’s customers and sales personnel,

18

have directly infringed, and continue to directly infringe, either literally and/or

19

under the doctrine of equivalents, in violation of 35 U.S.C. § 271(a), by using,

20

selling, and or offering for sale in the United States, and/or importing into the

21

United States, products supplied by Defendant that infringe at least claims 1, 8, 9,

22

10, 11, 12, 14, 19, 21, 22, 23, 24, 25, 28, 29, 35, 60, 61, 62 and 65 of the ’777

23

patent, including but not limited to Model S (including all “D” and non-D variants)

24

and, based on information and belief, Model X vehicles, sold or offered for sale on

25

or after April 29, 2014.

26

56.

Upon information and belief, based on the information presently

27

available to West View Research absent discovery, in addition to and/or in the

28

alternative to direct infringement, West View Research contends that Defendant
-9COMPLAINT FOR PATENT INFRINGEMENT

1

has, since receiving notice of the filing of this Complaint, induced infringement and

2

continues to induce infringement of at least claims 1, 8, 9, 10, 11, 12, 14, 19, 21,

3

22, 23, 24, 25, 28, 29, 35, 60, 61, 62 and 65 of the ’777 patent under 35 U.S.C. §

4

271(b). The filing and service of the Complaint in this action satisfies the

5

knowledge requirement for induced infringement. Defendant has, since receiving

6

notice of the filing of this Complaint, actively, knowingly, and intentionally

7

induced, and continues to actively, knowingly, and intentionally induce,

8

infringement of the ’777 patent by making, using, importing, and selling or

9

otherwise supplying products including but not limited to Model S (including all

10

“D” and non-D variants) and, based on information and belief, Model X vehicles,

11

sold or offered for sale on or after April 29, 2014 to third parties (e.g., consumers

12

or Defendant’s sales personnel), with the knowledge and specific intent that such

13

third parties will use, sell, offer for sale, and/or import, products supplied by

14

Defendant to infringe the ’777 patent; and with the knowledge and specific intent to

15

encourage and facilitate the infringement through the dissemination of the products

16

and/or the creation and dissemination of promotional and marketing materials,

17

supporting materials, instructions, user manuals, training manuals or videos,

18

product manuals, technical manuals and/or technical assistance related to such

19

products which actively direct, encourage and/or assist the infringement of the ’777

20

patent.

21

57.

West View Research has no adequate remedy at law against these acts

22

of patent infringement. Defendant’s actions complained of herein are causing

23

irreparable harm and damages to West View Research and will continue to do so

24

unless and until Defendant is permanently enjoined by the Court.

25

58.

As a direct and proximate result of the acts of patent infringement by

26

Defendant, West View Research has been damaged and continues to be damaged in

27

an amount not presently known.

28

59.

West View Research has incurred and will incur attorneys’ fees, costs,
-10COMPLAINT FOR PATENT INFRINGEMENT

1

and expenses in the prosecution of this action. The circumstances of this dispute

2

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

3

Research is entitled to recover its reasonable and necessary fees and expenses.

4

COUNT VIII

5

FOR INFRINGEMENT OF THE ’038 PATENT

6
7
8

60.

West View Research incorporates paragraphs 1 through 59 by

reference as if fully stated herein.
61.

Defendant has been and is infringing literally and/or under the doctrine

9

of equivalents, directly, at least claims 1, 4, 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 18,

10

22, 23, 24, 25, 27, 33, 34, 37, 38, 40, 41, 42, 43, 47, 49, 50, 51, 52 and 53 of the

11

’038 patent.

12

62.

Defendant has directly infringed, and continues to directly infringe,

13

either literally and/or under the doctrine of equivalents, in violation of 35 U.S.C. §

14

271(a), by making, using, selling, offering for sale, and/or importing in or into the

15

United States, without authority products that infringe at least claims 1, 4, 5, 6, 7, 8,

16

9, 11, 12, 13, 14, 15, 16, 18, 22, 23, 24, 25, 27, 33, 34, 37, 38, 40, 41, 42, 43, 47,

17

49, 50, 51, 52 and 53 of the ’038 patent, including but not limited to Model S

18

(including all “D” and non-D variants) and, based on information and belief, Model

19

X vehicles, sold or offered for sale one or after May 6, 2014.

20

63.

West View Research has no adequate remedy at law against these acts

21

of patent infringement. Defendant’s actions complained of herein are causing

22

irreparable harm and damages to West View Research and will continue to do so

23

unless and until Defendant is permanently enjoined by the Court.

24

64.

As a direct and proximate result of the acts of patent infringement by

25

Defendant, West View Research has been damaged and continues to be damaged in

26

an amount not presently known.

27
28

65.

West View Research has incurred and will incur attorneys’ fees, costs,

and expenses in the prosecution of this action. The circumstances of this dispute
-11COMPLAINT FOR PATENT INFRINGEMENT

1

create an exceptional case within the meaning of 35 U.S.C. § 285, and West View

2

Research is entitled to recover its reasonable and necessary fees and expenses.
PRAYER FOR RELIEF

3
4

West View Research respectfully requests that judgment be entered in its

5

favor and against Defendant, and that the Court award the following relief to West

6

View Research:

7

A.

8
9

A judgment in favor of West View Research that Defendant has

infringed, directly and/or indirectly, the Patents-in-Suit;
B.

A permanent injunction against Defendant, its officers, directors,

10

agents, servants, affiliates, employees, divisions, branches, subsidiaries, parents,

11

and all others acting in active concert therewith from infringement of the Patents-

12

in-Suit, or such other equitable relief the Court determines is warranted;

13

C.

A judgment and order that Defendant account for and pay all damages

14

necessary to adequately compensate West View Research for infringement of the

15

Patents-in-Suit, but in no event less than a reasonable royalty;

16

D.

A judgment and order finding that this is an exceptional case within

17

the meaning of 35 U.S.C. § 285 and awarding West View Research its reasonable

18

attorneys’ fees against Defendant;

19

E.

A judgment and order requiring Defendant to provide an accounting

20

and to pay supplemental damages to West View Research, including without

21

limitation, pre-judgment and post-judgment interest; and

22

F.

Any and all other relief to which West View Research may be entitled.

23
24
25
26
27
28
-12COMPLAINT FOR PATENT INFRINGEMENT

JURY DEMAND

1
2
3

West View Research hereby respectfully demands trial by jury of all issues
so triable.

4
5
6
7
8
9
10
11

Dated: November 10, 2014

Respectfully submitted,
GAZDZINSKI & ASSOCIATES, P.C.
/s/ Adam Garson__________________
ADAM GARSON (Bar No. 240440)
JOSH EMORY (Bar No. 247398)
Attorneys for Plaintiff
West View Research, LLC

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-13COMPLAINT FOR PATENT INFRINGEMENT