Bartech Systems International, Inc. v. Mobile Simple Solutions, Inc. et al

Filing 269

ORDER re ECF No. 254 Order, ECF No. 255 -1 Proposed Order, and ECF No. 268 Minutes of Proceedings. (See pdf Order for specifics.) Signed by Judge Miranda M. Du on 4/6/2017. (Copies have been distributed pursuant to the NEF - DRM)

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1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 Michael R. Kealy, Nevada Bar No. 971 Ashley C. Nikkel, Nevada Bar No. 12838 PARSONS BEHLE & LATIMER 50 W. Liberty Street, Suite 750 Reno, Nevada 89501 Telephone:(775) 323-1601 Facsimile:(775)348-7250 Email: mkealy@parsonsbehle.com anikkel@parsonsbehle.com — and — Gregory T. Lawrence, Esq. (Admitted Pro Hac Vice) Kyle S. Kushner, Esq. (Admitted Pro Hac Vice) CONTI FENN & LAWRENCE LLC 36 S. Charles Street, Suite 2501 Baltimore, Maryland 21201 Telephone: (410)837-6999 Facsimile:(410) 510-1647 Email: greg@lawcfl.com kyle@lawcfl.com Attorneys for Plaintiff/Counter-Defendant BARTECH SYSTEMS INTERNATIONAL,INC. 17 UNITED STATES DISTRICT COURT 18 DISTRICT OF NEVADA I9 20 BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, 21 Plaintiff/Counter-defendant, 22 vs. 23 MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE 24 SOLUTIONS (IAS), INC., a Canadian VINCENT TESSIER, an corporation, 25 individual, CHRISTELLE PIGEAT, an individual, 26 27 28 PARSONS BEHLE & LATIMER Defendants/Counterclaimants. Case No. 2:15-cv-02422-MMD-NJK [PROPOSED] ORDER UPON CONSIDERATION of the pleadings, Plaintiff and Counter-Defendant Bartech Systems International's ("Bartech") Second Motion for Contempt (ECF No. 117, sealed unredacted ECF No. 121) and the errata thereto(ECF No. 132), the Response filed by Defendants and Counterclaimants Mobile Simple Solutions, Inc., Mobile Simple Solutions (IAS), Inc., Vincent Tessier, and Christelle Pigeat ("Defendants")(ECF No. 128), the Reply filed by Bartech (ECF No. 135), and for the reasons stated on the record during the March 23, 2017 hearing and the minutes (ECF No. 254) and transcript of that hearing, it is hereby ORDERED that Defendants shall: (1) Immediately cease selling, leasing, renting, or offering for sale, lease, rent or subscription any version of the ABreez software that contains any version of the PMS application without leave of Court. Leave of Court shall not be granted except in the following circumstances: an independent expert in the fields of computer science and computer forensics, at Defendants' expense, shall file a status report with the independent expert's certification that Defendants' software no longer contains Bartech's source code or other misappropriated trade secrets. (2) Provide notice via electronic and regular mail in the form of Exhibit A to this Order to all customers of ABreez not using the ABreez software as a "stand alone" solution that notifies such customers (identified in Exhibit B)that this Court's May 24, 2016 Order (ECF No. 96) prohibits Defendants from selling, leasing, renting, or offering for sale, lease, rent, or subscription any version of the ABreez software that contains any version of the PMS application, and that any further use of the ABreez software is prohibited without further Order of this Court. (3) File proofs of service to show that the notice in the form of Exhibit A was provided to the customers identified in Exhibit B. PARSONS BEHLE & LATIMER 2 IT IS FURTHER ORDERED that: 2 (1) If Defendants fail to file proofs of service of the notice in the form of Exhibit A to the 3 customers identified in Exhibit B within five (5) days of the date of this Order, then 4 Bartech may provide the notice. 5 6 (2) Bartech is awarded reasonable attorneys' fees incurred in briefing and arguing the Second Motion for Contempt. 7 8 IT IS SO ORDERED. I() I1 12 DATED: April 6, 2017 UNITED STATES DISTRICT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PARSONS BEHLE & LATIMER 3 4 EXHIBIT 7 8 9 I() II 12 13 14 15 16 17 18 19 20 21 92 26 27 28 PARSONS BEHLE & LATIMER EXHIBIT 4 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Holiday Inn Vilnius (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 5 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 1O Defendants/Counterclaimants. 11 12 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that the Beekman Hotel (the "Hotel") cannot use the ABreez 14 software until further notice. Therefore, please take whatever steps are necessary to disable the 15 ABreez software on the Hotel's network system, including uninstalling the ABreez software if 16 necessary. This directive is the result of a court order issued by the United States District Court 17 18 19 for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems 20 International, Inc. Therefore, further use of the ABreez software is prohibited without 21 22 further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with 23 the Property Management System Application installed. 24 25 26 27 28 PARSONS BEHLE & LATIMER 7 1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 10 Defendants/Counterclaimants. 11 12 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that the Royalton Hotel (the "Hotel") cannot use the ABreez 14 software until further notice. Therefore, please take whatever steps are necessary to disable the 15 ABreez software on the Hotel's network system, including uninstalling the ABreez software if 16 necessary. This directive is the result of a court order issued by the United States District Court 17 18 19 for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems 20 International, Inc. Therefore, further use of the ABreez software is prohibited without 21 22 further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with 23 the Property Management System Application installed. 24 25 26 27 28 PARSONS BEHLE & LATIMER 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Wythe Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Nativ Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 10 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 10 Defendants/Counterclaimants. I I I2 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that the Clift Hotel (the "Hotel") cannot use the ABreez software 14 until further notice. Therefore, please take whatever steps are necessary to disable the ABreez 15 software on the Hotel's network system, including uninstalling the ABreez software if necessary. 16 This directive is the result of a court order issued by the United States District Court for the 17 18 19 District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. 20 Therefore, further use of the ABreez software is prohibited without further order of the 21 22 court. The court ordered that this notice be sent to all customers using the ABreez software with 23 the Property Management System Application installed. 24 26 27 28 PARSONS BEHLE & LATIMER 11 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that The Raphael Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 12 1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 10 Defendants/Counterclaimants. 11 12 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that the Peninsula Beverly Hills Hotel (the "Hotel") cannot use 14 the ABreez software until further notice. Therefore, please take whatever steps are necessary to 15 disable the ABreez software on the Hotel's network system, including uninstalling the ABreez 16 software if necessary. This directive is the result of a court order issued by the United States 17 18 District Court for the District of Nevada. The court found that the ABreez Property Management 19 System Application was developed using trade secrets misappropriated from Bartech Systems 20 International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with 23 the Property Management System Application installed. 24 25 26 27 28 PARSONS BEHLE & LATIMER 13 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 10 Defendants/Counterclaimants. 11 12 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that The Quin Hotel (the "Hotel") cannot use the ABreez software 14 until further notice. Therefore, please take whatever steps are necessary to disable the ABreez 15 software on the Hotel's network system, including uninstalling the ABreez software if necessary. 16 This directive is the result of a court order issued by the United States District Court for the 17 18 19 District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. 20 Therefore, further use of the ABreez software is prohibited without further order of the 21 22 23 court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. 24 2$ 26 27 28 PARSONS BEHLE & LATIMER 14 1 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 BARTECH SYSTEMS INTERNATIONAL, 4 INC., a Delaware corporation, 5 Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. 6 MOBILE SIMPLE SOLUTIONS, INC., a 7 Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian 8 corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an 9 individual, 10 Defendants/Counterclaimants. 11 12 NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE 13 You are hereby notified that the Renaissance Paris Republique (the "Hotel") cannot use 14 the ABreez software until further notice. Therefore, please take whatever steps are necessary to 15 disable the ABreez software on the Hotel's network system, including uninstalling the ABreez 16 software if necessary. This directive is the result of a court order issued by the United States 17 18 19 District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems 20 International, Inc. Therefore, further use of the ABreez software is prohibited without 21 22 further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with 23 the Property Management System Application installed. 24 25 26 28 PARSONS BEHLE & LATIMER 15 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian TESSIER, an corporation, VINCENT individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Mondrian Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 16 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian corporation, VINCENT TESSIER, an individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that The Dorchester Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 18 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian TESSIER, an corporation, VINCENT individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Trump Vancouver Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 19 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA BARTECH SYSTEMS INTERNATIONAL, INC., a Delaware corporation, Case No. 2:15-cv-02422-MMD-NJK Plaintiff/Counter-defendant, vs. MOBILE SIMPLE SOLUTIONS, INC., a Delaware corporation, MOBILE SIMPLE SOLUTIONS (IAS), INC., a Canadian TESSIER, an VINCENT corporation, individual, CHRISTELLE PIGEAT, an individual, Defendants/Counterclaimants. NOTICE OF INJUNCTION PROHIBITING USE OF ABREEZ SOFTWARE You are hereby notified that the Pontchartrain Hotel (the "Hotel") cannot use the ABreez software until further notice. Therefore, please take whatever steps are necessary to disable the ABreez software on the Hotel's network system, including uninstalling the ABreez software if necessary. This directive is the result of a court order issued by the United States District Court for the District of Nevada. The court found that the ABreez Property Management System Application was developed using trade secrets misappropriated from Bartech Systems International, Inc. Therefore, further use of the ABreez software is prohibited without further order of the court. The court ordered that this notice be sent to all customers using the ABreez software with the Property Management System Application installed. PARSONS BEHLE & LATIMER 20 1 2 3 4 EXHIBIT B 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PARSONS BEHLE & LATIMER EXHIBIT B 21 State Postal Code Country Company Hotel Name Address City AB "Valmeda" Holiday Inn Vilnius Simyniskiy str 1 Vilnius 8358 Sunset Boulevard Los Angeles California 90069 United States 123 Nassau Street New York New York 10038 United States 5 Beekman Property Owner LLC Beekman Hotel 38 Park Row New York New York 10038 United States Royalton 44 Hotel Leasing L.L.C. Royalton Hotel 545 E. John Carpenter Freeway Suite 1300 Irving Texas 75062-8124 United States 80 Wythe LLC Wythe Hotel 45 Main Street, Suite 602 Brooklyn New York 11201 United States 1612 Wazee LLC Nativ Hotel 1612 Wazee LLC Denver Colorado 80202 United States Clift Holdings LLC Clift Hotel c/o Cara Ciuffani, 475 Tenth Avenue New York New York 10018 United States Lighthouse Properties, LLC The Raphael Hotel P.O. Box 856 Salina Kansas 67402-0856 United States Peninsula Beverly Hills Hotel Peninsula Beverly Hills Hotel 9882 South Santa Monica Boulevard Beverly Hills California 90212 United States The Quin Hotel The Quin Hotel New York New York 10019 United States Sunset Tower Hotel Sunset Tower Hotel Beekman Hotel Beekman Hotel 101 West 57th Street at 6th Avenue Lithuania Renaissance Paris Republique SAS S.H.P.R, Renaissance Paris Republique 40, Rene Boulanger Paris Wolverine Lessee LLC Mondrian Hotel c/o I.W. Winsten Honigman Miller Schwartz and Cohn LLP 660 Woodward Avenue Detroit Profitability Consulting PTY Limited Alpine Gables Apartment Hotel PO. Box 1882 Wollongo New South ng Wales 53 Park Lane, Mayfair London W1K 1Q1 United Kingdom 1161 West Georgia Street British Vancouver Columbia V6E 006 Canada 2031 St. Charles Avenue New Orleans 70130 United States The Dorchester LTD The Dorchester Hotel TA Hotel Management LP Trump Vancouver Hotel Pontchartrain Hotel Pontchartrain Hotel 75010 Michigan Louisiana France 48226-3506 United States Australia CERTIFICATE OF SERVICE I hereby certify that I am an employee of the law firm of Parsons Behle & Latimer and that on the 28th day of March, 2017, I served a true and correct copy of the foregoing [PROPOSED] ORDER via courtesy email (listed below) and U.S. Mail, at Reno, Nevada, in a sealed envelope with first-class postage fully prepaid and addressed as follows: Mobile Simple Solutions, Inc. 2711 Centerville Road, Suite 400 Wilmington, Delaware 19808 Mobile Simple Solutions (IAS), Inc. 3900-1, Place Ville Marie Montreal, QC,H3B 4M7, Canada Vincent Tessier 2298 Aria Drive Henderson, Nevada 89052 Courtesy Email: vintessier(eb,gmail.com; vincent@mobile-simple.com Christelle Pigeat 1457 rue Laurier Est,#4 Montreal, QC,H2J 1H8, Canada Courtesy Email: christelleAmobile-simple.com; christelle.pigeatAgmail.com /s/ Kathy Souviron Employee of Parsons Behle & Latimer PARSONS BEHLE & LATIMER 4810-9190-2497 vl

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