Microunity Systems Engineering, Inc v. Acer Inc. et al

Filing 1

COMPLAINT for Patent Infringement against AT&T Inc, AT&T Mobility LLC, Acer America Corporation, Acer Inc., Apple Inc, Cellco Partnership, Exedea Inc, Google Inc., HTC America Inc., HTC Corporation, LG Electronics Inc., LG Electronics MobileComm USA, Inc., Motorola Inc.,, Nokia Corporation, Nokia Inc., Palm Inc., Qualcomm Inc., Samsung Electronics Co., LTD.,, Samsung Semiconductor Inc., Samsung Telecommunications America LLC, Sprint Nextel Corporation, Texas Instruments Inc. ( Filing fee $ 350 receipt number 0540-2513044.), filed by Microunity Systems Engineering, Inc. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit C, # 3 Exhibit C-1, # 4 Exhibit U part 1, # 5 Exhibit U part 2, # 6 Exhibit U part 3, # 7 Exhibit U part 4, # 8 Exhibit U part 5)(Susman, Stephen)

Microunity Systems Engineering, Inc v. Acer Inc. et al

Doc. 1

IN TFIE LINITED STATES DISTRICT COURT FOR THE EASTERN DISTzuCT OF TEXAS MARSTIALL DIVISION MICROI.]NITY SYSTEMS ENGINEERING, INC., a California corporation,
$ $ $

v.

Plaintift

(l) ACER INC.,

of China corporation, $ (2) ACER AMEzuCA CORPORATION, $ California corporation, (3) APPLE, $ a California corporation, (4) AT&T INC., $ Delaware corporation, (5) AT&T $ LLC,aDelaware limited liability $ (6) CELLCO PARTNERSHIP, $ partnership, (7) EXEDEA, INC., a $ corporation, (8) GOOGLE INC., a $ corporation, (9) HTC CORPORATION, aRepublic $ of China corporation, (10) HTC AMEzuCA, I\IC., $ a Texas corporation, (11) LG Electronics, Inc., $ Korean limited company, (12) LG Electronics $ Mobilecomm U.S.A.,Inc., a Califomia corporation, $ (13) MOTOROLA, INC., a Delaware corporation, $ (14) NOKIA CORPORATION a Finnish $ corporation, (15) NOKIA INC., a Delaware $ corporation, (16) PALM, [NIC., a Delaware $ corporation, (17) QUALCOMM INC., a Delaware $ corporation, (18) SAMSLTNG ELECTRONICS CO.,$ LTD., a Korean limited company, (19) SAMSUNG, $ SEMICONDUCTOR INC., a $ (20) corporation, $
a Republic

$

Civil Action No.

a [NIC., a MOBILITY company, aDelaware Texas Delaware a

ruRY TRIAL DEMANDED

California SAMSI-ING

TELECOMMLINICATIONSAMEzuCA,LLC,
limited liability company, (21) SPRINT NEXTEL CORPORATION, a Kansas corporation, (ZZ)TEXAS INSTRUMENTS INC., aDelaware coryoratlon,
a Delaware

$
$

$ $

Defendants.

COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff MicroUnity Systems Engineering, Inc., for its complaint against Defendants Acer,
Inc., Acer America Corporation, Apple, Inc., AT&T Inc., AT&T Mobility LLC, Cellco Partnership, Exedea, Inc., Google Inc., HTC Corporation, HTC Americ4 Inc.,

LG Electronics, Inc., LG

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Dockets.Justia.com

Electronics Mobilecomm U.S.A., Inc., Motorola, Inc., Nokia Corporation, Nokia Inc., Palm, Inc.,

Qualcomm Inc., Samsung Electronics Co., LTD., Samsung Semiconductor, Inc., Samsung
Telecommunications America, LLC, SprintNextel Corporation, and Texas Instruments Inc., alleges:

THE PARTIES

1.

MicroUnity Systems Engineering, Inc. ("MicroUnity") is a corporation duly

organized and existing under the laws of the State of California, with its principal place of business

at376 Martin Avenue, Santa CIara, CA 95050.

2.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Texas Instruments Inc.

("TI") is a corporation duly organized

and existing under the laws

of the state
has

of Delaware, with its principal place of business at 12500 TI Blvd., Dallas, TX 75226; that TI

developed, manufactures, and sells its OMAP3 series of processors to the suppliers of cell phones
and other products; that TI has announced that it is developing its OMAP4 series of processors; that

OMAP3 and OMAP4 processors are designed, used, offered for sale and sold in this district; and that
products implementing such processors are designed, used, offered for sale and sold in this district
and throughout the United States and imported into the United States.

3.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Qualcomm, Inc. ("Qualcomm") is a corporation duly organized and existing under the laws of the
state

of Delaware, with its principal place of business at 5775 Morehouse Drive, San Diego, CA

9212I; that Qualcomm has developed, manufactures, and sells its Snapdragon series of processors, including but not limited to its QSD8250 and QSD8650 processors, to the suppliers of cell phones,

tablet computers and other products; and that products implementing such processors are used,
ofÊered

for sale and sold in this district and throughout the United States and imported into the

United States.

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4.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Samsung Electronics Co., Ltd. ("Samsung") is a public limited company duly organized and existing under the laws of South Korea, with its principal place of business at#24 Nongseo-Dong, Kiheung-

Gu, Yongin-City, Kyunggi-Do, Korea; that Defendant Samsung Semiconductor, Inc., ("SSI") is a

wholly owned subsidiary of Samsung, and is a corporation duly organtzed and existing under the
laws of the state of California, with its principal place of business at3655 N. I't St., San Jose, CA
95134;that Samsung and SSI have developed, manufacture, and sell processors such as the S5PC100

to the suppliers of cell phones, media players and other products; that Samsung manufactures the
Apple A4 processor for use in tablet computers and other products; and that products implementing
such processors are used, offered for sale and sold in this district and throughout the United States and imported into the United States.

5.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Motorola, Inc. ("Motorola") is a corporation duly orgatttzedand existing under the laws of the state of Delaware, with its principal place of business at 1303 E. Algonquin Rd., Schaumburg,IL 60196;
and that cell phones such as the

Droid are manufactured by Motorola and are used, offered for

sa]e

and sold in this district and throughout the United States and imported into the United States by

Motorola.

6.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Nokia Corporation is a corporation duly organized and existing under the laws of Finland, with its principal place of business at Keilalahdentie 2-4, Espoo, Fl-02-150, Finland; and that Defendant Nokia Inc. is a wholly owned subsidiary of Nokia Corporation, and is a corporation duly organized
and existing under the laws of the state of Delaware, with its principal place of business at 6000

Connection Drive, Irving,

TX 75039. Nokia

Corporation and Nokia Inc. are individually and

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collectively referred to herein as "Nokia." MicroUnity is informed and believes, and on that basis
alleges, that cell phones such as the N900 are manufactured by Nokia and are used, offered for sale

and sold in this district and throughout the United States and imported into the United States by Nokia.

1.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Palm, Inc. ("Palm") is a corporation duly organized and existing under the laws of the state of
Delaware, with its principal place of business at 950 V/. Maude Ave., Sunnyvale, CA 94085; and that cell phones such as the Pre are manufactured by Palm and are used, offered for sale and sold in this district and throughout the United States and imported into the United States by Palm.

8.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Samsung Telecommunications America, LLC, ("STA")

is wholly owned by Samsung, and is

a

limited liability company duly organized and existing under the laws of the state of Delaware, with
its principal place of business at 1301 East Lookout Drive, Richardson, Collin County, TX75082; that Samsung and STA manufacture cell phones such as the Galaxy Spica GT-i5700 and OmniaHD i8910; and that such cell phones are used, offered for sale and sold in this district and throughout the United States and imported into the United States by Samsung and STA.

9.

MicroUnity is informed and believes, and on that basis alleges, that Defendant Acer

Inc. is a corporation duly organzed and existing under the laws of the Republic of China (Taiwan),

with its principal place of business at 8F, 88, Sec. 1, Hsin Tai Wu Rd., Hsichih, Taipei 22I,Taiwan,
ROC; and that Defendant Acer America Corporation is a wholly owned subsidiary of Acer Inc., and

is a corporation duly organrzed and existing under the laws of the state of Califomia, with its
principal place of business at 333 V/. San Carlos St., Ste. 1500, San Jose, CA 951 10. Acer Inc. and
Acer America Corporation are individually and collectively referred to herein as "Acer." MicroUnity

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is informed and believes, and on that basis alleges, that cell phones such as the Liquid A1 and
neoTouch are manufactured by Acer and are used, offered for sale and sold in this district and
throughout the United States and imported into the United States by Acer.

10.

MicroUnity is informed and believes, and on that basis alleges, that Defendant HTC

Corporation, also known as High Tech Computer Corporation, is a public limited

liabilþ

company

duly organized and existing under the laws of the Republic of China, with its principal place of
business at. 23 Xinghua Rd., Taoyuan 330, Taiwan, Republic

of

China; that Defendant HTC

America, Inc.

is a wholly owned subsidiary of HTC

Corporation, through an intermediary

corporation, and is a corporation duly organized and existing under the laws of the state of Texas,

with its principal place of business at 13920 SE Eastgate Way, Suite 400, Bellevue, WA 98005; and that Exedea, Inc., is a wholly owned subsidiary of HTC Corporation, through an intermediary
corporation, and is a corporation duly organized and existing under the laws of the state of Texas,

with its principal place of business at 5950 Corporate Drive, Houston, Texas 77036. HTC
Corporation, HTC America, Inc. and Exedea are individually and collectively referred to herein
as

.'HTC." MicroUnity is informed and believes, and on that basis alleges, that cell phones such HTC Droid Incredible and Evo 4G
are manufactured

as the

by HTC and are used, offered for sale and sold

in this district and throughout the United States and imported into the United States by HTC.

11.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Google Inc. ("Google") is a corporation duly orgarnzed and existing under the laws of the state of Delaware, with its principal place of business at 1600 Amphitheatre Pkwy., Mountain View, CA
94043; that HTC manufactures and Google sells cell phones such as the Nexus One; that such cell phones are used, offered for sale and sold

in this district and throughout the United

States and

imported into the United States by Google and HTC; and that Google makes software for Nexus One

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and other cell phones that is used, offered for sale and sold in this district and throughout the United
States and imported into the United States

by Google.

12.

MicroUnity is informed and believes, and on that basis alleges, that Defendant LG

Electronics, Inc., is a public limited company duly organized and existing under the laws of South Korea, with its principal place of business at LG Twin Towerc,20 Yeouido-dong, Yeoungdeungtrlogu, Seoul, 150-7-2I, South Korea; and that Defendant LG Electronics Mobilecomm U.S.A., Inc. is a

wholly owned subsidiary of LG Electronics, Inc., and is a corporation duly organized and existing
under the laws of the state of California with its principal place of business at 10101 Old Grove

Road, San Diego, CA92L3I. LG Electronics, Inc. and LG Electronics MobilecoÍrm U.S.A., Inc. are

individually and collectively referred to herein

as

"LG." MicroUnity

is informed and believes, and

on that basis alleges, that LG manufactures and sells cell phones such as the eXpo; and that such cell phones are used, offered for sale and sold in this district and throughout the United States and

imported into the United States by LG.

13.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Apple, Inc. ("Apple") is a corporation duly organized and existing under the laws of the state of
California, with its principal place of business at 1 Infinite Loop, Cupertino, CA 95014; that Apple
has developed processors such as the A4 that Apple uses in certain products that Apple sells, and contracted with Samsung for their manufacture; that Apple manufactures and sells products such as the iPhone 3GS cell phone, iPod Touch 32 and 64GB ("iPod Touch 3G") media player, and the iPad and iPad3G tablet computers, and provides software for such products; and that such cell phones, media players, tablet computers and other products and software ate used, offered for sale and sold in this district and throughout the United States and imported into the United States by Apple.

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14.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Cellco Partnership ("Verizon"), doing business as Verizon Vy'ireless, is a general partnership, duly
organtzed and existing under the laws of the state of Delaware, between Verizon Communications

Inc., a corporation duly organized and existing under the laws of the state of Delaware, and
Vodafone Group Plc, a public liability company duly organized and existing under the laws of the United Kingdom, with Verizon's principal place of business at

I Yenzon

Way, Basking Ridge, NJ

07920; that Verizon sells and plans to sell cell phones such as the Motorola Droid, HTC Droid

Incredible, HTC/Google Nexus One and Palm Pre and other products, and services utilizing and software utilized by such products; and that such cell phones and other products, services and software are used, offered for sale and sold in this district and throughout the United States and
imported into the United States by Verizon.

15.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

Sprint Nextel Corporation ("Sprint") is a corporation duly organized and existing under the laws of

the state of Kansas, with its principal place of business at 6500 Sprint Pknry., Overland Park, KS 6625I; that Sprint sells cell phones and other products such as the Palm Pre and HTC Evo 4G, and services utilízing and software utilized

by such products; and that such cell phones and other

products, services and software are used, offered for sale and sold in this district and throughout the

United States and imported into the United States by Sprint.

16.

MicroUnity is informed and believes, and on that basis alleges, that Defendant

AT&T Inc. is a corporation duly organized and existing under the laws of the state of Delaware, with
its principal place of business at 208 S Akard St., Dallas, TX 75201; and that Defendant AT&T

Mobility LLC is wholly owned by AT&T Inc., and is a limited liability company duly organized and
existing under the laws of the state of Delaware, with its principal place of business at 5565

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Glenridge Connector, Atlanta, GA30342. AT&T Inc. and AT&T Mobility LLC are individually and

collectively referred to herein as "AT&T." MicroUnity is informed and believes, and on that basis
alleges, that

AT&T sells cell phones and other products such as the LG eXpo and Apple iPhone

3GS, and services utilizing and software utilized by such products; and that such cell phones and

other products, services and software are used, oflered for sale and sold
throughout the United States and imported into the United States by AT&T.

in this distict

and

JURISDICTION AND VENUE

17.

The Court has subject matter jurisdiction pursuant to 28 U.S.C. $$ 1331 and

1338(a) because this action arises under the patent laws of the United States, 35 U.S.C. $$

I

e/ seq.

Venue is proper in this Federal District pursuant to 28 U.S.C. $$ 1391(b)-(c) and 1400(b) in that the
defendants reside in this district, a substantial part of the events giving rise to the claim occurred in

this district, and the defendants have a regular and established place of business in this district and
have committed acts of infrinsement in this district.

18.
120;

This case ir"r"tut"¿ to, and involves some of the same patents involved in prior

actions, MicroUnity Systems Engineering, Inc. v. Intel Corporation and Dell, Inc.,C.A. No. 2-04CV-

MicroUnity Systems Engineering, Inc. v. Sony Computer Entertainment America 1nc., C.A. No.

2-05CV-505; MicroUnity Systems Engineering, Inc. v. Advanced Micro Devices, Inc.,C.A. No.206CV-486 and pending action MicroUnity Systems Engineering, Inc v. Acer Inc., et al., Case No.
02:10-cv-91, all of which were filed in the United States District Court for the Eastern District
Texas, Marshall Division.

of

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INFRINGEMENT OF U.S. PATENT NO.5,742,840 Cl

19.

On April 21,1998, United States Patent No. 5,742,840

Cl

(the "'840 patent") was

duly and legally issued for an invention entitled "General Purpose, Multþle Precision Parallel
Operation, Programmable Media Processor." MicroUnity was assigned the '840 patent and continues to hold all rights and interest in the '840 patent. A true and correct copy of the '840 patent is attached
hereto as Exhibit C.

20.

The '840 patent has been the subject of a reexamination proceeding, reexamination

request number 901007,583,

in which the patentability of claim 11 is confirmed, claim 1 is

determined to be patentable as amended, claims 2-6,8 and 9 are dependent on an amended claim and
are determined to be patentable, and claims

7 and 10 are canceled. To the extent that amended claim
issued, then claims 1-6, 8 and 9

I is deemed to be not substantially identical to claim 1 as it originally

have an effective date of May 4, 2010 when the Reexamination Certificate
Reexamination Certificate 5,742,840

issued. A copy of

Cl

is attached hereto as Exhibit

Cl.

21.

TI, Samsung, SSI, Qualcomm and Apple have infringed and continue to infringe

one or more of the claims of the '840 patent by their manufacture, use, sale, importation, and/or offer

to sell their infringing processors, including but not limited to TI's OMAP3 and OMAP4

series

processors, Samsung and SSI's S5PC100 processors, Qualcomm's Snapdragon processors and

Apple's A4 processors. TI, Samsung, SSI, Qualcomm and Apple are liable for their infringement of
the '840 patent pursuant to 35 U.S.C . 5 271.

22.

Motorola, Nokia, Palm, Samsung, STA, Acer, HTC, Google, LG and Apple have

infringed and continue to infringe one or more of the claims of the '840 patent by their manufacture,

use, sale, importation, andlor offer

to sell their infringing cell phones, media players,

tablet

computers and other products, including but not limited to the Motorola Droid, Nokia N900, Palm Pre, Samsung Galaxy Spica GT-i5700 and OmniaHD i8910, Acer Liquid

Al

and neoTouch, HTC

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Droid Incredible and Evo 4G, Google/HTC Nexus One, LG eXpo, and Apple iPhone 3GS, iPod
Touch 3G and iPad and iPad 3G. Motorola, Nokia, Palm, Samsung, STA, Acer, HTC, Google, LG
and Apple are liable for their infüngement of the '840 patent pursuant to 35 U.S.C . S 271.

23.

Verizon, AT&T and Sprint have infringed and continue to infringe one or more

of

the claims of the '840 patent by their use, sale, importation, and/or offer to sell infringing cell phones

and other products. Verizon, AT&T and Sprint are liable for their infringement of the '840 patent
pursuant to 35 U.S.C . ç 271.

24.

Defendants' acts

of

infringement have caused damage

to MicroUnity, and
as a result

MicroUnity is entitled to recover from defendants the damages sustained by MicroUnity
their wrongful acts in an amount subject to proof at

of

trial. Defendants' infringement of MicroUnity's

exclusive rights under the '840 patent will continue to damage MicroUnity, causing irreparable harm

for which there is no adequate remedy at law, unless enjoined by this Court.

25.

MicroUnity is informed and believes, and on that basis alleges, that TI, Samsung

and Motorola have had communications and contact with MicroUnity and are fully aware of

MicroUnity's technology and patent portfolio including the '840 patent; that TI, Samsung and
Motorola have proceeded to infringe the '840 patent with full and complete knowledge of the patent
and its applicability to their products without any attempt to take a license under the '840 patent and

without a good faith belief that the '840 patent is invalid or not infringed, and thus TI, Samsung and

Motorola's infringement of the '840 patent is willful and deliberate, entitling MicroUnity to
increased damages under 35 U.S.C. $ 2S4 and to attorney's fees and costs incurred in prosecuting this

action under 35 U.S.C. $ 2S5. MicroUnity reserves the right to allege, after discovery, that the
remaining defendants' infringement of the '840 patent is willful and deliberate, entitling MicroUnity

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to increased damages under 35 U.S.C. $ 284 and to attorney's fees and costs incurred in prosecuting
this action under 35 U.S.C. $ 285.

INFRTNGEMENT OF U.S. PATENT NO. 7,730,287 B2

26.

On June 1,2010, United States Patent No. 7,730,287

Bl

(the "'287 patent") was

duly and legally issued for an invention entitled "Method and Software for Group Floating-Point
Arithmetic Operations." MicroUnity was assigned the'287 patent and continues to hold all rights and
interest in the '287 patent A true and correct copy of the '287 patent is attached hereto as Exhibit U.

27.

Samsung, SSI and Apple have infringed and continue to infringe one or more of the

claims of the '287 pafent by their manufacture, use, sale, importation, and/or offer to sell their
processors, including but not limited to Samsung and SSI's S5PC100 processors and Apple's A4
processors, and by knowingly contributing to and inducing others to manufacture, use, sell, import

and/or offer to sell cell phones, media players, tablet computers and other products and services

which practice processes and include software that infringe one or more of the claims of the '287 patent. Samsung, SSI and Apple are liable for their infringement of the '287 patent pursuant to 35

u.s.c. ç27r.

28.

Apple has infringed and continues to infringe one or more of the claims of the'287

patent by its manufacture, use, sale, importation, and/or offer to sell infringing cell phones, media players and tablet computers and other products, including but not limited to the Apple iPhone 3GS,

iPod Touch 3G, and iPad and iPad 3G, which practice processes and include software that infringe
one or more of the claims of the '287 patent, and by providing software for use in such cell phones,

media players, tablet computers and other products. Apple is liable for its infringement of the '287
patent pursuant to 35 U.S.C . 5 27L

29.

AT&T

has infringed and continues to infringe one or more of the claims of

the'287

patent by its use, sale, importation, and/or offer to sell cell phones and other products which practice
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processes and include software that infringe one or more of the claims of the '287 patent, and by its

knowingly contributing to and inducing its customers to purchase and use services which practice
processes that infringe one or more of the claims of the '287 patent, and by providing software for

use on such cell phones and other products.. AT&T is liable for its infringement of the '287 patent pwsuant to 35 U.S.C . ç 27L

30.

Samsung, SSI, Apple and AT&T's acts of infringement have caused damage to

MicroUnity, and MicroUnity is entitled to recover from Samsung, SSI, Apple and AT&T the
damages sustained by MicroUnity as a result of their wrongful acts in an amount subject to proof at

trial. Samsung, SSI, Apple and AT&T's

infringement of MicroUnity's exclusive rights under the

'287 patent will continue to damage MicroUnity, causing irreparable harm for which there is no
adequate remedy at law, unless enjoined by this Court.

31.

MicroUnity reserves the right to allege, after discovery, that Samsung, SSI, Apple

and AT&T's infringement

of the '287 patent is willful and deliberate, entitling MicroUnity

to

increased damages under 35 U.S.C. $ 284 and to attomey's fees and costs incured in prosecuting this

action under 35 U.S.C. $ 285.

JURY DEMAND

32.

MicroUnity demands atrial by jury on all issues. PRAYER FOR RELIEF

WHEREFORE, Plaintiff MicroUnity Systems Engineering, Inc., requests entry of
judgment in its favor and against defendants as follows:

a)
7,730,287 B2;

Declaring that defendants have infringed U.S. Patent Nos. 5,742,840

Cl

and

b)
5,742,840

Awarding the damages arising out of defendants' infringement of U.S. Patent Nos.

Cl

and 7,730,287 82, including enhanced damages pursuant to 35 U.S.C. $284, to

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MicroUnity, together with prejudgment and post-judgment interest, in an amount according to
proof;

c)

Permanently enjoining defendants and their respective officers, agents, employees,

and those acting

in privity with them, from further

infringement, including contributory

infringement and/or inducing infringement, of U.S. Patent Nos. 5,742,840 in the alternative,
a

Cl and7,730,287 82, or

post-judgment

royaþ for post-judgment infüngement;

d)
by law; and

Awarding of attomey's fees pursuant to 35 U.S.C. $ 285 or as otherwise permitted

e)

For such other costs and firrther relief as the Court may deem just and proper.

DATED: June 3,2010

Respectfully Submitted, /s/ Steohen D. Susman Stephen D. Susman, Attomey-in-Charge State BarNo. 1952100 ssusman@susmangodfrey. com Max L. Tribble, Jr. State BarNo.20213950 mtribble@susmangodfrey. com Joseph S. Grinstein State BarNo. 24002188 j grinstein@susmangodfr ey. com SUSMAN GODFREY L.L.P. 1000 Louisiana Street, Suite 5100 Houston, Texas 77002 Telephone: [phone] Facsimile: [phone] Sidney Calvin Capshaw State Bar No. 03783900 ccapshaw@capshawlaw. com CAPSFIAW DERIEI.IX, L.L.P. ll2TJudsonRd- Ste220 PO Box 3999

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Longview, TX 7 5601 -5 157 [phone] Fax: [phone]
Otis W. Canoll State Bar No.00794219 [e-mail]

IRELAND, CARROLL & KELLEY, P.C.
6101 South Broadway, Suite 500 Tyler, TX75703 Telephone: [phone] Facsimile: (903) 58 1 -1 071

Michael F. Heim State Bar No. 09380923 [e-mail] HEIM, PAYNE & CHORUSH, L.L.P. 600 Travis, Suite 6710 Houston, Texas 77002 Telephone : [phone] Facsimile: (7 13) 221 -2021
Douglas R. V/ilson

BarNo.24037719 [e-mail] HEIM, PAYNE & CHORUSH, L.L.P. 9442 Capital of Texas Hwy. Plazal, Suite 500-146 Austin, Texas 78759
State

Telephone : [phone] Facsimile: (512) 345 -2924 George M. Schwab State BarNo. 58250 (CA) gschwab@ gmspatent. com LAW OFFICES OF GEORGE M. SCHWAB 235Montgomery St., Suite 1026 San Francisco, CA 94104 Telephone: [phone] I 0

Attomeys for MICROLINITY SYSTEMS ENGINEERING. INC.

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