Motorola Mobility, Inc. et al v. TiVo Inc.

Filing 1

COMPLAINT for Patent Infringement and Declaratory Judgment against TiVo Inc. ( Filing fee $ 350 receipt number 0540-2905317.), filed by Motorola Mobility, Inc., General Instrument Corporation. (Attachments: # 1 Civil Cover Sheet)(Erickson, Brian)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TEXARKANA DIVISION

MOTOROLA MOBILITY, INC. and
GENERAL INSTRUMENT CORPORATION
Civil Action No. _____________
Plaintiffs,
vs.
TIVO INC.,

JURY TRIAL DEMANDED
Defendant.

COMPLAINT FOR PATENT INFRINGEMENT
AND DECLARATORY JUDGMENT
Plaintiffs Motorola Mobility, Inc. (“Motorola Mobility”) and General Instrument
Corporation (“General Instrument”) (collectively “Plaintiffs”) file this Complaint For Patent
Infringement and Declaratory Judgment against Defendant TiVo Inc. (“TiVo”), and in support of
their Complaint allege as follows:
INTRODUCTION
1.

General Instrument, a subsidiary of Motorola Mobility, owns multiple patents that

disclose and claim fundamental inventions related to digital video recorders (“DVRs”), which
are now ubiquitous in American households. These fundamental DVR patents include patents
for inventions from the mid 1990s by a group of former General Instrument engineers who went
on to found Imedia Corporation (“Imedia”). General Instrument subsequently acquired all of the
assets of Imedia, including the Imedia DVR patents. Among the patents the Imedia engineers
were awarded for their inventions are United States Patent Nos. 5,949,948 (“the ’948 Patent”);

6,304,714 (“the ’714 Patent”); and 6,356,708 (“the ’708 Patent”) (collectively “the Imedia
Patents”).
2.

The Imedia Patents were filed with the Patent Office beginning in April 1995.

More than two years later, TiVo was founded and began to develop a DVR product. In July
1998, more than three years after the Imedia Patents were first filed with the Patent Office, TiVo
filed a patent application for what it dubbed a “Multimedia Time Warping System.” From that
1998 application, TiVo obtained United States Patent Nos. 6,233,389 (“the ’389 Patent”) and
7,529,465 (“the ’465 Patent) (collectively “the TiVo Patents”), among others. The TiVo Patents
disclose and claim the same technology the Imedia engineers invented years before.
3.

TiVo currently is seeking to enforce its patents in this Court against Motorola

Mobility customer Verizon Communications, Inc. (“Verizon”). In TiVo Inc. v. Verizon Comms.,
Inc., et al., 2:09-cv-257-DF (E.D. Tex.) (the “Verizon Lawsuit”), TiVo has accused various QIP
set-top boxes of infringing certain claims of the TiVo Patents. Motorola Mobility and General
Instrument supply the accused QIP set-top boxes to Verizon.
4.

Therefore, Plaintiffs now bring this action to: (1) seek all available remedies for

TiVo’s willful infringement of the Imedia Patents; (2) obtain a declaratory judgment that the
claims of the TiVo Patents are anticipated and/or rendered obvious by the Imedia Patents and
Imedia inventions, thus rendering the TiVo Patents invalid; and (3) obtain a declaratory
judgment that the accused QIP set-top boxes do not infringe, directly or indirectly, literally or
under the doctrine of equivalents, claims 31 and 61 of the ’389 Patent or any claim of the ’465
Patent.

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THE PARTIES
5.

Motorola Mobility is a corporation organized and existing under the laws of the

State of Delaware, having a principal place of business at 600 North U.S. Highway 45,
Libertyville, Illinois 60048.
6.

General Instrument is a corporation organized and existing under the laws of the

State of Delaware, having a principal place of business at 101 Tournament Drive, Horsham,
Pennsylvania 19044. General Instrument is a wholly-owned subsidiary of Motorola Mobility.
General Instrument designs and supplies the QIP set-top boxes that Motorola Mobility sells and
supplies to Verizon.
7.

On information and belief, Defendant TiVo is a corporation organized and

existing under the laws of Delaware with a principal place of business at 2160 Gold Street,
Alviso, California 95002. TiVo can be served with process through its registered agent for
service, Corporation Service Company, d/b/a CSC Lawyers Incorporated, 211 E. 7th Street,
Suite 620, Austin, Texas 78701.
JURISDICTION AND VENUE
8.

The Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

§§ 1331 and 1338(a) because this action involves a claim arising under the patent laws of the
United States, 35 U.S.C. § 1, et seq., and under the Federal Declaratory Judgment Act, 28 U.S.C.
§§ 2201 and 2202.
9.

Personal jurisdiction and venue are proper in this Court pursuant to 28 U.S.C.

§§ 1391, 1391 and/or 1400, because TiVo resides in this state and district and does business in
this state and district, has committed acts of infringement in this district, and has availed itself of
this forum by repeatedly commencing litigation in this district on the TiVo Patents.

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FACTUAL BACKGROUND
A.

The Imedia Patents
10.

On September 7, 1999, the United States Patent and Trademark Office duly and

lawfully issued the ’948 Patent, entitled “Method and Apparatus for Implementing Playback
Features for Compressed Video Data” to Dr. Edward A. Krause, Paul Shen and Dr. Adam S.
Tom. A true and correct copy of the ’948 Patent is attached to this Complaint as Exhibit A.
General Instrument owns the entire right, title and interest in and to the ’948 Patent. The ’948
Patent was filed on November 20, 1995.
11.

On October 16, 2001, the United States Patent and Trademark Office duly and

lawfully issued the ’714 Patent, entitled “In-Home Digital Video Unit With Combine Archival
Storage and High-Access Storage” to Dr. Krause, Dr. Jerrold Heller, Dr. Tom and Mr. Shen. A
true and correct copy of the ’714 Patent is attached to this Complaint as Exhibit B. General
Instrument owns the entire right, title and interest in and to the ’714 Patent. The ’714 Patent
claims priority to application number 08/425,896, filed on April 21, 1995.
12.

On March 12, 2002, the United States Patent and Trademark Office duly and

lawfully issued the ’708 Patent, entitled “Method and Apparatus for Implementing Playback
Features for Compressed Video Data” to Dr. Krause, Mr. Shen and Dr. Tom. A true and correct
copy of the ’708 Patent is attached to this Complaint as Exhibit C. General Instrument owns the
entire right, title and interest in and to the ’708 Patent. The ’708 Patent is a division of
application number 08/560,732, filed on November 20, 1995, now the ’948 Patent.
B.

The TiVo Patents
13.

On May 15, 2001, the United States Patent and Trademark Office issued the ’389

Patent, entitled “Multimedia Time Warping System” to James M. Barton, Roderick James

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McInnis, Alan S. Moskowitz, Andrew Martin Goodman, Ching Tong Chow and Jean Swey Kao.
A true and correct copy of the ’389 Patent is attached to this Complaint as Exhibit D. TiVo has
alleged that it owns the ’389 Patent.
14.

On May 5, 2009, the United States Patent and Trademark Office issued the ’465

Patent, entitled “System for Time Shifting Multimedia Content Streams” to James M. Barton,
Roderick James McInnis, Alan S. Moskowitz, Andrew Martin Goodman, Ching Tong Chow and
Jean Swey Kao. A true and correct copy of the ’465 Patent is attached to this Complaint as
Exhibit E. TiVo has alleged that it owns the ’465 Patent.
C.

General Instrument Is a Pioneer in Digital Television.
15.

General Instrument is a pioneer in the field of communication systems and is

responsible for many groundbreaking innovations in television set-top box technology. In 1990,
General Instrument proposed the world’s first all-digital HDTV (high-definition television)
technical standard.
16.

Until 1994, the inventors of the Imedia Patents were employed by General

Instrument developing technology that is still used in set-top boxes today, including those
supplied by General Instrument, Motorola Mobility, TiVo and others. For example, Dr. Krause
helped invent three patented technologies while at General Instrument that the MPEG LA
licensing organization determined were essential to the MPEG-2 compression standard. On
information and belief, TiVo subsequently licensed Dr. Krause’s patented inventions through the
MPEG LA licensing pool. As another example, in 1996 Dr. Krause was awarded an Emmy by
the Academy of Television Arts and Sciences for creating the DigiCipher system while working
at General Instrument. The winning DigiCipher technology was used to demonstrate digital TV
transmitted over satellite and cable channels.

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17.

In early 2000, Motorola, Inc. and General Instrument merged, which positioned

Motorola as a leader in the convergence of voice, video and data technologies. General
Instrument is now a wholly-owned subsidiary of Motorola Mobility. The combined company
continues to focus on broadband solutions that deliver interactive television, the Internet and
telephone services over wired and wireless networks.
D.

The Imedia Engineers Invented the DVR in the Mid 1990s.
18.

In March 1994, Dr. Krause, Dr. Tom and Mr. Shen left General Instrument to

found Imedia and were joined soon thereafter by Dr. Heller. Turning down an offer from
General Instrument to set up a separate division, the four engineers instead started their own
company in a spare room in Dr. Krause’s home in San Diego, California.
19.

Imedia quickly became a success, developing innovative products that enabled

cable operators to select and customize their program lineup for viewer preferences, including
the highly successful Cherry Picker product. While at Imedia, the Imedia engineers conceived of
their DVR invention and filed a series of patent applications covering various aspects of their
invention. They marketed their DVR invention as the “Home Video Server,” which featured
digital random-access storage of television programming, full trick-mode playback, and easy-touse content manager that allowed selective capturing of television programs.
20.

Each of the Imedia Patents was originally assigned to Imedia. In or about 1999,

Imedia was acquired by Terayon Communications Systems, Inc. (“Terayon”) for a reported $100
million. With the acquisition, the Imedia Patents were assigned to Terayon. Terayon later was
merged into General Instrument, making General Instrument the successor in interest to all right
and title to the Imedia patents.

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E.

TiVo Obtained Patents on its DVR Product and Sued the Industry.
21.

On information and belief, in or around 1997, TiVo was founded and began to

develop its DVR product. In July 1998—more than three years after the Imedia Patents were
first filed—TiVo submitted a patent application for what it dubbed a “Multimedia Time Warping
System.” That application eventually matured into the ’389 Patent and ’465 Patent, among
others. The TiVo Patents disclose and claim the same technology the Imedia engineers invented
years earlier.
22.

On January 5, 2004, TiVo filed a patent infringement lawsuit in the United States

District Court for the Eastern District of Texas against EchoStar Communications, Case No. 04cv-00001 (DF) (the “EchoStar Lawsuit”). In the EchoStar Lawsuit, TiVo asserted that EchoStar
infringed the ’389 Patent by making, using, offering to sell and/or selling digital recording
devices, digital video recording device software and/or personal television services falling within
the scope of one or more claims of the ’389 Patent.
23.

On August 26, 2009, TiVo filed a patent infringement lawsuit in the Eastern

District of Texas against AT&T Inc., Case No. 09-cv-00259 (DF) (the “AT&T Lawsuit”). In the
AT&T Lawsuit, TiVo asserted that AT&T infringed the TiVo Patents by making, using, offering
for sale, selling and/or importing products and/or processes falling within the scope of one or
more claims of the TiVo Patents, including AT&T’s U-verse product and/or service.
24.

On August 26, 2009, TiVo filed the Verizon Lawsuit. On February 2, 2010, TiVo

filed an amended complaint in the Verizon Lawsuit adding Verizon Services Corp. and Verizon
Corporate Resources Group, LLC as defendants (all defendants in the Verizon Lawsuit are
referred to collectively as “Verizon”). In the Verizon Lawsuit, TiVo asserted that Verizon’s
digital recording devices, digital video recording device software and personal television services

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infringed the TiVo Patents. On February 24, 2010, Verizon answered TiVo’s amended
complaint. On or about April 4, 2010, TiVo identified certain QIP set-top boxes as accused
instrumentalities in the Verizon Lawsuit.
25.

On or about August 27, 2010, TiVo served a subpoena on Motorola, Inc. seeking

documents related to the design, operation and sale by Motorola, Inc. to Verizon of “all DVRs
manufactured or otherwise produced for or sold to Verizon by Motorola, including the following
models: Motorola QIP 27xx Series Standard-Definition Watch and Record DVR, Motorola
QIP6200/QIP64xx Series, and Motorola QIP7200 Series.” On October 8, 2010, Motorola, Inc.
served its objections to TiVo’s subpoena. On January 4, 2011, Motorola Mobility ceased being a
subsidiary of Motorola, Inc. On January 14, 2011, TiVo served a substitute subpoena on
Motorola Mobility, seeking documents related to the QIP set-top boxes. On February 2, 2011,
Motorola Mobility served its objections to TiVo’s substitute subpoena and produced various
documents. TiVo has requested production of Motorola source code related to the accused QIP
set-top boxes, and Motorola Mobility currently is in the process of meeting and conferring with
TiVo regarding producing that source code for inspection.
26.

As a result of TiVo’s accusations of infringement and the Verizon Lawsuit,

Verizon has demanded that Motorola Mobility defend and/or indemnify Verizon against TiVo’s
claims of patent infringement related to the QIP set-top boxes. In light of TiVo’s aggressive
litigation history, TiVo’s accusations of infringement against QIP set-top boxes, TiVo’s requests
for detailed Motorola technical information related to the accused QIP set-top boxes and
Verizon’s indemnification demand, an actual controversy exists between Plaintiffs and TiVo
regarding questions of infringement and validity of the TiVo Patents.

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FIRST CAUSE OF ACTION
(TiVo’s Infringement of the ’714 Patent)
27.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

28.

General Instrument is the sole holder of the entire right, title and interest in the

’714 Patent.
29.

TiVo has infringed and continues to infringe, directly and indirectly by

contributing to and inducing the infringement of others, one or more claims of the ’714 Patent by
making, using, importing, selling, and/or offering to sell DVR devices, DVR software, DVR
accessories and related services that are covered by the claims of the ’714 Patent.
30.

On information and belief, TiVo has been on notice of and aware of the ’714

Patent since at least October 2005.
31.

On information and belief, TiVo has actively induced, and continues to actively

induce, the infringement of one or more claims of the ’714 patent by, among other things,
instructing its customers to operate the accused products in a manner that infringes the claims of
the ’714 patent. TiVo intends that its customers will use its DVR devices, DVR software and
DVR accessories in a manner that infringes the ’714 patent.
32.

On information and belief, TiVo has contributorily infringed and continues to

contributorily infringe the ’714 patent by offering to sell and/or selling within the United States
and/or importing into the United States one or more components of a machine, manufacture, or
combination covered by the ’714 patent that constitute a material part of the invention, which is
not a staple article or commodity of commerce suitable for substantial noninfringing use. On
information and belief, TiVo knows that the component and/or apparatus is especially made or
especially adapted for use in infringing the ’714 patent.

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33.

On information and belief, TiVo has been on notice of and aware of the ’714

Patent since at least October 2005 and has nevertheless continued to infringe, despite an
objectively high likelihood that its actions constitute infringement of the ’714 patent.
Accordingly, TiVo’s infringement has been and continues to be willful.
34.

As a result of TiVo’s infringement of the ’714 Patent, General Instrument is

suffering irreparable harm for which it has no adequate remedy at law. Unless enjoined by this
Court, this infringement will continue and will result in further irreparable harm to General
Instrument.
35.

General Instrument is entitled to recover damages from TiVo not less than a

reasonable royalty adequate to compensate for the infringement.
SECOND CAUSE OF ACTION
(TiVo’s Infringement of the ’948 Patent)
36.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

37.

General Instrument is the sole holder of the entire right, title and interest in the

’948 Patent.
38.

TiVo has infringed and continues to infringe, directly and indirectly by

contributing to and inducing the infringement of others, one or more claims of the ’948 Patent by
making, using, importing, selling, and/or offering to sell DVR devices, DVR software, DVR
accessories and related services that are covered by the claims of the ’948 Patent.
39.

On information and belief, TiVo has been on notice of and aware of the ’948

Patent since at least October 2005.
40.

On information and belief, TiVo has actively induced, and continues to actively

induce, the infringement of one or more claims of the ’948 patent by, among other things,

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instructing its customers to operate the accused products in a manner that infringes the claims of
the ’948 patent. TiVo intends that its customers will use its DVR devices, DVR software and
DVR accessories in a manner that infringes the ’948 patent.
41.

On information and belief, TiVo has contributorily infringed and continues to

contributorily infringe the ’948 patent by offering to sell and/or selling within the United States
and/or importing into the United States one or more components of a machine, manufacture, or
combination covered by the ’948 patent that constitute a material part of the invention, which is
not a staple article or commodity of commerce suitable for substantial noninfringing use. On
information and belief, TiVo knows that the component and/or apparatus is especially made or
especially adapted for use in infringing the ’948 patent.
42.

On information and belief, TiVo has been on notice of and aware of the ’948

Patent since at least October 2005 and has nevertheless continued to infringe, despite an
objectively high likelihood that its actions constitute infringement of the ’948 patent.
Accordingly, TiVo’s infringement has been and continues to be willful.
43.

As a result of infringement of the ’948 Patent, General Instrument is suffering

irreparable harm for which General Instrument has no adequate remedy at law. Unless enjoined
by this Court, this infringement will continue and will result in further irreparable harm to
General Instrument.
44.

General Instrument is entitled to recover damages from TiVo not less than a

reasonable royalty adequate to compensate for the infringement.
THIRD CAUSE OF ACTION
(TiVo’s Infringement of the ’708 Patent)
45.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

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46.

General Instrument is the sole holder of the entire right, title and interest in the

’708 Patent.
47.

TiVo has infringed and continues to infringe, directly and indirectly by

contributing to and inducing the infringement of others, one or more claims of the ’708 Patent by
making, using, importing, selling, and/or offering to sell DVR devices, DVR software, DVR
accessories and related services that are covered by the claims of the ’708 Patent.
48.

On information and belief, TiVo has been on notice of and aware of the ’708

49.

On information and belief, TiVo has actively induced, and continues to actively

Patent.

induce, the infringement of one or more claims of the ’708 patent by, among other things,
instructing its customers to operate the accused products in a manner that infringes the claims of
the ’708 patent. TiVo intends that its customers will use its DVR devices, DVR software and
DVR accessories in a manner that infringes the ’708 patent.
50.

On information and belief, TiVo has contributorily infringed and continues to

contributorily infringe the ’708 patent by offering to sell and/or selling within the United States
and/or importing into the United States one or more components of a machine, manufacture, or
combination covered by the ’708 patent that constitute a material part of the invention, which is
not a staple article or commodity of commerce suitable for substantial noninfringing use. On
information and belief, TiVo knows that the component and/or apparatus is especially made or
especially adapted for use in infringing the ’708 patent.
51.

On information and belief, TiVo has been on notice of and aware of the ’708

Patent and has nevertheless continued to infringe, despite an objectively high likelihood that its

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actions constitute infringement of the ’708 patent. Accordingly, TiVo’s infringement has been
and continues to be willful.
52.

As a result of infringement of the ’708 Patent, General Instrument is suffering

irreparable harm for which General Instrument has no adequate remedy at law. Unless enjoined
by this Court, this infringement will continue and will result in further irreparable harm to
General Instrument.
53.

General Instrument is entitled to recover damages from TiVo not less than a

reasonable royalty adequate to compensate for the infringement.
FOURTH CAUSE OF ACTION
(Invalidity of the ’389 Patent)
54.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

55.

Claims 31 and 61 of the ’389 Patent are invalid for failure to meet the

requirements of patentability under 35 U.S.C. §§ 102, 103 and/or 112.
56.

As a result of the acts described in the foregoing paragraphs, there exists a

substantial and actual controversy, within the meaning of 28 U.S.C. §§ 2201 and 2202, between
Plaintiffs and TiVo of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
57.

A judicial declaration is necessary and appropriate so that Plaintiffs may ascertain

their rights regarding claims 31 and 61 of the ’389 Patent.
FIFTH CAUSE OF ACTION
(Invalidity of the ’465 Patent)
58.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

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59.

The claims of the ’465 Patent are invalid for failure to meet the requirements of

patentability under 35 U.S.C. §§ 102, 103 and/or 112.
60.

As a result of the acts described in the foregoing paragraphs, there exists a

substantial and actual controversy, within the meaning of 28 U.S.C. §§ 2201 and 2202, between
Plaintiffs and TiVo of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
61.

A judicial declaration is necessary and appropriate so that Plaintiffs may ascertain

their rights regarding the ’465 Patent.
SIXTH CAUSE OF ACTION
(Noninfringement of the ’389 Patent)
62.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

63.

The QIP set-top boxes do not infringe directly, indirectly, or otherwise, either

literally or equivalently, claim 31 or 61 of the ’389 Patent.
64.

As a result of the acts described in the foregoing paragraphs, there exists a

substantial and actual controversy, within the meaning of 28 U.S.C. §§ 2201 and 2202, between
Plaintiffs and TiVo of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
65.

A judicial declaration is necessary and appropriate so that Plaintiffs may ascertain

their rights regarding claims 31 and 61 of the ’389 Patent.
SEVENTH CAUSE OF ACTION
(Noninfringement of the ’465 Patent)
66.

Plaintiffs incorporate by reference the allegations in the preceding paragraphs.

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67.

The QIP set-top boxes do not infringe, directly, indirectly, or otherwise, either

literally or equivalently, any valid claim of the ’465 Patent.
68.

As a result of the acts described in the foregoing paragraphs, there exists a

substantial and actual controversy, within the meaning of 28 U.S.C. §§ 2201 and 2202, between
Plaintiffs and TiVo of sufficient immediacy and reality to warrant the issuance of a declaratory
judgment.
69.

A judicial declaration is necessary and appropriate so that Plaintiffs may ascertain

their rights regarding the ’465 Patent.
DEMAND FOR JURY TRIAL
Plaintiffs demand trial by jury of all issues triable of right by a jury.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs ask this Court to enter judgment in its favor against TiVo and
grant the following relief:
A.

Judgment that the ’714, ’948 and ’708 Patents are each valid, enforceable, and

infringed by TiVo;
B.

A preliminary and permanent injunction enjoining TiVo, its officers, agents,

servants, employees, subsidiaries and affiliated companies, and those persons acting in active
concert or participation therewith, from engaging in the aforesaid unlawful acts of patent
infringement;
C.

An award of damages arising out of each of TiVo’s acts of patent infringement,

together with pre-judgment and post-judgment interest;
D.

Judgment that the damages be trebled in accordance with 35 U.S.C. § 284;

E.

Judgment declaring that claims 31 and 61 of the ’389 Patent are invalid under 35

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U.S.C. §§ 102, 103 and/or 112;
F.

Judgment declaring that each of the claims of the ’465 Patent are invalid under 35

U.S.C. §§ 102, 103 and/or 112;
G.

Judgment declaring that neither claim 31 nor claim 61 of the ’389 Patent has been

infringed by Plaintiffs, directly or indirectly, literally or equivalently, by the making, using,
selling, offering to sell, and/or importing of QIP set-top boxes;
H.

Judgment declaring that no valid claim of the ’465 Patent has been infringed by

Plaintiffs, directly or indirectly, literally or equivalently, by the making, using, selling, offering
to sell, and/or importing of QIP set-top boxes;
I.

Declaring this case exceptional and awarding Plaintiffs their attorneys’ fees and

costs incurred in this action, pursuant to 35 U.S.C. § 285; and
J.

Granting Plaintiffs such other, further and different relief as the Court may deem

just and proper.
Dated: February 25, 2011

By: /s/ Brian Erickson
John Allcock (pro hac vice app. pending)
[e-mail]
Sean Cunningham (pro hac vice app. pending)
[e-mail]
Erin Gibson (pro hac vice app. pending)
[e-mail]
DLA Piper LLP (US)
401 B Street, Suite 1700
San Diego, CA 92101
Telephone: [phone]
Facsimile: 619-699-2701
Wayne Harding
Texas Bar No. 08978500
[e-mail]
Brian Erickson
Texas Bar No. 24012594
[e-mail]
John Guaragna

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Texas Bar No. 24043308
[e-mail]
DLA Piper LLP (US)
401 Congress Avenue, Suite 2500
Austin, TX 78701-3799
Telephone: [phone]
Facsimile: 512-457-7001
Attorneys for Plaintiffs
MOTOROLA MOBILITY, INC. and
GENERAL INSTRUMENT CORPORATION

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