Innovatio IP Ventures, LLC v. Madison Marriott West et al

Filing 1

COMPLAINT for Patent Infringement against Courtyard La Crosse Downtown/Mississippi Riverfront, Courtyard Madison East, Courtyard Madison West/Middleton, Courtyard Wausau, Fairfield Inn & Suites Beloit, Fairfield Inn & Suites Madison East, Fairfield Inn & Suites Madison West/Middleton, Fairfield Inn & Suites Stevens Point, Fairfield Inn & Suites Wausau, Fairfield Inn Hudson, Madison Marriott West, Residence Inn Madison East, Residence Inn Madison West/Middleton. ( Filing fee $ 350 receipt number 0758-838806.), filed by Innovatio IP Ventures, LLC. (Attachments: # 1 Exhibit A - US6714559, # 2 Exhibit B - US7386002, # 3 Exhibit C - US7535921, # 4 Exhibit D - US7548553, # 5 Exhibit E - US5740366, # 6 Exhibit F - US5940771, # 7 Exhibit G - US6374311, # 8 Exhibit H - US7457646, # 9 Exhibit I - US5546397, # 10 Exhibit J - US5844893, # 11 Exhibit K - US6665536, # 12 Exhibit L - US6697415, # 13 Exhibit M - US7013138, # 14 Exhibit N - US7710907, # 15 Exhibit O - US7916747, # 16 Exhibit P - US7873343, # 17 Exhibit Q Part 1 - US7536167, # 18 Exhibit Q Part 2 - US7536167, # 19 JS-44 Civil Cover Sheet Civil Cover Sheet, # 20 Summons Madison Marriott West, # 21 Summons Fairfield Inn & Suites Beloit, # 22 Summons Fairfield Inn Hudson, # 23 Summons Courtyard La Crosse Downtown/Mississippi Riverfront, # 24 Summons Courtyard Madison East, # 25 Summons Residence Inn Madison East, # 26 Summons Fairfield Inn & Suites Madison East, # 27 Summons Courtyard Madison West/Middleton, # 28 Summons Residence Inn Madison West/Middleton, # 29 Summons Fairfield Inn & Suites Madison West/Middleton, # 30 Summons Fairfield Inn & Suites Stevens Point, # 31 Summons Courtyard Wausau, # 32 Summons Fairfield Inn & Suites Wausau, # 33 Report on Filing Patent/Trademark Action) (McAndrews, Matthew)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN
INNOVATIO IP VENTURES, LLC,
Plaintiff,
Civil Action No. 11-cv-644

v.
MADISON MARRIOTT WEST;
FAIRFIELD INN & SUITES BELOIT;
FAIRFIELD INN HUDSON;
COURTYARD LA CROSSE
DOWNTOWN/MISSISSIPPI RIVERFRONT;
COURTYARD MADISON EAST;
RESIDENCE INN MADISON EAST;
FAIRFIELD INN & SUITES MADISON EAST;
COURTYARD MADISON
WEST/MIDDLETON;
RESIDENCE INN MADISON
WEST/MIDDLETON;
FAIRFIELD INN & SUITES MADISON
WEST/MIDDLETON;
FAIRFIELD INN & SUITES STEVENS POINT;
COURTYARD WAUSAU; and
FAIRFIELD INN & SUITES WAUSAU,

COMPLAINT
(Jury Trial Demand)

Defendants.

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
For its Original Complaint for Patent Infringement, Plaintiff Innovatio IP Ventures, LLC
(“Innovatio”), by and through its undersigned counsel, alleges against the Marriott Defendants –
as particularly identified below – as follows:
THE PARTIES
1.

Plaintiff Innovatio is a limited liability company organized under the laws of the

State of Delaware and has a place of business at 22 West Washington Street, Suite 1500,
Chicago, Illinois 60602.

2.

On information and belief, Defendant Madison Marriott West owns and operates

a hotel at 1313 John Q Hammons Drive, Middleton, Wisconsin 53562.
3.

On information and belief, Defendant Fairfield Inn & Suites Beloit owns and

operates a hotel at 2784 Milwaukee Road, Beloit, Wisconsin 53511.
4.

On information and belief, Defendant Fairfield Inn Hudson owns and operates a

hotel at 2400 Center Drive, Hudson, Wisconsin 54016.
5.

On

information

and

belief,

Defendant

Courtyard

La

Crosse

Downtown/Mississippi Riverfront owns and operates a hotel at 500 Front Street South, La
Crosse, Wisconsin 54601.
6.

On information and belief, Defendant Courtyard Madison East owns and operates

a hotel at 2502 Crossroads Drive, Madison, Wisconsin 53718.
7.

On information and belief, Defendant Residence Inn Madison East owns and

operates a hotel at 4862 Hayes Road, Madison, Wisconsin 53704.
8.

On information and belief, Defendant Fairfield Inn & Suites Madison East owns

and operates a hotel at 2702 Crossroads Drive, Madison, Wisconsin 53718.
9.

On information and belief, Defendant Courtyard Madison West/Middleton owns

and operates a hotel at 2266 Deming Way, Middleton, Wisconsin 53562.
10.

On information and belief, Defendant Residence Inn Madison West/Middleton

owns and operates a hotel at 8400 Market Street, Middleton, Wisconsin 53562.
11.

On information and belief, Defendant Fairfield Inn & Suites Madison

West/Middleton owns and operates a hotel at 8212 Greenway Boulevard, Middleton, WI 53562.
12.

On information and belief, Defendant Fairfield Inn & Suites Stevens Point owns

and operates a hotel at 5317 U.S. Highway 10 East, Stevens Point, Wisconsin 54482.

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13.

On information and belief, Defendant Courtyard Wausau owns and operates a

hotel at 1000 South 22nd Avenue, Wausau, Wisconsin 54401.
14.

On information and belief, Defendant Fairfield Inn & Suites Wausau owns and

operates a hotel at 600 Oasis Road, Black River Falls, Wisconsin 54615.
15.

The defendants identified in paragraphs 2-14 above are hereinafter referred to

collectively as “the Marriott Defendants.”
JURISDICTION AND VENUE
16.

This action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et

seq. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. §§ 1331
and 1338(a).
17.

This Court has personal jurisdiction over each of the Marriott Defendants.

18.

Venue for this action is proper in this district pursuant to 28 U.S.C. §§ 1391 and

1400(b).
THE PATENTS-IN-SUIT
19.

On March 30, 2004, the United States Patent and Trademark Office (“the

USPTO”) duly and legally issued U.S. Patent No. 6,714,559 (“the ‘559 Patent”) titled
“Redundant Radio Frequency Network Having A Roaming Terminal Communication Protocol.”
A copy of the ‘559 Patent is attached as Exhibit A.
20.

On June 10, 2008, the USPTO duly and legally issued U.S. Patent No. 7,386,002

(“the ‘002 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal
Communication Protocol.” A copy of the ‘002 Patent is attached as Exhibit B.

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21.

On May 19, 2009, the USPTO duly and legally issued U.S. Patent No. 7,535,921

(“the ‘921 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal
Communication Protocol.” A copy of the ‘921 Patent is attached as Exhibit C.
22.

On June 16, 2009, the USPTO duly and legally issued U.S. Patent No. 7,548,553

(“the ‘553 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal
Communication Protocol.” A copy of the ‘553 Patent is attached as Exhibit D.
23.

On April 14, 1998, the USPTO duly and legally issued U.S. Patent No. 5,740,366

(“the ‘366 Patent”) titled “Communication Network Having Plurality Of Bridging Nodes Which
Transmit A Beacon To Terminal Nodes In Power Saving State That It Has Messages Awaiting
Delivery.” A copy of the ‘366 Patent is attached as Exhibit E.
24.

On August 17, 1999, the USPTO duly and legally issued U.S. Patent No.

5,940,771 (“the ‘771 Patent”) titled “Network Supporting Roaming, Sleeping Terminals.” A
copy of the ‘771 Patent is attached as Exhibit F.
25.

On April 16, 2002, the USPTO duly and legally issued U.S. Patent No. 6,374,311

(“the ‘311 Patent”) titled “Communication Network Having A Plurality Of Bridging Nodes
Which Transmit A Beacon To Terminal Nodes In Power Saving State That It Has Messages
Awaiting Delivery.” A copy of the ‘311 Patent is attached as Exhibit G.
26.

On November 25, 2008, the USPTO duly and legally issued U.S. Patent No.

7,457,646 (“the ‘646 Patent”) titled “Radio Frequency Local Area Network.” A copy of the ‘646
Patent is attached as Exhibit H.
27.

On August 13, 1996, the United States Patent and Trademark Office (“USPTO”)

duly and legally issued U.S. Patent No. 5,546,397 (“the ‘397 Patent”) titled “High Reliability

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Access Point For Wireless Local Area Network.” A copy of the ‘397 Patent is attached as
Exhibit I.
28.

On December 1, 1998, the USPTO duly and legally issued U.S. Patent No.

5,844,893 (“the ‘893 Patent”) titled “System For Coupling Host Computer Means With Base
Transceiver Units On A Local Area Network.” A copy of the ‘893 Patent is attached as Exhibit J.
29.

On December 16, 2003, the USPTO duly and legally issued U.S. Patent No.

6,665,536 (“the ‘536 Patent”) titled “Local Area Network Having Multiple Channel Wireless
Access.” A copy of the ‘536 Patent is attached as Exhibit K.
30.

On February 24, 2004, the USPTO duly and legally issued U.S. Patent No.

6,697,415 (“the ‘415 Patent”) titled “Spread Spectrum Transceiver Module Utilizing Multiple
Mode Transmission.” A copy of the ‘415 Patent is attached as Exhibit L.
31.

On March 14, 2006, the USPTO duly and legally issued U.S. Patent No.

7,013,138 (“the ‘138 Patent”) titled “Local Area Network Having Multiple Channel Wireless
Access.” A copy of the ‘138 Patent is attached as Exhibit M.
32.

On May 4, 2010, the USPTO duly and legally issued U.S. Patent No. 7,710,907

(“the ‘907 Patent”) titled “Local Area Network Having Multiple Channel Wireless Access.” A
copy of the ‘907 Patent is attached as Exhibit N.
33.

On March 29, 2011, the USPTO duly and legally issued U.S. Patent No.

7,916,747 (“the ‘747 Patent”) titled “Redundant Radio Frequency Network Having A Roaming
Terminal Communication Protocol.” A copy of the ‘747 Patent is attached as Exhibit O.
34.

On January 18, 2011, the USPTO duly and legally issued U.S. Patent No.

7,873,343 (“the ‘343 Patent”) titled “Communication Network Terminal With Sleep Capability.”
A copy of the ‘343 Patent is attached as Exhibit P.

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35.

On May 19, 2009, the USPTO duly and legally issued U.S. Patent No. 7,536,167

(“the ‘167 Patent”) titled “Network Supporting Roaming, Sleeping Terminals.” A copy of the
‘167 Patent is attached as Exhibit Q.
36.

The seventeen patents identified in paragraphs 19-35 are hereinafter referred to

collectively as the “WLAN Patents.”
37.

Innovatio owns all rights, title, and interest in and to, and has standing to sue for

infringement of, the WLAN Patents, including the right to sue for and collect past damages.
COUNT ONE
INFRINGEMENT OF THE ‘559 PATENT
38.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
39.

Each of the Marriott Defendants has infringed and continues to infringe one or

more claims of the ‘559 Patent in violation of 35 U.S.C. § 271(a) by using, in this judicial district,
wireless local area network products (“WLAN Products”) to provide wireless network access to
their customers, guests, employees, and/or the public, and/or in their business operations, where
such WLAN Products practice the methods of, by way of example and not limitation, at least
claims 6, 7, and 8 of the ‘559 Patent.
COUNT TWO
INFRINGEMENT OF THE ‘002 PATENT
40.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
41.

Each of the Marriott Defendants has infringed and continues to infringe one or

more claims of the ‘002 Patent in violation of 35 U.S.C. § 271(a) by using, in this judicial district,
WLAN Products to provide wireless network access to their customers, guests, employees,

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and/or the public, and/or in their business operations, where such WLAN Products practice the
methods of, by way of example and not limitation, at least claims 14-16, 18, and 19 of the ‘002
Patent.
COUNT THREE
INFRINGEMENT OF THE ‘921 PATENT
42.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
43.

Each of the Marriott Defendants has infringed and continues to infringe one or

more claims of the ‘921 Patent in violation of 35 U.S.C. § 271(a) by using, in this judicial district,
WLAN Products to provide wireless network access to their customers, guests, employees,
and/or the public, and/or in their business operations, where such WLAN Products practice the
methods of, by way of example and not limitation, at least claims 1, 2, 5, 7, and 8 of the ‘921
Patent.
COUNT FOUR
INFRINGEMENT OF THE ‘553 PATENT
44.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
45.

Each of the Marriott Defendants has infringed and continues to infringe one or

more claims of the ‘553 Patent in violation of 35 U.S.C. § 271(a) by using, in this judicial district,
WLAN Products to provide wireless network access to their customers, guests, employees,
and/or the public, and/or in their business operations, where such WLAN Products practice the
methods of, by way of example and not limitation, at least claims 10-12, 17, 19, and 20 of the
‘553 Patent.

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COUNT FIVE
INFRINGEMENT OF THE ‘366 PATENT
46.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
47.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘366 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 5-7, 9-17, 19-24, 26-29, and 32 of
the ‘366 Patent.
COUNT SIX
INFRINGEMENT OF THE ‘771 PATENT
48.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
49.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘771 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1-7 of the ‘771 Patent.
COUNT SEVEN
INFRINGEMENT OF THE ‘311 PATENT
50.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.

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51.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘311 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 20-24, 26-30, 32-37, 39-41, 43-51,
53-56, 60, and 64 of the ‘311 Patent.
COUNT EIGHT
INFRINGEMENT OF THE ‘646 PATENT
52.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
53.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘646 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
practice the methods of, by way of example and not limitation, at least claims 14-17, 19-22, 2635, 39-40, 43-45, 47, 49-51, 53-56, 59-64, 66-69, 71-73, 79, 82-89, 91-94, 98-104, 107, 108, 111,
112, 114-123, 125-128, 130, 135-137, 143, and 144 of the ‘646 Patent.
COUNT NINE
INFRINGEMENT OF THE ‘397 PATENT
54.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.

9

55.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘397 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1-5 of the ‘397 Patent.
COUNT TEN
INFRINGEMENT OF THE ‘893 PATENT
56.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
57.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘893 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 7-11 of the ‘893 Patent.
COUNT ELEVEN
INFRINGEMENT OF THE ‘536 PATENT
58.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
59.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘536 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,

10

employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1, 5, 8, 10, 11, 13-17, 19, 20, and
49 of the ‘536 Patent.
COUNT TWELVE
INFRINGEMENT OF THE ‘415 PATENT
60.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
61.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘415 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 11, 12, and 15 of the ‘415 Patent.
COUNT THIRTEEN
INFRINGEMENT OF THE ‘138 PATENT
62.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
63.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘138 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1, 5, 8, 10, 11, 13-15, 17, 18, 21,
24, 26, 28, and 36 of the ‘138 Patent.

11

COUNT FOURTEEN
INFRINGEMENT OF THE ‘907 PATENT
64.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
65.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘907 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1, 7, 10, 12, 13, 15-17, 20, 21, 23,
24, 30, 33, 35, 36, 38, 39, 40, 43, 44, and 46-50 of the ‘907 Patent.
COUNT FIFTEEN
INFRINGEMENT OF THE ‘747 PATENT
66.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
67.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘747 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1-3, 5-8, 11, 13, 16, 17, and 20-25
of the ‘747 Patent.

12

COUNT SIXTEEN
INFRINGEMENT OF THE ‘343 PATENT
68.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
69.

Innovatio believes that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘343 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
infringe, by way of example and not limitation, at least claims 1-6, 8-12, 15-20, 22, 23, 25, 28-30,
31-36, 38-42, 45-50, 52, 53, 55, and 58-60 of the ‘343 Patent.
COUNT SEVENTEEN
INFRINGEMENT OF THE ‘167 PATENT
70.

Innovatio repeats and realleges the allegations of the preceding paragraphs 1 - 37

as if fully set forth herein.
71.

Innovatio believe that a reasonable opportunity for further investigation or

discovery will likely show that each of the Marriott Defendants has infringed and continues to
infringe one or more claims of the ‘167 Patent in violation of 35 U.S.C. § 271(a) by using, in this
judicial district, WLAN Products to provide wireless network access to their customers, guests,
employees, and/or the public, and/or in their business operations, where such WLAN Products
practice the methods of, by way of example and not limitation, at least claims 73-77, 79-83, 85,
89-97, 100, 102-107, 109-113, 115, 119-127, 130, 132-134, and 203 of the ‘167 Patent.

13

PRAYER FOR RELIEF
WHEREFORE, Innovatio respectfully requests entry of judgment in its favor and the
following relief, including:
A.

That each of the Marriott Defendants be adjudged to have infringed one or more

claims of each of the WLAN Patents;
B.

That each of the Marriott Defendants and all related entities and their officers,

agents, employees, representatives, servants, successors, assigns and all persons in active concert
or participation with any of them, directly or indirectly, be preliminarily and permanently
enjoined from using, or contributing or inducing the use of, any WLAN Product, system or
network that infringes any WLAN Patent;
C.

That each of the Marriott Defendants account for damages sustained by Innovatio

as a result of each of the Marriott Defendants’ infringement of the WLAN Patents, including
both pre- and post-judgment interest and costs as fixed by this Court under 35 U.S.C. § 284; and
D.

That the Court grant Innovatio such other and further relief as the Court may

deem just and proper.
JURY TRIAL DEMAND
Innovatio demands a trial by jury on all issues so triable.

Dated: September 19, 2011

Respectfully submitted,

/s/ Matthew G. McAndrews
Matthew G. McAndrews
Raymond P. Niro, Jr.
Brian E. Haan
Gabriel I. Opatken
NIRO, HALLER & NIRO
181 West Madison St., Suite 4600
Chicago, Illinois 60602

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Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Plaintiff,
INNOVATIO IP VENTURES, LLC

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