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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WALKER DIGITAL, LLC Plaintiff, v. GOOGLE INC. Defendant. Civil Action No. ___________ JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT 1. Plaintiff Walker Digital, LLC, (“Walker Digital”) files this complaint for patent infringement against defendant Google Inc. THE PARTIES 2. Walker Digital is a Delaware limited liability company with its principal place of business located at 2 High Ridge Park, Stamford, CT 06905. Walker Digital is a world- renowned research and development laboratory responsible for launching several successful businesses, including Priceline.com and Synapse, Inc. 3. On information and belief, defendant Google Inc. (“Google”) is a Delaware corporation with its corporate headquarters and principal place of business at 1600 Amphitheater Parkway, Mountain View, California, 94043. JURISDICTION AND VENUE 4. This action arises under the patent laws of the United States, Title 35 of the United States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 5. On information and belief, Google is subject to this Court’s jurisdiction because Google has transacted business in this district, including, more specifically, directly and/or

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Page 1: Walker Digital v Google

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

WALKER DIGITAL, LLC

Plaintiff,

v.

GOOGLE INC.

Defendant.

Civil Action No. ___________

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

1. Plaintiff Walker Digital, LLC, (“Walker Digital”) files this complaint for patent

infringement against defendant Google Inc.

THE PARTIES

2. Walker Digital is a Delaware limited liability company with its principal place of

business located at 2 High Ridge Park, Stamford, CT 06905. Walker Digital is a world-

renowned research and development laboratory responsible for launching several successful

businesses, including Priceline.com and Synapse, Inc.

3. On information and belief, defendant Google Inc. (“Google”) is a Delaware

corporation with its corporate headquarters and principal place of business at 1600 Amphitheater

Parkway, Mountain View, California, 94043.

JURISDICTION AND VENUE

4. This action arises under the patent laws of the United States, Title 35 of the

United States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and

1338(a).

5. On information and belief, Google is subject to this Court’s jurisdiction because

Google has transacted business in this district, including, more specifically, directly and/or

Page 2: Walker Digital v Google

- 2 -

through intermediaries, making, using, importing, offering for sale and/or selling products and

services in the State of Delaware (including via the provision of such goods and services over the

Internet). Google, upon information and belief, is doing substantial business in this District, and

has committed acts of patent infringement in this District. In addition, Google is a corporation

organized and existing under the laws of the State of Delaware.

6. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and (c), and 1400(b).

THE ASSERTED PATENTS

7. On June 19, 2001, the United States Patent and Trademark Office (“USPTO”)

duly and legally issued U.S. Patent No. 6,249,772 (the “‘772 patent”), entitled “Systems And

Methods Wherein A Buyer Purchases A Product At A First Price And Acquires The Product

From A Merchant That Offers The Product For Sale At A Second Price” to Jay S. Walker, James

A. Jorasch, and Andrew S. Van Luchene, who assigned their rights and interests in the ‘772

patent to Walker Digital. A true and correct copy of the ‘772 patent is attached as Exhibit A.

8. On June 22, 2004, the USPTO duly and legally issued U.S. Patent No. 6,754,636

(the “‘636 patent”), entitled “Purchasing Systems And Methods Wherein A Buyer Takes

Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.

Walker, Andrew S. Van Luchene, Magdalena Mik, and Daniel E. Tedesco, who assigned their

rights and interests in the ‘636 patent to Walker Digital. A true and correct copy of the ‘636

patent is attached as Exhibit B.

9. On May 2, 2006, the USPTO duly and legally issued U.S. Patent No. 7,039,603

(the “‘603 patent”), entitled “Settlement Systems And Methods Wherein A Buyer Takes

Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.

Walker, Jonothan Otto, Andrew S. Van Luchene, Magdalena Mik, Daniel E. Tedesco, and Ian

Page 3: Walker Digital v Google

- 3 -

Levitan, who assigned their rights and interests in the ‘603 patent to Walker Digital. A true and

correct copy of the ‘603 patent is attached as Exhibit C.

10. On March 30, 2010, the USPTO duly and legally issued U.S. Patent No.

7,689,468 (the “‘468 patent”), entitled “Purchasing, Redemption And Settlement Systems And

Methods Wherein A Buyer Takes Possession At A Retailer Of A Product Purchased Using A

Communication Network,” to Jay S. Walker, Andrew S. Van Luchne, Magdalena M. Fincham,

and Daniel E. Tedesco, who assigned their rights and interests in the ‘468 patent to Walker

Digital. A true and correct copy of the ‘468 patent is attached as Exhibit D.

11. Walker Digital is the owner of the ‘772, ‘636, ‘603 and ‘468 patents (collectively,

the “Asserted Patents”).

FACTUAL BACKGROUND

12. Walker Digital is a research and development laboratory that has invested many

millions of dollars in its intellectual property. Walker Digital is comprised of a diverse group of

inventors who solve business problems by analyzing human behavior and designing innovative

solutions incorporating modern information technologies. The novel inventions developed by

the Walker Digital team are reflected in a portfolio of more than 200 U.S. and international

patents in a wide range of industries that includes retail, vending, credit cards, security, gaming,

educational testing, and entertainment.

13. Jay S. Walker, the chairman of Walker Digital, is a named inventor of more than

450 issued and pending U.S. and international patents, including each of the Asserted Patents.

Mr. Walker is best known as the founder of Priceline.com, which revolutionized the travel

industry through unprecedented technology, with the end result of bringing huge savings in

airfare, hotel and car rental rates, and other travel related goods and services to every-day

Page 4: Walker Digital v Google

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consumers. The systems at the heart of Priceline.com’s success were developed in the research

and development laboratory of Walker Digital.

14. Development of the inventions conceived by Mr. Walker and the Walker Digital

team of inventors would not have been possible without substantial financial investments made

by Walker Digital. Funds invested by Walker Digital have been used for many things, including

the construction of laboratory facilities utilized to develop and test new inventions. Many of the

inventions developed at the Walker Digital laboratories have led to successful businesses,

including Priceline.com and Synapse, Inc. Revolutionary technologies, including the systems

and methods for purchasing a product online at a first price and acquiring the product from a

merchant that offers the product for sale at a second price, as described and claimed in the

Asserted Patents, were a direct result of investments made by Walker Digital.

15. The Asserted Patents represent breakthroughs in the field of electronic commerce.

COUNT I

(Infringement of the ‘772)

16. Walker Digital incorporates and realleges the allegations of paragraphs 1-15 as

are fully set forth above.

17. Upon information and belief, Google is infringing (literally and/or under the

doctrine of equivalents) the ‘772 patent in this District and throughout the United States by,

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

services on its Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘772 patent. For instance, upon information and belief, Google

offers buyers products and services from retailers at discounted prices and arranges for users to

take possession of the goods or services at the retailers’ locations. An sample of a Google

offering is provided below:

Page 5: Walker Digital v Google

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18. Google committed its acts of infringement without license or authorization.

19. As a result of Google’s infringement of the ‘772 patent, Walker Digital has

suffered monetary damages in an amount not yet determined, and will continue to suffer

damages in the future unless Google’s infringing activities are enjoined by this Court.

20. Walker Digital has suffered and will continue to suffer severe and irreparable

harm unless this Court issues a permanent injunction prohibiting Google, its agents, servants,

employees, representatives, and all others acting in active concert therewith from infringing the

‘772 patent.

COUNT II

(Infringement of the ‘636 Patent)

Page 6: Walker Digital v Google

- 6 -

21. Walker Digital incorporates and realleges the allegations of paragraphs 1-21 as

are fully set forth above.

22. Upon information and belief, Google is infringing (literally and/or under the

doctrine of equivalents) the ‘636 patent in this District and throughout the United States by,

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

services on its Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘636 patent.

23. Google committed its acts of infringement without license or authorization.

24. As a result of Google’s infringement of the ‘636 patent, Walker Digital has

suffered monetary damages in an amount not yet determined, and will continue to suffer

damages in the future unless Google’s infringing activities are enjoined by this Court.

25. Walker Digital has suffered and will continue to suffer severe and irreparable

harm unless this Court issues a permanent injunction prohibiting Google, its agents, servants,

employees, representatives, and all others acting in active concert therewith from infringing the

‘636 patent.

COUNT III

(Infringement of the ‘603 Patent)

26. Walker Digital incorporates and realleges the allegations of paragraphs 1-25 as

are fully set forth above.

27. Upon information and belief, Google is infringing (literally and/or under the

doctrine of equivalents) the ‘603 patent in this District and throughout the United States by,

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

services on Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘603 patent.

Page 7: Walker Digital v Google

- 7 -

28. Google committed its acts of infringement without license or authorization.

29. As a result of Google’s infringement of the ‘603 patent, Walker Digital has

suffered monetary damages in an amount not yet determined, and will continue to suffer

damages in the future unless Google’s infringing activities are enjoined by this Court.

30. Walker Digital has suffered and will continue to suffer severe and irreparable

harm unless this Court issues a permanent injunction prohibiting Google, its agents, servants,

employees, representatives, and all others acting in active concert therewith from infringing the

‘603 patent.

COUNT IV

(Infringement of the ‘468 Patent)

31. Walker Digital incorporates and realleges the allegations of paragraphs 1-30 as

are fully set forth above.

32. Upon information and belief, Google is infringing (literally and/or under the

doctrine of equivalents) the ‘468 patent in this District and throughout the United States by,

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

services on its Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘468 patent.

33. Google committed its acts of infringement without license or authorization.

34. As a result of Google’s infringement of the ‘468 patent, Walker Digital has

suffered monetary damages in an amount not yet determined, and will continue to suffer

damages in the future unless Google’s infringing activities are enjoined by this Court.

35. Walker Digital has suffered and will continue to suffer severe and irreparable

harm unless this Court issues a permanent injunction prohibiting Google, its agents, servants,

Page 8: Walker Digital v Google

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employees, representatives, and all others acting in active concert therewith from infringing the

‘468 patent.

DEMAND FOR JURY TRIAL

Plaintiff Walker Digital, under Rule 38 of the Federal Rules of Civil Procedure, requests

a trial by jury of any issues so triable by right.

PRAYER FOR RELIEF

For the above reasons, Walker Digital respectfully requests that this Court grant the

following relief in favor of Walker Digital and against Google:

(a) A judgment in favor of Walker Digital that Google has directly infringed (either

literally or under the doctrine of equivalents) one or more claims of each of the Asserted Patents;

(b) A permanent injunction enjoining Google and its officers, directors, agents,

servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in

active concert or participation with them, from infringing each of the Asserted Patents;

(c) A judgment and order requiring Google to pay Walker Digital its damages, costs,

expenses, and pre-judgment and post-judgment interest for Google’s infringement of each of the

Asserted Patents;

(d) A judgment and order requiring Google to provide an accounting and to pay

supplemental damages to Walker Digital, including, without limitation, pre-judgment interest;

(e) A judgment and order finding that this is an exceptional case within the meaning

of 35 U.S.C. § 285 and awarding Walker Digital its reasonable attorneys’ fees; and

(f) Any and all such other relief as the Court deems just and proper.

Page 9: Walker Digital v Google

- 9 -

April 21, 2011

Of Counsel:

Marc A. Fenster

California Bar No. 181067

RUSS, AUGUST & KABAT

12424 Wilshire Boulevard 12th Floor

Los Angeles, California 90025

Telephone: 310/826-7474

Facsimile: 310/826-6991

[email protected]

BAYARD, P.A.

/s/ Richard D. Kirk

Richard D. Kirk (rk0922)

Stephen B. Brauerman (sb4952)

222 Delaware Avenue, Suite 900

P.O. Box 25130

Wilmington, DE 19899

[email protected]

[email protected]

(302) 655-5000

Attorneys for Plaintiff Walker Digital, LLC

Page 10: Walker Digital v Google

CIVIL COVER SHEET The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required

by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the

use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I.(a) PLAINTIFF DEFENDANTS

WALKER DIGITAL, LLC

GOOGLE, INC.

(b) County Of Residence Of First Listed Plaintiff Fairfield County, Connecticut County Of Residence Of First Listed Defendant New Castle County, Delaware

(c) Attorneys (Firm Name, Address And Telephone Number) Attorneys (If Known)

Richard D. Kirk (No. 0922) Stephen Brauerman (No. 4952) Bayard, P.A. 222 Delaware Avenue, Suite 900 Wilmington, DE 19899-5130 (302) 655-5000

CITIZENSHIP OF PRINCIPAL PARTIES (Place An 'X' In One Box For Plaintiff

(For Diversity Cases Only) And One Box For Defendant) II. BASIS OF JURISDICTION (PLACE AN "X" IN ONE BOX

ONLY) III.

PTF DEF PTF DEF

1

U.S. Government

Plaintiff

3

Federal Question

(U.S. Government Not a Party) Citizen of This State 1 1

Incorporated or Principal Place

of Business in this State 4 4

Citizen of Another State 2 2

Incorporated and Principal Place

of Business in Another State 5 5

2

U.S. Government

Defendant

4 Diversity

(Indicate Citizenship of Parties

in Item III)

Citizen or Subject of a

Foreign Country

3 3 Foreign Nation 6 6

IV. NATURE OF SUIT PLACE AN "X" IN ONE BOX ONLY)

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

422 Appeal 28 USC 158

423 Withdrawal

28 USC 157

PROPERTY RIGHTS

610 Agriculture

620 Other Food & Drug

625 Drug Related Seizure

of Property 21 USC 881

630 Liquor Laws

640 RR & Truck

650 Airline Regs

660 Occupational

Safety/Health

690 Other

820 Copyrights

830 Patent

840 Trademark

LABOR SOCIAL SECURITY

110 Insurance

120 Marine

130 Miller Act

140 Negotiable Instrument

150 Recovery of Overpayment

& Enforcement of Judgment

151 Medicare Act

152 Recovery of Defaulted

Student Loans

(Excl. Veterans)

153 Recovery of Overpayment

of Veteran’s Benefits

160 Stockholders’ Suits

190 Other Contract

195 Contract Property Liability

PERSONAL INJURY

310 Airplane

315 Airplane Product

Liability

320 Assault, Libel &

Slander

330 Federal Employers’

Liability

340 Marine

345 Marine Product

Liability

350 Motor Vehicle

355 Motor Vehicle

Product Liability

360 Other Personal Injury

PERSONAL INJURY

362 Personal Injury

Med. Malpractice

365 Personal Injury

Product Liability

368 Asbestos Personal

Injury Product Liability

PERSONAL PROPERTY

370 Other Fraud

371 Truth in Lending

380 Other Personal

Property Damage

385 Property Damage

Product Liability

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS

861 HIA (1395ff)

862 Black Lung (923)

863 DIWC/DIWW

(405(g))

864 SSID Title XVI

865 RSI (405(g)

FEDERAL TAX SUITS

210 Land Condemnation

220 Foreclosure

230 Rent Lease & Ejectment

240 Torts to Land

245 Tort Product Liability

290 All Other Real Property

441 Voting

442 Employment

443 Housing/

Accommodations

444 Welfare

440 Other Civil Rights

510 Motions to Vacate

Sentence

HABEUS CORPUS:

530 General

535 Death Penalty

540 Mandamus & Other

550 Civil Rights

555 Prison Condition

710 Fair Labor Standards

Act

720 Labor/Mgmt Relations

730 Labor/Mgmt Reporting

& Disclosure Act

740 Railway Labor Act

790 Other Labor Litigation

791 Empl Ref Inc

Security Act 870 Taxes (U.S. Plaintiff

or Defendant)

871 IRS Third Party

26 USC 7609

400 State Reapportionment

410 Antitrust

420 Banks and Banking

450 Commerce/ICC Rates/etc.

460 Deportation

470 Racketeer Influenced and

Corrupt Organizations

810 Selective Service

850 Securities/Commodities/

Exchange

875 Customer Challenge

12 USC 3410

891 Agricultural Acts

892 Economic Stabilization Act

893 Environmental Matters

894 Energy Allocation Act

895 Freedom of I

Information Act

900 Appeal of Fee Determination

Under Equal Access to

Justice

950 Constitutionality of

State Statutes

890 Other Statutory Actions

V. ORIGIN

1 Original

Proceeding

2 Removed from

State Court

3 Remanded from

State Court

4 Reinstated or

Reopened

5 Transferred from

another district

(specify)

6 Multidistrict

Litigation

7

Appeal to

District

Judge from

Magistrate

Judgment (Cite The U.S. Civil Statute Under Which You Are Filing And Write Brief Statement Of Cause. VI. CAUSE OF ACTION

Do Not Cite Jurisdictional Statutes Unless Diversity)

Action for patent infringement under 35 U.S.C. § 101, et seq. injunctive and declaratory relief and for damages for patent infringement

CHECK IF THIS IS A CLASS ACTION

DEMAND $ VII. REQUESTED IN

COMPLAINT UNDER F.R.C..P. 23

CHECK YES only if demanded in complaint

JURY DEMAND: YES NO

VIII. RELATED CASE(S) (See instructions)

JUDGE

Sue L. Robinson DOCKET

NUMBERS 11-317-SLR DATE SIGNATURE OF ATTORNEY OF RECORD

APRIL 21, 2011 /S/ RICHARD D. KIRK (RK0922)

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Page 11: Walker Digital v Google

AO 120 (Rev. 08/10)

TO:Mail Stop 8

Director of the U.S. Patent and Trademark Office

P.O. Box 1450

Alexandria, VA 22313-1450

REPORT ON THE

FILING OR DETERMINATION OF AN

ACTION REGARDING A PATENT OR

TRADEMARK

In Compliance with 35 U.S.C. § 290 and/or 15 U.S.C. § 1116 you are hereby advised that a court action has been

filed in the U.S. District Court on the following

G Trademarks or G Patents. ( G the patent action involves 35 U.S.C. § 292.):

DOCKET NO. DATE FILED U.S. DISTRICT COURT

PLAINTIFF DEFENDANT

PATENT OR

TRADEMARK NO.

DATE OF PATENT

OR TRADEMARKHOLDER OF PATENT OR TRADEMARK

1

2

3

4

5

In the above—entitled case, the following patent(s)/ trademark(s) have been included:

DATE INCLUDED INCLUDED BY

G Amendment G Answer G Cross Bill G Other Pleading

PATENT OR

TRADEMARK NO.

DATE OF PATENT

OR TRADEMARKHOLDER OF PATENT OR TRADEMARK

1

2

3

4

5

In the above—entitled case, the following decision has been rendered or judgement issued:

DECISION/JUDGEMENT

CLERK (BY) DEPUTY CLERK DATE

Copy 1—Upon initiation of action, mail this copy to Director Copy 3—Upon termination of action, mail this copy to Director

Copy 2—Upon filing document adding patent(s), mail this copy to Director Copy 4—Case file copy

for the District of Delaware

4/21/2011 for the District of Delaware

Walker Digital, LLC Google, Inc.

6,249,772 6/19/2001 Walker Digital, LLC

6,754,636 6/22/2004 Walker Digital, LLC

7,039,603 5/2/2006 Walker Digital, LLC

7,689,468 3/30/2010 Walker Digital, LLC

Page 12: Walker Digital v Google

AO 440 (Rev. 12/09) Summons in a Civil Action

United States District Court

for the

District of Delaware

WALKER DIGITAL, LLC

Plaintiff, v. GOOGLE, INC., Defendant.

Civil Action No. TRIAL BY JURY DEMANDED

Summons in a Civil Action

To: Google, Inc. c/o The Corporation Trust Company 1209 Orange Street Wilmington, DE 19801

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received

it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:

Richard D. Kirk Stephen B. Brauerman Bayard, P.A. 222 Delaware Avenue, Suite 900 Wilmington, Delaware 19801 302-655-5000 (phone)

302-658-6395 (fax)

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. DATE DEPUTY CLERK’S SIGNATURE

Page 13: Walker Digital v Google

AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 4(1))

This summons for (name of individual and title, if any) ______________________________________

was received by me on (date) _________________.

I personally served the summons on the individual at (place) __________________________

___________________________________________________ on (date) _______________________; or

I left the summons at the individual’s residence or usual place of abode with (name) ___

_________________________________________________________, a person of suitable age and

discretion who resides there, on (date) ____________________, and mailed a copy to the

individual’s last known address; or

I served the summons on (name of individual) ___________________________________, who is

designated by law to accept service of process on behalf of (name of organization)

_______________________________________________ on (date) ______________________; or

I returned the summons unexecuted because _______________________________; or Other (specify):

My fees are $ ________ for travel and $ ________ for services, for a total of $ ________.

I declare under penalty of perjury that this information is true.

Date: ___________________ ____________________________________

Server’s signature

____________________________________ Printed name and title

____________________________________

Server’s address

Additional information regarding attempted service, etc:

Page 14: Walker Digital v Google

Complaints

U.S. District Court

District of Delaware

Notice of Electronic Filing The following transaction was entered by Kirk, Richard on 4/21/2011 at 11:46 PM EDT and filed on 4/21/2011

Docket Text: COMPLAINT - Walker Digital, LLC v. Google, Inc.. Filing fee $ 350, receipt number 0311-879254. (Attachments: # (1) Exhibit A (Part I), # (2) Exhibit A (Part II), # (3) Exhibit B (Part I), # (4) Exhibit B (Part II), # (5) Exhibit B (Part III), # (6) Exhibit C (Part I), # (7) Exhibit C (Part II), # (8) Exhibit C (Part III), # (9) Exhibit D (Part I), # (10) Exhibit D (Part II), # (11) Exhibit D (Part III), # (12) Exhibit D (Part IV), # (13) Exhibit D (Part V), # (14) Exhibit D (Part VI), # (15) Exhibit D (Part VII), # (16) Exhibit D (Part VIII), # (17) Civil Cover Sheet, # (18) Patent/Trademark Report, # (19) Summons Forms - Unsigned Google, Inc.)(Kirk, Richard)

1:99-mc-09999 Notice has been electronically mailed to: 1:99-mc-09999 Notice has been delivered by other means to:

The following document(s) are associated with this transaction:

1:99-mc-09999 Plaintiff(s) v. Defendant(s)

Case Name: Plaintiff(s) v. Defendant(s)

Case Number: 1:99-mc-09999

Filer:

Document Number:175

Document description:Main Document Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1079733196 [Date=4/21/2011] [FileNumber=1187989-0 ] [b0dba0fec0a9063c1e24b281851e502e18293e3951f267ea8d51882e6c0740f9a69 12a85c768c856573bb9f5137240a120ae5184d663017220863cf499bbe153]] Document description:Exhibit A (Part I) Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1079733196 [Date=4/21/2011] [FileNumber=1187989-1 ] [2187d0260b2d9276c02a7bb548d1fa15b6eb76ce90ee6f1d5226aa7230d1c1e6808 316affdf8ee3b494e6b009230aa4f4fd6b17edd27dd35f51a7c624b85179a]] Document description:Exhibit A (Part II) Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1079733196 [Date=4/21/2011] [FileNumber=1187989-2 ] [bb431a0bbb765b705a9f28490a993101cf59782e2cea85f980499f2213b8ee7ea09 ab20cafbedb40289ead2fe21ed7f9d87f46c0f789d3a1fd1dc91e97634406]] Document description:Exhibit B (Part I) Original filename:n/a Electronic document Stamp:

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