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COMPLAINT FOR PATENT INFRINGEMENT
QUINN EMANUEL URQUHART & SULLIVAN, LLP
Frederick A. Lorig (Bar No. 057645)
Iredlorig(quinnemanuel.com
Steven M. Anderson (Bar No. 144014)
stevenanderson(quinnemanuel.com
Christopher A. Mathews (Bar No. 144021)
chrismathews(quinnemanuel.com
865 South Figueroa Street, 10th Floor
Los Angeles, CaliIornia 90017-2543
Telephone: (213) 443-3000
Facsimile: (213) 443-3100
Attorneys Ior PlaintiII
PACKETVIDEO CORPORATION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
PACKETVIDEO CORPORATION, a Delaware
corporation,
PlaintiII,
v.
SPOTIFY USA INC., a Delaware corporation,
SPOTIFY LIMITED, a United Kingdom
corporation, and SPOTIFY TECHNOLOGY
SARL, a Luxembourg corporation,
DeIendants.
CASE NO.
COMPLAINT FOR PATENT
INFRINGEMENT
DEMAND FOR JURY TRIAL
COMPLAINT
PlaintiII PacketVideo Corporation ("PacketVideo") Ior its complaint against DeIendants
SpotiIy USA Inc. ("SpotiIy USA"): SpotiIy Limited ("SpotiIy UK") and SpotiIy Technology
SARL ("SpotiIy Lux") (all collectively "DeIendants"), hereby demands a iury trial and alleges as
Iollows:
'11CV1659 WMc IEG
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 1 of 11
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-2-
COMPLAINT FOR PATENT INFRINGEMENT
1urisdiction and Venue
1. This Court has iurisdiction over the subiect matter oI this action under 28 U.S.C.
1331 and 1338(a).
2. Venue is established in this iudicial district pursuant to 28 U.S.C. 1391(b), (c),
(d) and 1400(b). DeIendants have committed acts oI inIringement in this iudicial district: and
DeIendants SpotiIy UK and SpotiIy Lux are alien companies.
Nature of the Action
3. This is a civil action Ior inIringement oI United States Patent No. 5,636,276 (the
"Patent-in-Suit" or "'276 Patent"). This action is based upon the Patent Laws oI the United States,
35 U.S.C. 100 et seq.
Parties
4. PlaintiII PacketVideo Corporation ("PacketVideo") is a corporation organized
under the laws oI the state oI Delaware, having its principal place oI business at 10350 Science
Center Drive, San Diego, CA 92121.
5. On inIormation and belieI, DeIendant SpotiIy USA is incorporated under the laws
oI the state oI Delaware, having its principal place oI business at 76 9th Avenue, Suite 1110, 11th
Floor, New York, NY 10011. On inIormation and belieI, SpotiIy products accused oI
inIringement in this Complaint are and have been oIIered Ior sale, sold, and imported by SpotiIy
USA in this and other iudicial districts.
6. On inIormation and belieI, DeIendant SpotiIy UK is incorporated under the laws oI
the United Kingdom, having its principal place oI business at Golden House, 30 Great Pulteney
Street, London W1F 9NN, United Kingdom. On inIormation and belieI, SpotiIy UK
manuIactures, distributes, and imports the products alleged to inIringe herein in this and other
iudicial districts.
7. On inIormation and belieI, DeIendant SpotiIy Lux is incorporated under the laws oI
Luxembourg, having its principal place oI business at Avenue Marie-Therese 22, 2132
Luxembourg, Luxembourg. On inIormation and belieI, SpotiIy Lux manuIactures, distributes, and
imports the products alleged to inIringe herein in this and other iudicial districts.
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 2 of 11
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COMPLAINT FOR PATENT INFRINGEMENT
8. Upon inIormation and belieI, at all relevant times mentioned in this Complaint,
DeIendants, and each oI them, were the agents oI each other, and in doing the things alleged
herein, each was acting within the scope and course oI its agency and authority and was subiect to
and under the supervision oI its co-deIendants as co-conspirators.
9. On inIormation and belieI, DeIendants are subiect to this Court's personal
iurisdiction because they have conducted and do conduct business within this district. DeIendants,
including through intermediaries, (including, distributors, retailers, partners, subsidiaries and
others), make, manuIacture, ship, distribute, oIIer Ior sale, sell, advertise, and use their products
and services in the United States, including this district, through which they derive substantial
revenue. Personal iurisdiction exists speciIically over DeIendants because oI their inIringing
conduct within and directed at citizens in this district, including by virtue oI at least their website
(www.spotiIy.com) that actively reaches out to citizens in the Southern District oI CaliIornia and
oIIers DeIendants' inIringing products. These inIringing products have been and continue to be
used in this district. DeIendants have committed patent inIringement within this district.
Background Facts and the Patent-in-Suit
10. Founded in 1998, PacketVideo is a San Diego-based company that produces
soItware that allows the user to enioy wireless music and video. PacketVideo oIIers everything
Irom browsing Ior, recommendation oI, and discovery oI music and video, to the purchase,
playback and sharing oI music and video. The company's soItware supports all maior media
Iormats, broadcast standards, home networking protocols, operating systems and handsets/mobile
phones. PacketVideo's customers include mobile operators such as Verizon Wireless, NTT
DoCoMo and Orange, handset manuIacturers, and consumer electronics companies.
PacketVideo`s soItware is currently embedded in more than 260 million devices worldwide and
more than 320 diIIerent products.
11. PacketVideo's soItware products Iorm the Ioundation Ior audience-interactive
media experiences that give consumers the Ireedom to enioy multimedia content however,
whenever and wherever they want.
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 3 of 11
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-4-
COMPLAINT FOR PATENT INFRINGEMENT
12. DeIendants oIIer a music streaming service called SpotiIy, Iound at
www.spotiIy.com. The SpotiIy service provides streaming oI selected music Irom a range oI
record labels (e.g.. Sony, Warner, Universal, EMI). The SpotiIy service enables users to access
music available through the service. SpeciIically, the SpotiIy servers enable users to browse by,
Ior example, artist, album, record label, genre or playlist. The service is presently only available in
the United States, and in certain countries oI Europe. The system is currently accessible using
diIIerent computer soItware operating systems and mobile operating systems.
13. On June 3, 1997, the United States Patent and Trademark OIIice ("USPTO") issued
the '276 Patent to RolI Brugger Ior his invention entitled "Device Ior the Distribution oI Music in
Digital Form." PacketVideo is the exclusive and current owner oI all right, title, and interest in
and to the '276 Patent, including the right to bring this suit Ior iniunctive relieI and damages.
COUNT I
(Patent Infringement Against Spotify USA)
14. Paragraphs 1 through 13 are incorporated by reIerence as iI stated Iully herein.
15. The '276 Patent is valid and enIorceable.
16. At least as early as May 11, 2011, when PacketVideo brought the '276 Patent to
DeIendants' attention, DeIendants have had actual knowledge oI both PacketVideo's rights in the
'276 Patent and the details oI DeIendants' inIringement oI the '276 Patent. Nevertheless, SpotiIy
USA has oIIered Ior sale, sold, and imported products and/or services conIigured to inIringe the
'276 Patent, and instructed and encouraged others to use the '276 Patent in an inIringing manner.
17. With knowledge oI the '276 Patent, and intent to encourage others to perIorm acts
that SpotiIy USA knew inIringed the '276 Patent, SpotiIy USA has inIringed and is currently
inIringing the '276 Patent by making, using, selling, oIIering Ior sale, and/or importing into the
United States, without authority, products or services that are covered by one or more claims oI
the '276 Patent, including claim 1, including but not limited to DeIendants' inIringing music
streaming system and services, including Ior their SpotiIy system and service.
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 4 of 11
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-5-
COMPLAINT FOR PATENT INFRINGEMENT
18. With knowledge oI the '276 Patent, SpotiIy USA have contributed to and/or
induced, and will continue to contribute to and/or induce the inIringement oI the '276 Patent by
others in this District and elsewhere in the United States, by selling, oIIering Ior sale, advertising,
leasing, oIIering to lease, instructing and/or importing into the United States, without authority,
with the direct inIringement being accomplished by end users oI at least the Ioregoing products
and/or services.
19. SpotiIy USA is not licensed or otherwise authorized by PacketVideo to practice,
contributorily practice and/or induce third parties to practice the claims oI the '276 Patent.
20. By reason oI SpotiIy USA's inIringing activities, PacketVideo has suIIered, and
will continue to suIIer, substantial damages in an amount to be proven at trial, but in no event less
than a reasonable royalty.
21. SpotiIy USA's continuing acts oI inIringement are irreparably harming and causing
damage to PacketVideo, Ior which PacketVideo has no adequate remedy at law, and will continue
to suIIer such irreparable iniury unless DeIendants' continuing acts oI inIringement are enioined
by the Court. The hardships that would be imposed by an iniunction are less than those Iaced by
PacketVideo should an iniunction not issue. The public interest would be served by issuance oI an
iniunction.
22. SpotiIy USA's inIringement oI the '276 Patent has been and continues to be willIul
and deliberate, iustiIying a trebling oI damages under 35 U.S.C. 284.
23. SpotiIy USA's inIringement oI the '276 Patent is exceptional and entitles
PacketVideo to attorneys' Iees and costs incurred in prosecuting this action under 35 U.S.C. 285.
COUNT II
(Patent Infringement Against Spotify UK)
24. Paragraphs 1 through 23 are incorporated by reIerence as iI stated Iully herein.
25. The '276 Patent is valid and enIorceable.
26. At least as early as May 11, 2011, when PacketVideo brought the '276 Patent to
DeIendants' attention, DeIendants have had actual knowledge oI both PacketVideo's rights in the
'276 Patent and the details oI DeIendants' inIringement oI the '276 Patent. Nevertheless, SpotiIy
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 5 of 11
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-6-
COMPLAINT FOR PATENT INFRINGEMENT
UK has distributed and imported products and/or services conIigured to inIringe the '276 Patent,
and instructed and encouraged others to use the '276 Patent in an inIringing manner.
27. With knowledge oI the '276 Patent, and intent to encourage others to perIorm acts
that SpotiIy UK knew inIringed the '276 Patent, SpotiIy UK has inIringed and is currently
inIringing the '276 Patent by making, using, selling, oIIering Ior sale, and/or importing into the
United States, without authority, products or services that are covered by one or more claims oI
the '276 Patent, including claim 1, including but not limited to DeIendants' inIringing music
streaming system and services, including their SpotiIy system and service.
28. With knowledge oI the '276 Patent, SpotiIy UK have contributed to and/or induced,
and will continue to contribute to and/or induce the inIringement oI the '276 Patent by others in
this District and elsewhere in the United States, by selling, oIIering Ior sale, advertising, leasing,
oIIering to lease, instructing and/or importing into the United States, without authority, with the
direct inIringement being accomplished by end users oI at least the Ioregoing products and/or
services.
29. SpotiIy UK is not licensed or otherwise authorized by PacketVideo to practice,
contributorily practice and/or induce third parties to practice the claims oI the '276 Patent.
30. By reason oI SpotiIy UK's inIringing activities, PacketVideo has suIIered, and will
continue to suIIer, substantial damages in an amount to be proven at trial, but in no event less than
a reasonable royalty.
31. SpotiIy UK's continuing acts oI inIringement are irreparably harming and causing
damage to PacketVideo, Ior which PacketVideo has no adequate remedy at law, and will continue
to suIIer such irreparable iniury unless DeIendants' continuing acts oI inIringement are enioined
by the Court. The hardships that would be imposed by an iniunction are less than those Iaced by
PacketVideo should an iniunction not issue. The public interest would be served by issuance oI an
iniunction.
32. SpotiIy UK's inIringement oI the '276 Patent has been and continues to be willIul
and deliberate, iustiIying a trebling oI damages under 35 U.S.C. 284.
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 6 of 11
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-7-
COMPLAINT FOR PATENT INFRINGEMENT
33. SpotiIy UK's inIringement oI the '276 Patent is exceptional and entitles
PacketVideo to attorneys' Iees and costs incurred in prosecuting this action under 35 U.S.C. 285.
COUNT III
(Patent Infringement Against Spotify Lux)
34. Paragraphs 1 through 33 are incorporated by reIerence as iI stated Iully herein.
35. The '276 Patent is valid and enIorceable.
36. At least as early as May 11, 2011, when PacketVideo brought the '276 Patent to
DeIendants' attention, DeIendants have had actual knowledge oI both PacketVideo's rights in the
'276 Patent and the details oI DeIendants' inIringement oI the '276 Patent. Nevertheless, SpotiIy
Lux has distributed and imported products and/or services conIigured to inIringe the '276 Patent,
and instructed and encouraged others to use the '276 Patent in an inIringing manner.
37. With knowledge oI the '276 Patent, and intent to encourage others to perIorm acts
that SpotiIy Lux knew inIringed the '276 Patent, SpotiIy Lux has inIringed and is currently
inIringing the '276 Patent by making, using, selling, oIIering Ior sale, and/or importing into the
United States, without authority, products or services that are covered by one or more claims oI
the '276 Patent, including claim 1, including but not limited to DeIendants' inIringing music
streaming system and services, including their SpotiIy system and service.
38. With knowledge oI the '276 Patent, SpotiIy Lux have contributed to and/or
induced, and will continue to contribute to and/or induce the inIringement oI the '276 Patent by
others in this District and elsewhere in the United States, by selling, oIIering Ior sale, advertising,
leasing, oIIering to lease, instructing and/or importing into the United States, without authority,
with the direct inIringement being accomplished by end users oI at least the Ioregoing products
and/or services.
39. SpotiIy Lux is not licensed or otherwise authorized by PacketVideo to practice,
contributorily practice and/or induce third parties to practice the claims oI the '276 Patent.
40. By reason oI SpotiIy Lux's inIringing activities, PacketVideo has suIIered, and will
continue to suIIer, substantial damages in an amount to be proven at trial, but in no event less than
a reasonable royalty.
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 7 of 11
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-8-
COMPLAINT FOR PATENT INFRINGEMENT
41. SpotiIy Lux's continuing acts oI inIringement are irreparably harming and causing
damage to PacketVideo, Ior which PacketVideo has no adequate remedy at law, and will continue
to suIIer such irreparable iniury unless DeIendants' continuing acts oI inIringement are enioined
by the Court. The hardships that would be imposed by an iniunction are less than those Iaced by
PacketVideo should an iniunction not issue. The public interest would be served by issuance oI an
iniunction.
42. SpotiIy Lux's inIringement oI the '276 Patent has been and continues to be willIul
and deliberate, iustiIying a trebling oI damages under 35 U.S.C. 284.
43. SpotiIy Lux's inIringement oI the '276 Patent is exceptional and entitles
PacketVideo to attorneys' Iees and costs incurred in prosecuting this action under 35 U.S.C. 285.
PRAYER FOR RELIEF
WHEREFORE, PacketVideo respectIully requests the Iollowing relieI:
A. A iudgment holding the DeIendants liable Ior inIringement oI the Patent-in-Suit
asserted against them:
B. A permanent iniunction pursuant to 35 U.S.C. 283 against DeIendants, their
oIIicers, agents, employees, attorneys, parent and subsidiary corporations, assigns and successors
in interest, and all others acting in concert or participation with them, enioining them Irom
continued acts oI inIringement oI the Patent-in-Suit asserted against them, to the extent those
patents have not yet expired:
C. An accounting oI damages resulting Irom the DeIendants' inIringement oI the
Patent-in-Suit asserted against them, together with pre-iudgment and post-iudgment interest:
D. A iudgment holding that the DeIendants' inIringement is willIul, and a trebling oI
damages pursuant to 35 U.S.C. 284:
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 8 of 11
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-9-
COMPLAINT FOR PATENT INFRINGEMENT
E. A iudgment holding this Action to be an exceptional case, and an award to PlaintiII
PacketVideo Ior its attorneys' Iees and costs pursuant to 35 U.S.C. 285: and
F. Such other and Iurther relieI as this Court deems iust and proper.
DATED: July 27, 2010 RespectIully submitted,
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
By:
/s/ Chris Mathews
Chris Mathews
Attorneys Ior PlaintiII
PACKETVIDEO CORPORATION
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 9 of 11
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COMPLAINT FOR PATENT INFRINGEMENT
JURY TRIAL DEMANDED
PacketVideo Corporation demands a trial by iury on all issues triable oI right by a iury.
DATED: July 27, 2011 QUINN EMANUEL URQUHART &
SULLIVAN, LLP
By: /s/ Chris Mathews
Chris Mathews
Attorneys Ior PlaintiII
PACKETVIDEO CORPORATION
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 10 of 11
Federal Question
JS 44 (Rev. 12/07) 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.
I. (a) PLAINTIFFS
(b) County of Residence of First Listed Plaintiff
(EXCEPT IN U.S. PLAINTIFF CASES)
DEFENDANTS
County of Residence of First Listed Defendant
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION
1
Plaintiff
2
Defendant
3
(U.S. Government Not a Party)
4
(Indicate Citizenship of Parties in Item III)
III. CITIZENSHIP OF PRINCIPAL PARTIES
(For Diversity Cases Only)
(Place an X in One Box for Plaintiff
and One Box for Defendant)
PTF DEF PTF DEF
Citizen of This State 1 1
Citizen of Another State 2 2
Citizen or Subject of a
Foreign Country
3 3
Incorporated or Principal Place 4 4
of Business In This State
Incorporated and Principal Place
of Business In Another State
5 5
Foreign Nation 6 6
VII. CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
DEMAND $ CHECK YES only if demanded in complaint:
JURY DEMAND: Yes No
VI.
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
CONTRACT TORTS
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
153 Recovery of Overpayment
of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
330 Federal Employers'
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
CIVIL RIGHTS
441 Voting
442 Employment
443 Housing/
444 Welfare
440 Other Civil Rights
PRISONER PETITIONS
510Motion to Vacate
Sentence
Habeas Corpus:
530General
535Death Penalty
540Mandamus & other
550Civil Rights
PERSONAL INJURY
362 Personal Injury -
Med. Malpractice
365 Personal Injury -
Product Liability
368 Asbestos Personal
Injury Product
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
FORFEITURE/PENALTY
610 Agriculture
620 Other Food & Drug
625 Drug Related Seizure
of Property 2 1 USC 88 1
630 Liquor Laws
640 R.R. & Truck
650 Airline Regs.
660 Occupational
Safety/Health
690 Other
LABOR
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. Ret. Inc.
Security Act
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRS - Third Party
26 USC 7609
OTHER STATUTES
400 State Reapportionment
410 Antitrust
430 Banks and Banking
Commerce
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 Information
Act
900 Appeal of Fee
Determination Under
Equal Access to Justice
950 Constitutionality of
State Statutes
890 Other Statutory Actions
VIII.
555Prison Condition
(Place an X in One Box Only)
CAUSE OF ACTION
REQUESTED IN
RELATED CASE(S)
28 USC 157
450
COMPLAINT:
DATE
SIGNATURE OF ATTORNEY OF RECORD
Slander
(See instructions):
CSDJS44
Franchise 196
Amer. w/Disabilities -
Amer. w/Disabilities -
Consumer Credit
Cable/Sat TV
445
446
480
490
NATURE OF SUIT IV. (Place an X in One Box Only)
V.
Original
Proceeding
Removed from
State Court
Remanded from
Appellate Court
Reinstated or
Reopened another district
Transferred from
(specify)
Multidistrict
Litigation
Judge from
Magistrate
Judgment
ORIGIN (Place an X in One Box Only)
1 2 3 4 5 6 7
Brief description of cause:
JUDGE DOCKET NUMBER
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
Accommodations
Employment
Other
Injury
Liability
IMMIGRATION
Naturalization Application
Habcas Corpus -
Alien Detainee
462
463
465 Other Immigration
Actions
Appeal to District
IF ANY
PACKETVIDEO CORPORATION, a Delaware
corporation
San Diego
Christopher A. Mathews (SBN 144021)
Quinn Emanuel Urquhart & Sullivan LLP
865 South Figueroa Street, 10th Floor
Los Angeles, CA 90017
(213) 443-3000
SPOTIFY USA INC., a Delaware corporation,
SPOTIFY LIMITED, a United Kingdom
corporation, and SPOTIFY TECHNOLOGY SARL,
a Luxembourg corporation,
NY/San Diego
x
x
x
35 USC 1 et seq.
Patent infringement.
x
July 27, 2011
/s/ Christopher A. Mathews
(SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
U.S. Government
U.S. Government Diversity
(Excl. Veterans)
(405(g))
'11CV1659 WMc IEG
Case 3:11-cv-01659-IEG -WMC Document 1 Filed 07/27/11 Page 11 of 11
35:145 yeb