IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

HUAWEI TECHNOLOGIES CO., LTD.,

HUAWEI DEVICE CO., LTD., and

HUAWEI DIGITAL TECHNOLOGIES

(CHENGDU) CO., LTD.

Plaintiffs,

v.

VERIZON COMMUNICATIONS, INC.,

CELLCO PARTNERSHIP D/B/A VERIZON

WIRELESS, and VERIZON BUSINESS

NETWORK SERVICES, INC.

Defendants.

C.A. No. 6:20-CV-00090

 JURY TRIAL REQUESTED

VERIZON’S MOTION TO DISMISS CLAIMS OF INDIRECT INFRINGEMENT 

UNDER FEDERAL RULE OF CIVIL PROCEDURE 12(B)(6) 

Verizon moves to dismiss portions of the Complaint filed by Plaintiffs Huawei 

Technologies Co., Ltd., Huawei Device Co, Ltd., and Huawei Digital Technologies (Chengdu) 

Co., Ltd. (collectively “Huawei” or “Plaintiffs”) under Federal Rule of Civil Procedure 12(b)(6). 

The Complaint does not support a plausible claim for indirect infringement, for multiple 

independent reasons: (a) it fails to identify any basis for pre-suit indirect infringement as to U.S. 

Patent No. 8,761,839; (b) it fails to provide any plausible factual allegations to support the specific 

intent required for induced infringement; and (c) it fails to provide plausible factual allegations to 

support the requirements of no substantial non-infringing uses and materiality for contributory 

infringement. For these reasons, Huawei’s indirect infringement allegations should be dismissed. 

1. Statement of Facts

Plaintiffs filed their Complaint against Verizon on February 5, 2020, alleging infringement 

of U.S. Patent Nos. 7,965,709 (“the ’709 Patent”), 8,154,986 (“the ’986 Patent”), 10,027,693 (“the 

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’693 Patent”), 7,609,288 (“the ’288 Patent”), 9,521,366 (“the ’366 Patent”), 7,715,832 (“the ’832 

Patent”), and 8,761,839 (“the ’839 Patent”) (collectively, the “Asserted Patents”). The Complaint 

asserts direct infringement and indirect infringement, including both induced infringement and 

contributory infringement.

2. Legal Standard

To survive a motion to dismiss, “a complaint must contain sufficient factual matter,

accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 

662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The plausibility 

standard is not met unless the “plaintiff pleads factual content that allows the court to draw the 

reasonable inference that the defendant is liable for the misconduct alleged.” Id. Courts “are not 

bound to accept as true a legal conclusion couched as a factual allegation.” Id. Thus, “[t]hreadbare 

recitals of the elements of a cause of action, supported by mere conclusory statements, do not 

suffice.” Id. “A claim has facial plausibility when the plaintiff pleads factual content that allows 

the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”

Id. The plausibility standard “asks for more than a sheer possibility that a defendant has acted 

unlawfully.” Id.; Admiral Ins. Co. v. W. Rest Haven, Inc., No. 6:19-cv-00190-ADA-JCM, 2019 

WL 6037259, at *2 (W.D. Tex. Sept. 16, 2019) (Albright, J.); ProTradeNet, LLC v. Predictive 

Profiles, Inc., 369 F. Supp. 3d 788, 794 (W.D. Tex. 2019) (Albright, J.).

a. Induced Infringement

For claims of induced infringement, the complaint must plead facts that plausibly show the 

defendant: “(1) had actual knowledge of the patent; (2) knowingly induced a third-party to infringe

the patent; and (3) had specific intent to induce the patent infringement.” Affinity Labs of Tex., 

LLC v. Toyota Motor N. Am., No. W:13-cv-365, 2014 WL 2892285, at *2 (W.D. Tex. May 12, 

2014) (citing DSU Med. Corp. v. JMS Co., 471 F.3d 1293, 1305 (Fed. Cir. 2006)). Moreover, 

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“[t]he mere knowledge of possible infringement by others does not amount to inducement; specific 

intent and action to induce infringement must be proven.” Cleveland Clinic Found. v. True Health 

Diagnostics LLC, 859 F.3d 1352, 1364 (Fed. Cir. 2017). “There must be some showing by the 

Plaintiff of the accused infringer’s ‘taking of affirmative steps to bring about the desired result [of 

infringement].’” Iron Oak Techs., LLC v. Acer Am. Corp., No. 6:17-CV-00143-RP-JCM, 2017 

WL 9477677, at *4 (W.D. Tex. Nov. 28, 2017) (citing Global–Tech Appliances, Inc. v. SEB S.A., 

131 S. Ct. 2060, 2065 (2011)). 

b. Contributory Infringement

For claims of contributory infringement, a patentee must allege: “1) that there is direct 

infringement, 2) that the accused infringer had knowledge of the patent, 3) that the component has 

no substantial noninfringing uses, and 4) that the component is a material part of the invention.” 

Affinity Labs, 2014 WL 2892285 at *8 (internal quotation marks omitted). Additionally, “[t]o state 

a claim for contributory infringement, [] a plaintiff must, among other things, plead facts that allow 

an inference that the components sold or offered for sale have no substantial non-infringing uses.” 

In re Bill of Lading, 681 F.3d 1323, 1337 (Fed. Cir. 2012). “[S]imply mak[ing] the conclusory 

statement that defendants’ accused products are not staple articles of commerce and have no 

substantial uses that do not infringe the [Asserted Patent]” will not suffice. Iron Oak Techs., 2017 

WL 9477677, at *6.

3. The Complaint Fails to Adequately Plead Induced Infringement

The Complaint fails to set forth a plausible claim for induced infringement because it does 

not allege facts that plausibly show the defendant had specific intent to cause another to directly 

infringe and knew the other’s act constituted infringement. 

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a. The Complaint Fails to Plead Pre-Suit Knowledge of The ’839 Patent or of 

Alleged Infringement of the ’839 Patent.

Huawei concedes in its Complaint that Verizon had no pre-suit knowledge of any claim of 

infringement by Huawei on the ’839 Patent. Indeed, Huawei never raised this patent during presuit discussions between Verizon and Huawei. Compl. ¶ 35. At best, Huawei relies on postcomplaint knowledge of the ’839 Patent. Compl. ¶ 323. But allegations of post-suit knowledge 

are insufficient to establish the requisite knowledge for an inducement claim. See Aguirre v. 

Powerchute Sports, LLC, No. SA-10-CV-0702 XR, 2011 WL 2471299 at *3 (W.D. Tex. June 17, 

2011) (“To the extent [plaintiff] relies on knowledge of [plaintiff]’s patent after the lawsuit was 

filed, such knowledge is insufficient to plead the requisite knowledge for indirect infringement.”).1 

Because Huawei relies exclusively on post-filing knowledge, its induced infringement claim for 

the ’839 Patent should be dismissed. 

b. The Complaint Fails to Plead Facts Plausibly Supporting that Verizon Had 

Specific Intent to Encourage Others’ Alleged Infringement of the Asserted

Patents.

With respect to its allegations regarding induced infringement prior to Huawei filing the 

Complaint, the Complaint falls short of showing specific intent. The Complaint vaguely asserts 

that Verizon induced users to infringe, but provides no evidence that Verizon had the specific 

intent to induce users to practice the asserted claims. 

 

1

 See also Xpoint Techs., Inc. v. Microsoft Corp., 730 F. Supp. 2d 349, 357 (D. Del.

2010) (dismissing claims of indirect infringement because “knowledge after filing of the present 

action is not sufficient for pleading the requisite knowledge for indirect 

infringement”); Mallinckrodt, Inc. v. E–Z–Em Inc., 670 F. Supp. 2d 349, 354 n. 1 (D. Del.

2009) (“The Court is not persuaded by Plaintiffs’ contention that the requisite knowledge can be 

established by the filing of Plaintiff's Complaint.”); Medsquire, LLC v. Compulink Bus. Sys., Inc., 

No. CV 2:11-10122 (JHN) (PLAx), 2012 WL 13012704, at *3 (C.D. Cal. May 16, 2012); 

Brandywine Commc'ns Techs., LLC v. Casio Computer Co., 912 F. Supp. 2d 1338, 1345 (M.D. 

Fla. 2012) (“The weight of authority addressing the knowledge required for indirect infringement, 

especially following the Supreme Court's decision in Global–Tech, requires a plaintiff to allege

that defendant had pre-suit knowledge of the patents-in-suit.”).

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Simply pleading that a defendant advertises or promotes its products generally is not 

sufficient. Pleading specific intent is a “demanding” requirement not satisfied by “unsubstantiated 

assertions.” Affinity Labs, 2014 WL 2892285, at *7. “Conclusory allegations, or legal conclusions 

masquerading as factual conclusions, will not suffice to prevent a motion to dismiss.” Iron Oak 

Techs., 2017 WL 9477677, at *6. Rather, courts require the identification of a “particular 

statement or material” suggesting specific intent. Dodots Licensing Sols. LLC v. Lenovo Holding 

Co., No. CV 18-098 (MN), 2018 WL 6629709, at *4 (D. Del. Dec. 19, 2018). Plaintiffs must point 

to advertising or promotional materials that “track the asserted patents” to support specific intent 

to induce infringement. Memory Integrity LLC v. Intel Corp., 144 F. Supp. 3d 1185, 1195 (D. Or. 

2015). 

Here, the Complaint falls far short of these requirements. Regarding the ’709 and ’986 

Patents, the Complaint alleges no facts, nor support, that suggest any connection between Verizon

and end users or customers to encourage them to even use the accused products2in any particular 

way, much less a specific intent to encourage acts of infringement. See Compl. ¶¶ 76-81, 137-

145. 

For the’288, ’832, ’366, ’693, and ‘839 Patents, the Complaint generally alleges that 

Verizon induces others to infringe by “encouraging, advertising (including by internet websites, 

television, store displays, print advertisements, etc.), promoting, and instructing others to use 

and/or how to” operate the accused products, and cites some advertising and promotional

materials. See Compl. ¶¶ 176, 215, 261, 289, 321. Specifically, as to the ’288 Patent, the 

Complaint cites a high-level brochure (a 2-page PDF) describing features of Cisco WebEx 

Verizon. Id. ¶ 215. For the ’832 Patent, the Complaint cites two web pages merely identifying 

 

2 The EFP products in connection with the ’709 Patent and the Cisco Convergence Products 

and the Juniper Convergence Products in connection with the ’986 Patent.

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features of Verizon Smart Family Service. See id. ¶ 289 (referring to “the web pages above”). For 

the ’366 Patent, the Complaint cites a general Verizon webpage for Cisco WebEx Verizon. See 

id. ¶ 261. For the ’693 Patent, the Complaint cites websites and press releases generally describing 

cloud-based security services. See id. ¶ 176. And for the ‘839 Patent, the Complaint cites two 

YouTube videos. See id. ¶¶ 309, 315.3

However, those materials, at most, show how the accused products work, not how to use 

the accused products to allegedly infringe, and therefore cannot support an allegation of induced 

infringement. See Memory Integrity, 144 F. Supp. 3d at 1196 (“[T]he quotations do not teach how 

to use [the defendant’s] products to infringe [the plaintiff’s] patents, but simply describe how [the 

defendant’s] products work.”); Dodots Licensing Sols. LLC, 2018 WL 6629709, at *4 (“Although 

Plaintiff cites Defendants’ website as support for its allegation, it does so generically and does not 

identify any particular statement or material that plausibly suggests Defendants intend to induce 

infringement of the Patents-in-Suit.”); IP Commc’ns Sols., LLC v. Viber Media (USA) Inc., No. 

CV 16-134-GMS, 2017 WL 1312942, at *4 (D. Del. Apr. 5, 2017) (Plaintiff “only provides 

examples of webpages that relate to [defendant’s] application and customers' interaction with the 

VoIP application. [Plaintiff] fails to allege facts supporting how [defendant] specifically instructed 

or directed customers to use the [defendant’s] application and corresponding server system in a 

manner that would infringe the ’071 patent.”). Because Huawei’s factual allegations, even if 

accepted as true, would not meet the requirement of specific intent, all its induced infringement 

claims fail and should be dismissed.

 

3

 The Complaint cites to two YouTube videos allegedly describing One Talk. Compl. ¶¶ 309, 

315. However, neither video is publicly accessible; both indicate “[v]ideo unavailable” stating 

that “[t]his video is private.” 

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4. The Complaint Fails to Adequately Plead Contributory Infringement

The Complaint fails to set forth a plausible claim for contributory infringement because it 

does not allege facts that plausibly show that there are no non-infringing uses for the accused 

products. 

a. The Complaint Fails to Plead Pre-Suit Knowledge of Alleged Contributory 

Infringement of the ’839 Patent.

As discussed above, Huawei concedes in its Complaint that Verizon had no pre-suit 

knowledge of any claim of infringement by Huawei on the ’839 Patent. Just as allegations of 

exclusively post-suit knowledge are fatal to an inducement claim, they are insufficient to establish 

the requisite knowledge for a contributory infringement claim. See Aguirre, 2011 WL 2471299 at 

*3 (“Like contributory infringement, direct infringement by inducing infringement has an essential 

knowledge component. . . . Absence of knowledge is a fatal flaw in a claim for indirect patent 

infringement.”). Because Huawei relies exclusively on post-filing knowledge, its contributory 

infringement claim for the ’839 Patent should also be dismissed.

b. The Complaint Fails to Plead Facts Showing There Are No Substantial NonInfringing Uses for the Accused Products.

For all of the Asserted Patents, the Complaint fails to allege facts sufficient to allow an 

inference that there are no substantial non-infringing uses for the accused products—and 

furthermore, the Complaint provides clear, affirmative evidence that the accused products have 

numerous non-infringing uses and functionalities. The Complaint cites documents that clearly 

state that the accused products have a wide variety of non-accused functionalities. Therefore, 

Huawei itself has “supplie[d] the very facts which defeat its claims of contributory infringement”

by introducing non-infringing uses for the accused products into the Complaint. See In re Bill of 

Lading, 681 F.3d at 1338 (“Where the product is equally capable of, and interchangeably capable 

of both infringing and substantial non-infringing uses, a claim for contributory infringement does 

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not lie. The materials regarding [Defendants’] products from which [Plaintiff] quotes, and, which 

are attached to the amended complaints, contain repeated descriptions of non-infringing uses to 

which the accused products can be put.”).

For the ’709, ’986, and ’693 Patents, the Complaint cites to configuration guides for the 

various accused routers, switches, and frameworks that identify many non-accused features of 

those products. The ’709 Patent allegations accuse Cisco’s “Ethernet Flow Point functionality,”

but the configuration guide for the accused Cisco ASR9000 series router in the Complaint (see, 

e.g., Compl. ¶ 55 (citing https://www.cisco.com/c/en/us/td/docs/routers/asr9000/software/

asr9k_r53/lxvpn/configuration/guide/b-l2vpn-cg53xasr9k.pdf)) lists many other non-accused 

capabilities, including “Hot Standby Routing Protocol,” “Multiple Spanning Tree Protocol,” and 

“Layer 2 Access Lists.” Similarly, for the ’986 Patent, the Complaint cites to a configuration guide 

for the accused “Cisco Convergence Products” (see, e.g., Compl. ¶ 95 (citing 

https://www.cisco.com/c/en/us/td/docs/ios-xml/ios/iproute_bgp/configuration/xe-16/irg-xe-16-

book/bgp-pic-edge-for-ip-and-mpls-vpn.pdf)) which lists numerous non-infringing uses besides 

the accused fast convergence feature. Examples include the “MPLS VPN--BGP Local 

Convergence,” “Cisco Express Forwarding,” and standard BGP convergence. Similarly, the 

configuration guide for the “Juniper Convergence Products” (see, e.g., Compl. ¶ 116), also accused 

under the ’986 Patent, lists multiple non-infringing uses apart from the fast convergence feature, 

including “VPN Graceful Restart,” “Creating Unique VPN Routes Using VRF Tables,” and 

standard BGP convergence. The ’693 Patent allegations accuse the “Juniper ATP Products,” but 

the cited Juniper Sky Advanced Threat Prevention framework administration guide (see, e.g., 

Compl. ¶ 158 (citing https://www.juniper.net/documentation/en_US/release-independent/skyatp/information-products/pathway-pages/sky-atp-admin-guide.pdf) describes many nonCase 6:20-cv-00090-ADA Document 26 Filed 04/01/20 Page 8 of 14
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infringing uses other than the malware monitoring architecture. For example, the framework 

allows users to quarantine infected systems, prevent data exfiltration, and disrupt lateral 

movement.

Additionally, for the ’709 and ’986 patents, the Complaint repeatedly states that the 

accused Cisco (accused by both the ’709 and ’986 Patent allegations) and Juniper (accused by the 

‘986 Patent allegations) products “can be configured to” or “are operable to” perform the 

allegedly infringing functionality. See, e.g., Compl. ¶¶ 55, 95, 116, 126. Further, the documents 

cited in the Complaint state that the accused features must be enabled or configured in order to 

function. See https://www.cisco.com/c/en/us/td/docs/ios-xml/ios/iproute_bgp/configuration/xe16/irg-xe-16-book/bgp-pic-edge-for-ip-and-mpls-vpn.pdf (“When the BGP PIC feature is enabled, 

BGP calculates a backup or alternate path per prefix and installs it into BGP RIB, IP RIB, and 

FIB.”); https://www.cisco.com/c/en/us/td/docs/routers/asr9000/software/asr9k_r5-3/lxvpn/

configuration/guide/b-l2vpn-cg53xasr9k.pdf (“You can perform a variety of operations on the 

traffic flows when a router is configured with EFPs on various interfaces.”);

https://www.juniper.net/documentation/enUS/junos/information-products/pathway-pages/configguide-routing/config-guide-routing-bgp.pdf (“ . . . with the BGP PIC feature enabled . . . ”); 

https://www.juniper.net/documentation/enUS/junos/information-products/pathway-pages/configguide-vpns/config-guide-vpns-layer-3.pdf (“BGP Prefix-Independent Convergence (PIC) Edge 

allows you to install a Layer 3 VPN route in the forwarding table as an alternate path”). The fact 

that Huawei limits its infringement theories to particular features or configurations of the accused 

products creates an inference that there are other non-accused configurations for the accused

products as well. See U.S. Ethernet Innovations, LLC v. Cirrus Logic, Inc., No. CV 6:12-366 

(MHS) (JDL), 2013 WL 8482270, at *4 (E.D. Tex. Mar. 6, 2013) (“In fact, [Plaintiff’s] allegation 

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that customers infringe when they use operating systems and components in accordance with 

[Defendant’s] instructions actually creates an inference that they might otherwise be used in a noninfringing manner. Accordingly, the Court finds that USEI's contributory infringement allegations 

fail to state a claim.”).

For the ’288 and ’366 Patents, the Complaint cites to a Verizon webpage advertising Cisco 

Webex (see, e.g., Compl. at ¶¶ 215, 261 (citing https://enterprise.verizon.com/products/businesscommunications/unified-communications-and-collaboration/cisco-webex/)) that lists various nonaccused features of the accused Webex product, such as “flexible application and enterprise-grade 

security integration,” “persistent messaging,” “file sharing,” “integration with most 3rd party 

enterprise applications,” and viewing “[u]p to 25 attendees at once at up to 720p screen resolution.” 

None of those features of Webex mentioned in this cited document are the accused direct screen 

share or conference signal playing features. Therefore, all of those features are non-accused and 

non-infringing uses of the accused product. By citing documents that reference non-accused and 

non-infringing features in the Complaint, Huawei rebuts its own allegations of contributory 

infringement, and shows that the accused products clearly have non-infringing uses. See Sonrai

Sys., LLC v. AMCS Grp. Inc., No. CV 16-9404, 2017 WL 4281122, at *8 (N.D. Ill. Sept. 27, 2017) 

(“AMCS contends that AMCS’s website—which Sonrai cited to identify the purportedly 

infringing uses—discloses several uses of the RFID system that do not infringe the patent. The 

court agrees that AMCS’s website discloses non-infringing uses. According to the website, the 

AMCS RFID system is also capable of providing proof of service to customers, tracking the precise 

number of receptacles lifted, and reporting waste hauling vehicle locations. Sonrai has no 

substantive response to the non-infringing uses that AMCS has identified. Accordingly, Sonrai’s 

claim for contributory infringement is dismissed.”) (internal citations omitted).

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Similarly, the Verizon Smart Family Service accused of infringing the ’832 Patent has 

numerous non-accused functionalities, many of which are specifically referenced in the documents 

cited by Huawei in the Complaint. Non-accused features include managing blocked contacts and 

blocked numbers, trusted contacts, sending a location check-in from a child’s app, requesting pick 

up from a child’s app, arrival and departure alerts, limiting data usage, blocking purchases, limiting

texting, and setting call restrictions. See Compl. ¶ 278 

(https://www.verizonwireless.com/support/how-to-use-verizon-smart-family/). The same is true 

for the Verizon One Talk application accused of infringing the ’839 Patent, which likewise has 

many non-accused features, such as Account Codes (which allow a user to associate individual 

calls with a specific code for tracking purposes), an “Automated Receptionist,” Calling Line ID 

Delivery, Custom Ringback, Group Forwarding, Hunt Group, Music on Hold, Remote Group 

Pickup, office hours scheduling, Virtual On-Net Extensions, Anonymous Call Rejection, 

Automatic Callback, Bridge Line, Busy Lamp Field, Call Barge, Call Forwarding, Call Hold, Call 

Move, Call Park & Retrieve, Call Transfer, Call Waiting, Caller ID Blocking, Caller Name ID,

Calling Plan, Do Not Disturb, Extension Dialing, Fax, Intercom, Internal Calling ID, Line Sharing, 

voicemail, Pre-Alerting Announcement, Remote Call Pickup with Barge In, Selective Call 

Acceptance / Rejection, Simultaneous Ring Service, Text Messaging, Video Calling, and 

Voicemail Operator Opt Out, none of which are addressed in the Complaint. See 

https://www.verizonwireless.com/support/one-talk-features/.

Additionally, the Complaint fails to sufficiently allege that the accused components are a 

material part of the invention. In order to properly plead contributory infringement, the Complaint 

must allege specific facts regarding materiality. SeeMerck Sharp & Dohme Corp. v. Teva 

Pharms. USA, Inc., No. CV 14-874 (SLR) (SRF), 2015 WL 4036951, at *6 (D. Del. July 1, 2015) 

Case 6:20-cv-00090-ADA Document 26 Filed 04/01/20 Page 11 of 14
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(“Section 271(c) specifies that the allegedly infringing component must ‘constitut[e] a material 

part of the invention,’ and recent case law from this court identifies the materiality requirement as 

an element of the analysis. This court requires that facts regarding all elements of a claim for 

contributory infringement must be pleaded.”) (internal citation omitted); Core Wireless Licensing 

S.A.R.L. v. Apple, Inc., No. CV 6:14-752 (JRG) (JDL), 2015 WL 4910427, at *5 (E.D. Tex. Aug. 

14, 2015) (“But none of these generic allegations provide any factual basis upon which a plausible 

inference of contributory infringement can be drawn. Core Wireless does not identify the general 

functionality of the respective patents, the hardware and/or software components it accuses, or 

how those components are material and especially adapted for infringement.”). For each of the 

Patents-in-Suit, the Complaint merely includes a formulaic recitation that the accused component 

is “material.” Compl. ¶¶ 79, 141, 178, 216, 262, 290, 322. Courts in this District have held that 

“[c]onclusory allegations, or legal conclusions masquerading as factual conclusions, will not 

suffice to prevent a motion to dismiss.” Iron Oak Techs., 2017 WL 9477677, at *6. Huawei’s 

allegations consist of bare legal conclusions, which cannot sustain its allegations of contributory 

infringement. Therefore, because the Complaint itself reveals that the accused products have 

substantial non-infringing uses, and because the Complaint fails to sufficiently plead materiality, 

the allegations of contributory infringement should be dismissed.

5. Conclusion

Verizon respectfully requests that Plaintiffs’ claims of induced infringement and 

contributory infringement be dismissed with prejudice.

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Dated: April 1, 2020

 /s/ Deron R. Dacus

Deron R. Dacus

State Bar No. 00790553

THE DACUS FIRM, P.C.

821 ESE Loop 323, Suite 430

Tyler, TX 75701

Phone: (903) 705-1117

Fax: (903) 581-2543

ddacus@dacusfirm.com

Charles Verhoeven

QUINN EMANUEL URQUHART & SULLIVAN, LLP

50 California Street, 22nd Floor

San Francisco, California 94111-4788

Telephone: 415-875-6600

Fax: 415-875-6700

charlesverhoeven@quinnemanuel.com

Patrick Curran

QUINN EMANUEL URQUHART & SULLIVAN, LLP

111 Huntington Ave, Suite 520

Boston, Massachusetts 02199

Telephone: 617-712-7100

Fax: 617-712-7200

patrickcurran@quinnemanuel.com

Brianne M. Straka

QUINN EMANUEL URQUHART & SULLIVAN, LLP

191 N. Wacker Dr., Suite 2700

Chicago, IL 60606

Telephone: 312-705-7400

Fax: 312-705-7401

briannestraka@quinnemanuel.com

John T. McKee

QUINN EMANUEL URQUHART & SULLIVAN, LLP

51 Madison Avenue, 22nd Floor,

New York, NY 10010

Telephone: 212-849-7000

Fax: 212-849-7100

johnmckee@quinnemanuel.com

Counsel for Verizon Communications, Inc., Cellco

Partnership d/b/a Verizon Wireless & Verizon

Business Network Services, Inc.

Case 6:20-cv-00090-ADA Document 26 Filed 04/01/20 Page 13 of 14
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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing document has 

been served on all counsel of record via the Court’s ECF system on April 1, 2020. 

/s/ Deron R. Dacus__________

Deron R. Dacus 

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