IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

Trend Micro Incorporated and Trend Micro, 

Inc. 

Plaintiffs 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

v. 

Taasera Licensing LLC, 

Defendant. 

NO. _____________ 

JURY TRIAL DEMANDED

COMPLAINT FOR DECLARATORY JUDGMENT 

Declaratory judgment Plaintiffs Trend Micro Incorporated and Trend Micro, Inc. 

(collectively, “Trend Micro”) hereby respectfully files this Complaint against Defendant Taasera 

Licensing LLC (“Taasera”), seeking declaratory judgment of non-infringement as to the following 

nine United States patents: U.S. Patent No. 6,842,796, U.S. Patent No. 7,673,137, U.S. Patent No. 

8,327,441, U.S. Patent No. 8,955,038, U.S. Patent No. 9,608,997, U.S. Patent No. 9,923,918, U.S. 

Patent No. 8,990,948, U.S. Patent No. 9,092,616, and U.S. Patent No. 8,850,517 (collectively, the 

“Patents-in-Suit”).1

Trend Micro hereby alleges as follows: 

NATURE OF THE ACTION 

1. This is an action arising under the patent laws of the United States, 35 U.S.C. § 1 

et. seq. and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202, seeking a declaratory 

judgment of: (i) non-infringement of the Patents-in-Suit; (ii) and for such other relief as the Court 

 

1

 On November 30, 2021, Taasera filed an action against Trend Micro Incorporated in the Eastern District of Texas, 

Taasera Licensing LLC v. Trend Micro Incorporated, No. 2:21-cv-00441-JRG, alleging infringement of the Patentsin-Suit. See Ex. A (Taasera’s Complaint in the Eastern District of Texas). Under Fed. R. Civ. P. Rule 4(m), Taasera’s 

deadline to serve Trend Micro Incorporated, a Japanese Corporation, was February 28, 2022. As of the filing of this 

complaint, Trend Micro Incorporated has not been served. 

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deems just and proper. Additionally, Trend Micro further reserves the right to assert invalidity as 

an affirmative defense if Taasera asserts infringement. 

THE PARTIES 

2. Plaintiff Trend Micro Incorporated (“Trend Micro Japan”) is a Japanese 

corporation whose stock is publicly traded on the Tokyo Stock Exchange, with a principal place 

of business located at Shinjuku Maynds Tower, 2-1-1 Yoyogi, Shibuya-ku, Tokyo, Japan 151-

0053. 

3. Plaintiff Trend Micro, Inc. (“Trend Micro U.S.”)2 is a corporation organized under 

the laws of California, with its principal place of business at 225 East John Carpenter Freeway, 

Irving, Texas 75062. 

4. Upon information and belief, Defendant Taasera Licensing LLC is a limited 

liability company organized and existing under the laws of the State of Texas, with its principal 

place of business located at 100 West Houston Street, Marshall, Texas 75670. 

JURISDICTION AND VENUE 

5. This action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq., 

and the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202. Subject matter jurisdiction over 

this action is based upon 28 U.S.C. §§ 1331 and 1338(a). 

6. An actual and justifiable controversy exists between Trend Micro Japan and 

Taasera regarding whether various Trend Micro’s products infringe the Patents-in-Suit. 

Specifically, on November 30, 2021, Taasera filed a complaint against Trend Micro Japan in the 

Eastern District of Texas. See Ex. A (Taasera’s Complaint in the Eastern District of Texas). In 

that complaint, Taasera alleged that Trend Micro Japan infringed and continues to infringe one or 

 

2

 Trend Micro U.S. is a wholly owned subsidiary of Trend Micro America, Inc., an unnamed party in this 

declaratory judgment action. Trend Micro America, Inc. is a wholly owned subsidiary of Trend Micro Japan. 

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more claims of the Patents-in-Suit by making, selling, offering for sale, importing and distributing 

and by actively inducing others to make, use, sell, offer to sell, and/or import products that 

implement Trend Micro’s network security inventions. Id., ¶ 29. Because a controversy exists 

over whether Trend Micro’s products and services infringe the Patents-in-Suit, the Court may grant 

declaratory relief pursuant to 28 U.S.C. §§ 2201 and 2202. 

7. An actual and justifiable controversy also exists between Trend Micro U.S. and 

Taasera. In Taasera’s complaint against Trend Micro Japan, Taasera alleged Trend Micro’s 

products infringe one or more claims of the Patents-in-Suit. Id., ¶ 29. Trend Micro U.S. directs 

and controls the sale of Trend Micro’s products in the United States. Because a controversy exists 

over whether Trend Micro’s products and services infringe the Patents-in-Suit, including those 

sold by Trend Micro U.S. in the United States, the Court may grant declaratory relief pursuant to 

28 U.S.C. §§ 2201 and 2202. 

8. This Court has general and specific jurisdiction over Taasera at least because 

Taasera is at home in the State of Texas, where it is incorporated. 

9. Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b) and 1400 because 

this is the district in which a substantial part of the events and allegations giving rise to the claims 

occurred, or a substantial part of property that is subject to this action is situated. Additiona lly, 

Taasera’s principal place of business is located within the State of Texas, where it is incorporated. 

THE PATENTS-IN-SUIT 

10. On its face, U.S. Patent No. 6,842,796 (the “’796 Patent”) is entitled, “Information 

Extraction from Documents with Regular Expression Matching,” and indicates an issue date of 

January 11, 2005 to named inventors Geoffrey G. Zweig and Mukund Padmanabhan. A true and 

correct copy of the ’796 Patent is attached as Ex. B. 

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11. On its face, U.S. Patent No. 7,673,137 (the “’137 Patent”) is entitled, “System and 

Method for the Managed Security Control of Processes on a Computer System,” and indicates an 

issue date of March 2, 2010 to named inventors Thomas James Satterlee and William Frank 

Hackenberger. A true and correct copy of the ’137 Patent is attached as Ex. C. 

12. On its face, U.S. Patent No. 8,327,441 (the “’441 Patent”) is entitled, “System and 

Method for Application Attestation,” and indicates an issue date of December 4, 2012 to named 

inventors Srinivas Kumar and Gurudatt Shashikumar. A true and correct copy of the ’441 Patent 

is attached as Ex. D. 

13. On its face, U.S. Patent No. 8,955,038 (the “’038 Patent”) is entitled, “Methods and 

Systems for Controlling Access to Computing Resources Based on Known Security 

Vulnerabilities,” and indicates an issue date of February 10, 2015 to named inventors Blair 

Nicodemus and Billy Edison Stephens. A true and correct copy of the ’038 Patent is attached as 

Ex. E. 

14. On its face, U.S. Patent No. 9,608,997 (the “’997 Patent”) is entitled, “Methods and 

Systems for Controlling Access to Computing Resources Based on Known Security 

Vulnerabilities,” and indicates an issue date of March 28, 2017 to named inventors Blair 

Nicodemus and Billy Edison Stephens. A true and correct copy of the ’997 Patent is attached as 

Ex. F. 

15. On its face, U.S. Patent No. 9,923,918 (the “’918 Patent”) is entitled, “Methods and 

Systems for Controlling Access to Computing Resources Based on Known Security 

Vulnerabilities,” and indicates an issue date of March 20, 2018 to named inventors Blair Gaver 

Nicodemus and Billy Edison Stephens. A true and correct copy of the ’918 Patent is attached as 

Ex. G. 

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16. On its face, U.S. Patent No. 8,990,948 (the “’948 Patent”) is entitled, “Systems and 

Methods for Orchestrating Runtime Operational Integrity,” and indicates an issue date of March 

24, 2015 to named inventors Srinivas Kumar and Dennis Pollutro. A true and correct copy of the 

’948 Patent is attached as Ex. H. 

17. On its face, U.S. Patent No. 9,092,616 (the “’616 Patent”) is entitled, “Systems and 

Methods for Threat Identification and Remediation,” and indicates an issue date of July 28, 2015 

to named inventors Srinivas Kumar and Dennis Pollutro. A true and correct copy of the ’616 

Patent is attached as Ex. I. 

18. On its face, U.S. Patent No. 8,850,517 (the “’517 Patent”) is entitled, “Runtime 

Risk Detection Based on User, Application, and System Action Sequence Correlation,” and 

indicates an issue date of September 30, 2014 to named inventor Srinivas Kumar. A true and 

correct copy of the ’517 Patent is attached as Ex. J. 

19. On information and belief, Taasera is the owner by assignment of the Patents-inSuit. Taasera claims to have the authority to enforce rights under the Patents-in-Suit and to bring 

litigation to enforce those rights. Ex. A, ¶ 16. 

THE PARTIES’ DISPUTE CONCERNING THE PATENTS-IN-SUIT 

20. On November 30, 2021, Taasera filed suit in the Eastern District of Texas against 

Trend Micro Japan, Taasera Licensing LLC v. Trend Micro Incorporated, No. 2:21-cv-00441-

JRG, accusing Trend Micro Japan of infringing one or more of the Patents-in-Suit by making, 

using, selling, offering to sell, and/or importing, and by actively inducing others to make, use, sell, 

offer to sell, and/or import products that implement the network security inventions claimed in the 

Patents-in Suit. A true and correct copy of Taasera’s complaint in the Eastern District of Texas is 

attached as Ex. A (Taasera’s Complaint in the Eastern District of Texas). Taasara has not served 

Trend Micro Japan or withdrawn its complaint in the Eastern District of Texas. While Taasara did 

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not name Trend Micro U.S. as a defendant in the Complaint, Taasara’s allegations of infringement 

as to Trend Micro’s products, which are sold in the United States by Trend Micro U.S., establish 

a justiciable case or controversy between Taasara and Trend Micro U.S. of sufficient immediacy 

and reality. 

21. Taasera alleges that products incorporating the integrated Data Loss Prevention 

feature (e.g., Trend Micro OfficeScan, Cloud App Security, ScanMail for Microsoft Exchange, 

ScanMail for Lotus Domino, InterScan Messaging Security, InterScan Web Security, IM Security 

for Microsoft Lync, Portal Protect for Microsoft SharePoint, and Smart Protection for Endpoints 

& Complete) infringe one or more claims of the ’796 Patent. Id., ¶ 34. 

22. Taasera alleges that products incorporating the Application Control feature (e.g., 

Trend Micro Apex One and Trend Micro Vision One) infringe one or more claims of the ’137 

Patent. Id., ¶ 45. 

23. Taasera alleges that products incorporating the Predictive Machine Learning 

feature (e.g., Trend Micro Apex One and Trend Micro Vision One) infringe one or more claims of 

the ’441 Patent. Id., ¶ 56. 

24. Taasera alleges that products incorporating the Vulnerability Protection feature 

(e.g., Trend Micro Apex One and Trend Micro Vision One) infringe one or more claims of the 

’038 Patent, one or more claims of the ’997 Patent and one or more claims of the ’918 Patent. Id., 

¶¶ 67, 111, 126. 

25. Taasera alleges that products incorporating the Extended Detection and Response 

feature (e.g., Trend Micro Apex One and Trend Micro Vision One) infringe one or more claims of 

the ’948 Patent and one or more claims of the ’616 Patent. Id., ¶¶ 82, 95. 

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26. Taasera alleges that products incorporating the Correlated Rule and/or Targeted 

Attack Campaign features (e.g., Trend Micro Deep Discovery Inspector, Trend Micro Apex 

Central, Trend Micro Apex One, and Trend Micro Vision One) infringe one or more claims of the 

’517 Patent. Id., ¶ 140. 

27. Taasera alleges that Trend Micro Japan has and continues to indirectly infringe one 

or more claims of the Patents-in-Suit by knowingly and intentionally inducing others, including 

Trend Micro Japan subsidiaries, customers, and end-users, to directly infringe, either literally or 

under the doctrine of equivalents, by making, using, offering to sell, selling, and/or importing into 

the United States products that include infringing technology. See, e.g., id., ¶ 38. 

28. Taasera alleges that Trend Micro Japan, with the knowledge that these products, or 

the use thereof, infringed the Patents-in-Suit, knowingly and intentionally induced, and continues 

to knowingly and intentionally induce, direct infringement of the Patents-in-Suit by providing 

these products to end-users for use in an infringing manner. See, e.g., id., ¶ 39. 

29. Taasera alleges that Trend Micro Japan induced infringement by others, including 

end-users, with the intent to cause infringing acts by others or, in the alternative, with the belief 

that there was a high probability that others, including end-users, infringe the Patents-in-Suit, but 

while remaining willfully blind to the infringement. See, e.g., id., ¶ 40. 

30. Taasera claims it has suffered damages as a result of Trend Micro Japan’s direct 

and indirect infringement of the Patents-in-Suit and it will continue to suffer, irreparable harm as 

a result of Trend Micro Japan’s infringement of the Patents-in-Suit. See, e.g., id., ¶¶ 41, 42. 

31. Accordingly, an actual and justiciable controversy exists between Trend Micro and 

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Suit. Trend Micro now seeks a declaratory judgment that Trend Micro does not infringe the claims 

of the Patents-in-Suit. 

COUNT ONE 

(Declaratory Judgment of Non-Infringement of the ’796 Patent) 

32. This is a claim for declaratory judgment of non-infringement of the ’796 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

33. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

34. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’796 Patent. On information and 

belief, at least Trend Micro OfficeScan, Cloud App Security, ScanMail for Microsoft Exchange, 

ScanMail for Lotus Domino, InterScan Messaging Security, InterScan Web Security, IM Security 

for Microsoft Lync, Portal Protect for Microsoft SharePoint, and Smart Protection for Endpoints 

& Complete, have not infringed, and do not infringe, directly or indirectly, literally or under the 

doctrine of equivalents, willfully or otherwise, any valid and enforceable claim of the ’796 Patent. 

35. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’796 Patent. 

COUNT TWO 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’137 Patent) 

36. This is a claim for declaratory judgment of non-infringement of the ’137 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

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37. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

38. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’137 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’137 Patent. 

39. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’137 Patent. 

COUNT THREE 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’441 Patent) 

40. This is a claim for declaratory judgment of non-infringement of the ’441 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

41. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

42. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’441 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’441 Patent. 

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43. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’441 Patent. 

COUNT FOUR 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’038 Patent) 

44. This is a claim for declaratory judgment of non-infringement of the ’038 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

45. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

46. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’038 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’038 Patent. 

47. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’038 Patent. 

COUNT FIVE 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’997 Patent) 

48. This is a claim for declaratory judgment of non-infringement of the ’997 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

49. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

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50. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’997 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’997 Patent. 

51. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’997 Patent. 

COUNT SIX 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’918 Patent) 

52. This is a claim for declaratory judgment of non-infringement of the ’918 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

53. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

54. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’918 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’918 Patent. 

55. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’918 Patent. 

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COUNT SEVEN 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’948 Patent) 

56. This is a claim for declaratory judgment of non-infringement of the ’948 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

57. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

58. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’948 Patent. On information and 

belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’948 Patent. 

59. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’948 Patent. 

COUNT EIGHT 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’616 Patent) 

60. This is a claim for declaratory judgment of non-infringement of the ’616 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

61. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

62. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’616 Patent. On information and 

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belief, at least Trend Micro Apex One and Trend Micro Vision One, have not infringed, and do 

not infringe, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any valid and enforceable claim of the ’616 Patent. 

63. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’616 Patent. 

COUNT NINE 

(Declaratory Judgment of Non-Infringement of U.S. Patent No. ’517 Patent) 

64. This is a claim for declaratory judgment of non-infringement of the ’517 Patent. 

The allegations of the foregoing paragraphs above are repeated as though fully set forth herein. 

65. As a result of the acts described in the preceding paragraphs, there exists a 

controversy of sufficient immediacy and reality between Trend Micro and Taasera to warrant the 

issuance of a declaratory judgment. 

66. Trend Micro’s products, including at least the Accused Products, have not 

infringed, and do not infringe, directly or indirectly, literally or under the doctrine of equivalents, 

willfully or otherwise, any valid and enforceable claim of the ’517 Patent. On information and 

belief, at least Trend Micro Deep Discovery Inspector, Trend Micro Apex Central, Trend Micro 

Apex One, and Trend Micro Vision One, have not infringed, and do not infringe, directly or 

indirectly, literally or under the doctrine of equivalents, willfully or otherwise, any valid and 

enforceable claim of the ’517 Patent. 

67. Trend Micro is entitled to a judgment from this Court that Trend Micro has not 

infringed, and does not infringe, any valid and enforceable claim of the ’517 Patent. 

PRAYER FOR RELIEF 

WHEREFORE, Trend Micro prays for the following judgment and relief: 

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(A) The Court enter a declaratory judgment that Trend Micro is not infringing and has 

not infringed, directly or indirectly, literally or under the doctrine of equivalents, willfully or 

otherwise, any claims of the Patents-in-Suit; 

(B) Preliminarily and permanently enjoining Taasera, its officers, agents, servants, 

employees, and attorneys, and those persons in active concert or participation with it who receive 

actual notice by personal service or otherwise, from asserting or threatening to assert against Trend 

Micro or its customers, potential customers, or users of any Trend Micro products, any charge of 

infringement of any claims of the Patents-in-Suit; 

(C) The Court declare this case exceptional under 35 U.S.C. § 285, awarding Trend 

Micro its costs, expenses, and reasonable attorneys’ fees under 35 U.S.C. § 285 and all other 

applicable statutes, rules and common law, including this Court’s inherent authority; and 

(D) Any other equitable rights and/or legal relief that this Court may deem just and 

proper. 

DEMAND FOR JURY TRIAL 

In accordance with Federal Rules of Civil Procedure 38(b), Trend Micro demands a trial 

by jury on all issues so triable. 

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DATED: February 28, 2022 PAUL HASTINGS LLP 

By: /s/ Yar R. Chaikovsky

Yar R. Chaikovsky (admitted)

Philip Ou (pro hac vice)

Bruce S. Yen (pro hac vice)

Alexander H. Lee (pro hac vice)

Paul Hastings LLP 

1117 S. California Avenue 

Palo Alto, CA 94304-1106 

Telephone: 650.320.1800 

Facsimile: 650.320.1900 

Email: yarchaikovsky@paulhastings.com 

Email: philipou@paulhastings.com 

Email: bruceyen@paulhastings.com 

Email: alexanderlee@paulhastings.com 

Attorneys for Plaintiffs, 

Trend Micro Incorporated and Trend Micro, 

Inc. 

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