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JENNIFER LEE TAYLOR (SBN 161368)

JTaylor@mofo.com 

STACEY M. SPRENKEL (SBN 241689)

SSprenkel@mofo.com

JOYCE LIOU (SBN 277720)

JLiou@mofo.com

AMANDA D. PHILLIPS (SBN 305614)

APhillips@mofo.com

MORRISON & FOERSTER LLP

425 Market Street

San Francisco, California 94105-2482

Telephone: (415) 268-7000

Facsimile: (415) 268-7522

Attorneys for Defendants/Counterclaimants

UBIQUITI NETWORKS, INC., UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

and Defendant CHING-HAN TSAI

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

SYNOPSYS, INC.,

Plaintiff,

v.

UBIQUITI NETWORKS, INC., UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

CHING-HAN TSAI, and DOES 1-20,

inclusive,

Defendants.

Case No. 3:17-cv-00561-WHO (LB)

DEFENDANTS UBIQUITI 

NETWORKS, INC., UBIQUITI 

NETWORKS INTERNATIONAL 

LIMITED, AND CHING-HAN 

TSAI’S BRIEF IN OPPOSITION 

TO SYNOPSYS’ REQUESTS FOR 

INSPECTION

Date: January 18, 2018

Time: 9:30 a.m.

Place: Courtroom C, 15th Floor

Judge: Honorable Laurel Beeler

UBIQUITI NETWORKS, INC. and UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

Counterclaimants,

v.

SYNOPSYS, INC.,

Counterdefendant.
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INTRODUCTION

Synopsys has approached this case with a single discovery demand from the beginning—

to image Defendants’ computers. The very first time the parties spoke about discovery, 

immediately after the June 14, 2017 case management conference, Synopsys said that it would 

need to image Defendants’ computers. No discovery requests had even been served at the time. 

Synopsys proposed first imaging the devices of what Synopsys called “the top five users” once 

Synopsys provided those names to Defendants, but it did not identify them until August 22. A 

few weeks after that, Synopsys served the 56 requests for inspection at issue here, disregarding its

proposal to focus on the “top five users.” 

During a November 3 in-person conference regarding the requests for inspection, 

Synopsys did not address any of the objections that Defendants made to the inspection requests 

and instead focused on how the imaging and inspection should proceed. Synopsys also deflected 

discussion of the voluminous documents that Defendants had already collected and was 

reviewing because this case would allegedly turn “entirely” on forensic evidence. Demonstrating 

ignorance of the burden of its 56 requests for inspection, Synopsys even suggested that as a first 

step Defendants should collect the multitude of devices at issue in a single room in Taiwan so that 

its forensic experts could then quickly inspect each device by typing in a few simple commands. 

This is not the type of inspection it now seeks for Defendant Ching-Han Tsai’s devices.

Synopsys made these repeated demands even while it refused to turn over the “call-home” 

data that it claims support its allegation of over 39,000 acts of circumvention of Synopsys’ license 

key system. Synopsys will claim that it could not turn over that data without a protective order, 

even though the “call-home” data is data that Synopsys acquired from Defendants, and that 

Defendants dragged their feet in negotiating the protective order—which is not at all true. What 

is true is that the “call-home” data that Synopsys finally produced on December 1 demonstrates 

that all but 626 of the alleged acts of circumvention took place entirely outside the United States, 

and that the remaining 626 acts of circumvention were all completed outside the United States as 

well. Thus, while Synopsys has been pressing to image dozens of computers and multiple 

complex servers, containing highly confidential and attorney-client privileged information, it was 
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withholding from Defendants the very data that show that none of the acts of circumvention took 

place completely within the United States (despite Synopsys’ allegations in its complaint), and 

that at most, 626 of the acts were initiated from the United States. 

As discussed further below, the case law is clear that there is no DMCA liability for acts 

such as those recorded by Synopsys’ call-home data. Defendants have already imaged the 

computers used by Defendant Tsai, who occasionally works from the U.S. and has reason to use 

the type of electronic design automation (EDA) software tools at the center of this dispute. An 

inspection of those images will take place as soon as the parties agree to an inspection protocol. 

Defendants are also willing to make available for inspection the computers of the one U.S-based 

engineer, Sheng-Feng Wang, who engaged in a single instance of debugging assistance using 

Synopsys software. Given that there is no liability in the U.S. for acts of circumvention that 

occur or are completed outside of the U.S., Synopsys has no basis to image or inspect any of the 

other computers or servers that it is seeking.

BACKGROUND

A. Synopsys’ Requests for Forensic Inspection

On September 8, 2017, Synopsys served 59 identical requests on Ubiquiti and UNIL to

inspect and copy a variety of electronic devices. (Declaration of Jennifer Lee Taylor (“Taylor 

Decl.”) ¶ 3, Ex. A.) The requests cover forensic inspection of:

 electronic devices used by nine employees (Request Nos. 1-9);

 electronic devices used by users of fifteen usernames (Request Nos. 10-24);

 electronic devices bearing fourteen MAC addresses (Request Nos. 25-38);

 electronic devices bearing sixteen IP addresses (Request Nos. 39-54); and

 electronic devices bearing five hostnames (Request Nos. 55-59).

On December 1, 2017, Synopsys finally produced a spreadsheet of the “call-home” data that it 

states provide the basis for these inspection requests. As indicated by that spreadsheet, only 626 

of the approximately 39,000 call-home events—each of which Synopsys argues is a single act of 

circumvention under the Digital Copyright Millennium Act (DMCA)—correspond to an “egress” 

IP address originating from the United States between November 2014 and March 2016. (Taylor 
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Decl. ¶ 6.) The remaining 38,178 data entries correspond to an egress IP address from Taiwan. 

(Id.) In addition to an egress IP address, each call-home entry identifies a server or host name, 

username, date, time, and one or more associated MAC addresses. (Id.) Synopsys’ counsel has 

represented that the MAC addresses identified by the call-home data correspond to computers that 

have Synopsys software on them and that transmit data back to Synopsys when a counterfeit key

is detected. (Id.)

B. Relationship of Requested Devices to the United States

Employee Computers. Synopsys’ inspection requests encompass at least 26 different 

employee computers.1 Not only are most of these devices physically located in Taiwan, most 

have no connection whatsoever to computer systems in the United States because they are used 

by team members who reside in Taiwan, work in UNIL’s Taipei office, and perform their daily

work on UNIL’s local computer networks in Taipei. The team consists of 18 engineers with 

different roles on a discrete project to design a semiconductor chip for one of Ubiquiti’s products. 

(Declaration of Ching-Han Tsai (“Tsai Decl.”) ¶ 2.) Defendant Tsai was hired first as the project 

lead in September 2013, and was responsible for building the rest of the team. (Id.) Due to a 

faster hiring process in Taiwan, Tsai chose to base the team, with one exception, at Ubiquiti’s 

major research and development location in UNIL’s Taipei office, and relocated himself from the 

U.S. to Taiwan to be in the same location as other team members. (Id.) 

Of the 17 current team members in UNIL’s Taipei office, just one—Tsai—travels from 

Taiwan to the U.S. on occasion for work or to visit family, and would have need to use EDA 

software tools regularly while in the United States. (Id. ¶¶ 13-14.) One other team member, 

Sheng-Feng Wang, is based in the U.S. but has no need to use EDA software tools in his regular 

 

1 Defendants emphasize “at least” because Synopsys’ requests, specifically Request 

Nos. 39-54 for any electronic devices “bearing” fifteen different IP addresses, potentially capture 

hundreds and hundreds of Defendants’ computers—not just those used by the relevant custodians 

whom Defendants identified in interrogatory responses—that may have used any one of the 

corporate IP addresses at any given point in time, but that have no relevancy other than use of a 

common IP address at a hundred-plus person site. Defendants timely objected to these requests 

as vague, overly broad, and unduly burdensome. (See Taylor Decl. ¶ 3, Ex. B.) Synopsys never 

conferred regarding those objections. (Id. ¶ 4.) Defendants request that the Court decline to 

allow any inspection that would be covered by Request Nos. 39-54 based on those objections.
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work given his project role. (Declaration of Shen-Feng Wang (“Wang Decl.”) ¶¶ 2, 6.) While 

the entire team has access to two shared username accounts on UNIL’s computer systems, only a 

select few have a reason to access EDA software for designing application specific integrated 

circuits (ASIC), let alone the technical skills to use such software or an occasion to use it from the 

United States. (Tsai Decl. ¶ 17.) 

Server Devices. In addition to employee devices, Synopsys’ inspection requests identify

MAC addresses and host names for several computational servers and virtual machines that are 

not only located in Taiwan, but also contain the only copies of EDA software that would have 

been used by the current team members whose role is to design and test ASIC chips. (See id. 

¶¶ 7-13.) All EDA software used by the team is located on a storage array in UNIL’s Taipei 

office, and accessible only via three computational servers and the virtual machines on them, also 

in Taiwan, which are networked with the storage array. (Id. ¶ 12.) This local area network is 

remotely accessed by ASIC design team members using their individual laptops and computers. 

(Id.) Because of the nature of ASIC design work, including the processing resources that are 

required for running simulations, this local network of computational servers and virtual 

machines in UNIL’s Taipei office is separate from Ubiquiti’s IT infrastructure, including the rest 

of UNIL’s IT infrastructure in Taiwan. (Id.) 

Any ASIC design team member who needs to access EDA software on the storage array

does so by first logging into his computer and connecting remotely to the computational servers 

to initiate simulations. (Id. ¶ 13.) Those computational servers, and any virtual machines 

residing on them, then use the EDA software located on the storage array to conduct the 

simulations. (Id.) Because of how UNIL’s computer networks and servers are configured, there 

is no need for any EDA software or license key to be loaded on an employee computer. (Id.)

ARGUMENT

I. U.S. COPYRIGHT LAWS APPLY ONLY TO ACTS THAT ARE COMPLETED 

WITHIN THE UNITED STATES

The purported purpose of Synopsys’ requests to forensically inspect Defendants’ 

electronic devices—to find evidence of forensic artifacts of license key generators, use of piracy
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websites, external drives, and user profiles (see Dkt. No. 99 at 2)—is only relevant to Synopsys’ 

first claim of circumvention of Synopsys’ license-key system under the DMCA, 17 U.S.C. 

§ 1201(a)(1). This section of the DMCA makes it a violation to “circumvent” a technological 

measure that effectively controls access to a copyrighted work, by descrambling a scrambled 

work, decrypting an encrypted work, or otherwise avoiding, bypassing, removing, deactivating, or 

impairing the technological measure. 17 U.S.C. § 1201(a)(1), (3). Synopsys asserts thirteen 

copyrighted software programs that are access-controlled by Synopsys’ license-key system, and 

Synopsys alleges that Defendants circumvented the license-key system through use of 

“counterfeit” license keys in violation of the DMCA. (Dkt. No. 73 ¶¶ 24-26, 28.) No other claim 

asserted by Synopsys justifies a burdensome forensic inspection of Defendants’ devices for 

forensic artifacts of software usage, nor has Synopsys asserted that one is necessary for any other 

claim. Discovery on Synopsys’ other claims may be addressed through document production. 

As explained below, Defendants believe the requested forensic inspection, which would 

encompass at least 26 employee computers and 3 servers located in Taiwan, goes well beyond the 

scope of this action, and seeks discovery of entirely irrelevant information, because liability under 

the DMCA can only extend to acts of circumvention that are completed within the United States. 

First, it is black letter law that U.S. copyright laws do not impose liability for 

extraterritorial acts. In Subafilms, the Ninth Circuit confirmed the longstanding principle that 

U.S. copyright laws do not reach acts of infringement that occur outside the United States. 

Subafilms, Ltd. v. MGM-Pathe Commc’ns Co., 24 F.3d 1088, 1095-96, 98 (9th Cir. 1994) (en 

banc) (“The undisputed axiom . . . that the United States’ copyright laws have no application to 

extraterritorial infringement predates the 1909 Act, . . . and, . . . the principle of territoriality

consistently has been reaffirmed.”) (citations omitted). Faced with a U.S. defendant who, from 

the United States, authorized a foreign company to distribute copyrighted materials outside the 

United States, the Ninth Circuit stated that the defendant’s “mere authorization of acts of 

infringement . . . [that] occur entirely outside of the United States does not state a claim for 

infringement under the Copyright Act,” and found the defendant not liable. Id. at 1099.

Similarly, in Allarcom, the Ninth Circuit found that a U.S. defendant was not liable under 
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the Copyright Act for committing a part of an act of infringement that began in the United States 

and culminated overseas. Allarcom Pay Television, Ltd. v. Gen. Instrument Corp., 69 F.3d 381, 

387 (9th Cir. 1995). Citing its prior Subafilms decision, the Ninth Circuit stated:

We held that in order for U.S. copyright law to apply, at least one 

alleged infringement must be completed entirely within the United 

States, and that mere authorization of extraterritorial infringement 

was not a completed act of infringement in the United States. 

Subafilms, 24 F.3d at 1094, 1098. In this case, defendants either 

initiated a potential infringement in the United States by

broadcasting the Showtime signal, which contained copyrighted 

material, or defendants authorized people in Canada to engage in 

infringement. In either case, the potential infringement was only

completed in Canada once the signal was received and viewed. 

Accordingly, U.S. copyright law did not apply, and therefore did 

not preempt Allarcom’s state law claims.

Allarcom, 69 F.3d at 387 (emphasis added). 

As Subafilm and Allarcom show, liability does not exist if only some part of a violative act 

was initiated within the United States. Rather, the violative act must be completed within the 

territorial boundaries of the United States for U.S. copyright law to apply, as a contrary result 

would displace foreign copyright laws and cause potential international discord. See Subafilms, 

24 F.3d at 1097-98 (noting an application of U.S. law to copyrighted materials distributed 

exclusively by national citizens in a foreign country undermines the spirit of national treatment 

under the Berne Convention); cf. Robert Stigwood Grp. Ltd. v. O'Reilly, 530 F.2d 1096, 1100-01 

(2d Cir. 1976) (no liability for performances of copyrighted work in Canada merely because 

performers assembled and arranged all necessary elements in the United States). These cases are 

clear that the site of the completed violative act determines which country’s copyright laws apply, 

and it is irrelevant whether the initiating act is integral to the final completed act.

Second, to assess whether acts involving computer transmissions over the Internet may

create liability under U.S. copyright law, the Ninth Circuit has derived a “server test” for 

determining the site of the alleged violation. See Perfect 10, Inc. v. Yandex N.V., 962 F. Supp. 2d 

1146, 1153 (N.D. Cal. 2013). That test “makes the hosting website’s computer [which stores 

electronic information and serves that information to the user], rather than the search engine’s 

computer [which merely frames electronic information for the user but does not store it], the situs 
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of direct copyright infringement liability.” Id. (citing Perfect 10, Inc. v. Amazon.com, Inc., 508 

F.3d 1146, 1159-60 (9th Cir. 2007)). In Yandex, the defendants moved for summary judgment on 

the plaintiff’s direct copyright infringement claim based on acts of infringement concerning 

content hosted on servers in Russia. Applying the Ninth Circuit’s server test, the Yandex court 

granted summary judgment for the defendants, holding that the hosting of images on Russian 

servers are extraterritorial acts that are not actionable under U.S. copyright law. 962 F. Supp. 2d 

at 1152-53. Notably, the court rejected the notion that U.S. copyright liability may arise merely 

because an image could be downloaded from a foreign server by a user in the United States as 

“[s]uch a principle would destroy the concept of territoriality inherent in the Copyright Act for 

works on the internet.” Id. at 1153. As Yandex illustrates, even activities conducted over the 

Internet must be identified by where they occur—i.e., within the borders of the country of origin 

or destination—for purposes of determining which country’s copyright laws govern.

II. ACTS INITIATED IN TAIWAN AND COMPLETED ON TAIWAN SERVERS 

ARE NOT ACTIONABLE UNDER THE DMCA

Synopsys has asserted a claim of circumvention under the Digital Millennium Copyright 

Act, a copyright law that implemented two World of Intellectual Property Organization (WIPO) 

treaties to which the U.S. is a signatory—the WIPO Copyright Treaty and WIPO Performances 

and Phonograph Treaty—and created U.S. remedies for circumvention conduct.2

As an initial matter, Synopsys has previously suggested that extraterritoriality

jurisprudence under the Copyright Act does not extend to the DMCA. This is contrary to both 

Subafilms and lower court authority that have held that U.S. copyright laws, of which the DMCA

is one, do not have extraterritorial effect. See, e.g., M Seven Sys. Ltd. v. Leap Wireless Int’l, Inc., 

2014 WL 12026065, at *6 (S.D. Cal. June 4, 2014) (the DMCA does not apply if the alleged 

violation occurred in a foreign nation). Furthermore, the Supreme Court has held that courts must 

“assume that Congress legislates against the backdrop of the presumption against 

extraterritoriality,” and must presume a federal statute concerns only domestic activities absent 

“the affirmative intention of the Congress clearly expressed.” EEOC v. Arabian Am. Oil Co., 499 

 

2

See http://www.wipo.int/copyright/en/activities/internet_treaties.html.
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U.S. 244, 248 (1991) (citation omitted). Here, the statutory language lacks any indication of 

Congress’ intent to reach beyond U.S. borders, as confirmed by text relating to U.S.-only sales of 

copy-control circumvention technology in 17 U.S.C. § 1201, and the legislative history “further 

supports the contention that the DMCA was seen [by Congress] as a protectionist, nationalistic 

law that only applied territorially.” Adam D. Fuller, Extraterritorial Implications of the Digital 

Millennium Copyright Act, 35 Case W. Res. J. Int’l L. 89, 111-112 (2003). The territorial limit of 

the DMCA is therefore presumed.

Because the DMCA does not apply to extraterritorial activity, Defendants cannot be held 

liable for any alleged acts of circumvention that were initiated on employee computers in Taiwan 

and completed on servers in Taiwan, which did not involve any computer systems in the United 

States. Under Ninth Circuit law, Defendants are not liable because these alleged acts occurred 

entirely in Taiwan. See Subafilms, 24 F.3d at 1099. According to Synopsys’ data, 38,178 of the 

approximately 39,000 call-home entries are associated with (i) an egress IP address from Taiwan, 

and (ii) a host name and MAC address corresponding to a computational server or virtual 

machine in Taiwan. (See Taylor Decl. ¶ 6, Tsai Decl. ¶¶ 6-9.) This is no surprise as only one

engineer on the entire project team, Sheng-Feng Wang, is based in the U.S., and only Defendant 

Tsai in UNIL’s Taipei office regularly travels to and works from the U.S. (Wang Decl. ¶ 2, Tsai 

Decl. ¶ 14.) Because these 38,178 alleged acts of license-key circumvention initiated from

Taiwan are not actionable in the U.S., Synopsys has no basis to forensically inspect the UNIL

employee computers that might account for such wholly extraterritorial acts. Defendants have 

submitted declarations from fifteen of the sixteen UNIL engineers verifying that each person lives

and works in Taiwan and had no reason to access Synopsys software using his work computer in 

the U.S. (either because the employee has never traveled to the U.S. or had no need for it).3 

 

3

The sixteenth UNIL employee (a software engineer based in Taipei) is on vacation this 

week. He traveled to the U.S. only one time for work in August 2017, after the filing of the 

lawsuit. (Declaration of Hayley Nivelle ¶ 6.) Defendants have submitted a separate declaration 

regarding two project team members no longer employed UNIL who, like the current UNIL 

engineers, worked in the Taiwan office. (Id. ¶¶ 3-5.) One never traveled to the U.S. for work; the 

other traveled to the U.S. in March 2014, which predates the period of “calls home” from the 

United States according to Synopsys’ data, meaning that employee could not have used Synopsys 

software in the U.S. (See Taylor Decl. ¶ 6.)
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These employees’ computers, totaling 26 or more, should thus be excluded by the Court from any

required forensic inspection. 

III. ACTS INITIATED IN THE UNITED STATES AND COMPLETED ON TAIWAN 

SERVERS ARE NOT ACTIONABLE UNDER THE DMCA

Synopsys’ call-home data makes it clear that all of the remaining 626 alleged acts of 

circumvention were, at most, only initiated in the U.S. and then completed on servers in Taiwan. 

Under Allarcom, there is no liability where an act is initiated in the U.S. but completed in another 

country. Allarcom, 69 F.3d at 387. Further, applying the Ninth Circuit’s “server test” to these 

alleged acts of circumvention initiated in the U.S., it is clear that the site of the violative act (the 

alleged use of “counterfeit” license keys to circumvent Synopsys’ license-key system) are the 

servers that actually hosted Synopsys software—because that is the only place where the act 

could be completed—and not an employee computer that remotely initiated the act or where the

displayed results could be viewed. See Perfect 10, 508 F.3d at 1159-61 (noting “it is the website 

publisher’s computer, rather than Google’s computer, that stores and displays the infringing 

image,” and “Google’s search engine communicates HTML instructions that tell a user’s browser 

where to find full-size images on a website publisher’s computer, but Google does not itself 

distribute copies of the infringing photographs”); Yandex, 962 F. Supp. 2d at 1152-53 (hosting of

infringing images on Russian servers are extraterritorial acts that are not actionable under U.S. 

copyright law). 

Synopsys’ call-home data includes 14 MAC addresses. (Taylor Decl. ¶ 6.) A MAC 

address is a unique identification number for an electronic device. (Tsai Decl. ¶ 7.) The 14 MAC 

addresses correspond to three UNIL servers located in Taiwan, and to virtual machines located on 

those servers (see Tsai Decl. ¶¶ 7-9), but only 3 of the 14 MAC addresses appear in the entries 

where “USA” is listed as the country. (Declaration of Shahin Nazarian (“Nazarian Decl.”) ¶ 8.) 

The three UNIL servers have never left UNIL’s facility in Taiwan. (Tsai Decl. ¶ 11.) Notably, 

the MAC addresses for Tsai’s own computers do not appear at all in the call-home data, including 

in the call-home data for entries where “USA” is listed as the country, even though Tsai used his 

laptop while in the U.S. to initiate simulations remotely in Taiwan. (Id. ¶¶ 10, 14-15.) This is not 
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surprising because, as explained by Defendants’ expert, Professor Shahin Nazarian of the 

University of Southern California Viterbi School of Engineering, the MAC addresses in the callhome data identifying “USA” as the country are for servers in Taiwan. (Nazarian Decl. ¶¶ 7-11.) 

Given this, there is no support for a claim that any Synopsys software was installed on Tsai’s 

computers. (Id. ¶ 12.) Likewise, there is no support for a claim that Synopsys’ software was 

installed anywhere other than on servers and virtual machines in Taiwan. Thus, the facts here are 

analogous to those in Allarcom, where the Ninth Circuit held that there was no liability under the 

U.S. copyright laws where transmissions were initiated or authorized from the U.S., but 

completed in Canada. Allarcom, 69 F.3d at 387.

Nevertheless, even though there is no reason to believe that they ever had Synopsys 

software installed on them, Defendants have already imaged Tsai’s computers and will make 

them available to Synopsys for inspection as soon as the parties agree to an inspection 

protocol. (Taylor Decl. ¶ 5.) Defendants are willing to do the same for the computers of ShengFeng Wang, the only team member based in the U.S., not because Synopsys has come forward 

with any justification for believing that they ever had Synopsys software installed on them, but 

because inspecting them will prove that they did not. There is absolutely no justification for 

inspecting any other devices based upon claims that Synopsys’ software was used from the 

United States. It is Synopsys’ burden to show that it is seeking discovery “relevant to any party’s 

claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1) (emphasis 

added). It has not and its requests for further imaging or inspection should be denied.

CONCLUSION

Defendants believe Judge Orrick will rule on summary judgment that none of the 39,000 

alleged license-key circumventions that happened in Taiwan—as could only have happened since 

Synopsys’ software was hosted on servers in Taiwan—is actionable under the DMCA. Thus,

Defendants believe that there is no basis to permit Synopsys to forensically inspect 29 or more 

employee computers and servers located in Taiwan, considering the immense burden and expense 

of coordinating such inspection, and the disproportionality of the requests based on their marginal

value to the case.
11

CASE NO. 3:17-CV-00561-WHO (LB)

DEFENDANTS’ BRIEF IN OPPOSITION TO SYNOPSYS’ REQUESTS FOR INSPECTION

sf-3854153

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Dated: December 29, 2017 JENNIFER LEE TAYLOR

STACEY M. SPRENKEL

JOYCE LIOU

AMANDA D. PHILLIPS

MORRISON & FOERSTER LLP

By: 

JENNIFER LEE TAYLOR

Attorneys for 

Defendants/Counterclaimants

UBIQUITI NETWORKS, INC., 

UBIQUITI NETWORKS 

INTERNATIONAL LIMITED, and

Defendant CHING-HAN TSAI