IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION 

ADVANCED TRANSACTIONS, LLC, 

 Plaintiff, 

 v. 

AMERICAN AIRLINES, INC., 

 Defendant. 

 Case No. 4:23-cv-00558 

 Jury Trial Demanded 

 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Advanced Transactions, LLC (“Advanced Transactions”) files this 

Complaint against American Airlines, Inc. for infringement of United States Patent 

Nos.: 6,986,460 and RE 43,351 (the “Patents-in-Suit”), and alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for patent infringement arising under the patent laws of 

the United States, 35 U.S.C. §§ 1 et seq.

THE PARTIES 

2. Advanced Transactions is a limited liability company organized under 

laws of the State of Georgia with its principal place of business situated at the Day 

Building, Suite 230, 4725 Peachtree Corners Circle, Peachtree Corners, GA 30092. 

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3. On information and belief, defendant American Airlines, Inc. is a 

corporation organized and existing under the laws of the state of Delaware with a 

principal place of business at One Skyview Drive, Fort Worth, Texas 76155. 

4. On information and belief, American Airlines, Inc. may be served with 

process through its registered agent, Corporation Service Company d/b/a CSCLawyers Inc., 211 East 7th Street, Suite 620, Austin, Texas 78701 or anywhere it may be 

found. 

5. American Airlines, Inc. has been authorized to do business in the State of 

Texas and the Eastern District of Texas since at least June 13, 1934, under Texas SoS File 

Number 0000816206. 

6. On information and belief, American Airlines, Inc. (hereinafter “American 

Airlines” or “Defendant”) sold and offered to sell products and services throughout 

Texas, including in this judicial district, as well as throughout the United States, and 

introduced products and services that performed infringing processes into the stream of 

commerce knowing that they would be used, offered for sale, or sold in this judicial 

district and elsewhere in the United States. 

7. On information and belief, American Airlines has made, used, offered to 

sell and/or sold products and services, including the following specifically accused 

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products and services: (1) Inflight Wi-Fi;1 (2) U.S Domestic Wi-Fi;2 (3) All-Day Pass;3

(4)Traveler Pass;4 (5) International Wi-Fi;5 (6) AAInFlight.com;6 (7) AA.com/wifi; (8) 

current or legacy products or services, which have used, one or more of the foregoing 

products and services as a component product or component service; (9) combinations 

of products and/or services comprising, in whole or in part, two or more of the 

foregoing products and services; and (10) all other current or legacy products and 

services imported, made, used, sold, or offered for sale by American Airlines that have 

operated in a substantially similar manner as the above-listed products and services. 

(As used herein, one or more of the forgoing products and services are individually and 

collectively referred to as the accused “American Airlines WI-FI Products and 

Services”). 

1 See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

2 See e.g., 

https://www.aa.com/reservation/orderWifiMenuAll.do?recordLocator=PLDELT&path=ViewRes

ervation&wifiType=wifiAll. 

3 See e.g., 

https://www.aa.com/reservation/orderWifiMenuAll.do?recordLocator=PLDELT&path=ViewRes

ervation&wifiType=wifiAll. 

4 See e.g., 

https://www.aa.com/reservation/orderWifiMenuAll.do?recordLocator=PLDELT&path=ViewRes

ervation&wifiType=wifiAll. 

5 See e.g., 

https://www.aa.com/reservation/orderWifiMenuAll.do?recordLocator=PLDELT&path=ViewRes

ervation&wifiType=wifiAll. 

6 See e.g, https://inflightwifi.one/aainflight/; https://support.aainflight.com.

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8. On information and belief, American Airlines, as well as the hardware 

and software components comprising the American Airlines Wi-Fi Products and 

Services and/or that enabled the American Airlines Wi-Fi Products and Services to 

operate, including but not limited to servers, server software, webserver software, 

webserver hardware, airplane-based hardware and software; ground-based hardware 

and software; payment processing hardware; payment processing software; network 

connectivity hardware and software; website client software, mobile computing device 

client application software, network routers, network switches, network hubs, WIFI 

access point hardware, WIFI access point software, point-of-sale hardware, point-of-sale 

software, wireless antennas, satellite antennas, air-to-ground antennas, back-end 

hardware, back-end software, cloud-based software, cloud-based hardware, and other 

hardware and software computing systems and components (individually and 

collectively referred to herein as the accused “American Airlines Wi-Fi System”), 

infringed (literally and/or under the doctrine of equivalents) at least one claim of each 

of the Patents-in-Suit. 

JURISDICTION AND VENUE 

9. This Court has personal jurisdiction over American Airlines because it 

committed acts of infringement in this judicial district in violation of 35 U.S.C. § 271(a). 

In particular, on information and belief, American Airlines has made, used, offered to 

sell access to, and/or sold access to the accused American Airlines Wi-Fi Products and 

Services in the Eastern District of Texas, and has made, used, offered to sell access to, 

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and/or sold access to the American Airlines Wi-Fi System in the Eastern District of 

Texas. 

10. On information and belief, American Airlines is subject to the Court’s 

jurisdiction because it regularly conducts and solicits business, or otherwise engages in 

other persistent courses of conduct in this judicial district, and/or derived substantial 

revenue from the use, sale, and distribution of goods and services, including but not 

limited to the accused American Airlines Wi-Fi Products and Services provided to 

individuals and businesses in the Eastern District of Texas. 

11. On information and belief, American Airlines infringed the patents-in-suit 

in the Eastern District of Texas, at least, by making, using, offering to sell access to, 

and/or selling access to the accused American Airlines Wi-Fi Products and Services in 

the Eastern District of Texas, and its making, use, offering to sell access to, and/or 

selling access to the American Airlines Wi-Fi System. 

12. On information and belief, American Airlines is a major US-based airline 

and operates at least 346 ticket counters in 62 countries. 

13. Indeed, on information and belief, American Airlines operates ticket 

counters in at least 26 airports in the State of Texas alone,7 with airline services 

originating in and operating in the skies above this judicial district. 

14. Further, this Court has personal jurisdiction over American Airlines 

because it has engaged, and continues to engage, in continuous, systematic, and 

7 See https://www.aa.com/booking/find-flights?tripType=roundTrip.

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substantial activities within this State, including the substantial marketing and sale of 

products and services within this State and this District. Indeed, this Court has personal 

jurisdiction over American Airlines because it has committed acts giving rise to 

Advanced Transactions’ claims for patent infringement within and directed to this 

District, has derived substantial revenue from its goods and services provided to 

individuals in this State and this District, and maintains regular and established places 

of business in this District, including at least its airplanes, operations centers, terminals, 

ticket counters, and other places of business used to facilitate flights to and from the 

Tyler Pounds Regional Airport in Tyler, TX and the Jack Brooks Regional Airport in 

Beaumont/Port Arthur, TX. 

15. On information and belief, personal jurisdiction is appropriate in this 

Judicial District because American Airlines has availed itself of the Courts in this 

Judicial District, including, at least, by its filing of counterclaims in this Judicial District. 

16. On information and belief, the accused American Airlines Wi-Fi Products 

and Services and/or the American Airlines Wi-Fi System were used, sold and offered 

for sale by American Airlines, or its agents, on board American Airlines airplanes, 

including those airplanes located in the Eastern District of Texas. 

17. On information and belief, American Airlines customers located in the 

Eastern District of Texas have obtained access to and used the accused American 

Airlines Wi-Fi Products and Services and/or the American Airlines Wi-Fi System while 

located in the Eastern District of Texas. 

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18. The Court has personal jurisdiction over American Airlines at least 

because it has continuous business contacts in the State of Texas and in the Eastern 

District of Texas; American Airlines has engaged in business activities including 

transacting business in the Eastern District of Texas and purposefully directing its 

business activities, including the sale or the offering for sale of the American Airlines 

Wi-Fi Products and Services into the Eastern District of Texas. 

19. This Court has personal jurisdiction over American Airlines because, inter 

alia, American Airlines, on information and belief: (1) has committed acts of patent 

infringement in this Eastern District of Texas; (2) maintains a regular and established 

place of business in the Eastern District of Texas; (3) has substantial, continuous, and 

systematic contacts with this State and the Eastern District of Texas; (4) owns, manages, 

and operates facilities in this State and the Eastern District of Texas; (5) enjoys 

substantial income from its operations and sales in this State and the Eastern District of 

Texas; (6) employs Texas residents in this State and the Eastern District of Texas, and (7) 

solicits business related to the accused American Airlines Wi-Fi Products and Services 

and American Airlines Wi-Fi System in this State and the Eastern District of Texas. 

20. On information and belief, American Airlines solicited Texas-based 

customers for its infringing products and services, including American Airlines’ Wi-Fi 

Products and Services in the State of Texas and in this Judicial District. 

21. Venue is proper pursuant to 28 U.S.C. §§ 1391(b), (c), (d) and/or 1400(b), 

at least because American Airlines, has committed acts of infringement in this judicial 

district, and has regular and established places of business in this judicial district. 

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22. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b) 

because American Airlines has regular and established places of business in the District, 

including the operations centers, terminals, ticket counters, airplanes, and other 

equipment and facilities at the Tyler Pounds Regional Airport and the Jack Brooks 

Regional Airport. Venue is further proper in this District because American Airlines has 

directly infringed the patents-in-suit in this District. American Airlines has conducted 

business in this District, including marketing and providing the American Airlines’ WiFi Products and Services to customers located in this District. Moreover, American 

Airlines’ activities and the actions of the American Airlines’ Wi-Fi Products and 

Services in this District constituted substantial infringements of the patents-in-suit. 

United States Patent No. 6,986,460 

23. On January 17, 2006, the USPTO duly and legally issued United States 

Patent No. 6,986,460 (“the ’460 patent”) entitled “Credit Card Validation for an 

Interactive Wireless Network” to inventor Royce D. Jordan, Jr. 

24. The ’460 patent is presumed valid under 35 U.S.C. § 282. 

25. Advanced Transactions owns all rights, title, and interest in the ’460 

patent. 

26. Advanced Transactions has not granted American Airlines an approval, 

an authorization, or a license to the rights under the ’460 patent. 

27. The ’460 patent relates to, among other things, a system for validating a 

credit card over a wireless network. 

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28. The claimed invention(s) of the ’460 patent sought to solve problems with, 

and improve upon, existing credit card validation systems. For example, the ’460 patent 

states: 

Credit card validation requires a predetermined arrangement with various credit 

card validation agencies. For example, Internet online vendors and consumers use 

credit card validation services such as PAYPAL to enable users (e.g., vendors or 

consumers) with an e-mail address to send and receive credit card payments 

online. The PAYPAL validation service uses existing infrastructures of bank 

accounts and credit cards to create a global real-time payment for its users. There 

are, however, no credit card validation services that provide a communication link 

over an interactive wireless network for subscribers to the network. For example, 

there are no credit card validation services that allow a user to obtain credit card 

validation using a wireless device over an interactive wireless network without 

requiring specialized applications and integration. Therefore, there is a need in the 

art to provide a wireless credit card validation service that operates over an 

interactive wireless network that allows a wireless user to obtain credit card 

verification via an interactive message without requiring specialized application 

development. 

See ’460 Specification at col. 1, ll. 17-37.

29. The invention(s) claimed in the ’460 patent solves various technological 

problems inherent in the then-existing existing credit validation systems to, among 

other things, allow wireless users to obtain credit card verification. 

United States Patent No. RE43,351 

30. On May 8, 2012, the USPTO duly and legally issued United States Patent 

No. RE43,351 (“the ’351 patent”) entitled “Credit Card Validation for an Interactive 

Wireless Network” to inventor Royce D. Jordan, Jr. 

31. The ’351 patent is presumed valid under 35 U.S.C. § 282. 

32. Advanced Transactions owns all rights, title, and interest in the ’351 

patent. 

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33. Advanced Transactions has not granted American Airlines an approval, 

an authorization, or a license to the rights under the ’351 patent. 

34. The ’351 patent relates to, among other things, a method and apparatus 

for validating a credit card over a wireless network. 

35. The specification of the ’351 patent is the same as the ’460 patent 

specification, and solves the problems recited above and described in the ’460 patent 

specification. 

CLAIMS FOR RELIEF 

Count I – Infringement of United States Patent No. 6,986,460 

36. Advanced Transactions repeats, realleges, and incorporates by reference, 

as if fully set forth here, the allegations of the preceding paragraphs above. 

37. On information and belief, American Airlines (or those acting on its 

behalf) made, used, sold, imported and/or offered to sell the American Airlines Wi-Fi 

Products and Services; and made, used, sold, sold access to, imported, offered to sell 

and/or offered to sell access to the American Airlines Wi-Fi System in the United States 

that infringed (literally and/or under the doctrine of equivalents) at least claim 1 of the 

’460 patent. 

38. On information and belief, one or more components of the American 

Airlines Wi-Fi System comprise a system for validating a credit card over a wireless 

network. 

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See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

See e.g. https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fiterms/terms-of-use.jsp. 

See e.g., https://american-wifi-subscription.com/app/ssocp/payment/#/pickapass. 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

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39. On information and belief, one or more components of the American 

Airlines Wi-Fi System comprise a system for validating a credit card over a wireless 

network further comprising a wireless communication network (e.g., a wireless 

communication network installed in an American Airlines airplane), for receiving a 

request message (e.g., a message initiated through aainflight.com) including credit card 

information for identifying a credit card (e.g., a credit card number and/or a credit card 

expiration date associated with a credit card belonging to an American Airlines flight 

passenger) to be validated from a wireless device (e.g., a wireless device approved for 

use aboard an American Airlines flight, such as laptop, tablet, or cellphone). 

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

40. On information and belief, one or more components of the American 

Airlines Wi-Fi System comprise a system for validating a credit card over a wireless 

network further comprising a gateway (e.g., server hardware and software installed in 

American Airlines airplanes related to inflight wireless services, including for example 

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one or more of webservers) in communication with the wireless communication 

network, (e.g., a Wi-Fi network that operates inside an American Airlines airplane 

comprising wireless access points, wireless antennas, and/or wired networking 

components such as routers, switches, or hubs installed inside an American Airlines 

airplane) wherein the gateway is for receiving the credit card validation request 

message (e.g., a message initiated through aainflight.com) from the wireless device (e.g., 

a wireless device approved for use aboard an American Airlines flight, such as laptop, 

tablet, or cellphone). 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

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See e.g., https://travelradar.aero/wifi-on-board-how-does-in-flight-wifi-work/. 

41. On information and belief, one or more components of the American 

Airlines Wi-Fi System comprise a system for validating a credit card over a wireless 

network further comprising an external network (e.g., networking hardware and 

software installed in, on the sides of, on the bottom of, or on top of American Airlines 

airplanes related to inflight wireless services, including for example one or more of 

satellite antennas, air-to-ground antennas, and/or wired networking components such 

as routers, switches, or hubs) in communication with the gateway (e.g., server hardware 

and software installed in American Airlines airplanes related to inflight wireless 

services, including for example one or more of webservers) for providing credit card 

validation data to the gateway, (e.g., server hardware and software installed in 

American Airlines airplanes related to inflight wireless services, including for example 

one or more of webservers), wherein the gateway is configured for processing the credit 

card validation data for sending a credit card validation reply message to the wireless 

device. 

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See e.g., https://travelradar.aero/wifi-on-board-how-does-in-flight-wifi-work/. 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/. 

42. On information and belief, one or more components of the American 

Airlines Wi-Fi System comprise a system for validating a credit card over a wireless 

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network wherein the gateway (e.g., server hardware and software installed in American 

Airlines airplanes related to inflight wireless services, including for example one or 

more of webservers) comprises a database for storing the credit card validation reply 

message, (e.g., a message that confirms that a credit card belonging to an American 

Airlines passenger has been successfully used to pay for one or more American Airlines 

Wi-Fi Products and Services) and the database has a directory structure for associating 

the wireless device (e.g., a wireless device approved for use aboard an American 

Airlines flight, such as laptop, tablet, or cellphone) with the credit card validation reply 

message. 

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

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See e.g. https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fiterms/terms-of-use.jsp. 

See e.g., https://american-wifi-subscription.com/app/ssocp/payment/#/pickapass. 

43. Advanced Transactions has been damaged by American Airlines’ 

infringement and suffered damages as a result of this infringement. 

Count II – Infringement of United States Patent No. RE43,351 

44. Advanced Transactions repeats, realleges, and incorporates by reference, 

as if fully set forth here, the allegations of the preceding paragraphs above. 

45. On information and belief, American Airlines (or those acting on its 

behalf) made, used, sold, imported and/or offered to sell the American Airlines Wi-Fi 

Products and Services; and made, used, sold, sold access to, imported, offered to sell 

and/or offered to sell access to the American Airlines Wi-Fi System in the United States 

that infringed (literally and/or under the doctrine of equivalents) at least claim 31 of the 

’351 patent. 

46. On information and belief, one or more components of the American 

Airlines Wi-Fi System practices and provides a method for validating a credit card (e.g., 

a credit card associated with an account that is used to pay for American Airlines Wi-Fi 

Products and Services) over a wireless data network (e.g., a Wi-Fi network that operates 

inside an American Airlines airplane comprising wireless access points, wireless 

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antennas, and/or wired networking components such as routers, switches, or hubs 

installed inside an American Airlines airplane). 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

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47. On information and belief, one or more components of the American 

Airlines Wi-Fi System practices and provides a method for validating a credit card (e.g., 

a credit card associated with an account that is used to pay for American Airlines Wi-Fi 

Products and Services) over a wireless data network (e.g., a Wi-Fi network that operates 

inside an American Airlines airplane comprising wireless access points, wireless 

antennas, and/or wired networking components such as routers, switches, or hubs 

installed inside an American Airlines airplane) comprising the step of processing credit 

card information (e.g., a credit card number and/or a credit card expiration date 

associated with a credit card belonging to an American Airlines flight passenger) 

associated with a credit card to be validated at a wireless communication gateway (e.g., 

server hardware and software installed in American Airlines airplanes related to 

inflight wireless services, including for example one or more of webservers) to be in 

communication with a wireless data network (e.g., a Wi-Fi network that operates inside 

an American Airlines airplane comprising wireless access points, wireless antennas, 

and/or wired networking components such as routers, switches, or hubs installed 

inside an American Airlines airplane), the gateway configured to process credit card 

validation data to be received from an external network (e.g., networking hardware and 

software installed in, on the sides of, on the bottom of, or on top of American Airlines 

airplanes related to inflight wireless services, including for example one or more of 

satellite antennas, air-to-ground antennas, and/or wired networking components such 

as routers, switches, or hubs), the gateway to send a credit card validation reply 

message (e.g., a message that confirms that a credit card belonging to an American 

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Airlines passenger has been successfully used to pay for one or more American Airlines 

Wi-Fi Products and Services) to a wireless device (e.g., a wireless device approved for 

use aboard an American Airlines flight, such as laptop, tablet, or cellphone) in 

communication with the wireless network in response to receiving a credit card 

validation request message from the wireless device, the request message including the 

credit card information for identifying the credit card to be validated. 

See e.g., https://travelradar.aero/wifi-on-board-how-does-in-flight-wifi-work/. 

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

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See e.g. https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fiterms/terms-of-use.jsp. 

See e.g., https://american-wifi-subscription.com/app/ssocp/payment/#/pickapass. 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

48. On information and belief, one or more components of the American 

Airlines Wi-Fi System practices and provides a method for validating a credit card (e.g., 

a credit card associated with an account that is used to pay for American Airlines Wi-Fi 

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Products and Services) over a wireless data network (e.g., a Wi-Fi network that operates 

inside an American Airlines airplane comprising wireless access points, wireless 

antennas, and/or wired networking components such as routers, switches, or hubs 

installed inside an American Airlines airplane), wherein the credit card information 

(e.g., a credit card number and/or a credit card expiration date associated with a credit 

card belonging to an American Airlines flight passenger) is to be processed at the 

gateway (e.g., server hardware and software installed in American Airlines airplanes 

related to inflight wireless services, including for example one or more of webservers) 

by a software application developed independently of external credit card validation 

processes to be provided remotely from the gateway (e.g., credit card validation 

processes caried out remotely by the entity that issued the credit card used to pay for 

American Airlines Wi-Fi Products and Services). 

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fiterms/terms-of-use.jsp. 

See e.g., https://american-wifi-subscription.com/app/ssocp/payment/#/pickapass. 

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49. On information and belief, one or more components of the American 

Airlines Wi-Fi System practices and provides a method for validating a credit card (e.g., 

a credit card associated with an account that is used to pay for American Airlines Wi-Fi 

Products and Services) over a wireless data network (e.g., a Wi-Fi network that operates 

inside an American Airlines airplane comprising wireless access points, wireless 

antennas, and/or wired networking components such as routers, switches, or hubs 

installed inside an American Airlines airplane) comprising the step of storing the credit 

card validation reply message (e.g., a message that confirms that a credit card belonging 

to an American Airlines flight passenger has been successfully used to pay for one or 

more American Airlines Wi-Fi Products and Services) in a database associated with the 

gateway (e.g., server hardware and software installed in American Airlines airplanes 

related to inflight wireless services, including for example one or more of webservers). 

See e.g., https://travelradar.aero/wifi-on-board-how-does-in-flight-wifi-work/. 

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See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

50. On information and belief, one or more components of the American 

Airlines Wi-Fi System practices and provides a method for validating a credit card (e.g., 

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a credit card associated with an account that is used to pay for American Airlines Wi-Fi 

Products and Services) over a wireless data network wherein storing further comprises 

storing the credit card validation reply message (e.g., a message that confirms that a 

credit card belonging to an American Airlines passenger has been successfully used to 

pay for one or more American Airlines Wi-Fi Products and Services) in a database that 

includes a directory structure for associating the wireless device with the credit card 

validation reply message. 

See e.g., https://thepointsguy.com/news/state-of-american-airlines-wifi/.

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See e.g., https://www.aa.com/i18n/travel-info/experience/entertainment/wi-fi-andconnectivity.jsp. 

JURY DEMANDED 

51. Pursuant to Federal Rule of Civil Procedure 38(b), Advanced Transactions 

hereby requests a trial by jury on all issues so triable. 

PRAYER FOR RELIEF 

Advanced Transactions respectfully requests this Court to enter judgment in 

Advanced Transaction’s favor and against American Airlines as follows: 

a. finding that American Airlines has infringed one or more claims of the ’460 

patent under 35 U.S.C. § 271(a); 

b. finding that American Airlines has infringed one or more claims of the ’351 

patent under 35 U.S.C. § 271(a); 

c. awarding Advanced Transactions damages under 35 U.S.C. § 284, or otherwise 

permitted by law; 

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d. awarding Advanced Transactions pre-judgment and post-judgment interest on 

the damages award and costs; 

e. declaring that this case is exceptional and awarding costs of this action 

(including all disbursements) and attorney fees pursuant to 35 U.S.C. § 285, or as 

otherwise permitted by the law; and 

f. awarding such other costs and further relief that the Court determines to be just 

and equitable. 

Dated: June 16, 2023 Respectfully submitted, 

/s/ Zachary H. Ellis 

Zachary H. Ellis* 

Texas State Bar No. 24122606 

zellis@daignaultiyer.com 

Tel. 512-829-7992 

Of Counsel: 

Ronald M. Daignault (pro hac vice to be filed)* 

Chandran B. Iyer (pro hac vice to be filed) 

Oded Burger (admitted to practice)* 

Tedd W. Van Buskirk (pro hac vice to be filed)* 

rdaignault@daignaultiyer.com 

cbiyer@daignaultiyer.com 

oburger@daignaultiyer.com 

tvanbuskirk@daignaultiyer.com 

DAIGNAULT IYER LLP

8618 Westwood Center Drive - Suite 150 

Vienna, VA 22182 

Attorneys for Plaintiff Advanced Transactions, 

LLC 

*Not admitted to practice in Virginia

Case 4:23-cv-00558-ALM Document 1 Filed 06/16/23 Page 27 of 27 PageID #: 27