Hyundai Motor Am. v. Depo Auto Parts - Complaint
Hyundai Motor Am. v. Depo Auto Parts - Complaint
Hyundai Motor Am. v. Depo Auto Parts - Complaint
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DEPO AUTO PARTS INDUSTRIAL
CO., LTD., a Taiwanese corporation,
25 and MAXZONE VEHICLE LIGHTING
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CORP., a California corporation,
27 Defendants.
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_________________________________________________________________________________
COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 2 of 24 Page ID #:2
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Exhibit 9 - D645,591 (the “D’591 patent”) Headlamp for Automobiles
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Exhibit 10 - D640,812 (the “D’812 patent”) Headlamp for Automobiles
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Exhibit 11 - D637,319 (the “D’319 patent”) Headlamp for Automobiles
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Exhibit 12 - D631,583 (the “D’583 patent”) Headlamp for Automobiles
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 7 of 24 Page ID #:7
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 8 of 24 Page ID #:8
1 25. Upon information and belief, Defendants have made, had made, used,
2 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
3 import, and/or sell products which infringe the innovative headlamp design of the
4 D'690 patent. The infringing products include, but are not limited to, at least the
5 replacement headlamps advertised by Defendants for the Hyundai Elantra GT at
6 https://depo.com.tw.
7 26. As a direct and proximate result of Defendants' acts of infringement,
8 HYUNDAI has been damaged in an amount not yet determined, including but not
9 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
10 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
11 27. HYUNDAI has been irreparably harmed by Defendants' infringing
12 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
13 the future unless those infringing activities are enjoined by this Court because, inter
14 alia, HYUNDAI and Defendants directly compete for sales of the replacement
15 headlamps.
16 28. Upon information and belief, Defendants' infringement of the D'690
17 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
18 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
19 29. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
20 below.
21 THIRD CLAIM FOR RELIEF
22 (Infringement of the D’476 patent)
23 30. HYUNDAI incorporates and realleges paragraphs 1 through 29 of this
24 Complaint.
25 31. Upon information and belief, Defendants have made, had made, used,
26 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
27 import, and/or sell products which infringe the innovative headlamp design of the
28 D'476 patent. The infringing products include, but are not limited to, at least the
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 10 of 24 Page ID #:10
1 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
2 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
3 39. HYUNDAI has been irreparably harmed by Defendants' infringing
4 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
5 the future unless those infringing activities are enjoined by this Court because, inter
6 alia, HYUNDAI and Defendants directly compete for sales of the replacement
7 headlamps.
8 40. Upon information and belief, Defendants' infringement of the D'690
9 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
10 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
11 41. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
12 below.
13 FIFTH CLAIM FOR RELIEF
14 (Infringement of the D’898 patent)
15 42. HYUNDAI incorporates and realleges paragraphs 1 through 41 of this
16 Complaint.
17 43. Upon information and belief, Defendants have made, had made, used,
18 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
19 import, and/or sell products which infringe the innovative headlamp design of the
20 D'898 patent. The infringing products include, but are not limited to, at least the
21 replacement headlamps advertised by Defendants for the Hyundai Genesis at
22 https://depo.com.tw.
23 44. As a direct and proximate result of Defendants' acts of infringement,
24 HYUNDAI has been damaged in an amount not yet determined, including but not
25 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
26 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
27 45. HYUNDAI has been irreparably harmed by Defendants' infringing
28 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 12 of 24 Page ID #:12
1 the future unless those infringing activities are enjoined by this Court because, inter
2 alia, HYUNDAI and Defendants directly compete for sales of the replacement
3 headlamps.
4 46. Upon information and belief, Defendants' infringement of the D'898
5 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
6 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
7 47. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
8 below.
9 SIXTH CLAIM FOR RELIEF
10 (Infringement of the D’897 patent)
11 48. HYUNDAI incorporates and realleges paragraphs 1 through 47 of this
12 Complaint.
13 49. Upon information and belief, Defendants have made, had made, used,
14 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
15 import, and/or sell products which infringe the innovative headlamp design of the
16 D'897 patent. The infringing products include, but are not limited to, at least the
17 replacement headlamps advertised by Defendants for the Hyundai Genesis at
18 https://depo.com.tw.
19 50. As a direct and proximate result of Defendants' acts of infringement,
20 HYUNDAI has been damaged in an amount not yet determined, including but not
21 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
22 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
23 51. HYUNDAI has been irreparably harmed by Defendants' infringing
24 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
25 the future unless those infringing activities are enjoined by this Court because, inter
26 alia, HYUNDAI and Defendants directly compete for sales of the replacement
27 headlamps.
28 52. Upon information and belief, Defendants' infringement of the D'897
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 13 of 24 Page ID #:13
1 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
2 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
3 53. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
4 below.
5 SEVENTH CLAIM FOR RELIEF
6 (Infringement of the D’835 patent)
7 54. HYUNDAI incorporates and realleges paragraphs 1 through 53 of this
8 Complaint.
9 55. Upon information and belief, Defendants have made, had made, used,
10 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
11 import, and/or sell products which infringe the innovative headlamp design of the
12 D'835 patent. The infringing products include, but are not limited to, at least the
13 replacement headlamps advertised by Defendants for the Hyundai Accent at
14 https://depo.com.tw.
15 56. As a direct and proximate result of Defendants' acts of infringement,
16 HYUNDAI has been damaged in an amount not yet determined, including but not
17 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
18 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
19 57. HYUNDAI has been irreparably harmed by Defendants' infringing
20 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
21 the future unless those infringing activities are enjoined by this Court because, inter
22 alia, HYUNDAI and Defendants directly compete for sales of the replacement
23 headlamps.
24 58. Upon information and belief, Defendants' infringement of the D'835
25 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
26 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
27 59. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
28 below.
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 14 of 24 Page ID #:14
1 67. Upon information and belief, Defendants have made, had made, used,
2 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
3 import, and/or sell products which infringe the innovative headlamp design of the
4 D'591 patent. The infringing products include, but are not limited to, at least the
5 replacement headlamps advertised by Defendants for the Hyundai Azera.
6 68. As a direct and proximate result of Defendants' acts of infringement,
7 HYUNDAI has been damaged in an amount not yet determined, including but not
8 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
9 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
10 69. HYUNDAI has been irreparably harmed by Defendants' infringing
11 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
12 the future unless those infringing activities are enjoined by this Court because, inter
13 alia, HYUNDAI and Defendants directly compete for sales of the replacement
14 headlamps.
15 70. Upon information and belief, Defendants' infringement of the D'591
16 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
17 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
18 71. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
19 below.
20 TENTH CLAIM FOR RELIEF
21 (Infringement of the D’812 patent)
22 72. HYUNDAI incorporates and realleges paragraphs 1 through 71 of this
23 Complaint.
24 73. Upon information and belief, Defendants have made, had made, used,
25 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
26 import, and/or sell products which infringe the innovative headlamp design of the
27 D'812 patent. The infringing products include, but are not limited to, at least the
28 replacement headlamps advertised by Defendants for the Hyundai Elantra at
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 16 of 24 Page ID #:16
1 https://depo.com.tw.
2 74. As a direct and proximate result of Defendants' acts of infringement,
3 HYUNDAI has been damaged in an amount not yet determined, including but not
4 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
5 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
6 75. HYUNDAI has been irreparably harmed by Defendants' infringing
7 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
8 the future unless those infringing activities are enjoined by this Court because, inter
9 alia, HYUNDAI and Defendants directly compete for sales of the replacement
10 headlamps.
11 76. Upon information and belief, Defendants' infringement of the D'812
12 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
13 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
14 77. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
15 below.
16 ELEVENTH CLAIM FOR RELIEF
17 (Infringement of the D’319 patent)
18 78. HYUNDAI incorporates and realleges paragraphs 1 through 77 of this
19 Complaint.
20 79. Upon information and belief, Defendants have made, had made, used,
21 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
22 import, and/or sell products which infringe the innovative headlamp design of the
23 D'319 patent. The infringing products include, but are not limited to, at least the
24 replacement headlamps advertised by Defendants for the Hyundai Sonata Hybrid at
25 https://depo.com.tw.
26 80. As a direct and proximate result of Defendants' acts of infringement,
27 HYUNDAI has been damaged in an amount not yet determined, including but not
28 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 17 of 24 Page ID #:17
1 alia, HYUNDAI and Defendants directly compete for sales of the replacement
2 headlamps.
3 88. Upon information and belief, Defendants' infringement of the D'583
4 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
5 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
6 89. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
7 below.
8 THIRTEENTH CLAIM FOR RELIEF
9 (Infringement of the D’478 patent)
10 90. HYUNDAI incorporates and realleges paragraphs 1 through 89 of this
11 Complaint.
12 91. Upon information and belief, Defendants have made, had made, used,
13 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
14 import, and/or sell products which infringe the innovative headlamp design of the
15 D'478 patent. The infringing products include, but are not limited to, at least the
16 replacement headlamps advertised by Defendants for the Hyundai Sonata at
17 https://depo.com.tw.
18 92. As a direct and proximate result of Defendants' acts of infringement,
19 HYUNDAI has been damaged in an amount not yet determined, including but not
20 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
21 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
22 93. HYUNDAI has been irreparably harmed by Defendants' infringing
23 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
24 the future unless those infringing activities are enjoined by this Court because, inter
25 alia, HYUNDAI and Defendants directly compete for sales of the replacement
26 headlamps.
27 94. Upon information and belief, Defendants' infringement of the D'478
28 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 19 of 24 Page ID #:19
1 109. Upon information and belief, Defendants have made, had made, used,
2 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
3 import, and/or sell products which infringe the innovative headlamp design of the
4 D'003 patent. The infringing products include, but are not limited to, at least the
5 replacement headlamps advertised by Defendants for the Hyundai Elantra at
6 https://depo.com.tw.
7 110. As a direct and proximate result of Defendants' acts of infringement,
8 HYUNDAI has been damaged in an amount not yet determined, including but not
9 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
10 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
11 111. HYUNDAI has been irreparably harmed by Defendants' infringing
12 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
13 the future unless those infringing activities are enjoined by this Court because, inter
14 alia, HYUNDAI and Defendants directly compete for sales of the replacement
15 headlamps.
16 112. Upon information and belief, Defendants' infringement of the D'003
17 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
18 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
19 113. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
20 below.
21 SEVENTEENTH CLAIM FOR RELIEF
22 (Infringement of the D’057 patent)
23 114. HYUNDAI incorporates and realleges paragraphs 1 through 113 of this
24 Complaint.
25 115. Upon information and belief, Defendants have made, had made, used,
26 offered for sale, imported, and/or sold, and continue to make, use, offer for sale,
27 import, and/or sell products which infringe the innovative headlamp design of the
28 D'057 patent. The infringing products include, but are not limited to, at least the
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 22 of 24 Page ID #:22
1 limited to lost profits, price erosion, lost convoyed sales, and, in no event, less than a
2 reasonable royalty and/or damages as defined by 35 U.S.C. § 289.
3 123. HYUNDAI has been irreparably harmed by Defendants' infringing
4 activities, and HYUNDAI will continue to be irreparably harmed by such activities in
5 the future unless those infringing activities are enjoined by this Court because, inter
6 alia, HYUNDAI and Defendants directly compete for sales of the replacement
7 headlamps.
8 124. Upon information and belief, Defendants' infringement of the D'292
9 patent has been and continues to be willful and deliberate and HYUNDAI is entitled
10 to treble damages and attorneys' fees pursuant to 35 U.S.C. § 284.
11 125. WHEREFORE, HYUNDAI prays for judgment as set forth more fully
12 below.
13 PRAYER FOR RELIEF
14 WHEREFORE, HYUNDAI prays for relief, as follows:
15 1. A judgment that Defendants DEPO and MAXZONE have infringed each
16 of HYUNDAI's asserted patents;
17 2. An order and judgment permanently enjoining Defendants DEPO and
18 MAXZONE and their officers, directors, agents, servants, employees, affiliates,
19 attorneys, and all others acting in privity or in concert with them, and their parents,
20 subsidiaries, divisions, successors and assigns, from further acts of infringement of
21 HYUNDAI's asserted patents;
22 3. A judgment awarding HYUNDAI all damages adequate to compensate
23 for DEPO and MAXZONE’s infringement of HYUNDAI's asserted patents, and in no
24 event less than a reasonable royalty for Defendants’ acts of infringement, including all
25 pre-judgment and post-judgment interest at the maximum rate permitted by law;
26 4. A judgment awarding HYUNDAI all damages, including treble damages,
27 based on any infringement found to be willful, pursuant to 35 U.S.C. § 284, together
28 with prejudgment interest;
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1 Filed 12/04/18 Page 24 of 24 Page ID #:24
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DEMAND FOR JURY TRIAL
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Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, HYUNDAI
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hereby demands trial by jury on all issues raised by the Complaint.
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COMPLAINT FOR PATENT INFRINGEMENT
Case No. __________________
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 1 of 9 Page ID #:25
EXHIBIT 1
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 2 of 9 Page ID #:26
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 3 of 9 Page ID #:27
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 4 of 9 Page ID #:28
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 5 of 9 Page ID #:29
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 6 of 9 Page ID #:30
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 7 of 9 Page ID #:31
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 8 of 9 Page ID #:32
Case 8:18-cv-02151 Document 1-1 Filed 12/04/18 Page 9 of 9 Page ID #:33
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 1 of 9 Page ID #:34
EXHIBIT 2
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 2 of 9 Page ID #:35
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 3 of 9 Page ID #:36
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 4 of 9 Page ID #:37
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 5 of 9 Page ID #:38
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 6 of 9 Page ID #:39
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 7 of 9 Page ID #:40
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 8 of 9 Page ID #:41
Case 8:18-cv-02151 Document 1-2 Filed 12/04/18 Page 9 of 9 Page ID #:42
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 1 of 9 Page ID #:43
EXHIBIT 3
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 2 of 9 Page ID #:44
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 3 of 9 Page ID #:45
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 4 of 9 Page ID #:46
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 5 of 9 Page ID #:47
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 6 of 9 Page ID #:48
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 7 of 9 Page ID #:49
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 8 of 9 Page ID #:50
Case 8:18-cv-02151 Document 1-3 Filed 12/04/18 Page 9 of 9 Page ID #:51
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 1 of 9 Page ID #:52
EXHIBIT 4
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 2 of 9 Page ID #:53
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 3 of 9 Page ID #:54
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 4 of 9 Page ID #:55
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 5 of 9 Page ID #:56
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 6 of 9 Page ID #:57
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 7 of 9 Page ID #:58
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 8 of 9 Page ID #:59
Case 8:18-cv-02151 Document 1-4 Filed 12/04/18 Page 9 of 9 Page ID #:60
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 1 of 9 Page ID #:61
EXHIBIT 5
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 2 of 9 Page ID #:62
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 3 of 9 Page ID #:63
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 4 of 9 Page ID #:64
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 5 of 9 Page ID #:65
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 6 of 9 Page ID #:66
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 7 of 9 Page ID #:67
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 8 of 9 Page ID #:68
Case 8:18-cv-02151 Document 1-5 Filed 12/04/18 Page 9 of 9 Page ID #:69
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 1 of 9 Page ID #:70
EXHIBIT 6
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 2 of 9 Page ID #:71
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 3 of 9 Page ID #:72
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 4 of 9 Page ID #:73
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 5 of 9 Page ID #:74
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 6 of 9 Page ID #:75
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 7 of 9 Page ID #:76
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 8 of 9 Page ID #:77
Case 8:18-cv-02151 Document 1-6 Filed 12/04/18 Page 9 of 9 Page ID #:78
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 1 of 9 Page ID #:79
EXHIBIT 7
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 2 of 9 Page ID #:80
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 3 of 9 Page ID #:81
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 4 of 9 Page ID #:82
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 5 of 9 Page ID #:83
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 6 of 9 Page ID #:84
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 7 of 9 Page ID #:85
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 8 of 9 Page ID #:86
Case 8:18-cv-02151 Document 1-7 Filed 12/04/18 Page 9 of 9 Page ID #:87
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 1 of 9 Page ID #:88
EXHIBIT 8
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 2 of 9 Page ID #:89
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 3 of 9 Page ID #:90
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 4 of 9 Page ID #:91
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 5 of 9 Page ID #:92
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 6 of 9 Page ID #:93
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 7 of 9 Page ID #:94
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 8 of 9 Page ID #:95
Case 8:18-cv-02151 Document 1-8 Filed 12/04/18 Page 9 of 9 Page ID #:96
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 1 of 9 Page ID #:97
EXHIBIT 9
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 2 of 9 Page ID #:98
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 3 of 9 Page ID #:99
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 4 of 9 Page ID #:100
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 5 of 9 Page ID #:101
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 6 of 9 Page ID #:102
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 7 of 9 Page ID #:103
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 8 of 9 Page ID #:104
Case 8:18-cv-02151 Document 1-9 Filed 12/04/18 Page 9 of 9 Page ID #:105
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 1 of 9 Page ID #:106
EXHIBIT 10
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 2 of 9 Page ID #:107
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 3 of 9 Page ID #:108
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 4 of 9 Page ID #:109
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 5 of 9 Page ID #:110
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 6 of 9 Page ID #:111
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 7 of 9 Page ID #:112
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 8 of 9 Page ID #:113
Case 8:18-cv-02151 Document 1-10 Filed 12/04/18 Page 9 of 9 Page ID #:114
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 1 of 9 Page ID #:115
EXHIBIT 11
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 2 of 9 Page ID #:116
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 3 of 9 Page ID #:117
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 4 of 9 Page ID #:118
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 5 of 9 Page ID #:119
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 6 of 9 Page ID #:120
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 7 of 9 Page ID #:121
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 8 of 9 Page ID #:122
Case 8:18-cv-02151 Document 1-11 Filed 12/04/18 Page 9 of 9 Page ID #:123
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 1 of 9 Page ID #:124
EXHIBIT 12
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 2 of 9 Page ID #:125
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 3 of 9 Page ID #:126
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 4 of 9 Page ID #:127
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 5 of 9 Page ID #:128
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 6 of 9 Page ID #:129
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 7 of 9 Page ID #:130
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 8 of 9 Page ID #:131
Case 8:18-cv-02151 Document 1-12 Filed 12/04/18 Page 9 of 9 Page ID #:132
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 1 of 9 Page ID #:133
EXHIBIT 13
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 2 of 9 Page ID #:134
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 3 of 9 Page ID #:135
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 4 of 9 Page ID #:136
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 5 of 9 Page ID #:137
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 6 of 9 Page ID #:138
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 7 of 9 Page ID #:139
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 8 of 9 Page ID #:140
Case 8:18-cv-02151 Document 1-13 Filed 12/04/18 Page 9 of 9 Page ID #:141
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 1 of 9 Page ID #:142
EXHIBIT 14
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 2 of 9 Page ID #:143
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 3 of 9 Page ID #:144
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 4 of 9 Page ID #:145
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 5 of 9 Page ID #:146
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 6 of 9 Page ID #:147
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 7 of 9 Page ID #:148
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 8 of 9 Page ID #:149
Case 8:18-cv-02151 Document 1-14 Filed 12/04/18 Page 9 of 9 Page ID #:150
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 1 of 9 Page ID #:151
EXHIBIT 15
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 2 of 9 Page ID #:152
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 3 of 9 Page ID #:153
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 4 of 9 Page ID #:154
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 5 of 9 Page ID #:155
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 6 of 9 Page ID #:156
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 7 of 9 Page ID #:157
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 8 of 9 Page ID #:158
Case 8:18-cv-02151 Document 1-15 Filed 12/04/18 Page 9 of 9 Page ID #:159
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 1 of 9 Page ID #:160
EXHIBIT 16
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 2 of 9 Page ID #:161
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 3 of 9 Page ID #:162
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 4 of 9 Page ID #:163
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 5 of 9 Page ID #:164
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 6 of 9 Page ID #:165
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 7 of 9 Page ID #:166
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 8 of 9 Page ID #:167
Case 8:18-cv-02151 Document 1-16 Filed 12/04/18 Page 9 of 9 Page ID #:168
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 1 of 9 Page ID #:169
EXHIBIT 17
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 2 of 9 Page ID #:170
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 3 of 9 Page ID #:171
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 4 of 9 Page ID #:172
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 5 of 9 Page ID #:173
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 6 of 9 Page ID #:174
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 7 of 9 Page ID #:175
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 8 of 9 Page ID #:176
Case 8:18-cv-02151 Document 1-17 Filed 12/04/18 Page 9 of 9 Page ID #:177
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 1 of 9 Page ID #:178
EXHIBIT 18
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 2 of 9 Page ID #:179
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 3 of 9 Page ID #:180
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 4 of 9 Page ID #:181
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 5 of 9 Page ID #:182
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 6 of 9 Page ID #:183
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 7 of 9 Page ID #:184
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 8 of 9 Page ID #:185
Case 8:18-cv-02151 Document 1-18 Filed 12/04/18 Page 9 of 9 Page ID #:186