IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
WEBMAP TECHNOLOGIES LLC
v. Civil Action No. 2:09-CV-343-DF-CE
CITY ACCOMODATIONS NETWORK, INC.; CITYSEARCH, LLC; EXPEDIA, INC. IAC/INTERACTIVECORP; GOOGLE, INC.; THE WASHINGTON POST COMPANY; TRAVELOCITY.COM, LP; TRIPADVISOR LLC; YAHOO! INC.; YELP! INC.; ZAGAT SURVEY, LLC; GARMIN INTERNATIONAL, INC.; GARMIN LTD.; GARMIN USA, INC.; GLOBALMOTION MEDIA INC.; GUSTO, LLC; GUSTO.COM, INC.; GUSTO.COM, LLC MAPMYFITNESS, INC.; MASHUP TECHNOLOGIES, LLC; TOMTOM INTERNATIONAL BV; TOMTOM, INC. A/K/A TOMTOM NAVIGATION, INC.; TOMTOM NV; AND YOUMU, INC. JURY TRIAL DEMANDED
THIRD AMENDED COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff WebMap Technologies LLC files this Third Amended Complaint against CITY
ACCOMODATIONS NETWORK, INC.; CITYSEARCH, LLC; EXPEDIA, INC.; GOOGLE,
INC.; IAC/INTERACTIVECORP; THE WASHINGTON POST COMPANY;
TRAVELOCITY.COM, LP; TRIPADVISOR LLC; YAHOO! INC.; YELP! INC.; ZAGAT
SURVEY, LLC; GARMIN INTERNATIONAL, INC.; GARMIN LTD.; GARMIN USA, INC.; GLOBALMOTION MEDIA INC.; GUSTO, LLC; GUSTO.COM, INC.; GUSTO.COM, LLC;
MAPMYFITNESS, INC.; MASHUP TECHNOLOGIES, LLC; TOMTOM INTERNATIONAL
BV; TOMTOM, INC. A/K/A TOMTOM NAVIGATION, INC.; TOMTOM NV; and YOUMU,
INC. (collectively "Defendants").
PARTIES
1. WebMap Technologies LLC (“WebMap Technologies” or “Plaintiff”) is a Texas
Limited Liability Company with its principal place of business in Frisco, Texas.
2. On information and belief, Defendant CITY ACCOMODATIONS NETWORK,
INC., a/k/a U.S. Travel Group, and d/b/a Riverwalk Hotel Map, and d/b/a Airport Hotel Guide,
and d/b/a Austin Hotel Map (“CAN”) is an Arizona corporation with its principal place of
business in Queen Creek, Arizona.
3. On information and belief, Defendant CITYSEARCH, LLC (“CITYSEARCH”) is
a Delaware corporation with its principal place of business in Queen Creek, Arizona.
4. On information and belief, Defendant EXPEDIA, INC. (“EXPEDIA”) is a
Washington corporation with its principal place of business in Bellevue, Washington.
5. On information and belief, Defendant GOOGLE, INC. (“GOOGLE”) is a
Delaware corporation with its principal place of business in Mountainview, California.
6. On information and belief, Defendant IAC/INTERACTIVECORP (“IAC”) is a
Delaware corporation with its principal place of business in New York, New York.
7. On information and belief, Defendant THE WASHINGTON POST COMPANY
(“WASHINGTON POST”) is a Delaware corporation with its principal place of business in
Washington, DC.
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8. On information and belief, Defendant TRAVELOCITY.COM, LP
(“TRAVELOCITY”) is a Delaware limited partnership with its principal place of business in
Southlake, Texas.
9. On information and belief, Defendant TRIPADVISOR LLC (“TRIPADVISOR”)
is a Delaware corporation with its principal place of business in Needham, Massachusetts.
10. On information and belief, Defendant YAHOO! INC. (“YAHOO”) is a Delaware corporation with its principal place of business in Sunnyvale, California.
11. On information and belief, Defendant YELP! INC. (“YELP”) is a Delaware corporation with its principal place of business in San Francisco, California.
12. On information and belief, Defendant ZAGAT SURVEY, LLC (“ZAGAT”) is a
Delaware corporation with its principal place of business in New York, New York.
13. On information and belief, Defendant GARMIN INTERNATIONAL, INC.
(“GARMIN INTERNATIONAL”) is a Kansas corporation with its principal place of business in
1200 East 151st Street, Olathe, Kansas 66062.
14. On information and belief, Defendant GARMIN LTD. is a Cayman Islands entity with a place of business in 1200 East 151st Street, Olathe, Kansas 66062 and a place of business in George Town, Cayman Islands.
15. On information and belief, Defendant GARMIN USA, INC. (“GARMIN USA”) is a Kansas corporation with its principal place of business in 1200 East 151st Street, Olathe,
Kansas 66062 (GARMIN INTERNATIONAL, GARMIN LTD. and GARMIN USA are collectively referred to herein as “GARMIN”).
16. On information and belief, Defendant GLOBALMOTION MEDIA INC. corporation with its principal place of business in Palo Alto, California.
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17. On information and belief, Defendant GUSTO, LLC is a Delaware LLC with its principal place of business in Springfield, Missouri.
18. On information and belief, Defendant GUSTO.COM, INC. is a Delaware corporation with its principal place of business in Springfield, Missouri.
19. On information and belief, Defendant GUSTO.COM, LLC is a Delaware or
Missouri LLC or fictitious name with its principal place of business in Springfield, Missouri.
(GUSTO, LLC , GUSTO.COM, INC. and GUSTO.COM, LLC are collectively referred to herein as “GUSTO”).
20. On information and belief, Defendant MAPMYFITNESS, INC.
(“MAPMYFITNESS”) is a Colorado corporation with its principal place of business in Denver,
Colorado.
21. On information and belief, Defendant MASHUP TECHNOLOGIES, LLC
(“MASHUP”) is a Delaware LLC with its principal place of business in Murrysville,
Pennsylvania.
22. On information and belief, Defendant TOMTOM INTERNATIONAL BV
(“TOMTOM INTERNATIONAL”) is a Netherlands corporation with its principal place of business in Amsterdam, Netherlands.
23. On information and belief, Defendant TOMTOM, INC. A/K/A TOMTOM
NAVIGATION, INC. (“TOMTOM, INC.”) is a Massachusetts corporation with its principal place of business in Concord, Massachusetts.
24. On information and belief, Defendant TOMTOM NV (“TOMTOM NV”) is a
Netherlands corporation with its principal place of business in Amsterdam, Netherlands (TOM
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TOM INTERNATIONAL, TOMTOM, INC. and TOMTOM NV are collectively referred to herein as “TOMTOM”).
25. On information and belief, Defendant YOUMU, INC. (“YOUMU”) is a
Washington corporation with its principal place of business in Seattle, Washington.
JURISDICTION AND VENUE
1. This action arises under the patent laws of the United States, Title 35 of the
United States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). On information and belief, Defendants are subject to this Court’s specific and general personal jurisdiction, pursuant to due process and/or the Texas Long Arm Statute, due at least to their substantial business in this forum, including at least a portion of the infringements alleged herein. Without limitation, within this district the Defendants have engaged in at least the making and using of the accused interactive mapping functionality on the websites identified herein below. In addition, on information and belief, Defendants have derived substantial revenues from reviews and bookings in and from this district and nearby areas. Further, on information and belief, Defendants are subject to the Court’s general jurisdiction, including from regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals in Texas.
2. Venue is proper in this district under 28 U.S.C. §§ 1391(b), 1391(c) and 1400(b).
On information and belief, from and within this Judicial District each Defendant has committed at least a portion of the infringements at issue in this case. Without limitation, within this district the Defendants have engaged in the making and using of the accused interactive mapping functionality on the websites identified herein below. Also, Defendants have induced and contributed to infringing end use within this district of the accused interactive mapping
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functionality on the websites identified herein below. In addition, on information and belief,
Defendants have derived substantial revenues from reviews and bookings in and from this
district and nearby areas.
COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,772,142
3. United States Patent No. 6,772,142 (“the ‘142 Patent”) entitled “Method and
Apparatus for Collecting and Expressing Geographically-Referenced Data” was filed on October
31, 2000 and duly and legally issued on August 3, 2004. A true and correct copy of the ‘142
Patent is Exhibit A to Plaintiff’s prior complaints. The inventors of the ‘142 Patent assigned the entire right, title and interest in and to the ‘142 Patent jointly to Cornell Research Foundation,
Inc. (“Cornell”) and the National Audubon Society, Inc. (“Audubon”). Audubon and Cornell entered into an agreement whereby Audubon authorized Cornell to act on its behalf relative to the ‘142 Patent. Prior to this suit being filed, Cornell, on behalf of itself and Audubon, granted an exclusive worldwide license under and all substantial rights to the ‘142 Patent to Acacia Patent
Acquisition LLC (“APAC”). Prior to this suit being filed, APAC assigned all of its rights in the
‘142 Patent to WebMap, which is the exclusive licensee of, and owner of all substantial rights to the ‘142 Patent. Accordingly, WebMap has standing to bring this lawsuit for infringement of the
‘142 patent.
4. On information and belief, Defendant CAN has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising River Walk Hotel Map found at www.riverwalkhotelmap.com, Austin Hotel Map found at www.austinhotelmap.com and/or the
Airport Hotel Map pages of Airport Hotel Guide found at www.airporthotelguide.com, including
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relative to receiving first geographical locations and associated data, for example reviews, from
observers, storing the data, receiving inquiries from users specifying locations, and providing
data associated with user specified locations. Defendant CAN is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
5. On information and belief, Defendant CITYSEARCH has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising www.citysearch.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant CITYSEARCH is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
6. On information and belief, Defendant EXPEDIA has been and now is directly infringing the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising www.expedia.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant EXPEDIA is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
On information and belief, Defendant GOOGLE has been and now is directly infringing the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously
7 disclosed Accused Instrumentalities comprising Google Maps (e.g., http://maps.google.com) and
Google Earth, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Moreover, on information and belief, Defendant GOOGLE has been and now is indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by providing all or portions of the interactive mapping functionality described in this paragraph to at least CAN, URBAN SPOON,
TRIPADVISOR, WASHINGTON POST, YELP, GLOBALMOTION, GUSTO,
MAPMYFITNESS, MASHUP, TOMTOM and/or YOUMU. Defendant GOOGLE is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
7. On information and belief, Defendant IAC has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United
States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising www.urbanspoon.com and www.citysearch.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant IAC is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
8. On information and belief, Defendant WASHINGTON POST has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising the “Going Out
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Guide” and www.washingtonpost.com/gog, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant WASHINGTON POST is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
9. On information and belief, Defendant TRAVELOCITY has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising www.travelocity.com
(including the Experience Finder), including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations.
Defendant TRAVELOCITY is thus liable for infringement of the ‘142 Patent pursuant to 35
U.S.C. § 271.
10. On information and belief, Defendant TRIPADVISOR has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously disclosed Accused Instrumentalities comprising www.tripadvisor.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant TRIPADVISOR is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
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11. On information and belief, Defendant YAHOO has been and now is infringing the
‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods of its previously disclosed
Accused Instrumentalities comprising http://maps.yahoo.com, http://travel.yahoo.com/ and/or http://local.yahoo.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Upon information and belief, discovery in this case may show that one or more third-party websites receiving substantial functionality from http://maps.yahoo.com and/or http://local.yahoo.com may also infringe the ‘142 patent, and if such is the case, then YAHOO would be indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘142
Patent in the State of Texas in connection with such websites and such functionality. Defendant
YAHOO is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
12. On information and belief, Defendant YELP has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
United States by actions comprising the interactive mapping methods of its previously disclosed
Accused Instrumentalities comprising the Yelp website at www.yelp.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant YELP is thus liable for infringement of the
‘142 Patent pursuant to 35 U.S.C. § 271
13. On information and belief, Defendant ZAGAT has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
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United States by actions comprising making and using the interactive mapping methods of its
previously disclosed Accused Instrumentalities comprising the Zagat restaurant location and
review website found at www.zagat.com, including relative to receiving first geographical
locations and associated data, for example reviews, from observers, storing the data, receiving
inquiries from users specifying locations, and providing data associated with user specified
locations. Defendant ZAGAT is thus liable for infringement of the ‘142 Patent pursuant to 35
U.S.C. § 271.
14. On information and belief, Defendant GARMIN has been and now is infringing,
at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in
the United States by actions comprising making and using the interactive mapping methods
practiced in connection with Garmin Connect and http://connect.garmin.com, and further in
connection with Garmin devices making uses of the foregoing, including Forerunner and Edge
devices, including relative to receiving first geographical locations and associated data, for
example maps comprising locations and data, from observers, storing the data, receiving
inquiries from users specifying locations, and providing data associated with user specified
locations. Defendant GARMIN is thus liable for infringement of the ‘142 Patent pursuant to 35
U.S.C. § 271. Moreover, on information and belief, Defendant GARMIN has been and now is
indirectly infringing by way of inducing infringement and/or contributing to the infringement of
the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States
by providing all or portions of the interactive mapping functionality described in this paragraph,
including to its customers and/or users.
15. On information and belief, Defendant GLOBALMOTION has been and now is
infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and
11 elsewhere in the United States by actions comprising making and using the interactive mapping methods found at www.everytrail.com, including relative to receiving first geographical locations and associated data, for example maps comprising locations and data, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant GLOBALMOTION is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
16. On information and belief, Defendant GUSTO has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
United States by actions comprising making and using the interactive mapping methods found at www.gusto.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant GUSTO is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
17. On information and belief, Defendant MAPMYFITNESS has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods found at www.mapmyfitness.com, www.mapmyrun.com, www.mapmyride.com, www.mapmywalk.com, www.mapmyhike.com, www.mapmytri.com and/or www.mapmymountain.com, including relative to receiving first geographical locations and associated data, for example maps comprising locations and data, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant MAPMYFITNESS is thus liable for infringement of the ‘142
Patent pursuant to 35 U.S.C. § 271.
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18. On information and belief, Defendant MASHUP has been and now is infringing,
at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in
the United States by actions comprising making and using the interactive mapping methods
found at http://www.mapbuilder.net, including relative to receiving first geographical locations
and associated data, for example maps comprising locations and data, from observers, storing the
data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Defendant MASHUP is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
19. On information and belief, Defendant TOMTOM has been and now is infringing, at least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by actions comprising making and using the interactive mapping methods practiced in connection with TomTom Mapshare and www.tomtom.com, including www.tomtom.com/mapshare, and further in connection with TomTom devices making uses of the foregoing, including the TomTom EASE, 125, 130, 140, 325, 330, 340, 350, 530, 535, 540,
550, 630, 730 and/or 740, and/or the TomTom App, including relative to receiving first geographical locations and associated data, for example maps comprising locations and data, from observers, storing the data, receiving inquiries from users specifying locations, and providing data associated with user specified locations. Moreover, on information and belief,
Defendant TOMTOM has been and now is indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by providing all or portions of the interactive
mapping functionality described in this paragraph, including to its customers and/or users.
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Defendant TOMTOM is thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. §
271.
20. On information and belief, Defendant YOUMU has been and now is infringing, at
least directly, the ‘142 Patent in the State of Texas, in this judicial district, and elsewhere in the
United States by actions comprising making and using the interactive mapping methods found at www.dine.com, including relative to receiving first geographical locations and associated data, for example reviews, from observers, storing the data, receiving inquiries from users specifying
locations, and providing data associated with user specified locations. Defendant YOUMU is
thus liable for infringement of the ‘142 Patent pursuant to 35 U.S.C. § 271.
21. As a result of Defendants’ infringing conduct, Defendants have damaged
WebMap Technologies. Defendants are liable to WebMap Technologies in an amount that
adequately compensates WebMap Technologies for their infringement, which, by law, can be no
less than a reasonable royalty.
22. On information and belief, WebMap Technologies has complied with the marking
requirements of 35 U.S.C. § 287 to the extent required by law.
23. Upon information and belief, at least Google has been aware of the ‘142 patent for some time prior to the filing of this suit, and at least Google’s infringing activities have been willful and objectively reckless since receiving notice of the patent. Further, upon information and belief, CAN, CITYSEARCH, EXPEDIA, GOOGLE, IAC, WASHINGTON POST,
TRAVELOCITY, TRIPADVISOR, YAHOO, YELP and ZAGAT have, at a minimum, continued to infringe the ‘142 Patent during the pendency of this suit, and such infringement has been willful and objectively reckless since said Defendants received notice of the ‘142 Patent.
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24. Further, WebMap reserves the right to take discovery on whether GARMIN,
GLOBALMOTION, GUSTO, MAPMYFITNESS, MASHUP, TOMTOM and YOUMU relative to their awareness/notice of the ‘142 patent prior to the filing of suit. In any event, to the extent
GARMIN, GLOBALMOTION, GUSTO, MAPMYFITNESS, MASHUP, TOMTOM and/or
YOUMU continues to infringe the ‘142 patent during the pendency of this suit, such infringement would necessarily be willful and objectively reckless.
25. Accordingly, WebMap Technologies seeks and/or reserves the right to seek a willfulness finding against Defendants relative to their infringement of the ‘142 patent, in accordance with the above.
26. On information and belief, aside from the knowledge noted above, all Defendants have at least had constructive notice of the ‘142 patent by operation of law, and WebMap and any predecessors-in-interest have complied with any marking requirements of 35 U.S.C. § 287 to the extent required by law.
PRAYER FOR RELIEF
WHEREFORE, WebMap Technologies respectfully requests that this Court enter:
1. A judgment in favor of WebMap Technologies that Defendants have infringed, directly, jointly, and/or indirectly, by way of inducing and/or contributing to the infringement of the ‘142 Patent;
2. A judgment that the Defendants’ infringement is and/or has been willful and objectively reckless;
3. A permanent injunction enjoining Defendants, and their officers, directors, agents, servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in
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active concert therewith from infringement, inducing the infringement of, or contributing to the
infringement of the ‘142 Patent;
4. A judgment and order requiring Defendants to pay WebMap Technologies its damages, costs, expenses, and prejudgment and post-judgment interest for Defendants’ infringement of the ‘142 Patent as provided under 35 U.S.C. § 284;
5. An award to WebMap Technologies for enhanced damages as provided under 35
U.S.C. § 284;
6. A judgment and order finding that this is an exceptional case within the meaning of 35 U.S.C. § 285 and awarding to WebMap Technologies its reasonable attorneys’ fees; and
7. Any and all other relief to which WebMap Technologies may show itself to be entitled.
DEMAND FOR JURY TRIAL
Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
any issues so triable by right.
June 10, 2010 Respectfully submitted,
WEBMAP TECHNOLOGIES LLC
By: /s/ John J. Edmonds John J. Edmonds – LEAD COUNSEL Texas Bar No. 00789758 Michael J. Collins Texas Bar No. 04614510 Henry M. Pogorzelski Texas Bar No. 24007852 COLLINS, EDMONDS & POGORZELSKI, PLLC 709 Sabine Street Houston, Texas 77007 Telephone: (281) 501-3425 Facsimile: (832) 415-2535 [email protected] [email protected] [email protected]
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Andrew W. Spangler State Bar No. 24041960 Spangler Law P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 (903) 753-9300 (903) 553-0403 (fax) [email protected]
ATTORNEYS FOR PLAINTIFF WEBMAP TECHNOLOGIES LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court’s CM/ECF system per Local Rule CV-5(a)(3) on June 10, 2010. New defendants will be served in accordance with the Federal Rules of Civil Procedure and other applicable laws.
/s/ John J. Edmonds____ John J. Edmonds
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