IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN … · 2020-03-07 · dr. lakshmi arunachalam...

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Dr. Lakshmi Arunachalam

222 Stanford Avenue, Menlo Park, CA 94025

Telephone: (650) 690-0995; Facsimile: (650) 854-3393

Email: [email protected]

Pro Se Plaintiff


IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

DR. LAKSHMI ARUNACHALAM,

Plaintiff,

v.

APPLE, INC., et al,

AND

DOES 1-100,

Defendants.

C.A. No. 4:18-cv-01250-DMR

JURY TRIAL DEMANDED

PLAINTIFF’S MOTION FOR THIS COURT TO GIVE A STATEMENT OF DECISION

ON WHETHER CONTRACT LAW APPLIES TO PATENTS

Plaintiff Dr. Lakshmi Arunachalam (hereafter "Dr. Arunachalam") respectfully files this

Motion for this Court to file a Statement of Decision immediately on the following sole material

issue in this case:

1. Whether Chief Justice Marshall’s ruling in Fletcher v. Peck, 10 U.S. 87 (1810),

prohibiting the quashing of Government issued contract grants applies to Patent Contract Grants

issued by the Government. [U.S. Supreme Court has ruled in subsequent cases in Trustees of

Dartmouth College v. Woodward (1819) as well as the U.S. v. American Bell Telephone

Company (1897) patent case that Fletcher applies to any contract grant, whether it be a

University charter as in Dartmouth in 1819, or if it is patents, as in the U.S. v. American Bell

Telephone Company (1897) patent case.]

Case 5:18-cv-01250-EJD Document 32 Filed 03/18/18 of 28

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2. If so, whether any Court or Legislature or Congress (by the AIA) or

USPTO/PTAB or USITC or any Agency can rescind a patent contract grant without being in

treasonous breach of the Constitution.

3. If so, whether the Legislature, the judiciary, USPTO/PTAB and USITC are in

collusion, aiding and abetting Antitrust and civil RICO violations by the Corporate Defendants

and in violation of the Separation of Powers clause of the Constitution.

The Motion is based upon the attached Memorandum of Points and Authorities and the

following facts and the law:

1) Supreme Court’s Recognition of Public Contract Basis of Patent Rights in Grant v. Raymond

(1832): U.S. Supreme Court J. Marshall articulated the public contract basis of patent grants as

“indispensably necessary to the faithful execution of the solemn promise made

by the United States;”

2) In U.S. v. American Bell Telephone Company (1897); Justice Brewer concluded that

“the differences between the two types of patents give the federal government

“higher rights” to cancel land patents than to cancel patents for inventions. “…the

patent for an invention is not a conveyance of something which the government

owns….The inventor is the one who has discovered something of value. It is his

absolute property….;”

3) Supreme Court’s Recognition of the Public Contract Basis of Patent Rights after Grant v.

Raymond: Shaw v. Cooper (1833); Justice John McLean articulated the contract basis for patent

rights; recognized the public benefit produced by inventive discoveries and the importance of

securing protections for inventors in exchange for that benefit:

“All enlightened governments reward the inventor. He is justly considered a

public benefactor. Many of the most splendid productions of genius, ...have been

conceived and elaborated in a garret or hovel. Such results not only enrich a

nation, but render it illustrious. And should not their authors be cherished and

rewarded? ...But in order that such property should be of any value, it is necessary

that society should interfere actively for its protection. It can interfere by the


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enactment of penalties, which, in order to be effectual, must be severe; or it can

interfere by prohibition, which is a stern and summary exercise of power.”

4) U.S. v. Dubilier Condenser Corp. (1933);

5) Bonito Boats, Inc. v. Thunder Craft Boats, Inc. (1989);

6) James Madison in Federalist No. 44 stated:

“…Patent rights receive protection pursuant to public contracts between inventors

and the federal government, acting on behalf of the people.”

The Judiciary, USPTO/PTAB, USITC and the Legislature/Congress/AIA have failed to provide

the protections they pledged in their Contract with Plaintiff.

7) In Burrow-Giles Lithographic Co. v. Sarony (1884), Justice Samuel Miller stated:

“On the one hand, grants of patents cannot, by law, be issued to the inventor until

the novelty, the utility, and the actual discovery or invention by the claimant have

been established by proof before the commissioner of patents…The public faith is

pledged to the exclusive rights protections set out in the law upon the inventors’

compliance with the corresponding procedures provided in the law.”

Plaintiff satisfied all these requirements before the USPTO granted Plaintiff her patents and

continues paying her maintenance fees to the USPTO, in living up to her end of the Contract.

8) Public Contract Basis of Patent Rights Applied by Lower Courts:

In Celluloid Manufacturing. Co. v. Arlington Manufacturing. Co. (1890), Judge Edward T.

Green of the District Court of New Jersey stated:

“The object of the patentee is to secure to himself complete control, the monopoly

of his invention, and the use of it as a certain source of income. The object sought

by the government is to obtain from the inventor a clear, definite, precise

description of the invention for the public good. These constitute mutual

considerations for the proposed contract evidenced in the letters patent.”

9) In William C. Robinson’s The Law of Patents for Useful Inventions (1890), Robinson defined

a patent as:


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“a purchase by the government, acting on behalf of the whole people, of some

new art or instrument, capable of beneficial use, for which it recompenses the

inventor by securing to him for a time its sole enjoyment.”

10) Samuel Love Hopkins, in The Law of Patents and Patent Practice in the Patent Office and

the Federal Courts (1911), described a patent as:

“the analogue of a contract…. The right created by their issuance is a public

franchise, of which the letters patent are the grant.”

11) Madison in Federalist Nos. 10 and 51 explained:

“The extension, separation, and division of powers would provide better security

to “[t]he diversity in the faculties of men, from which the rights of property

originate.”

12) Justice Brewer said:

“…the contract basis for intellectual property rights heightens the federal government’s

obligations to protect those rights.”

13) USPTO/PTAB have not been protecting the rights of Plaintiff/inventor, under color of re-

examination under pre-AIA and AIA.

14) By entering into public contracts with inventors, the federal government must ensure what J.

Marshall described in Grant v. Raymond as a “faithful execution of the solemn promise made by

the United States.” The AIA provision to examine granted patents is inconsistent with “faithful

execution of the solemn promise made by the United States” and is void.

15) Nothing in the AIA can be claimed to rescind a grant’s ‘Patent Prosecution History

Estoppel;’ or, reexamine a granted patent. Nothing in the Act authorized a ‘Breach of

Contract’ — for the purpose of quashing a granted patent [For a Corporate client,

represented by the USPTO, per request authorized by the AIA.].

16) J. Marshall declared: “It can require no argument to prove that the circumstances of this

case constitute a contract.” This is prima facie evidence that Defendants committed treason


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in waging war against and not upholding J. Marshall’s rulings that are Constitutional precedents.

J. Marshall declared in Dartmouth College v. Woodward (1819) that:

“Surely, in this transaction, every ingredient of a complete and legitimate contract

is to be found. The points for consideration are,

1. Is this contract protected by the Constitution of the United States?

2. Is it impaired by the acts under which the Defendants hold?”

The answers are “yes” to both questions. Defendants clearly violated Plaintiff’s right to property.

Like J. Marshall stated in Dartmouth:

“Circumstances have not changed it. In reason, in justice, and in law, it is

now what is was in 1769…The law of this case is the law of all… The opinion

of the Court, after mature deliberation, is that this is a contract the

obligation of which cannot be impaired without violating the Constitution of

the United States…It results from this opinion that the acts of the” Judges

Andrews, Robinson, Laporte, Davila and Stark “which are stated in the special

verdict found in this cause are repugnant to the Constitution of the United States,

and that the judgment on this special verdict ought to have been for the

Plaintiff/inventor. The judgment of the” Judges Andrews, Robinson, Laporte,

Davila and Stark “must, therefore, be reversed.”

There are two questions for this Court to decide:

1. Is the patent grant of Plaintiff a contract?

2. If it be, do the Orders in question impair its obligation?

The answer is unequivocally a ‘Yes” to both. If a doubt could exist that a grant is a

contract, the point was decided in the case of Fletcher v. Peck. If, then, a grant be a contract

within the meaning of the Constitution of the United States, J. Marshall stated: “these principles

and authorities prove incontrovertibly that” a patent grant “is a contract.” J. Marshall

declared that any acts and Orders [by Judges Andrews, Stark, Robinson and Laporte.] that

impair the obligation of the patent grant contract within the meaning of the Constitution of

the United States “are consequently unconstitutional and void.” As J. Marshall concluded,

“The predicament in which this Court stands in relation to the nation at large is

full of perplexities and embarrassments. It is called to decide on causes between


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citizens of different States, between a State and its citizens, and between different

States. It stands, therefore in the midst of jealousies and rivalries of conflicting

parties with the most momentous interests confided to its care. Under such

circumstances, it never can have a motive to do more than its duty, and I trust it

will always be found to possess firmness enough to do that.”

The Constitution of the United States declares that

“no State shall pass any bill of attainder, ex post facto law, or law impairing the

obligation of contracts.”

The case now under consideration comes within this prohibitory section of the Constitution. The

Orders by Judges Andrews, Robinson, Laporte, Davila and Stark violate the U.S. Constitution

and constitute treason. J. Marshall declared in Fletcher: “It would be strange if a contract to

convey was secured by the Constitution, while an absolute conveyance remained unprotected

…This rescinding act” [of Judges Andrews, Robinson, Laporte, Davila and Stark] “would have

the effect of an ex post facto law. It forfeits the estate of” Plaintiff “for a crime not committed

by” Plaintiff, but by the Adjudicators, namely, Defendants and Judges Andrews, Robinson,

Laporte, Davila and Stark by their Orders which “unconstitutionally impaired” the patent grant

contract with Plaintiff/inventor, which, “as in a conveyance of land, the court found a contract

that the grant should not be revoked.”

In the U.S. Supreme Court ruling in “TC Heartland LLC v. Kraft Foods Group

Brands LLC,” No. 16–341. May 22, 2017, a landmark case on patent venue, the U.S. Supreme

Court reversed decades (60 years) of Federal Circuit’s erroneous rulings and decided that the

Federal Circuit had ignored what had been ruled by the U. S. Supreme Court over a century ago

in Fourco Glass Co. v. Transmirra Products Corp., 353 U. S. 222, 226 (1957), which

reaffirmed the U.S. Supreme Court ruling in Stonite Products Co. v. Melvin Lloyd Co., 315

U. S. 561, 563 (1942). America Invents Act (AIA) did not modify the meaning of the

contract clause as interpreted by Fletcher v. Peck by Chief Justice Marshall. This Court


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must take Judicial Notice of the Fletcher, Stonite, Fourco and TC Heartland rulings by the

U.S. Supreme Court and not be in breach of the solemn oath of office, and must not

violate the Supreme Law of the Land, as delineated in Fletcher, Stonite, Fourco and TC

Heartland. In Fletcher, the U.S. Supreme Court definitively and unambiguously held that a

Government issued contract grant cannot be rescinded by the highest authority. The U.S.

Supreme Court ruling in Fletcher has never been reversed and is unaltered. The current

version of AIA does not contain any indication that Congress intended to alter the meaning

of the contract clause as interpreted in Fletcher. AIA did not modify the meaning of the

contract clause as interpreted by Fletcher.

In 2011, Congress took steps by enacting the AIA that indicated that the U.S.

Supreme Court’s decision in Fletcher was a nullity and that -- and that its disregard by

lower courts had somehow become the law of the land. The AIA “has been around so long

that, at some point, the mistake becomes the law.” And the U.S. Supreme Court “has again

and again and again stood up for its authority to declare what the law is.”

CONCLUSION: The Andrews, Robinson, Davila, Laporte and Stark Courts with regard to

Plaintiff’s patents lost their jurisdiction and immunity and their Orders dismissing civil RICO

claims and patent infringement claims are void.

WHEREFORE, Plaintiff respectfully propounds (in no uncertain terms and with all due

respect to this Judge that, unless Fletcher has been overturned, it must hold for Plaintiff in

compliance with the law of the land and solemn oath to protect and enforce J. Marshall’s 'First

Impression' prohibition against rescinding government issued grants. Wherefore, this Honorable

Court must provide a Statement of Decision, answering the issues Plaintiff has identified above.

A Certificate of Service is attached.


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Dated: March 18, 2018 Respectfully submitted,

222 Stanford Ave, Menlo Park, CA 94025

Tel: 650 690 0995 Plaintiff

[email protected] Dr. Lakshmi Arunachalam


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222 Stanford Avenue, Menlo Park, CA 94025

Telephone: (650) 690-0995; Facsimile: (650) 854-3393

Email: [email protected]

Pro Se Plaintiff





Plaintiff,

v.

APPLE, INC., et al,

AND

DOES 1-100,

Defendants.

C.A. No. 4:18-cv-01250-DMR

JURY TRIAL DEMANDED

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF

PLAINTIFF’S MOTION FOR THIS COURT TO GIVE A STATEMENT OF DECISION

ON WHETHER CONTRACT LAW APPLIES TO PATENTS

Plaintiff Dr. Lakshmi Arunachalam (hereafter "Dr. Arunachalam") respectfully files this

“Memorandum of points and authorities in support of Plaintiff’s motion for this Court to give a

statement of decision on whether contract law applies to patents.” Plaintiff incorporates by

reference pp. 2-7 of “Plaintiff’s motion for this Court to give a statement of decision on whether

contract law applies to patents” as if fully stated herein.

I

Res accendent lumina rebus

One thing throws light upon others

ABOUT THIS CASE

[T]HE ONE THING HERE IS ‘CONTINUING AVOIDANCE TO ADJUDICATE’ THE ‘SINGLE ISSUE’ IN

THIS CASE; THROWING LIGHT UPON, a) the ‘Overwhelming [Alleged Good Cause] Reasons’

these ‘High Priced’ Patent Attorneys are expecting extensions before continuing to file frivolous


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motions thereafter (in frustration) by propounding the overwhelming appearance [Not the single

material issue.] in this case. Collectively, their lawyerly reasons (extending time) and arguments

are consistently [Wrongfully.] propounded by the Courts’ wanton failure(s) to adjudicate [First

and Foremost Consistent with their Solemn Oaths.] the single issue [Or adjudicate without

considering the single issue imposed upon the Courts [And the Patent Lawyers themselves.], as

‘First Impression’ [With or without jurisdiction.]. Collusively, vested in avoidance this

‘Overwhelming Appearance’ [However real or imagined.] is compounded by the clerks of the

various courts refusing to timely file my pleadings and/or materially [Substantively and

fundamentally.] altering the ‘Captioned Responsiveness’ of my filings, prejudicing the fair and

proper administration of justice [Compromisingly, for the same advantageous avoidance and

disadvantageous privations denying Plaintiff access to the various courts’ electronic filing

resources and returning documents for minute error.]; causing, this case to be dragged on for

years. The filings by Defendants’ Attorneys have not been altered in the least. First, they all

propound my patents are rescinded and disclose that even the Court stated I am a ‘Frivolous

Filer’, that I fail to mention this, that, or the other; and, have wasted their time. Moreover, they

state that even the Supreme Court did not entertain my prayer as a reason influencing a non-

adjudicative finding [Emphasis added.] on this single issue. Yet, not one discloses the fact that

none of them affirmatively addresses the ‘First Impression Mandated Prohibition’ against

rescinding government issued grants [And rightfully so!]. In furtherance, they repetitiously

(and wrongfully) state (in passing I might add) that: a) Fletcher does not apply to patents, only

land grants; b) that, for over 200 years, Fletcher has not been applicable to patent law; and, c)

that, reexamining existing grants under the AIA for patentability is constitutional. To all of this

[Of which I have had to contend.] I say: If the lot (honestly) believe that to be true, then they


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would not be adverse in denying my REQUEST TO THIS COURT, TO ENTERTAIN A ‘TENTATIVE

RULING’ DELINEATED IN THE ‘AT ISSUE MEMORANDUM’ as to whether or not Chief Justice

Marshall’s ‘Mandated Prohibition’ against rescinding government issued grants (in the case of

Fletcher v. Peck, 10 U.S. 87 (1810)), is the law of the land governing granted patents; because,

a) THE COURT IS COMPELLED TO PROTECT THE CONSTITUTION ABOVE ALL ELSE:

The Court has the same solemn duty to uphold, protect, and defend the Constitution

[Which I have had to contend doing against Defendants and those ‘Associated-in-Fact’ with

them (because, of the Oath taken to become an American Citizen) for the past 5+ years.].

The Document has been assaulted by Defendants, the Judiciary and Legislative bodies; along

with the USPTO/PTAB and the USITC; requiring, a ‘TENTATIVE BAND-AID’ so these

treasonous professionals might see the damage they are doing for whatever self-serving

reason (however real or imagined).

b) THE ONLY DEFENSE FOR WANTON BREACH OF SOLEMN OATH IS INSANITY:

The Offenses propounded are manifestly and directly linked to the same solemn duty as

the single prima facie element connecting the union between them ASSOCIATED-BY-

BREACH; the, trust of which promotes antitrust and defeats the public trust; and,

c) A TENTATIVE RULING WILL SEVER FRAUD FROM JUSTICE:

The tentative ruling must limit Defendants’ reliance on the Court’s extensions.

Compelling briefs to convince this Court why it should not find Fletcher above all else?

Exercising research to prove their guilt or innocence [Unwittingly induced upon them by the

Courts and Supreme Court’s failing leadership-of-avoidance [Setting the standard of

Lawyerly Conducts by doing the same nothingness — a logical excuse is a waste of time

because the offenses are merely incidental to their solemn oaths.]; rather, to focus on proof


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that the Mandated Prohibition delineated in Fletcher v. Peck is not applicable to the

Administration of Patent Law. It is the Breach of Solemn Oath from which the offenses arise

therefrom [In Breach of the Public Trust.]. The Breach of Solemn Oath is the Treason or

Misprision of it from which Antitrust is the only by-product that can arise in Patent Law to

prey on the Public Trust. Moreover, ironically, this unholy birth on the record is strictly

conducive to the ‘Judicial and the Practicing Professional axiom’; traditionally,

propounded “THAT IGNORANCE OF THE LAW EXCUSES NO MAN!” It is only fair this Court

makes a Tentative Ruling and opportunity for Defendant to opt-out of the successful judicial

conspiracy institutionally allowing these Patent Lawyers to rip off their clients [Under color

of Lawyerly proceedings.]

OR IN THE ALTERATIVE:

d) Poll Defendants as to their Professional Standing on this Issue or Plead the 5th

Amendment in furtherance; which, in either case would finally adjudicate the case [As far as I

am concerned.].

II

Malum quo communius eo pejus

The more common an evil is, the worse it is

INTRODUCTION

When Microsoft breached the confidentiality Agreement and infringed upon Plaintiff’s patent,

it was during the time the U.S. Attorney was litigating an antitrust action against Microsoft. At

the time, the Court found that the very nature and cultural mentalis of Microsoft itself was

incapable of fairly competing and opined that Microsoft was more likely than not, predicated

instinctively to monopolize in the future. Defendants here were opposing parties there.

III

Qui non prohibit id quod prohibere potest assentire videur

He who does not forbid what he is able to prevent, is considered to assent


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When the case went to trial [Prior to the AIA sneaking in the ‘Reexamining of Existing

Patents’], THE USPTO/PTAB WERE ALREADY RESCINDING GRANTED PATENTS WITHOUT

LEGISLATIVE AUTHORITY AND IN WANTON BREACH OF THEIR SOLEMN OATHS. Venue (Pre-

AIA) was already corrupted (in association with the Federal Circuit) taking ‘Judicial Notice’ to

materially exclude ‘Patent Prosecution History Estoppel’ in adjudicating the patent itself. It

follows, the USPTO/PTAB excluded the material contract provision in finding venue to the

Federal Circuit. At the time [Without Legislative authority.] the process was designed and

limited to ‘Applications Denied Patentability’ [With the limitation going along for the venue ride

to the Federal Circuit for adjudication.]. With the USPTO/PTAB being a ‘Closed Practicing

Agency’ [Compounded by the changing Data Compatibility and Browser Wars of the 90’s.]

destined to be a ‘Revolving (Lawyerly) Door’ interested in existing Patents, not necessarily

Applications for Patentability. Little wonder how the revolving door and conveyer belt venue to

the Federal Circuit started moving granted patents [Resulting in conflicting representations of

former competitors and former corporate retainers (Like Defendants); vended, to the Federal

Circuit itself transforming vested interest adjudicators (structured and newly structured) in the

court.].

Political Science Educators will readily state the same happens in every government agency.

When tasked to feed the hungry and everybody is fed; the agency will move to create and

maintain its necessity to survive budget cuts and dissolution. Hence, Patent Prosecution

History Estoppel had to be removed on the one side of the conveyor so the agency could

broadly attach competitive constructions and terms for the court to consider [Instead of

being compelled to consider the patent in its limited and restrictively protected sense.]. On the

other side of the conveyor, the Federal Circuit Court had to take ‘Judicial Notice’ that


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Patent Prosecution History Estoppel could not be admitted for consideration as a matter of

law to adjudicate. NOW! THIS IS A JUDICIAL CONSPIRACY IN COHORT WITH THE

USPTO/PTAB.

However, it is more than that. Because its design is to deprive an inventor of the patent right

and protection under color of law and authority; and, even more than that [Because the

Conspiracy has continued unfettered and more likely than not will continue adjudicating

inventive economies of scale affecting commerce, it elevates the conspiracy against right to a

pattern of conducts corrupting government programs designed to avoid antitrust patterns to

perpetuating them intentionally.

Ultimately, the agency and courts here have created a criminal enterprise colored by their

adjudicative standing. If anyone believes the AIA inserting the reexamination of existing patents

was to give authority to begin the process; when, the agency had been doing it all along to color

the criminal enterprise to continue promoting antitrust adjudications; contrary to the public’s

trust.

CONCLUSION

Vires acquirit eundo

It gains strength by continuance

ONE THING DOES SHED LIGHT UPON OTHERS! [T]hat thing here before this Court is simply

Justice Marshall’s ‘Mandated (First Impression) Prohibition’ against rescinding government

grants, once issued that everyone here [As well as the entire ‘Patent Practicing [Including the

USITC Administration and Associated Judicial Counterparts [Including the Supreme Court.’]

knows of or should have known. Yet, look past the Bench and see the unified consistency of

Lawyering, adjudicating, pleading, and justifications for dismissal [Not adjudication predicated

on ascertaining whether Fletcher v. Peck (1810) is applicable to the Patent Profession or whether


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the ‘Reexamination of Existing Granted Patents’ de jure reversed a ‘First Impression’ Supreme

Court decision without one objection [1].].

1) The AIA did not Authorize ‘Rescinding by Reexamination’, it Just Colored it with Law:

When one observes 15 people, from 15 different cultural backgrounds whistling the same

tune in harmony that is not a conspiracy. When the same individual observes the USPTO

publicly soliciting inventors to contract ownership of their invention. Promising (in exchange a

20-Year Royalty with Patent Prosecution History Estoppel attaching to the patent); and,

thereafter reexamines the patent [Void of Patent Prosecution History Estoppel and without

Legislative Authority.] finding un-patentability [As to the Certified Construction and Terms

[Certified.] by the USPTO and required for granting a patent.] for venue to the Federal Circuit

[Specifically learned in Patent Law.] to adjudicate [Void of Patent Prosecution History Estoppel

constructively aware of.] that fact and rescind the granted patent. That is not a conspiracy, it is a

‘UNILATERAL BREACH OF PUBLIC CONTRACT’ fraudulently propounded as to the USPTO; and,

an ‘UNETHICAL JUDICIAL COMPROMISE’ (Maybe Discretion).

3) PATTERN OF REEXAMINING DESIGNED TO ADJUDICATE NOT PATENTABILITY BUT

UNILATERAL PUBLIC BREACH OF CONTRACT REQUIRING JUDICIAL NOTICE NOT TO

CONSIDER ‘PATENT PROSECUTION HISTORY ESTOPPEL':

However, when the same process is used after infringement [And after surviving 12

reexaminations [By the Agency representing the Infringer and some of the Defendants on a

revolving door request.] after the granted patent was infringed (stolen) on notice thereof; initiates

venue TO THE FEDERAL CIRCUIT [CONTINUING TO IGNORE THE FACTS AND PATENT PROSECUTION

HISTORY ESTOPPEL]; THIS, GIVES A STRONG APPEARANCE OF A CONSPIRACY [BUT FOR THE VENUE

IT IS MORE A ‘PATTERN’ TO ADJUDICATE UNILATERAL BREACHED PUBLIC CONTRACTS (NOT BY

1 FROM THE SUPREME COURT: Allowing the Legislature to quasi-adjudicate that which is entrusted to them to do.

Notwithstanding, allowing this while Inventors are burning their patents outside the USPTO office in public protest.


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ALTERING OR MATERIALLY WITHHOLDING TERMS OF THE CONTRACT; RATHER, BY, PROCEDURALLY

INVOKING ‘JUDICIAL NOTICE’ TO EXCLUDE PATENT PROSECUTION HISTORY ESTOPPEL FROM

RESTRICTING THE CONSTRUCTION AND TERMS CERTIFIED BY THE USPTO TO INVOKE THEIR

CORPORATE CLIENTS’ CONSTRUCTION AND TERMS ADJACENT TO THE AGENCIES’ FINDING OF

UNPATENTABILITY; OTHERWISE, THE COURT WOULD BE IN WANT OF SOMETHING CONFLICTING TO

ADJUDICATE.). AT BEST, IT IS MORE A PROCESS DESIGNED PATTERN TO MAINTAIN JURISDICTIONAL

INTEGRITY AS TO FINDING PATENT ADJUDICATION AS OPPOSED TO FINDING CONTRACTUAL [2]

ADJUDICATION.

4) THIS ANTITRUST ACTIVITY BEGAN IN THE LATE 90’S BY DEFENDANT & ADVERSARIES:

The court was correct when it found that Microsoft was incapable of arresting the

monopolistic tendency to antitrust the environments where it exists. After infringing Plaintiff’s

patent, IBM, SAP, Apple, Samsung and others associated in the antitrust action brought against

Microsoft by the USA; thereafter, Defendants associated with each other. Ultimately controlling

the ‘Eclipse (Non-profit) Foundation’ created by IBM to capture the licensing market worldwide;

with, back-door access resulting in partnership with the government. That exporting for

importing smart phones, notebooks, and the like carrying Plaintiff’s infringed patented ‘VAN

Switch’ for sale in the United States restricting domestic competition in [As noted in 1995 by the

court in every aspect of the industry.]. Distributing Plaintiff’s patent through the Eclipse

Foundation as Freeware supported by the very government attempting to curb the resulting

antitrust fallout then; has astronomically grown uncontrollably worldwide. The only difference

2 WITH RESPECT TO J. MARSHALL’S ‘MANDATED PROHIBITION’: Perhaps this is why one of the Defendant

Attorneys uttered that “A Patent is not a Contract!” This is half-true, as it is materially a substantive part of the

Consideration of the Grant [That is the Contract.].


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now is Microsoft owns the government [3]. But for Plaintiff’s invention, the government would

not have been able to spy on Americans or enemies abroad. The USITC allowing Eclipse

Members to import infringed products; the, USPTO is nothing more than a corrupt subsidiary of

defendants. In the center is the Federal Circuit still imposing Judicial Notice to avoid having to

consider adjudicating a patent fairly and impartially. All three indifferent to the antitrust impact

on our economy.

5) THE FEDERAL CIRCUIT AND USPTO/PTAB LIKE DEFENDANTS’ DEMONSTRATED

CONDUCTS DISCLOSE THE OBJECT OF THEIR PRETENSE IS TO PREVENT THIS CASE FROM

BEING ADJUDICATED.

A conspiracy (as here) may be a continuing one. Because all are linked to the Eclipse

Foundation Defendants can drop out of, while others drop in. While the details of the initial

operation may have changed from time to time with members not knowing each other or the part

played by each; nor, the details of the plan or operation, they must know the purpose of the

conspiracy and agree to participate in it. MORE DEFINITIVELY (AS HERE) ACTING IN CONCERT

OR COMBINATION TO DEFRAUD OR OTHERWISE CAUSE OTHER INJURY TO A PERSON OR

PROPERTY, RESULTING IN DAMAGE TO THE PERSON OR PROPERTY. INFRINGEMENT FALLS INTO

THIS CATEGORY HALLMARKED BY A COMMON CORE BREACH OF OATH AND INFRINGEMENT. So

also operating as a combination or confederacy for the purpose of committing by joint effort

some act which is lawful in itself [For example: Seeking a continuance.], but becomes unlawful

when done by the concerted actions [WITH OTHER DEFENDANTS.] or for the purpose of

using unlawful means [DISHONESTLY TO FRUSTRATE TIMELY ADJUDICATION.] to the commission

of an act not in itself unlawful [TO DEPRIVE PLAINTIFF OF HER DAY IN COURT.]. That Defendants

3 WITH COURT INFLUENCE: No doubt from early inside information upon which investments were made and

appreciated by Federal Judges in the instant actions refusing to recuse after disclosure of stock in Defendants’

Corporations to ensure disadvantage to Plaintiff at the expense of breaching judicial cannons and solemn oath

directly at issue in this case. In another instance another attorney alleging Money Markets are authorized which is

not the truth; rather, a self-serving utterance propounded to appear as true.


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are collectively standing before this Court in breach of solemn oaths for the same treasonous

contempt for the laws of the land, with filings consistent with each other’s [Failing to address the

‘At Issue Offense’ or produce any evidence in their defense [For which none exists.].] itself

implies antitrust.

Neither the USPTO/PTAB nor any Court has the authority to invalidate any patent.

In TC Heartland case, the U.S. Supreme Court’s ruling was as follows:

“The patent venue statute, 28 U. S. C. §1400(b), provides that “[a]ny civil action

for patent infringement may be brought in the judicial district where the defendant

resides, or where the defendant has committed acts of infringement and has a

regular and established place of business.” In Fourco Glass Co. v. Transmirra

Products Corp., 353 U. S. 222, 226, this Court concluded that for purposes of

§1400(b) a domestic corporation “resides” only in its State of incorporation,

rejecting the argument that §1400(b) incorporates the broader definition of

corporate “residence” contained in the general venue statute, 28 U. S. C.

§1391(c). Congress has not amended §1400(b) since Fourco, but it has twice

amended §1391, which now provides that, “[e]xcept as otherwise provided by

law” and “[f]or all venue purposes,” a corporation “shall be deemed to reside, if a

defendant, in any judicial district in which such defendant is subject to the court’s

personal jurisdiction with respect to the civil action in question.” §§1391(a), (c)…

Held: As applied to domestic corporations, “reside[nce]” in §1400(b) refers only

to the State of incorporation. The amendments to §1391 did not modify the

meaning of §1400(b) as interpreted by Fourco. Pp. 3– 10….

In Fourco, this Court definitively and unambiguously held that the word

“reside[nce]” in §1400(b), as applied to domestic corporations, refers only to the

State of incorporation. Because Congress has not amended §1400(b) since

Fourco, and neither party asks the Court Cite as: 581 U. S. ____ (2017) 3

Syllabus to reconsider that decision, the only question here is whether Congress

changed §1400(b)’s meaning when it amended §1391. When Congress intends to

effect a change of that kind, it ordinarily provides a relatively clear indication of

its intent in the amended provision’s text. No such indication appears in the

current version of §1391. Respondent points out that the current §1391(c)

provides a default rule that, on its face, applies without exception “[f]or all venue

purposes.” But the version at issue in Fourco similarly provided a default rule that

applied “ ‘for venue purposes,’ ” 353 U. S., at 223, and those phrasings are not

materially different in this context. The addition of the word “all” to the already

comprehensive provision does not suggest that Congress intended the Court to

reconsider its decision in Fourco. Any argument based on this language is even

weaker now than it was when the Court rejected it in Fourco. Fourco held that


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§1400(b) retained a meaning distinct from the default definition contained in

§1391(c), even though the latter, by its terms, included no exceptions. The current

version of §1391 includes a saving clause, which expressly states that the

provision does not apply when “otherwise provided by law,” thus making explicit

the qualification that the Fourco Court found implicit in the statute. Finally, there

is no indication that Congress in 2011 ratified the Federal Circuit’s decision in VE

Holding. Pp. 7–10…

This Court squarely rejected that interpretation, reaffirming Stonite’s holding that

§1400(b) “is the sole and exclusive provision controlling venue in patent

infringement actions, and . . . is not to be supplemented by . . . §1391(c).” 353 U.

S., at 229…

…VE Holding Corp. v. Johnson Gas Appliance Co., 917 F. 2d 1574 (1990)…

Following VE Holding, no new developments occurred until Congress adopted

the current version of §1391 in 2011 (again leaving §1400(b) unaltered)….

We reverse the Federal Circuit…

Congress has not amended §1400(b) since Fourco, and neither party asks us to

reconsider our holding in that case. Accordingly, the only question we must

answer is whether Congress changed the meaning of §1400(b) when it amended

§1391. When Congress intends to effect a change of that kind, it ordinarily

provides a relatively clear indication of its intent in the text of the amended

provision. See United States v. Madigan, 300 U. S. 500, 506 (1937) (“[T]he

modification by implication of the settled construction of an earlier and different

section is not favored”); A. Scalia & B. Garner, Reading Law 331 (2012) (“A

clear, authoritative judicial holding on the meaning of a particular provision

should not be cast in doubt and subjected to challenge whenever a related though

not utterly inconsistent provision is adopted in the same statute or even in an

affiliated statute”)…

The current version of §1391 does not contain any indication that Congress

intended to alter the meaning of §1400(b) as interpreted in Fourco. Although

the current version of §1391(c) provides a default rule that applies “[f]or all venue

purposes,” the version at issue in Fourco similarly provided a default rule that

applied “for venue purposes.” 353 U. S., at 223 (internal quotation marks

omitted).”

In the oral arguments in TC Heartland, its counsel argued:

MR. DABNEY: “I'd like to open first with some undeniable points. In Fourco

Glass, this Court made two holdings about 1400(b) that control this case. The first

is this Court interpreted Section 1400(b) as a standalone. It's the sole and

exclusive provision governing venue in patent cases and is not to be supplemented

with Section 1391.


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It's noteworthy that in -- in the Respondent's brief, they don't cite a single real

world example where there was any problem interpreting and applying Section

1400(b) ever since the Sperry v. American Railroad…

JUSTICE KAGAN: What do you think Congress would have to do to reverse our

decision in Fourco?

MR. DABNEY: Well, there are many ways that it could be done. And -- and in

2001, the American Law Institute proposed that Section 1400(b) be repealed.

JUSTICE KAGAN: Is there any way Congress could do it without repealing

1400? Is there any change that Congress could make to 1391 that would have that

effect.

MR. DABNEY: I could imagine that if instead of saying "except as otherwise

provided by law," the statute said "notwithstanding any other provision of law,

this would govern." That would be a way to do that. But –

JUSTICE KAGAN: That -- that would do it? In other words, your argument in the

end rests on that "except" provision?

MR. DABNEY: It rests importantly on the "except" provision. The "except"

provision makes this case an easier case than Fourco Glass was because at the

time of Fourco Glass, all you had was the general venue statute and the very

specific tailored, historic venue statute that had been dating back to 1897. And so

in that case, the Court used the standard tools of statutory construction and said,

you know, the specific statute is not going to be swallowed up and rendered

nugatory by the more general, and it applied the kind of reasoning that the

Radzanower case did. Radzanower v. Touche Ross is a very, very analogous case

to this. But now that Congress has specifically provided not that 1391 overrides

1400(b), but that 1391 yields, is subordinate to other statutes and common law

that -- that provide otherwise for venue, that makes this case just easy to apply…

So the plain meaning of "govern" applies to 1391(c) by their own

characterization. They're the ones who are saying that 1391(c) governs venue in

this case, which is what they say on page 8, and then they try to do this

acrobatic maneuver to escape the exceptions clause by saying it doesn't

govern. Well, as we say in our reply brief, the plain meaning of "govern" means

that 1391(c) is part of the sections that in the structure of 1391 is subordinated to

the exception language.

So the -- the Court doesn't need to do anything here except say that Fourco's

interpretation of 1400(b), which under Kimble v. Marvel and statutory precedence

of this Court, it is as much a part of that statute as the words originally were, that

that is part of the law that everyone agrees provides for a venue otherwise than

what the Respondent is arguing for. The Respondent is arguing that 1400(b)


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should now be given an artificial meaning imported from 1391(c). That is the

exact argument that the Respondent made in the Fourco case….

And the Court said, in the context of 1400(b), which distinguishes between

resident and nonresident defendants, you can't import that synthetic, fictitious

definition of "resides" without destroying both the text of the statute and

completely defeating its purpose….

JUSTICE KAGAN: But, Mr. Dabney, I mean, one oddity of this case is -- is

usually, when we say something, when we issue a decision, we can be pretty

confident that Congress is acting against the backdrop of that -- that decision. But

I think that that would be an odd thing to say in this case, given that for 30 years

the Federal Circuit has been ignoring our decision and the law has effectively

been otherwise. And then the question is, well, what is the backdrop against

which Congress is legislating.

It seems actually that if -- if I were a congressman, I'd think that the practical

backdrop against which I'm legislating is not Fourco; it is instead the Federal

Circuit's decision in VE Holding, which is the decision that the practice has

conformed to.

MR. DABNEY: Well, I -- I can tell the Court from someone who does practice

that not everyone ever acceded to VE Holding. And I think, if you look at what

actually happened in the 2011 act, it seems to me that, in 2011, Congress took

steps that indicated that they didn't get the memo, that this Court's decision

in Fourco Glass was a nullity and that -- and that its disregard by lower

courts had somehow become the law of the land.

First, VE Holding, the 1990 decision of the Federal Circuit, had seized upon a

prepositional phrase in a 1988 version under this chapter. So if Congress was

thinking, oh, what I want to do is lock in a situation in which an enormous,

extreme controversial imbalance in Federal patent litigation that goes to a very

small number of victics, it was an odd thing for Congress to have repealed the

very grab-hold that -- that the Federal Circuit had seized on to justify its

results.

So I would argue that the legislation that Congress passed, far from ratifying

that holding, very intentionally abrogated it. Not only that, in September, three

months before the 2011 act was passed, Congress amended the America Invents

Act to provide for a new restriction on what could be deemed a regular and

established place of business under 1400(b). Section 18(c) of the AIA says that an

automated teller machine, an ATM, shall not be deemed a regular and established

place of business. Now, I suppose the Respondent would say that -- that provision

was not inserted at the behest of New York money center banks; that -- that

provision was put in at the behest of individuals who didn't even form an LLC or

a corporation so that they would enjoy the protection alone…


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So the key point I'd just like to leave you with is, for more than 100 years, a

patent venue has been a function of the domicile of a defendant, and it

provides for an easy-to-administer, clear rule that prescribes where venue is -

- is permissive in a patent case.

JUSTICE KAGAN: Well, but for more than 30 years the practice has been the

other way. I mean, I'm -- I'm -- I was thinking as I was reading the briefs,

sometimes we have accidental theme days at the Supreme Court. So today's

accidental theme is: When 30 years of practice goes against you, what

happens?

MR. DABNEY: I -- I -- I heard Justice Souter say something like that in the KSR

case, you know, the teaching-suggestion-motivation test has been around so long

that, at some point, the mistake becomes the law. And -- and this Court has

again and again and again stood up for its authority to declare what the law

is.

On -- on issues of patent law, there's actually a precedent, Andrews v. Hovey that

says no issue of patent law is settled until we have settled it. In Dickenson v.

Zurko, there's a tremendous administrative law -- body of law that this Court

said the Federal Circuit was wrong in the way it --…

JUSTICE GINSBURG: Well, maybe the Federal Circuit was wrong in not

following Fourco, but the question is now before us, and you are asking us to

say that venue in a patent infringement case is only where the entity is

incorporated or comparable to that, and you have acknowledged that there is no

other venue…

MR. DABNEY: The injury claimed in patent litigation usually is -- is a

synthetic non-receipt of a reasonable royalty that allegedly is due, and -- and

that can be marketed and sold and transmitted into a forum. There's all

kinds of reasons why 1400(b) is an important law to enforce and uphold.”

Defendants and their Counsel of Record are in violation of the Supreme Law of the

Land, as delineated in Fletcher v. Peck, 10 U.S. 87 (1810), prohibiting the quashing of a

Government issued contract grant even by the highest authority. Any Court or Administrative

Agency going along with IBM or SAP is aiding and abetting violations of antitrust, civil RICO

and other statutes and has engaged in a Constitutional public breach.


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The judiciary [Systematically, issuing Erroneous and fraudulently (collusive )

favorable findings for Corporate Defendants and the “Revolving-Door” USPTO/PTAB [Aiding

and judicially Abetting Unfair Public Competition.]; enforcing, the legislative enactment

provision (colorfully) ‘Reexamining’ existing patent contract grants authorized by the America

Invents Act [Aiding and Abetting the antitrust objective(s) of Infringers-at-Large.]; enforcing,

‘Bad Law’ from ‘Lawless Legislation’ (ignorant or not) for over two centuries; today, (now

contemptuously) effectually perpetrates the very thing entrusted to prevent by USPTO’s mission

statement: Fundamentally,

§ 140. “…Due Process does…entitle a litigant to an honest, though not

learned tribunal. If a litigant is injured through the corruption or fraud of

the court or other body disposing of his case, She (sic) is entitled to

redress under this section of the Constitution.” [Fallbrook Irrigation

District v. Bradley, 164, U.S. pp.1267-70.]

§141. “Any legislative attempt to do this, whether by direct denial of

access to the courts upon this question, or by hindering such access by

making resort to the courts upon it difficult, expensive, hazardous, all alike

violates the constitutional provision.”

“On the question of ‘Due Process Itself’ and the State of the Union in the

fair and proper administration of patent law [Vol. 12, Constitutional Law.

Chapter VII, Due Process and Equal Protection of Law: Procedure.

Section 1. Due Process of Law]; clearly, entitles Plaintiff to Redress for

this treasonous breach of Solemn Oaths to enforce rights of access.”

These are the circumstances under which violations of antitrust and other statutes

have occurred, namely, the entire judiciary and administration failing to enforce the Law of

the Land, [Causing damage to the public itself entitled to redress from their practicing

attorneys and adjudicating judges’ ruling(s) without jurisdiction and immunity.]; or, have

been administering the patent laws corruptly in breach of the public’s trust.

Even after the Federal Circuit ruled in Aqua Products, Inc. v. Matal, Case No. 15-

1177, October 2017 that all cases, that did not consider ‘Patent Prosecution History


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Estoppel’ in respective USPTO/PTAB adjudications, are warranted a reversal, the

USPTO/PTAB (in contempt) failed to uphold this Aqua Products, Inc. v. Matal ruling in

Plaintiff’s cases regarding Plaintiff’s significant patents, that have benefited this entire nation

and globe (for that matter), discriminating against Plaintiff.

PTAB’s ultra vires unconstitutional decision “invalidating” Plaintiff’s U.S. Patent

No. 7,340,506 (“the ‘506 patent) is void, because the PTAB Judges lost their jurisdiction and

immunity, in PTAB Judge McNamara and PTAB Judge Stephen C. Siu holding direct stock in

Microsoft, the Third Party Requester in the ‘506 re-examination, as per their own annual

financial disclosure statements, and PTAB Judges Kevin Turner lying and obstructing justice

along with PTAB Judges Jennifer Bisk who was conflicted out from presiding over the CBM

review of the ‘506 patent as she had worked with SAP’s attorneys at Sterne Kessler; and PTAB

Judge G. Braden; and the PTAB has no authority to invalidate a patent, contrary to the U.S.

Supreme Court ruling in Fletcher v. Peck (1810). The Federal Circuit ruled in Aqua Products v.

Matal, 15-1177, October 2017 that any PTAB or court case that did not consider Patent

Prosecution History must be reversed and reversed its own rulings that were contrary to its ruling

in Aqua Products, but the Federal Circuit refused to uphold its own Aqua Products ruling in

Dr. Arunachalam’s case against Microsoft with regard to the re-examination of Plaintiff’s

U.S. Patent No. 6,212,556, in a blatant civil rights discrimination against Dr. Arunachalam.

In Plaintiff’s ‘492, ‘158 and ‘500 patent cases, JPMorgan Chase and Company and Judge

Robinson, and PTAB failed to consider Patent Prosecution History. Had they considered

Patent Prosecution History, the terms Judge Robinson ruled as indefinite would not be and

are not indefinite.


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Given the lawless misconduct and Constitutional public breach and fraud by the PTAB

and the Federal Circuit, which voids their rulings and caused them to lose their jurisdiction and

immunity, Plaintiff finds no reason to go to the Federal Circuit to appeal the alleged

“invalidation” of the valid ‘506 patent, because the ‘506 patent is a patent contract grant issued

by the Government and remains valid through the time certain.

Judge Andrews lost his immunity and jurisdiction when he failed to recuse in

Plaintiff’s cases against JPMorgan Chase & Company, Wells Fargo, Citibank and Citizens’

Financial, IBM and Fulton Financial Corporation, despite Judge Andrews admitting he

bought direct stock in JPMorgan during the pendency of Plaintiff’s case against JPMorgan

and his orders are void in the IBM case 16-281-RGA (D.Del.) case as well as in the Fulton

case and the JPMorgan, Wells Fargo, Citibank and Citizen’s Financial Corporation cases. Judge

Andrews’ Order dismissing the civil RICO claim in the IBM case is void. Judge Andrews’ Order

in the Fulton case dismissing it on the falsely alleged basis of collateral estoppel in

Constitutional public breach and fraud is void. Judge Andrews compromised the position of the

Court and is in treasonous breach of Justice Marshall’s ruling in Fletcher v. Peck and the Federal

Circuit’s ruling in Aqua Products.

The U.S. Supreme Court ruled subsequently in the Dartmouth College (1819) case and

the U.S. v. American Bell Telephone Company (1897) case that the Supreme Court ruling in

Fletcher holds and that a patent is a contract grant and cannot be rescinded even by the highest

authority. See Trustees of Dartmouth College v. Woodward (1819), in which the U.S. Supreme

Court held the

“original charter to be a contract, perpetually continuing, which the

New Hampshire legislation unconstitutionally impaired. In a

corporate charter, as in a conveyance of land, the court found a

contract that the grant should not be revoked.”


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See Bonito Boats, Inc. v. Thunder Craft Boats, Inc. (1989); Grant v. Raymond (1832);

Cable News Network, Inc. v. Video Monitoring Services of America, Inc. (1984); Shaw v. Cooper

(1833); William E. Simonds, “Manual of Patent Law” (1874); William E. Simonds, “A Summary

of the Law of Patents” (1883); James W. Ely, Jr, “The Guardian of Every Other Right: A

Constitutional History of Property Rights” (3d ed.) (2008); Samuel J. Konefsky, “John Marshall

and Alexander Hamilton, Architects of the American Constitution” (Macmillan, 1964); and

Francis N. Stites, “Private Interest and Public Gain: The Dartmouth College Case, 1819” (Univ.

of Mass. Press, 1972). The above references affirm Justice Marshall’s ruling in Fletcher v. Peck

(1810) that a Government issued contract grant cannot be rescinded even by the highest authority

and applies to patent contract grants.4

In fairness, the court must poll defendants to ascertain whether they still agree in whole

or in part with IBM’s wanton argument that Fletcher does not apply; before, moving on the

Courts own motion for sanctions against IBM and followers for attempts and conspiracy in

propounding treasonous litigation (rather than [Solemn Oath Compliance.] for this Court to

enforce (deceitfully) by ignorance, indifference, and contempt for the law of the land prohibiting

the rescinding of government issued grants in the public's best interest [Sending a long overdue

chilling effect to everyone practicing Patent Law believing in this unconstitutional treasonous

belief.].

CONCLUSION: THE COURT IN THIS CASE IS PRESENTED WITH AN HISTORIC

CHOICE. That choice is between upholding or destroying contract grant protections that

Congress provided in the Contract Clause of the 10th Amendment, and that the U.S. Supreme

Court interpreting that statute declared to exist in its Fletcher decision. And the correct choice,

4 The U.S Attorney Claire T. Cormier alleged that Fletcher applies only to land. She is ignorant of the law and even

after being put on notice, she willfully breached her Solemn Oath of Office in waging war against the Constitution.

She failed to abide by the Supreme Law of the Land.


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Plaintiff submits, is to adhere to the U.S. Supreme Court’s existing, long-established

interpretation of the contract clause and to reject the new call for a new revisionist interpretation

that would render the contract clause of the Constitution nugatory in this case and in all but the

most unusual cases. There are all kinds of reasons why Fletcher is an important law to enforce

and uphold.

A Certificate of Service is attached.

Dated: March 18, 2018 Respectfully submitted,

222 Stanford Ave, Menlo Park, CA 94025

Tel: 650 690 0995 Plaintiff

[email protected] Dr. Lakshmi Arunachalam


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Plaintiff,

v.

APPLE, INC., et al,

AND

DOES 1-100,

Defendants.

C.A. No. 4:18-cv-01250-DMR

JURY TRIAL DEMANDED

CERTIFICATE OF SERVICE

I, Dr. Lakshmi Arunachalam, hereby certify that on March 18, 2018, the attached documents

were electronically filed with the Clerk of the Court using CM/ECF which will send notification

to the registered attorney(s) of record that the document has been filed and is available for

viewing and downloading.

I also certify that I sent the same via the U.S. Post Office on the same day to (i) deliver 2 paper

copies to the Clerk of the Court. I also certify that I sent the same to all counsel of record for all

Defendants via email and/or First Class U.S. Mail on March 18, 2018.

DATED: March 18, 2018


222 Stanford Avenue

Menlo Park, CA 94025

650 690 0995

[email protected]


IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN … · 2020-03-07 · dr. lakshmi arunachalam...

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