Thrival v. Mollohan - Answer & Counterclaims
Thrival v. Mollohan - Answer & Counterclaims
Counterclaim-plaintiff,
v.
Counter-defendant,
______________________________________________________________________________
“Mollohan”), by and through its undersigned counsel, hereby provides its Answer, Defenses, and
(“Defendant” or “Thrival”) Counterclaims filed on October 28, 2022 (Dkt. 55), and states and
avers as follows:
GENERAL DENIAL
Mollohan denies all the allegations in Thrival’s Counterclaims unless expressly admitted
in the following paragraphs. Moreover, Mollohan denies that Thrival is entitled to any relief,
including that requested in its Prayer for Relief. Mollohan reserves the right to take additional
Because headings are not allegations, no response to them is required. To the extent the
headings in Thrival’s Counterclaims are deemed to contain factual allegations, such allegations
1. Except to admit that Thrival filed a counterclaim action for various claims,
declaratory judgment of trademark fair use, and intentional interference with prospective
business relations, Mollohan denies the allegations set forth in Paragraph 1 and denies that
THE PARTIES
truth or falsity of the allegations set forth in Paragraph 2, and on that basis denies them.
3. Admitted.
4. Mollohan admits that he is one of Pso-Rite’s founders, owners, and principals and
is the inventor of “The Pso-Rite.” Mollohan further admits that he is Pso-Rite’s registered agent
and that he can be served at 1815 Purdy Avenue, Miami Beach, FL 33139 in his capacity as Pso-
Rite’s agent only. Mollohan denies Paragraph 4 to the extent that it alleges that he currently
1All headings and subheadings are as stated in Thrival’s Counterclaims. Mollohan’s replication
of headings in the Counterclaims are merely for convenience and are not to be considered an
admission of their accuracy. Accordingly, Mollohan denies them on this basis.
2
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 3 of 26
resides in Miami, Florida. Any other allegation set forth in Paragraph 4 not expressly admitted is
denied.
this Court, so no response is required. To the extent that a response is required, Mollohan admits
that this Court has subject matter jurisdiction over Thrival’s Counts I-III and VI-VIII, but denies
that the Court has subject matter jurisdiction over Thrival’s Counts IV and V. Mollohan denies
this Court, so no response is required. To the extent that a response is required, Mollohan admits
that this Court has subject matter jurisdiction over Thrival’s state-law counterclaims, Thrival’s
Court, so no response is required. To the extent that a response is required, Mollohan admits that
for the purposes of this action only the Court has personal jurisdiction over it. Mollohan denies
required. To the extent that a response is required, Mollohan denies the allegations set forth in
Paragraph 8.
response is required. To the extent that a response is required, Mollohan admits that for the
3
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 4 of 26
purposes of this action only venue is proper in this Court as to counterclaims against Mollohan.
BACKGROUND
truth or falsity of the allegations set forth in Paragraph 10, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 11, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 12, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 13, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 14, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 15, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 16, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 17, and on that basis denies them.
4
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 5 of 26
truth or falsity of the allegations set forth in Paragraph 18, and on that basis denies them.
19. To the extent the allegations of Paragraph 19 purport to characterize the contents
of the ’180 Design Patent, the ’180 Design Patent speaks for itself. As for the remaining
belief as to the truth or falsity of the allegations set forth therein, and on that basis denies them.
20. Admitted.
21. Admitted.
truth or falsity of the allegations set forth in Paragraph 22, and on that basis denies them.
23. Denied.
truth or falsity of the allegations set forth in Paragraph 24, and on that basis denies them.
25. Denied.
26. Denied.
truth or falsity of the allegations set forth in Paragraph 27, and on that basis denies them.
28. Admitted.
29. Admitted.
30. Admitted.
31. Admitted.
5
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 6 of 26
32. Admitted.
33. Admitted.
34. Admitted.
35. Admitted.
36. Denied.
37. Mollohan admits that the Court granted in part Thrival’s Motion to Dismiss and
dismissed with prejudice Pso-Rite’s claim that Thrival and its members infringe the ’479 Design
Patent, but further states that this decision is not a final, non-appealable judgment and thus may
still be appealed to the United States Court of Appeals for the Federal Circuit.
38. Admitted.
39. To the extent the allegations of Paragraph 39 purport to characterize the contents
of the ’336 Design Patent, the ’336 Design Patent speaks for itself. Mollohan denies the
40. To the extent the allegations of Paragraph 40 purport to characterize the contents
of the ’336 Design Patent, the ’336 Design Patent speaks for itself. Mollohan denies the
41. To the extent the allegations of Paragraph 41 purport to characterize the contents
of the ’336 Design Patent, the ’336 Design Patent speaks for itself. Mollohan denies the
42. Mollohan admits the allegations set forth in Paragraph 42. However, because
Mollohan is not aware of the source of the photographs depicted in Paragraph 42, Mollohan is
6
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 7 of 26
without knowledge or information as to the authenticity of the photographs, and leaves Thrival to
43. Denied.
44. Admitted.
45. Admitted.
46. Denied.
47. Because Mollohan is not aware of the source of the quotation and screenshot set
forth in Paragraph 47, Mollohan is without knowledge or information as to their authenticity, and
48. To the extent the allegations of Paragraph 48 purport to characterize the contents
of Pso-Rite’s website, Pso-Rite’s website speaks for itself. Mollohan denies the remaining
49. Denied.
50. Denied.
51. Denied.
truth or falsity of the allegations set forth in Paragraph 52, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 53, and on that basis denies them.
Moreover, because Mollohan is not aware of the source of the screenshot set forth in Paragraph
7
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 8 of 26
53, Mollohan is without knowledge or information as to its authenticity, and therefore denies the
truth or falsity of the allegations set forth in Paragraph 54, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 55, and on that basis denies them.
Moreover, because Mollohan is not aware of the source of the screenshot set forth in Paragraph
55, Mollohan is without knowledge or information as to its authenticity, and therefore denies the
56. Denied.
57. Denied.
58. Denied.
59. Denied.
60. Mollohan admits that on or about December 29, 2020, Pso-Rite sent a cease and
desist letter to Defendant Mr. Cameron Smith, with copy to Defendant Mr. William Edward
Smith, Defendant Mr. Dominic Rainville, Ms. McKenzie Flinchum, Mr. River Radamus, and
Ms. Wendy Puckett, accusing Thrival of, among other things, willfully infringing the ’479
Design Patent and unfairly competing and tortiously interfering with Pso-Rite’s business.
61. Denied.
62. Denied.
63. Denied.
8
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 9 of 26
FIRST COUNTERCLAIM
([Alleged] Infringement of U.S. Patent No. 9,687,416)
(Against Pso-Rite and Mr. Mollohan)
64. Mollohan repeats its responses to the prior allegations as if fully set forth herein.
truth or falsity of the allegations set forth in Paragraph 65, and on that basis denies them.
truth or falsity of the allegations set forth in Paragraph 66, and on that basis denies them.
67. Denied.
68. Denied.
69. Denied.
70. Denied.
71. Denied.
72. Denied.
73. Denied.
SECOND COUNTERCLAIM
(Request for Declaratory Judgment of Invalidity of the ’336 Design Patent)
(Against Pso-Rite)
THIRD COUNTERCLAIM
(Request for Declaratory Judgment of Non-Infringement of the ’336 Design Patent)
(Against Pso-Rite)
FOURTH COUNTERCLAIM
(Request for Declaratory Judgment of Invalidity of the ’479 Design Patent)
(Against Pso-Rite)
9
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 10 of 26
FIFTH COUNTERCLAIM
(Request for Declaratory Judgment of Non-Infringement of the ’479 Design Patent)
(Against Pso-Rite)
SIXTH COUNTERCLAIM
(Trademark Cancellation – 15 U.S.C. § 1119)
(Against Pso-Rite)
SEVENTH COUNTERCLAIM
(Request for Declaratory Judgment of Non-Infringement and Invalidity of PSO Marks)
(Against Pso-Rite)
EIGHTH COUNTERCLAIM
(Request for Declaratory Judgment of Fair Use of “Pso”)
(Against Pso-Rite)
NINTH COUNTERCLAIM
([Alleged] Intentional Interference with Prospective Business Relations)
(Against Pso-Rite and Mr. Mollohan)
133. Mollohan repeats its responses to the prior allegations as if fully set forth herein.
134. Mollohan admits that on or about December 29, 2020, Pso-Rite sent a cease and
desist letter to Defendant Mr. Cameron Smith, with copy to Defendant Mr. William
Edward Smith, Defendant Mr. Dominic Rainville, Ms. McKenzie Flinchum, Mr. River
Radamus, and Ms. Wendy Puckett, accusing Thrival of, among other things, willfully
infringing the ’479 Design Patent, Pso-Rite’s trademarks, and unfairly competing and
135. Denied.
10
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 11 of 26
136. Denied.
137. Denied.
138. Denied.
Mollohan denies that this is an exceptional case and therefore denies that Defendants are
entitled to an award of their reasonable attorneys’ fees, costs, and expenses incurred in
connection with this action pursuant to 35 U.S.C. § 285, 15 U.S.C. § 1117, or any other statute,
Mollohan denies each and every allegation not expressly admitted above. A response is
not required to Thrival’s Prayer for Relief. To the extent that a response is required, Mollohan
expressly denies that Thrival is entitled to the judgment and relief prayed for in Paragraphs A
through Q or to any relief whatsoever. Mollohan respectfully requests that the Court deny all of
Thrival’s Counterclaims and Prayer for Relief in their entirety and with prejudice.
ADDITIONAL DEFENSES
so, Mollohan does not assume any burden of proof on any issues that is Thrival’s burden as a
matter of law. Mollohan also reserves the right to amend or supplement these defenses as
FIRST DEFENSE
(Lack Of Subject Matter Jurisdiction)
11
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 12 of 26
The Court lacks subject matter jurisdiction over at least Thrival’s Fourth and Fifth
Counterclaims regarding the ’479 Design Patent because Thrival does not make, use, sell, or
offer for sale any product that Mollohan is presently accusing infringes the ’479 Design Patent.
SECOND DEFENSE
(Failure To State A Claim)
Thrival’s Counterclaims and any purported claims for relief alleged therein fail to state a
THIRD DEFENSE
(Non-Infringement Of The ’416 Patent)
Mollohan has not infringed, and currently does not infringe, including directly, indirectly,
and/or under the doctrine of equivalents, any valid and enforceable claim of the ’416 Patent, and
FOURTH DEFENSE
(Invalidity Of The ’416 Patent)
The ’416 Patent is invalid for failure to comply with one or more of the conditions and
requirements of the patent laws, including but not limited to 35 U.S.C. §§ 101, 102, 103, 112,
and/or any other applicable statutory provisions of Title 35 of the United States Code.
FIFTH DEFENSE
(Prosecution History Estoppel)
The relief sought by Thrival with respect to the ’416 Patent is barred, in whole or in part,
under the doctrine of prosecution history estoppel due to amendments and/or statements made
SIXTH DEFENSE
(Limitation On Damages And Costs)
12
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 13 of 26
Thrival’s claim for damages for any alleged infringement of the ’416 Patent is barred, in
whole or in part, because Thrival and/or the predecessor or licensee(s) of the ’416 Patent failed
to satisfy the requirements of one or more of 35 U.S.C. §§ 286, 287, and/or 288.
SEVENTH DEFENSE
(Unavailability Of Injunctive Relief)
Thrival is not entitled to injunctive relief, as a matter of law, and cannot satisfy the
EIGHTH DEFENSE
(Good Faith)
Mollohan has engaged in all relevant activities in good faith and, therefore, Mollohan’s
actions do not give rise to an exceptional case under 35 U.S.C. § 285 or 15 U.S.C. § 1117.
Accordingly, even if Thrival prevails, it is precluded from recovering its reasonable attorneys’
NINTH DEFENSE
(Equitable Defenses)
Thrival’s claims against Mollohan are barred, in whole or in part, by the doctrine of
laches, waiver, estoppel, acquiescence, implied license, unclean hands, and/or any other
equitable remedy.
Mollohan reserves the right to assert additional defenses in the event that discovery or
13
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 14 of 26
COUNTERCLAIMS
Thrival LLC (“Thrival”) and Mr. Cameron Smith, Mr. Dominic Rainville, and Mr. William
Smith (Messrs. Smith, Rainville and Smith collectively referred to as “Individual Defendants”;
all Defendants collectively referred to as “Defendants”). Mollohan avers and states as follows:
Mollohan incorporates by reference herein Paragraphs 1-138 and its Defenses set forth
1. This is a counterclaim action for various claims arising under the patent laws of
the United States, under 35 U.S.C. § 1, et seq., including but not limited to patent infringement
Section incorporates by reference and hereby alleges each of the facts set forth in the Complaint
THE PARTIES
Beach, Florida 33139. Mackenzie Mollohan is the owner of Pso-Rite.com LLC (“Pso-Rite”)
formed and owned by Defendants Cameron Smith, Dominic Rainville and William Smith. Upon
information and belief, Thrival has its principal place of business at 2655 Copper Ridge Circle,
14
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 15 of 26
Routt County, Colorado. Upon information and belief, Cameron Smith is one of Thrival’s
founders, owners and principals. Upon information and belief, at all relevant times, Cameron
owners and principals. Upon information and belief, at all relevant times, Dominic Rainville is
6. Upon information and belief, William Smith is one of Thrival’s founders, owners
and principals. Upon information and belief, at all relevant times, William Smith is and has been
7. Upon information and belief, the Individual Defendants are the owners and
principals of Thrival. Upon information and belief, as part of their roles as Thrival, the
Individual Defendants directly and personally participate and participated in the acts of patent
infringement alleged and described herein, with full knowledge that such activities are in
violation of Mollohan’s rights pursuant to the U.S. patent laws. Accordingly, upon information
and belief, the Individual Defendants, in their capacity as owners and principals of Thrival, were
the moving, active and conscious forces behind Thrival’s infringement and other illegal
8. This Court has subject matter jurisdiction over this action and Mollohan’s
15
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 16 of 26
9. This Court has personal jurisdiction over Thrival for the reasons set forth in the
Complaint, which are incorporated herein by reference. Dkt. 1, ¶ 10. This Court also has
personal jurisdiction over Thrival because, inter alia, Thrival has submitted to the personal
10. This Court has personal jurisdiction over each of the Individual Defendants for
the reasons set forth in the Complaint, which are incorporated herein by reference. Dkt. 1, ¶ 11.
This Court also has personal jurisdiction over each of the Individual Defendants because, inter
alia, each Individual Defendant has submitted to the personal jurisdiction of this Court by filing
an Answer to the Complaint without challenging personal jurisdiction therein. Dkt. 55. As such,
any assertion that this Court does not have personal jurisdiction over the Individual Defendants
11. Pursuant to 28 U.S.C. §§ 1391(b), (c) and 1400(b), venue is proper in this judicial
district as to the Defendants for the reasons set forth in the Complaint, which are incorporated
herein by reference. Dkt. 1, ¶ 12. Venue is also proper in this judicial district as to the
Defendants because, inter alia, Thrival has submitted to the venue of this Court by filing its
Counterclaims, because each Individual Defendant has submitted to the venue of this Court by
filing an Answer to the Complaint without challenging venue therein (and thus such challenge is
waived), and because the Defendants have committed acts of patent infringement in this district
16
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 17 of 26
12. Mollohan hereby incorporates by reference Paragraphs 1-11 as if fully set forth
herein.
13. On August 17, 2021, United States Design Patent No. D928,336 (the “D’336
Patent”), entitled “Massager,” was duly and legally issued by the United States Patent and
Trademark Office (“USPTO”). A true and correct copy of the D’336 Patent is attached hereto as
Exhibit A. The D’336 Patent is valid, enforceable, and currently in full force and effect.
14. Pso-Rite is the owner and assignee of all substantial rights, title, and interest in the
D’336 Patent, including the full and exclusive right to bring this action and enforce the D’336
Patent against infringers, and the right to recover damages for all relevant time periods, including
15. Defendants have infringed and continue to infringe the D’336 Patent at least by
making, using, offering for sale, selling, and/or importing into or in the United States its Bullseye
product (“Infringing Product”), which is covered by the design claimed in the D’336 Patent,
16. As shown by the side-by-side comparisons of the design claimed in the D’336
Patent and the Infringing Product set forth below, in the eye of the ordinary observer familiar
with the relevant prior art, giving such attention as a purchaser usually gives, the overall
appearance of the claimed design of the D’336 Patent and the design of the Infringing Product
are substantially the same, such that the ordinary observer would be deceived into believing that
the Infringing Product is the same as the design claimed in the D’336 Patent, and would be
17
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 18 of 26
18
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 19 of 26
19
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 20 of 26
17. Pso-Rite did not give Defendants a license or other authorization to make, use,
offer to sell, sell, or import the Infringing Product in or into the United States.
18. Defendants have directly infringed, and continue to directly infringe, the D’336
Patent by making, using, offering to sell, selling and/or importing into or in the United States the
19. Upon information and belief, Defendants also induced, and continue to induce,
others to infringe the D’336 Patent by encouraging and promoting the use and/or sale by others
20. Defendants have applied the patented design of the D’336 Patent, or at least a
colorable imitation thereof, to an article of manufacture for the purpose of sale, and/or have sold
or exposed for sale an article of manufacture to which such design or colorable imitation has
20
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 21 of 26
been applied. Thus, Defendants are liable to Pso-Rite to the extent of Defendants’ total profit for
21. Upon information and belief, Defendants have had actual knowledge of the D’336
Patent since at least August 17, 2021 (the date the D’336 Patent issued) because Pso-Rite put
Defendants on notice of the D’336 Patent’s expected issuance and Defendants’ infringement
22. Upon information and belief, Defendants knew or should have known that the
making, using, offering to sell, selling and/or importing into the United States of the Infringing
23. Defendants’ direct and indirect infringement of the D’336 Patent has caused and
24. Defendants’ direct and indirect infringement has also caused and will continue to
cause irreparable harm to Pso-Rite for which there is no adequate remedy at law unless and until
such infringing conduct is enjoined pursuant to 35 U.S.C. § 283 and/or the equitable powers of
this Court.
25. Because Defendants had knowledge of their direct infringement of the D’336
Patent since at least August 17, 2021, Defendants’ acts of infringement have been and continue
characteristic of a pirate and an egregious case of misconduct beyond typical. Therefore, such
acts constitute willful infringement and make this case exceptional pursuant to 35 U.S.C. §§ 284
and 285. Defendants’ willful infringement entitles Pso-Rite to enhanced damages under 35
21
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 22 of 26
U.S.C. § 284 and to its reasonable attorneys’ fees and costs in prosecuting this action under 35
U.S.C. § 285.
26. Mollohan hereby incorporates by reference Paragraphs 1-25 as if fully set forth
herein.
27. Based on Thrival’s filing of its Counterclaim against Mollohan for alleged
infringement of U.S. Patent No. 9,687,416 (the “’416 Patent”) and Mollohan’s defenses to same
as set forth in Mollohan’s Answer above, an actual controversy has arisen and now exists
between Thrival and Mollohan as to Mollohan’s alleged infringement of the ’416 Patent.
28. Mollohan has not infringed, nor is it infringing, any of the asserted claims of the
’416 Patent either directly, or indirectly, literally or under the doctrine of equivalents, at least
because its Pso-Rite Massage Tool does not infringe, literally or under the doctrine of
29. Mollohan respectfully requests the Court to declare that the asserted claims of the
30. Mollohan hereby incorporates by reference Paragraphs 1-29 as if fully set forth
herein.
31. Based on Thrival’s filing of its Counterclaim against Mollohan for alleged
infringement of the ’416 Patent and Mollohan’s defenses to same as set forth in Mollohan’s
22
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 23 of 26
Answer above, an actual controversy has arisen and now exists between Thrival and Mollohan as
32. The asserted claims of the ’416 Patent are invalid for failing to comply with the
patent law provisions of the United States, as codified in Title 35 of the United States Code,
including failing to comply with one or more of the requirements of 35 U.S.C. §§ 101, 102, 103,
and/or 112 thereof, or the Rules and Regulations of the USPTO set forth in Title 37 of the Code
of Federal Regulations.
33. For example, the asserted claims of the ’416 Patent are invalid because they fail to
meet the conditions for patentability under 35 U.S.C. §§ 101, 102, 103, and/or 112 because they
lack utility, are taught by, suggested by, and/or rendered obvious in view of the prior art, and/or
are not adequately supported by the written description, and/or are indefinite and/or are not
enabled.
34. Mollohan requests the Court to declare that the asserted claims of the ’416 Patent
are invalid.
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Mollohan hereby demands a
B. Entry of a judgment that Thrival takes nothing by its Counterclaims and dismiss
23
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 24 of 26
C. Entry of a judgment that Defendants have directly and/or indirectly infringed the
and/or the equitable powers of this Court, to prevent further direct and/or induced infringement
compensate Mollohan for the infringement that has occurred, pursuant to 35 U.S.C. § 284;
F. Entry of an Order requiring Defendants to account for and pay to Mollohan any
and all profits made by Defendants from the sales of their infringing products pursuant to 35
U.S.C. § 289;
H. Entry of a judgment that Mollohan has not infringed, nor is it infringing, either
directly or indirectly, literally or under the doctrine of equivalents, any of the asserted claims of
I. Entry of a judgment that the asserted claims of the ’416 Patent are invalid;
J. Entry of a judgment finding that this case is exceptional within the meaning of 35
U.S.C. § 285 and an Order requiring Defendants to pay Mollohan its costs and attorneys’ fees in
this action pursuant to 35 U.S.C. § 285 and/or other applicable laws; and
K. Entry of an award for any further relief as the Court may deem just and proper.
24
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 25 of 26
s/ Hollie J. Kucera
Hollie J. Kucera
[email protected]
Insigne PC
5650 El Camino Real, Ste 130
Carlsbad, CA 92008
Telephone: (858) 227-6633
Facsimile: (858) 408-4422
Trevor Q. Coddington
[email protected]
Insigne PC
2121 Lohmans Crossing Rd., Ste 504-138
Austin, TX 78734
Telephone: (737) 282-3600
25
Case 1:21-cv-00775-PAB-STV Document 87 Filed 03/31/23 USDC Colorado Page 26 of 26
CERTIFICATE OF SERVICE
I hereby certify that on March 31, 2023, I electronically filed the foregoing with the Clerk
of the Court using the CM/ECF system which will send notification of such filing to all counsel of
record.
26