Complex Memory, LLC v. Texas Instruments, Inc.

COMPLAINT against SVTronics, Inc., Texas Instruments, Inc. ( Filing fee $ 400 receipt number 0540-6507216.), filed by Complex Memory, LLC. (Attachments: # (1) Exhibit Attachment A, # (2) Exhibit Attachment B, # (3) Exhibit 1, # (4) Exhibit 2, # (5) Exhibit 3, # (6) Exhibit 4, # (7) Exhibit 5, # (8) Exhibit 6, # (9) Exhibit 7, # (10) Exhibit 8, # (11) Exhibit 9, # (12) Exhibit 10, # (13) Exhibit 11, # (14) Exhibit 12, # (15) Exhibit 13, # (16) Exhibit 14, # (17) Exhibit 15, # (18) Exhibit 16, # (19) Exhibit 17, # (20) Exhibit 18, # (21) Exhibit 19, # (22) Exhibit 20, # (23) Exhibit 21, # (24) Exhibit 22, # (25) Exhibit 23, # (26) Exhibit 24, # (27) Civil Cover Sheet)(Van Cleef, L.)

2017-10-13

1

View

Notice of Filing of Patent/Trademark Form (AO 120). AO 120 mailed to the Director of the U.S. Patent and Trademark Office. (Van Cleef, L.)

2017-10-13

1

View

CORPORATE DISCLOSURE STATEMENT filed by Complex Memory, LLC (Van Cleef, L.)

2017-10-13

1

View

DEMAND for Trial by Jury by Complex Memory, LLC. (Van Cleef, L.)

2017-10-13

1

View

NOTICE of Attorney Appearance by Dmitry Kheyfits on behalf of Complex Memory, LLC (Kheyfits, Dmitry)

2017-10-14

1

View

SUMMONS Issued as to SVTronics, Inc., Texas Instruments, Inc.. (Attachments: # (1) Summons(es))(ch, )

2017-10-16

1

View

NOTICE of Attorney Appearance by Andrey Belenky on behalf of Complex Memory, LLC (Belenky, Andrey)

2017-10-16

1

Download

In accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice Regarding Consent to Proceed Before Magistrate Judge. (ch, )

2017-10-16

1

No Actions

Notice of Magistrate Availability

2017-10-16

1

No Actions

Case Assigned/Reassigned

2017-10-16

1

No Actions

Case assigned to Judge Rodney Gilstrap. (ch, )

2017-10-16

1

No Actions

Defendant's Unopposed First Application for Extension of Time to Answer Complaint re Texas Instruments, Inc.( Hill, Jack)

2017-10-24

1

Download

Application Granted for Extension of Time to Answer Complaint

2017-10-24

1

No Actions

Defendant's Unopposed FIRST Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for Texas Instruments, Inc. to 12/13/2017. 30 Days Granted for Deadline Extension.( ch, )

2017-10-24

1

No Actions

Defendant's Unopposed First Application for Extension of Time to Answer Complaint re SVTronics, Inc..( Hill, Jack)

2017-10-27

1

Download

Application Granted for Extension of Time to Answer Complaint

2017-10-30

1

No Actions

Defendant's Unopposed First Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for SVTronics, Inc. to 12/11/2017. 30 Days Granted for Deadline Extension.( nkl, )

2017-10-30

1

No Actions

NOTICE of Attorney Appearance by Hanna Glomska Cohen on behalf of Complex Memory, LLC (Cohen, Hanna)

2017-11-02

1

View

NOTICE of Attorney Appearance by Craig Steven Jepson on behalf of Complex Memory, LLC (Jepson, Craig)

2017-11-07

1

View

SUMMONS Returned Executed by Complex Memory, LLC. Texas Instruments, Inc. served on 10/20/2017 (ch, )

2017-11-08

1

View

SUMMONS Returned Executed by Complex Memory, LLC. SVTronics, Inc. served on 10/19/2017 (ch, )

2017-11-08

1

View

NOTICE of Attorney Appearance by Amanda Aline Abraham on behalf of Texas Instruments, Inc. (Abraham, Amanda)

2017-12-01

1

View

NOTICE of Attorney Appearance by Amanda Aline Abraham on behalf of SVTronics, Inc. (Abraham, Amanda)

2017-12-07

1

View

Defendant's Unopposed Second Application for Extension of Time to Answer Complaint re SVTronics, Inc..( Abraham, Amanda)

2017-12-08

1

View

Defendant's Unopposed Second Application for Extension of Time to Answer Complaint re Texas Instruments, Inc..( Abraham, Amanda)

2017-12-08

1

View

Application Granted for Extension of Time to Answer Complaint

2017-12-08

1

No Actions

Application Granted for Extension of Time to Answer Complaint

2017-12-08

1

No Actions

Defendant's Unopposed SECOND Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for SVTronics, Inc. to 12/26/2017. 15 Days Granted for Deadline Extension.( ch, )

2017-12-08

1

No Actions

Defendant's Unopposed SECOND Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for Texas Instruments, Inc. to 12/28/2017. 15 Days Granted for Deadline Extension.( ch, )

2017-12-08

1

No Actions

Unopposed MOTION for Extension of Time to File Answer to Plaintifff's Complaint by SVTronics, Inc., Texas Instruments, Inc.. (Attachments: # (1) Text of Proposed Order)(Abraham, Amanda)

2017-12-21

1

View

ORDER granting [18] Motion for Extension of Time to Answer re [1] Complaint. Signed by District Judge Rodney Gilstrap on 12/22/2017. (nkl, )

2017-12-22

1

View

Update Answer Deadline

2017-12-22

1

No Actions

Answer Due Deadline Updated for SVTronics, Inc. to 1/10/2018; Texas Instruments, Inc. to 1/10/2018. (nkl, )

2017-12-22

1

No Actions

SCHEDULING ORDER - Scheduling Conference set for 2/2/2018 01:30 PM before District Judge Rodney Gilstrap. Signed by District Judge Rodney Gilstrap on 1/4/18. (ch, )

2018-01-04

1

View

NOTICE of Attorney Appearance by Andrea Leigh Fair on behalf of Texas Instruments, Inc. (Fair, Andrea)

2018-01-05

1

View

CORPORATE DISCLOSURE STATEMENT filed by Texas Instruments, Inc. (Abraham, Amanda)

2018-01-10

1

View

Texas Instruments Incorporated's ANSWER to [1] Complaint,, And, COUNTERCLAIM against Complex Memory, LLC by Texas Instruments, Inc..(Abraham, Amanda)

2018-01-10

1

Download

SVTronics, Inc.'s ANSWER to [1] Complaint,, and, COUNTERCLAIM against Complex Memory, LLC by SVTronics, Inc..(Abraham, Amanda)

2018-01-10

1

View

CORPORATE DISCLOSURE STATEMENT filed by SVTronics, Inc. (Abraham, Amanda)

2018-01-10

1

View

In accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice Regarding Consent to Proceed Before Magistrate Judge. (ch, )

2018-01-10

1

No Actions

NOTICE of Designation of Mediator, Honorable David Folsom, filed by Complex Memory, LLC. (Van Cleef, L.)

2018-01-12

1

Download

NOTICE of Discovery Disclosure by Complex Memory, LLC (PR 3-1 and 3-2 Disclosures) (Van Cleef, L.)

2018-01-19

1

View

NOTICE of Attorney Appearance by Jeffrey G Toler on behalf of Complex Memory, LLC (Toler, Jeffrey)

2018-01-22

1

View

NOTICE of Attorney Appearance by Raymond William Mort, III on behalf of Complex Memory, LLC (Mort, Raymond)

2018-01-23

1

View

NOTICE of Hearing: Scheduling Conference RESET for 2/1/2018 01:30 PM in Ctrm 106 (Marshall) before District Judge Rodney Gilstrap. (jml)

2018-01-23

1

No Actions

ANSWER to [23] Answer to Complaint, Counterclaim By Texas Instruments, Inc. by Complex Memory, LLC.(Van Cleef, L.)

2018-01-29

1

View

ANSWER to [24] Answer to Complaint, Counterclaim by SVTronics, Inc. by Complex Memory, LLC.(Van Cleef, L.)

2018-01-29

1

View

Minute Entry for proceedings held before Judge Rodney Gilstrap: Scheduling Conference held on 2/1/2018. Counsel for the parties appeared and were asked if they consented to a trial before the United States Magistrate Judge. The Court then gave Markman and Jury Selection dates; deadlines for submitting Mediator names (3 days); and deadlines for submitting Agreed Scheduling and Discovery Orders (14 days). (Court Reporter Shelly Holmes, CSR-TCRR.)(jml)

2018-02-01

1

No Actions

ORDER REFERRING CASE to Mediator David Folsom, Jackson Walker, L.L.P., 6002-B Summerfield Drive, Texarkana, Texas 75503, telephone number 903-255-3251, fax number 903-255-3266, and email dfolsom@jw.com, is hereby appointed as mediator in the above referenced case. Signed by District Judge Rodney Gilstrap on 2/2/18. (ch, )

2018-02-02

1

View

Scheduling Conference

2018-02-02

1

No Actions

Joint MOTION for Entry of Agreed Docket Control Order and Agreed Discovery Order by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order Proposed Docket Control Order, # (2) Text of Proposed Order Proposed Discovery Order)(Van Cleef, L.)

2018-02-15

1

View

DOCKET CONTROL ORDER - granting [33] Joint MOTION for Entry of Agreed Docket Control Order and Agreed Discovery Order. Pretrial Conference set for 4/8/2019 09:00 AM before District Judge Rodney Gilstrap., Amended Pleadings due by 8/29/2018., Jury Selection set for 5/6/2019 09:00AM before District Judge Rodney Gilstrap., Mediation Completion due by 12/12/2018., Markman Hearing set for 11/14/2018 01:30 PM before District Judge Rodney Gilstrap., Motions due by 3/22/2019., Proposed Pretrial Order due by 4/1/2019. Signed by District Judge Rodney Gilstrap on 2/20/2018. (ch, )

2018-02-20

1

View

DISCOVERY ORDER. Signed by District Judge Rodney Gilstrap on 2/20/2018. (ch, )

2018-02-20

1

View

Joint MOTION for Entry of Agreed Protective Order by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

2018-02-22

1

View

NOTICE of Discovery Disclosure by Complex Memory, LLC (Van Cleef, L.)

2018-02-22

1

View

NOTICE of Discovery Disclosure by SVTronics, Inc. (Abraham, Amanda)

2018-02-23

1

Download

NOTICE of Discovery Disclosure by Texas Instruments, Inc. (Abraham, Amanda)

2018-02-23

1

View

PROTECTIVE ORDER granting [36] Agreed Motion for Entry of Protective Order. Signed by District Judge Rodney Gilstrap on 2/23/2018. (ch, )

2018-02-23

1

View

NOTICE of Attorney Appearance by Anupam Sharma on behalf of Texas Instruments, Inc. (Sharma, Anupam)

2018-03-08

1

View

NOTICE of Attorney Appearance by Ranganath Sudarshan on behalf of Texas Instruments, Inc. (Sudarshan, Ranganath)

2018-03-08

1

View

NOTICE of Attorney Appearance by Patrick N Flynn on behalf of Texas Instruments, Inc. (Flynn, Patrick)

2018-03-08

1

View

NOTICE of Attorney Appearance by Robert Thomas Haslam, III on behalf of Texas Instruments, Inc. (Haslam, Robert)

2018-03-08

1

View

NOTICE of Attorney Appearance by Aakash S Parekh on behalf of Complex Memory, LLC (Parekh, Aakash)

2018-04-30

1

View

NOTICE of Attorney Appearance by Benjamin R Johnson on behalf of Complex Memory, LLC (Johnson, Benjamin)

2018-04-30

1

View

NOTICE of Change of Address by Raymond William Mort, III (Mort, Raymond)

2018-05-01

1

View

Unopposed MOTION to Withdraw as Attorney by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Mort, Raymond)

2018-05-01

1

View

ORDER granting [48] Motion to Withdraw as Attorney. Attorney Raymond William Mort, III terminated. Signed by District Judge Rodney Gilstrap on 5/2/2018. (nkl, )

2018-05-03

1

View

STIPULATION of Partial Dismissal by all Parties by Complex Memory, LLC. (Van Cleef, L.) (Additional attachment(s) added on 5/9/2018: # (1) Text of Proposed Order) (ch, ).

2018-05-09

1

View

ORDER re [50] Stipulation of Partial Dismissal by all Parties filed by Complex Memory, LLC. Signed by District Judge Rodney Gilstrap on 5/10/2018. (nkl, )

2018-05-10

1

View

Joint MOTION to Stay All Deadlines and Notice of Settlement by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

2018-05-18

1

View

ORDER granting [52] Motion to Stay All Deadlines and Notice of Settlement. Signed by District Judge Rodney Gilstrap on 5/18/2018. (nkl, )

2018-05-18

1

View

Joint MOTION to Extend Stay re [53] Order on Motion to Stay by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

2018-06-13

1

View

ORDER granting [54] Motion to Extend Stay. Signed by District Judge Rodney Gilstrap on 6/15/2018. (nkl, )

2018-06-15

1

View

NOTICE of Change of Address by Dmitry Kheyfits (Kheyfits, Dmitry)

2018-06-20

1

Download

NOTICE of Change of Address by Andrey Belenky (Belenky, Andrey)

2018-06-20

1

View

NOTICE of Change of Address by Hanna Glomska Cohen (Cohen, Hanna)

2018-06-20

1

View

Joint MOTION to Dismiss all Claims and Counterclaims as to SVTronics, Inc. Without Prejudice by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

2018-07-02

1

View

Joint MOTION to Dismiss all Claims and Counterclaims as to Texas Instruments, Inc. With Prejudice by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

2018-07-02

1

View

ORDER granting [60] Joint MOTION to Dismiss all Claims and Counterclaims as to Texas Instruments, Inc. With Prejudice. granting [59] Joint MOTION to Dismiss all Claims and Counterclaims as to SVTronics, Inc. Without Prejudice. Signed by District Judge Rodney Gilstrap on 7/6/18. (ch, )

2018-07-06

1

View

Notice of Filing of Patent/Trademark Form (AO 120) at termination of case. AO 120 mailed to the Director of the U.S. Patent and Trademark Office. (ch, )

2018-07-06

1

View

Overview

Parties

Defendant

SVTronics, Inc. Follow

Represented By

Texas Instruments, Inc. Follow

Represented By

Plaintiff

Complex Memory, LLC Follow

Represented By

Court & Judges

Patents Involved

Docket Entries

Notice of Filing of Patent/Trademark Form (AO 120). AO 120 mailed to the Director of the U.S. Patent and Trademark Office. (Van Cleef, L.)

CORPORATE DISCLOSURE STATEMENT filed by Complex Memory, LLC (Van Cleef, L.)

DEMAND for Trial by Jury by Complex Memory, LLC. (Van Cleef, L.)

NOTICE of Attorney Appearance by Dmitry Kheyfits on behalf of Complex Memory, LLC (Kheyfits, Dmitry)

SUMMONS Issued as to SVTronics, Inc., Texas Instruments, Inc.. (Attachments: # (1) Summons(es))(ch, )

NOTICE of Attorney Appearance by Andrey Belenky on behalf of Complex Memory, LLC (Belenky, Andrey)

Notice of Magistrate Availability

Case Assigned/Reassigned

Case assigned to Judge Rodney Gilstrap. (ch, )

Defendant's Unopposed First Application for Extension of Time to Answer Complaint re Texas Instruments, Inc.( Hill, Jack)

Application Granted for Extension of Time to Answer Complaint

Defendant's Unopposed FIRST Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for Texas Instruments, Inc. to 12/13/2017. 30 Days Granted for Deadline Extension.( ch, )

Defendant's Unopposed First Application for Extension of Time to Answer Complaint re SVTronics, Inc..( Hill, Jack)

Application Granted for Extension of Time to Answer Complaint

Defendant's Unopposed First Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for SVTronics, Inc. to 12/11/2017. 30 Days Granted for Deadline Extension.( nkl, )

NOTICE of Attorney Appearance by Hanna Glomska Cohen on behalf of Complex Memory, LLC (Cohen, Hanna)

NOTICE of Attorney Appearance by Craig Steven Jepson on behalf of Complex Memory, LLC (Jepson, Craig)

SUMMONS Returned Executed by Complex Memory, LLC. Texas Instruments, Inc. served on 10/20/2017 (ch, )

SUMMONS Returned Executed by Complex Memory, LLC. SVTronics, Inc. served on 10/19/2017 (ch, )

NOTICE of Attorney Appearance by Amanda Aline Abraham on behalf of Texas Instruments, Inc. (Abraham, Amanda)

NOTICE of Attorney Appearance by Amanda Aline Abraham on behalf of SVTronics, Inc. (Abraham, Amanda)

Defendant's Unopposed Second Application for Extension of Time to Answer Complaint re SVTronics, Inc..( Abraham, Amanda)

Defendant's Unopposed Second Application for Extension of Time to Answer Complaint re Texas Instruments, Inc..( Abraham, Amanda)

Application Granted for Extension of Time to Answer Complaint

Application Granted for Extension of Time to Answer Complaint

Defendant's Unopposed SECOND Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for SVTronics, Inc. to 12/26/2017. 15 Days Granted for Deadline Extension.( ch, )

Defendant's Unopposed SECOND Application for Extension of Time to Answer Complaint is granted pursuant to Local Rule CV-12 for Texas Instruments, Inc. to 12/28/2017. 15 Days Granted for Deadline Extension.( ch, )

Unopposed MOTION for Extension of Time to File Answer to Plaintifff's Complaint by SVTronics, Inc., Texas Instruments, Inc.. (Attachments: # (1) Text of Proposed Order)(Abraham, Amanda)

ORDER granting [18] Motion for Extension of Time to Answer re [1] Complaint. Signed by District Judge Rodney Gilstrap on 12/22/2017. (nkl, )

Update Answer Deadline

Answer Due Deadline Updated for SVTronics, Inc. to 1/10/2018; Texas Instruments, Inc. to 1/10/2018. (nkl, )

SCHEDULING ORDER - Scheduling Conference set for 2/2/2018 01:30 PM before District Judge Rodney Gilstrap. Signed by District Judge Rodney Gilstrap on 1/4/18. (ch, )

NOTICE of Attorney Appearance by Andrea Leigh Fair on behalf of Texas Instruments, Inc. (Fair, Andrea)

CORPORATE DISCLOSURE STATEMENT filed by Texas Instruments, Inc. (Abraham, Amanda)

Texas Instruments Incorporated's ANSWER to [1] Complaint,, And, COUNTERCLAIM against Complex Memory, LLC by Texas Instruments, Inc..(Abraham, Amanda)

SVTronics, Inc.'s ANSWER to [1] Complaint,, and, COUNTERCLAIM against Complex Memory, LLC by SVTronics, Inc..(Abraham, Amanda)

CORPORATE DISCLOSURE STATEMENT filed by SVTronics, Inc. (Abraham, Amanda)

NOTICE of Designation of Mediator, Honorable David Folsom, filed by Complex Memory, LLC. (Van Cleef, L.)

NOTICE of Discovery Disclosure by Complex Memory, LLC (PR 3-1 and 3-2 Disclosures) (Van Cleef, L.)

NOTICE of Attorney Appearance by Jeffrey G Toler on behalf of Complex Memory, LLC (Toler, Jeffrey)

NOTICE of Attorney Appearance by Raymond William Mort, III on behalf of Complex Memory, LLC (Mort, Raymond)

NOTICE of Hearing: Scheduling Conference RESET for 2/1/2018 01:30 PM in Ctrm 106 (Marshall) before District Judge Rodney Gilstrap. (jml)

ANSWER to [23] Answer to Complaint, Counterclaim By Texas Instruments, Inc. by Complex Memory, LLC.(Van Cleef, L.)

ANSWER to [24] Answer to Complaint, Counterclaim by SVTronics, Inc. by Complex Memory, LLC.(Van Cleef, L.)

Scheduling Conference

Joint MOTION for Entry of Agreed Docket Control Order and Agreed Discovery Order by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order Proposed Docket Control Order, # (2) Text of Proposed Order Proposed Discovery Order)(Van Cleef, L.)

DISCOVERY ORDER. Signed by District Judge Rodney Gilstrap on 2/20/2018. (ch, )

Joint MOTION for Entry of Agreed Protective Order by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

NOTICE of Discovery Disclosure by Complex Memory, LLC (Van Cleef, L.)

NOTICE of Discovery Disclosure by SVTronics, Inc. (Abraham, Amanda)

NOTICE of Discovery Disclosure by Texas Instruments, Inc. (Abraham, Amanda)

PROTECTIVE ORDER granting [36] Agreed Motion for Entry of Protective Order. Signed by District Judge Rodney Gilstrap on 2/23/2018. (ch, )

NOTICE of Attorney Appearance by Anupam Sharma on behalf of Texas Instruments, Inc. (Sharma, Anupam)

NOTICE of Attorney Appearance by Ranganath Sudarshan on behalf of Texas Instruments, Inc. (Sudarshan, Ranganath)

NOTICE of Attorney Appearance by Patrick N Flynn on behalf of Texas Instruments, Inc. (Flynn, Patrick)

NOTICE of Attorney Appearance by Robert Thomas Haslam, III on behalf of Texas Instruments, Inc. (Haslam, Robert)

NOTICE of Attorney Appearance by Aakash S Parekh on behalf of Complex Memory, LLC (Parekh, Aakash)

NOTICE of Attorney Appearance by Benjamin R Johnson on behalf of Complex Memory, LLC (Johnson, Benjamin)

NOTICE of Change of Address by Raymond William Mort, III (Mort, Raymond)

Unopposed MOTION to Withdraw as Attorney by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Mort, Raymond)

ORDER granting [48] Motion to Withdraw as Attorney. Attorney Raymond William Mort, III terminated. Signed by District Judge Rodney Gilstrap on 5/2/2018. (nkl, )

STIPULATION of Partial Dismissal by all Parties by Complex Memory, LLC. (Van Cleef, L.) (Additional attachment(s) added on 5/9/2018: # (1) Text of Proposed Order) (ch, ).

ORDER re [50] Stipulation of Partial Dismissal by all Parties filed by Complex Memory, LLC. Signed by District Judge Rodney Gilstrap on 5/10/2018. (nkl, )

Joint MOTION to Stay All Deadlines and Notice of Settlement by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

ORDER granting [52] Motion to Stay All Deadlines and Notice of Settlement. Signed by District Judge Rodney Gilstrap on 5/18/2018. (nkl, )

Joint MOTION to Extend Stay re [53] Order on Motion to Stay by Complex Memory, LLC. (Attachments: # (1) Text of Proposed Order)(Van Cleef, L.)

SVTronics, Inc.

Texas Instruments, Inc.

Complex Memory, LLC