|
Experience
Litigation
Pulse Electronics, Inc. v. U.D. Electronic Corp.
U.S. District Court for the Southern District of California, Case No. 3:18-cv-00373
Counsel for U.D. Electronic Corp. in three-patent case relating to RJ-45 Integrated Connector Modules; pending.
Vanguard Pai Lung, LLC and Pai Lung Machinery Mill Co., Ltd v. William Moody et al
State of California, County of Mecklenburg, Business Court
Lead counsel for plaintiffs in business litigation before Judge Robert Conrad involving claims of fraud, conversion, breach of contract, and other business claims. Case pending.
Lucent Trans Electronic Co., Inc. v. Foreign Trade Corporation D/B/A Technocel et al
U.S. District Court for the Central District of California
Lead counsel for plaintiff Lucent Trans in business litigation before Judge Fernando Olguin involving claims of fraud, breach of contract, and unjust enrichment. Case settled.
Aperture Net, LLC v. TCT Mobile (US) Inc. et al.
U.S. District Court for the Northern District of Texas
Lead counsel for TCL defendants in patent litigation before Judge Ed Kinkeade concerning wireless technologies, particularly channel sounding for a spread spectrum signal, used in mobile devices. Case pending.
Ancora Technologies, Inc. v. TCT Mobile (US) Inc. et al.
U.S. District Court for the Eastern District of Texas and Central District of California
Lead counsel for TCL defendants in patent litigation concerning software restriction in accused mobile devices before Judge George Wu (California). Case pending.
Wi-Lan Inc. et al. v. TCT Mobile (US) Inc. et al.
U.S. District Court for the Central District of California
Lead counsel for TCL in a three-patent case concerning 4G LTE standards in mobile handsets before Judge James Selna. Case pending.
Bell Northern Research, LLC v. Coolpad Technologies, Inc.
U.S. District Court for the Southern District of California
Lead counsel for defendant Coolpad Technologies in a multiple patent case before Judge Cathy Ann Bencivengo related to mobile devices implicating Android, 802.11, and LTE. Case pending.
Lund Motion Products, Inc. v. T-Max (Hangzhou) Technology Co., Ltd., T-Max (Qingdao) Industrial Co., Ltd., T-Max (Qingdao) International Trading Co., Ltd., and T-Max Industrial (Hk) Co., Ltd.
U.S. District Court for the Central District of California
Lead counsel for T-Max in a three-patent and one-copyright case before Judge Cormac J. Carney and Magistrate Judge Jean P. Rosenbluth concerning retractable vehicle step automotive accessories. Case pending.
Monolithic Power Systems, Inc. v. Intersil Corporation
U.S. District Court for the District of Delaware
Lead counsel for Monolithic Power Systems in litigation including claims for trade secret misappropriation, tortious interference, disparagement, defamation, and unfair competition; pending.
Shenzhen Auto-Vox Technology Co., Ltd., v. The Noco Company
U.S. District Court for the Western District of Washington
Lead counsel for Auto-Vox in litigation including claims tortious interference and declaratory judgment of non-infringement of a design patent, and declaratory judgment of invalidity, unenforceability, cancellation, and non-infringement of a trademark; complaint dismissed.
Oy Ajat Ltd. v. Genoray Co. Ltd. and Genoray America, Inc.
U.S. District Court for the Middle District of Florida
Lead counsel for Genoray in a three-patent case before Judge Roy B. Dalton, Jr. and Magistrate Judge David A. Baker concerning power supply and image processing for dental x-ray imaging equipment; settled favorably.
Vehicle IP LLC v. AT&T Mobility LLC
U.S. District Court for the District of Delaware
Counsel for Cellco Partnership (doing business as Verizon Wireless Inc.), TeleCommunication Systems, Inc. and Networks In Motion, Inc. in a one-patent case before Judge Leonard Stark concerning systems for determining estimated times of arrival of vehicles; stipulated entry of final judgment of non-infringement after favorable claim construction order shortly before trial; argued appeal brought by Vehicle IP and obtained affirmance of Judge Stark’s rulings; case subsequently dismissed with prejudice.
CallWave Communication LLC v. Verizon Services Corp., et al.
U.S. District Court for the District of Delaware
Lead counsel for Verizon in a five-patent case before Judge Richard G. Andrews concerning location determination services; Judge Andrews granted a motion invalidating the asserted patent under Section 101; claims relating to asserted patent dismissed as a result of settlement.
IP Cube Partners Co., Ltd. v. Telecommunication Systems, Inc.
U.S. District Court for the Southern District of New York
Lead counsel for TeleCommunication Systems Inc. in an IP asset sale contractual dispute before Judge Laura Taylor Swain and Magistrate Judge Ronald L. Ellis; case dismissed due to settlement after motion to dismiss fraud and negligent misrepresentation counts was granted.
Koninklijke Philips N.V. and U.S. Philips Corporation v. HTC Corporation and HTC America, Inc.
U.S. District Court for the District of Delaware
U.S. District Court for the Northern District of California
Lead counsel for HTC in a ten-patent case before Judge Gregory Sleet (Delaware) and Judge Haywood Gilliam (California) involving user interfaces, audio processing and streaming, data compression, and device data entry; settled favorably after four years of complex litigation.
Children’s Miracle Network v. Miracle Babies
U.S. District Court for the Southern District of California and Trademark Trial and Appeal Board
Lead counsel for defendant Miracle Babies in litigation including claims for trademark infringement, unfair competition, cybersquatting, and false designation of origin related to plaintiff’s purported “Miracle”-related trademarks. The dispute also included an opposition proceeding filed by Children’s Miracle Network related to the Miracle Babies & Design trademark. Settled both proceedings favorably.
Monolithic Power Systems, Inc. v. Silergy Corporation, Compal Electronics, et al.
U.S. District Court for the Northern District of California
Lead counsel for Monolithic Power Systems in litigation including claims for breach of contract and infringement of three patents related to chip scale, flip chip, and microelectronic packages for power integrated circuits; settled favorably.
Largan Precision, Company Ltd. v. Samsung Electronics, et al.
U.S. District Court for the Southern District of California
Lead counsel for Largan Precision in a six-patent case before Judge Dana Sabraw and Judge Cathy Ann Palumbo Bencivengo concerning optical lens in smartphones, tablets, and other products; settled favorably a week before a three-week trial was to begin.
Largan Precision, Company Ltd. v. Genius Electronic Optical Co.
U.S. District Court for the Northern District of California
Lead counsel for Largan in patent litigation concerning optical lens structures; pending.
FlashPoint Technology Inc. v. HTC Corporation and HTC America Inc.
U.S. District Court for the Eastern District of North Carolina
U.S. District Court for the District of Delaware
Lead counsel for HTC in a six-patent case before Judge Terrence Boyles concerning camera user interface, file system, and graphics processing functionality in smart phones; during claim construction phase obtained order transferring case to District of Delaware before Judge Sleet; filed five inter partes review petitions against the asserted patents, and five inter partes review trials were instituted; settled favorably.
Wireless Mobile Devices LLC v. HTC Corporation and HTC America Inc.
U.S. District Court for the Northern District of Texas
Lead counsel for HTC in a six-patent case before Judge David Godbey concerning navigation devices, and synchronization of data over a network; filed six inter partes review petitions against the asserted patents; settled favorably before institution of the inter partes review petitions.
Smartflash LLC v. HTC Corporation and HTC America Inc.
U.S. District Court for the Eastern District of Texas
Lead counsel for HTC in a six-patent litigation before Judge Schroeder concerning content delivery and payment systems; pending.
E.Digital, Inc. v. Transcend Information Inc.
Lead counsel for Transcend in a one-patent case before Judge Marilyn Huff concerning flash memory devices; settled favorably.
Optoplex Corporation v. O-Net Communications (USA), Inc. and O-Net Communications (Group), LTD.
U.S. District Court for the Northern District of California
Lead counsel for O-Net in a two-patent case concerning optical demodulators and interleaver products; settled favorably.
Smart Audio v. HTC Corporation and HTC America Inc.
U.S. District Court for the District of Delaware
Lead counsel for HTC in a one patent case before Judge Sleet concerning vehicle audio system having random access player and play list control functionality; settled favorably.
Round Rock Research v. ASUSTeK Computer Inc. and ASUS Computer International
U.S. District Court for the District of Delaware
U.S. District Court for the Northern District of California
Lead counsel for ASUS in a nine-patent case before Judge Richard Andrews (DE) and Judge Claudia Wilken (NDCA) concerning DDR1-3 SDRAM memory (data strobe, ODT and write leveling), SSD NAND flash memory, LCD, Bluetooth, USB 3.0, BIOS, CMOS image sensor components in ASUS PC-related products; settled favorably.
ASUSTeK Computer Inc. and ASUS Computer International v. Round Rock Research
U.S. District Court for the Northern District of California
Lead counsel for ASUS in a six-patent case before Judge William Alsup and Judge Jon Tigar concerning flash memory, SDDRAM memory, and image sensor components in ASUS PC-related products; settled favorably shortly before trial.
Pragmatus AV, LLC v. ASUSTeK Computer Inc., et al.
U.S. District Court for the District of Delaware
Lead counsel for ASUS in a five-patent case concerning teleconferencing technologies, e.g., Google Talk, in ASUS tablets; settled favorably.
Immersion Corporation v. HTC Corporation and HTC America Inc., et al.
U.S. District Court for the District of Delaware
Lead counsel for HTC in a six-patent case concerning haptics functionality in smartphones; stayed pending collateral U.S. ITC proceeding which Immersion terminated two weeks before trial; the district court case stay was then lifted and litigated to trial; settled favorably a day before trial was to begin.
Graphic Properties Holding v. ASUSTeK Computer Inc. and ASUS Computer International, et al.
U.S. District Court for the District of Delaware
Lead counsel for ASUS in two cases before Judge Stark concerning five patents involving floating point rasterization and frame buffering, removable backlighting in flat panel displays, and large area wide aspect ratio flat panel technologies; settled favorably.
Graphic Properties Holding Inc. v. HTC Corporation, HTC America Inc., et al.
U.S. District Court for the District of Delaware
Lead counsel for HTC in two cases involving before Judge Andrews involving four patents concerning CPU architecture, floating point rasterization and framebuffering, and large area wide aspect ratio flat panel technologies; settled favorably.
IpVenture, Inc. v. ASUSTeK Computer Inc. and ASUS Computer International
U.S. District Court for the District of Delaware
U.S. District Court for the Northern District of California
Lead counsel for ASUS in a four-patent case before Judge White concerning thermal management technologies in ASUS notebook computers; dismissed pending interferences.
Simple Air v. HTC Corporation and HTC America Inc., et al.
U.S. District Court for the Eastern District of Texas
Lead counsel for HTC in a two-patent case before Judge Michael Schneider; settled favorably.
Personal Audio, LLC v. HTC Corporation and HTC America Inc., et al.
U.S. District Court for the Eastern District of Texas
Lead counsel for HTC in a two-patent case before Judge Ronald Clark concerning audio playlist functionality; settled favorably after the claim construction hearing.
MyPort IP Inc. v. HTC Corporation and HTC America Inc., et al.
U.S. District Court for the Eastern District of Texas
Lead counsel for HTC in a two-patent case before Judge Leonard Davis concerning techniques for embedding searchable information in a file for transmission, storage and retrieval; prepared and filed inter partes reexamination requests that were subsequently granted and as a result obtained a stay of the case just weeks before claim construction hearing; stayed during pendency of proceedings before the USPTO; the PTAB affirmed the examiner’s rejection of all claims of both asserted patents.
FlashPoint Technology Inc. v. HTC Corporation, HTC America Inc., et al.
U.S. International Trade Commission
Lead counsel for HTC in a ten-patent case before Judge Sleet concerning camera user interface functionality in smart phones; obtained a stay of the entire case after Judge Sleet lifted previous stay due to reexaminations in light of FlashPoint’s filing of a complaint asserting four of the ten patents before the U.S. ITC; settled favorably after numerous trial wins in other cases.
Largan Precision, Company Ltd. v. Fujinon Corporation
U.S. District Court for the Northern District of California
Counsel for Largan in patent litigation concerning optical lens structures; pending.
Fujinon Corporation v. HTC Corporation and HTC America Inc.
U.S. District Court for the Southern District of Texas
Lead counsel for HTC in patent litigation before Judge Vanessa Gilmore concerning optical lens structures found in cellular phones; pending.
ATEN International Company, Ltd., and ATEN Technology Inc. v. Emine Technology Company, Ltd., Belkin International Inc., and Belkin Inc.
U.S. District Court for the Central District of California
Lead counsel for ATEN in patent litigation before Judge Andrew Guilford concerning KVM switches; settled favorably after Markman hearing.
Innovative Patented Technology, LLC v. HTC Corporation and HTC America, Inc.*
U.S. District Court for the Southern District of Florida
U.S. District Court for the Southern District of California
Lead counsel for HTC in patent litigation concerning cellular phones; settled favorably.
Monolithic Power Systems Inc., et al. v. O2 Micro Int'l Ltd.*
U.S. District Court for the Northern District of California
Co-lead counsel for MPS and ASUS in patent litigation concerning products implementing inverter circuits; subsequently withdrew as counsel due to conflict issue.
ASUSTeK Computer Inc. v. IBM*
U.S. District Court for the Southern District of California
Lead counsel for ASUSTeK in four-patent case concerning storage area network, servers, wired and wireless routers, gigabit switches, and personal navigation devices; obtained favorable Markman order and case subsequently settled favorably just prior to exchange of initial expert reports.
ASUSTeK Computer Inc. and ASUS Computer International v. IBM*
U.S. District Court for the Northern District of California
Lead counsel for ASUS in three-patent case concerning products implementing power supplies, variable speed fans, and Network Address Port Translation; successfully obtained stay of case after a year into litigation, and case subsequently settled favorably.
Monolithic Power Systems Inc., et al. v. Chip Advanced Technologies Inc.*
U.S. District Court for the Central District of California
Lead counsel for MPS in patent litigation concerning DC-DC converters having bootstrap power supplies; settled favorably.
Wrapsidy LLC v. Nielsen Media Research Inc.*
Superior Court of California, County of Santa Clara
Engaged as trial counsel for Wrapsidy three months before trial in state action concerning trade secret misappropriation, unfair competition, tortious interference and breach of contract actions related to Wrapsidy’s ratings data analysis software.
IBM Corporation v. Amazon.com Inc.*
U.S. District Court for the Eastern District of Texas
Lufkin Division
Counsel for Amazon.com leading the litigation team handling the development of the offensive litigation strategy, the analysis of Amazon.com’s patent portfolio to locate e-commerce and database technology related patents being infringed by IBM, and the assertion and litigation of those patents against IBM; settled favorably.
IBM Corporation v. Amazon.com Inc.*
U.S. District Court for the Eastern District of Texas
Tyler Division
Counsel for Amazon.com leading the litigation team handling the development of the offensive litigation strategy, the analysis of Amazon.com’s patent portfolio locating wrapper and search refinement patents being infringed by IBM, and the assertion and litigation of those patents against IBM; settled favorably.
TVI Interactive Data Corporation v. Microsoft Corporation*
U.S. District Court for the Northern District of California
Counsel for Microsoft in patent litigation concerning autoplay technologies; settled favorably. Moreover, many of the asserted claims were subsequently rejected in concurrent reexamination proceedings before the USPTO.
Teknowledge Corporation v. Yahoo! Inc., Microsoft Corporation, America Online Inc., and Netscape Communications Corporation*
U.S. District Court for the Northern District of California
Counsel for Microsoft in patent litigation concerning notification and alerts using intelligent software agents, electronic bill payment and presentment systems and information aggregation systems; settled favorably.
Von Grabe v. Sprint Corporation, et al.*
U.S. District Court for the Southern District of California
Counsel for Sprint entities in business litigation concerning breach of contract, Lanham Act, and other tort actions; win.
Immersion Corporation v. Sony Computer Entertainment America Inc., Sony Computer Entertainment Inc. and Microsoft Corporation*
U.S. District Court for the Northern District of California
Counsel for Microsoft in patent litigation concerning tactile feedback features in Xbox video game system; settled favorably.
Intel Corporation v. Broadcom*
U.S. District Court for the District of Delaware
Counsel for Intel in patent litigation involving semiconductors, integrated circuits, networking, and video compression; win resulting in favorable settlement.
Omnivision Technologies Inc., v. Photobit Corp and California Institute of Technology*
U.S. District Court for the Northern District of California
Counsel for Photobit and Caltech in patent litigation, including other tort-based claims, concerning CMOS active pixel sensors, settled favorably.
Powertech Association LLC v. O2 Micro Int’l Ltd., O2 Micro Inc., Toshiba Corporation, Toshiba America Inc., Viewsonic Corp, Sumida Corporation, Taiwan Sumida, Sumida Electronic Components Company Ltd. and Sumida America Components Inc.*
U.S. District Court for the Eastern District of New York
Lead counsel for Powertech in patent litigation concerning apparatus and techniques to strike fluorescent lamps, such as cold cathode fluorescent lamps, using inverter controllers and inverter circuits.
Monolithic Power Systems Inc. v. Chip Advanced Technologies Inc.*
U.S. District Court for the Central District of California
Counsel for MPS in patent litigation concerning DC-DC converters having bootstrap power supplies; settled favorably.
ITC Section 337 Actions
In the Matter of Certain Electronic Devices, Including Streaming Players, Televisions, Set Top Boxes, Remote Controllers, and Components Thereof, U.S. International Trade Commission Investigation No. 337-TA-1200
Lead counsel for respondent TTE Technology Inc. in multi-patent case brought by Universal Electronics related to remote control technologies. Case pending.
In the Matter of Certain Semiconductor Devices, Integrated Circuits, and Consumer Products Containing the Same, U.S. International Trade Commission Investigation No. 337-TA-1149
Lead counsel for TCL in a multi-patent case brought by Innovative Foundries related to semiconductor process technologies allegedly employed by Taiwan Semiconductor Manufacturing Company’s manufacture of Qualcomm chips incorporated in TCL mobile products. The case settled after TCL’s suppliers reached a settlement with complainant.
In the Matter of Certain Touchscreen Controllers and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-957
Lead counsel for respondents Shenzhen Huiding Technology Co., Ltd. (d.b.a. Goodix) and Goodix Technology Inc. in a four-patent investigation before Administrative Law Judge Theodore Essex (later transferred to Administrative Law Judge MaryJoan McNamara) concerning touchscreen controllers used in smartphones; settled favorably after the hearing. At the time of the hearing the Office of Unfair Import Investigations recommended a finding of no violation. Participated in filing of nine inter partes review petitions during the pendency of the investigation challenging the asserted patents, five of which were instituted and four pending at the time of settlement.
In the Matter of Audio Processing Hardware and Software and Products Containing the Same, U.S. International Trade Commission Investigation No. 337-TA-949
Lead counsel for non-parties Fortress Investment Group LLC and AND34 Funding LLC in a five-patent investigation before former Administrative Law Judge Thomas Pender concerning processing audio signals to avoid interference in tablets, desktops, and laptops. The commission selected the investigation for the second ever 100-Day Pilot Program to determine within 100 days whether complainant has standing to sue or if the investigation should be immediately terminated for failure to include Fortress Investment Group LLC or AND34 Funding LLC as additional complainants. The ALJ found that complainant had standing to sue, and the commission denied respondents’ motion for oral argument and determined not to review the ALJ’s initial determination. The case settled by the parties before the hearing.
In the Matter of Point-to-Point Network Communication Devices and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-892
Lead counsel for respondents AmTRAN Technology Co., Ltd. and AmTRAN Logistics, Inc. in a three-patent case before Administrative Law Judge David Shaw concerning Smart TVs, blu-ray players and other devices and software involved in point-to-point communication and content delivery networks. Complainant Straight Path IP Group, Inc. unilaterally sought to terminate the investigation days before the hearing. Subsequently settled the corresponding district court case favorably.
In the Matter of Certain Electronic Imaging Devices, U.S. International Trade Commission Investigation No. 337-TA-850
Lead counsel for respondents HTC Corporation and HTC America Inc. in a four-patent case before ALJ Essex concerning various camera functionality and image processing systems in smart phones; prior to trial one patent was dismissed and obtained final determination finding non-infringement, and none of the domestic industry licensees practiced two of the remaining three asserted patents; settled favorably.
In the Matter of Certain Consumer Electronics, Including Mobile Phones and Tablets, U.S. International Trade Commission Investigation No. 337-TA-839
Lead counsel for respondent ASUS in a five-patent case before Administrative Law Judge James Gildea concerning teleconferencing technologies, e.g., Google Talk, in ASUS tablets; settled favorably.
In the Matter of Certain Consumer Electronics and Display Devices and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-836
Lead counsel for respondents HTC Corporation and HTC America Inc. in a four-patent case before ALJ Essex concerning CPU architecture, floating point rasterization and framebuffering, and large area wide aspect ratio flat panel technologies; settled favorably.
In the Matter of Certain Mobile electronic Devices Incorporating Haptics, U.S. International Trade Commission Investigation No. 337-TA-834
Lead counsel for respondents HTC Corporation and HTC America Inc. in a five-patent case before ALJ Gildea concerning haptics functionality in smartphones; Immersion moved to terminate the investigation two weeks before trial; terminated.
In the Matter of Certain Portable Electronic Devices and Related Software, U.S. International Trade Commission Investigation No. 337-TA-797
Counsel for respondents HTC Corporation and HTC America Inc. in a patent case before ALJ Gildea concerning smartphones.
In the Matter of Certain Semiconductor Chips and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-753
Counsel for Broadcom in a six-patent case before ALJ Essex concerning DDRx memory controller products and peripheral interface products; settled.
In the Matter of Certain Electronic Imaging Devices, U.S. International Trade Commission Investigation No. 337-TA-726
Lead trial counsel for HTC in a three-patent case before Chief Administrative Law Judge Paul Luckern concerning camera functionality in smart phones; win at trial and initial ID finding non-infringement, invalidity based on-sale bar, and none of the domestic industry licensees practiced the asserted patents; commission reviewed the ID, affirmed the findings on petition and also found HTC had an implied license to practice the asserted patents for its Windows-based products; other respondents Nokia and RIM settled shortly before trial and LG settled after trial and before the initial determination; Fed. Cir. affirmed commission’s FD less than a week after oral arguments.
In the Matter of Certain Cold Cathode Fluorescent Lamp (CCFL) Inverter Circuits and Products Containing the Same, U.S. International Trade Commission Investigation No. 337-TA-666*
Co-lead counsel for respondents MPS and ASUS in patent litigation concerning products implementing inverter circuits; subsequently withdrew as counsel due to a previously unknown conflict.
In the Matter of Certain Computer Products, Computer Components and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-628*
Lead counsel for respondent ASUS in a three patent case before ALJ Essex concerning products implementing power supplies, variable speed fans, and Network Address Port Translation; win at trial and initial ID, commission decided not to review initial ID which became the final ID, and case, along with two other federal court cases between the parties, subsequently settled favorably.
In the Matter of Certain Semiconductor Chips Having Synchronous Dynamic Random Access Memory Controllers and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-661*
Lead counsel for ASUS in patent litigation concerning products incorporating nVidia memory controllers and DDR2 and DDR3 memory.
In the Matter of Certain NAND Flash Memory Devices and Components Thereof, and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-592*
Counsel for Hynix in patent litigation concerning flash memory devices; settled favorably.
In the Matter of Certain Flash Memory Devices and Components Thereof, and Products Containing Such Devices and Components, U.S. International Trade Commission Investigation No. 337-TA-552*
Trial counsel for Hynix in patent litigation before ALJ Lukern concerning circuit and process related patents allegedly involving flash memory device; win at trial and initial ID, and then case subsequently settled favorably.
In the Matter of Certain Set-Top Boxes and Components Thereof, U.S. International Trade Commission Investigation No. 337-TA-454*
Counsel for complainant Gemstar-TV Guide International Inc. against respondents including Scientific Atlanta Inc. and Echostar Communications in patent litigation concerning core television technologies, including interactive program guides and set-top box electronics; adverse final ID reversed on appeal to Federal Circuit, case subsequently settled favorably.
In the Matter of Certain CMOS Active Pixel Image Sensors and Products Containing Same, U.S. International Trade Commission Investigation No. 337-TA-451*
Counsel for complainant Photobit and Caltech in patent litigation before ALJ Luckern concerning Complementary Metal-Oxide Semiconductor (CMOS) active pixel sensors; settled favorably prior to trial. ITC proceeding
*Prior Experience
