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(Attachments: # 1 Complaint part 1, # 2 Complaint part 2) (KKR) (Entered: 08/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/478893063/","id":478893063,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/74715926/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/494528715/","id":494528715,"tags":[],"absolute_url":"/docket/74715926/3/malikie-innovations-ltd-v-foundry-digital-llc/","date_created":"2026-09-22T05:45:01.050031-07:00","date_modified":"2026-09-22T05:45:01.050047-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"3","attachment_number":null,"pacer_doc_id":"12907137630","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2026-09-22T05:45:00.999535-07:00","date_modified":"2026-09-22T05:45:01.013302-07:00","date_filed":"2026-08-31","time_filed":null,"entry_number":3,"recap_sequence_number":"2026-08-31.001","pacer_sequence_number":20,"description":"Summons Issued as to Foundry Digital LLC. (KKR) (Entered: 08/31/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476340211/","id":476340211,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/74715926/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491900378/","id":491900378,"tags":[],"absolute_url":"/docket/74715926/2/malikie-innovations-ltd-v-foundry-digital-llc/","date_created":"2026-08-31T06:58:09.280963-07:00","date_modified":"2026-08-31T06:58:09.280974-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"2","attachment_number":null,"pacer_doc_id":"12907136087","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2026-08-31T06:58:09.258265-07:00","date_modified":"2026-08-31T06:58:09.264435-07:00","date_filed":"2026-08-28","time_filed":null,"entry_number":2,"recap_sequence_number":"2026-08-28.002","pacer_sequence_number":8,"description":"Corporate Disclosure Statement by Key Patent Innovations Ltd., Malikie Innovations Ltd. identifying Corporate Parent Malikie Innovations Ltd. for Key Patent Innovations Ltd., Malikie Innovations Ltd. (Flynn, Terrance) (Entered: 08/28/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476340210/","id":476340210,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/74715926/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491900377/","id":491900377,"tags":[],"absolute_url":"/docket/74715926/1/malikie-innovations-ltd-v-foundry-digital-llc/","date_created":"2026-08-31T06:58:09.229116-07:00","date_modified":"2026-09-08T19:48:30.065952-07:00","sha1":"a1883d78639fb9b610cda020c9c1b8496eaf77d2","page_count":65,"file_size":1325576,"filepath_local":"recap/gov.uscourts.nywd.164474/gov.uscourts.nywd.164474.1.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.nywd.164474/gov.uscourts.nywd.164474.1.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"            Case 6:26-cv-06874        Document 1       Filed 08/28/26       Page 1 of 65\n\n\n\n\n                      IN THE UNITED STATES DISTRICT COURT\n                     FOR THE WESTERN DISTRICT OF NEW YORK\n                              ROCHESTER DIVISION\n\n\nMalikie Innovations Ltd. and                  \u00a7\nKey Patent Innovations Ltd.                   \u00a7\n                                              \u00a7\n                   Plaintiffs,                \u00a7\n       v.                                     \u00a7       CIVIL ACTION NO.\n                                              \u00a7\nFoundry Digital LLC,                          \u00a7       JURY TRIAL DEMANDED\n                                              \u00a7\n                   Defendant.                 \u00a7\n                                              \u00a7\n\n\n            COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND\n\n       Plaintiffs Malikie Innovations Ltd. (\u201cMalikie\u201d) and Key Patent Innovations Ltd. (\u201cKPI\u201d)\n\n(collectively, \u201cPlaintiffs\u201d), by and through their undersigned counsel, bring this Complaint for\n\npatent infringement and damages against Defendant Foundry Digital LLC (\u201cFoundry\u201d or\n\n\u201cDefendant\u201d) and, in support, allege the following:\n\n                                             PARTIES\n\n       1.      Plaintiff Malikie is the successor-in-interest to a substantial patent portfolio created\n\nand procured over many years by Blackberry Ltd., formerly known as Research in Motion Ltd.,\n\nand its predecessor, subsidiary, and affiliated companies (collectively, \u201cBlackberry\u201d). Malikie is\n\nan Irish entity duly organized and existing under the laws of Ireland. Malikie has registered offices\n\nat: The Glasshouses GH2, 92 Georges Street Lower, Dun Laoghaire, Dublin A96 VR66, Ireland.\n\n       2.      Plaintiff KPI is the beneficiary of a trust pursuant to which Malikie owns, holds,\n\nand asserts the Asserted Patents (set forth below). KPI is an Irish entity duly organized and existing\n\nunder the laws of Ireland. KPI has registered offices at: The Glasshouses GH2, 92 Georges Street\n\nLower, Dun Laoghaire, Dublin A96 VR66, Ireland.\n\f            Case 6:26-cv-06874         Document 1       Filed 08/28/26      Page 2 of 65\n\n\n\n\n       3.      On information and belief, Defendant Foundry Digital LLC (\u201cFoundry\u201d) is a\n\nDelaware limited liability company, with a principal place of business at: 1100 Pittsford Victor\n\nRoad, Pittsford, NY 14534. On information and belief, Foundry is headquartered and maintains\n\nits principal place of business in this District, and maintains operational facilities in other states.\n\nOn   information and       belief,    Foundry owns and        operates the      website located      at\n\nhttps://foundrydigital.com/.1\n\n                                     NATURE OF THE ACTION\n\n       4.      This is a civil action for patent infringement under the patent laws of the United\n\nStates, 35 U.S.C. \u00a7 1 et seq.\n\n       5.      This case centers on ground-breaking innovations in elliptic curve cryptography\n\nthat were discovered by some of the field\u2019s leading technologists at Certicom Corporation and\n\nBlackberry Limited (formerly known as Research In Motion, or \u201cRIM\u201d), that years later were\n\nrecognized and selected by the designers of Bitcoin2\u2014 far and away the world\u2019s most valuable\n\ncryptocurrency\u2014to enable Bitcoin\u2019s characteristic quality as a \u201ctrustless\u201d payment system\n\nrequiring no third party intermediary. Specifically, the Bitcoin protocol incorporates cryptographic\n\ntechnology developed and patented by Certicom and Blackberry\u2014technology covered by the\n\nAsserted Patents. Foundry, in turn, uses this patented technology to operate one of the largest\n\nbitcoin mining operations in the world, manage its proceeds, and engage in bitcoin transactions.\n\n       6.      Malikie is the assignee of and owns all right and title to U.S. Patent Nos. 8,788,827\n\n(the \u201c\u2019827 Patent\u201d); 8,806,197 (the \u201c\u2019197 Patent\u201d); 8,666,062 (the \u2019062 Patent\u201d); 8,532,286 (the\n\n\n\n1\n All URLs cited in this Complaint were last accessed on August 17, 2026, unless otherwise\nnoted.\n2\n As used herein, \u201cBitcoin\u201d with a capital \u201cB\u201d refers to Bitcoin\u2019s protocol, network, and blockchain,\nwhereas \u201cbitcoin\u201d with a lower case \u201cb\u201d refers to the unit of cryptocurrency.\n\n\n                                                  2\n\f              Case 6:26-cv-06874      Document 1        Filed 08/28/26     Page 3 of 65\n\n\n\n\n\u201c\u2019286 Patent\u201d); and 8,712,039 (the \u201c\u2019039 Patent\u201d) (collectively, the \u201cAsserted Patents\u201d), which\n\nwere duly and legally issued by the United States Patent and Trademark Office (\u201cUSPTO\u201d).\n\nMalikie seeks monetary damages and, where appropriate, injunctive relief.\n\n                              FACTS COMMON TO ALL CLAIMS\n\n                                              Background\n\n                                         The Rise of Bitcoin\n\n         7.      Earlier this year, the price of a single bitcoin (1 BTC3) surpassed $126,000.4 While\n\nthat is an impressive figure in absolute terms, it is even more impressive considering how much\n\nthe value of bitcoin has increased over the years. When today\u2019s leading U.S.-based cryptocurrency\n\nexchange was founded in 2012, \u201ca bitcoin was worth $6 and only known by a few nerds on the\n\ninternet.\u201d5 Just two years prior to that, 1 BTC was worth less than a penny: $0.0041. On May 22,\n\n2010, in what is widely understood to be the first commercial Bitcoin transaction, Laszlo Hanyecz\n\n(one of Bitcoin\u2019s earliest developers and proponents) paid 10,000 BTC\u2014worth about $41 at the\n\ntime\u2014for two Papa John\u2019s pizzas.6 And only seven months before that, 1 BTC was worth just\n\n$0.00099. In the first ever exchange of bitcoin for U.S. dollars, Martti Malmi (Bitcoin\u2019s second\n\ndeveloper after Satoshi Nakamoto) sold 5,050 BTC for $5.02 on October 12, 2009.7 Following\n\nthe meteoric rise of Bitcoin, had they kept them, Hanyecz\u2019s 10,000 BTC would have been worth\n\n\n3\n \u201cBTC\u201d is a common unit used to designate one bitcoin. See https://bitcoin.org/en/vocabulary#btc.\nBitcoin can be transacted in units smaller than 1 BTC, in units of \u201csatoshi,\u201d which is the smallest\nunit of bitcoin, equivalent to a one hundred millionth of a single bitcoin (0.00000001 BTC). See\nhttps://en.bitcoin.it/wiki/Satoshi_(unit).\n4\n    https://www.coinbase.com/price/bitcoin.\n5\n https://www.cnbc.com/2021/04/14/coinbase-co-founders-launched-when-a-bitcoin-btc-was-\nworth-6.html (quoting Fred Ehrsam, co-founder of Coinbase).\n6\n https://www.youtube.com/watch?v=tWU3O3X5kKE; https://www.coinbase.com/learn/crypto-\nglossary/what-is-bitcoin-pizza.\n7\n    https://bitcoinmagazine.com/markets/bitcoins-first-trade-now-worth-130-million.\n\n                                                  3\n\f               Case 6:26-cv-06874       Document 1        Filed 08/28/26   Page 4 of 65\n\n\n\n\nover $1.26 billion in October 2025 and Malmi\u2019s 5,050 BTC would have been worth over $636\n\nmillion. No other cryptocurrency has attained such incredible value.\n\n          8.      Bitcoin is regarded as the first \u201ccryptocurrency\u201d and \u201cremains by far the biggest,\n\nmost influential, and best-known.\u201d8 Other leading cryptocurrencies today include Ethereum,\n\nTether, and Solana, which, although they are perhaps relatively well-known among those familiar\n\nwith cryptocurrency, are worth orders of magnitude less than Bitcoin.9               Thousands of\n\ncryptocurrencies exist today10, but, as the Ethereum website acknowledges, it was all \u201cpioneered\n\nby Bitcoin.\u201d11\n\n          9.      While Bitcoin is the foundation of today\u2019s sprawling cryptocurrency market, the\n\nfoundation of Bitcoin\u2019s trailblazing trustless digital currency model\u2014its digital signature\n\nframework\u2014uses cryptographic technology developed and patented by Certicom and\n\nBlackberry.12 Bitcoin\u2019s adoption of this technology set a trend that has propagated throughout the\n\ncryptocurrency landscape. The Bitcoin mining industry has also adopted techniques developed by\n\nCerticom for efficiently processing cryptographic hash functions\u2014part of a process for adding\n\nBitcoin transactions to the blockchain and minting new bitcoin known as \u201cmining.\u201d13 Globally,\n\n\n\n\n8\n    https://www.coinbase.com/learn/crypto-basics/what-is-cryptocurrency.\n9\n    See, e.g., id.; https://coinmarketcap.com/.\n10\n   For example, the Coinbase exchange lists hundreds of tradable crypto assets among thousands\nin existence. https://www.coinbase.com/explore.\n11\n     https://ethereum.org/what-is-ethereum/.\n12\n     https://bitcoin.org/bitcoin.pdf (\u201cBitcoin Whitepaper\u201d) at 1, 2, 8.\n13\n     https://bitcoin.org/en/vocabulary#mining.\n\n\n                                                    4\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 5 of 65\n\n\n\n\nthe Bitcoin mining industry processes over one sextillion (1021 or 1,000,000,000,000,000,000,000)\n\ncryptographic hashes every second.14\n\n                   Bitcoin\u2019s Foundation is Certicom-Developed Cryptography\n\n       10.     The creation of Bitcoin is attributed to Satoshi Nakamoto (\u201cSatoshi\u201d), the presumed\n\npseudonym used by the author15 of a white paper titled \u201cBitcoin: A Peer-to-Peer Electronic Cash\n\nSystem,\u201d which was reportedly sent on October 31, 2008 to a small group of recipients on \u201cThe\n\nCryptography Mailing List\u201d using a pipermail message service hosted by metzdowd.com.16\n\nSatoshi\u2019s message included a link to the white paper, which was (and still is) hosted at bitcoin.org,\n\na site \u201coriginally registered and owned by Bitcoin\u2019s first two developers, Satoshi Nakamoto and\n\nMartti Malmi.\u201d17\n\n       11.     The first line of Satoshi\u2019s initial message to the \u201ccryptography\u201d community\n\narticulated the goal of Bitcoin: to provide \u201ca new electronic cash system that\u2019s fully peer-to-peer,\n\nwith no trusted third party.\u201d18     This defining characteristic of Bitcoin is achieved using\n\n\n\n\n14\n   https://www.coinwarz.com/mining/bitcoin/hashrate-chart;\nhttps://thebitcoinmanual.com/articles/btc-hashrate-1-zetahash/.\n15\n   Satoshi Nakamoto might be one or more persons. See, e.g.,\nhttps://www.metzdowd.com/pipermail/cryptography/2008-October/014810.html (\u201cI\u2019ve been\nworking on a new electronic cash system\u2026.\u201d); id. (\u201cWe propose a solution to the double\nspending problem\u2026.\u201d).\n16\n  See Bitcoin Whitepaper; see also https://www.wired.com/story/after-10-years-bitcoin-changed-\neverything-nothing/.\n17\n   https://bitcoin.org/en/about-us#own;\nhttps://www.metzdowd.com/pipermail/cryptography/2008-October/014810.html.\n18\n  https://www.metzdowd.com/pipermail/cryptography/2008-October/014810.html; see also\nBitcoin Whitepaper (abstract).\n\n\n                                                 5\n\f             Case 6:26-cv-06874        Document 1        Filed 08/28/26       Page 6 of 65\n\n\n\n\ncryptography.19 Specifically, \u201c[d]igital signatures provide part of the solution.\u201d20 As Satoshi\n\nexplained in a February 11, 2009 message to another online community\u2014the \u201cp2p-research\u201d\n\nmailing list\u2014\u201c[o]ne of the fundamental building blocks for such a system [as Bitcoin] is digital\n\nsignatures.\u201d21\n\n          12.    A digital signature is a cryptographic tool for verifying the authenticity of digital\n\ndata (i.e., validating its original source and genuineness) and its integrity (i.e., that it is accurate,\n\ncomplete, and has not been tampered with).22 In fact, a bitcoin is fundamentally just \u201ca chain of\n\ndigital signatures\u201d recorded in a public history or \u201cchain\u201d of transactions. See Bitcoin Whitepaper\n\nat 2 (\u201cWe define an electronic coin as a chain of digital signatures. Each owner transfers the coin\n\nto the next by digitally signing a hash of the previous transaction and the public key of the next\n\nowner and adding these to the end of the coin.\u201d), 8 (describing \u201ca peer-to-peer network using proof-\n\nof-work to record a public history of transactions\u201d).\n\n\n\n\n19\n   Bitcoin Whitepaper at 1 (\u201cWhat is needed is an electronic payment system based on\ncryptographic proof instead of trust, allowing any two willing parties to transact directly with each\nother without the need for a trusted third party.\u201d).\n20\n  https://www.metzdowd.com/pipermail/cryptography/2008-October/014810.html (abstract);\nBitcoin Whitepaper (abstract).\n21\n     https://satoshi.nakamotoinstitute.org/emails/p2p-research/35/.\n22\n     https://www.cisa.gov/news-events/news/understanding-digital-signatures.\n\n                                                   6\n\f             Case 6:26-cv-06874        Document 1        Filed 08/28/26    Page 7 of 65\n\n\n\n\n                                        Bitcoin Whitepaper at 2\n\nSee also https://satoshi.nakamotoinstitute.org/emails/p2p-research/35/ (\u201cA digital coin contains\n\nthe public key of its owner. To transfer it, the owner signs the coin together with the public key of\n\nthe next owner. Anyone can check the signatures to verify the chain of ownership\u201d). Specifically,\n\nas Satoshi explained to the \u201ccryptography\u201d community shortly after releasing the white paper but\n\nbefore releasing the first version of Bitcoin software, \u201cit\u2019s ECC digital signatures.\u201d23\n\n          13.    The acronym \u201cECC\u201d stands for elliptic curve cryptography.24 ECC \u201crepresents a\n\ndifferent way to do public-key cryptography\u2014an alternative to the older RSA system\u2014and also\n\noffers certain advantages.\u201d25 \u201cECC devices require less storage, less power, less memory, and less\n\nbandwidth than other systems. This allows you to implement cryptography in platforms that are\n\nconstrained, such as wireless devices, handheld computers, smart cards, and thin-clients. It also\n\n\n\n\n23\n   https://satoshi.nakamotoinstitute.org/emails/cryptography/14/; see also\nhttps://satoshi.nakamotoinstitute.org/emails/cryptography/2/ (explaining that \u201cECC is nicely\ncompact\u201d).\n24\n     https://en.bitcoin.it/wiki/Elliptic_curve_cryptography.\n25\n     https://www.certicom.com/content/certicom/en/the-basics-of-ecc.html.\n\n                                                   7\n\f                 Case 6:26-cv-06874      Document 1      Filed 08/28/26     Page 8 of 65\n\n\n\n\nprovides a big win in situations where efficiency is important.\u201d26 As explained by Certicom\n\nCorporation, \u201cthe authority for strong, efficient cryptography,\u201d when asymmetric cryptography\n\n(such as public-key cryptography) is desired \u201cElliptic curve cryptography (ECC) is the best choice,\n\nbecause\u201d it \u201cwill give you the most security per bit.\u201d27 For example, \u201cECC offers considerably\n\ngreater security for a given key size\u201d and enables \u201cfaster cryptographic operations, running on\n\nsmaller chips or more compact software\u201d resulting in \u201cless heat production and less power\n\nconsumption.\u201d28\n\n           14.      ECC is also secure. In 1997, Certicom introduced the \u201cElliptic Curve Cryptosystem\n\n(ECC) Challenge\u201d as a way \u201cto increase industry understanding and appreciation for the difficulty\n\nof the elliptic curve discrete logarithm problem, and to encourage and stimulate further research\n\nin the security analysis of elliptic curve cryptosystems.\u201d29 Certicom challenged participants to\n\ncompute the ECC private key from a list of ECC public keys and associated parameters.30 The\n\nchallenge included relatively easier (Level I) challenges, some of which have been solved, and\n\nmore difficult (Level II) challenges, which Certicom believed to be \u201ccomputationally infeasible\u201d\n\nand still have not been solved.31\n\n           15.      As mentioned above, Bitcoin uses ECC digital signatures. Specifically, Bitcoin\n\nuses an elliptic curve digital signature algorithm (\u201cECDSA\u201d) with parameters known as\n\n\n\n\n26\n     Id.\n27\n     https://www.certicom.com/content/dam/certicom/images/pdfs/WP-ECCprimer.pdf at 3, 22.\n28\n     Id. at 3.\n29\n     https://www.certicom.com/content/certicom/en/the-certicom-ecc-challenge.html.\n30\n     Id.\n31\n     Id.\n\n\n                                                    8\n\f               Case 6:26-cv-06874     Document 1      Filed 08/28/26     Page 9 of 65\n\n\n\n\n\u201csecp256k1.\u201d32       Secp256k1 is defined in a Standards for Efficient Cryptography (SEC)\n\nspecification titled \u201cSEC 2: Recommended Elliptic Curve Domain Parameters\u201d (Version 2.0, Jan.\n\n2010), which is a publication of the Standards for Efficient Cryptography Group (SECG).33 The\n\nSEC 2 paper (Version 2.0) was generated by Certicom Research and identifies Dan Brown of\n\nCerticom as the main contact.34 Dan Brown is a co-inventor of several of the Asserted Patents in\n\nthis case. See infra.\n\n          16.     Certicom\u2014which was \u201c[f]ounded in 1985, the same year Elliptic Curve\n\nCryptography (ECC) was invented\u201d\u2014has a long been regarded as the leader in ECC technology.35\n\nIndeed, Scott Vanstone, who co-founded Certicom in 1985 with Gord Agnew and Ron Mullin, was\n\nan internationally recognized top ECC researcher and the recipient of prestigious awards and\n\nrecognitions for his monumental and profound contributions in the field of ECC.36 Vanstone\n\nauthored numerous papers and was awarded hundreds of patents related to ECC.37 To help drive\n\nECC\u2019s commercial adoption, Certicom (with Vanstone) founded the SECG in 1998.38 The purpose\n\nof the SECG is \u201cto develop commercial standards that facilitate the adoption of efficient\n\n\n\n\n32\n   https://en.bitcoin.it/wiki/Elliptic_Curve_Digital_Signature_Algorithm;\nhttps://en.bitcoin.it/wiki/Secp256k1.\n33\n     https://www.secg.org/sec2-v2.pdf at 9.\n34\n     Id. (cover page).\n35\n     https://www.certicom.com/content/certicom/en/about.html.\n36\n   See, e.g., https://www.certicom.com/content/certicom/en/about/news/release/2004/certicom-\nfounder-scott-vanstone-wins-prestigious-research-award.html;\nhttps://www.certicom.com/content/certicom/en/about/news/release/2009/certicom-founder-wins-\npremiers-catalyst-award-for-lifetime-achie.html; https://uwaterloo.ca/news/profound-impact-\nresearcher.\n37\n     See id.\n38\n     https://www.cnet.com/tech/tech-industry/certicom-creates-standards-body/.\n\n\n                                                 9\n\f             Case 6:26-cv-06874      Document 1      Filed 08/28/26      Page 10 of 65\n\n\n\n\ncryptography and interoperability across a wide range of computing platforms.\u201d39           \u201cSECG\n\nmembers include leading technology companies and key industry players in the information\n\nsecurity industry,\u201d including its founding member, Certicom.40 Certicom\u2019s development of a\n\nstandards body to promote ECC was welcomed by many in the cryptography industry. As the\n\nchief scientist of one security firm put it in 1998, \u201cIt\u2019s good news for the industry as a whole to\n\nmove ECC forward because it is a promising technology.\u201d41 In 2004, a professor at Texas Tech\n\nUniversity (winner of the Certicom Elliptic Curve Cryptography (ECC)2-109 Challenge) said, \u201cI\n\nthink public-key cryptography based on ECC is what we should and will be moving toward.\u201d42\n\nWalt Davis, former senior vice-president at Motorola, told Vanstone that he believed \u201cECC was\n\nthe only technology that would work in their constrained environments.\u201d43\n\n           17.   Demonstrating its position as the leader in developing and promoting ECC\n\ntechnology, Certicom hosted the annual ECC Conference beginning in 2004, which \u201cwas designed\n\nto interest both a technical audience and business managers.\u201d44 Vanstone recalled that the 2004\n\nconference \u201cwas well-attended by cryptography experts, industry leaders and members of the\n\ndeveloper community.\u201d45 The conference also \u201cheld significant historical value,\u201d with \u201cluminaries\n\n\n\n\n39\n   https://www.secg.org/.\n40\n   Id.; see also\nhttps://www.certicom.com/content/certicom/en/about/news/release/2005/standards-for-efficient-\ncryptography-group--secg--announce-new-i.html (identifying Certicom as \u201ca founding member\nof SECG\u201d).\n41\n     https://www.cnet.com/tech/tech-industry/certicom-creates-standards-body/.\n42\n     https://www.metzdowd.com/pipermail/cryptography/2004-April/006798.html.\n43\n  https://www.certicom.com/content/certicom/en/code-and-cipher/article/529-reflections-the-\nyear-that-was-.html.\n44\n     Id.\n45\n     Id.\n\n\n                                                10\n\f             Case 6:26-cv-06874      Document 1       Filed 08/28/26     Page 11 of 65\n\n\n\n\nsuch as Dr. Ralph Merkle, Dr. Neal Koblitz, Dr. Victor Miller and Dr. Walt Davis\u201d in attendance.46\n\nThose luminaries were the pioneers of public key cryptography and ECC: Miller and Koblitz\n\n\u201cindependently invented elliptic curve cryptography\u201d; Merkle was one of the inventors of public\n\nkey cryptography; and Davis was a senior vice-president at Motorola who was an early advocate\n\nfor ECC and recipient of the first ECC Visionary Award.47 As a testament to Certicom\u2019s status as\n\nthe unrivaled leader and authority in ECC research and development, industry members recognized\n\nCerticom as \u201cthe most commercial promoter of elliptic curve crypto.\u201d48 Indeed, Certicom has been\n\ndescribed as the \u201cauthority,\u201d \u201cleader,\u201d and \u201cexpert\u201d in the field of ECC.49\n\n           18.   Resulting from its pioneering discoveries in ECC, Certicom is well known to have\n\nbeen the holder of many valuable patents covering certain implementations of ECC. For example,\n\nBruce Schneier50, an internationally renowned security technologist (known as the \u201csecurity guru\u201d)\n\nand Adjunct Lecturer in Public Policy at the Harvard Kennedy School, once said that \u201cCerticom\n\ncertainly can claim ownership of ECC,\u201d noting that \u201c[t]he algorithm was developed and patented\n\nby the company\u2019s founders, and the patents are well written and strong.\u201d51 Certicom claimed to\n\n\n\n\n46\n     Id.\n47\n     Id.\n48\n     https://www.cnet.com/tech/tech-industry/certicom-creates-standards-body/.\n49\n   See, e.g., https://www.metzdowd.com/pipermail/cryptography/2004-April/006798.html;\nhttps://news.profoundimpact.com/tag/dr-scott-vanstone/;\nhttps://cpl.thalesgroup.com/partners/rim-certicom.\n50\n  See https://web.archive.org/web/20250513035631/https://www.hks.harvard.edu/faculty/bruce-\nschneier; https://www.belfercenter.org/person/bruce-schneier.\n51\n     https://betanews.com/2007/05/30/certicom-patent-suit-against-sony-threatens-to-unravel-aacs/.\n\n                                                 11\n\f            Case 6:26-cv-06874        Document 1      Filed 08/28/26     Page 12 of 65\n\n\n\n\nhave had \u201cthe world\u2019s largest intellectual property portfolio for these types of [ECC] patents.\u201d52\n\nAfter acquiring Certicom, BlackBerry grew that portfolio to over 500 ECC patents.53\n\n          19.    Satoshi chose Certicom\u2019s secp256k1 curve for Bitcoin\u2019s digital signature\n\nalgorithm.54 According to the Bitcoin wiki site, \u201csecp256k1 was almost never used before Bitcoin\n\nbecame popular.\u201d55 As one commentator said, \u201cIf it wasn\u2019t for Satoshi Nakamoto, you probably\n\nwould never have heard of the secp256k1 Elliptic Curve Cryptography (ECC) method.\u201d56 Even\n\nDan Brown was surprised to learn that Bitcoin uses secp256k1 instead of other, more commonly\n\nused parameters.57 Some suggest that Satoshi, having not received a recommendation for a\n\nspecific curve, just \u201cpicked one.\u201d58 Others suggest that Satoshi relied on expert cryptographers in\n\nselecting secp256k1.59\n\n          20.    Whatever the reason, Satoshi\u2019s choice of secp256k1 has proven to be well-liked by\n\nthe Bitcoin community and the broader cryptocurrency community. The Bitcoin wiki site reports\n\n\n\n52\n  https://www.certicom.com/content/certicom/en/about/news/release/2007/certicom-announces-\nexecutive-changes.html.\n53\n     https://blackberry.certicom.com/en.\n54\n   See, e.g., https://medium.com/asecuritysite-when-bob-met-alice/the-bluffers-guide-to-\nsecp256k1-when-satoshi-said-goodbye-to-pki-bad327c4f079;\nhttps://news.ycombinator.com/item?id=28813291.\n55\n     https://en.bitcoin.it/wiki/Secp256k1.\n56\n  https://medium.com/asecuritysite-when-bob-met-alice/the-bluffers-guide-to-secp256k1-when-\nsatoshi-said-goodbye-to-pki-bad327c4f079.\n57\n  https://bitcoinmagazine.com/technical/satoshis-genius-unexpected-ways-in-which-bitcoin-\ndodged-some-cryptographic-bullet-1382996984 (quoting Brown as saying \u201cI did not know that\nBitCoin is using secp256k1. Indeed, I am surprised to see anybody use secp256k1 instead of\nsecp256r1.\u201d).\n58\n  https://learnmeabitcoin.com/technical/cryptography/elliptic-curve/ (quoting email between\nSatoshi and Mike Hearn, a \u201cBitcoin developer\u201d who published his emails with Satoshi).\n59\n   https://cointelegraph.com/news/satoshi-nakamoto-had-outside-cryptography-help-says-early-\nbitcoin-dev (citing Laszlo Hanyecz\u2019s account of his conversations with Satoshi).\n\n\n                                                12\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26      Page 13 of 65\n\n\n\n\nthat after Bitcoin\u2019s adoption of secp256k1, the curve \u201cis now gaining in popularity due to its several\n\nnice properties.\u201d60 Gregory Maxwell, a former Bitcoin developer, said in a public forum in\n\nOctober 2021 that Satoshi\u2019s choice of secp256k1 \u201cwas a good choice at the time, esp[ecially] now\n\nafter the expiration of the GLV patent.\u201d61 \u201cThe GLV patent\u201d refers to another groundbreaking\n\ninnovation by Certicom\u2019s in-house experts in elliptic curve cryptography, famously known as\n\n\u201cGLV Endomorphism,\u201d62 which the Bitcoin community had been stalking for a decade or more\n\nafter Hal Finney, foundational Bitcoin developer (and receiver of the first ever Bitcoin transaction),\n\ndiscovered in early 2011 that it can be used to speed up signature verifications by 25%.63\n\n          21.    Finney, a well-known and highly respected cryptographer, posted on February 8,\n\n2011 that he figured out a way to speed up ECDSA signature verification for the secp256k1 curve\n\nused by Bitcoin, based on techniques described in \u201cGuide to Elliptic Curve Cryptography\u201d by\n\nHankerson, Menezes and Vanstone.64 The \u201cVanstone\u201d of the book\u2019s authoring trio is Scott\n\nVanstone, co-founder of Certicom and co-inventor of several of the Asserted Patents in this case.\n\nThe technique that Finney\u2019s post referred to is famously known among the Bitcoin community and\n\nelsewhere as \u201cGLV Endomorphism\u201d or the \u201cGLV method,\u201d where \u201cGLV\u201d refers to the trio of\n\nCerticom innovators that came up with it: Robert Gallant, Robert Lambert, and Scott Vanstone.65\n\nAll three were Certicom technologists and are co-inventors of several of the Asserted Patents in\n\nthis case. It is widely reported that Finney\u2019s proposed inclusion of GLV Endomorphism in the\n\n\n\n60\n     https://en.bitcoin.it/wiki/Secp256k1.\n61\n     https://news.ycombinator.com/item?id=28813291.\n62\n     The Asserted Patents\u2019 inventions are independent from and not described in the GLV patent.\n63\n   https://btctimes.com/hal-finneys-proposal-for-optimizing-bitcoin-to-be-enabled-in-bitcoin-\ncore/.\n64\n   Id.\n65\n   See id.\n\n\n                                                 13\n\f               Case 6:26-cv-06874     Document 1         Filed 08/28/26   Page 14 of 65\n\n\n\n\nBitcoin protocol, though it was eventually included in the Bitcoin Core software library named\n\nlibscep256k1, was not officially implemented at the time because of concerns that it would infringe\n\n\u201cthe GLV patent,\u201d i.e., U.S. Patent No. 7,110,538, which names Gallant, Lambert, and Vanstone\n\nas the inventors.66 On the day the GLV patent expired, and over the days that followed, the Bitcoin\n\ncommunity celebrated the anticipated inclusion of GLV Endomorphism in future Bitcoin Core\n\nreleases. 67 In fact, on the day the GLV patent expired, the Bitcoin Core community began the\n\nprocess of deleting the \u201cslower non-endomorphism code\u201d and replacing it with the faster \u201cGLV\n\noptimization,\u201d including by deleting the code that previously made GLV endomorphism optional,\n\nthereby enabling GLV Endomorphism by default.68             Others in the Bitcoin community later\n\nconfirmed Finney\u2019s observations that GLV Endomorphism results in significantly faster signature\n\nverifications (reportedly by 28%).69 Following Bitcoin\u2019s lead, others in the crypto community\n\nfollowed suit in adopting GLV Endomorphism optimizations.70\n\n          22.      While some people like Finney, Malmi, and Hearn are known as early Bitcoin\n\ndevelopers, Satoshi Nakamoto is credited with creating the first Bitcoin client, i.e., the first\n\nsoftware implementing the Bitcoin protocol.71 Satoshi announced the release of the first version\n\nof Bitcoin software to the \u201ccryptography\u201d community on January 8, 2009.72 Satoshi\u2019s original\n\n\n\n\n66\n     See id.\n67\n     See id.\n68\n  https://github.com/bitcoin-core/secp256k1/pull/826 (\u201cAs the patent on the GLV optimization\nhas expired, there is no need to keep the slower non-endomorphism code around anymore.\u201d).\n69\n   https://btctimes.com/bitcoin-upgrade-glv-enomorphism-tests-show-faster-verification/.\n70\n   See https://github.com/RustCrypto/elliptic-curves/issues/211 (\u201cbitcoin-core/secp256k1 is now\nswitching to the endomorphism implementation by default: bitcoin-core/secp256k1#826 I think\nit would make sense for us to do the same.\u201d).\n71\n     https://en.bitcoin.it/wiki/Satoshi_Nakamoto.\n72\n     https://satoshi.nakamotoinstitute.org/emails/cryptography/16/.\n\n                                                    14\n\f            Case 6:26-cv-06874       Document 1       Filed 08/28/26     Page 15 of 65\n\n\n\n\nBitcoin software is the foundation of today\u2019s de facto authoritative reference implementation of\n\nthe Bitcoin protocol, known as \u201cBitcoin Core.\u201d73 Bitcoin Core continues to implement ECC digital\n\nsignatures using ECDSA with secp256k1.74\n\n          23.    The public history of Bitcoin\u2019s development discussed above shows the impact that\n\nCerticom\u2019s innovations had on the shaping of Bitcoin and is a testament to the bona fides of\n\nCerticom\u2019s innovators as significant contributors to the advancement of important and valuable\n\nECC technology.\n\n          24.    The Bitcoin industry\u2019s use of Certicom innovations did not stop with digital\n\nsignatures. The Bitcoin industry widely relies on patented Certicom innovations to efficiently hash\n\nnew blocks to add them to the blockchain and \u201cmine\u201d new bitcoin. Bitcoin transactions are\n\nvalidated and added to the blockchain through this \u201cmining\u201d process, whereby transactions are\n\nadded to blocks and operators of specialized mining computers race to solve a cryptographic puzzle\n\nthat allows a next block to be added to the blockchain, entitling the winner to collect a \u201cblock\n\nreward.\u201d75 This process is computationally intensive, thereby making it very difficult to tamper\n\nwith the blockchain (e.g., to modify or rewrite past transactions).76 The computational intensity\n\ncomes from a need to repeatedly perform a cryptographic hash function to discover a hash value\n\nthat satisfies certain criteria, which some mining entities perform at the rate of \u201cexahashes\u201d per\n\n\n73\n  https://en.bitcoin.it/wiki/Bitcoin_Core (Bitcoin Core is \u201cbased on the original reference code\nby Satoshi Nakamoto\u201d); https://bitcoincore.org/en/about/ (\u201c[Bitcoin Core] is a direct descendant\nof the original Bitcoin software client released by Satoshi Nakamoto after he published the\nfamous Bitcoin whitepaper.\u201d).\n74\n   https://en.bitcoin.it/wiki/Elliptic_Curve_Digital_Signature_Algorithm;\nhttps://en.bitcoin.it/wiki/Secp256k1.\n75\n   https://www.coinbase.com/learn/crypto-basics/how-do-cryptocurrency-miners-work; Bitcoin\nWhitepaper at 3 (\u201cProof-of-Work\u201d), 5 (\u201cIncentive\u201d), 6-8 (\u201cCalculations\u201d);\nhttps://en.bitcoin.it/wiki/Block; https://en.bitcoin.it/wiki/Controlled_supply.\n76\n     Bitcoin Whitepaper at 3 (\u201cProof-of-Work\u201d), 6-8 (\u201cCalculations\u201d).\n\n\n                                                 15\n\f             Case 6:26-cv-06874         Document 1    Filed 08/28/26     Page 16 of 65\n\n\n\n\nsecond (EH/s), i.e., quintillions of hashes per second.77 To do this, the Bitcoin industry relies on\n\nspecialized mining computers containing application-specific integrated circuits (\u201cASICs\u201d) that\n\nare designed specifically (and typically, solely) for processing the SHA-256 hash function (a type\n\nof SHA-2 hash function) used by the Bitcoin network.78 Before the advent of ASIC mining,\n\nCerticom invented techniques for processing SHA-2 hash functions faster and more efficiently.\n\n           25.    On information and belief, several commonly used mining machines, including\n\nmodels made by Bitmain\u2014a top manufacturer of bitcoin miners79\u2014utilize the improved hash\n\nprocessing techniques developed and patented by Certicom.\n\n                   Blackberry Acquired Certicom Following Years-Long Alliance\n\n           26.    Blackberry was an early adopter of Certicom\u2019s ECC technology. In July 2000, in\n\nrecognition of \u201cCerticom\u2019s high performance, efficient ECC,\u201d Blackberry and Certicom entered\n\ninto \u201can alliance which will enable RIM to utilize Certicom\u2019s elliptic curve cryptography (ECC)\n\ntechnology throughout its wireless product offerings.\u201d80 Blackberry recognized that \u201cCerticom\u2019s\n\nElliptic Curve Cryptography (ECC) technology enables strong, high performance security for\n\nmany pieces of the computing infrastructure,\u201d and that \u201cCerticom\u2019s patented implementation of\n\nECC technology provides a more efficient alternative to conventional public key cryptographic\n\nalgorithms \u2026 allowing for faster processing speed, reduced bandwidth usage and decreased\n\nbattery requirements.\u201d81 Accordingly, BlackBerry entered into an \u201cagreement with Certicom, a\n\n\n\n77\n     https://www.pcmag.com/encyclopedia/term/exahash.\n78\n     https://en.bitcoin.it/wiki/ASIC.\n79\n   https://www.bitmain.com/about; https://www.cryptominerbros.com/blog/most-profitable-\nbitcoin-mining-machines/.\n80\n  https://www.certicom.com/content/certicom/en/about/news/release/2000/research-in-motion-\nand-certicom-to-enable-trusted-mobile-commerc.html.\n81\n     Id.\n\n\n                                                16\n\f             Case 6:26-cv-06874       Document 1          Filed 08/28/26   Page 17 of 65\n\n\n\n\nleader in ECC wireless security technology, [to] enable [BlackBerry] to provide the market with\n\nthe secure mobile devices they require for m-commerce transactions.\u201d82\n\n           27.   In 2009, BlackBerry acquired Certicom, giving rise to BlackBerry Certicom, \u201cthe\n\nleader in applied cryptography and key management.\u201d83 Certicom\u2019s industry-leading research and\n\ndevelopment continued under BlackBerry Certicom; together BlackBerry and Certicom continued\n\ninnovating and improving ECC technology. As a result of its rich history in ECC technology\n\ndevelopment, \u201cBlackBerry Certicom has industry leading expertise in Elliptic Curve Cryptography\n\nand has established the world\u2019s largest ECC-based patent portfolio.\u201d84 Plaintiff Malikie now owns\n\npart of that portfolio, including the Asserted Patents.\n\n                                        Cryptocurrency Basics\n\n           28.   Bitcoin paved the way for the thousands of cryptocurrencies that exist today. The\n\nterm \u201ccryptocurrency,\u201d or \u201ccrypto\u201d for short, refers to a category of \u201cdigital money\u201d that, like the\n\nfundamental purpose of Bitcoin, \u201cmakes it possible to transfer value online without the need for a\n\nmiddleman like a bank or payment processor.\u201d85 Most cryptocurrencies, including Bitcoin, are\n\ndecentralized (not managed or controlled by a government or other central authority), not backed\n\nby anything of independent value (such as gold), and not guaranteed by anyone (such as a\n\ngovernment or bank). Instead, cryptocurrencies are managed by \u201cpeer-to-peer networks of\n\ncomputers running free, open-source software.\u201d86 Specifically, cryptocurrency transactions are\n\nvetted and recorded using a technology called \u201cblockchain,\u201d which is a decentralized database\n\n\n\n82\n     Id.\n83\n     https://www.certicom.com/content/certicom/en/about.html.\n84\n     Id.; see https://blackberry.certicom.com/en.\n85\n     https://www.coinbase.com/learn/crypto-basics/what-is-cryptocurrency.\n86\n     Id.\n\n\n                                                    17\n\f               Case 6:26-cv-06874    Document 1        Filed 08/28/26      Page 18 of 65\n\n\n\n\nsystem that stores data in a distributed network of computers. This is in some ways analogous to\n\nthe ledger of accounts and transactions maintained by a traditional financial intermediary (such as\n\na bank or credit card company). However, unlike with a traditional intermediary where the security\n\nof transactions and accounts is vested solely in the intermediary (which requires its customers to\n\ntrust the intermediary with their money), the security of blockchain transactions is effected by the\n\nuse of cryptography and \u201cconsensus\u201d mechanisms to ensure that a majority of the computers on\n\nthe network agree that a transaction is valid before it is recorded (i.e., deemed to have occurred).87\n\n           29.     As the name suggests, cryptocurrencies fundamentally rely on concepts from\n\ncryptography and computer science to enable the creation of such decentralized, internet-based\n\nmonetary systems that are secure. Cryptocurrencies rely on cryptography (hence the name\n\ncryptocurrency) to protect participants\u2019 assets from theft and to protect the cryptocurrency system\n\nfrom dishonest or unauthorized manipulation that results in dilution of the currency (e.g., double\n\nspending).88 More fundamentally, cryptography is what enables cryptocurrencies like Bitcoin to\n\nbe \u201ctrustless,\u201d i.e., what allows cryptocurrency to be transacted securely (even between strangers)\n\nwithout the need for a trusted intermediary to verify and process payments.89\n\n                                            Transactions\n\n           30.     The role of cryptography as a fundamentally enabling technology in\n\ncryptocurrencies like Bitcoin is evident in how cryptocurrency transactions are processed, i.e.,\n\ninitiated, validated, and recorded in the blockchain.       Unlike with typical currencies, where\n\ntransactions transfer an amount of currency from one account to another that is redeemable in\n\n\n\n\n87\n     Id.\n88\n     See https://www.coinbase.com/learn/crypto-basics/what-is-cryptography.\n89\n     See id.\n\n\n                                                 18\n\f               Case 6:26-cv-06874      Document 1       Filed 08/28/26    Page 19 of 65\n\n\n\n\nphysical notes and coins, \u201ccryptocurrency transactions are simply data entries recorded on an\n\nunchangeable, distributed ledger, referred to as a blockchain.\u201d90 That is, with cryptocurrencies,\n\n\u201cno cryptocurrency is actually exchanged between people. Instead, ownership data associated with\n\nboth parties\u2019 crypto wallets is updated on the blockchain each time a transaction is processed.\u201d91\n\n           31.     A cryptocurrency transaction\u2014transferring crypto from the sender\u2019s digital wallet\n\nto the receiver\u2019s digital wallet\u2014involves several steps. Using wallet software, a transaction\n\n(essentially, a bundle of data) is created that identifies the sender\u2019s address (using a public key),\n\nthe recipient\u2019s address (also using a public key), and the amount of cryptocurrency to be sent.92\n\nThe transaction requestor then creates a digital signature for the transaction with its private key\n\nand public key (which are cryptographically linked, as the private key is used to create the public\n\nkey) and submits the signed transaction to the blockchain network for validation. By signing the\n\ntransaction with its private key, the requestor proves to the receiving party and to the blockchain\n\nnetwork that the transaction is valid. After the receiving party validates the transaction using the\n\nsender\u2019s public key, the transaction is broadcast to and propagated through the blockchain network,\n\nwhere a majority network nodes must independently verify that the transaction is valid in order for\n\nthe transaction to be added to the next \u201cblock\u201d of the blockchain and thus be permanently and\n\nirreversibly recorded.93\n\n\n\n\n90\n     https://www.kraken.com/learn/how-do-cryptocurrency-transactions-work.\n91\n     Id.\n92\n     Id.\n93\n     See id.\n\n\n                                                  19\n\f            Case 6:26-cv-06874          Document 1       Filed 08/28/26    Page 20 of 65\n\n\n\n\n                                               Wallets\n\n         32.     A cryptocurrency \u201cwallet\u201d is a tool for interacting with a Blockchain network that\n\nallows a user to send and receive cryptocurrencies like Bitcoin.94 A wallet is typically an\n\napplication (software) that functions as a wallet for storing the user\u2019s private keys and provides\n\ninterfaces to access and perform transactions with the user\u2019s cryptocurrency. Wallets can be\n\ncustodial (keys are managed by a third party) or non-custodial (keys are managed solely by the\n\nuser). Forms of hardware wallets also exist (e.g., a USB drive wallet). Crypto wallets don\u2019t store\n\nthe actual cryptocurrency (because the cryptocurrency exists as data in the blockchain) but instead\n\nstore the public and private keys needed to carry out crypto transactions on the blockchain.95\n\n                                   Private Keys and Public Keys\n\n         33.     Private keys and public keys are related but different pieces of information used in\n\ncryptocurrency transactions. They are part of a technique known as asymmetric cryptography, in\n\nwhich two keys are used: (1) a private key (possessed by only the entity wishing to prove its\n\nidentity) and (2) a public key (possessed by any number of entities who wishes to verify the identity\n\nof the entity possessing the private key).96 Unlike the alternative approach known as symmetric\n\ncryptography\u2014in which a single key is used by both (or all) parties for their respective purposes,\n\nthereby preventing the key from being associated with a unique identity\u2014asymmetric\n\ncryptography simplifies key exchange by reducing the number of keys needed to secure messages\n\nbetween parties and allows a message signature to be uniquely authenticated (i.e., associated with\n\nthe unique identity of the sender).97\n\n\n94\n     https://www.investopedia.com/terms/b/bitcoin-wallet.asp.\n95\n     See id.\n96\n   https://www.certicom.com/content/dam/certicom/images/pdfs/WP-ECCprimer.pdf (\u201cECC\nPrimer\u201d) at 4.\n97\n   Id. at 4\u20135.\n\n\n                                                  20\n\f          Case 6:26-cv-06874           Document 1     Filed 08/28/26      Page 21 of 65\n\n\n\n\n                                          ECC Primer at 5\n\n       34.     Importantly, while the public key can be used by an entity to verify that another\n\npossesses the corresponding private key, \u201cyou cannot derive the private key from the public. This\n\nis the critical feature of asymmetric cryptographic schemes that makes them so useful.\u201d ECC\n\nPrimer at 4; see also id. (\u201cThe critical feature of asymmetric cryptography, that makes it useful, is\n\nthis key pair\u2014and more specifically, a particular feature of the key pair: the fact that one of the\n\nkeys cannot be obtained from the other.\u201d).        It is also \u201cthe core technology behind digital\n\nsignatures.\u201d Id. \u201cA digital signature is a transform performed on a message using the private key,\n\nwhose integrity may be verified with the public key.\u201d Id. at 5.\n\n\n\n\n                                          ECC Primer at 5\n\nElliptic curve cryptography (ECC) is an approach to doing asymmetric cryptography, including\n\nfor use with digital signatures. Id.\n\n\n                                                 21\n\f            Case 6:26-cv-06874      Document 1        Filed 08/28/26     Page 22 of 65\n\n\n\n\n         35.    Private and public keys form a related key-pair\u2014a public key is generated from a\n\nprivate key through a one-way hash function (or \u201ctrapdoor function\u201d) that is relatively easy to\n\nsolve in one direction but nearly impossible to solve in the other direction, making it nearly\n\nimpossible to determine a private key from a public key.98 See also ECC Primer at 6-7 (\u201cIn all\n\nasymmetric cryptographic schemes, this property\u2014the property that one key is used for\n\nencryption, and another for decryption, and the decryption key cannot be found from the\n\nencryption key\u2014is derived from the use of mathematical functions whose inverse is extremely\n\ndifficult to calculate. You may understand an asymmetric cryptographic key pair as a pair of\n\nnumbers which have some relationship associated with a mathematical function which is relatively\n\neasy to compute in one direction, but whose inverse is in practical terms intractable. This feature\u2014\n\nthe function which is tractable in one direction, but intractable in the other, is common to all\n\nasymmetric cryptosystems, including ECC.\u201d). This characteristic of asymmetric cryptography\n\nallows the sender of cryptocurrency to digitally sign a transaction using their unique and secret\n\nprivate key as proof of ownership, and it allows the recipient and blockchain nodes to verify the\n\ndigital signature and validate the transaction using the sender\u2019s public key. Accordingly, in\n\ncryptocurrency transactions, public keys are used to identify the sending and receiving addresses\n\n(akin to account numbers in a bank), and private keys are used to sign transactions when sending\n\ncryptocurrency to others (which can be verified by the receiver and the blockchain network using\n\nthe sender\u2019s public key).99\n\n\n\n\n98\n     https://www.ledger.com/academy/blockchain/what-are-public-keys-and-private-keys.\n99\n     See id.\n\n\n                                                22\n\f            Case 6:26-cv-06874       Document 1        Filed 08/28/26       Page 23 of 65\n\n\n\n\n                                             Blockchain\n\n          36.    Cryptocurrencies like Bitcoin are based on a technology called \u201cblockchain.\u201d100 A\n\nblockchain is essentially a distributed database that, in a cryptocurrency network like Bitcoin,\n\ncontains a list or \u201cledger\u201d of all historical transactions on the network (i.e., a record of every time\n\nanyone sent or received bitcoin). The blockchain of a cryptocurrency like Bitcoin is in some ways\n\nakin to the ledger or balance sheet of a bank.\n\n          37.    A blockchain network includes a number of distributed computers (called \u201cnodes\u201d)\n\nthat store a copy of the blockchain ledger and participate in the verification and recording of each\n\ntransaction.101 To become part of the blockchain ledger, a transaction must be transmitted to the\n\nnetwork of nodes, which work to confirm the validity of the transaction using cryptographic\n\nalgorithms. Valid transactions are collected into a fixed-size data file called a \u201cblock\u201d (akin to a\n\npage of a ledger) that, once filled, is run through a cryptographic hash function (that is, the block\n\nis \u201chashed\u201d) to generate a unique hash value for that block. That block\u2019s hash value is included\n\nwithin the next block that is created so that when the next block is hashed, its hash value depends\n\non the hash of the previous block, thereby creating an irreversible \u201cchain\u201d of blocks (hence the\n\nname \u201cblockchain\u201d) as the process continues.102 See also Bitcoin Whitepaper at 2\u20135.\n\n\n\n\n                                      Bitcoin Whitepaper at 3\n\n\n\n100\n      See https://www.investopedia.com/terms/b/blockchain.asp.\n101\n      See id.\n102\n      See id.\n\n\n                                                  23\n\f            Case 6:26-cv-06874      Document 1        Filed 08/28/26     Page 24 of 65\n\n\n\n\n                                     Bitcoin Whitepaper at 5\n\n          38.   The Bitcoin blockchain creates a chronological ledger of chained transactions\n\nwhere each new block depends on the information from all previous blocks, thereby making it\n\nnearly impossible to undo or manipulate historical transactions without permission.103 See also\n\nBitcoin Whitepaper at 2\u20133 (\u201cOnce the CPU effort has been expended to make it satisfy the proof-\n\nof-work, the block cannot be changed without redoing the work. As later blocks are chained after\n\nit, the work to change the block would include redoing all the blocks after it.\u201d), id. (\u201cTo modify a\n\npast block, an attacker would have to redo the proof-of-work of the block and all blocks after it\n\nand then catch up with and surpass the work of the honest nodes. We will show later that the\n\nprobability of a slower attacker catching up diminishes exponentially as subsequent blocks are\n\nadded.\u201d).\n\n                  Bitcoin\u2019s Consensus Mechanism: Proof of Work (\u201cMining\u201d)\n\n          39.   \u201c\u2018Proof of work\u2019 and \u2018proof of stake\u2019 are the two major consensus mechanisms\n\ncryptocurrencies use to verify new transactions, add them to the blockchain, and create new\n\n\n\n103\n      See id.\n\n\n                                                24\n\f            Case 6:26-cv-06874       Document 1       Filed 08/28/26     Page 25 of 65\n\n\n\n\ntokens.\u201d104 \u201cProof of work, first pioneered by Bitcoin, uses mining to achieve those goals.\u201d105 In\n\na proof of work blockchain, members of the network (\u201cminers\u201d) race against each other to be the\n\nfirst to solve a complex cryptographic math problem for determining a hash value associated with\n\na particular block of transactions and present their solution to the network.106 If the miner\u2019s\n\nsolution is verified by the network, the miner is allowed to create a new block (containing the\n\ntransactions verified by the miner) and broadcast it to the network. The nodes on the network will\n\nthen perform audits of the ledger and the new block, and if the auditing nodes agree, the new block\n\nis \u201cchained\u201d to the previous block (creating a chronological chain of transactions) and the miner\n\nis rewarded with a unit of \u201ccoin\u201d (i.e., cryptocurrency), consisting of a mining fee for solving the\n\nblock, as well as transaction fees for processing the underlying transactions, as compensation for\n\nexpending their resources (e.g., energy) in the performance of this work. As the block chain grows,\n\nmining the next block to receive its reward becomes more computationally expensive (and\n\ntherefore more resource intensive). Accordingly, the proof-of-work consensus model is more\n\nrewarding for those with more resources to deploy.107\n\n                                             Hashing\n\n          40.    Part of the mining process includes repeatedly performing a cryptographic hash\n\nfunction to discover a hash value that solves the block puzzle. To do this, miners hash a group of\n\ndata fields included at the beginning of a candidate block called the \u201cblock header,\u201d which includes\n\na special field called the \u201cnonce,\u201d108 and compare the resulting hash value to criteria specified by\n\n\n104\n      https://www.coinbase.com/learn/crypto-basics/what-is-proof-of-work-or-proof-of-stake.\n105\n      Id.\n106\n      See id.; Bitcoin Whitepaper at 3\u20134; https://www.investopedia.com/terms/b/blockchain.asp.\n107\n      See id.\n108\n   The term \u201cnonce\u201d stands for \u201cnumber used once.\u201d See\nhttp://learnmeabitcoin.com/technical/block/nonce/.\n\n\n                                                 25\n\f            Case 6:26-cv-06874           Document 1   Filed 08/28/26      Page 26 of 65\n\n\n\n\nthe Bitcoin network. If the hash value meets the criteria, the solution is valid and may be submitted\n\nto the network in exchange for a block reward. If the hash value does not satisfy the specified\n\ncriteria, the miners change the nonce value and re-hash the block header. This process is repeated\n\nuntil a valid solution is discovered.109 The rate at which individual mining machines can perform\n\nthis hashing operation is often measured in terahashes per second (TH/s), i.e., trillions of hashes\n\nper second.110 For large mining entities, the rate at which they perform this hashing operation is\n\noften measures in \u201cexahashes\u201d per second (EH/s), i.e., quintillions of hashes per second.111 Miners\n\ntypically perform this hashing operation using specialized mining computers that contain\n\napplication-specific integrated circuits (\u201cASICs\u201d) that are designed specifically (and sometimes,\n\nsolely) for processing the SHA-256 hash function (a type of SHA-2 hash function) used by the\n\nBitcoin network.112\n\n                                             Pool Mining\n\n          41.     \u201cA mining pool is the consolidation of computational power amongst a group of\n\ncryptocurrency miners (nodes) who work collectively to solve mathematical problems in order to\n\nbetter their chances of receiving rewards.\u201d113 \u201cPooled mining is a way for individual miners to\n\ncombine their hash power so that they can mine as if they are one big miner. The individual miners\n\n\u2026 share in the reward of any blocks found by the combined pool, adjusted by their contributed\n\nshare of the hash power.\u201d114 In other words, \u201c[i]nstead of each miner working alone to solve\n\n\n109\n   https://medium.com/fcats-blockchain-incubator/understanding-the-bitcoin-blockchain-header-\na2b0db06b515.\n110\n      https://www.coinwarz.com/mining/bitcoin/hardware.\n111\n      https://www.pcmag.com/encyclopedia/term/exahash.\n112\n      https://en.bitcoin.it/wiki/ASIC.\n113\n      https://crypto.com/glossary/mining-pool.\n114\n      https://bitcoinmagazine.com/guides/what-are-bitcoin-mining-pools.\n\n\n                                                 26\n\f              Case 6:26-cv-06874        Document 1      Filed 08/28/26     Page 27 of 65\n\n\n\n\ncomplex mathematical problems (which is how new Bitcoin is created), a group of miners combine\n\ntheir computational power. When the pool successfully mines a Bitcoin block, the reward is\n\ndistributed among all members according to the work each one provided.\u201d115\n\n                  Foundry Operates One of the World\u2019s Largest Bitcoin Mining Pools\n\n            42.     Foundry styles itself as \u201cThe world\u2019s #1 Bitcoin mining pool.\u201d116 Foundry\u2019s CEO,\n\nMike Colyer, recently described the Foundry USA Pool as \u201cthe biggest pool in the world.\u201d117 Over\n\nthe past year, the Foundry USA Pool has been responsible for over 30% of the global Bitcoin\n\nhashrate, amounting to over 290 exahashes per second (EH/s)\u2014that\u2019s 290 quintillion\n\n(290,000,000,000,000,000,000) cryptographic calculations per second.118 Since 2020, Foundry\n\nhas won over 62,000 blocks.119 In October 2025 alone, Foundry\u2019s blocks included over 4.9 million\n\ntransactions.120 And in November 2025, Foundry\u2019s blocks included over 4 million transactions.121\n\n\n\n\n115\n      https://www.blockchain-council.org/bitcoin/pros-and-cons-of-joining-a-bitcoin-mining-pool/.\n116\n      https://foundrydigital.com/enterprise-software/foundry-usa-pool/.\n117\n   https://www.youtube.com/watch?v=lWcdrepehsM at 19:36-40 (\u201cWe never anticipated being\nthe biggest pool in the world, but here we are.\u201d).\n118\n      See, e.g., https://hashrateindex.com/hashrate/pools.\n119\n      https://mempool.space/mining/pool/foundryusa.\n120\n      Id.\n121\n      Id.\n\n\n                                                   27\n\f            Case 6:26-cv-06874       Document 1       Filed 08/28/26      Page 28 of 65\n\n\n\n\n                 https://hashrateindex.com/hashrate/pools (accessed Nov. 20, 2025)\n\n          43.    The Foundry USA Pool is a bitcoin \u201cmining pool,\u201d i.e., it is \u201ca group of miners who\n\ncombine their computing power to solve the mathematical equations required to add new blocks\n\nto the blockchain.\u201d122 Pool operators like Foundry orchestrate groups of miners who join the pool\n\nas \u201cmembers\u201d to contribute their computational resources (e.g., hashrate) toward solving the\n\npuzzle required to create new blocks, and share the block rewards.123 For example, on information\n\nand belief, non-parties Fortitude Mining, LLC (\u201cFortitude\u201d), Riot Platforms, Inc. (\u201cRiot\u201d), and\n\nCipher Mining Inc. (\u201cCipher\u201d) are members of the Foundry USA Pool.124 In a mining pool, the\n\n\n\n122\n      https://medium.com/foundry-digital/how-luck-impacts-bitcoin-miner-success-31d7f346ced6.\n123\n   https://foundrydigital.com/enterprise-software/foundry-usa-pool/;\nhttps://www.sec.gov/Archives/edgar/data/1083301/000110465923009266/tm234968d1_ex10-\n1.htm; https://foundrydigital.com/terms-and-conditions/;\nhttps://www.chainalysis.com/blog/crypto-mining-pools/;\nhttps://www.investopedia.com/terms/m/mining-pool.asp.\n124\n   See https://intel.arkm.com/explorer/entity/riot-platforms (showing transactions from Foundry\nto Riot); Cipher 2025 10-K at 63, F-18 (Cipher\u2019s 10-K describing pool mining with Foundry);\nhttps://intel.arkm.com/explorer/entity/cipher-mining (showing transactions from Foundry to\nCipher); https://www.businesswire.com/news/home/20250129138884/en/DCG-Launches-\nFortitude-Mining-A-New-Venture-Mining-Subsidiary-Targeting-High-Growth-Digital-Assets\n\n\n\n                                                 28\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26     Page 29 of 65\n\n\n\n\npool operator sends \u201cshares\u201d of work to each member (e.g., a range of nonces to hash), and as the\n\nmembers complete their shares, they submit the results to the pool operator.125 The pool operator\n\nuses the aggregated computing power of its members to operate nodes and validate blocks on the\n\nBitcoin blockchain, and it distributes pro-rata shares of the proceeds (e.g., block rewards and\n\ntransaction fees) to its members based on the computing power each contributes (e.g., the number\n\nof shares a member submits), less a fee retained by the pool operator.126 Foundry performs daily\n\npayout calculations according to a Ful-Pay-Per-Share (FPPS) methodology, whereby Foundry\n\ndivides the block rewards and transaction fees earned by the pool among its members, less an\n\noperating fee retained by Foundry.127\n\n          44.    The Foundry USA Pool mines over 30% of the blocks on the Bitcoin network,128\n\nand it has earned over 322,820 BTC in mining rewards since 2020.129 Using the average daily\n\nprice of bitcoin since 2020 (approximately 46,790130), that would be worth over $15 billion. Using\n\n\n\n\n(recently spun out, Fortitude was \u201cthe self-mining division of Foundry,\u201d the operator of \u201cthe #1\nBitcoin mining pool in the world,\u201d and continues to mine bitcoin).\n125\n   https://www.investopedia.com/terms/m/mining-pool.asp;\nhttps://www.chainalysis.com/blog/crypto-mining-pools/.\n126\n   See https://www.sec.gov/Archives/edgar/data/1964789/000155837024004176/hut-\n20231231x10kt.htm at 41.\n127\n   See, e.g., https://www.sec.gov/Archives/edgar/data/1964789/000155837024004176/hut-\n20231231x10kt.htm at 41, 108; https://pool-faq.foundrydigital.com/what-is-foundry-usa-pools-\npayout-methodology.\n128\n   See, e.g., https://mempool.space/graphs/mining/pools; see also\nhttps://www.youtube.com/watch?v=lWcdrepehsM at 25:04-07 (\u201cI mine 30% of all the blocks\nevery day.\u201d \u2013 Mike Colyer).\n129\n      See, e.g., https://mempool.space/mining/pool/foundryusa.\n130\n      based on values reported at https://www.investing.com/crypto/bitcoin/historical-data.\n\n\n                                                  29\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26   Page 30 of 65\n\n\n\n\nthe recent all-time high price of bitcoin in October 2025 (approximately 126,000131), the value is\n\nnorth of $40 billion.\n\n\n\n\n                           https://mempool.space/graphs/mining/pools#1y.\n\n\n\n\n                           https://mempool.space/mining/pool/foundryusa.\n\n\n131\n      as reported at https://www.coinbase.com/price/bitcoin.\n\n\n                                                 30\n\f            Case 6:26-cv-06874       Document 1          Filed 08/28/26   Page 31 of 65\n\n\n\n\n          45.    In addition to managing the Foundry USA Pool, Foundry was also an institutional\n\ngrade bitcoin miner itself. 132 Foundry was \u201claunched in 2020 by Digital Currency Group\u201d to meet\n\n\u201cgrowing demand for institutional infrastructure in mining and network operations.\u201d133 At least as\n\nearly as Q3 2020, \u201cFoundry claim[ed] to already be one of the largest Bitcoin miners in North\n\nAmerica.\u201d134 During a recent interview, Foundry\u2019s CEO, Mike Colyer, recalled that, at least in the\n\nUnited States, Foundry was \u201cthe biggest bitcoin miner in 2021.\u201d135 On information and belief,\n\nFoundry\u2019s self-mining operations continued through 2025 and were only recently spun off into a\n\nnew subsidiary of Digital Currency Group (Foundry\u2019s parent company), called Fortitude\n\nMining.136\n\n          46.    Foundry has also been a significant provider of financing, equipment, and\n\noperational services to other bitcoin miners.137 For example, Foundry agreed to provide \u201cup to\n\n\n\n\n132\n  See, e.g., https://foundrydigital.com/site-operations/ (\u201cFoundry USA Pool\u2122 \u2026. Built by\nminers for miners, delivering best-in-class services for every step of the miner journey.\u201d).\n133\n      https://cryptoslate.com/companies/foundry/.\n134\n  https://www.crowdfundinsider.com/2020/08/165819-time-to-mine-dcg-reveals-crypto-\nmining-subsidiary-foundry/.\n135\n  https://www.youtube.com/watch?v=lWcdrepehsM at 17:54-47 (\u201cWe were the biggest bitcoin\nminer in 2021.\u201d)\n136\n       https://www.businesswire.com/news/home/20250129138884/en/DCG-Launches-Fortitude-\nMining-A-New-Venture-Mining-Subsidiary-Targeting-High-Growth-Digital-Assets                 (\u201c\u2018Mike\nColyer built a successful self-mining business as part of the broader Foundry portfolio, featuring\na best-in-class mining fleet and significant revenues in 2024,\u2019 said Barry Silbert, Founder & CEO,\nDCG. \u2018With this strong foundation, spinning out Fortitude Mining as the leading venture miner\nprovides greater growth opportunities to further scale the business, including raising capital,\nmaking additional investments, and attracting top-tier talent.\u2019\u201d).\n137\n    https://www.theblock.co/linked/76165/dcg-bitcoin-mining-foundry (\u201cCrypto venture capital\nfirm Digital Currency Group (DCG) has entered into crypto mining space. \u2026 The group has\nformed a wholly-owned subsidiary called Foundry which provides mining and staking, equipment\nfinancing and procurement, and consulting and advisory services. DCG said it has committed to\ninvest more than $100 million into Foundry through 2021.\u201d).\n\n\n                                                    31\n\f          Case 6:26-cv-06874        Document 1        Filed 08/28/26     Page 32 of 65\n\n\n\n\n$23 million dollars in financing for Core Scientific and its clients\u2019 mining equipment,\u201d138 financed\n\nHut 8\u2019s acquisition of 5,400 mining machines,139 and helped finance equipment for Blockcap and\n\nBitfarms.140 Foundry reportedly \u201chelped to procure nearly half of the Bitcoin mining machines\n\ninstalled in North America in 2020.\u201d141 Foundry supplied Compute North with 14,000 mining\n\nmachines142 and eventually acquired Compute North\u2019s bitcoin mining operations in multiple states,\n\nincluding in Texas.143 Foundry also launched the \u201cFoundry Academy\u201d to \u201ctrain and develop\u201d\n\nbitcoin mining technicians in \u201ceverything from bitcoin fundamentals to the nuances of miner\n\ndiagnostics and maintenance.\u201d144\n\n\n\n\n138\n   https://www.prnewswire.com/news-releases/core-scientific-partners-with-foundry-in-\nfinancing-deal-up-to-23-million-301189563.html.\n139\n    https://www.coindesk.com/markets/2021/01/22/hut-8-completes-118m-financing-for-new-\nbitcoin-mining-machines.\n140\n   https://cointelegraph.com/news/bitcoin-miner-blockcap-closes-75m-investment-led-by-off-\nthe-chain-foundry-digital; https://www.einpresswire.com/article/539216284/bitfarms-partners-\nwith-foundry-to-expand-bitcoin-mining-fleet-and-join-foundry-usa-pool-instantly-boost-\nhashrate-by-15.\n141\n    https://www.einpresswire.com/article/539216284/bitfarms-partners-with-foundry-to-expand-\nbitcoin-mining-fleet-and-join-foundry-usa-pool-instantly-boost-hashrate-by-15.\n142\n   https://www.coindesk.com/markets/2021/01/13/compute-north-foundry-team-up-to-target-\nnorth-american-bitcoin-miners.\n143\n   https://www.prnewswire.com/news-releases/foundry-to-acquire-two-turnkey-mining-\nfacilities-from-compute-north-plus-right-to-acquire-third-facility-under-development-\n301685734.html; https://www.coindesk.com/business/2022/11/22/crypto-mining-and-staking-\nfirm-foundry-buys-some-of-troubled-bitcoin-miner-compute-norths-assets;\nhttps://decrypt.co/198889/texas-top-us-state-for-bitcoin-mining-foundry-cambridge.\n144\n   https://www.prnewswire.com/news-releases/foundry-announces-foundry-academy-to-train-\ntechnicians-for-bitcoin-mining-industry-301588729.html.\n\n\n                                                32\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 33 of 65\n\n\n\n\n                          Foundry\u2019s Use of the Patented Technologies\n\n       47.     On information and belief, Foundry has engaged in bitcoin mining activities since\n\nat least 2020 and continues to do so.145 For example, on information and belief, since 2020,\n\nFoundry has operated, and continues operates, the Foundry USA Pool for mining bitcoin.146\n\nAdditionally, on information and belief, from at least 2020 until the spinout of its internal self-\n\nmining division (Fortitude) in 2025, Foundry operated specialized mining computers (\u201cminers\u201d)\n\nand other equipment.147\n\n\n\n145\n   See https://cryptoslate.com/companies/foundry/ (Foundry was \u201claunched in 2020 by Digital\nCurrency Group\u201d to meet \u201cgrowing demand for institutional infrastructure in mining and\nnetwork operations.\u201d); https://www.crowdfundinsider.com/2020/08/165819-time-to-mine-dcg-\nreveals-crypto-mining-subsidiary-foundry/ (\u201cDigital Currency Group (DCG) is moving into\ncrypto mining. According to a release, DCG created a subsidiary called \u201cFoundry\u201d [in] 2019 and\ntoday the company is outing the mining firm with Mike Colyer, a former Core Scientific\nexecutive, being Foundry\u2019s Chief Executive Officer. Foundry claims to already be one of the\nlargest Bitcoin miners in North America.\u201d); https://www.youtube.com/watch?v=lWcdrepehsM at\n17:54-47 (\u201cWe were the biggest bitcoin miner in 2021.\u201d);\nhttps://www.youtube.com/watch?v=Pyyasvlyo4M&t=69s1:01-08 (\u201cWe\u2019re best known for our\nmining pool\u2014Foundry USA Pool. We also do a bit of our own proprietary self mining.\u201d).\n146\n   See https://foundrydigital.com/enterprise-software/foundry-usa-pool/;\nsec.gov/Archives/edgar/data/1083301/000110465923009266/tm234968d1_ex10-1.htm;\nhttps://foundrydigital.com/terms-and-conditions/;\nhttps://www.youtube.com/watch?v=lWcdrepehsM at 22:25-22:48 (\u201cI remember the first block\nwe mined. November 3rd, 2020. I think we were like three days in. At that point in time, I think\nwe had like 1%--we were 1% of the whole network ourselves as a miner, right, we were a pretty\nbig miner, relatively speaking, at that time. And we threw all of it at trying to get the pool off the\nground.\u201d)\n147\n   https://www.youtube.com/watch?v=lWcdrepehsM at 16:25-18:29 (\u201cAnd, again, to Barry\u2019s\ncredit, he said, \u2018Hey, Mike, if you\u2019re going to do equipment financing, you should probably buy\nsome machines.\u2019 And I\u2019m like, \u2018Oh, yeah, yeah, good idea. So how many do you want me to\nbuy?\u2019 And he goes \u2018Id\u2019 buy all you can buy.\u2019 \u2026 So we bought\u2014we started placing orders \u2026 We\nwere placing orders for the new M30S and the new S19\u2019s \u2026 What was tough was Barry said \u2018the\nonly thing I don\u2019t want to be is was bitcoin miner.\u2019 And, I remember \u2026 we got on a Teams call\nand he said\u2014I\u2019m like, \u2018Nobody took me up on my offer and I got a lot of machines coming.\u2019\nAnd he goes, \u2018Well, I guess we\u2019ll be a bitcoin miner.\u2019 So that was the beginning of it. So, we\nwere the biggest bitcoin miner in 2021. \u2026 We put it everywhere. I called everyone back up, they\nhad rack space, and we plugged in machines everywhere.\u201d);\n\n\n\n                                                  33\n\f          Case 6:26-cv-06874         Document 1       Filed 08/28/26      Page 34 of 65\n\n\n\n\n       48.     On information and belief, Foundry\u2019s bitcoin mining activities include and have\n\nincluded verifying bitcoin transactions, including verifying digital signatures consistent with the\n\nBitcoin protocol using ECDSA and secp256k1.148 On information and belief, since 2020, Foundry\n\nhas operated and continues to operate a mining pool, wherein Foundry performs transaction\n\nverifications and digital signature verifications for the pool, to enable the pool to mine blocks. On\n\ninformation and belief, Foundry verifies Bitcoin transactions, including verifying digital signatures\n\nassociated with such transactions, and provides its pool members with equipment, blocks, block\n\ntemplates, or block headers based on those transactions.\n\n       49.     On information and belief, Foundry generates and has generated digital signatures,\n\nincluding digital signatures consistent with the Bitcoin protocol using ECDSA and secp256k1,\n\nincluding for generating bitcoin transactions. For example, Foundry makes daily payouts in\n\nbitcoin to its pool members.149\n\n\n\n\nhttps://www.businesswire.com/news/home/20250129138884/en/DCG-Launches-Fortitude-\nMining-A-New-Venture-Mining-Subsidiary-Targeting-High-Growth-Digital-Assets.\n148\n   See also, e.g., https://en.bitcoin.it/wiki/Protocol_documentation#Transaction_Verification;\nhttps://en.bitcoin.it/wiki/Elliptic_Curve_Digital_Signature_Algorithm;\nhttps://en.bitcoin.it/wiki/Secp256k1.\n149\n   See, e.g.: https://pool-faq.foundrydigital.com/what-is-foundry-usa-pools-payout-\nmethodology; see also, e.g., https://pool-faq.foundrydigital.com/payouts; https://pool-\nfaq.foundrydigital.com/does-the-pool-pay-out-freshly-minted-coins; https://pool-\nfaq.foundrydigital.com/how-is-my-pricing-tier-calculated.\n\n\n                                                 34\n\f            Case 6:26-cv-06874       Document 1          Filed 08/28/26   Page 35 of 65\n\n\n\n\n          50.    On information and belief, Foundry uses digital asset wallets for receiving and\n\ndisbursing bitcoin.150 On information and belief, Foundry regularly receives digital assets (e.g.,\n\nblock rewards) and transfers portions of them to Foundry USA Pool members.151\n\n          51.    On information and belief, Foundry owned and/or operated specialized bitcoin\n\nmining computers (e.g., \u201cminers\u201d or \u201cmining machines\u201d) for performing hash operations to mine\n\nbitcoin. For example, on information and belief, Foundry was an institutional grade bitcoin\n\nminer.152 Foundry was \u201claunched in 2020 by Digital Currency Group\u201d to meet \u201cgrowing demand\n\nfor institutional infrastructure in mining and network operations.\u201d153 At least as early as Q3 2020,\n\n\u201cFoundry claim[ed] to already be one of the largest Bitcoin miners in North America.\u201d154 During\n\na recent interview, Foundry\u2019s CEO, Mike Colyer, recalled that, at least in the United States,\n\nFoundry was \u201cthe biggest bitcoin miner in 2021.\u201d155 On information and belief, Foundry\u2019s self-\n\nmining operations continued through 2025 and were only recently spun off into a new subsidiary\n\n\n\n\n150\n   See, e.g.: https://mempool.space/address/bc1qxhmdufsvnuaaaer4ynz88fspdsxq2h9e9cetdj;\nhttps://mempool.space/address/bc1p8k4v4xuz55dv49svzjg43qjxq2whur7ync9tm0xgl5t4wjl9ca9\nsnxgmlt.\n151\n   See, e.g.: https://pool-faq.foundrydigital.com/what-is-foundry-usa-pools-payout-\nmethodology; https://mempool.space/address/bc1qxhmdufsvnuaaaer4ynz88fspdsxq2h9e9cetdj;\nhttps://mempool.space/address/bc1p8k4v4xuz55dv49svzjg43qjxq2whur7ync9tm0xgl5t4wjl9ca9\nsnxgmlt.\n152\n   See, e.g., https://foundrydigital.com/site-operations/ (\u201cWe, like you, are miners. We apply\nour vast experience to each client site, giving us an advantage over other operators.\u201d (emphasis\nadded)).\n153\n      https://cryptoslate.com/companies/foundry/.\n154\n  https://www.crowdfundinsider.com/2020/08/165819-time-to-mine-dcg-reveals-crypto-\nmining-subsidiary-foundry/.\n155\n  https://www.youtube.com/watch?v=lWcdrepehsM at 17:54-47 (\u201cWe were the biggest bitcoin\nminer in 2021.\u201d).\n\n\n                                                    35\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26      Page 36 of 65\n\n\n\n\nof Digital Currency Group (Foundry\u2019s parent company), called Fortitude Mining.156                 On\n\ninformation and belief, Foundry operated specialized bitcoin mining machines for performing\n\nBitcoin\u2019s SHA-256 algorithm, including models manufactured by Bitmain (e.g., S19157) and\n\nMicroBT (e.g., M30S158).159\n\n          52.    Foundry began engaging in the foregoing infringing activities years after Certicom\n\nand BlackBerry invented and received patents covering the ECC technologies at issue in this\n\naction. Indeed, most of these innovations were already incorporated into the Bitcoin protocol and\n\narchitecture by the time Foundry began its Bitcoin mining operations.\n\n                                        PATENTS IN SUIT\n\n          53.    Malikie is the assignee of and owns all right and title to U.S. Patent Nos. 8,788,827\n\n(the \u201c\u2019827 Patent\u201d); 8,806,197 (the \u201c\u2019197 Patent\u201d); 8,666,062 (the \u2019062 Patent\u201d); 8,532,286 (the\n\n\u201c\u2019286 Patent\u201d); and 8,712,039 (the \u201c\u2019039 Patent\u201d) (collectively, the \u201cAsserted Patents\u201d).\n\n\n\n156\n   https://www.businesswire.com/news/home/20250129138884/en/DCG-Launches-Fortitude-\nMining-A-New-Venture-Mining-Subsidiary-Targeting-High-Growth-Digital-Assets (\u201c\u2018Mike\nColyer built a successful self-mining business as part of the broader Foundry portfolio, featuring\na best-in-class mining fleet and significant revenues in 2024,\u2019 said Barry Silbert, Founder &\nCEO, DCG. \u2018With this strong foundation, spinning out Fortitude Mining as the leading venture\nminer provides greater growth opportunities to further scale the business, including raising\ncapital, making additional investments, and attracting top-tier talent.\u2019\u201d).\n157\n      https://support.bitmain.com/hc/en-us/articles/900000253583-S19-Specifications.\n158\n      https://d-central.tech/whatsminer-m30-series/; https://whatsminer.net/product/m30s-shipnow/.\n159\n   https://www.youtube.com/watch?v=lWcdrepehsM at 16:25-18:29 (\u201cAnd, again, to Barry\u2019s\ncredit, he said, \u2018Hey, Mike, if you\u2019re going to do equipment financing, you should probably buy\nsome machines.\u2019 And I\u2019m like, \u2018Oh, yeah, yeah, good idea. So how many do you want me to\nbuy?\u2019 And he goes \u2018Id\u2019 buy all you can buy.\u2019 \u2026 So we bought\u2014we started placing orders \u2026 We\nwere placing order for the new M30S and the new S19\u2019s \u2026 What was tough was Barry said \u2018the\nonly thing I don\u2019t want to be is was bitcoin miner.\u2019 And, I remember \u2026 we got on a Teams call\nand he said\u2014I\u2019m like, \u2018Nobody took me up on my offer and I got a lot of machines coming.\u2019\nAnd he goes, \u2018Well, I guess we\u2019ll be a bitcoin miner.\u2019 So that was the beginning of it. So, we\nwere the biggest bitcoin miner in 2021. \u2026 We put it everywhere. I called everyone back up, they\nhad rack space, and we plugged in machines everywhere.\u201d).\n\n\n                                                  36\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26      Page 37 of 65\n\n\n\n\n          54.    The Asserted Patents, now owned by Malikie, were originally assigned to Certicom.\n\nTheir inventors are former Certicom employees who spearheaded Certicom\u2019s industry-leading\n\nresearch and development in elliptic curve cryptography, applied cryptography and key\n\nmanagement, and other data security technologies.          After a longstanding alliance between\n\nBlackBerry and Certicom that enabled BlackBerry to utilize Certicom\u2019s elliptic curve\n\ncryptography technology in its products, BlackBerry acquired Certicom in 2009.160 Through its\n\nacquisition of Certicom and continued research and development in ECC, key management, and\n\nother aspects of data security, BlackBerry amassed \u201cthe world\u2019s largest ECC-based patent\n\nportfolio,\u201d161 which grew to include over 500 ECC patents162.\n\n          55.    Certicom and BlackBerry developed numerous innovative and diverse\n\ntechnologies, including groundbreaking inventions pertaining to generating and verifying digital\n\nsignatures and related cryptographic and data security technology. Some of these groundbreaking\n\ninventions are described and claimed in certain of the Asserted Patents.\n\n                       The \u201cAccelerated Verification Patents\u201d (\u2019827, \u2019197)\n\n          56.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n          57.    The \u2019827 Patent, entitled \u201cAccelerated Verification of Digital Signatures and Public\n\nKeys,\u201d was duly and lawfully issued on July 22, 2014. A true and correct copy of the \u2019827 Patent\n\nis attached hereto as Exhibit 1. The application for the \u2019827 Patent was filed on September 14,\n\n2012 as a continuation of the \u2019197 patent and claims the benefit of priority to earlier related\n\napplications, including provisional application no. 60/644,034, filed on January 18, 2005.\n\n\n160\n    See https://www.certicom.com/content/certicom/en/about.html;\nhttps://www.certicom.com/content/certicom/en/about/news/release/2000/research-in-motion-\nand-certicom-to-enable-trusted-mobile-commerc.html.\n161\n    https://www.certicom.com/content/certicom/en/about.html.\n162\n      https://blackberry.certicom.com/en; https://www.certicom.com/.\n\n\n                                                  37\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 38 of 65\n\n\n\n\n       58.     The \u2019827 Patent was at all points during its lifetime in full force and effect from its\n\nissuance. Malikie owns by assignment the entire right and title in and to the \u2019827 Patent, including\n\nthe right to seek damages for any infringement thereof.\n\n       59.     The \u2019197 Patent, entitled \u201cAccelerated Verification of Digital Signatures and Public\n\nKeys,\u201d was duly and lawfully issued on May August 12, 2014. A true and correct copy of the \u2019197\n\nPatent is attached hereto as Exhibit 2. The application for the \u2019197 Patent was filed on May 23,\n\n2012 and claims the benefit of priority to earlier related applications, including provisional\n\napplication no. 60/644,034, filed on January 18, 2005.\n\n       60.     The \u2019197 Patent was at all points during its lifetime in full force and effect from its\n\nissuance. Malikie owns by assignment the entire right and title in and to the \u2019197 Patent, including\n\nthe right to seek damages for any infringement thereof.\n\n       61.     The\u2019827 Patent and \u2019197 Patent (the \u201cAccelerated Verification Patents\u201d) share the\n\nsame title, specification, inventors, and a common priority claim.\n\n       62.     The Accelerated Verification Patents relate to computational techniques used in\n\ncryptographic algorithms, including elliptic curve algorithms for generating and verifying digital\n\nsignatures, that enable accelerated digital signature verification. See, e.g., Ex. 1 at 1:12-13, 4:15-\n\n33, 9:32-37, 11:43-50, 12:47-59, 13:60-62, 14:40-42, 15:27-40.163\n\n       63.     Cryptographic algorithms for generating and verifying digital signatures are used\n\nin cryptographic systems (or \u201ccryptosystems\u201d) to secure electronic data in computer systems and\n\ncomputer networks. See, e.g., Ex. 1 at 1:18-48; see also, e.g., 2:17-3:17, 6:23-36. The nature of\n\n\n\n163\n   Citations to the Accelerated Verification Patents (Exhibits 1 and 2) are exemplary and non-\nlimiting. Because the \u2019827 Patent and \u2019197 Patent share a common specification, only the \u2019827\nPatent (Exhibit 1) is cited in this Section. Citations to Exhibit 1 in this Section are intended to be\nrepresentative of the Accelerated Verification Patents.\n\n\n                                                 38\n\f          Case 6:26-cv-06874         Document 1       Filed 08/28/26      Page 39 of 65\n\n\n\n\nelectronic data in computer systems and computer networks presents unique security concerns\n\nrelating to, for example, digital message authenticity, for which specialized digital signature\n\ntechniques were found to be necessary. See, e.g., Ex. 1 at 1:18-48; see also, e.g., id. at 2:17-3:17;\n\nWhitfield Diffie and Martin Hellman, New Directions in Cryptography (1976)164 at 645 (\u201cCurrent\n\nelectronic authentication techniques cannot meet this need.\u201d), 647 (\u201cUnforgeable digital signatures\n\nand receipts are needed.\u201d), 649 (\u201cCurrent electronic authentication systems cannot meet the need\n\nfor a purely digital, unforgeable, message dependent signature. They provide protection against\n\nthird party forgeries, but do not protect against disputes between transmitter and receiver.\u201d), 649\n\n(observing that \u201cwe must discover a digital phenomenon\u201d to provide authentication for a \u201cpurely\n\nelectronic form of communication\u201d).\n\n       64.     Digital signatures are generated using public key cryptography, see, e.g., Ex. 1 at\n\n1:18-48; see also, e.g., id. at 2:17-3:17, which is a type of technology for securing electronic\n\ncommunications that was discovered after the advent of digital computing to address cryptography\n\nproblems arising particularly in \u201ccomputer controlled communication networks\u201d that created \u201ca\n\nneed for new types of cryptographic systems.\u201d165 New Directions in Cryptography at 644; see also\n\nid. (\u201cContemporary cryptography is unable to meet the requirements, in that its use would impose\n\nsuch severe inconveniences on the system users, as to eliminate many of the benefits of\n\nteleprocessing.\u201d); https://www.invent.org/inductees/whitfield-diffie (\u201cIn 1976, Whitfield Diffie,\n\nMartin Hellman, and Ralph Merkle developed public key cryptography (PKC), an innovative new\n\n\n\n164\n    https://ee.stanford.edu/~hellman/publications/24.pdf (\u201cNew Directions in Cryptography\u201d).\n165\n   Some credit Whitfield Diffie, Martin Hellman, and Ralph Merkle with discovering public key\ncryptography, while others credit James Ellis, Clifford Cocks, and Malcom Williamson. Diffie,\nHellman, and Merkle have received multiple patents for public key cryptography techniques,\nincluding U.S. Patent Nos. 4,200,770 and 4,218,582. Other public key cryptography techniques,\nlike RSA, have also been patented. See, e.g., U.S. Patent No. 4,405,829.\n\n\n                                                 39\n\f           Case 6:26-cv-06874      Document 1         Filed 08/28/26   Page 40 of 65\n\n\n\n\nmethod for securing electronic communications.\u201d); https://archive.nytimes.com/www.nytimes\n\n.com/library/cyber/week/122497encrypt.html (\u201cThe set of algorithms, equations and arcane\n\nmathematics that make up public key cryptography are a crucial technology for preserving\n\ncomputer privacy in and making commerce possible on the Internet. Some hail its discovery as\n\none of the most important accomplishments of 20th-century mathematics \u2026. Without it, there\n\nwould be no privacy in cyberspace.\u201d); Whitfield Diffie, The First Ten Years of Public Key\n\nCryptography (1988)166 at 560 (\u201cPublic key cryptography was born in May 1975, the child of two\n\nproblems,\u201d where \u201c[t]he second problem \u2026 was the problem of signatures. Could a method be\n\ndevised that would provide the recipient of a purely digital electronic message with a way of\n\ndemonstrating to other people that it had come from a particular person\u2026?\u201d); id. at 560 (\u201cThis\n\nseparation [of the capacities for encryption and decryption using public key cryptography] allows\n\nimportant improvements in the management of cryptographic keys and makes it possible to \u2018sign\u2019\n\na purely digital message.\u201d); https://bitcoinwiki.org/wiki/public-key-cryptography (\u201cPublic key\n\nalgorithms are fundamental security ingredients in modern [ ] applications and protocols assuring\n\nthe confidentiality [and] authenticity [ ] of electronic communications and data storage. They\n\nunderpin    various   Internet   standards    \u2026.\u201d);     https://www.nsa.gov/History/Cryptologic-\n\nHistory/Historical-Figures/Historical-Figures-View/Article/3006218/clifford-cocks-james-ellis-\n\nand-malcolm-williamson/ (\u201cThe security of the global communication infrastructure is built on\n\npublic key cryptography and the importance of PKC in enabling the modern world of secure\n\nbanking, e-commerce, and encrypted messaging cannot be overstated.\u201d).\n\n\n\n\n166\n   https://www.cs.virginia.edu/~evans/greatworks/diffie.pdf (\u201cThe First Ten Years of Public-Key\nCryptography\u201d).\n\n                                               40\n\f          Case 6:26-cv-06874        Document 1       Filed 08/28/26      Page 41 of 65\n\n\n\n\n       65.     As the patents explain, \u201cPublic key cryptography permits the secure\n\ncommunication over a data communication system without the necessity to transfer identical keys\n\nto other parties in the information exchange through independent mechanisms, such as a courier\n\nor the like.\u201d See, e.g., Ex. 1 at 1:24-34. \u201cPublic key cryptography is based upon the generation of\n\na key pair, one of which is private and the other public that are related by a one way mathematical\n\nfunction.\u201d Id. \u201cThe one way function is such that, in the underlying mathematical structure, the\n\npublic key is readily computed from the private key but the private key cannot feasibly be\n\nascertained from the public key.\u201d Id. \u201cPublic key cryptography may also be used to digitally sign\n\na message to authenticate the origin of the message.\u201d Id. at 1:44-48. \u201cThe author of the message\n\nsigns the message using his private key and the authenticity of the message may then be verified\n\nusing the corresponding public key.\u201d Id. So, in a network where members do not know each other\n\n(or wish to remain pseudonymous) and have never even communicated with each other previously,\n\n\u201c[a] subscriber can sign a message by encrypting it with his own secret key. Anyone with access\n\nto the public key can verify that it must have been encrypted with the corresponding secret key,\n\nbut this is of no help to him in creating (forging) a message with this property.\u201d The First Ten\n\nYears of Public-Key Cryptography at 561. \u201cThe availability of a signature that the receiver of a\n\nmessage cannot forge and the sender cannot readily disavow makes it possible to trust the network\n\nwith negotiations and transactions of much higher value than would otherwise be possible.\u201d Id.\n\nAccordingly, digital signature technology based on public key cryptography fundamentally\n\nenables \u201ctrustless\u201d networks that do not require a trusted intermediary to verify or authenticate\n\nmessages.\n\n       66.     The patents further explain that \u201c[t]he security of such systems [employing digital\n\nsignatures using public key cryptography] is dependent to a large part on the underlying\n\n\n\n\n                                                41\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 42 of 65\n\n\n\n\nmathematical structure.\u201d See, e.g., Ex. 1 at 1:49-55. \u201cThe most commonly used structure for\n\nimplementing discrete logarithm systems is a cyclic subgroup of a multiplicative group of a finite\n\nfield in which the group operation is multiplication or cyclic subgroups of elliptic curve groups in\n\nwhich the group operation is addition.\u201d Id.\n\n       67.     \u201cAn elliptic curve E is a set of points of the form (x,y) where x and y are in a field\n\nF, such as the integers modulo a prime [number] p, commonly referred to as Fp, and x and y satisfy\n\na non-singular cubic equation, which can take the form y2=x3+ax+b for some a and b in F.\u201d Id. at\n\n1:56-2:16. Elliptic curves have other defining characteristics that give them special properties\n\nmaking them useful for cryptographic implementations. See id.\n\n       68.     \u201cIn an elliptic curve cryptosystem,\u201d \u201c[t]he key pair may be used with various\n\ncryptographic algorithms to establish common keys for encryption and to perform digital\n\nsignatures.\u201d Id. at 2:17-27. \u201cOne such algorithm is the Elliptic Curve Digital Signature Algorithm\n\n(ECDSA) used to generate digital signatures on messages exchanged between entities. Entities\n\nusing ECDSA have two roles, that of a signer and that of a verifier.\u201d Id. at 2:28-31. In ECDSA\n\ncryptosystems, \u201c[the] signer selects a long term private key d, which ... must be secret.\u201d Id. at\n\n2:31-41. The signer also computes \u201cQ\u201d, which is \u201cthe long term public key of the signer, and is\n\nmade available to the verifiers.\u201d Id. \u201cFinding the private key d from the public key Q is believed\n\nto [be] an intractable problem for the choices of elliptic curves used today.\u201d Id. Accordingly,\n\n\u201c[f]or any message M, the signer can create a signature, which is a pair of integers (r, s) in the case\n\nECDSA,\u201d and \u201c[a]ny verifier can take the message M, the public key Q, and the signature (r, s),\n\nand verify whether it was created by the corresponding signer.\u201d Id. at 2:42-48. This is because\n\ncreation of a valid signature (r, s) is believed to possible only by an entity who knows the private\n\nkey d corresponding to the public key Q.\u201d Id.\n\n\n\n\n                                                  42\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 43 of 65\n\n\n\n\n       69.     The process for creating a digital signature (signing an electronic message) using\n\nECDSA includes, among others, the following steps. \u201cFirst, the signer chooses some integer k \u2026\n\nthat is to be used as a session, or ephemeral, private key. The value k must be secret.\u201d Id. at 2:49-\n\n63. \u201cThen, the signer computes a point R=kG that has coordinates (x, y).\u201d Id. \u201cNext, the signer\n\nconverts x to an integer x' and then computes r=x' mod n, which is the first coordinate of the\n\nsignature.\u201d Id. \u201cThe signer must also compute the integer e=h(M) mod n, where h is [a] hash\n\nfunction.\u201d Id. \u201cFinally, the second coordinate s is computed as s=(e+dr)/s mod n.\u201d Id. \u201cThe\n\ncomponents (r, s) are used by the signer as the signature of the message, M, and sent with the\n\nmessage to the intended recipient.\u201d Id.\n\n       70.     The process for verifying a digital signature created using ECDSA includes, among\n\nothers, the following steps. \u201cFirst the verifier computes an integer e=h(M) mod n from the received\n\nmessage.\u201d Ex. 1 at 2:64-3:4. \u201cThen the verifier computes integers u and v such that u=e/s mod n\n\nand v=r/s mod n.\u201d Id. \u201cNext, the verifier computes a value corresponding to the point R that is\n\nobtained by adding uG+vQ. This has co-ordinates (x, y).\u201d Id. \u201cFinally the verifier converts the\n\nfield element x to an integer x' and checks that r=x' mod n. If it does the signature is verified.\u201d Id.\n\n       71.     The inventors recognized technological problems associated with the above-\n\ndescribed ECDSA signature verification process and invented ways to improve it. For example,\n\nthe inventors recognized that \u201cthe verification of an ECDSA signature appears to take twice as\n\nlong as the creation of an ECDSA signature, because the verification process involves two scalar\n\nmultiplications, namely uG and vQ, whereas signing involves only one scalar multiplication,\n\nnamely kG.\u201d Ex. 1 at 3:5\u201317. The inventors further recognized that \u201c[e]lliptic curve scalar\n\nmultiplications consume most of the time of these processes, so twice as many of them essentially\n\ndoubles the computation time.\u201d Id. And, while some \u201c[m]ethods are known for computing uG+vQ\n\n\n\n\n                                                  43\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 44 of 65\n\n\n\n\nthat takes less time than computing uG and v[Q] separately,\u201d the inventors recognized that such\n\nmethods nevertheless \u201cmean that computing uG+vQ can take 1.5 times as long as computing kG.\u201d\n\nId.\n\n       72.     Accelerating elliptic curve computations (reducing computing time) is a\n\ntechnological problem for which the inventors discovered technological solutions. Accelerating\n\nelliptic curve computations requires the use of additional computer resources, such as memory and\n\nprocessing capabilities. See Ex. 1 at 3:18-4:14. However, known techniques for accelerating\n\nelliptic curve computations provided limited overall benefits to the overall computer architecture\n\nbecause the ability to achieve faster operations came at the significant cost of more memory and\n\npotentially wasteful pre-computation processing cycles. Id. The inventors recognized that \u201cthese\n\ncosts may accumulate to the point that any benefit of faster computation is offset by the need to\n\nstore or communicate\u201d more pre-computed data. Moreover, \u201c[t]he net benefit depends on the\n\nrelative cost of time, memory and bandwidth, which can vary tremendously between\n\nimplementations and systems.\u201d Id. Accordingly, achieving such benefits required case-by-case\n\noptimizations of parameters to strike a balance between an achievable increase in speed with\n\nincreases in computational and memory costs. See id.\n\n       73.     The inventors taught improvements to the ECDSA digital signature verification\n\nprocess. Ex. 1 at 4:15-33. For example, the patents teach techniques that enable accelerated\n\nsignature verification, which include, among other things, generating, for use with a digital\n\nsignature (e.g., a signature with components (r, s)), an indicator (e.g., i) to identify which value of\n\na plurality of values (e.g., for a point with coordinates (x, y)) recover able from the first signature\n\ncomponent (e.g., r of the pair (r, s)) is an ephemeral public key (e.g., R). See, e.g., Ex. 1 at 5:23-\n\n31, 6:37\u20137:38, 9:44-46, 10:61\u201311:5, 12:11\u201359, 15:29\u201333. The patents teach that such techniques\n\n\n\n\n                                                  44\n\f            Case 6:26-cv-06874       Document 1        Filed 08/28/26      Page 45 of 65\n\n\n\n\naccelerate the recovery of, for example, an ephemeral public key (e.g., R) for verifying digital\n\nsignatures (thereby also accelerating digital signature verification), which provide a technological\n\nimprovement. See, e.g., id.\n\n       74.      The patents also teach techniques that enable accelerated digital signature\n\nverification, which include, among other things, recovering (or generating) a signer\u2019s public key\n\n(e.g., Q) from the digital signature of a message, where doing so includes computing Q as r-1(sR-\n\neG) using components of the digital signature (rather than sending Q in the message or retrieving\n\nit elsewhere), where G comprises a generator of an elliptic curve group that includes a first elliptic\n\ncurve point R and the second elliptic curve point Q. See, e.g., Ex. 1 at 4:48-5:4; 7:39\u201358, 8:12\u2013\n\n9:31, 9:67\u201310:34, 12:43\u201359, 13:1\u201326, 15:15\u201340. The patents teach that such techniques reduce\n\nbandwidth and storage and accelerate the verification of digital signatures, allowing more digital\n\nsignatures to be verified in a given amount of time, which provide technological improvements\n\nover preexisting techniques. See, e.g., id.\n\n                              The \u201cFinite Field Engine Patent\u201d (\u2019062)\n\n       75.      Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       76.      The \u2019062 Patent, entitled \u201cMethod and Apparatus for Performing Finite Field\n\nCalculations,\u201d was duly and lawfully issued on March 4, 2014. A true and correct copy of the \u2019062\n\nPatent is attached hereto as Exhibit 3. The application for the \u2019062 Patent was filed on April 11,\n\n2008 and claims the benefit of priority to earlier related applications, including provisional\n\napplication nos. 60/343,220, 60/343,223, and 60/343,226, and 60/343,227, all filed on December\n\n31, 2001.\n\n\n\n\n                                                 45\n\f            Case 6:26-cv-06874        Document 1       Filed 08/28/26       Page 46 of 65\n\n\n\n\n          77.    The \u2019062 Patent was in full force and effect from its issuance until it expired on\n\nOctober 14, 2025. Malikie owns by assignment the entire right and title in and to the \u2019062 Patent,\n\nincluding the right to seek damages for any infringement thereof.\n\n          78.    The \u2019062 Patent relates generally to finite field engines and methods for use with\n\ncryptographic systems. See, e.g., Ex. 3 at 1:15\u201318.167\n\n          79.    The patent teaches that \u201c[c]ryptography is commonly used to provide data security,\n\nintegrity, and authentication\u201d over communication channels, such as, for example, connections\n\nover the Internet or a wireless network. See, e.g., id. at 1:22\u201344. Protocols employing such\n\ncryptographic technology may require the use of secret keys. Id. For example, \u201c[c]orrespondents\n\nusing public key cryptography each have a private key and a corresponding public key\u201d such that\n\n\u201cit is computationally infeasible to compute the private key given only the public key,\u201d while \u201ca\n\nmathematical relationship between the keys allows them to be used to provide security, integrity,\n\nor authentication in various protocols where the public keys are shared and the private keys are\n\nkept secret.\u201d Id.\n\n          80.    The patent teaches that \u201c[e]lliptic curve cryptography (ECC) is a particularly\n\nefficient form of public key cryptography that is especially useful in [resource] constrained\n\nenvironments.\u201d See, e.g., id. at 1:45\u201360.\n\n          81.    As the patent explains, an elliptic curve is specified with \u201ca finite field and an\n\nequation over that finite field are needed,\u201d where \u201c[t]he points on the elliptic curve are the pairs of\n\nfinite field elements satisfying the equation of the curve.\u201d See, e.g., id. \u201cTo carry out calculations\n\ninvolving points on the elliptic curve, calculations are done in the underlying finite field, according\n\nto well-known formulas that use parameters of the curve.\u201d Id. \u201cThese formulas define an addition\n\n\n167\n      Citations to the \u2019062 Patent (Exhibit 3) are exemplary and non-limiting.\n\n\n                                                  46\n\f           Case 6:26-cv-06874        Document 1        Filed 08/28/26      Page 47 of 65\n\n\n\n\noperation on a pair of elliptic curve points,\u201d and \u201c[a] scalar multiplication operation is defined by\n\nrepeated additions, analogously to regular integer multiplication.\u201d Id.\n\n         82.    Users of an elliptic curve cryptosystem generate a key pair comprising a private\n\nkey and a public key based on parameters common to all uses (including the finite field, the elliptic\n\ncurve, and a generator point on the curve). Id. at 1:61\u20132:3. A correspondent\u2019s private key is an\n\ninteger (which is kept secret, such as a random number) that is less than the order of the elliptic\n\ncurve.    Id.   \u201cA correspondent\u2019s public key is the elliptic curve point obtained by scalar\n\nmultiplication of the private key with a generator point.\u201d Id.\n\n         83.    The patent teaches that \u201c[t]he security level of a cryptographic system mainly\n\ndepends on the key size that is used,\u201d where \u201c[l]arger key sizes give a higher security level than\n\ndo smaller key sizes.\u201d See, e.g., id. at 2:4-11. \u201c[H]owever, different key sizes require defining\n\ndifferent elliptic curves over different finite fields,\u201d where (generally) \u201cthe greater the desired\n\ncryptographic strength of the ECC, the larger will be the size of the finite field.\u201d Id. Multiple\n\ntechnological problems emerge from these possibilities.\n\n         84.    For example, given the possible variability in elliptic curves and finite fields, \u201can\n\nimplementation of elliptic curve cryptography may need to support several different finite fields\n\nfor use in particular applications.\u201d Id. at 2:12\u201317. The patent teaches that \u201c[i]mplementing [such]\n\nan elliptic curve cryptosystem therefore requires either the implementation of specific methods for\n\neach finite field or a generic method usable in any finite field.\u201d See, e.g., id. The patents further\n\nteach that \u201c[t]he use of specific methods for each finite field leads to more efficient code since it\n\nmay be optimized to take advantage of the specific finite field,\u201d but that \u201csupporting several finite\n\nfields in this way will increase the code size dramatically.\u201d See, e.g., id. On the other hand, \u201c[t]he\n\nuse of a generic method prevents the use of optimization techniques, since the code cannot take\n\n\n\n\n                                                 47\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 48 of 65\n\n\n\n\nadvantage of any particular properties of the finite field,\u201d which \u201cmakes the code less efficient but\n\nhas the advantage of much smaller code size.\u201d Id.\n\n       85.     Another technological problem is that \u201c[s]oftware implementation of finite fields\n\nraises the question of how to arrange the storage of the bits corresponding to the finite field\n\nelements.\u201d Id. at 2:27\u201335. The patent teaches that elliptic curve cryptosystems may employ finite\n\nfields (whether binary fields or prime fields) with elements that may be represented as bits in\n\nhardware or software, where \u201c[t]hese bits must then be represented in the memory storage of the\n\ncomputer system.\u201d See, e.g., id. The patent teaches, however, that \u201c[w]hen using a general purpose\n\ncomputational engine (for example a typical CPU), finite field elements are often too long to be\n\nrepresented in a single machine word of the engine (engine word lengths are typically 16, 32, or\n\n64 bit).\u201d See, e.g., id. And, \u201c[s]ince the finite field [elements] used in ECC operations are typically\n\n160 bits or more, these elements must be represented in several machine words.\u201d Id. \u201cEngine\n\nroutines (programs) that provide finite field calculations must therefore deal with multiple machine\n\nwords to complete their calculations.\u201d Id. Moreover, \u201c[w]ith either type of codes,\u201d i.e., software\n\nemploying specific methods (which may be word size-specific) or general methods (which may\n\nbe word size non-specific), \u201cit is necessary to provide finite field operations including\n\nmultiplication, addition, inversion, squaring and modular reduction.\u201d Id. To compute the results\n\nof such operations on ECC finite field elements and store them in computer memory, complicated\n\noperations and \u201cmany bit shifts are required,\u201d which \u201cresults in longer processing time and also\n\nextra processor operation.\u201d Id.\n\n       86.     The inventors recognized that improvements in finite field operations, including for\n\nECC operations, may be achievable to improve the speed and efficiency of finite field engines.\n\nEx. 3 at 4:10\u201325; see id. at 2:4\u20133:32.\n\n\n\n\n                                                  48\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 49 of 65\n\n\n\n\n       87.     For example, the patent teaches techniques that enable the performance of finite\n\nfield operations on elements of a finite field (e.g., coordinates of points on an elliptic curve) that\n\ninclude, among other things, obtaining a first set of instructions for performing the finite field\n\noperation on values representing the elements of the finite field and executing it to generate an\n\nunreduced result, obtaining a second set of instructions for performing a modular reduction for a\n\nspecific finite field and executing it to generate a reduced result, and providing the reduced result\n\nas an output for use in a cryptographic operation. See, e.g., id. at 6:22\u20137:8, 7:9\u20138:63, 8:64\u201312:4,\n\n14:57\u201316:19. Using such techniques, technological benefits are achievable. For example, \u201cfast\n\nengines can be produced for many specific finite fields, without duplicating the bulk of the engine\n\ninstructions (program).\u201d Id., Abstract, 4:21\u201325; see also, e.g., id. at 12:43\u201313:2, 14:53\u201365.\n\nAdditionally, \u201cfinite field elements may be consistently stored in registers of the same word\n\nlength.\u201d Id. at 8:36\u201349. Furthermore, fewer bit shifts are required, thereby resulting in shorter\n\nprocessing time and fewer processor operations. Id. at 10:65\u201311:2, 11:17\u201323; see id. at 3:28\u201332.\n\n                      The \u201cImproved Modular Reduction\u201d Patent (\u2019286)\n\n       88.     Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       89.     The \u2019286 Patent, entitled \u201cSystem and Method for Reducing the Computation and\n\nStorage Requirements for a Montgomery-Style Reduction,\u201d was duly and lawfully issued on\n\nSeptember 10, 2013. A true and correct copy of the \u2019286 Patent is attached hereto as Exhibit 4.\n\nThe application for the \u2019286 Patent was filed on July 19, 2010, and claims the benefit of priority\n\nof Provisional App. No. 61/226,427, filed on July 17, 2009.\n\n       90.     The \u2019286 Patent has been and continues to be in full force and effect since its\n\nissuance. Malikie owns by assignment the entire right and title in and to the \u2019286 Patent, including\n\nthe right to seek damages for any infringement thereof.\n\n\n\n\n                                                 49\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 50 of 65\n\n\n\n\n       91.     The \u2019286 Patent relates generally to systems and methods for reducing the\n\ncomputation and storage requirements for a Montgomery style reduction (a form of modular\n\narithmetic). See, e.g., Ex. 6 at 1:13\u201316; see also id., Abstract.\n\n       92.     The patent teaches that \u201c[i]n cryptography, e.g. public key cryptography, operations\n\nsuch as multiplication or exponentiation of integers in some group Zn, may be required, where\n\nmodular arithmetic is used to operate on the integers.\u201d Ex. 6 at 1:20\u201330. \u201cFor example, to multiply\n\ntwo numbers modulo some [number] n, the classical approach is to first perform the multiplication\n\nand then calculate the remainder.\u201d168 Id. The patent teaches that \u201c[a]lthough the classical approach\n\nis simple for basic operations such as in multi-precision calculations and does not require\n\nprecomputation, the step of calculating the remainder is considered slow.\u201d Id. \u201cThe calculation\n\nof the remainder is referred to as reduction in modular arithmetic.\u201d Id.\n\n       93.     The patent further teaches that \u201c[i]n Montgomery reduction, calculations with\n\nrespect to a modulus n are carried out with the aid of an auxiliary number R called the Montgomery\n\nradix or base.\u201d Ex. 6 at 1:47\u201364. For example, \u201c[t]he Montgomery reduction of a number a with\n\nradix R and prime modulus n is the quantity given by aR-1 mod n.\u201d Id.\n\n       94.     \u201cIn a given cryptographic system,\u201d the patent teaches, \u201ca computational engine may\n\nbe used for calculating the Montgomery product of two numbers, this engine being sometimes\n\nreferred to as a Montgomery engine or Montgomery machine.\u201d Ex. 6 at 1:65\u20132:13. The patent\n\nfurther teaches that \u201c[t]he engine may be implemented in a hardware or software module and\n\n\n\n\n168\n   The term \u201cmodulo\u201d means to calculate the remainder after dividing one number by another.\nSee, e.g., https://www.mathsisfun.com/definitions/modulo-operation.html; see also\nhttps://en.wikipedia.org/wiki/Modulo (\u201cIn computing and mathematics, the modulo operation\nreturns the remainder or signed remainder of a division, after one number is divided by another,\nthe latter being called the modulus of the operation.\u201d).\n\n\n                                                  50\n\f            Case 6:26-cv-06874       Document 1        Filed 08/28/26     Page 51 of 65\n\n\n\n\noperates on a set of parameters to produce a result.\u201d Id. For example, using a Montgomery engine,\n\n\u201cMontgomery multiplication may proceed as follows:\n\n       1.     c \u2190 0, where c will hold the result abR-1 mod n and c = (c\ud835\udc58 c\ud835\udc58\u22121 \u2026 c1 c0 ).\n\n       2. For i from 0 to (k-1) do the following:\n       2.1 m \u2190 (c0 + a\ud835\udc56 , bo )\u03bc mod 2\ud835\udc64 ; and\n       2.2 c \u2190 (c + a\ud835\udc56 b + mn)/2\ud835\udc64\n\n       3.     If c \u2267 n then c \u2190 c \u2212 n\n\n       4.     Return (c).\u201d\n\nEx. 6 at 2:14\u201333.\n\n       95.      \u201cIn Montgomery reduction, the value \u00b5 is used to zero w least significant bits of a\n\nvalue a,\u201d whereby \u201c[f]irst, a multiplier m=\u00b5a mod 2w is computed,\u201d where \u201c[t]he value m has at\n\nmost w bits.\u201d Ex. 6 at 2:47\u201353. \u201cAdding a+mn will zero w least significant bits of a, and a may\n\nbe shifted down w bits.\u201d Id. \u201cSince typically L=kw, where k is the number of w-bit words in R[,]\n\nthis operation is repeated k times to effect the Montgomery reduction aR-1 mod n.\u201d Id.\n\n       96.      The patent teaches that \u201cefficiency may be increased by pre-computing certain\n\nfixed values to be used in the calculations,\u201d where \u201c[s]uch values include \u00b5=(-n)-1 mod 2w, for\n\nsome w typically being the bit size of a word (or block) of the value (or perhaps the entire value)\n\nbeing operated on; and R2 mod n.\u201d Ex. 6 at 2:34\u201346.\n\n       97.      The patent further teaches that \u201c[i]n a register-based processor, registers are\n\ntypically used to hold components of the value to be reduced, namely the precomputed value \u00b5\n\nand the modulus n.\u201d Ex. 6 at 2:59\u201361.\n\n       98.      The inventors recognized these technological problems and discovered\n\nimprovements in modular reduction engines for computers (e.g., Montgomery engines) to address\n\nthem. See, e.g., Ex. 6 at 3:21\u201345, 5:28\u201336, 3:40\u201345, 5:24\u201335, 5:45\u20136:19, 6:51\u201365.\n\n\n\n\n                                                 51\n\f          Case 6:26-cv-06874         Document 1       Filed 08/28/26      Page 52 of 65\n\n\n\n\n       99.     For example, the patent teaches techniques for performing, on a cryptographic\n\napparatus, a Montgomery-style reduction in a cryptographic operation that includes obtaining an\n\noperand for the cryptographic operation; computing a modified operand using a reduction value,\n\ninstead of a modulus used in performing a standard Montgomery reduction, to perform a\n\nreplacement of a least significant word of the operand, rather than per form a cancellation thereof,\n\nwhere the reduction value is a function of the modulus; and outputting the modified operand. See,\n\ne.g., Ex. 6 at 4:40\u20136:65. The patent teaches that such inventive techniques can reduce the number\n\nof multiplications and registers needed to effect the modular reduction, thereby providing a new\n\nand inventive technique for efficient modular reduction machines.169 See, e.g., id. at 3:40\u201342,\n\n5:28\u201336, 6:2\u201319, 6:51\u201365. For example, the patent teaches that \u201c[i]n a machine 22 that has a\n\nlimited number of registers and/or computational capabilities, it is desirable to reduce both the\n\nnumber of stored values and the number of computations,\u201d and that \u201c[t]o avoid having to store\n\nboth \u00b5 and n, it has been recognized by the inventor that a modified reduction value or a logical\n\nshift or signed version of such a value can be used in place of \u00b5 and n for the bulk of the low-order\n\nreduction.\u201d Id. at 5:28\u201336. The patent also teaches that the inventive technique \u201cavoids both the\n\nmultiplication necessary to compute m and the storage required for \u00b5\u201d and that the modified\n\nreduction value \u201cdoes not require more registers than would be needed\u201d otherwise. Id. at 6:2\u201319.\n\nThe patent further teaches that the inventors observed significant benefits of the inventive\n\ntechniques when used, for example, to perform ECC operations using resource-constrained\n\ncomputer processor architectures (e.g., \u201cthe popular ARM architecture\u201d). Id. at 6:51\u201365.\n\n\n\n169\n   A register is hardware in a CPU for temporary storage of data during program execution. See,\ne.g., https://techterms.com/definition/register; https://www.allaboutcircuits.com/video-\nlectures/internal-registers-alu/; https://gunkies.org/wiki/Register;\nhttps://www.theiotacademy.co/blog/registers-in-cpu/.\n\n\n                                                 52\n\f          Case 6:26-cv-06874          Document 1        Filed 08/28/26       Page 53 of 65\n\n\n\n\n                         The \u201cImproved Hash Processing Patent\u201d (\u2019039)\n\n        100.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n        101.    The \u2019039 Patent, entitled \u201cEfficient Implementation of Hash Algorithm on a\n\nProcessor,\u201d was duly and lawfully issued on April 29, 2014. A true and correct copy of the \u2019039\n\nPatent is attached hereto as Exhibit 5. The application for the \u2019039 Patent was filed on April 5,\n\n2012, and claims the benefit of priority of Provisional App. No. 61/472,422, filed on April 6, 2011.\n\n        102.    The \u2019039 Patent has been and continues to be in full force and effect since its\n\nissuance. Malikie owns by assignment the entire right and title in and to the \u2019039 Patent, including\n\nthe right to seek damages for any infringement thereof.\n\n        103.    The \u2019039 Patent relates generally to systems and methods for efficient\n\nimplementations of hash algorithms on a computer processor, including techniques for utilizing a\n\nprocessor\u2019s registers to efficiently perform multiple iterations of SHA-2 family secure hash\n\nalgorithms. See, e.g., Ex. 6 at 1:17-20, 1:39-54, 2:8-20; see also id., Abstract.\n\n        104.    The patent teaches that an issue related to processing secure hash algorithms, such\n\nas secure hash algorithms in the SHA-2 family170, is that implementing such secure hash\n\nalgorithms on advanced processor architectures, such as ARM processors, is challenging because\n\nthe number of available registers is insufficient to store the entire state of the secure hash algorithm,\n\nsuch that \u201conly portions of it at a time would be loaded into them and undergo the necessary\n\ncalculations before being stored back on the stack.\u201d Id. at 1:39-54. The patent teaches that \u201c[t]he\n\nchallenge lies in optimizing the registers utilization and minimizing the relatively lengthy load\n\noperations.\u201d Id.\n\n\n170\n   The SHA-2 family includes, for example, SHA-256, SHA-384, and SHA-512, among others.\nSee https://csrc.nist.gov/projects/hash-functions/nist-policy-on-hash-functions;\nhttps://csrc.nist.gov/files/pubs/fips/180-3/final/docs/fips180-3_final.pdf at 3.\n\n\n                                                   53\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26       Page 54 of 65\n\n\n\n\n       105.    The inventors recognized these technological problems and discovered improved\n\nways to implement secure hash algorithms in computer processors to address them. See, e.g., Ex.\n\n6 at 2:8-20, 2:65-5:49. For example, the patent teaches methods and systems for maximizing a\n\nnumber of registers at an end of an iteration of a hash algorithm for use in a next iteration,\n\ncomprising categorizing and unrolling iterations of an original secure hash algorithm into even\n\niterations and odd iterations, reversing a sequence of computations in the even iterations to those\n\nin the odd iterations that results in an average number of words that need to be loaded into the\n\nregisters per iteration being reduced by at least one-half compared to the original secure hash\n\nalgorithm, and combining an even iteration and odd iteration to provide a new iteration of a loop.\n\nSee, e.g., 2:8-20, 2:65-5:49, 11:38-49.        For example, the patent teaches that in certain\n\nembodiments, words may be 64 bits long while the processor registers are 32 bits long. Id. at 3:1-\n\n3. The state of every iteration of the secure hash algorithm may include, for example, eight 64-bit\n\nwords (e.g., A-H) such that the block to be hashed includes sixteen 64-bit words. Id. at 3:4-9.\n\nWhereas with an original secure hash algorithm all the values of words A-H require load operations\n\nfrom the stack into the registers to undergo the specified functions, \u201c[t]he present embodiment\n\nminimizes the number of load instructions required in every iteration by reusing values from the\n\nprevious iteration that are still in the registers,\u201d which \u201cis achieved by categorizing, and unrolling,\n\nthe algorithm iterations into even and odd ones, where the sequence of computation in the even\n\niteration is reversed.\u201d Id. at 3:49-58. The inventive techniques of the \u2019039 patent allow the average\n\nnumber of words loaded per original iteration to be reduced, for example, in some embodiments,\n\nfrom eight (sixteen 32-bit loads) to four (eight 32-bit loads). Id. at 4:60-63.\n\n                                 JURISDICTION AND VENUE\n\n       106.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n\n\n\n                                                  54\n\f            Case 6:26-cv-06874        Document 1        Filed 08/28/26      Page 55 of 65\n\n\n\n\n          107.   This civil action arises under the patent laws of the United States, 35 U.S.C. \u00a7 1 et\n\nseq., including without limitation 35 U.S.C. \u00a7\u00a7 271, 281, 283, 284, and 285. This is a patent\n\ninfringement lawsuit over which this Court has subject matter jurisdiction under, inter alia, 28\n\nU.S.C. \u00a7\u00a7 1331, 1332, and 1338(a).\n\n          108.   This Court has general and specific personal jurisdiction over Foundry because\n\nFoundry resides in this District, where it is headquartered and maintains its principal place of\n\nbusiness, and because, directly or through intermediaries, Foundry has committed acts within this\n\nDistrict giving rise to this action; is present in and transacts and conducts business, directly and/or\n\nindirectly, in this District and the State of New York; and transacts and conducts business with\n\nresidents of this District and the State of New York.\n\n          109.   Plaintiffs\u2019 causes of action arise, at least in part, from Foundry\u2019s contacts with and\n\nactivities in and/or directed at this District and the State of New York. On information and belief,\n\nFoundry\u2019s corporate headquarters and principal place of business are located at 1100 Pittsford\n\nVictor Road, Pittsford, New York 14534, which is in Monroe County and within this Judicial\n\nDistrict.    Foundry identifies that address on its own website as the address of its Legal\n\nDepartment.171 Foundry publicly describes itself as \u201cbased in Rochester, NY,\u201d and it issues its\n\ncorporate announcements from Rochester, New York.172\n\n          110.   On information and belief, Foundry is a Delaware limited liability company that\n\nhas been authorized to do business in the State of New York. On information and belief, the\n\naddress to which the New York Secretary of State is directed to mail process served on Foundry is\n\n\n\n\n171\n      See https://foundrydigital.com/terms-and-conditions/.\n172\n  See https://www.prnewswire.com/news-releases/tech-entrepreneur-dan-magnuszewski-\nnamed-foundry-chief-technology-officer-company-to-open-buffalo-office-301567763.html.\n\n\n                                                  55\n\f            Case 6:26-cv-06874        Document 1          Filed 08/28/26   Page 56 of 65\n\n\n\n\nLegal Department, 1100 Pittsford Victor Road, Pittsford, NY 14534, which is also within this\n\nJudicial District.173\n\n          111.   On information and belief, Foundry employs personnel in this Judicial District and\n\nhas built its workforce here. Foundry has stated publicly that its expansion into Buffalo, New York\n\n(which is in Erie County and also within this Judicial District) \u201cwill replicate what the company\n\nhas built in Rochester \u2014 hiring talent from local universities, engaging with, and giving back to\n\nthe community.\u201d174\n\n          112.   On information and belief, Foundry directs, controls, and conducts from its New\n\nYork headquarters in this Judicial District the business activities accused of infringement in this\n\naction, including its ownership and operation of the Foundry USA Pool. Under the Foundry USA\n\nPool Service Agreement, \u201c[t]he ownership and operation rights of the services provided by the\n\nFoundry USA Pool (\u2018Pool\u2019) are owned by Foundry Digital LLC,\u201d and \u201c[a]s the operator of the\n\nPool, Foundry shall provide a mining Pool Service \u2026 to User.\u201d175\n\n          113.   On information and belief, Foundry has purposefully availed itself of the privilege\n\nof conducting business in the State of New York and of the protection of its laws, including by\n\nestablishing and maintaining its principal place of business in this District, by registering to do\n\nbusiness in New York, and by requiring that its Terms and Conditions \u201cbe governed by and\n\nconstrued and enforced in accordance with the laws of the State of New York.\u201d176\n\n\n173\n      https://foundrydigital.com/terms-and-conditions/.\n174\n  See https://www.prnewswire.com/news-releases/tech-entrepreneur-dan-magnuszewski-\nnamed-foundry-chief-technology-officer-company-to-open-buffalo-office-301567763.html.\n175\n   https://www.sec.gov/Archives/edgar/data/1083301/000110465923009266/tm234968d1_ex10-\n1.htm.\n176\n      See https://foundrydigital.com/terms-and-conditions/.\n\n\n\n\n                                                 56\n\f           Case 6:26-cv-06874        Document 1        Filed 08/28/26       Page 57 of 65\n\n\n\n\n       114.    Foundry has infringed the Asserted Patents within this District and the State of New\n\nYork by making, using, selling, offering for sale, and/or importing or by having made, used, sold,\n\noffered for sale, and/or imported in or into this District and elsewhere in the State of New York,\n\nproducts and services covered by claims in the Asserted Patents, including without limitation\n\nproducts that, when made or used, practice the claimed methods of the Asserted Patents. Foundry,\n\ndirectly and through intermediaries, has and continues to make, use, sell, offer for sale, import,\n\nship, distribute, advertise, promote, and/or otherwise commercialize such infringing products and\n\nservices in or into this District and the State of New York. Foundry regularly conducts and solicits\n\nbusiness in, engages in other persistent courses of conduct in, and/or derives substantial revenue\n\nfrom goods and services provided to residents of this District and the State of New York.\n\n       115.    This Court has personal jurisdiction over Foundry pursuant to N.Y. C.P.L.R. \u00a7\u00a7 301\n\nand 302.\n\n       116.    Venue is proper in this District under 28 U.S.C. \u00a7\u00a7 1391(b)-(c) and 1400(b).\n\n       117.    Foundry is doing business, either directly or through its agents, on an ongoing basis\n\nin this Judicial District and elsewhere in the United States, and has committed and continues to\n\ncommit acts of infringement in this District. Foundry resides in this District for purposes of 28\n\nU.S.C. \u00a7 1400(b) because it has a regular and established place of business in this Judicial District,\n\nnamely its corporate headquarters at 1100 Pittsford Victor Road, Pittsford, New York 14534, as\n\nalleged above, which is a physical place in this District, is regular and established, and is the place\n\nof Foundry. On information and belief, Foundry has and continues to make, use, sell, offer to sell,\n\nand/or import infringing products and services into and/or within this District, maintains a\n\npermanent and continuing presence within this District, and has the requisite minimum contacts\n\nwith this District such that this venue is a fair and reasonable one. Upon information and belief,\n\n\n\n\n                                                  57\n\f           Case 6:26-cv-06874        Document 1          Filed 08/28/26   Page 58 of 65\n\n\n\n\nFoundry has transacted and, at the time of the filing of this Complaint, is continuing to transact\n\nbusiness within this District.\n\n                                         FIRST CLAIM\n\n                                 (Infringement of the \u2019827 Patent)\n\n       118.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       119.    The \u2019827 Patent is generally directed to improved techniques for use in\n\ncryptographic algorithms, and, in particular, to methods and apparatuses for generating a public\n\nkey of the signer of a digital signature by computing Q=r-1 (sR-eG), where G comprises a generator\n\nof an elliptic curve group that includes a first elliptic curve point R and a second elliptic curve\n\npoint Q.\n\n       120.    Foundry has been on notice of the \u2019827 Patent and a specific factual basis for its\n\ninfringement of the \u2019827 Patent since at least March 28, 2025. On information and belief, Foundry\n\ndid not take any action to stop its infringement.\n\n       121.    Foundry has, under 35 U.S.C. \u00a7 271(a), directly infringed, literally and/or under the\n\ndoctrine of equivalents, one or more claims, including without limitation at least claim 1 of the\n\n\u2019827 Patent, by having made, used, tested, sold, offered for sale, and/or imported hardware and/or\n\nsoftware including devices and software that complied with the Bitcoin protocol (excluding any\n\nproducts licensed under the \u2019827 Patent), such as bitcoin mining equipment (including, for\n\nexample, hardware and software for digital asset mining, including mining rigs, application-\n\nspecific integrated circuits (ASICs), computers, nodes, miners, and software applications) and\n\nwallets (including hardware and software that functions as a bitcoin wallet). An exemplary claim\n\nchart showing one way in which Foundry infringed claim 1 of the \u2019827 Patent is attached as Exhibit\n\n6.\n\n\n\n\n                                                    58\n\f          Case 6:26-cv-06874         Document 1          Filed 08/28/26   Page 59 of 65\n\n\n\n\n       122.    Foundry\u2019s infringement has been willful in view of the above and its failure to take\n\nany action, even after being put on notice, to stop its infringement.\n\n                                        SECOND CLAIM\n\n                                (Infringement of the \u2019197 Patent)\n\n       123.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       124.    The \u2019197 Patent is generally directed to improved computational techniques for use\n\nin cryptographic algorithms, and, in particular, to methods and apparatuses for generating a digital\n\nsignature of a message, the digital signature having first and second signature components, where\n\nthe first is based on a first coordinate of an elliptic curve point representing an ephemeral public\n\nkey, and generating an indicator to identify which value of multiple values recoverable from the\n\nfirst signature component is the ephemeral public key.\n\n       125.    Foundry has been on notice of the \u2019197 Patent and a specific factual basis for its\n\ninfringement of the \u2019197 Patent since at least March 28, 2025. On information and belief, Foundry\n\ndid not take any action to stop its infringement.\n\n       126.    Foundry has, under 35 U.S.C. \u00a7 271(a), directly infringed, literally and/or under the\n\ndoctrine of equivalents, one or more claims, including without limitation at least claim 1 of the\n\n\u2019197 Patent, by having made, used, tested, sold, offered for sale, and/or imported hardware and/or\n\nsoftware including devices and software that complied with the Bitcoin protocol (excluding any\n\nproducts licensed under the \u2019197 Patent), such as bitcoin mining equipment (including, for\n\nexample, hardware and software for digital asset mining, including mining rigs, application-\n\nspecific integrated circuits (ASICs), computers, nodes, miners, and software applications) and\n\nwallets (including hardware and software that functions as a bitcoin wallet). An exemplary claim\n\n\n\n\n                                                    59\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 60 of 65\n\n\n\n\nchart concerning one way in which Foundry infringed claim 1 of the \u2019197 Patent is attached as\n\nExhibit 7.\n\n       127.    Foundry\u2019s infringement has been willful in view of the above and its failure to take\n\nany action, even after being put on notice, to stop its infringement.\n\n                                         THIRD CLAIM\n\n                                (Infringement of the \u2019062 Patent)\n\n       128.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       129.    The \u2019062 Patent is generally directed to finite field engines and methods for use\n\nwith cryptographic systems, and, in particular, techniques that enable the performance of finite\n\nfield operations on elements of a finite field that include, among other things, obtaining a first set\n\nof instructions for performing the finite field operation on values representing the elements of the\n\nfinite field and executing it to generate an unreduced result, obtaining a second set of instructions\n\nfor performing a modular reduction for a specific finite field and executing it to generate a reduced\n\nresult, and providing the reduced result as an output for use in a cryptographic operation.\n\n       130.    Foundry has been on notice of the \u2019062 Patent and a specific factual basis for its\n\ninfringement of the \u2019062 Patent since at least March 28, 2025.\n\n       131.    Foundry has, under 35 U.S.C. \u00a7 271(a), directly infringed, literally and/or under the\n\ndoctrine of equivalents, one or more claims, including without limitation at least claim 1 of the\n\n\u2019062 Patent, by having made, used, tested, sold, offered for sale, and/or imported hardware and/or\n\nsoftware including devices and software that complied with the Bitcoin protocol (excluding any\n\nproducts licensed under the \u2019062 Patent), such as bitcoin mining equipment (including, for\n\nexample, hardware and software for digital asset mining, including mining rigs, application-\n\nspecific integrated circuits (ASICs), computers, nodes, miners, and software applications) and\n\n\n\n\n                                                 60\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 61 of 65\n\n\n\n\nwallets (including hardware and software that functions as a bitcoin wallet). An exemplary claim\n\nchart showing one way in which Foundry infringed claim 1 of the \u2019062 Patent is attached as Exhibit\n\n8.\n\n                                        FOURTH CLAIM\n\n                                (Infringement of the \u2019286 Patent)\n\n       132.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       133.    The \u2019286 Patent is generally directed to systems and methods for reducing the\n\ncomputation and storage requirements for a Montgomery style reduction and, in particular, to\n\ntechniques for performing, on a cryptographic apparatus, a Montgomery-style reduction in a\n\ncryptographic operation that includes obtaining an operand for the cryptographic operation;\n\ncomputing a modified operand using a reduction value, instead of a modulus used in performing a\n\nstandard Montgomery reduction, to perform a replacement of a least significant word of the\n\noperand, rather than per form a cancellation thereof, where the reduction value is a function of the\n\nmodulus; and outputting the modified operand.\n\n       134.    Foundry has been on notice of the \u2019286 Patent since at least March 28, 2025, and a\n\nspecific factual basis for its infringement of the \u2019286 Patent since at least April 11, 2025. On\n\ninformation and belief, Foundry did not take any action to stop its infringement.\n\n       135.    Foundry has, under 35 U.S.C. \u00a7 271(a), directly infringed, and continues to directly\n\ninfringe, literally and/or under the doctrine of equivalents, one or more claims, including without\n\nlimitation at least claim 1 of the \u2019286 Patent, by making, using, testing, selling, offering for sale,\n\nand/or importing hardware and/or software including devices and software that comply with the\n\nBitcoin protocol (excluding any products licensed under the \u2019286 Patent), such as bitcoin mining\n\nequipment (including, for example, hardware and software for digital asset mining, including\n\n\n\n\n                                                 61\n\f          Case 6:26-cv-06874         Document 1        Filed 08/28/26      Page 62 of 65\n\n\n\n\nmining rigs, application-specific integrated circuits (ASICs), computers, nodes, miners, and\n\nsoftware applications) and wallets (including hardware and software that functions as a bitcoin\n\nwallet). An exemplary claim chart showing one way in which Foundry infringes claim 1 of the\n\n\u2019286 Patent is attached as Exhibit 9.\n\n       136.    Foundry\u2019s infringement has been willful in view of the above and its failure to take\n\nany action, even after being put on notice, to stop its infringement.\n\n                                          FIFTH CLAIM\n\n                                (Infringement of the \u2019039 Patent)\n\n       137.    Plaintiffs incorporate by reference the preceding paragraphs of this Complaint.\n\n       138.    The \u2019039 Patent is generally directed to systems and methods for efficient\n\nimplementations of hash algorithms on a computer processor, including techniques for utilizing a\n\nprocessor\u2019s registers to efficiently perform multiple iterations of SHA-2 family secure hash\n\nalgorithms and, in particular, to techniques for maximizing a number of registers at an end of an\n\niteration of a hash algorithm for use in a next iteration, where the method includes categorizing\n\nand unrolling iterations of an original secure hash algorithm into even iterations and odd iterations,\n\nreversing a sequence of computations in the even iterations to those in the odd iterations, said\n\nreversing resulting in an average number of words that need to be loaded into the registers per\n\niteration being reduced by at least one half compared to the original secure hash algorithm, and\n\ncombining an even iteration and an odd iteration to provide a new iteration of a loop.\n\n       139.    Foundry has been on notice of the \u2019039 Patent since at least March 28, 2025, and a\n\nspecific factual basis for its infringement of the \u2019039 Patent since at least the filing of this\n\nComplaint. On information and belief, Foundry did not take any action to stop its infringement.\n\n\n\n\n                                                 62\n\f          Case 6:26-cv-06874        Document 1        Filed 08/28/26     Page 63 of 65\n\n\n\n\n       140.    Foundry has, under 35 U.S.C. \u00a7 271(a), directly infringed, literally and/or under the\n\ndoctrine of equivalents, one or more claims, including without limitation at least claim 1 of the\n\n\u2019039 Patent, by having made, used, tested, sold, offered for sale, and/or imported hardware and/or\n\nsoftware including devices and software for mining bitcoin (excluding any products licensed under\n\nthe \u2019039 Patent), such as, for example, hardware and software for digital asset mining, including\n\nmining rigs, application-specific integrated circuits (ASICs), computers, miners, firmware, and\n\nsoftware applications. An exemplary claim chart showing one way in which Foundry directly\n\ninfringed claim 1 of the \u2019039 Patent is attached as Exhibit 10.\n\n       141.    Foundry has also indirectly infringed, and continues to indirectly infringe, the \u2019039\n\nPatent under 35 U.S.C. \u00a7 271(b) and (c).\n\n       142.    Foundry has knowingly, intentionally actively aided, abetted, and induced others,\n\nincluding members of the Foundry USA Pool, to directly infringe at least claim 1 of the \u2019039\n\nPatent, and continues to do so, by, for example, encouraging others to use bitcoin mining machines\n\nand compensating them for such use through pool \u201cpayouts.\u201d See Exhibit 10.\n\n       143.    Foundry has also contributed to the direct infringement of at least claim 1 of the\n\n\u2019039 Patent, and continues to do so, by, for example, supplying, with knowledge of the \u2019039 Patent,\n\na material part of a claimed invention, where the material part is not a staple article of commerce\n\nand is incapable of substantial noninfringing use. For example, Foundry has sold, repaired,\n\nprocured, financed, and/or deployed hardware and/or software including devices and software for\n\nmining bitcoin (excluding any products licensed under the \u2019039 Patent), such as, for example,\n\nhardware and software for digital asset mining, including mining rigs, application-specific\n\nintegrated circuits (ASICs), computers, miners, firmware, and software applications that are not a\n\nstaple article of commerce and are incapable of substantial noninfringing use. See Exhibit 10.\n\n\n\n\n                                                63\n\f              Case 6:26-cv-06874       Document 1       Filed 08/28/26      Page 64 of 65\n\n\n\n\n         144.     Foundry\u2019s infringement has been willful in view of the above and its failure to take\n\nany action, even after being put on notice, to stop its infringement.\n\n                                       PRAYER FOR RELIEF\n\nWHEREFORE, Plaintiffs pray for judgment against Defendant as follows:\n\n         A.       That Foundry has infringed each of the Asserted Patents and will continue to\n\ninfringe the \u2019286 Patent and \u2019039 Patent unless enjoined;\n\n         B.       That Foundry\u2019s infringement of the \u2019827 Patent, \u2019197 Patent, \u2019286 Patent, and \u2019039\n\nPatent has been willful;\n\n         C.       That Foundry pay Plaintiffs damages adequate to compensate for its past\n\ninfringement of each of the Asserted Patents as appropriate, and present and future infringement\n\nof the \u2019286 Patent and \u2019039 Patent as appropriate, together with interest and costs under 35 U.S.C.\n\n\u00a7 284;\n\n         D.       That Foundry pay prejudgment and post-judgment interest on the damages\n\nassessed;\n\n         E.       That Foundry pay Plaintiffs enhanced damages pursuant to 35 U.S.C. \u00a7 284;\n\n         F.       That Foundry be enjoined from infringing the \u2019286 Patent and \u2019039 Patent as\n\nappropriate or if its infringement is not enjoined, that it be ordered to pay ongoing royalties to\n\nPlaintiffs for any post-judgment infringement of the \u2019286 Patent and \u2019039 Patent as appropriate;\n\n         G.       That this is an exceptional case under 35 U.S.C. \u00a7 285; and that Foundry pay\n\nPlaintiffs\u2019 attorneys\u2019 fees and costs in this action; and\n\n         H.       That Plaintiffs be awarded such other and further relief, including equitable relief,\n\nas this Court deems just and proper.\n\n\n\n\n                                                   64\n\f          Case 6:26-cv-06874            Document 1    Filed 08/28/26      Page 65 of 65\n\n\n\n\n                                   DEMAND FOR JURY TRIAL\n\n        Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiffs hereby demand a trial by\n\njury on all issues triable to a jury.\n\n\n\nDated: August 28, 2026                       Respectfully submitted,\n\n\n\n                                             Terrance P. Flynn\n                                             Harris Beach Murtha Cullina PLLC\n                                             726 Exchange Street, Suite 900\n                                             Buffalo, NY 14210\n                                             Telephone: (716) 200-5050\n                                             Facsimile: (716) 200-5201\n                                             Email: tflynn@harrisbeachmurtha.com\n\n                                             Khue V. Hoang (Pro Hac Vice Forthcoming)\n                                             Reichman Jorgensen Lehman & Feldberg LLP\n                                             400 Madison Avenue, Suite 14D\n                                             New York, NY 10017\n                                             Tel: (212) 381-1965\n                                             khoang@reichmanjorgensen.com\n\n                                             Matthew G. Berkowitz (Pro Hac Vice Forthcoming)\n                                             Reichman Jorgensen Lehman & Feldberg LLP\n                                             100 Marine Parkway, Suite 300\n                                             Redwood Shores, CA 94065\n                                             Tel: (650) 623-1401\n                                             mberkowitz@reichmanjorgensen.com\n\n                                             Philip J. Eklem (Pro Hac Vice Forthcoming)\n                                             Reichman Jorgensen Lehman & Feldberg LLP\n                                             1909 K Street, NW, Suite 800\n                                             Washington, DC 20006\n                                             Tel: (202) 894-7310\n                                             peklem@reichmanjorgensen.com\n\n                                             Attorneys for Plaintiffs Malikie Innovations Ltd. and\n                                             Key Patent Innovations Ltd.\n\n\n\n\n                                                 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