https://docs.rpxcorp.com/lits/161/98801/casdce-446296.pdf?Signature=Z0%2FoNbY%2FzXX3AwSgclUDfotS7GY%3D&Expires=1408472781&AWSAccessKeyId=AKIAI2UWKALIEYBVOKDA

Apple’s decision to “jump the gun” and commence a preemptive action against Wi-LAN in the Northern District of California cannot override the principles of

judicial efficiency and economy. In re Vistaprint Ltd., 628 F.3d 1342, 1346 (Fed. Cir.

2010) (noting that “courts have consistently held that judicial economy plays a paramount role in trying to maintain an orderly, effective, administration of justice.”).

There is simply no justification for blessing the inefficiency Apple demands and condoning Apple’s forum shopping.

IV. CONCLUSION

For the foregoing reasons, Wi-LAN respectfully requests that the Court deny

Apple’s motion to dismiss.

Dated: August 18, 2014 Respectfully submitted,

MCKOOL SMITH, P.C.

PATTERSON LAW GROUP, APC