Jeffrey K. Joyner (Bar No. 180485)
E-mail: jjoyner@kmwlaw.com
Jai H. Rho (Bar No. 123248)
E-mail: jrho@kmwlaw.com
Samuel L. Alberstadt (Bar No. 186402)
E-mail: salberstadt@kmwlaw.com
KEATS McFARLAND & WILSON LLP
9720 Wilshire Boulevard
Beverly Hills, California 90212
Telephone: (310) 248-3830
Facsimile: (310) 860-0363

Attorneys for Plaintiff
U.S. PHILIPS CORPORATION

Nature of the Action

1. 1. This is a civil action for patent infringement arising under the laws of the
   United States relating to patents, including, but not limited to, 35 U.S.C. § 281.
2. 2. In addition, this action includes claims arising under other federal statutes,
   specifically claims for violation of the Racketeering Influenced and Corrupt
   Organizations Act, 18 U.S.C. § 1961 et seq. (“RICO”).

Subject Matter Jurisdiction

1. 3. This Court has subject matter jurisdiction over this action pursuant to 28
   U.S.C. §§ 1331 and 1338(a), because this civil action arises under the laws of the
   United States and under Acts of Congress relating to patents and RICO violations. To
   the extent any state claims may be asserted, the court also has supplemental
   jurisdiction under 28 U.S.C. § 1367.

Parties

1. 4. Plaintiff U.S. Philips Corporation (“Philips”) is a corporation organized
   and existing under the laws of Delaware, with a place of business at 3000 Minuteman
   Road, Andover, Massachusetts 01810.
2. 5. Defendant Shanghai Hongsheng Technology Co., Ltd. (“Shanghai
   Hongsheng”) is a business entity of unknown form, with an office and principal place
   of business at 13/F, Liangyou Mansion, No. 618, Shangcheng Road, Shanghai Pudong,
   China 200120.
3. 6. Defendant International Reliance Corporation (“IRC”) is registered as a
   California corporation and has a place of business at 1201 West Foothill Boulevard,
   Azusa, California 91702.
4. 7. Defendant Shanghai Hongpu Industry Investment Co. Ltd. (“Shanghai
   Hongpu”) is a business entity of unknown form, with an office and principal place of
   business at Room 1509, Liangyou Mansion, No. 618, Shangcheng Road, Shanghai
   Pudong, China 200120. Shanghai Hongsheng discloses that Shanghai Hongpu holds
   31.65% of the shares of Shanghai Hongsheng, so that Shanghai Hongpu is thus the

largest shareholder of Shanghai Hongsheng. Shanghai Hongsheng's second largest
shareholder holds 1.47% of the shares. Shanghai Hongpu is controlled by Jennifer
Long and Shu Zhi Ju, her mother.

1. 8. Upon information and belief, Defendant Hongpu International
   Development Co., Ltd. (“Hongpu International”) is a business entity of unknown form,
   with an office and principal place of business at 13/F, Liangyou Building No. 618,
   Shangcheng Road, Shanghai, China 200120. Hongpu International is a subsidiary of
   Shanghai Hongsheng.
2. 9. Defendant Anman Electronics Co. Ltd. (“Anman”) is a business entity of
   unknown form, with an office and principal place of business at Second Floor, Plant
   25, No. 30 Fute Dong San Road, Waigaoqiao Free Trade Zone, Shanghai, China.
   Anman is a subsidiary of Shanghai Hongsheng.
3. 10. Defendant Origon International Holdings Ltd. (“Origon”) is a business
   entity of unknown form, with an office and principal place of business at Room 1001,
   10/F, Far East Financial Centre, 16 Harcourt Road, Admiralty, Hong Kong. Upon
   information and belief, Origon is a supplier of at least Shanghai Hongsheng and IRC.
4. 11. Defendant IRCC Holding, Inc. (“IRCC”) is registered as a California
   corporation with an address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765.
5. 12. Defendant Xias Technology, Inc. (“Xias”) is registered as a California
   corporation with an address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765.
6. 13. Defendant IRC Electronics, Inc. (“IRCE”) is registered as a California
   corporation with an address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765.
7. 14. Defendant INT Trading, Inc. (“INTT”) is registered as a California
   corporation with an address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765.

1. 15. Defendant Shu Zhi Ju, also known as Shu Zhi Long (“Ju”), is an
   individual having a residence in Arcadia, California. Ju is: a director of Shanghai
   Hongsheng; a director and 50 percent owner of Norcent Holdings, Inc. (“NHI”), which
   owns 100 percent of International Norcent Technology (“INT”) and IRC; a director of
   IRCC, IRCE, and INTT; the Chief Executive Officer, Chief Financial Officer, and
   Secretary of IRCE and INTT; the former Chief Executive Officer, Chief Financial
   Officer, and Secretary of IRCC; and the mother of Kevin Long and Jennifer Long.
2. 16. Defendant Kevin Long, also known as Chang Sheng Long (“Kevin
   Long”), is an individual having a residence in Arcadia, California. Kevin Long is, or
   was during the relevant time period, a Director of Shanghai Hongsheng and Chairman
   of the Board of Directors. He is or was also the equivalent of a chief executive officer.
3. 17. Defendant Jennifer Long, also known as Chang Hong Long (“Jennifer
   Long”), is an individual having a residence in Arcadia, California. Jennifer Long is: a
   past director of Shanghai Hongsheng; the Chief Executive Officer and a director of
   INT, IRC, NHI; a 50 percent owner of NHI; and was President of IRCC. Ju, Jennifer
   Long, and Kevin Long either directly or indirectly, control Shanghai Hongsheng. Ju
   and Jennifer Long are the controlling persons of Shanghai Hongpu, the largest
   shareholder of Shanghai Hongsheng.
4. 18. Defendant Dennis Robinson (“Robinson”) is an individual having a
   regular place of business at 1201 West Foothill Boulevard, Azusa, California 91702.
   Robinson is Chief Financial Officer of NHI, INT, and IRC. Robinson is, or at least for
   a period of time was, President of Xias. Robinson is the incorporator of INTT and
   IRCE.
5. 19. As described in more detail below, Jennifer Long, INT and NHI were
   found liable for willful infringement in a judgment entered September 18, 2007. INT
   and NHI filed Chapter 11 bankruptcy petitions on October 11, 2007. INT and NHI are
   not named defendants in this Complaint. Nothing herein is intended to be, nor shall be
   construed as, a commencement or continuation of any action or proceeding against

INT, NHI or their respective Bankruptcy estates. Further, nothing herein is intended to
be, nor shall be construed as, an act with respect to the creation, perfection, or
enforcement against INT, NHI or their respective Bankruptcy estates of any judgment,
claim or lien, or an act to obtain possession of any property of INT, NHI or their
respective Bankruptcy estates.

1. 20. The true names and capacities, whether individual, corporate, or otherwise
   of the Defendants named herein as DOES 1 through 10 are unknown to Plaintiff, who,
   therefore, sues them by such fictitious names. Based on information and belief,
   Plaintiff alleges that each of DOES 1 through 10 was the agent, representative, or
   employee of each of the other Defendants and was acting at all times within the scope
   of his or her agency or representative capacity, with the knowledge and consent of each
   of the other Defendants, and that each of DOES 1 through 10 are liable to Plaintiff in
   connection with the claims sued upon here and are responsible in some manner for the
   wrongful acts and conduct alleged here, including, but not limited to violating RICO,
   and that each were doing substantial business in the State of California and within this
   District. At such time as their true names and capacities have been ascertained,
   Plaintiff will seek leave of the Court to amend this Complaint accordingly. The named
   defendants and DOES 1 through 10 are hereinafter collectively referred to
   “Defendants.”

//

//

//

//

//

//

//

//

//

1. 21 Defendants are part of a larger enterprise of individuals and companies,
   some of which are depicted on the following chart:¹

¹ Individual and entity names marked in bold-face, underline are named defendants in
this Complaint. The named defendants in this case are Shanghai Hongsheng, IRC,
Shanghai Hongpu, Hongpu International, Anman, IRCC, Xias, Origon, IRCE, INTT,
Ju, Kevin Long, Jennifer Long, and Robinson.

The relationships of the parties depicted in the preceding chart have been determined
from information publically available in the United States and the People's Republic of
China.

Personal Jurisdiction and Venue

1. 22. Shanghai Hongsheng, IRC, Hongpu International, and/or Kevin Long, or
   their alter ego, acting in concert, voluntarily placed patented, unlicensed, infringing
   digital versatile disc (also known as digital video disc) (“DVD”) products, including
   DVD players, that can suitably read information from a DVD disc into the stream of
   U.S. commerce, conscious that California and this judicial district were the likely
   destination of a substantial quantity of those unlicensed infringing DVD products.
2. 23. Venue for the claim of RICO violations is proper under 18 U.S.C. §1965
   because, among other things, Defendants Ju, Jennifer Long, Robinson and IRC reside
   in this judicial district, are found in this district, have agents in this district, and
   transact their affairs in this district.
3. 24. A substantial part of the events giving rise to this claim for patent
   infringement and RICO violations occurred in California and this judicial district.
4. 25. Shanghai Hongsheng is an alien for purposes of 28 U.S.C. § 1391(d).
5. 26. Shanghai Hongpu is an alien for purposes of 28 U.S.C. § 1391(d).
6. 27. Hongpu International is an alien for purposes of 28 U.S.C. § 1391(d).
7. 28. Anman is an alien for purposes of 28 U.S.C. § 1391(d).
8. 29. Origon is an alien for purposes of 28 U.S.C. § 1391(d).
9. 30. Kevin Long maintains or has maintained continuous and systematic
   contacts with California and this judicial district.
10. 31. Kevin Long resides in this judicial district for purposes of 28 U.S.C. §
    1400(b).
11. 32. Kevin Long has committed acts of infringement and has a regular and
    established place of business in this judicial district for purposes of 28 U.S.C. §
    1400(b).

1. 33. IRC, Shanghai Hongsheng, Hongpu International, and Kevin Long are
   subject to personal jurisdiction in this judicial district because they purposefully
   engaged in activities that gave rise to this claim for patent infringement and which
   were directed at residents of California and this judicial district.
2. 34. IRC, Shanghai Hongsheng, Shanghai Hongpu, Hongpu International,
   Anman, Origon, IRCC, Xias, and INTT reside in this judicial district for purposes of
   28 U.S.C. §§ 1391(c) and 1400(b) because they are subject to personal jurisdiction in
   this district.
3. 35. Venue for this civil action in this judicial district is proper under 28
   U.S.C. §§ 1391(b)(2), 1391(c), 1391(d), 1400(b), and 18 U.S.C. § 1965.

Factual Background

DEFENDANTS IRC, KEVIN LONG, SHANGHAI HONGSHENG, AND
HONGPU INTERNATIONAL ARE LIABLE FOR PATENT
INFRINGEMENT

1. 36. IRC, Shanghai Hongsheng, and Hongpu International are in the business
   of making, having made, offering for sale, selling, or importing DVD products,
   including DVD players, that can suitably read information from a DVD disc.
2. 37. IRC, Shanghai Hongsheng, and Hongpu International have made, offered
   for sale, sold, or imported DVD products, including DVD players, for sale or use in the
   United States. Therefore, these products infringe U.S. Patent No. 5,677,903 (“the '903
   patent”) and U.S. Patent No. 5,463,607 (“the '607 patent”).
3. 38. DVD products of IRC, Shanghai Hongsheng, and Hongpu International,
   including DVD players, have been made, used, offered for sale, sold, or imported
   within the United States without authority or license from Philips.
4. 39. Kevin Long has been involved in the control and active management of
   IRC, Shanghai Hongsheng, and Hongpu International.

1. 40. Kevin Long has been in active concert or participation with IRC,
   Shanghai Hongsheng, and Hongpu International in the manufacture, use, sale, offer for
   sale, and/or importation of unlicensed DVD products within the United States.
2. 41. IRC, Shanghai Hongsheng, Hongpu International, and/or Kevin Long
   have entered into agreements, arrangements, or understandings with each other for the
   manufacture or distribution of DVD products, including the distribution of unlicensed
   DVD products within the United States.
3. 42. In May 2002, Philips entered into a DVD license agreement (“License
   Agreement”) with Shanghai Hongsheng and Shanghai Hongsheng listed INT as its
   associated entity. The License Agreement was terminated in January 2003 for
   nonpayment of royalties.
4. 43. On March 3, 2006, Philips filed a patent infringement action against INT,
   NHI, and Jennifer Long ( U.S. Philips v. International Norcent Technology, Inc. et al.
   , Case No. 06-cv-01366-R-PLA, Central District of California (D.I. 1)). On September
   5, 2007, a jury found that INT, NHI, and Jennifer Long willfully infringed the '903 and
   '607 patents. (D.I. 308.) The Court entered final judgment in the amount of
   $12,853,793 on September 18, 2007 (“Judgment,” D.I. 328). The Court granted
   Philips' post-trial motions seeking enhanced damages, attorneys' fees, and pre- and
   post-judgment interest and an accounting.

DEFENDANTS IRC, SHANGHAI HONGSHENG, HONGPU
INTERNATIONAL, ANMAN, IRCC, KEVIN LONG AND JENNIFER
LONG ARE ALTER EGOS

1. 44. IRC, Shanghai Hongsheng, Anman, and Hongpu International are, and at
   all times herein mentioned were, the alter ego of Kevin Long. INT and NHI are, and at
   all times herein mentioned were, the alter ego of Kevin Long, Jennifer Long, and IRC.
   Jennifer Long is, and at all times herein mentioned was, the alter ego of IRC. Upon
   information and belief, Plaintiff alleges that there exists, and at all times herein

mentioned has existed, a unity of interest and ownership between such entities and
individual such that any separateness has ceased to exist.

1. 45. Kevin Long conducts his enterprise of patent infringement under the guise
   of numerous corporations and/or fictitious business names including, but not limited to,
   IRC, Shanghai Hongsheng, Anman, Hongpu International, INT, NHI, and IRCC
   ("Norcent Related Companies"). Ju, Kevin Long, and/or Jennifer Long are the only
   officers and/or directors of several Norcent Related Companies, and personally
   authorize, direct and control the operations conducted under each corporate name.
2. 46. The Norcent Related Companies are, and at all times herein mentioned
   were, controlled, dominated, and operated by Defendants Kevin Long and Jennifer
   Long.
3. 47. Upon information and belief, the activities and business of the Norcent
   Related Companies were carried out without the appropriate corporate formalities
   including without limitation the appointment of a non-employee of a corporation as an
   authorized signer to the corporation's bank accounts; and that Kevin Long entered into
   personal transactions with the Norcent Related Companies without the approval of
   other directors or shareholders.
4. 48. Upon information and belief, the Norcent Related Companies were, and at
   all times herein mentioned were, mere shells, instrumentalities and conduits through
   which Kevin Long conducted his own personal business, both individually and through
   said entities.
5. 49. Upon information and belief, Kevin Long and Jennifer Long direct,
   control, authorize and are completely involved in the infringing businesses of
   numerous legal (and fictitious) entities in every way on a regular basis.
6. 50. Kevin Long, Jennifer Long, and IRC are alter egos of INT and NHI, and
   are jointly liable for the infringing acts of INT and NHI as alleged in Paragraphs 42-43.
   Upon information and belief, Kevin Long, Jennifer Long, INT, NHI, and IRC, in
   concert with Shanghai Hongsheng and its subsidiaries and related companies, entered

into agreements, formal or informal, to manipulate the assets and liabilities of INT,
NHI, IRC, and Shanghai Hongsheng and its subsidiaries and related companies. Upon
information and belief, Kevin Long has been detained in China for his participation in
and inducement of these agreements. Upon information and belief, additional
information will be made available through discovery in this action and in the
bankruptcy proceeding involving NHI and INT that further supports Philips' alter ego
allegations.

THE RICO ENTERPRISE'S ONGOING SCHEME TO DEFRAUD
PHILIPS
The RICO Enterprise

1. 51. In or about 2002, INT, NHI, and Jennifer Long started importing and
   selling DVD products, including DVD players, that infringe the '903 patent and the
   '607 patent, both of which are owned by Philips.
2. 52. Upon information and belief, in order to avoid paying royalty, and
   potential or actual damages to Philips, Shanghai Hongsheng, IRC, Hongpu
   International, Origon, INT, NHI, Kevin Long and Jennifer Long have been shifting
   importation of products from INT to IRC. This activity started as early as on or about
   2004 or 2005 so that if INT were to be sued by Philips, INT would have essentially no
   assets and thereby preventing Philips from collecting damages awarded by the
   Judgment, which proximately caused injury to Philips.
3. 53. One or more Defendants has falsified and concealed relevant documents
   and records and engaged in, among other things, mail and/or wire fraud as defined by
   18 U.S.C. §§ 1341, 1343. Upon information and belief, this activity constituted an
   effort to prevent Philips from collecting damages awarded by the Judgment.
4. 54. Each of Defendants, namely Shanghai Hongsheng, IRC, Shanghai
   Hongpu, Hongpu International, Anman, IRCC, Xias, Origon, IRCE, INTT, Ju, Kevin
   Long, Jennifer Long, and Robinson, act in concert as an association-in-fact enterprise
   (the "RICO Enterprise"). Upon information and belief, the RICO Enterprise has

continued to defraud Philips since as early as 2004 by preventing Philips from
collecting damages awarded by the Judgment through, inter alia, depleting,
encumbering, or concealing assets, through fraudulently transferring and/or concealing
business and assets, which proximately caused injury to Philips.

1. 55. The extent of Defendants' scheme to defraud Philips has been revealed to
   date in, inter alia, Shanghai Hongsheng's publicly filed notices and reports and INT's
   and NHI's publicly filed bankruptcy records.
2. 56. Both INT and IRC are under the direction and control of Ju, Kevin Long,
   and Jennifer Long.
3. 57. Upon information and belief, INT has been making systematic and
   continuous asset transfers to IRC by either: (1) U.S. Mail or other private or
   commercial interstate carrier; or by (2) wire transfer in interstate or foreign commerce.

Shifting Importation to Another Entity

1. 58. INT has disclosed that it shifted importation of products from itself to IRC
   because of IRC's stronger purchasing power. Yet, INT disclosed that it had made a
   substantial amount of cash transfers to IRC to facilitate IRC purchasing products
   through a series of wire transfers. Upon information and belief, the "cash transfers"
   were contrived transactions to encumber or deplete INT's assets, thereby advancing
   Defendants' scheme of preventing Philips from collecting damages awarded by the
   Judgment; deriving income by IRC's receipt of the cash transfers; and using, investing,
   directly or indirectly, all or part of the income or proceeds thereof to establish and
   operate the RICO Enterprise to further facilitate the scheme to defraud Philips, all of
   which acts proximately caused injury to Philips.

The $13.7 Million Transfer

1. 59. On August 31, 2007, only a few days prior to the jury verdict that became
   the Judgment, transfers in the amounts of $2,784,000, $2,224,000, 1,334,000,
   $2,784,000, $2,287,000, and $2,287,000, approximately $13.7 million in total ($13.7

Million Transfer), were redirected, at the direction of INT which is under the control of
Jennifer Long, from INT's customers to Hongpu International.

1. 60. Upon information and belief, the $13.7 Million Transfer was redirected to
   Hongpu International to benefit Kevin Long, Jennifer Long, and Ju who directly or
   indirectly control Hongpu International.
2. 61. Upon information and belief, the $13.7 Million Transfer was initiated by
   INT for the purpose of avoiding the disclosure of that transfer in NHI, INT, and IRC's
   bank accounts and preventing Philips' discovery of that transfer in the enforcement of
   the Judgment.
3. 62. Upon information and belief, INT, under the control of Jennifer Long,
   redirected the $13.7 Million Transfer to an entity in China so that the assets would no
   longer be located in this United States to prevent attachment of those funds in the
   United States.
4. 63. Upon information and belief, the $13.7 Million Transfer was made for the
   purpose of dissipating INT's assets, thereby advancing Defendants' scheme of
   preventing Philips from collecting damages awarded by the Judgment; deriving income
   by Hongpu International's receipt of the $13.7 Million Transfer; and using, investing,
   directly or indirectly, all or part of the income or proceeds thereof to establish and
   operate the RICO Enterprise to further facilitate the scheme to defraud Philips, all of
   which acts proximately caused injury to Philips.

Tri-Lateral Agreements

1. 64. INT, Hongpu International, Anman, and Origon entered into a series of
   agreements ("Tri-Lateral Agreements") from April through June 2007, including
   Agreement Numbers 2007AM001, 002, 003, 004, 005, 2007HP001, 002, 003, 004,
   005, 006, 007, and 008 as disclosed in Shanghai Hongsheng's public notice files with
   the Shanghai Stock Exchange ("SSE") on November 28, 2007, No. 2007-016 ("2007-
   016 Notice").

1. 65. The 2007-016 Notice incorrectly claims INT, Origon, and Shanghai
   Hongsheng do not have any affiliation. As alleged in Paragraphs 5-21, 44-50, INT and
   Shanghai Hongsheng are commonly owned and/or controlled. Upon information and
   belief, Origon is or was controlled or owned by Kevin Long and/or Jennifer Long.
   Upon information and belief, INT, Origon, and Shanghai Hongsheng intentionally
   withheld information regarding their affiliation from the Tri-Lateral Agreements.
2. 66. The Tri-Lateral Agreements provide that, among other things, INT
   assumes debts owed by Hongpu International and Anman to Origon. The Tri-Lateral
   Agreements caused INT to owe Origon US$255,740,100, and owe Hongpu
   International and Anman US$14,403,620.
3. 67. INT's historical sales revenue, as disclosed in the bankruptcy proceedings
   resulting from the October 11, 2007 petitions of INT and NHI, does not support the
   amount of outstanding debt owed by INT.
4. 68. INT claimed in its Disclosure Statement filed with the United States
   Bankruptcy Court that it does not owe US$255,740,100 to Origon despite the
   information disclosed in the 2007-016 Notice.
5. 69. Upon information and belief, the Tri-Lateral Agreements were
   instruments designed to heavily encumber or deplete INT's assets, thereby advancing
   Defendants' scheme of preventing Philips from collecting damages awarded by the
   Judgment; deriving income by INT's assumption of the debt and Shanghai Hongsheng,
   Hongpu International, Anman, and Origon's receipt of all or part of the benefits from
   the Tri-Lateral Agreements; and using, investing, directly or indirectly, all or part of
   the income or proceeds thereof to establish and operate the RICO Enterprise to further
   facilitate the scheme to defraud Philips, all of which acts proximately caused injury to
   Philips.
6. 70. Upon information and belief, Shanghai Hongsheng, Hongpu International,
   Anman, INT, and Origon conspired and agreed with each other to prevent Philips from

collecting damages awarded by the Judgment through, inter alia, the Tri-Lateral
Agreements.

CECIC Agreements

1. 71. IRC, IRCE, Hongpu International, Anman, Shanghai Hongpu and China
   Export Credit Insurance Company ("CECIC") entered into agreements ("CECIC
   Agreements") that were disclosed in Shanghai Hongsheng's public notice filed with
   the SSE on January 3, 2008, No. 2008-002 ("2008-002 Notice").
2. 72. As alleged in Paragraphs 5-21, 44-50, IRC, IRCE, Hongpu International,
   Anman, and Shanghai Hongpu are commonly owned and/or controlled.
3. 73. The CECIC Agreements provide, among other things, that Shanghai
   Hongpu unconditionally assumes debt owed to CECIC by Hongpu International and
   Anman in the amount of US$101,387,475.86.
4. 74. The CECIC Agreements required Hongpu International and Anman to
   assign their account receivables against IRC and IRCE to Shanghai Hongpu.
5. 75. Upon information and belief, INT has been making continuous and
   systematic money transfers to IRC, including but not limited to those disclosed in the
   bankruptcy proceeding resulting from the chapter 11 petitions filed October 11, 2008
   by INT and NHI.
6. 76. Publicly available news reports from China have disclosed that Chinese
   authorities are investigating CECIC officers in relation to the CECIC Agreements.
7. 77. Upon information and belief, the CECIC Agreements and the 2007-016
   Notice are instruments designed to heavily encumber or deplete IRC's, INT's and
   IRCE's assets, thereby advancing Defendants' scheme of preventing Philips from
   collecting damages awarded by the Judgment; deriving income by Shanghai Hongpu's
   assumption of debt and Hongpu International and Anman's assignment of account
   receivables; and using, investing, directly or indirectly, all or part of the income or
   proceeds thereof to establish and operate the RICO Enterprise to further facilitate the
   scheme to defraud Philips, all of which acts proximately caused injury to Philips.

1. 78. Upon information and belief, Shanghai Hongsheng, Shanghai Hongpu,
   Jennifer Long and Ju (as the controlling persons of Shanghai Hongpu), Hongpu
   International, Anman, IRC, and IRCE conspired and agreed with each other to prevent
   Philips from collecting damages awarded by the Judgment through, inter alia, the
   CECIC Agreements.

Anman/Hongpu Transfer Agreements

1. 79. Shanghai Hongsheng, Hongpu International, Anman, Shanghai Hongpu,
   INT, and Origon entered into agreements ("Anman/Hongpu Transfer Agreements")
   that were disclosed in Shanghai Hongsheng's public notice filed with the SSE on
   January 3, 2008, No. 2008-003 ("2008-003 Notice").
2. 80. As alleged in Paragraphs 5-21 and 44-50, Shanghai Hongsheng, Hongpu
   International, Anman, Shanghai Hongpu, and INT are commonly owned and/or
   controlled. Upon information and belief, Origon is or was controlled or owned by
   Kevin Long and/or Jennifer Long.
3. 81. The Anman/Hongpu Transfer Agreements provide, among other things,
   that Anman transferred to Shanghai Hongpu its credit of US$88,746,995 against INT
   and debt of the same amount owed to Origon.
4. 82. The Anman/Hongpu Transfer Agreements provide, among other things,
   that Hongpu International transferred to Shanghai Hongpu its credit of US$56,530,870
   against INT and debt of the same amount owed to Origon.
5. 83. INT claimed in its Disclosure Statement filed with the United States
   Bankruptcy Court that it has no knowledge of the agreements disclosed in the 2008-
   003 Notice despite such public disclosure.
6. 84. Upon information and belief, the 2007-016 Notice and the agreements
   disclosed therein are instruments designed to heavily encumber or deplete INT's
   assets, thereby advancing Defendants' scheme of preventing Philips from collecting
   damages awarded by the Judgment; deriving income by Shanghai Hongpu's receipt of
   a credit and assumption of debt; and using, investing, directly or indirectly, all or part

of the income or proceeds thereof to establish and operate the RICO Enterprise to
further facilitate the scheme to defraud Philips, all of which acts proximately caused
injury to Philips.

1. 85. Upon information and belief, Shanghai Hongsheng, Shanghai Hongpu,
   Jennifer Long and Ju (as the controlling persons of Shanghai Hongpu), Hongpu
   International, Anman, IRC, and IRCE conspired and agreed with each other to prevent
   Philips from collecting damages awarded by the Judgment through, inter alia, the
   Anman/Hongpu Transfer Agreements.

Sale of 10,452,006 Shares of Shanghai Hongsheng

1. 86. Ju, Jennifer Long and Shanghai Hongpu sold 10,452,006 shares of
   Shanghai Hongsheng stock from on or about February 13 to 14, 2008. This sale of
   10,452,006 shares of Shanghai Hongsheng stock is disclosed in Shanghai Hongsheng's
   public notice filed with the SSE on February 16, 2008, No. 2008-005.
2. 87. According to publicly available information, the sale of 10,452,006 shares
   was valued at approximately US$18 million.
3. 88. Upon information and belief, the sale of 10,452,006 shares of Shanghai
   Hongsheng stock was designed to liquidate Ju's, Jennifer Long's and Shanghai
   Hongpu's assets, thereby advancing Defendants' scheme of preventing Philips from
   collecting damages awarded by the Judgment; deriving income by Shanghai Hongpu's
   sale of shares; and using, investing, directly or indirectly, all or part of the income or
   proceeds thereof to establish and operate the RICO Enterprise to further facilitate the
   scheme to defraud Philips, all of which acts proximately caused injury to Philips.
4. 89. Upon information and belief, Shanghai Hongpu, Jennifer Long, and Ju
   conspired and agreed with each other to prevent Philips from collecting damages
   awarded by the Judgment through, inter alia, the Sale of 10,452.006 shares of
   Shanghai Hongsheng.

Criminal Fraud Charges in China

1. 90. Upon information and belief, Kevin Long is incarcerated in China on
   fraud charges relating to events as alleged in Paragraphs 64-89.
2. 91. According to public notices filed with the SSE by Shanghai Hongsheng,
   Shanghai Hongsheng and Shanghai Hongpu are currently under investigation by China
   authorities for violation of securities laws. Upon information and belief, such
   investigation is related to events as alleged in Paragraphs 64-89.

Continuous and Systematic Money Transfers

1. 92. INT discloses in its Disclosure Statement filed with the United States
   Bankruptcy Court that IRCC is in the business of accepting money for customers of
   Hongpu International and Shanghai Hongsheng. Upon information and belief, IRC
   and INT have been making continuous and systematic money transfers to IRCC.
2. 93. Shanghai Hongsheng discloses in its 2007 Annual Report that IRCC is
   one of its top debtors, along with IRC, IRCE, and INT.
3. 94. INT discloses in its Disclosure Statement filed with the United States
   Bankruptcy Court that INT and IRC have transferred over US$80 million to IRCC in
   2007.
4. 95. IRCC's address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765 is only a commercial postal box.
5. 96. Upon information and belief, transfers made from INT and IRC to IRCC
   are for the purpose of advancing Defendants' scheme of by preventing Philips from
   collecting damages awarded by the Judgment, which proximately caused injury to
   Philips.
6. 97. Upon information and belief, IRC and INT have been making continuous
   and systematic money transfers to Hongpu International and Anman in advancement of
   Defendants' scheme of preventing Philips from collecting damages awarded by the
   Judgment, which proximately caused injury to Philips.

1. 98. Upon information and belief, income was derived from the money
   transfers as alleged in Paragraphs 92-97 and used, invested, directly or indirectly, all or
   part of the income or proceeds thereof to establish and operate the RICO Enterprise to
   further facilitate the scheme to defraud Philips, all of which acts proximately caused
   injury to Philips.
2. 99. Upon information and belief, Shanghai Hongsheng, Shanghai Hongpu,
   Jennifer Long and Ju (as the controlling persons of Shanghai Hongpu), Anman, INT,
   IRC, and IRCC conspired and agreed with each other to prevent Philips from
   collecting damages awarded by the Judgment through, inter alia, continuous and
   systematic money transfers.

Diverting Business to Xias, INTT and IRCE

1. 100. Upon information and belief, Ju, an INT insider, established Xias with
   INT's and IRC's resources and has been diverting business from NHI, INT and IRC to
   Xias.
2. 101. Xias' address at 324 S. Diamond Bar Boulevard, #628, Diamond Bar,
   California 91765 is only a commercial postal box. As indicated by publicly available
   documents, Ju and Xias are conducting business with NHI's, INT's, and IRC's
   employees, facilities, and resources.
3. 102. Upon information and belief, Ju and Xias are promoting Xias with NHI's,
   INT's, and IRC's customers.
4. 103. Upon information and belief, Ju and Xias are co-opting NHI's, INT's, and
   IRC's reputations and good will, thereby advancing Defendants' scheme of preventing
   Philips from collecting damages awarded by the Judgment; deriving income by Xias'
   receipt of diverted assets; and using, investing, directly or indirectly, all or part of the
   income or proceeds thereof to establish and operate the RICO Enterprise to further
   facilitate the scheme to defraud Philips, all of which acts proximately caused injury to
   Philips.

1. 104. Upon information and belief, Ju, an INT insider, is the former Chief
   Executive Officer, Chief Financial Officer, Secretary, and sole Director of both INTT
   and IRCE who receive continuous shipments containing Norcent products at INT's and
   IRC's facilities.
2. 105. INTT's and IRCE's address at 324 S. Diamond Bar Boulevard, #628,
   Diamond Bar, California 91765 is only a commercial postal box.
3. 106. Upon information and belief, Ju, INTT and IRCE are utilizing INT's and
   IRC's resources for the purpose of receiving Norcent products.
4. 107. Upon information and belief, Ju, INTT and IRCE have been diverting
   business from NHI, INT and IRC to INTT and IRCE, thereby co-opting NHI's, INT's
   and IRC's assets, reputations and good will, in advancement of Defendants' scheme of
   preventing Philips from collecting damages awarded by the Judgment; deriving income
   by INTT and IRCE's receipt of diverted assets; and using, investing, directly or
   indirectly, all or part of the income or proceeds thereof to establish and operate the
   RICO Enterprise to further facilitate the scheme to defraud Philips, all of which acts
   proximately caused injury to Philips.

Incorporation of Entities to Make Certain Defendants Judgment Proof

1. 108. Upon information and belief, Robinson, Chief Financial Officer and
   Director of INT, NHI, and IRC, knows or should have known documents or records of
   INT, NHI, and IRC are or may be false and recklessly disregards such falsity.
2. 109. Upon information and belief, Robinson, as CFO and Director of INT,
   NHI, and IRC, maintains or caused to be maintained documents or records of NHI,
   INT and IRC.
3. 110. Robinson has produced untrue information, records and documents to
   Philips, including without limitation providing a declaration in support of INT's
   Disclosure Statement where INT refuses to acknowledge any corporate information of
   INTT and IRCE, yet Robinson is the incorporator of INTT and IRCE.

1. 111. Upon information and belief, Robinson assisted Ju in incorporating INTT
   and IRCE for the purpose of diverting business away from INT and IRC to INTT and
   IRCE.
2. 112. Upon information and belief, Robinson served as President of Xias for the
   purpose of using INT resources to conduct Xias' business.
3. 113. Robinson has entered into agreements on behalf of Xias with INT without
   adequate consideration, including without limitation the tradename agreement between
   INT and Xias.
4. 114. Upon information and belief, Robinson has assisted one or more
   Defendants in concealing and/or transferring property and assets, and/or diverting
   business good will, thereby advancing Defendants' scheme of preventing Philips from
   collecting damages awarded by the Judgment; deriving income by Xias', INTT's and
   IRCE's receipt of diverted assets; and using, investing, directly or indirectly, all or part
   of the income or proceeds thereof to establish and operate the RICO Enterprise to
   further facilitate the scheme to defraud Philips, all of which acts proximately caused
   injury to Philips.
5. 115. Upon information and belief, Robinson aids, abets, and advances
   Defendants' scheme to prevent Philips from collecting damages awarded by the
   Judgment.

FIRST COUNT
(Patent Infringement)
[Applicable to Defendants IRC, Shanghai Hongsheng,
Hongpu International and Kevin Long]

1. 116. The '903 patent issued on October 14, 1997, to Antonius H. M. Holtslag,
   Derk Visser, Peter Coops, and Jacobus P. J. Heemskerk. A copy of the '903 patent,
   entitled "Multi-Layer Information Storage System with Improved Aberration
   Correction," is attached hereto as Exhibit A.
2. 117. Philips is the owner by assignment of the '903 patent

1. 118. Shanghai Hongsheng had knowledge of the '903 patent before the filing
   of this suit. Upon information and belief, IRC, Hongpu International, and/or Kevin
   Long had knowledge of the '903 patent before the filing of this suit
2. 119. Shanghai Hongsheng had notice of infringement of the '903 patent before
   the filing of this suit. Upon information and belief, IRC, Hongpu International, and/or
   Kevin Long had notice of infringement of the '903 patent before the filing of this suit.
3. 120. Upon information and belief, IRC, Shanghai Hongsheng, Hongpu
   International, and/or Kevin Long (collectively "the Patent Defendants") have directly
   infringed, induced infringement of, and/or contributed to infringement of one or more
   claims of the '903 patent, both literally and under the doctrine of equivalents, by
   making, using, offering for sale, selling, and/or importing unlicensed DVD products
   within the United States, including DVD products, such as DVD players, that can
   suitably read information from a DVD disc.
4. 121. Upon information and belief, IRC, Shanghai Hongsheng, Hongpu
   International, and/or Kevin Long have directly infringed, induced infringement of,
   and/or contributed to infringement of one or more claims of the '903 patent, both
   literally and under the doctrine of equivalents, by selling, offering for sale, and/or
   importing unlicensed DVD products within the United States, including DVD players,
   through International Norcent Technology ("INT") and IRC.
5. 122. On September 5, 2007, a jury found that INT, NHI, and Jennifer Long
   willfully infringed the '903 patent. (U.S. Philips v. International Norcent Technology
   Inc et al., Case No. 06-cv-01366-R-PLA, Central District of California (D.I. 308).)
   The Court entered final judgment of $12,853,793 on September 18, 2007. (D.I. 328.)
   The Court granted Philips' post-trial motions seeking enhanced damages, attorneys'
   fees, and pre- and post-judgment interest and an accounting.
6. 123. Upon information and belief, Kevin Long personally, actively, and
   knowingly assisted with the infringement of the '903 patent by INT, NHI, Jennifer
   Long, IRC, Shanghai Hongsheng, and/or Hongpu International by inducing and

directing others to engage in acts of infringement and by aiding, abetting, participating
in, approving, and ratifying the infringement of the '903 patent by INT, NHI, Jennifer
Long, IRC, Shanghai Hongsheng, and/or Hongpu International.

1. 124. Upon information and belief, Kevin Long, INT, NHI, and IRC
   disregarded the corporate formality of each other, including, among other things,
   comingling of assets, sharing the same employees, officers, facilities, ownerships,
   customers, and suppliers; and held themselves out as one and the same entity. Upon
   information and belief, the business purpose or function of Kevin Long, INT, NHI, and
   IRC was not separate and distinct from each other. Kevin Long, INT, NHI, and/or IRC
   were not operated as entities separate and apart from each other. Upon information
   and belief, Kevin Long and IRC are alter egos of INT and NHI, and are jointly liable
   for the infringing act of INT and NHI as identified in Paragraph 50. Publicly available
   information also demonstrates that Kevin Long, INT, NHI, and IRC, in concert with
   Shanghai Hongsheng and its subsidiaries and related companies, entered into contracts
   to manipulate the assets and liabilities of INT, NHI, IRC, and Shanghai Hongsheng
   and its subsidiaries and related companies. Upon information and belief, Kevin Long
   has been incarcerated in China for his participation in and inducement of these
   contracts. Upon information and belief, additional information is available from the
   bankruptcy proceeding involving NHI and INT that further supports Philips' alter ego
   allegations.
2. 125. Upon information and belief, the infringement by IRC, Shanghai
   Hongsheng, Hongpu International, and/or Kevin Long, has been deliberate and willful.
3. 126. Upon information and belief, infringement of the '903 patent is ongoing
   and will continue unless the Defendants are enjoined from further infringement by the
   Court.

SECOND COUNT
(Patent Infringement)
[Applicable to Defendants IRC, Shanghai Hongsheng,
Hongpu International and Kevin Long]

1. 127. The '607 patent issued on October 31, 1995, to Rudolf Roth and Johannes
   C. Van Offenbeek. A copy of the '607 patent, entitled "System for Recording and
   Reading Information on a Record Carrier at a Constant Scanning Speed Independent of
   the Bit Rate of Such Information," is attached hereto as Exhibit B.
2. 128. Philips is the owner by assignment of the '607 patent.
3. 129. Shanghai Hongsheng had knowledge of the '607 patent before the filing
   of this suit. Upon information and belief, IRC, Hongpu International, and/or Kevin
   Long had knowledge of the '607 patent before the filing of this suit.
4. 130. Shanghai Hongsheng had notice of infringement of the '607 patent before
   the filing of this suit. Upon information and belief, IRC, Hongpu International, and/or
   Kevin Long had notice of infringement of the '607 patent before the filing of this suit.
5. 131. Upon information and belief, IRC, Shanghai Hongsheng, Hongpu
   International, and/or Kevin Long have directly infringed, induced infringement of,
   and/or contributed to infringement of one or more claims of the '607 patent, both
   literally and under the doctrine of equivalents, by making, using, offering for sale,
   selling, and/or importing unlicensed DVD products within the United States, including
   DVD products, such as DVD players, that can suitably read information from a DVD
   disc.
6. 132. Upon information and belief, IRC, Shanghai Hongsheng, Hongpu
   International, and Kevin Long have directly infringed, induced infringement of, and/or
   contributed to infringement of one or more claims of the '607 patent, both literally and
   under the doctrine of equivalents, by selling, offering for sale, and/or importing
   unlicensed DVD products within the United States, including DVD players, through
   INT and IRC.

1. 133. On September 5, 2007, a jury found that INT, NHI, and Jennifer Long
   willfully infringed the ' 607 patent. (U.S. Philips v. International Norcent Technology
   Inc., Case No. 06-cv-01366-R-PLA, Central District of California (D.I. 308).) The
   Court entered final judgment of $12,853,793 on September 18, 2007. (D.I. 328.) The
   Court granted Philips' post-trial motions seeking enhanced damages, attorneys' fees,
   and pre- and post-judgment interest and an accounting.
2. 134. Upon information and belief, Kevin Long personally, actively, and
   knowingly assisted with the infringement of the 骷 patent by INT, NHI, Jennifer
   Long, IRC, Shanghai Hongsheng, and Hongpu International by inducing and directing
   others to engage in acts of infringement and by aiding, abetting, participating in,
   approving, and ratifying the infringement of the 骷 patent by INT, NHI, Jennifer
   Long, IRC, Shanghai Hongsheng, and Hongpu International
3. 135. Upon information and belief, Kevin Long, INT, NHI, and IRC
   disregarded the corporate formality of each other, including, among other things,
   comingling of assets, sharing the same employees, officers, facilities, ownerships,
   customers, and suppliers; and held themselves out as one and the same entity. Upon
   information and belief, the business purpose or function of Kevin Long, INT, NHI, and
   IRC was not separate and distinct from each other. Upon information and belief,
   Kevin Long, INT, NHI, and/or IRC were not operated as entities separate and apart
   from each other. Kevin Long and IRC are alter egos of INT and NHI, and are jointly
   liable for the infringing act of INT and NHI as identified in Paragraph 50. Publicly
   available information also demonstrates that Kevin Long, INT, NHI, and IRC, in
   concert with Shanghai Hongsheng and its subsidiaries and related companies, entered
   into contracts to manipulate the assets and liabilities of INT, NHI, IRC, and Shanghai
   Hongsheng and its subsidiaries and related companies. Upon information and belief,
   Kevin Long has been incarcerated in China for his participation in and inducement of
   these contracts. Upon information and belief, additional information is available from

the bankruptcy proceeding involving NHI and INT that further supports Philips' alter
ego allegations.

1. 136. Upon information and belief, the infringement by IRC, Shanghai
   Hongsheng, Hongpu International, and Kevin Long has been deliberate and willful.
2. 137. Upon information and belief, infringement of the '607 patent is ongoing
   and will continue unless the Defendants are enjoined from further infringement by the
   Court.

THIRD COUNT
(RICO Violations of 18 U.S.C. § 1962(a))
[Applicable to Shanghai Hongsheng, IRC, Hongpu International, Anman, Origon,
IRCE, INTT, Xias, Kevin Long, Jennifer Long, Ju, and Robinson]

1. 138. Philips realleges Paragraphs 1-115 as if fully set forth herein.
2. 139. As natural persons capable of holding a legal or beneficial interest in
   property, Kevin Long, Jennifer Long, Ju, and Robinson are "persons" for purposes of
   18 U.S.C. §1961(3).
3. 140. As a corporation or other legal entity, Shanghai Hongsheng, IRC, Hongpu
   International, Anman, Xias, Origon, IRCE, and INTT are "enterprises" for purposes of
   18 U.S.C. §1961(4).
4. 141. Shanghai Hongsheng, IRC, Hongpu International, Anman, Origon, IRCE,
   INTT, Xias, Kevin Long, Jennifer Long, Ju, and Robinson's asset transfers and/or
   encumbrances, and business diversion have been part of a deliberately orchestrated
   scheme to enrich the RICO Enterprise by interfering with Philips' right to collect
   damages awarded by the Judgment. Defendants have intended to prevent Philips from
   collecting the damages awarded by the Judgment by fraudulently transferring and/or
   encumbering property and assets of the judgment debtors beyond the reach of Philips.
   The RICO Enterprise has carried out its scheme in interstate and foreign commerce,
   making extensive use of the United States mail and wire to fraudulently transfer or
   encumber property and assets of the judgment debtors in the United States and abroad.
5. 142. Each of the above fraudulent transfers by IRC, Shanghai Hongsheng,
   Shanghai Hongpu, Hongpu International, Anman, IRCC, Xias, Origon, IRCE, INTT,

Kevin Long, Jennifer Long, Ju, and Robinson alleged in Paragraphs 51-109 constitutes
an act of mail fraud in violation of 18 U.S.C. § 1341, or, in the alternative, an act of
wire fraud in violation of 18 U.S.C. § 1343.

1. 143. All of these acts of mail and/or wire fraud by Defendants consisted of the
   intentional transfers and/or encumbrances, and business diversion either: (1) by U.S.
   Mail or other private or commercial interstate carrier; or (2) by wire or radio
   communication in interstate or foreign commerce, and hence all such acts had a
   common method of commission. All of the above acts of mail fraud, or in the
   alternative, wire fraud, by the RICO Enterprise furthered the common purpose of
   preventing Philips from collecting damages awarded by the Judgment. These acts
   therefore constitute a pattern of racketeering activity for purposes of 18 U.S.C. §
   1961(5). There has been and remains a danger that the RICO Enterprise' racketeering
   activity will continue.
2. 144. Shanghai Hongsheng, IRC, Hongpu International, Anman, Origon, IRCE,
   INTT, Xias, Kevin Long, Jennifer Long, Ju, and Robinson have received income
   derived, directly or indirectly from the pattern of racketeering activity described herein.
   Shanghai Hongsheng, IRC, Hongpu International, Anman, Origon, IRCE, INTT, Xias,
   Kevin Long, Jennifer Long, Ju, and Robinson have used and invested that racketeering
   income or the proceeds thereof, directly or indirectly, in the investment, establishment
   or operation of the RICO Enterprise, an enterprise engaging in interstate or foreign
   commerce in violation of 18 U.S.C. §1962(a).
3. 145. Philips suffered financial harm, as Philips is prevented from collecting the
   damaged awarded by the Judgment, as a proximate result of Defendants' violation of
   18 U.S.C. §1962(a).

FOURTH COUNT
(RICO Violations of 18 U.S.C. § 1962(c))
[Applicable to All Defendants

1. 146. Philips realleges Paragraphs 1-115, and 138-145 as if fully set forth
   herein.
2. 147. All Defendants have conducted and participated, directly or indirectly, in
   the conduct of the affairs of the RICO Enterprise, an enterprise engaging in interstate
   or foreign commerce, through a pattern of racketeering activity in violation of 18
   U.S.C. §1962(c). All Defendants used their position of management and/or control
   over the RICO Enterprise, and its resources, to engage in their pattern of racketeering
   activity. For reasons stated above, all Defendants' direct or indirect conduct and
   participation of the conduct of the RICO Enterprise through a pattern of racketeering
   activity proximately caused Philips financial harm. All Defendants have engaged in its
   racketeering activity with the purpose of defrauding Philips by preventing Philips from
   collecting damages awarded by the Judgment through, inter alia, depleting,
   encumbering, or concealing assets, through fraudulently transferring and/or concealing
   businesses and assets.
3. 148. Philips suffered financial harm, as Philips is prevented from collecting the
   damaged awarded by the Judgment, as a proximate result of Defendants' violation of
   18 U.S.C. §1962(c).

FIFTH COUNT
(RICO Violations of 18 U.S.C. § 1962(d): Conspiracy to Violate 18 U.S.C. §
1962(a) and (c))
[Applicable to Shanghai Hongsheng, Shanghai Hongpu, IRC, IRCE, IRCC,
Origon, Hongpu International, Anman, Jennifer Long, and Ju]

1. 149. Philips realleges Paragraphs 1-115, and 138-148 as if fully set forth
   herein.
2. 150. Shanghai Hongsheng, Shanghai Hongpu, IRC, IRCE, IRCC, Origon,
   Hongpu International, Anman, Jennifer Long, and Ju have unlawfully, knowingly, and
   intentionally combined, conspired and agreed together with each other and with others

whose names are known and unknown, to: (1) conduct and participate, directly or
indirectly, in the conduct of the affairs of the RICO Enterprise, an enterprise engaged
in interstate or foreign commerce, through a pattern of racketeering activity, as
described in the Fourth Count of this Complaint, consisting of multiple acts in
violation of 18 U.S.C. §§ 1341 or 1343, in violation of 18 U.S.C. §1962(d); and (2) use
and investment of income or the proceeds thereof derived, directly or indirectly, from
the pattern of racketeering activity described in the Third Count of this Complaint, in
operation of the RICO Enterprise, an enterprise engaged in interstate or foreign
commerce, in the manner described in the Third Count of this Complaint in violation
of 18 U.S.C. §1962(d) .

1. 151. Philips suffered financial harm, as Philips is prevented from collecting the
   damaged awarded by the Judgment, as a proximate result of Defendants' violation of
   18 U.S.C. §1962(a) and (c).

PRAYER FOR RELIEF

WHEREFORE, Philips respectfully requests that judgment be entered:

Demand for Jury Trial

Philips demands a jury trial for all issues that can be so tried.