This document is a complaint filed by Intellectual Capital Consulting, Ltd. (ICC) with the U.S. International Trade Commission against several automotive manufacturers for infringing on ICC's patent for a smartwatch vehicular system. ICC alleges that companies such as Hyundai, GM, Audi, Volkswagen, and others manufacture and import products incorporating ICC's patented technology without a license. ICC is seeking exclusion and cease and desist orders against the respondents to prevent importation and sale of infringing products in the United States.
The presentation is all about drones and their legal background in India. It also gives you information about the permit and UIN requirements along with respect to drone.
If you want to stay safe while air travelling, then you should fly with Qatar Airways because of the technology it's bringing to its flights. It will ensure social distancing.
Ars electronica asks faa to fly 200 quadcoptersRepentSinner
This document is a petition filed by Ars Electronica Linz GmbH (Ars) with the US Department of Transportation, requesting an exemption from certain Federal Aviation Regulations and approval to operate unmanned aircraft systems to perform light shows in the US. Ars is an Austrian company that specializes in light shows using unmanned aircraft flying in formations. The petition provides details of Ars' experience operating similar shows internationally, describes the specific unmanned aircraft system and automated flight control technology that would be used, and explains safety measures to ensure separation from other air traffic and protection of people on the ground. It argues that an exemption is in the public interest to demonstrate unmanned aircraft capabilities and provide a safe, environmentally friendly alternative to traditional
The document discusses India's drone regulations version 1.0 and provides an overview of the permit and operational requirements for drones in India. Key points include:
1) The Digital Sky Platform is a national unmanned traffic management system that implements a "no permission, no takeoff" policy requiring pre-approval for all drone flights.
2) Operators must obtain an Unmanned Aircraft Operator Permit, register drones with a Unique Identification Number, and remote pilots require training and security clearance.
3) Drones are categorized based on weight and higher categories have increased equipment and licensing requirements. Operational restrictions include daytime visual line of sight flights below 400 feet.
Hmc industry report_drone_technology_160321[1]Robert Cheek
The document discusses the growing drone industry ecosystem. It outlines the various stakeholders in the drone industry value chain, including manufacturers, technology suppliers, component suppliers, operators, and training centers. It then discusses trends in the industry such as rising commercial use, emerging competitors, and the development of drone insurance. Key challenges discussed include regulations and traffic management.
This document outlines requirements for operating civil remotely piloted aircraft systems (RPAS) in India. Key points include:
- RPAS are categorized based on maximum weight as nano, micro, small, medium, and large.
- Operators must obtain a Unique Identification Number (UIN) from the DGCA for all RPAS except nano operating below 50 feet.
- Operators must obtain an Unmanned Aircraft Operator Permit (UAOP) from the DGCA for all operations except those under 50 or 200 feet, as well as government agencies.
- Operators must follow security, safety, remote pilot training, and maintenance requirements and report any incidents.
Partners Rory McPhillips, Stuart Kennedy and Senior Associate Stephen Gardiner of the Aviation Finance and Transportation team co-author an article for Lexology Navigator - Aviation in Ireland.
This document discusses camera monitor systems for vehicles that can eliminate blind spots and improve safety. It notes that vehicle blind spots are a major factor in collisions and that camera systems provide wider viewing angles and clearer images than mirrors to reduce risks. Camera systems can meet various health and safety regulations and reduce costs from insurance premiums, vehicle damage, and downtime from accidents. Examples of camera placements for different vehicle types are provided to provide views of front, side, rear, and internal areas to improve driver visibility and help prevent collisions and crimes on vehicles.
The presentation is all about drones and their legal background in India. It also gives you information about the permit and UIN requirements along with respect to drone.
If you want to stay safe while air travelling, then you should fly with Qatar Airways because of the technology it's bringing to its flights. It will ensure social distancing.
Ars electronica asks faa to fly 200 quadcoptersRepentSinner
This document is a petition filed by Ars Electronica Linz GmbH (Ars) with the US Department of Transportation, requesting an exemption from certain Federal Aviation Regulations and approval to operate unmanned aircraft systems to perform light shows in the US. Ars is an Austrian company that specializes in light shows using unmanned aircraft flying in formations. The petition provides details of Ars' experience operating similar shows internationally, describes the specific unmanned aircraft system and automated flight control technology that would be used, and explains safety measures to ensure separation from other air traffic and protection of people on the ground. It argues that an exemption is in the public interest to demonstrate unmanned aircraft capabilities and provide a safe, environmentally friendly alternative to traditional
The document discusses India's drone regulations version 1.0 and provides an overview of the permit and operational requirements for drones in India. Key points include:
1) The Digital Sky Platform is a national unmanned traffic management system that implements a "no permission, no takeoff" policy requiring pre-approval for all drone flights.
2) Operators must obtain an Unmanned Aircraft Operator Permit, register drones with a Unique Identification Number, and remote pilots require training and security clearance.
3) Drones are categorized based on weight and higher categories have increased equipment and licensing requirements. Operational restrictions include daytime visual line of sight flights below 400 feet.
Hmc industry report_drone_technology_160321[1]Robert Cheek
The document discusses the growing drone industry ecosystem. It outlines the various stakeholders in the drone industry value chain, including manufacturers, technology suppliers, component suppliers, operators, and training centers. It then discusses trends in the industry such as rising commercial use, emerging competitors, and the development of drone insurance. Key challenges discussed include regulations and traffic management.
This document outlines requirements for operating civil remotely piloted aircraft systems (RPAS) in India. Key points include:
- RPAS are categorized based on maximum weight as nano, micro, small, medium, and large.
- Operators must obtain a Unique Identification Number (UIN) from the DGCA for all RPAS except nano operating below 50 feet.
- Operators must obtain an Unmanned Aircraft Operator Permit (UAOP) from the DGCA for all operations except those under 50 or 200 feet, as well as government agencies.
- Operators must follow security, safety, remote pilot training, and maintenance requirements and report any incidents.
Partners Rory McPhillips, Stuart Kennedy and Senior Associate Stephen Gardiner of the Aviation Finance and Transportation team co-author an article for Lexology Navigator - Aviation in Ireland.
This document discusses camera monitor systems for vehicles that can eliminate blind spots and improve safety. It notes that vehicle blind spots are a major factor in collisions and that camera systems provide wider viewing angles and clearer images than mirrors to reduce risks. Camera systems can meet various health and safety regulations and reduce costs from insurance premiums, vehicle damage, and downtime from accidents. Examples of camera placements for different vehicle types are provided to provide views of front, side, rear, and internal areas to improve driver visibility and help prevent collisions and crimes on vehicles.
Presentación sobre lo que es el cáncer: epidemiología, prevención, diagnóstico y tratamiento. Respuesta emocional de los hijos de padres con cáncer así como pautas para la comunicación y atención de estos.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise causes chemical changes in the brain that may help protect against mental illness and improve symptoms.
This document discusses signaling systems and facsimile technology. It covers Signaling System 7 (SS7) which is a telecommunication protocol that handles telecommunication network control and call setup. SS7 improves call management, network management, and supports features like 800 numbers. The document also discusses facsimile systems including fax standards, technology, and customer premise systems. It describes printing, fax features, and fax servers which can deliver inbound faxes via email or the internet.
Protocolos del modelo osi de javier peñamichelle_95
El documento describe el modelo OSI y varios protocolos de red. El modelo OSI es un marco de referencia para definir arquitecturas de interconexión entre sistemas de comunicación. Se describen protocolos como TCP, IP, ARP y otros que operan en las capas de transporte y red del modelo OSI. También se mencionan aplicaciones como Telnet, FTP, SMTP y DNS que utilizan estos protocolos.
Londres ha crecido de una pequeña ciudad a una de las mayores aglomeraciones urbanas del mundo a través de la absorción de pueblos y aldeas circundantes. Actualmente tiene una población de 7.5 millones de habitantes y un clima templado oceánico. Londres es uno de los principales centros financieros internacionales y genera aproximadamente el 19% del PIB del Reino Unido, con su economía metropolitana representando casi el 30% de la economía nacional.
Presentación usada por el Departamento Administrativo de Planeación Municipal para hablar de las herramientas de gestión y control en el Plan de Ordenamiento Territorial
The document is a resume for Ashish Garg seeking a marketing position. It summarizes his work experience including over 5 years in marketing and advertising roles at Sharda University, and previous roles as an insurance advisor and trainee at ICICI Prudential Life Insurance. It also lists his education including an MBA in Marketing and Finance from Sharda University and BCA from Global Institute of Information & Tech.
La Cúpula de Las Arenas es un espacio multifuncional de 2,598 metros cuadrados situado en el centro de Barcelona con vistas panorámicas de la ciudad. El espacio principal circular tiene 1,912 metros cuadrados y 12 metros de altura máxima, y está equipado con iluminación, climatización, sonido y servicios para organizar eventos como ferias, conciertos, convenciones corporativas y exhibiciones. El espacio también incluye áreas de recepción, vestuarios, cocina y sanitarios.
oXirium Seminario Supply Chain Management Planificacion Produccion LogisticaoXirium
El documento habla sobre la gestión de la cadena de suministro y la integración entre producción y logística. Explica que una cadena de suministro efectiva requiere una visión global sobre una visión local, y métricas como throughput, stock y gastos de operación. También discute la importancia de identificar cuellos de botella, medir procesos, y usar software especializado para mejorar la planificación de demanda, gestión de almacenes, transporte, proveedores y clientes.
The document describes Hydraulics Software Solutions, a company that provides comprehensive hydraulic and fluid power automation solutions including enterprise software, industrial automation services, staff augmentation, and hydraulic consulting for various industries. It details the company's expertise, products, services, and solutions for issues like predictive maintenance, remote monitoring and diagnostics, industrial IoT, and hydraulic system consulting, training, and maintenance.
The document is an application packet for JusticeCorps, which provides legal assistance to self-represented litigants through AmeriCorps. As a JusticeCorps member, applicants would be trained to provide legal information to help self-represented litigants resolve legal issues. Members are required to complete 300 hours of service over one year working 6-8 hours per week at a court self-help center or small claims advisor program. The application requests information about the applicant and their availability and asks them to explain their interest in the program and how it relates to their goals.
Este documento discute la naturaleza y la importancia de la filosofía. Explica que la filosofía surge cuando el hombre pierde sus certezas y busca respuestas a preguntas fundamentales sobre sí mismo y el mundo. También describe las diferentes escuelas filosóficas a través de la historia y algunos de los filósofos más importantes como Platón, Aristóteles y Sócrates. Finalmente, argumenta que el estudio de la filosofía es importante porque representa la evolución superior de la razón humana y es la base de todas las
Gary Tschida at a glance_resume-portfolio2Gary Tschida
Gary Tschida is an experienced creative leader with many years of experience managing creative teams in advertising and marketing. He has a wide range of expertise, including shopper marketing, promotions, branding, and social media. He is a strategic thinker, mentor, and team player with excellent creative and communication skills. Throughout his career he has held various creative director and art director roles working on projects for many major brands.
Este documento contiene una lista de candidatos para diferentes cargos políticos en el departamento de Pando, Bolivia. Se incluyen los nombres completos de los candidatos, su número de documento de identidad, la posición a la que aspiran, el partido político al que pertenecen y la circunscripción territorial o población que representarían. Algunas de las posiciones incluidas son gobernador, vicegobernador, asambleístas departamentales, alcaldes y concejales. Dos de los principales partidos políticos mencionados
Fabricación de bloques a medida para END. Bloques demostración para TOFD, cualificación para operadores. Soldadura con procesos automáticos y/o robotizados, generación de defectos/entallas
Las firmas Gonvel Aggredere y Vertiba Consulting se han unido para ofrecer una amplia gama de servicios profesionales, incluyendo asesoramiento jurídico, fiscal, financiero, auditoría, gestión de proyectos inmobiliarios y administración de empresas. El documento describe cada una de estas áreas de servicio y presenta breves biografías del personal experto de ambas firmas.
Facebook fue creado por Mark Zuckerberg en 2004 como una red social para estudiantes de la Universidad de Harvard. Se ha convertido en la red social más grande del mundo con miles de millones de usuarios. El documento describe la historia de Facebook, sus características, importancia y cómo acceder a una cuenta de Facebook.
This document discusses the emerging wearable technology segment and Qualcomm's role in leading it. Some key points made include: 1) Wearable device shipments are expected to grow significantly over the next few years across categories like smartwatches, fitness/wellness, and healthcare; 2) Qualcomm is developing the core technologies needed for wearables like connectivity, power management, displays, and integrated systems-on-chips; 3) A successful personal wearable will need to optimize for characteristics like thin/light design, long battery life, always-on sensing capabilities, and continuous connectivity.
The United States Court of Appeals for the Federal Circuit summarized a district court ruling that dismissed claims brought by WIAV Solutions LLC regarding patents it held licenses to from Mindspeed Technologies. The district court concluded that WIAV did not have standing to assert these patents against various defendant companies because the patents were subject to licensing rights held by third parties, including Conexant Systems, Rockwell Science Center, Skyworks Solutions, Qualcomm, Mindspeed, and Sipro Lab Telecom. The Federal Circuit reviewed whether these third party licensing rights deprived WIAV of constitutional standing and remanded the case back to the district court for further consideration.
Presentación sobre lo que es el cáncer: epidemiología, prevención, diagnóstico y tratamiento. Respuesta emocional de los hijos de padres con cáncer así como pautas para la comunicación y atención de estos.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise causes chemical changes in the brain that may help protect against mental illness and improve symptoms.
This document discusses signaling systems and facsimile technology. It covers Signaling System 7 (SS7) which is a telecommunication protocol that handles telecommunication network control and call setup. SS7 improves call management, network management, and supports features like 800 numbers. The document also discusses facsimile systems including fax standards, technology, and customer premise systems. It describes printing, fax features, and fax servers which can deliver inbound faxes via email or the internet.
Protocolos del modelo osi de javier peñamichelle_95
El documento describe el modelo OSI y varios protocolos de red. El modelo OSI es un marco de referencia para definir arquitecturas de interconexión entre sistemas de comunicación. Se describen protocolos como TCP, IP, ARP y otros que operan en las capas de transporte y red del modelo OSI. También se mencionan aplicaciones como Telnet, FTP, SMTP y DNS que utilizan estos protocolos.
Londres ha crecido de una pequeña ciudad a una de las mayores aglomeraciones urbanas del mundo a través de la absorción de pueblos y aldeas circundantes. Actualmente tiene una población de 7.5 millones de habitantes y un clima templado oceánico. Londres es uno de los principales centros financieros internacionales y genera aproximadamente el 19% del PIB del Reino Unido, con su economía metropolitana representando casi el 30% de la economía nacional.
Presentación usada por el Departamento Administrativo de Planeación Municipal para hablar de las herramientas de gestión y control en el Plan de Ordenamiento Territorial
The document is a resume for Ashish Garg seeking a marketing position. It summarizes his work experience including over 5 years in marketing and advertising roles at Sharda University, and previous roles as an insurance advisor and trainee at ICICI Prudential Life Insurance. It also lists his education including an MBA in Marketing and Finance from Sharda University and BCA from Global Institute of Information & Tech.
La Cúpula de Las Arenas es un espacio multifuncional de 2,598 metros cuadrados situado en el centro de Barcelona con vistas panorámicas de la ciudad. El espacio principal circular tiene 1,912 metros cuadrados y 12 metros de altura máxima, y está equipado con iluminación, climatización, sonido y servicios para organizar eventos como ferias, conciertos, convenciones corporativas y exhibiciones. El espacio también incluye áreas de recepción, vestuarios, cocina y sanitarios.
oXirium Seminario Supply Chain Management Planificacion Produccion LogisticaoXirium
El documento habla sobre la gestión de la cadena de suministro y la integración entre producción y logística. Explica que una cadena de suministro efectiva requiere una visión global sobre una visión local, y métricas como throughput, stock y gastos de operación. También discute la importancia de identificar cuellos de botella, medir procesos, y usar software especializado para mejorar la planificación de demanda, gestión de almacenes, transporte, proveedores y clientes.
The document describes Hydraulics Software Solutions, a company that provides comprehensive hydraulic and fluid power automation solutions including enterprise software, industrial automation services, staff augmentation, and hydraulic consulting for various industries. It details the company's expertise, products, services, and solutions for issues like predictive maintenance, remote monitoring and diagnostics, industrial IoT, and hydraulic system consulting, training, and maintenance.
The document is an application packet for JusticeCorps, which provides legal assistance to self-represented litigants through AmeriCorps. As a JusticeCorps member, applicants would be trained to provide legal information to help self-represented litigants resolve legal issues. Members are required to complete 300 hours of service over one year working 6-8 hours per week at a court self-help center or small claims advisor program. The application requests information about the applicant and their availability and asks them to explain their interest in the program and how it relates to their goals.
Este documento discute la naturaleza y la importancia de la filosofía. Explica que la filosofía surge cuando el hombre pierde sus certezas y busca respuestas a preguntas fundamentales sobre sí mismo y el mundo. También describe las diferentes escuelas filosóficas a través de la historia y algunos de los filósofos más importantes como Platón, Aristóteles y Sócrates. Finalmente, argumenta que el estudio de la filosofía es importante porque representa la evolución superior de la razón humana y es la base de todas las
Gary Tschida at a glance_resume-portfolio2Gary Tschida
Gary Tschida is an experienced creative leader with many years of experience managing creative teams in advertising and marketing. He has a wide range of expertise, including shopper marketing, promotions, branding, and social media. He is a strategic thinker, mentor, and team player with excellent creative and communication skills. Throughout his career he has held various creative director and art director roles working on projects for many major brands.
Este documento contiene una lista de candidatos para diferentes cargos políticos en el departamento de Pando, Bolivia. Se incluyen los nombres completos de los candidatos, su número de documento de identidad, la posición a la que aspiran, el partido político al que pertenecen y la circunscripción territorial o población que representarían. Algunas de las posiciones incluidas son gobernador, vicegobernador, asambleístas departamentales, alcaldes y concejales. Dos de los principales partidos políticos mencionados
Fabricación de bloques a medida para END. Bloques demostración para TOFD, cualificación para operadores. Soldadura con procesos automáticos y/o robotizados, generación de defectos/entallas
Las firmas Gonvel Aggredere y Vertiba Consulting se han unido para ofrecer una amplia gama de servicios profesionales, incluyendo asesoramiento jurídico, fiscal, financiero, auditoría, gestión de proyectos inmobiliarios y administración de empresas. El documento describe cada una de estas áreas de servicio y presenta breves biografías del personal experto de ambas firmas.
Facebook fue creado por Mark Zuckerberg en 2004 como una red social para estudiantes de la Universidad de Harvard. Se ha convertido en la red social más grande del mundo con miles de millones de usuarios. El documento describe la historia de Facebook, sus características, importancia y cómo acceder a una cuenta de Facebook.
This document discusses the emerging wearable technology segment and Qualcomm's role in leading it. Some key points made include: 1) Wearable device shipments are expected to grow significantly over the next few years across categories like smartwatches, fitness/wellness, and healthcare; 2) Qualcomm is developing the core technologies needed for wearables like connectivity, power management, displays, and integrated systems-on-chips; 3) A successful personal wearable will need to optimize for characteristics like thin/light design, long battery life, always-on sensing capabilities, and continuous connectivity.
The United States Court of Appeals for the Federal Circuit summarized a district court ruling that dismissed claims brought by WIAV Solutions LLC regarding patents it held licenses to from Mindspeed Technologies. The district court concluded that WIAV did not have standing to assert these patents against various defendant companies because the patents were subject to licensing rights held by third parties, including Conexant Systems, Rockwell Science Center, Skyworks Solutions, Qualcomm, Mindspeed, and Sipro Lab Telecom. The Federal Circuit reviewed whether these third party licensing rights deprived WIAV of constitutional standing and remanded the case back to the district court for further consideration.
Embitel has expertise in developing Android Infotainment Projects, embedded software/hardware developers and infotainment testing. As your infotainment solution partner, we provide end-to-end support throughout your product development roadmap – technology strategy, UX design, infotainment software and hardware development and support.
One of the best ways to understand the investment potential of IoT is to have insights regarding the market growth potential and the earning power of specific technologies, business sectors or companies. Patent information can provide many valuable insights that can be exploited for finding investment potential of IoT. Most of all, patents can provide insights regarding the state of the art and future direction of IoT innovation for the specific technologies (e.g., Smart UI/UX, Autonomous Vehicles, M2M Connectivity), products/services (e.g., Smart Homes, Healthcare/Medical Devices, Connected Cars, Big Data Analytics) and companies (e.g., Apple, Cisco, IBM, Qualcomm, Samsung). Patents also can provide insights regarding a new company to become play a leading role in the emerging IoT market. Furthermore, patents can provide insights regarding emerging disruptive IoT products/Services by providing IoT products with new performance/value proposition attributes that may not previously have been valued by existing end users (e.g., convergence with other technologies to create synergies). Therefore, one can find the specific IoT technologies, business sectors or companies for investment opportunities in venture capital funding, M&A, patent/technology acquisition/monetization, leveraged buyout and stock investment. Following illustrates some examples of IoT technologies, business sectors and companies for potential investment opportunities that are obtained from patent information.
This document provides an overview of how various companies are integrating remote wireless sensor networks, known as motes, into their business operations. It discusses SAIC's involvement in developing motes for applications like border security. It also outlines how companies like HP, IBM, Intel, GE, PARC, and BP are using motes for tasks like data center monitoring, location tracking, health monitoring, and infrastructure maintenance. Challenges with mote integration include data security, costs, and ensuring business benefits outweigh expenses.
This document proposes an all-in-one vehicle simulation and protection system using RFID technology. It would improve upon existing solutions by allowing simulation of multiple vehicles over a long range using RFID sensors, as well as providing collision protection for vehicles. The system would use RFID detectors and transmitters to calculate distance and speed between vehicles to avoid accidents, especially in difficult conditions like fog. This innovative solution combines vehicle simulation, protection, and RFID technology into a single system with potential benefits for traffic handling and safety.
The document discusses the security and surveillance marketplace for the SurveillancePoint service. It analyzes the current marketplace, trends, competitors, market size, and opportunities. SurveillancePoint is a global video surveillance, alarm, monitoring and tracking management system that can be accessed over the internet or private network from various devices. It integrates security equipment and provides remote access and monitoring capabilities, addressing a need in the market.
Draft submission to the OMG RPC over DDS RPF.
This draft standard defines a Remote Procedure Call (RPC) framework using the basic building blocks of DDS, such as topics, types, and entities (e.g., DataReader, DataWriter) to provide request/reply semantics. It defines distributed services, characterized by a service interface, which serves as a shareable contract between service provider and a service consumer. It supports synchronous and asynchronous method invocation.
We filed a patent lawsuit against Samsung, and Qualcomm, with the U.S. International Trade Commission in early September 2014, alleging that the company has chosen to deploy our patented GPU technology without proper compensation to us. When we did so, we fully anticipated that Samsung would sue us in response. It’s a classic reaction, which we factored into our strategic analysis before filing our suit. Here's a copy of Samsung's suit.
1. Integrated Strategic Patent Management
2. The Monetizing Patent’s DNA: How to identify and develop the monetizing patents
3. Internet of Things (IoT) Patent Monetization New Business Model
4. Internet of Things (IoT) Strategic Patent R&D for New Value Creation
5. Evaluation of Monetized Patents for the Internet of Things (IoT) Connectivity Standards
6. Increasing Monetization Activities Exploiting LTE Patents
7. How much will Apple need to pay to Ericsson for a reasonable licensing royalty of 4G LTE patents?
8. Internet of Things (IoT) M&A Target Candidates Insights from Patents
9. Apple’s Strategic Alignment in Patent and M&A
10. Alcatel-Lucent acquisition by Nokia would provide leadership in Mobile based IoT innovation
11. Investment for Patent Monetization
12. Increasing IP Financing Activities Exploiting Wireless Patents
13. Internet of Things (IoT) Investment Insights from Patents
AirView aims to expand the Internet of Things (IoT) by connecting outdoor structures using drones to place low-cost sensors. The sensors would gather environmental and infrastructure data via WiFi networks in a cost-effective way. AirView's software platform would manage sensor communication, data storage, and analytics. This would provide useful data to reduce costs and generate future revenue streams from applications like remote security, environmental monitoring, and predictive maintenance of bridges and buildings.
DEF CON 23 -COLLIN ANDERSON and TOM CROSS - export controls on intrusion soft...Felipe Prado
The document discusses new export control rules under Wassenaar Arrangement regarding intrusion software and related technology. It provides background on export controls generally and how the new rules might apply. Specifically, it notes intrusion software itself is not controlled, but technology for its development is. It raises questions about how this may impact security research practices like vulnerability research, coordinated disclosure, bug bounties, training classes, and international travel with security tools. Overall it examines implications and uncertainties around how the new rules will be implemented and enforced.
J. Daniel Martínez - IoP: The Internet of Planes / Hacking millionaires jet c...RootedCON
The document discusses analyzing mobile applications used to manage cabin and in-flight entertainment systems on aircraft. It summarizes decompiling the Android apps, analyzing the code to understand how they work, and using tools like Wireshark and custom scripts to simulate the aircraft environment and observe traffic between an emulated server and the apps. Vulnerabilities were found by manipulating parameters like the app and configuration versions in the network responses.
Patents are a good information resource for obtaining IoT (Internet of Things) R&D status in a company. Followings are some examples of patents that provide Qualcomm IoT R&D status: smart home, connected car, cloud service for IoT, industrial IoT and IoT connectivity (LED visible light communication).
Drone Insights 2021, and its Impact on other sectors in IndiaKaushik Biswas
The Booming Drone Industry and its prospect by 2025. What are the sectors in which Drones can be used in India, the regulatory frameworks comparing World Vs India, What are the Top 3 companies we can do business with, who are the other players in the industry?
I have also done a small survey on what Indians think about the drone industry overall, and finally a conclusion on where we are vs the world
Michael fekete and howard fohr lexpert casl computer programs provisions and ...bsookman
1) The document discusses various challenges and strategies for complying with Canada's Anti-Spam Legislation (CASL) in different vertical sectors such as software, mobile/telecom, product manufacturing, and online businesses.
2) Key issues addressed include identifying regulated computer program activities, obtaining express consent, developing consent strategies, satisfying disclosure rules, and proving consent.
3) Challenges for the mobile/telecom sector include obtaining consent during device setup processes and the app submission process, while product manufacturers face issues with no direct user interaction.
Similar to ITC Investigation Draft (non-confidential version) (20)
Receivership and liquidation Accounts
Being a Paper Presented at Business Recovery and Insolvency Practitioners Association of Nigeria (BRIPAN) on Friday, August 18, 2023.
Guide on the use of Artificial Intelligence-based tools by lawyers and law fi...Massimo Talia
This guide aims to provide information on how lawyers will be able to use the opportunities provided by AI tools and how such tools could help the business processes of small firms. Its objective is to provide lawyers with some background to understand what they can and cannot realistically expect from these products. This guide aims to give a reference point for small law practices in the EU
against which they can evaluate those classes of AI applications that are probably the most relevant for them.
Genocide in International Criminal Law.pptxMasoudZamani13
Excited to share insights from my recent presentation on genocide! 💡 In light of ongoing debates, it's crucial to delve into the nuances of this grave crime.
Synopsis On Annual General Meeting/Extra Ordinary General Meeting With Ordinary And Special Businesses And Ordinary And Special Resolutions with Companies (Postal Ballot) Regulations, 2018
Lifting the Corporate Veil. Power Point Presentationseri bangash
"Lifting the Corporate Veil" is a legal concept that refers to the judicial act of disregarding the separate legal personality of a corporation or limited liability company (LLC). Normally, a corporation is considered a legal entity separate from its shareholders or members, meaning that the personal assets of shareholders or members are protected from the liabilities of the corporation. However, there are certain situations where courts may decide to "pierce" or "lift" the corporate veil, holding shareholders or members personally liable for the debts or actions of the corporation.
Here are some common scenarios in which courts might lift the corporate veil:
Fraud or Illegality: If shareholders or members use the corporate structure to perpetrate fraud, evade legal obligations, or engage in illegal activities, courts may disregard the corporate entity and hold those individuals personally liable.
Undercapitalization: If a corporation is formed with insufficient capital to conduct its intended business and meet its foreseeable liabilities, and this lack of capitalization results in harm to creditors or other parties, courts may lift the corporate veil to hold shareholders or members liable.
Failure to Observe Corporate Formalities: Corporations and LLCs are required to observe certain formalities, such as holding regular meetings, maintaining separate financial records, and avoiding commingling of personal and corporate assets. If these formalities are not observed and the corporate structure is used as a mere façade, courts may disregard the corporate entity.
Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
Group Enterprises: In some cases, where multiple corporations are closely related or form part of a single economic unit, courts may pierce the corporate veil to achieve equity, particularly if one corporation's actions harm creditors or other stakeholders and the corporate structure is being used to shield culpable parties from liability.
Sangyun Lee, 'Why Korea's Merger Control Occasionally Fails: A Public Choice ...Sangyun Lee
Presentation slides for a session held on June 4, 2024, at Kyoto University. This presentation is based on the presenter’s recent paper, coauthored with Hwang Lee, Professor, Korea University, with the same title, published in the Journal of Business Administration & Law, Volume 34, No. 2 (April 2024). The paper, written in Korean, is available at <https://shorturl.at/GCWcI>.
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1. U.S. International Trade Commission
Intellectual Capital Consulting, Ltd.
Certain Vehicular Smartwatch Systems, Related Software and Components Thereof
I. INTRODUCTION
1. This Complaint is filed by Intellectual Capital Consulting, Ltd. ("ICC" or
"Complainant") under Section 337 of the Tariff Act of 1930, as amended, 19 U.S.C.
§ 1337, based on the unlawful importation into the United States, the sale for
importation into the United States, the sale within the United States after
importation, and/or the use within the United States after importation by the
proposed Respondents of certain smartwatch vehicular systems and components
and software thereof that infringe certain claims of United States Patent No.
7,068,151 ("the ‘151 Patent") (also referred as the , "ICC Asserted Patent") either
literally or under the doctrine of equivalents.
2. Intellectual Capital Consulting, Ltd. is a pioneer in the field of wristwatch
operated vehicles security systems, also known as smartwatch vehicular systems.
The ICC smartwatch vehicular system, which is sold under the trade name
"Blackhawk RES," was the first commercialized aftermarket smartwatch vehicular
system solution.
3. For many of consumers, smartphones have become the center of their
lives, reminding them of appointments, keeping them up on the latest news, letting
them know what friends are up to, telling them how to get to places, and even
being a conduit to pay for products or services. At the same time, many new
2. 2
vehicles don't require a traditional key, instead letting consumers use a plastic key
fob remote to transmit RF signals to unlock doors and start the engine. Included
with the Blackhawk RES system is this traditional method of user engagement.
4. As an extension of the smartphone and plastic key fob, ICC integrated the
functions of these devices into wristwatch form factors, making one less item for
users to carry in their pocket. The Blackhawk RES system sends signals over its
data connection to ICC’s server, which then sends the lock or unlock signal to the
car, there is no distance restriction. Users can activate the locks from anywhere in
the world that have a data connection for their mobile phones.
5. In addition, the Blackhawk RES system incorporates a GPS module,
enabling a geo-fencing feature useful for parents. With that, consumers can use the
Blackhawk RES system to define a circular area around a central point. If the car
was driven outside of that area, the Blackhawk RES system shows an alert.
6. One of the challenges ICC faced in creating a commercially viable product
was to create a smartwatch vehicular system that matched the performance,
reliability and pricing of traditional plastic key fob, smartphone and GPS tracking
system solutions. ICC surpassed this challenge and developed a smartwatch
vehicular system that was commensurate to existing solutions like plastic key fob,
smartphone and GPS tracking security systems. To do so, ICC developed unique,
market rate, mid-tier and elite packaging options to appeal to the spectrum of
vehicle enthusiasts. Further, ICC needed to package the wristwatch remote in a
fashion forward manner while providing the user with necessary notifications,
alerts and/or updates from the vehicle. This is the essence of the ‘151 Patent.
3. 3
7. A user of the Blackhawk RES system will not only be able to keep track of
the time and check notifications from their smartphone via the smartwatch but
also will be able to arm/lock, disarm/unlock and remotely start their vehicle by
interfacing with the smartwatch. Moreover, it is common for people to lose or
misplace their keys along with the plastic remote fob that is attached to the keys.
Since the smartwatch situated on the users wrist, the user never has to worry
about damage due to dropping on a hard surfaces, in liquids (ex. water), or even
losing their plastic remote fob. Therefore, the ICC smartwatch vehicular
technology drastically improves consumer smartwatch adaptation, system
reliability, and significantly increases user convenience.
8. The proposed Respondents Hyundai Motor Company, Hyundai Motor
America, Hyundai Motor Manufacturing Alabama, LLC (collectively, “Hyundai”),
General Motors Corporation, General Motors LLC, OnStar, LLC (collectively, “GM”),
Audi AG, Audi of America LLC, Audi of America, Inc. (collectively, “Audi”),
Volkswagen AG, Volkswagen Group of America, Inc. (collectively, “Volkswagen”),
BMW of North America, LLC, Bayerische Motoren Werke AG (collectively, “BMW”),
Dr. Ing. h.c. F. Porsche AG, Porsche Cars North America, Inc. (collectively, “Porsche
AG”), DEI Holdings, Inc., Directed Electronics, Inc. (collectively, “Directed
Electronics”), Samsung Electronics Co. Ltd., Samsung Electronics America, Inc.,
Samsung Telecommunications America LLC (collectively, “Samsung”), LG
Corporation, LG Electronics U.S.A. Inc., LG Electronics MobileComm U.S.A., Inc.
(collectively, “LG”), Sony Corporation, Sony Electronics, Inc., Sony Corporation of
America (collectively, “Sony”), Lenovo Limited Group, Lenovo Holding Company,
Inc., Lenovo (United States), Inc. (collectively, “Lenovo”), Motorola Mobility, Inc.
4. 4
(“Motorola”), Apple, Inc. (Apple), Station Digital Media, Inc. (Station Digital) and
Rego Apps, LLC (Rego) develop, manufacture, import, sell for importation into the
United States, sell after importation into the United States, and uses after
importation into the United States smartwatch vehicular systems and components
and software therein, such as wristwatches and their on-board device
components, operating systems, and/or other software (collectively, the "Accused
Products"). As set forth in Section VII below, the Accused Products are
manufactured abroad in locations such as, but not limited to, Korea, Vietnam,
Mexico, Canada, Germany and China, and are imported for sale into the United
States. The Accused Products incorporate, without any license from ICC, many
technologies developed by ICC and protected by the patent owned by ICC. The
patent-in-suit and their asserted claims (independent claims in bold) are listed
below:
9. Certified copies of ICC’s Asserted Patent are included at Exhibit 1
ICC owns all rights, title, and interest in each of ICC’s Asserted Patents, including
the right to sue for infringement. Certified copies of the assignment records for
each of ICC’s Asserted Patent are included at Exhibit 2 & Confidential Exhibit 52.
10. A domestic industry as required by 19 U.S.C. §§ 1337(a)(2) and (3) exists
or is in the process of being established in the United States relating to articles
protected by ICC’s Asserted Patent, including significant investment in equipment,
Patent Number Asserted Claims
7,068,151 (Independent claim in bold)
Independent 1
Dependent 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, 22
5. 5
significant employment of labor and capital, and substantial investment in the
exploitation of the invention claimed in ICC’s Asserted Patent, including through
engineering, research, and development.
11. ICC seeks as relief a permanent limited exclusion order under 19 U.S.C. §
1337(d) barring from entry into the United States directly-infringing and/or
indirectly infringing smartwatch vehicular systems, components and software
thereof manufactured, sold, or used by or on behalf of Respondents. ICC further
seeks as relief a permanent cease and desist order under 19 U.S.C. § 1337(f)
prohibiting Respondents from marketing, distributing, selling, offering for sale,
warehousing inventory for distribution, or otherwise transferring or bringing into
the United States infringing smartwatch vehicular systems and/or their
components and software thereof.
II. COMPLAINANT
12. ICC is a limited liability company organized and existing under the laws of
Colorado, having its principal place of business at 3160 W. 71st Avenue, suite 3-
307, Westminster, Colorado 80030. ICC is the assignee and exclusive licensee of
the ICC Asserted Patent, with the right to sue for all infringement thereof.
13. Founded in 2010, ICC is a management consulting firm specializing in
patent prosecution, and technology transfer and commercialization that acquired
all rights to the ‘151 Patent, becoming a leading innovator of smartwatch vehicular
systems. ICC has significant operations in the United States, including with respect
to ICC’s Asserted Patent. ICC has researched, developed, tested, engineered,
6. 6
assembled, packaged, and installed the ICC Asserted Patent under the brand name
Blackhawk RES.
14. On July 18, 2014 the Specialty Equipment Marketing Association (SEMA)
selected the Blackhawk RES as one of the Top 10 innovations of 2014 See Exhibit
42. In addition, SEMA launched a Facebook voting campaign to narrow the
selected ten innovations down to five. On September 10, 2014, SEMA selected the
Blackhawk RES was as one of the top five innovations and invited to present the
technology during its 2014 SEMA trade show in Las Vegas See Exhibit 43. Further,
ICC debuted the ICC Patented Products via the Blackhawk RES brand and launched
a crowd funding campaign during the SEMA presentation.
15. ICC’s smartwatch vehicular system, specifically ICC’s smartwatch remote
start products use the inventions claimed in ICC’s Asserted Patent. As explained in
more detail in the chart included as Confidential Exhibit 39, one or more of ICC’s
Asserted Patents is implemented in the Blackhawk RES system (including at least
the Blackhawk RES 530, 810 and 818 series).
16. ICC researched and developed the technologies that are protected by
ICC’s Asserted Patent. ICC is the full owner of all rights and title to the ICC Asserted
Patent. Certified copies of the relevant assignment records are attached at
Exhibits 2. Additionally, the confidential exclusive license agreement is attached
at Confidential Exhibit 52.
17. ICC has made and continues to make significant investments in the
design and development of products protected by ICC’s Asserted Patent. In the
7. 7
United States, ICC exploits the technologies covered by ICC’s Asserted Patent
through various activities, including substantial research and development,
engineering, assembly, installation, and product and warranty support among
others, as discussed more fully in Section XI below.
III. THE PROPOSED RESPONDENTS
18. Upon information and belief, Hyundai Motor Company, General Motors
Corporation, Audi AG, BMW AG, Dr. Ing. h.c. F. Porsche AG, Directed Electronics,
Inc., Samsung Electronics Co. Ltd., LG Corporation, Sony Corporation, Lenovo
Group Limited., Motorola Mobility, Inc., Apple, Inc., Station Digital Media, Inc., and
Rego Apps, LLC each develop, manufacture, import, sell for importation into the
United States, sell after importation into the United States, and/or uses after
importation into the United States smartwatch vehicular systems and
components and software therein, such as wristwatches and their on-board
components, operating systems, and/or other software, as further described in
Section VII below.
A. Hyundai Motor Company
19. Upon information and belief, Hyundai Motor Company is a Korean
company with a place of business at 231 Yangjae-dong, Seocho-gu, Seoul, South
Korea 137-938. Further, Hyundai Motor Company is in the business of developing,
making, offering for sale, selling, importing, and supporting products containing
vehicular smartwatch systems, related software and components thereof
including, without limitation, vehicles, and their respective on board components
8. 8
that are manufactured outside of the United States. Moreover, said product either
under the doctrine of equivalents, or directly and/or indirectly infringe the ‘151
Patent. Hyundai Motor Company is the parent corporation of Respondents
Hyundai Motor America and Hyundai Motor Manufacturing Alabama.
B. Hyundai Motor America
20. Upon information and belief, Hyundai Motor America is a California
corporation with a place of business at 10550 Talbert Ave. Fountain View, CA
92708. Upon information and belief, Hyundai Motor America is a subsidiary of
Hyundai Motor Company and, in part, responsible for U.S. operations. Hyundai
Motor America sells, markets, distributes, manufactures, sells for importation,
imports, and/or sells after importation into the United States product that either
under the doctrine of equivalents, or directly and/or indirectly infringe the ‘151
Patent. Upon information and belief, further discovery will reveal additional
details regarding the division of responsibilities amongst Hyundai-family entities.
C. Hyundai Motor Manufacturing Alabama, LLC
21. Upon information and belief, Hyundai Motor Manufacturing Alabama,
LLC is a Delaware limited liability company with its principal place of business at
700 Hyundai Blvd., Montgomery, Alabama 36105. Hyundai Motor Manufacturing
Alabama, LLC is in the business of developing, making, offering for sale, selling,
importing, and supporting products containing vehicular smartwatch systems,
related software and components thereof including, without limitation, vehicles,
and their respective on board components that are manufactured outside of the
9. 9
United States that either under the doctrine of equivalents, or directly and/or
indirectly infringe the ‘151 Patent. Hyundai Motor Manufacturing Alabama, LLC is
a subsidiary corporation of Respondent Hyundai Motor Company. Hyundai Motor
Manufacturing Alabama, LLC, Hyundai Motor America and Hyundai Motor
Company are referred to collectively as “Hyundai.”
D. General Motors Company
22. Upon information and belief, General Motors Company is a company
organized under the laws of Delaware with its principal place of business at 300
Renaissance Center, Detroit, Michigan 48265. Further, General Motors Company is
in the business of developing, making, offering for sale, selling, importing, and
supporting products containing vehicular smartwatch systems, related software
and components thereof including, without limitation, vehicles, and their
respective on board components that are manufactured outside of the United
States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. General Motors Company is the
parent corporation of Respondents General Motors LLC and OnStar, LLC.
E. General Motors, LLC
23. Upon information and belief, General Motors LLC is a limited liability
company organized under the laws of Delaware with its principal place of business
at 300 Renaissance Center, Detroit, Michigan 48265. General Motors, LLC is in the
business of developing, making, offering for sale, selling, importing, and
supporting products containing vehicular smartwatch systems, related software
10. 10
and components thereof including, without limitation, vehicles, and their
respective on board components that are manufactured outside of the United
States that either under the doctrine of equivalents, or directly and/or indirectly
infringe the ‘151 Patent.
F. OnStar, LLC
24. Upon information and belief, OnStar, LLC is a limited liability company
organized under the laws of Delaware with its principal place of business at 400
Renaissance Center, Detroit, Michigan 48265. OnStar, LLC is a subsidiary of
General Motors Company and, in part, responsible for operations that use, sell,
market, distribute, manufacture, sells for importation, imports, and/or sells after
importation into the United States product that either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent. Patent. Upon
information and belief, further discovery will reveal additional details regarding
the division of responsibilities amongst GM-family entities. General Motors
Company, General Motors, LLC and OnStar, LLC are referred to collectively as
“GM.”
G. Volkswagen AG
25. Upon information and belief, Volkswagen AG is a corporation organized
and existing under the laws of Germany, having its principal place of business at
Brieffach 1848-2, 38436 Wolfsburg, Germany. Further, Volkswagen AG is in the
business of developing, making, offering for sale, selling, importing, and
supporting products containing vehicular smartwatch systems, related software
11. 11
and components thereof including, without limitation, vehicles, and their
respective on board components that are manufactured outside of the United
States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. Volkswagen AG is the parent
corporation of Respondent Volkswagen Group of America, Inc.
H. Volkswagen Group of America, Inc.
26. Upon information and belief, Volkswagen Group of America, Inc. is a New
Jersey corporation with its headquarters and principal place of business located at
2200 Ferdinand Porsche Drive, Herndon, Virginia 20171. Upon information and
belief, Volkswagen Group of America, Inc. is responsible for operations that use,
sell, market, distribute, manufacture, sells for importation, imports, and/or sells
after importation into the United States product that either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent.
27. Upon information and belief, Volkswagen AG and Volkswagen Group of
America, Inc. bear the primary responsibility for the marketing and sales of
Volkswagen-branded products within the United States. Upon information and
belief, further discovery will reveal additional details regarding the division of
responsibilities amongst Volkswagen-family entities. Volkswagen AG and
Volkswagen Group of America, Inc. are referred to collectively as “Volkswagen.”
I. Audi AG
28. Upon information and belief, Audi AG is a German corporation with its
12. 12
principal place of business at Ettinger Strasse, D-85045, Ingolstadt, Germany.
Further, Audi AG is in the business of developing, making, offering for sale, selling,
importing, and supporting products containing vehicular smartwatch systems,
related software and components thereof including, without limitation, vehicles,
and their respective on board components that are manufactured outside of the
United States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. Audi AG is the parent
corporation of Respondents Audi of America, Inc. and Audi of America, LLC. Audi
AG has primary responsibility for the business planning and manufacturing of
Audi-branded products.
J. Audi of America, Inc.
29. Upon information and belief, Audi of America, Inc. is a Delaware
corporation with its principal place of business at 2200 Ferdinand Porsche Dr.,
Herndon, VA 20171. Audi of America, Inc. is a subsidiary of Audi AG and is, in part,
responsible for operations that use, sell, market, distribute, manufacture, sells for
importation, imports, and/or sells after importation into the United States product
that either under the doctrine of equivalents, or directly and/or indirectly infringe
the ‘151 Patent.
K. Audi of America LLC
30. Upon information and belief, Audi of America LLC is a New Jersey
corporation with its principal place of business at 3800 W. Hamlin Road, Auburn
Hills, MI 48326. Audi of America LLC is a subsidiary of Audi AG and is, in part,
13. 13
responsible for operations that use, sell, market, distribute, manufacture, sells for
importation, imports, and/or sells after importation into the United States product
that either under the doctrine of equivalents, or directly and/or indirectly infringe
the ‘151 Patent.
31. Upon information and belief, Audi of America, Inc. and Audi of America
LLC bear the primary responsibility for the importation, marketing, and sales of
Audi-branded products within the United States. Upon information and belief,
further discovery will reveal additional details regarding the division of
responsibilities amongst Audi-family entities. Audi AG, Audi of America, Inc., and
Audi of America, LLC are referred to collectively as “Audi.”
L. Bayerische Motoren Werke AG
32. Upon information and belief, Bayerische Motoren Werke AG (“BMW AG”)
is a corporation organized under the laws of the Federal Republic of Germany with
its principal place of business at Petuelring 130, 80809 Munich, Germany. BMW
AG designs and manufactures motor vehicles, parts, and other products for sale in
Europe and for export and sale throughout the world. Further, BMW AG is in the
business of developing, making, offering for sale, selling, importing, and
supporting products containing vehicular smartwatch systems, related software
and components thereof including, without limitation, vehicles, and their
respective on board components that are manufactured outside of the United
States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. BMW AG is the parent
corporation of Respondents BMW of North America, LLC. BMW AG has primary
14. 14
responsibility for the business planning and manufacturing of BMW-branded
products
M. BMW of North America, LLC
33. Upon information and belief, BMW of North America, LLC (“BMW NA”) is
a Delaware limited liability company having its principal place of business at 300
Chestnut Ridge Road, Woodcliff Lake, New Jersey 07677. BMW NA is a wholly
owned subsidiary of BMW (US) Holding Corporation, a Delaware corporation,
which is a wholly owned subsidiary of BMW AG. BMW NA is responsible for
operations that use, sell, market, distribute, manufacture, sells for importation,
imports, and/or sells after importation into the United States product that either
under the doctrine of equivalents, or directly and/or indirectly infringe the ‘151
Patent.
34. Upon information and belief, BMW AG and BMW NA bear the primary
responsibility for the importation, marketing, and sales of BMW-branded products
within the United States. Upon information and belief, further discovery will
reveal additional details regarding the division of responsibilities amongst BMW-
family entities. BMW AG and BMW of North America, LLC are referred to
collectively as “BMW.”
N. Dr. Ing. h.c. F. Porsche AG
35. Upon information and belief, Dr. Ing. h.c. F. Porsche AG is a corporation
organized under the laws of Germany with its principal place of business at
15. 15
Porscheplatz 1, D 70435, Stuttgart, Germany. Dr. Ing. h.c. F. Porsche AG designs
and manufactures motor vehicles, parts, and other products for sale in Europe and
for export and sale throughout the world. Further, Dr. Ing. h.c. F. Porsche AG is in
the business of developing, making, offering for sale, selling, importing, and
supporting products containing vehicular smartwatch systems, related software
and components thereof including, without limitation, vehicles, and their
respective on board components that are manufactured outside of the United
States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. Dr. Ing. h.c. F. Porsche AG is the
parent corporation of Respondent Porsche Cars of North America, Inc. Dr. Ing. h.c.
F. Porsche AG has primary responsibility for the business planning and
manufacturing of Porsche-branded products.
O. Porsche Cars of North America, Inc.
36. Upon information and belief, Porsche Cars North America, Inc., is a
corporation organized under the laws of Delaware, with its principal place of
business at 980 Hammond Drive NE, Suite 1000, Atlanta, Georgia, 30328, and a
registered agent at The Corporation Trust Company, 1209 Orange Street,
Wilmington, Delaware, 1980. Upon information and belief, Porsche Cars North
America, Inc. bears the primary responsibility for the importation, marketing, and
sales of Porsche-branded products within the United States that either under the
doctrine of equivalents, or directly and/or indirectly infringe the ‘151 Patent..
37. Upon information and belief, further discovery will reveal additional
details regarding the division of responsibilities amongst Porsche-family entities.
16. 16
Dr. Ing. h.c. F. Porsche AG and Porsche Cars of North America, Inc. are referred to
collectively as “Porsche” or “Porsche AG.”
P. DEI Holdings, Inc.
38. Upon information and belief, DEI Holdings, Inc. is a Florida corporation
with its principal place of business at One Viper Way, Vista, California 92083. DEI
Holdings, Inc. is in the business of developing, making, offering for sale, selling,
importing, and supporting products containing vehicular smartwatch systems,
related software and components thereof including, without limitation, vehicle
security systems, and their respective on board components that are
manufactured outside of the United States. Moreover, said product either under
the doctrine of equivalents, or directly and/or indirectly infringe the ‘151 Patent.
DEI Holdings, Inc. is the parent corporation of Respondent Directed Electronics,
Inc.
39. Upon information and belief, DEI Holdings, Inc. has primary
responsibility for the business planning and support of Directed-branded
products.
Q. Directed Electronics, Inc.
40. Upon information and belief, Directed Electronics, Inc. is a corporation
organized and existing under the laws of the State of California, having its
principal place of business at One Viper Way, Vista, California 92083. Directed
Electronics, Inc. is responsible for operations that use, sell, market, distribute,
17. 17
manufacture, sells for importation, imports, and/or sells after importation into the
United States product that either under the doctrine of equivalents, or directly
and/or indirectly infringe the ‘151 Patent..
41. Upon information and belief, DEI Holdings, Inc. and Directed Electronics,
Inc. bear the primary responsibility for the importation, marketing, and sales of
Directed Electronics-branded products within the United States. Upon information
and belief, further discovery will reveal additional details regarding the division of
responsibilities amongst Directed Electronics-family entities. DEI Holdings, Inc.
and Directed Electronics, Inc. are referred to collectively as “Directed Electronics.”
R. Samsung Electronics Co., Ltd.
42. Upon information and belief, Samsung Electronics Co., Ltd. is a
corporation organized under the laws of South Korea with its principal place of
business located at Samsung Main Building, 250, Taepyeongno 2-ga, Jung-gu, Seoul
100-742, Republic of Korea. Further, Samsung Electronics Co., Ltd. is in the
business of developing, making, offering for sale, selling, importing, and
supporting products incorporating vehicular smartwatch systems, related
software and components thereof including, without limitation, smartwatches,
and their respective components that are manufactured outside of the United
States. Moreover, said product either under the doctrine of equivalents, or
directly and/or indirectly infringe the ‘151 Patent. Samsung Electronics Co., Ltd. is
the parent corporation of Respondents Samsung Electronics America, Inc. and
Samsung Telecommunications America LLC. Samsung Electronics Co., Ltd. has
18. 18
primary responsibility for the business planning and manufacturing of Samsung-
branded products
S. Samsung Electronics America, Inc.
43. Samsung Electronics America, Inc. is a New York corporation and a
subsidiary of Samsung Electronics Co., Ltd. This Respondent’s principal place of
business is located at 85 Challenger Rd., Ridgefield Park, NJ, 07660. It may be
contacted with process through its registered agent in the Commonwealth of
Virginia, CT Corporation System, 4701 Cox Rd., Suite 301, Glen Allen, Virginia
23060-6802. Samsung Electronics America, Inc. is responsible for operations that
use, sell, market, distribute, manufacture, sells for importation, imports, and/or
sells after importation into the United States product that either under the
doctrine of equivalents, or directly and/or indirectly infringe the ‘151 Patent.
T. Samsung Telecommunications America LLC
44. Samsung Telecommunications America LLC is a Delaware corporation
and a subsidiary of Samsung Electronics Co., Ltd. This Respondent’s principal
place of business is located at 1301 E. Lookout Drive, Richardson, Texas 75082. It
may be contacted with process through its registered agent in the Commonwealth
of Virginia, Corporation Service Company, 11 S. 12th St., PO Box 1463, Richmond,
Virginia 23218. Samsung Telecommunications America LLC is responsible for
operations that use, sell, market, distribute, manufacture, sells for importation,
imports, and/or sells after importation into the United States product that either
19. 19
under the doctrine of equivalents, or directly and/or indirectly infringe the ‘151
Patent.
45. Upon information and belief, Samsung Electronics America, Inc. and
Samsung Telecommunications America LLC are subsidiaries of Samsung
Electronics Co., Ltd. and bear the primary responsibility for the marketing and
sales of Samsung-branded products within the United States. Upon information
and belief, further discovery will reveal additional details regarding the division of
responsibilities amongst Samsung-family entities. Samsung Electronics Co., Ltd.,
Samsung Electronics America, Inc., and Samsung Telecommunications America
LLC are referred to collectively as “Samsung.”
U. LG Corporation
46. Upon information and belief, LG Corporation is a South Korea
corporation with its principal place of business in Seoul, South Korea. On
information and belief, this Respondent may be contacted with process at its
principal place of business at LG Twin Towers, 20 Yeouido-dong, Yeongdeungpo-
gu, Seoul 150 - 721, South Korea. Further, LG Corporation is in the business of
developing, making, offering for sale, selling, importing, and supporting products
incorporating vehicular smartwatch systems, related software and components
thereof including, without limitation, smartwatches, and their respective
components that are manufactured outside of the United States. Moreover, said
product either under the doctrine of equivalents, or directly and/or indirectly
infringe the ‘151 Patent. LG Corporation is the parent corporation of Respondents
LG Electronics U.S.A., Inc. and LG Electronics MobileComm U.S.A., Inc. LG
20. 20
Corporation has primary responsibility for the business planning and
manufacturing of LG-branded products.
V. LG Electronics U.S.A., Inc.
47. Upon information and belief, LG Electronics U.S.A., Inc. is a Delaware
corporation with its principal place of business at 1000 Sylvan Avenue Englewood
Cliffs, New Jersey, U.S.A. 07632, U.S.A. This Respondent may be contacted with
process in Delaware through its registered agent, United States Corporation
Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
48. LG Electronics U.S.A., Inc. is a subsidiary of LG Corporation and is
responsible for operations that use, sell, market, distribute, manufacture, sells for
importation, imports, and/or sells after importation into the United States product
that either under the doctrine of equivalents, or directly and/or indirectly infringe
the ‘151 Patent.. Upon information and belief, further discovery will reveal
additional details regarding the division of responsibilities amongst LG-family
entities.
W. LG Electronics MobileComm U.S.A., Inc.
49. LG Electronics MobileComm U.S.A., Inc. (“LGM”) is a California
corporation with its principal place of business at 10225 Willow Creek Road, San
Diego, California 92131, and at least one other place of business in the State of
California at 2570 North 1st Street, #360, San Jose, California 95131. On
information and belief, LGM is a wholly-owned subsidiary of LG Electronics U.S.A.,
21. 21
Inc. On information and belief, LGM manufactures, has manufactured, uses, offers
for sale, sells and/or imports into the United States various consumer electronics
products, including smartwatches, conducts primary market and product research
for LG Corporation and LG Electronics U.S.A., Inc. LGM is responsible for
operations that use, sell, market, distribute, manufacture, sells for importation,
imports, and/or sells after importation into the United States that either under the
doctrine of equivalents, or directly and/or indirectly infringe the ‘151 Patent. LG
Corporation, LG Electronics U.S.A., Inc., and LG Electronics MobileComm U.S.A., Inc.
are referred to collectively as “LG.”
X. Sony Corporation
50. Upon information and belief, Sony Corporation is a corporation
organized under the laws of Japan with its principal place of business at 1-7-1
Konan, Minato-ku, Tokyo 108-0075, Japan. Upon information and belief, Sony
Corporation is in the business of developing, making, manufacturing, offering for
sale, selling, importing, and supporting products incorporating vehicular
smartwatch systems, related software and components thereof including, without
limitation, smartwatches, and their respective components that are manufactured
outside of the United States. Moreover, said product either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent. Sony
Corporation is the parent corporation of Respondents Sony Corporation of
America and Sony Electronics, Inc. Sony Corporation has primary responsibility
for the business planning and manufacturing of Sony-branded products.
22. 22
Y. Sony Corporation of America
51. Upon information and belief, Sony Corporation of America ("Sony
America") is a corporation organized under the laws of the State of New York with
its principal place of business at 550 Madison Avenue, New York, New York 10022.
Upon information and belief, Sony America manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that either under the doctrine of equivalents, or directly and/or
indirectly infringe the ‘151 Patent.
Z. Sony Electronics, Inc.
52. Upon information and belief, Sony Electronics, Inc. ("Sony Electronics")
is a corporation organized under the laws of the State of California with its
principal place of business at 16530 Via Esprillo, San Diego, CA 92127. Upon
information and belief, Sony Electronics manufacturers, markets, sells for
importation, imports, and/or sells after importation into the United States
products that either under the doctrine of equivalents, or directly and/or
indirectly infringe the ‘151 Patent.
53. Upon information and belief, Sony America is a subsidiary of Sony
Corporation, and Sony Electronics is a subsidiary of Sony America. Upon
information and belief, Sony America is responsible for business planning and
marketing Sony-branded products within the United States. Upon information and
belief, Sony Electronics has primary responsibility for the marketing and sales of
23. 23
Sony-branded electronic products within the United States. Upon information and
belief, further discovery will reveal additional details regarding the division of
responsibilities amongst Sony family entities. Sony Corporation, Sony Corporation
of America, and Sony Electronics, Inc., are referred to collectively as “Sony.”
AA. Lenovo Group Limited
54. Upon information and belief, Lenovo Group Limited is a corporation
organized and existing under the laws of China, having a principal place of
business at No. 6 Chuang Ye Road, Haidian District, 100085, Beijing, China. Lenovo
Group Limited is in the business of developing, making, manufacturing, offering
for sale, selling, importing, and supporting products incorporating vehicular
smartwatch systems, related software and components thereof including, without
limitation, smartwatches, and their respective components that are manufactured
outside of the United States. Moreover, said product either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent. Lenovo Group
Limited is the parent corporation of Respondents Lenovo (United States), Inc.,
Lenovo Holding Company and Motorola Mobility, Inc. Lenovo Group Limited has
primary responsibility for the business planning and manufacturing of Lenovo and
Motorola branded products.
BB. Lenovo (United States), Inc.
55. Upon information and belief, Lenovo (United States), Inc. is a
corporation organized and existing under the laws of Delaware, having a principal
place of business at The Centre at Purchase, One Manhattanville Road, Purchase,
24. 24
New York, 10577. Upon information and belief, Lenovo (United States), Inc.
manufacturers, markets, sells for importation, imports, and/or sells after
importation into the United States products that either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent.
CC. Lenovo Holding Company, Inc.
56. Upon information and belief, Lenovo Holding Company, Inc. is a
corporation organized and existing under the laws of Delaware having a principal
place of business at 1009 Think Place, Morrisville, North Carolina, 27560. Upon
information and belief, Lenovo Holding Company Inc. manufacturers, markets,
sells for importation, imports, and/or sells after importation into the United States
products that either under the doctrine of equivalents, or directly and/or
indirectly infringe the ‘151 Patent.
57. Upon information and belief, Lenovo (United States), Inc. and Lenovo
Holding Company, Inc. are subsidiaries of Lenovo Group Limited and bear the
primary responsibility for the marketing and sales of Lenovo-branded products
within the United States. Upon information and belief, further discovery will
reveal additional details regarding the division of responsibilities amongst
Lenovo-family entities. Lenovo (United States), Inc., Lenovo Holding Company,
and Lenovo Group Limited are referred to collectively as “Lenovo.”
25. 25
DD. Motorola Mobility, Inc.
58. Upon information and belief, Motorola Mobility, Inc. is a wholly-owned
subsidiary of Lenovo Group Limited organized under the laws of Delaware with its
principal place of business at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago,
Illinois 60654. Motorola Mobility, Inc. is in the business of developing, making,
manufacturing, offering for sale, selling, importing, and supporting products
incorporating vehicular smartwatch systems, related software and components
thereof including, without limitation, smartwatches, and their respective
components that are manufactured outside of the United States. Moreover, said
product either under the doctrine of equivalents, or directly and/or indirectly
infringe the ‘151 Patent.
59. Upon information and belief, further discovery will reveal additional
details regarding the division of responsibilities amongst Motorola-family entities.
Motorola Mobility, Inc. is referred to as “Motorola.”
EE. Apple, Inc.
60. Upon information and belief, Apple, Inc. is a corporation organized and
existing under the laws of California, having a principal place of business at 1
Infinite Loop, Cupertino, CA 95014. Apple’s registered agent, registered with the
Texas State Secretary of State’s Office, is CT Corp. Systems at 350 N. St. Paul Street,
Suite 2900, Dallas, TX 75201
26. 26
61. Upon information and belief, Apple, Inc. is in the business of developing,
making, manufacturing, offering for sale, selling, importing, and supporting
products incorporating vehicular smartwatch systems, related software and
components thereof including, without limitation, smartwatches, and their
respective components that are manufactured outside of the United States.
Moreover, said product either under the doctrine of equivalents, or directly
and/or indirectly infringe the ‘151 Patent. Additionally, Apple, Inc. bears the
primary responsibility for the marketing and sales of Apple-branded products
within the United States. Upon information and belief, further discovery will
reveal additional details regarding the division of responsibilities amongst Apple-
family entities.
FF. Station Digital Media, Inc.
62. Station Digital Media, Inc. is a corporation organized and existing under
the laws of California, having a principal place of business at 111 W Ocean Blvd.
4th Floor Long Beach, CA 90802. Station Digital’s registered agent, registered with
the California State Secretary of State’s Office, is 17140 Bernardo Center Drive,
Suite 354, San Diego, CA 92128.
63. Upon information and belief, Station Digital Media, Inc. is in the business
of developing, making, manufacturing, offering for sale, selling, importing, and
supporting products incorporating vehicular smartwatch systems, related
software and components thereof including, without limitation, smartwatches and
software thereof, and their respective components that are manufactured outside
of the United States. Moreover, said product either under the doctrine of
27. 27
equivalents, or directly and/or indirectly infringe the ‘151 Patent. Additionally,
Station Digital Media, Inc. bears the primary responsibility for the development of
infringing Hyundai-branded products within the United States. Upon information
and belief, further discovery will reveal additional details regarding the division of
responsibilities amongst Hyundai family entities and Station Digital Media, Inc.
GG. Rego Apps, LLC
64. Upon information and belief, Rego Apps, LLC is a corporation organized
and existing under the laws of Florida, having a principal place of business at 217
Acadia Terrace, Celebration, Florida 34747.
65. Upon information and belief, Rego Apps, LLC is in the business of
developing, making, manufacturing, offering for sale, selling, importing, and
supporting products incorporating vehicular smartwatch systems, related
software and components thereof including, without limitation, smartwatches and
software thereof, and their respective components that are manufactured outside
of the United States. Moreover, said product either under the doctrine of
equivalents, or directly and/or indirectly infringe the ‘151 Patent. Rego Apps, LLC
bears the primary responsibility for the development of infringing smartwatch
products, component and/or software. Upon information and belief, further
discovery will reveal additional details regarding the division of responsibilities
amongst Rego Apps, LLC family entities.
28. 28
IV. TECHNOLOGY AND PRODUCTS AT ISSUE
66. The technology at issue relate to smartwatch vehicular systems and
certain components and software therein.
67. Specifically, the Accused Products smartwatch vehicular systems,
components, and software therein, such as wristwatches and their on-board
components, operating systems, and/or other software. These smart watches and
connected vehicle devices, components, operating systems, and other software are
imported into the United States and in turn used by businesses, institutions,
service providers, and other entities in the United States to supply networks and
transport data, voice, and video. By way of example, the Accused Products may be
deployed on individually owned vehicles or vehicle fleets with dedicated
computing center environments in connection with an organization's servers,
associated data, and/or IT applications and between such items and other
networks such as the Internet. The Accused Products are sold for importation into,
imported into, sold after importation into, and used within the United States by or
on behalf of each Respondent.
V. PATENT IN SUIT
68. From its research and development on vehicle security systems,
including its smartwatch vehicular systems technology, ICC obtained, on June 27,
2006, the duly, properly and legally issued U.S. Patent No. 7,068,151, entitled
"Vehicle Security System." ICC obtained the '151 Patent as assignee of named
29. 29
inventor and ICC founder, Samuel K. Giles, and exclusive licensee of named
inventor Christopher E. Smith. See Exhibits 2, 3 & Confidential Exhibit 52.
69. Generally speaking, the ICC '151 Patent is directed to smartwatch
operated vehicular security systems. The system generally includes a smartwatch
that communicates with an on-board vehicular control unit, thus providing end
users with vehicular security and convenience features such as remote door lock
and unlock, trunk release, and remote engine start.
70. Samuel K. Giles and Christopher E. Smith are the named inventors of
the ICC '151 Patent. As a part of his fiduciary duty with ICC, Samuel K. Giles
assigned all rights, title, and interest in the ICC '151 Patent to ICC. Additionally,
co-inventor Mr. Smith has also exclusively licensed to ICC all substantial rights in
the ’151 patent, including the right to exclude others and to enforce, sue, and
recover damages for past and future infringements. See Exhibit 2 & Confidential
52.
71. Pursuant to Commission Rule 210.12(c), copies of the certified
prosecution history of the ICC Asserted Patent have been submitted with this
Complaint as Appendices A. Pursuant to Commission Rule 210.12(c), the cited
references for the ICC Asserted Patents also have been submitted with this
Complaint as Appendices B.
30. 30
VI. NONTECHNICAL DESCRIPTION OF THE INVENTION
72. Pursuant to United States Patent No. 7,068,151 (‘151 Patent), entitled
"Vehicle Security System," issued on June 27, 2006 and lists Samuel K. Giles and
Christopher E. Smith as its inventors. The ‘151 Patent expires on June 27, 2023.
The ‘151 Patent claims priority to U.S. Provisional Patent App. No. 60/470,566,
filed on May 14, 2003.
73. The ‘151 Patent contains 22 claims, including 1 independent claim and
21 dependent claims. ICC asserts that Respondent's smartwatch enabled vehicular
system components and software therein, and activities relating thereto, infringe
at least system claim 1, and dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21,
& 22 of the ‘151 Patent, directly or indirectly, either literally or under the doctrine
of equivalents.
74. The ‘151 Patent generally relates to a system for improved
communication between wearable technology devices and connected vehicles.
Further, the ‘151 Patent discusses remote watch design for a car security system.
A user of the smartwatch will not only be able to keep track of the time but also
will be able to arm/lock, disarm/unlock and remotely start their vehicle by
interfacing with the watch. It is common for people to lose or misplace their keys
along with the keyless remote that is attached to the keys. Since the watch is
conveniently located on the users wrist, the user never has to worry about damage
due to dropping it on a hard surface, in liquids (ex. water), or even losing their
keyless remote as you would by having a keyless remote attached to keys or a key
31. 31
chain. If the user ever loses their keys or locks them in a trunk, the remote watch
will allow the user to maintain access to their vehicle.
VII. UNLAWFUL AND UNFAIR ACTS OF RESPONDENTS – PATENT INFRINGEMENT
75. The Respondents have engaged in unlawful and unfair acts including the
sale for importation into the United States, importation into the United States, sale
within the United States after importation, and/or use within the United States
after importation of the Accused Products that infringe one or more of the
following claims (independent claims in bold):
76. Upon information and belief, the Respondents import, sell for
importation, sell after importation into the United States, and/or uses after
importation into the United States Accused Products that infringe the ‘151 Patent.
77. The Accused Products infringe, directly and/or indirectly, at least system
claim 1, and dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 of the
‘151 Patent. Respondents directly and/or indirectly infringe at least system claim
1, and dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 of the ‘151
Patent by importing, selling for importation, selling after importation, and/or
using after importation into the United States the Accused Products. See Exhibits
5-32 (infringement claim charts for U.S. Patent No. 7,068,151). The Accused
Patent Number Asserted Claims
7,068,151 (Independent claim in bold)
Independent 1
Dependent 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, 22
32. 32
Products satisfy all claim limitations system claim 1, and dependent claims 2, 3, 4,
5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 at the time of importation, and Respondents
directly infringe the apparatus claim by importing, selling for importation, selling
after importation, and/or using after importation into the United States the
Accused Products. The Accused Products, at the time of importation, are capable
to dictate the performance of and mimic system claim 1 and all aspects of
dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22, and Respondents
directly infringe this claim by importing, selling for importation, selling after
importation, and/or using after importation into the United States the Accused
Products. In addition, as further alleged below, Respondents indirectly infringe
the apparatus claim by importing, selling for importation, selling after
importation, and/or using after importation into the United States the Accused
Products.
78. The Respondents actively induce others, including purchasers and end
users who deploy the Accused Products in their networks, to directly infringe at
least system claim 1, and dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, &
22 of the ‘151 Patent. On information and belief, purchasers who deploy the
Accused Products in their networks and make routine use of the Accused
Products, also directly infringe at least system claim 1, and dependent claims 2, 3,
4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 of the ‘151 Patent. Respondents are aware of
the ‘151 Patent at least because the Respondents have had actual knowledge of the
‘151 Patent at least as of June 2 2015, when ICC filed a Complaint asserting the
‘151 Patent against Respondents in the Eastern District of Texas, as discussed in
Section X, below. Further, in light of the above, Respondents knowingly induces
infringement of the ‘151 Patent with specific intent to do so by providing at least
33. 33
manuals, white papers, training, and/or other support, to perform acts intended
by Respondents to cause direct infringement of at least system claim 1, and
dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 of the ‘151 Patent.
79. Respondents contribute to infringement of at least system claim 1, and
dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 of the ‘151 Patent,
including purchasers who deploy the Accused Products in their vehicular systems,
by providing the Accused Products, which are specially made or adapted for use in
an infringement of these claims and are not staple articles of commerce suitable
for substantial non-infringing use. Respondents are aware of the ‘151 Patent at
least because Respondents have had actual knowledge of the ‘151 Patent at least
as of June 2, 2015, when ICC filed a Complaint asserting the ‘151 Patent against
Respondents in the Eastern District of Texas, as discussed in Section X, below.
Further, having debuted the technology during the 2014 international SEMA trade
show, Respondents are aware of the ‘151 Patent. In light of these allegations,
Respondents had knowledge that the Accused Products were specially made or
adapted for use in an infringement of the ‘151 Patent and not a staple article of
commerce suitable for substantial non-infringing use.
80. Claim charts comparing the ‘151 Patent's asserted independent system
claim 1, and dependent claims 2, 3, 4, 5, 8, 10, 12, 14, 18, 19, 20, 21, & 22 to
Respondents’ Accused Products are attached as Exhibits 5-32. Additional
evidence of importation is set forth below.
34. 34
A. Hyundai Motor Company
81. Upon information and belief, Hyundai manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Hyundai Products").
82. The Accused Hyundai Products include vehicles sold under the following
names and model numbers:
83. Upon information and belief, the Accused Hyundai Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Hyundai.
These acts of Hyundai constitute direct infringement of the ‘151 Patent. Claim
charts demonstrating how the Accused Hyundai Products directly infringe the
‘151 Patent are attached as Exhibit 6.
Company
Hyundai
Azera Elantra Equus Genesis Genesis Coupe
Sonata Sonata Hybrid Tucson Veloster
Azera Elantra Elantra Coupe Elantra GT Equus
Genesis Genesis Coupe Sante Fe Sante Fe Sport Sonata
Sonata Hybrid Tucson Veloster
Azera Elantra GT Genesis Genesis Coupe Sante Fe
Sante Fe Sport Sonata Sonata Hybrid Veloster
2012 Azera Sonata Sonata Hybrid Veloster
2013
Product - Bluelink ®
Models
2015
2014
35. 35
84. These acts of Hyundai also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Hyundai Products indirectly infringe the ‘151 Patent is attached as Exhibit 6.
85. Hyundai is a contributory infringer because the Accused Hyundai
Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Hyundai has
previously been given actual knowledge of the ‘151 Patent at least as of June 2,
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Hyundai
knows that the Accused Hyundai Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
B. General Motors Company & OnStar, LLC.
86. GM manufactures, markets, sells for importation, imports, and/or sells
after importation into the United States products that directly and/or indirectly
infringe the ‘151 Patent ("the Accused GM Products").
87. The Accused GM Products include vehicles sold under the following
names and model numbers:
36. 36
Company
GM / OnStar
Camaro Cruze Malibu Spark T ahoe
Captiva Equinox Orlando Spark EV T raverse
Colorado Express Silverado SS Performance Sedan T rax
Corvette Impala Sonic Suburban Volt
2015 Buick Enclave Encore LaCrosse Regal Verano
Acadia Canyon Denali Savana Sierra
T errain Yukon Yukon XL
AT S CT S CT S-V ELR Escalade
Escalade ESV SRX Stretch Limo XT S
Avalanche Camaro Captiva Corvette Cruze
Equinox Express Impala Malibu Orlando
Silverado Sonic Spark SS Suburban
T ahoe T raverse T rax Volt
2014 Buick Enclave Encore LaCrosse Regal Verano
Acadia Denali Savana Sierra T errain
Yukon
AT S CT S ELR Escalade SRX
XT S
Avalanche Camaro Captiva Cruze Equinox
Express Impala Malibu Silverado Sonic
Spark Suburban T ahoe T raverse Volt
2013 Buick Enclave Encore LaCrosse Regal Verano
Acadia Denali Savana Sierra T errain
Yukon
2013 Cadillac AT S CT S Escalade SRX XT S
Avalanche Camaro Captiva Cruze Equinox
Express Impala Malibu Silverado Sonic
Suburban T ahoe T raverse Volt
2012 Buick Enclave LaCrosse Regal Verano
2012 GMC Acadia Savana Sierra T errain Yukon
2012 Cadillac CT S Escalade SRX
Avalanche Camaro Cruze Equinox Express
HHR Impala Malibu Suburban T ahoe
T raverse Volt
2011 Buick Enclave LaCrosse Lucerne Regal
2011 GMC Acadia Savana Sierra T errain Yukon
2011 Cadillac CT S DT S Escalade SRX
Avalanche HHR Impala Malibu Silverado
Suburban T ahoe T raverse
2010 Buick Enclave Lucerne
2010 GMC Acadia Yukon
2010 Cadillac DT S Escalade
2014 Chevrolet
Product - RemoteLink ®
Model
2015 Chevrolet
2015 GMC
2015 Cadillac
2010 Chevrolet
2014 GMC
2014 Cadillac
2013 Chevrolet
2013 GMC
2012 Chevrolet
2011 Chevrolet
37. 37
88. On information and belief, the Accused GM Products are, whole or in
part, manufactured, assembled, and/or packaged outside of the United States.
These same products are then imported into the United States, sold for
importation into the United States, and/or sold after importation into the United
States by GM. These acts of GM constitute direct infringement of the ‘151 Patent.
Claim charts demonstrating how the Accused GM Products directly infringe the
‘151 Patent are attached as Exhibit 8.
89. These acts of GM also constitute contributory and induced infringement
of the ‘151 Patent. Claim charts demonstrating how the Accused GM Products
indirectly infringe the ‘151 Patent is attached as Exhibit 8.
90. GM is a contributory infringer because the Accused GM Products are not
staple articles of commerce and are not suitable for any substantial non-infringing
use. To the contrary, their sole, substantial use is to be used in infringing systems
as shown in the attached claim charts. GM has previously been given actual
knowledge of the ‘151 Patent at least as of June 2, 2015, when ICC filed a
Complaint asserting the ‘151 Patent against Respondents in the Eastern District of
Texas of their contributory infringement, and GM knows that the Accused GM
Products are specially adapted for use in practicing the inventions of the ‘151
Patent.
C. Volkswagen AG
91. Upon information and belief, Volkswagen manufactures, markets, sells
for importation, imports, and/or sells after importation into the United States
38. 38
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Volkswagen Products").
92. The Accused Volkswagen Products include vehicles sold under the
following names and model numbers:
93. On information and belief, the Accused Volkswagen Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by
Volkswagen. These acts of Volkswagen constitute direct infringement of the ‘151
Patent. Claim charts demonstrating how the Accused Volkswagen Products
directly infringe the ‘151 Patent is attached as Exhibit 10.
94. These acts of Volkswagen also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Volkswagen Products indirectly infringe the ‘151 Patent is attached as Exhibit 10.
95. Volkswagen is a contributory infringer because the Accused Volkswagen
Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Volkswagen has
previously been given actual knowledge of the ‘151 Patent at least as of June 2,
Company
Volkswagen
2015
Model
e-Golf
Product
39. 39
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Volkswagen
knows that the Accused Volkswagen Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
D. Audi AG
96. Upon information and belief, Audi manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Audi Products").
97. The Accused Audi Products include vehicles sold under the following
names and model numbers:
98. On information and belief, the Accused Audi Products are manufactured,
assembled, and/or packaged outside of the United States. These same products
are then imported into the United States, sold for importation into the United
States, and/or sold after importation into the United States by Audi. These acts of
Audi constitute direct infringement of the ‘151 Patent. Claim charts demonstrating
how the Accused Audi Products directly infringe the ‘151 Patent are attached as
Exhibit 12.
Company
Audi
2015
Product
Model
Q7
40. 40
99. These acts of Audi also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Audi Products indirectly infringe the ‘151 Patent is attached as Exhibit 12.
100. Audi is a contributory infringer because the Accused Audi Products are
not staple articles of commerce and are not suitable for any substantial non-
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. Audi has previously been
given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when ICC
filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and Audi knows that the
Accused Audi Products are specially adapted for use in practicing the inventions of
the ‘151 Patent.
E. BMW
101. Upon information and belief, BMW manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
BMW Products").
102. The Accused BMW Products include vehicles sold under the following
names and model numbers:
41. 41
103. On information and belief, the Accused BMW Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by BMW.
These acts of BMW constitute direct infringement of the ‘151 Patent. Claim charts
demonstrating how the Accused BMW Products directly infringe the ‘151 Patent
are attached as Exhibit 14.
104. These acts of BMW also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
BMW Products indirectly infringe the ‘151 Patent is attached as Exhibit 14.
105. BMW is a contributory infringer because the Accused BMW Products are
not staple articles of commerce and are not suitable for any substantial non-
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. BMW has previously
been given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when
ICC filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and BMW knows that the
Accused BMW Products are specially adapted for use in practicing the inventions
of the ‘151 Patent.
Company
BMW
2015
2015
Product - BMW I Remote®
Model
i8
i3
42. 42
F. Dr. Ing. h.c. F. Porsche AG
106. Upon information and belief, Porsche AG manufactures, markets, sells
for importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Porsche AG Products").
107. The Accused Porsche AG Products include vehicle sold under the
following names and model numbers:
108. On information and belief, the Accused Porsche AG Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Porsche
AG. These acts of Porsche AG constitute direct infringement of the ‘151 Patent.
Claim charts demonstrating how the Accused Porsche AG Products directly
infringe the ‘151 Patent are attached as Exhibit 16.
109. These acts of Porsche AG also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Porsche AG Products indirectly infringe the ‘151 Patent is attached as Exhibit 16.
Company
Porsche AG
Panamera 918 Spyder Macan Cayenne
Panamera 918 Spyder Macan Cayenne
2015
2014
Product - Porsche Car Connect ®
Models
43. 43
110. Porsche AG is a contributory infringer because the Accused Porsche AG
Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Porsche AG has
previously been given actual knowledge of the ‘151 Patent at least as of June 2,
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Porsche AG
knows that the Accused Porsche AG Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
G. DEI Holdings, Inc.
111. Upon information and belief, Directed Electronics manufactures,
markets, sells for importation, imports, and/or sells after importation into the
United States products that directly and/or indirectly infringe the ‘151 Patent
("the Accused Directed Electronics Products").
112. The Accused Directed Electronics Products include vehicle security
systems sold under the following names and model numbers:
Company
Directed Electronics
Viper SmartStart
Model
VSS5000
VMS250
Product
VSS3001
44. 44
113. On information and belief, the Accused Directed Electronics Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Directed
Electronics. These acts of Directed Electronics constitute direct infringement of
the ‘151 Patent. Claim charts demonstrating how the Accused Directed Electronics
Products directly infringe the ‘151 Patent are attached as Exhibit 18.
114. These acts of Directed Electronics also constitute contributory and
induced infringement of the ‘151 Patent. Claim charts demonstrating how the
Accused Directed Electronics Products indirectly infringe the ‘151 Patent is
attached as Exhibit 18.
115. Directed Electronics is a contributory infringer because the Accused
Directed Electronics Products are not staple articles of commerce and are not
suitable for any substantial non-infringing use. To the contrary, their sole,
substantial use is to be used in infringing systems as shown in the attached claim
charts. Directed Electronics has previously been given actual knowledge of the
‘151 Patent at least as of June 2, 2015, when ICC filed a Complaint asserting the
‘151 Patent against Respondents in the Eastern District of Texas of their
contributory infringement, and Directed Electronics knows that the Accused
Directed Electronics Products are specially adapted for use in practicing the
inventions of the ‘151 Patent.
45. 45
H. Samsung Electronics Co., Ltd.
116. Upon information and belief, Samsung manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Samsung Products").
117. The Accused Samsung Products include smartwatches sold under the
following names and model numbers:
118. On information and belief, the Accused Samsung Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by
Samsung. These acts of Samsung constitute direct infringement of the ‘151 Patent.
Claim charts demonstrating how the Accused Samsung Products directly infringe
the ‘151 Patent are attached as Exhibit 20.
119. These acts of Samsung also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Samsung Products indirectly infringe the ‘151 Patent is attached as Exhibit 20.
Company
Samsung
Gear Live
Product
Model
Galaxy Gear 2 (tizen)
Galaxy Gear 2 (Andriod Wear)
46. 46
120. Samsung is a contributory infringer because the Accused Samsung
Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Samsung has
previously been given actual knowledge of the ‘151 Patent at least as of June 2,
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Samsung
knows that the Accused Samsung Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
I. LG Corporation
121. Upon information and belief, LG manufactures, markets, sells for
importation, import, and/or sells after importation into the United States products
that directly and/or indirectly infringe the ‘151 Patent ("the Accused LG
Products").
122. The Accused LG Products include smartwatches sold under the following
names and model numbers:
Company
LG
G Watch R
Model
G Watch
Product
47. 47
123. On information and belief, the Accused LG Products are manufactured,
assembled, and/or packaged outside of the United States. These same products
are then imported into the United States, sold for importation into the United
States, and/or sold after importation into the United States by LG. These acts of LG
constitute direct infringement of the ‘151 Patent. Claim charts demonstrating how
the Accused LG Products directly infringe the ‘151 Patent are attached as Exhibit
22.
124. These acts of LG also constitute contributory and induced infringement
of the ‘151 Patent. Claim charts demonstrating how the Accused LG Products
indirectly infringe the ‘151 Patent is attached as Exhibit 22.
125. LG is a contributory infringer because the Accused LG Products are not
staple articles of commerce and are not suitable for any substantial non-infringing
use. To the contrary, their sole, substantial use is to be used in infringing systems
as shown in the attached claim charts. LG has previously been given actual
knowledge of the ‘151 Patent at least as of June 2, 2015, when ICC filed a
Complaint asserting the ‘151 Patent against Respondents in the Eastern District of
Texas of their contributory infringement, and LG knows that the Accused LG
Products are specially adapted for use in practicing the inventions of the ‘151
Patent.
J. Sony Corporation
126. Upon information and belief, Sony manufactures, markets, sells for
importation, import, and/or sells after importation into the United States products
48. 48
that directly and/or indirectly infringe the ‘151 Patent ("the Accused Sony
Products").
127. The Accused Sony Products include smartwatches sold under the
following names and model numbers:
128. Upon information and belief, the Accused Sony Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Sony.
These acts of Sony constitute direct infringement of the ‘151 Patent. Claim charts
demonstrating how the Accused Sony Products directly infringe the ‘151 Patent
are attached as Exhibit 24.
129. These acts of Sony also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Sony Products indirectly infringe the ‘151 Patent is attached as Exhibit 24.
130. Sony is a contributory infringer because the Accused Sony Products are
not staple articles of commerce and are not suitable for any substantial non-
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. Sony has previously
been given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when
Company
Sony Model
Smartwatch 3
Product
49. 49
ICC filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and Sony knows that the
Accused Sony Products are specially adapted for use in practicing the inventions of
the ‘151 Patent.
K. Lenovo Group Limited
131. Upon information and belief, Lenovo manufactures, markets, sells for
importation, imports, and/or sells after importation into the United States
products that directly and/or indirectly infringe the ‘151 Patent ("the Accused
Lenovo Products").
132. The Accused Lenovo Products include smartwatches sold under the
following names and model numbers:
133. On information and belief, the Accused Lenovo Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Lenovo.
These acts of Lenovo constitute direct infringement of the ‘151 Patent. Claim
charts demonstrating how the Accused Lenovo Products directly infringe the ‘151
Patent are attached as Exhibit 26.
Company
Lenovo / Motorola
Moto 360
Product
Model
50. 50
134. These acts of Lenovo also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Lenovo Products indirectly infringe the ‘151 Patent is attached as Exhibit 26.
135. Lenovo is a contributory infringer because the Accused Lenovo Products
are not staple articles of commerce and are not suitable for any substantial non-
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. Lenovo has previously
been given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when
ICC filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and Lenovo knows that the
Accused Lenovo Products are specially adapted for use in practicing the
inventions of the ‘151 Patent.
L. Motorola Mobility, Inc.
136. Upon information and belief, Motorola manufactures, markets, sells for
importation, import, and/or sells after importation into the United States products
that directly and/or indirectly infringe the ‘151 Patent ("the Accused Motorola
Products").
137. The Accused Motorola Products include smartwatches sold under the
following names and model numbers:
Company
Lenovo / Motorola
Moto 360
Product
Model
51. 51
138. On information and belief, the Accused Motorola Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by
Motorola. These acts of Motorola constitute direct infringement of the ‘151 Patent.
Claim charts demonstrating how the Accused Motorola Products directly infringe
the ‘151 Patent are attached as Exhibit 26.
139. These acts of Motorola also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Motorola Products indirectly infringe the ‘151 Patent is attached as Exhibit 26.
140. Motorola is a contributory infringer because the Accused Motorola
Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Motorola has
previously been given actual knowledge of the ‘151 Patent at least as of June 2,
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Motorola
knows that the Accused Motorola Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
52. 52
M. Apple, Inc.
141. Apple manufactures, markets, sells for importation, import, and/or sells
after importation into the United States products that directly and/or indirectly
infringe the ‘151 Patent ("the Accused Apple Products").
142. The Accused Apple Products include smartwatches sold under the
following names and model numbers:
143. On information and belief, the Accused Apple Products are
manufactured, assembled, and/or packaged outside of the United States. These
same products are then imported into the United States, sold for importation into
the United States, and/or sold after importation into the United States by Apple.
These acts of Apple constitute direct infringement of the ‘151 Patent. Claim charts
demonstrating how the Accused Apple Products directly infringe the ‘151 Patent
are attached as Exhibit 28.
144. These acts of Apple also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Apple Products indirectly infringe the ‘151 Patent is attached as Exhibit 28.
145. Apple is a contributory infringer because the Accused Apple Products
are not staple articles of commerce and are not suitable for any substantial non-
Company
Apple
Product
Model
Apple Watch
53. 53
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. Apple has previously
been given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when
ICC filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and Apple knows that the
Accused Apple Products are specially adapted for use in practicing the inventions
of the ‘151 Patent.
N. Station Digital Media, Inc.
146. Station Digital manufactures and develops for importation, import,
and/or sells after importation into the United States products that directly and/or
indirectly infringe the ‘151 Patent ("the Accused Station Digital Products").
147. The Accused Station Digital Products include smartwatch vehicular
systems components and/or software sold under the following names and model
numbers:
54. 54
148. On information and belief, the Accused Station Digital Products are
developed, manufactured, assembled, and/or packaged outside of the United
States. These same products are then imported into the United States, sold for
importation into the United States, and/or sold after importation into the United
States by Hyundai Motor Company. These acts of Station Digital constitute direct
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Station Digital Products directly infringe the ‘151 Patent are attached as Exhibit
30.
149. These acts of Station Digital also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Station Digital Products indirectly infringe the ‘151 Patent is attached as Exhibit
30.
150. Station Digital is a contributory infringer because the Accused Station
Digital Products are not staple articles of commerce and are not suitable for any
substantial non-infringing use. To the contrary, their sole, substantial use is to be
used in infringing systems as shown in the attached claim charts. Station Digital
has previously been given actual knowledge of the ‘151 Patent at least as of June 2,
2015, when ICC filed a Complaint asserting the ‘151 Patent against Respondents in
the Eastern District of Texas of their contributory infringement, and Station Digital
knows that the Accused Station Digital Products are specially adapted for use in
practicing the inventions of the ‘151 Patent.
55. 55
O. Rego Apps, LLC
151. Upon information and belief, Rego manufactures and develops for
importation, import, and/or sells after importation into the United States products
that directly and/or indirectly infringe the ‘151 Patent ("the Accused Rego
Products").
152. The Accused Rego Products include smartwatch vehicular systems
components and/or software sold under the following names and model numbers:
153. On information and belief, the Accused Rego Products are imported into
the United States, sold for importation into the United States, and/or sold after
importation into the United States by Rego. These acts of Rego constitute direct
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Rego Products directly infringe the ‘151 Patent are attached as Exhibit 32.
154. These acts of Rego also constitute contributory and induced
infringement of the ‘151 Patent. Claim charts demonstrating how the Accused
Rego Products indirectly infringe the ‘151 Patent is attached as Exhibit 32.
155. Rego is a contributory infringer because the Accused Rego Products are
not staple articles of commerce and are not suitable for any substantial non-
Company
BMW
2015
Product
Model
Rego S
56. 56
infringing use. To the contrary, their sole, substantial use is to be used in
infringing systems as shown in the attached claim charts. Rego has previously
been given actual knowledge of the ‘151 Patent at least as of June 2, 2015, when
ICC filed a Complaint asserting the ‘151 Patent against Respondents in the Eastern
District of Texas of their contributory infringement, and Rego knows that the
Accused Rego Products are specially adapted for use in practicing the inventions
of the ‘151 Patent.
VIII. SPECIFIC INSTANCES OF UNFAIR IMPORTATION AND SALE
156. The Proposed Respondents have sold for importations, imported, and/or
sold after importation in the United States Accused Products as identified below.
157. The United States National Highway Traffic Safety Administration
requires that all “passenger cars, multipurpose passenger vehicles, trucks, buses,
trailers (including trailer kits), incomplete vehicles, and motorcycles” bear a 17-
character vehicle identification number (VIN). (49 C.F.R. 565.1 et seq.) The VIN is
assigned by the automobile manufacturer, and must be affixed on the car in a
location that is not designed to be removed. Typically, the VIN is listed at least on
a sticker inside the driver’s door panel, as well as on a panel on the dash-board
facing out the windshield just above the steering wheel.
158. The first three digits of the VIN identify the manufacturer, make and type
of motor vehicle. The first digit typically identifies the country of final assembly,
for example vehicles with VIN’s that begin in the letter “J” are manufactured in
57. 57
Japan, those that begin in the number “3” are manufactured in Mexico, etc. A
sampling of codes as relevant to the exemplary Accused Products follows:
2 = Canada J = Japan 3 = Mexico K = Republic of Korea
W = Germany Y = Sweden S = England
159. The VIN of each of the exemplary Accused Products begins in a character
indicating that the automobile was made outside the United States. The
exemplary Accused Products were all offered for sale or sold in the United States.
This proves that the exemplary Accused Products were each manufactured abroad
and imported into the United States. The VIN for each exemplary accused product
is identified below and in the supporting claim charts at Exhibits 5-32.
160. Further, the Automobile Information Disclosure Act of 1958, 15 U.S.C. §§
1231-1233, requires:
“Every manufacturer of new automobiles distributed in commerce shall… securely
affix to the windshield, or side window of such automobile a label on which such
manufacturer shall endorse clearly, distinctly and legibly true and correct entries
disclosing the following information concerning such automobile - the final
assembly point.”
161. Even for automobiles that were finally assembled in the United States,
many such automobiles use smartwatch vehicular systems manufactured abroad
and imported into the United States. Such products are similarly embodied in the
scope of this Complaint.
58. 58
A. Hyundai Motor Company
162. Upon information and belief, Hyundai sells for importation, imports,
and/or sells after importation into the United States the Accused Hyundai
Products, for example, the Hyundai Elantra GT with Blue Link ® smartwatch
application. One 2015 Hyundai Sonata bears the VIN KMHD35LH2FU242485,
indicating that it was manufactured in Ulsan, Korea
163. Further, the Automobile Information Disclosure Act sticker at Exhibit 5
reveals that the Accused Hyundai Products are being imported, distributed for
commerce, and are widely available for sale in the United States.
164. The 2015 Hyundai Elantra GTand other Accused Hyundai Products are
available at Hyundai dealers nationwide, including but not limited to Planet
Hyundai located at 15601 W Colfax Ave Golden, CO 80401.
B. General Motors Company & OnStar, LLC.
165. Upon information and belief, GM sells for importation, imports, and/or
sells after importation into the United States the Accused GM Products, for
example, the Chevrolet, Buick, GMC and Cadillac brands with the OnStar
RemoteLink ® smartwatch application. One 2015 Chevrolet Camaro bears the
VIN 2G1FB3D34E9170555, indicating that it was manufactured Oshawa, ON
Canada.
59. 59
166. Further, the Automobile Information Disclosure Act sticker at Exhibit 7
reveals that the Accused GM Products are being imported, distributed for
commerce, and are widely available for sale in the United States.
167. The 2015 Chevrolet Camaro and other Accused GM Products are
available at GM dealers nationwide, including but not limited to Medved Chevrolet
Cadillac located at 11001 Interstate 70 Frontage Road North, Wheat Ridge, CO
80033.
C. Volkswagen AG
168. Upon information and belief, Volkswagen sells for importation, imports,
and/or sells after importation into the United States the Accused Volkswagen
Product, for example, the e-Golf with smartwatch keyfob applications. One 2015
e-Golf bears the VIN WVWKP7AU4FW90698 indicating that it was manufactured
in Germany.
169. Further, the Automobile Information Disclosure Act sticker at Exhibit 9
reveals that the Accused Volkswagen Product are being imported, distributed for
commerce, and are widely available for sale in the United States.
170. The 2015 e-Golf is available at Volkswagen dealers nationwide, including
but not limited to Coastal Volkswagen located at 1 Saturn Drive Hanover, MA
02339.
60. 60
D. Audi AG
171. Upon information and belief, Audi sells for importation, imports, and/or
sells after importation into the United States the Accused Audi Product, for
example, the Audi Q7 with smartwatch keyfob applications. One 2015 Audi Q7
bears the VIN WA1CGAFP5FAO34516, indicating that it was manufactured in
Germany.
172. Further, the Automobile Information Disclosure Act sticker at Exhibit 11
reveals that the Accused Audi Product are being imported, distributed for
commerce, and are widely available for sale in the United States.
173. The 2015 Audi Q7 and other Accused Audi Products are available at Audi
dealers nationwide, including but not limited to Audi Denver located at 6060 S
Broadway, Littleton, CO 80121.
E. BMW AG
174. Upon information and belief, BMW sells for importation, imports, and/or
sells after importation into the United States the Accused BMW Product, for
example, the BMW i3 with smartwatch keyfob applications. One 2015 BMW i3
bears the VIN WBY1Z2C50EVX51234, indicating that it was manufactured in
Germany.
175. Further, the Automobile Information Disclosure Act sticker at Exhibit 13
reveals that the Accused BMW Products are being imported, distributed for
commerce, and are widely available for sale in the United States.
61. 61
176. The 2015 BMW i3 and other Accused BMW Products are available at
BMW dealers nationwide, including but not limited to BMW of Denver located at
2910 S Havana St, Aurora, CO 80014.
F. Porsche AG
177. Upon information and belief, Porsche AG sells for importation, imports,
and/or sells after importation into the United States the Accused Porsche AG
Product, for example, the Porsche Cayenne Turbo S with smartwatch keyfob
applications. One 2014 Porsche Cayenne Turbo S bears the VIN
WP1AC2A28ELA85911, indicating that it was manufactured in Germany.
178. Further, the Automobile Information Disclosure Act sticker at Exhibit 15
reveals that the Accused Porsche AG Products are being imported, distributed for
commerce, and are widely available for sale in the United States.
179. The 2014 Porsche Cayenne Turbo S and other Accused Porsche AG
Products are available at Porsche dealers nationwide, including but not limited to
Stevinson Imports, 5500 South Broadway, Littleton, CO 80121.
G. DEI Holdings, Inc.
180. Upon information and belief, prior to filing this Complaint,
representatives for ICC purchased representative Accused Directed Electronics
Products in the United States. A copy of a receipt of one of those purchases is
62. 62
attached hereto as Exhibit 33. The packaging for these Accused Directed
Electronics Products indicates that the products were made outside the United
States. For example, the packaging of the representative Accused Directed
Electronics Product states that it was "Made in China."
H. Samsung Electronics Co., Ltd.
181. Upon information and belief, prior to filing this Complaint,
representatives for ICC purchased representative Accused Samsung Products in
the United States. A copy of a receipt of one of those purchases is attached hereto
as Exhibit 34. The packaging for these Accused Samsung Products indicates that
the products were made outside the United States. For example, the packaging of
the representative Accused Samsung Product states that it was "Made in Vietnam."
I. LG Corporation
182. Upon information and belief, prior to filing this Complaint,
representatives for ICC purchased representative Accused LG Products in the
United States. A copy of a receipt of one of those purchases is attached hereto as
Exhibit 35. The packaging for these Accused LG Products indicates that the
products were made outside the United States. For example, the packaging of the
representative Accused LG Product states that it was "Made in Korea."
63. 63
J. Sony Corporation
183. Upon information and belief, Upon information and belief, prior to filing
this Complaint, representatives for ICC purchased representative Accused Sony
Products in the United States. A copy of a receipt of one of those purchases is
attached hereto as Exhibit 36. The packaging for these Accused Sony Products
indicates that the products were made outside the United States. For example, the
packaging of the representative Accused Sony Product states that it was "Made in
China."
K. Lenovo Group Limited / Motorola Mobility, Inc.
184. Upon information and belief, prior to filing this Complaint,
representatives for ICC purchased representative Accused Motorola Products in
the United States. A copy of a receipt of one of those purchases is attached hereto
as Exhibit 37. The packaging for these Accused Motorola Products indicates that
the products were made outside the United States. For example, the packaging of
the representative Accused Motorola Product states that it was "Made in China."
IX. HARMONIZED TARIFF SCHEDULE ITEM NUMBERS
185. Upon information and belief, the Accused Products fall within at least the
8511.80.20, 8525.20.9080, and/or 9102.19.20 classification of the Harmonized
Tariff Schedule ("HTS") of the United States. See Exhibit 4. The identified HTS
number is intended to be for illustration only and is not exhaustive of the products
64. 64
accused of infringement in this Complaint. The HTS number is not intended to
limit the scope of the Investigation.
X. FOREIGN PATENTS CORRESPONDING
186. In accordance with Commission Rule 2l0.l2(a)(9)(v), ICC is unaware of any
foreign counterparts to the asserted ‘151 Patent.
XI. RELATED LITIGATION
187. On June 2, 2015, ICC filed a Complaint in the Eastern District of Texas,
accusing Hyundai Motor Company et al et al. of infringing ICC’s Asserted Patents.
See Exhibit 40 (Intellectual Capital Consulting, Ltd. v. Hyundai Motor Company et al.,
Case No. 2:15-cv-00917-RWS-RSP. Discovery has not yet commenced in this
action.
XII. THE DOMESTIC INDUSTRY
188. In accordance with 19 U.S.C. § 1337(a)(2) and 19 U.S.C. § 1337(a)(3), a
domestic industry exists and is also in the process of being established in the
United States in connection with the ‘151 Patent. Specifically, ICC has established
and is actively engaged in developing a domestic industry in the United States in
products covered by the ‘151 Patent. Furthermore, ICC has made significant
investments in engineering hours, research and development, pre-and post-
manufacturing activities in the United States, such as conceptualizing product
requirements and specifications, simulating designs, testing, marketing and selling
65. 65
to support its products practicing the Asserted Patent. Additionally, ICC does not
have any licensees and is not relying upon any license to establish standing or
satisfy the domestic injury requirement.
A. ICC Meets the Economic Prong of the Domestic Industry
Requirement
189. ICC offers a number of products that are covered by the ‘151 Patent, and
is preparing to offer additional such products (the "ICC Patented Products"). Prior
to product development, ICC previously manufactured prototypes of its ICC
Patented Products in working towards commercialization. ICC has completed the
pre-production phase and is marketing the ICC Patented Products under the
Blackhawk Remote Engine Starter (Blackhawk RES) brand.
190. Section 337(a)(3) sets forth the criteria for establishing the "economic
prong." Specifically, "an industry in the United States shall be considered to exist if
there is in the United States, with respect to the articles protected by patent ... (A)
significant investment in plant and equipment; (B) significant employment of
labor or capital; or (C) substantial investment in its exploitation, including
engineering, research and development, or licensing." 19 U.S.C. § 1337(a)(3)(A)-
(C). Satisfaction of anyone of these criteria is sufficient to meet the economic
prong of the domestic industry requirement. Certain Silicon Microphone Packages
and Products Containing the Same, Inv. No. 337-TA-695, Initial Determination, p.
86 (March 24, 2010). In the instant matter, ICC meets aspect § 337(a)(3)(C).
66. 66
191. Moreover, since the ‘151 Patent arises from inventive work in the United
States and ICC has continuously taken the necessary steps toward
commercialization, thus it has sufficiently established a nexus between its
domestic investments and the asserted ‘151 Patent. (See SKG Decl.¶19 Ex. 49).
192. Furthermore, the Federal Circuit had held that the “articles protected by
the patent” requirement is satisfied when the patented technology was found in
both the licensed products and the accused products, concluding: “As long as the
patent covers the article that is the subject of the exclusion proceeding, and as long
as the party seeking relief can show that it has a sufficiently substantial
investment in the exploitation of the intellectual property to satisfy the domestic
industry requirement of the statute, that party is entitled to seek relief under
section 337.” See InterDigital Communications LLC v. ITC, 707 F.3d 1295, 1297-98
(Fed. Cir. 2013). Claim charts showing that the ICC Patented Products practice the
‘151 Patent are attached hereto as Confidential Exhibit 39.
193. ICC’s acquisition licensing investment of the ‘151 Patent rights have
driven the adoption, development and the production of Blackhawk RES domestic
articles, thus the in-licensing activity satisfies 19 U.S.C. § 1337(a)(3)(C). See
Confidential Exhibit 52
i. ICC Has Made a Substantial Investment within the United
States for the Exploitation of Articles Protected by the Asserted
Patent, Including Engineering, and Research and Development
67. 67
194. ICC has made substantial investment in the United States for the
exploitation of its products practicing the claims of the Asserted Patents. For
example, ICC maintains significant wireless, warranty, and after-sales customer
service within the United States for its Blackhawk RES smartwatch vehicular
systems practicing the claims of the ICC Asserted Patent. Additionally, ICC
contracts with Aeris Communications to provide wireless support and services for
its current customers. Further, ICC has invested in continued research and
development in smartwatch interfaces applications for the vehicular system, as
detailed by the recent ICC design patent submission, U.S. Patent Application No.
29/513,798. See Confidential Exhibit 51.
B. Domestic Industry, If not Already Established, is in the Process of
Being Established
195. To the extent that ICC’s activities do not already establish domestic
industry, ICC’s investments demonstrate that it is taking necessary, tangible steps
to establish an industry in the United States, and there is a significant likelihood
that the domestic-industry requirement will be met in the future. As for the
legislative history of section 337(a)(2), an industry would be considered “in the
process of being established” if the patent owner “can demonstrate that he is
taking the necessary tangible steps to establish such an industry in the United
States.” S. Rep. 100-71 at 130. “The owner of the intellectual property right must
be actively engaged in steps leading to the exploitation of the intellectual property,
including application engineering, design work, or other such activities. The
Commission should determine whether the steps being taken indicate a significant
likelihood that the industry requirement will be satisfied in the future.” H. Rep.
68. 68
100-40 at 157. Moreover, “the mere ownership of a patent or other form of
intellectual property rights would not be sufficient to satisfy this test.” S. Rep.
100-71 at 129.
i. What was the level of interest from potential manufacturers,
investors, and licensees in ICC’s technology prior to release of
the Respondents’ smartwatch vehicular systems? Did
Respondents’ release of smartwatch vehicular systems cause
this interest to decrease? To what extent would the
products(s) being developed by ICC compete with
Respondents’ products?
196. On or about September 10, 2014, the Specialty Equipment Marketing
Association (SEMA) selected ICC’s patented Blackhawk RES was as one of the top
five innovations and was invited to present the technology during SEMA’s annual
trade show in Las Vegas See Exhibit 42. Further, ICC debuted the ICC Patented
Products via the Blackhawk RES brand and launched a crowd funding campaign
during the SEMA presentation. There was and still is interest from potential
manufacturers, investors and licensees. For example, potential manufacturers
such as Audiovox and Delphi expressed interest in the technology. Unfortunately,
it is suspected that Audiovox lost interest in the technology due to the barrage of
non-licensed market entrants.
197. Additionally, one potential investor is the renowned start-up accelerator
Techstars. As a global ecosystem, Techstars empowers entrepreneurs to bring
new technologies to market wherever they choose to build their business. The