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`Exhibit E
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 1 of 10 Page ID #:1Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 2 of 11 Page ID #:316
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`RUSS AUGUST & KABAT
`Brian Ledahl (CA SB No. 186579)
`Neil A. Rubin (CA SB No. 250761)
`Jacob Buczko (CA SB No. 269408)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Telephone: 310-826-7474
`Facsimile: 310-826-6991
`E-mail: bledahl@raklaw.com
`E-mail: nrubin@raklaw.com
`E-mail: jbuczko@raklaw.com
`Attorneys for Plaintiff Document Security Systems, Inc.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`DOCUMENT SECURITY SYSTEMS,
`INC.,
`
`Plaintiff,
`
`Civil Action No. 8:17-cv-00981
`
`v.
`JURY TRIAL DEMANDED
`SEOUL SEMICONDUCTOR CO., LTD.,
`and SEOUL SEMICONDUCTOR, INC.,
`Defendants.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`This is an action for patent infringement arising under the Patent Laws of the
`United States of America, 35 U.S.C. § 1 et seq. in which Document Security Systems,
`Inc. (“DSS” or “Plaintiff”) makes the following allegations against Defendants Seoul
`Semiconductor Co., Ltd. (“Seoul Korea”) and Seoul Semiconductor, Inc. (“Seoul
`America”) (collectively “Seoul” or “Defendants”).
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`1
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`Case No. 8:17-cv-00981
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`Exhibit E
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`Page 93
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 2 of 10 Page ID #:2Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 3 of 11 Page ID #:317
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`PARTIES
`1.
`Document Security Systems, Inc. is a publicly-traded New York
`corporation. Founded in 1984, DSS is a global leader in brand protection, digital
`security solutions and anti-counterfeiting technologies.
`2.
`In November 2016, DSS acquired a portfolio of patents covering
`technologies used in Light-Emitting Diode (“LED”) lighting products, including the
`patents-in-suit. The patents in this portfolio were originally assigned to Agilent
`Technologies, Inc. and/or the successors of its LED business. Since its recent
`acquisition of these patents, DSS has worked to expand its business efforts regarding
`LED technology. DSS is pursuing both licensing and commercialization of this
`technology acquisition.
`3. On information and belief, Seoul Semiconductor Co., Ltd. is a corporation
`organized and existing under the laws of the Republic of Korea with its principal place
`of business at 1B-25, 727, Wonsi- dong, Danwon-gu, Ansan-city, Gyeonggi-do,
`Korea 425-851. Upon information and belief, Seoul Korea manufactures light-
`emitting diode (“LED”) products in Korea and, through its subsidiary, Defendant
`Seoul America, has sales offices in the United States. Defendant Seoul Korea can be
`served with process in Korea pursuant to the Hague Convention on the Service
`Abroad of Judicial and Extrajudicial Documents, Article 1, November 15, 1965
`T.I.A.S. No. 6638, 20 U.S.T. 361 (U.S. Treaty 1969).
`4. On information and belief, Seoul Semiconductor, Inc. is a California
`corporation with its principal place of business at 1895 Beaver Ridge Circle, Suite G,
`Norcross, Georgia 30071. Upon information and belief, Seoul America sells and/or
`offers for sale nationwide LED products manufactured by Seoul Korea, including in
`the State of California and in this judicial district. Defendant Seoul America can be
`served through its registered agent, Jiyoon Jun, 5856 Corporate Avenue, Suite 240,
`Cypress, California 90630.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`2
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`Case No. 8:17-cv-00981
`
`Exhibit E
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`Page 94
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 3 of 10 Page ID #:3Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 4 of 11 Page ID #:318
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`JURISDICTION AND VENUE
`5. This action arises under the patent laws of the United States, Title 35 of the
`United States Code. Accordingly, this Court has subject matter jurisdiction under 28
`U.S.C. §§ 1331 and 1338(a).
`6. This Court has personal jurisdiction over Defendants in this action because,
`among other reasons, Defendants have committed acts within the Central District of
`California giving rise to this action and have established minimum contacts with the
`forum state of California. Defendants directly and/or through subsidiaries or
`intermediaries (including distributors, retailers, and others), have committed and
`continue to commit acts of infringement in this District by, among other things,
`making, using, importing, offering for sale, and/or selling products and/or services
`that infringe the patents-in-suit. Thus, Defendants have purposefully availed
`themselves of the benefits of doing business in the State of California and the exercise
`of jurisdiction over Defendants would not offend traditional notions of fair play and
`substantial justice.
`7. Venue is proper in this District under 28 U.S.C. §§ 1391 (b)-(c) and 1400(b)
`because Defendants have a regular and established place of business in this District
`and have committed acts of patent infringement in this District. Defendants, for
`example, have a regular and established place of business at 5856 Corporate Ave, No.
`240, Cypress, CA 90630, which is located in Orange County.
`BACKGROUND
`8. DSS is the owner by assignment of United States Patent No. 6,949,771 (“the
`’771 Patent”) entitled “Light Source.” The ’771 Patent was duly and legally issued by
`the United States Patent and Trademark Office on September 27, 2005. A true and
`correct copy of the ’771 Patent is included as Exhibit A.
`9. DSS is the owner by assignment of United States Patent No. 7,524,087 (“the
`’087 Patent”) entitled “Optical Device.” The ’087 Patent was duly and legally issued
`by the United States Patent and Trademark Office on April 28, 2009. A true and
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`Case No. 8:17-cv-00981
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`3
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`Exhibit E
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`Page 95
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 4 of 10 Page ID #:4Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 5 of 11 Page ID #:319
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`correct copy of the ’087 Patent is included as Exhibit B.
`10. DSS is the owner by assignment of United States Patent No. 7,256,486
`(“the ’486 Patent”) entitled “Packing Device for Semiconductor Die, Semiconductor
`Device Incorporating Same and Method of Making Same.” The ’486 Patent was duly
`and legally issued by the United States Patent and Trademark Office on August 14,
`2007. A true and correct copy of the ’486 Patent is included as Exhibit C
`11. DSS owns all rights, title, and interest in and to the ’771, ‘087 and ‘486
`Patents (collectively, “asserted patents” or “patents-in-suit”), including all rights to
`sue and recover for past and future infringement.
`COUNT I
`INFRINGEMENT OF THE ’771 PATENT
`12. DSS references and incorporates by reference paragraphs 1 through 10 of
`this Complaint.
`13. Defendants make, use, offer for sale, sell, and/or import in the United
`States products and/or services that infringe various claims of the ’771 Patent, and
`continues to do so. By way of illustrative example, Defendants’ infringing products
`include without limitation, all versions and variations, including predecessor and
`successor models, of its T6 Series, and LEDs including the 3020, 3030 (automotive)
`3528, and 5630 (automotive) packages. Defendants’ infringing products also include
`products, e.g., light bulbs, displays and fixtures that contain at least one infringing
`LED product. Defendants’ infringing products are collectively referred to hereinafter
`as “’771 Accused Instrumentalities.”
`14. Defendants have directly infringed and continue to directly infringe the
`’771 Patent by, among other things, making, using, offering for sale, selling, and/or
`importing the ’771 Accused Instrumentalities. Such products and/or services are
`covered by one or more claims of the ’771 Patent’s including at least claims 1 to 8
`because they contain each element of those claims.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
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`4
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`Case No. 8:17-cv-00981
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`Exhibit E
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`Page 96
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 5 of 10 Page ID #:5Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 6 of 11 Page ID #:320
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`15. By making, using, offering for sale, selling, and/or importing the ’771
`Accused Instrumentalities infringing the ’771 Patent, Defendants have injured DSS
`and are liable to DSS for infringement of the ’771 Patent pursuant to 35 U.S.C. §
`271(a) directly and/or under the doctrine of equivalents.
`16.
`In addition, Defendants are actively inducing others, such as their
`customers and end users of Accused Instrumentalities, services based thereupon, and
`related products and/or processes, to directly infringe each and every claim limitation,
`including without limitation claims 1 to 8 of the ’771 Patent, in violation of 35 U.S.C.
`§ 271(b). Defendants’ customers and/or end users have directly infringed and are
`directly infringing each and every claim limitation, including without limitation
`claims 1 to 8 of the ’771 Patent. Defendants have had actual knowledge of the ’771
`Patent at least as of service of this Complaint. Defendants are knowingly inducing
`their customers and/or end users to directly infringe the ’771 Patent, with the specific
`intent to encourage such infringement, and knowing that the induced acts constitute
`patent infringement. Defendants’ inducement includes, for example, providing
`technical guides, product data sheets, demonstrations, software and hardware
`specifications, installation guides, and other forms of support that induce their
`customers and/or end users to directly infringe the ’771 Patent. The ’771 Accused
`Instrumentalities are designed in such a way that when they are used for their intended
`purpose, the user infringes the ’771 Patent. Defendants know and intend that
`customers that purchase the ’771 Accused Instrumentalities will use those products for
`their intended purpose.
`17. Defendants have been aware of the ’771 Patent and of its infringement as
`of a date no later than the date they were served with this Complaint in this action. To
`the extent facts learned in discovery show that Defendants’ infringement of the ’771
`Patent is or has been willful, or to the extent that Defendants’ actions subsequent to
`the filing of this Complaint—such as their behavior as litigants or their failure to take
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
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`5
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`Case No. 8:17-cv-00981
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`Exhibit E
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`Page 97
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 6 of 10 Page ID #:6Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 7 of 11 Page ID #:321
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`remedial actions—render their infringement egregious, DSS reserves the right to
`request such a finding at time of trial.
`18. As a result of Defendants’ infringement of the ’771 Patent, DSS has
`suffered monetary damages in an amount adequate to compensate for Defendants’
`infringement, but in no event less than a reasonable royalty for the use made of the
`invention by Defendants, together with interest and costs as fixed by the Court.
`COUNT II
`INFRINGEMENT OF THE ’087 PATENT
`19. DSS references and incorporates by reference paragraphs 1 through 17 of
`this Complaint. Defendants make, use, offer for sale, sell, and/or import in the United
`States products and/or services that infringe various claims of the ’087 Patent, and
`continues to do so. By way of illustrative example, Defendants’ infringing products
`include without limitation, all versions and variations, including predecessor and
`successor models, of its 801 Series (Auto), 802 Series (Auto), 3528, 3528 (white),
`MJT 3528, and 6050 packages. Defendants’ infringing products also include
`products, e.g., light bulbs, displays and fixtures that contain at least one infringing
`LED product. Defendants’ infringing products are collectively referred to hereinafter
`as “’087 Accused Instrumentalities.”
`20. Defendants have directly infringed and continue to directly infringe the
`’087 Patent by, among other things, making, using, offering for sale, selling, and/or
`importing the ’087 Accused Instrumentalities. Such products and/or services are
`covered by one or more claims of the ’087 Patent’s including at least claim 1 because
`they contain each element of that claim.
`21. By making, using, offering for sale, selling, and/or importing the ’087
`Accused Instrumentalities infringing the ’087 Patent, Defendants have injured DSS
`and are liable to DSS for infringement of the ’087 Patent pursuant to 35 U.S.C. §
`271(a) directly and/or under the doctrine of equivalents.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`6
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`Case No. 8:17-cv-00981
`
`Exhibit E
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`Page 98
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 7 of 10 Page ID #:7Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 8 of 11 Page ID #:322
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`22.
`In addition, Defendants are actively inducing others, such as their
`customers and end users of Accused Instrumentalities, services based thereupon, and
`related products and/or processes, to directly infringe each and every claim limitation,
`including without limitation claim 1 of the ’087 Patent, in violation of 35 U.S.C. §
`271(b). Defendants’ customers and/or end users have directly infringed and are
`directly infringing each and every claim limitation, including without limitation claim
`1 of the ’087 Patent. Defendants have had actual knowledge of the ’087 Patent at
`least as of service of this Complaint. Defendants are knowingly inducing their
`customers and/or end users to directly infringe the ’087 Patent, with the specific intent
`to encourage such infringement, and knowing that the induced acts constitute patent
`infringement. Defendants’ inducement includes, for example, providing technical
`guides, product data sheets, demonstrations, software and hardware specifications,
`installation guides, and other forms of support that induce their customers and/or end
`users to directly infringe the ’087 Patent. The ’087 Accused Instrumentalities are
`designed in such a way that when they are used for their intended purpose, the user
`infringes the ’087 Patent. Defendants know and intend that customers that purchase
`the ’087 Accused Instrumentalities will use those products for their intended purpose.
`23. Defendants have been aware of the ’087 Patent and of its infringement as
`of a date no later than the date they were served with this Complaint in this action. To
`the extent facts learned in discovery show that Defendants’ infringement of the ’087
`Patent is or has been willful, or to the extent that Defendants’ actions subsequent to
`the filing of this Complaint—such as their behavior as litigants or their failure to take
`remedial actions—render their infringement egregious, DSS reserves the right to
`request such a finding at time of trial.
`24. As a result of Defendants’ infringement of the ’087 Patent, DSS has
`suffered monetary damages in an amount adequate to compensate for Defendants’
`infringement, but in no event less than a reasonable royalty for the use made of the
`invention by Defendants, together with interest and costs as fixed by the Court.
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`Case No. 8:17-cv-00981
`
`7
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`Exhibit E
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`Page 99
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`Case 8:17-cv-00981 Document 1 Filed 06/07/17 Page 8 of 10 Page ID #:8Case 8:17-cv-00981-JVS-JCG Document 23-7 Filed 08/29/17 Page 9 of 11 Page ID #:323
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`COUNT III
`INFRINGEMENT OF THE ’486 PATENT
`25. DSS references and incorporates by reference paragraphs 1 through 24 of
`this Complaint.
`26. On information and belief, Defendants make, use, offer for sale, sell,
`and/or import in the United States products and/or services that infringe various
`claims of the ’486 Patent, and continues to do so. By way of illustrative example,
`Defendants’ infringing products include without limitation, all versions and variations,
`including predecessor and successor models, of its ZPower LED – Z5M, Z5M0,
`Z5M1, Z5M2, Z5P, Z5, Z7, Z7-F, Z6, and P5 II LED products. Defendants’ infringing
`products also include products, e.g., light bulbs, displays and fixtures that contain at
`least one infringing LED product. Defendants’ infringing products are collectively
`referred to hereinafter as “’486 Accused Instrumentalities.”
`27. On information and belief, Defendants have directly infringed and
`continues to directly infringe the ’486 Patent by, among other things, making, using,
`offering for sale, selling, and/or importing the ’486 Accused Instrumentalities. On
`information and belief, such products are covered by one or more claims of the ’486
`Patent including at least claim 1 because they contain each element of that claim.
`28. By making, using, offering for sale, selling, and/or importing the ’486
`Accused Instrumentalities infringing the ’486 Patent, Defendants have injured DSS
`and is liable to DSS for infringement of the ’486 Patent pursuant to 35 U.S.C. § 271(a)
`directly and/or under the doctrine of equivalents.
`29.
`In addition, Defendants are actively inducing others, such as their
`customers and end users of Accused Instrumentalities, services based thereupon, and
`related products and/or processes, to directly infringe each and every claim limitation,
`including without limitation claim 1 of the ‘486 Patent, in violation of 35 U.S.C. §
`271(b). Defendants’ customers and/or end users have directly infringed and are
`directly infringing each and every claim limitation, including without limitation claim
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`Case No. 8:17-cv-00981
`
`8
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`Exhibit E
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`Page 100
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`1 of the ‘486 Patent. Defendants have had actual knowledge of the ‘486 Patent at
`least as of service of this Complaint. Defendants are knowingly inducing their
`customers and/or end users to directly infringe the ‘486 Patent, with the specific intent
`to encourage such infringement, and knowing that the induced acts constitute patent
`infringement. Defendants’ inducement includes, for example, providing technical
`guides, product data sheets, demonstrations, software and hardware specifications,
`installation guides, and other forms of support that induce their customers and/or end
`users to directly infringe the ‘486 Patent. The ’087 Accused Instrumentalities are
`designed in such a way that when they are used for their intended purpose, the user
`infringes the ‘486 Patent. Defendants know and intend that customers that purchase
`the ‘486 Accused Instrumentalities will use those products for their intended purpose.
`30. Defendants have been aware of the ‘486 Patent and of its infringement as
`of a date no later than the date they were served with this Complaint in this action. To
`the extent facts learned in discovery show that Defendants’ infringement of the ‘486
`Patent is or has been willful, or to the extent that Defendants’ actions subsequent to
`the filing of this Complaint—such as their behavior as litigants or their failure to take
`remedial actions—render their infringement egregious, DSS reserves the right to
`request such a finding at time of trial.
`31. As a result of Defendants’ infringement of the ‘486 Patent, DSS has
`suffered monetary damages in an amount adequate to compensate for Defendants’
`infringement, but in no event less than a reasonable royalty for the use made of the
`invention by Defendants, together with interest and costs as fixed by the Court.
`PRAYER FOR RELIEF
`Plaintiff respectfully requests the following relief from this Court:
`A. A judgment that Defendants have infringed one or more claims of the
`’771, ’087 and ‘486 Patents;
`B. A judgment and order requiring Defendants to pay DSS its damages,
`costs, expenses, and prejudgment and post-judgment interest for Defendants’ acts of
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`Case No. 8:17-cv-00981
`
`9
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`Exhibit E
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`Page 101
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`infringement in accordance with 35 U.S.C. § 284;
`C. A judgment and order requiring Defendants to provide accountings and
`to pay supplemental damages to DSS, including, without limitation, prejudgment and
`post-judgment interest;
`D. A judgment and order finding that this is an exceptional case within the
`meaning of 35 U.S.C. § 285 and awarding to DSS its reasonable attorneys’ fees
`against Defendants; and
`E. Any and all other relief to which DSS may show itself to be entitled.
`JURY TRIAL DEMANDED
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, DSS requests a
`trial by jury of any issues so triable by right.
`
`
`Dated: June 7, 2017
`
`
`
`By:
`
`
`
`Brian Ledahl
`
`RUSS AUGUST & KABAT
`Brian Ledahl (CA SB No. 186579)
`Neil A. Rubin (CA SB No. 250761)
`Jacob Buczko (CA SB No. 269408)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`Telephone: 310-826-7474
`Facsimile: 310-826-6991
`E-mail: bledahl@raklaw.com
`E-mail: nrubin@raklaw.com
`E-mail: jbuczko@raklaw.com
`
`Attorneys for Plaintiff,
`Document Security Systems, Inc.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`10
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`Case No. 8:17-cv-00981
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`Exhibit E
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`Page 102
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