`
`
`
`
`William E. Thomson, Jr. (SBN 47195)
`BROOKS KUSHMAN P.C.
`6005 S. Figueroa Street, Suite 2080
`Los Angeles, California 90017-5726
`Phone: (213) 622-3003 / Fax: (213) 622-3053
`E-Mail: wthomson@brookskushman.com
`
`Marc Lorelli (Admitted pro hac vice)
`mlorelli@brookskushman.com
`John P. Rondini (Admitted pro hac vice)
`jrondini@brookskushman.com
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`Phone: (248) 358-4400 / Fax: (248) 358-3351
`
`Attorneys for Plaintiff
`Ancora Technologies, Inc.
`
`
`
`
`
`ANCORA TECHNOLOGIES,
`INC.
`
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`
`
`Case No. 8:19-cv-02192-JLS-ADS
`
`[Hon. Josephine L. Staton]
`
`
`AMENDED COMPLAINT
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`Courtroom: 10A, 10th Floor
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`Plaintiffs,
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`v.
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`TCL CORP., SHENZHEN TCL
`CREATIVE CLOUD
`TECHNOLOGY CO., LTD.,
`HUIZHOU TCL MOBILE
`COMMUNICATION CO,
`LTD., and TCT MOBILE (US)
`INC.
`
`
`
`
`
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`Defendants.
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` RELATED CASE 2:20-cv-01252
`
` *
`
`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 2 of 15 Page ID #:191
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`
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`1.
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`Plaintiff, Ancora Technologies, Inc. (“Ancora”), for its Complaint
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`against TCL Corp., Shenzhen TCL Creative Cloud Technology Co., Ltd., Huizhou
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`TCL Mobile Communication Co. Ltd., and TCT Mobile (US) Inc. (collectively
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`“TCL”) herein, states as follows.
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`2.
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`Ancora further notes that the same claims exist in case No. 2:20-cv-
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`01252. As noted in the filing of Docket No. 22 in the 8:19-cv-02192 case, the
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`parties believe these cases should be consolidated.
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`I.
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`THE PARTIES
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`3.
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`Plaintiff Ancora Technologies, Inc. is a corporation organized and
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`existing under the laws of the State of Delaware and having a place of business at
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`23977 S.E. 10th Street, Sammamish, Washington 98075.
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`4.
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` Upon information and belief, TCL Corp. is a corporation duly
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`organized and existing under the laws of the People’s Republic of China, with a
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`principal place of business at No. 26, the Third Road, Zhongkai Avenue, Huizhou
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`City, Guangdong, P.R. China 516006.
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`5.
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`Upon
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`information and belief, Shenzhen TCL Creative Cloud
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`Technology Co., Ltd. is a corporation duly organized and existing under the laws of
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`the People’s Republic of China, with a principal place of business at 7F, Block F4,
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`TCL Communication Technology Building, TCL International E-city, Zhong Shan
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`Yuan Road, Nanshan District, Shenzhen, Guangdong, P.R. China.
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`6.
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`Upon information and belief, Huizhou TCL Mobile Communication
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`Co. Ltd. is a corporation duly organized and existing under the laws of the People’s
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 3 of 15 Page ID #:192
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`Republic of China, with a principal place of business at No. 86 Hechang Qi Lu Xi,
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`Zhongkai Gaoxin District, Huizhou City, Guandong Province, P.R. China.
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`7.
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`TCT Mobile (US) Inc. is a corporation organized and existing under the
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`laws of Delaware with a principal place of business at 25 Edelman, Suite 200,
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`Irvine, California 92618.
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`8.
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`Upon information and belief, TCL is licensed to make, use, and sell
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`Alcatel-branded mobile devices in the United States.
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`http://www.tctusa.com/
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`https://us.alcatelmobile.com/about-us/
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`9.
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`Upon information and belief, TCL is licensed to make, use, and sell
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`Blackberry-branded mobile devices in the United States.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`2
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 4 of 15 Page ID #:193
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`http://www.tctusa.com/
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`https://blackberrymobile.com/us/about-us/
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`10. The Defendants identified in paragraphs 2-5 above are an interrelated
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`group of companies which together comprise a manufacturer and seller of Android
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 5 of 15 Page ID #:194
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`mobile devices in the United States, including Android mobile devices that are sold
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`under the Alcatel and Blackberry brands.
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`II.
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`JURISDICTION
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`11. This is an action for infringement of United States patents arising under
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`35 U.S.C. §§ 271, 281, and 284–85, among others. This Court has subject matter
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`jurisdiction of the action under 28 U.S.C. § 1331 and § 1338(a).
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`12. This Court has personal jurisdiction over Defendants pursuant to due
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`process and/or the California Long Arm Statute and additional based on admission
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`by way of the Declaratory Judgment Action and the parties’ stipulation contained in
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`Docket No. 22.
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`13. Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b),
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`1391(c), and 1400(b) because (i) Defendants have done and continue to do business
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`in this district; (ii) Defendants have committed and continue to commit acts of patent
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`infringement in this district, including making, using, offering to sell, and/or selling
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`accused products in this district, and/or importing accused products into this district,
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`including by internet sales and sales via retail and wholesale stores, and/or inducing
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`others to commit acts of patent infringement in this district; and (iii) Defendants are
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`foreign entities.
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`14. Venue is proper as to Defendants based on the Declaratory Judgment
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`Action and on agreement/stipulation and also because they are organized under the
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`laws of the People’s Republic of China. 28 U.S.C. § 1391(c)(3) provides that “a
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`defendant not resident in the United States may be sued in any judicial district, and
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 6 of 15 Page ID #:195
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`the joinder of such a defendant shall be disregarded in determining where the action
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`III. BACKGROUND
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`15. On June 25, 2002, U.S. Patent No. 6,411,941 (“the ’941 patent”)
`
`entitled “Method Of Restricting Software Operation Within A License Limitation”
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`was duly and legally issued. (See Exhibit A, U.S. Patent No. 6,411,941.) A
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`reexamination certificate also issued to the ’941 Patent on June 1, 2010 where the
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`patentability of all claims was confirmed by the United States Patent Office.
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`(Exhibit B, Ex Parte Reexamination Certificate Issued Under 35 U.S.C. § 307.)
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`16. The ’941 patent has been involved in litigation against Microsoft
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`Corporation, Dell Incorporated, Hewlett Packard Incorporated, and Toshiba America
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`Information Systems. (See 2009-cv-00270, Western District of Washington).
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`17. The ’941 patent has also been involved in litigation against Apple
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`Incorporated. (See 2015-cv-03659, Northern District of California).
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`18. The ’941 patent is currently involved in litigation against HTC
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`America, Inc. and HTC Corporation. (See 2016-cv-01919, Western District of
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`Washington).
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`19. The ’941 patent is currently involved in litigation against Samsung
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`Electronics America, Inc. and Samsung Electronics Co., Ltd. (See 2019-cv-00385,
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`Western District of Texas).
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`20.
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` The ’941 patent is currently involved in litigation against LG
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`Electronics USA, Inc. and LG Electronics, Inc. (See 2019-cv-00384, Western
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`District of Texas).
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 7 of 15 Page ID #:196
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`21. The ’941 patent was involved in a Covered Business Method
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`proceeding before the U.S. Patent and Trademark Office (See PTAB-CBM2017-
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`00054). The U.S. Patent and Trademark Office denied institution of the petition
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`filed by HTC and found the ’941 patent recites a “technological improvement to
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`problems arising in prior art software and hardware methods of restricting an
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`unauthorized software program’s operation.” (See PTAB-CBM2017-00054, Paper
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`No. 7 at pg. 9).
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`22. The U.S. Court of Appeals for the Federal Circuit further issued an
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`order on November 16, 2018 regarding the validity of the ‘941 patent. (See CAFC
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`18-1404, Dkt. # 39.) In this appeal, the U.S. Court of Appeals for the Federal Circuit
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`held:
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`[T]he claimed invention moves a software-verification structure to a
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`BIOS location not previously used for this computer-security purpose
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`and alters how the function is performed (in that the BIOS memory
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`used for verification now interacts with distinct computer memory to
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`perform a software-verification
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`function), yielding a
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`tangible
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`technological benefit (by making the claimed system less susceptible to
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`hacking).
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`CAFC 18-1404, Dkt. # 39, pg. 13.
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`23. The U.S. Court of Appeals for the Federal Circuit further issued an
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`order on March 3, 2014 regarding claim construction and invalidity of the ’941
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`Patent. (See CAFC 13-1378, Dkt. # 57).
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`24. Ancora is the owner of all right, title and interest in the ’941 patent.
`
`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 8 of 15 Page ID #:197
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`
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`IV. COUNT I – PATENT INFRINGEMENT
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`25. Ancora realleges the preceding paragraphs as though set forth fully
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`herein.
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`26. TCL has infringed the ’941 patent in violation of 35 U.S.C. § 271(a) by,
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`prior to the expiration of the ’941 patent, selling, and/or offering for sale in the
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`United States, and/or importing into the United States, without authorization,
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`products that are capable of performing at least Claim 1 of the ’941 patent literally or
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`under the doctrine of equivalents and/or, without authorization, causing products to
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`perform each step of at least Claim 1 of the ’941 patent.
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`27. Accused Products include, but are not limited to,
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`the Alcatel
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`3c/33x/3v/3L; Alcatel 1c/1x/1/1t7/1T10; Alcatel A3/A3XL/A7XL/A7/A2XL/A3A;
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`Alcatel A5; Alcatel IDOL 4/4S/5; Alcatel POP 4/4S/4PLUS; Alcatel PIXI
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`4(4)/4(5)/4(6); Blackberry KeyONE; and Blackberry Key2 (“Accused Devices”).
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`28. Upon information and belief, TCL began selling the accused Alcatel
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`products between 2016 - 2018.
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`29. Upon information and belief, TCL began selling the Blackberry
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`KeyONE in 2017.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 9 of 15 Page ID #:198
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`https://blackberrymobile.com/press-room/
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`30. Upon information and belief, TCL began selling the Blackberry Key2
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`in 2018.
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`https://blackberrymobile.com/press-room/
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`31. At a minimum, the Accused Products include servers/software utilized
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`by TCL to transmit an over-the-air (“OTA”) software update, as well as those
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`smartphones and other devices and technology that received from TCL, or received
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`at TCL’s direction, an OTA update that caused such device to perform the method
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`recited in Claim 1 prior to the expiration of the ’941 patent.
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`32. Such Accused Products are configured by TCL such that they are
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`capable of performing each step of Claim 1 of the ’941 patent and to which TCL
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`provided one or more OTA updates before the expiration of the ’941 patent that
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`would cause a TCL device to perform each step of Claim 1 in order to upgrade its
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`operating
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`system.
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`(See
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`e.g.,
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 10 of 15 Page ID #:199
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`https://www.att.com/devicehowto/tutorial.html#!/stepbystep/id/stepbystep_KM1231
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`051?make=BlackBerry&model=BBB100&gsi=mpo8f8;
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`https://support.sprint.com/support/pages/printTemplate.jsp?articleId=WServiceAdvi
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`sory_542_GKB92134-dvc9760001prd.)
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`33. For example, Claim 1 of the ’941 patent claims “a method of restricting
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`software operation within a license for use with a computer including an erasable,
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`non-volatile memory area of a BIOS of the computer, and a volatile memory area;
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`the method comprising the steps of: [1] selecting a program residing in the volatile
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`memory, [2] using an agent to set up a verification structure in the erasable, non-
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`volatile memory of the BIOS, the verification structure accommodating data that
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`includes at least one license record, [3] verifying the program using at least the
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`verification structure from the erasable non-volatile memory of the BIOS, and [4]
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`acting on the program according to the verification.”
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`34. When TCL transmitted an OTA update, TCL performed and/or caused
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`to be performed each of these elements as part of what is described as “verified
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`boot”:
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`https://source.android.com/security/verifiedboot
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 11 of 15 Page ID #:200
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`35.
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`In particular, each mobile device contains both erasable, non-volatile
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`memory in the form of ROM and volatile memory in the form of RAM.
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`36. Further, each mobile device was configured by TCL to perform the
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`below described process (or one substantially like it) in order to install an OTA
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`update:
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`https://source.android.com/devices/tech/ota/nonab
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`37. For example, during this process, a program running on one or more
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`OTA servers owned and/or controlled by TCL set up a verification structure in the
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`erasable, non-volatile memory of the BIOS of the Accused Products by transmitting
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`to the device an OTA update. The Accused Products are then configured by TCL to
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`save to a partition (e.g., the “cache” or “A/B” partitions) of the erasable, non-volatile
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`memory of its BIOS.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 12 of 15 Page ID #:201
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`38. The OTA update contains a verification structure that include data
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`accommodating at least one license record. Examples of such a license record
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`include a cryptographic signature or key:
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`https://source.android.com/devices/tech/ota/sign_builds
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`39. Such license record also may comprise a cryptographic hash or hash
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`tree:
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`https://source.android.com/security/verifiedboot/verified-boot.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 13 of 15 Page ID #:202
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`40. Once the verification structure has been set up in the BIOS, the
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`Accused Products are configured by TCL to reboot into recovery mode, load the
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`OTA update into its volatile memory (e.g., RAM), and use the at least one license
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`record from the BIOS to verify the OTA update.
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`41.
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`If the OTA update is verified, the Accused Products are configured to
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`load and execute the update.
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`42.
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`In sum, as described above, once TCL has set up the verification
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`structure by transmitting to a device an OTA update, each Accused Product is
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`configured to automatically perform each of the remaining Claim 1 steps.
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`43. Further, on information and belief, when TCL provided OTA updates,
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`TCL performed or caused to be performed each of the Claim 1 steps.
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`44. Further, TCL conditions participation in the OTA update process and
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`the receipt of the benefit of a software update on the performance of each of the
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`45. Primarily, as described above, TCL pre-configures/programs each
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`Accused Product to perform the above described steps upon receiving an OTA
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`update from TCL.
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`46. Further, TCL takes steps to ensure that each Accused Product cannot
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`install an OTA update except by performing each of the above described steps.
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`47. Further, TCL emphasizes the benefits associated with updating the
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`software of its Accused Products.
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`48. Further, TCL controlled the manner of the performance of such method.
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`As set forth above, TCL configured each Accused Product such that, upon receiving
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 14 of 15 Page ID #:203
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`an OTA update, it would automatically perform each remaining step of the claimed
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`method.
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`49. TCL also controlled the timing of the performance of such method by
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`determining when to utilize its OTA servers/software to set up a verification
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`structure in each Accused Product.
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`50. TCL also had the right and ability to stop or limit infringement simply
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`by not performing the initial step of using its OTA servers/software to set up a
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`verification structure in each Accused Product. Absent this action by TCL, the
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`infringement at issue would not have occurred.
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`51. TCL’s infringement has caused damage to Ancora, and Ancora is
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`entitled to recover from TCL those damages Ancora has sustained as a result of
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`TCL’s infringement.
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`V. DEMAND FOR RELIEF
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`WHEREFORE, Plaintiff prays for judgment as follows:
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`A. Declaring that TCL has infringed United States Patent No. 6,411,941
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`in violation of 35 U.S.C. § 271;
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`B. Awarding damages to Ancora arising out of this infringement,
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`including enhanced damages pursuant to 35 U.S.C. § 284 and prejudgment and post-
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`judgment interest, in an amount according to proof;
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`C. Awarding such other costs and relief the Court deems just and proper,
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`including any relief that the Court may deem appropriate under 35 U.S.C. § 285.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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`Case 8:19-cv-02192-GW-AS Document 24 Filed 02/19/20 Page 15 of 15 Page ID #:204
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`VI. DEMAND FOR JURY TRIAL
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`Ancora respectfully demands a trial by jury of any and all issues triable of
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`right by a jury in the above-captioned action.
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`Date: February 19, 2020
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`BROOKS KUSHMAN P.C.
`
` /s/ Marc Lorelli
`Marc Lorelli (Admitted pro hac vice)
`mlorelli@brookskushman.com
`John P. Rondini (Admitted pro hac vice)
`jrondini@brookskushman.com
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`P: (248) 358-4400 /F: (248) 358-3351
`
`William E. Thomson, Jr. (SBN 47195)
`6005 S. Figueroa Street, Suite 2080
`Los Angeles, California 90017-5726
`Phone: (213) 622-3003
`Fax: (213) 622-3053
`wthomson@brookskushman.com
`
`Attorneys for Plaintiff
`Ancora Technologies, Inc.
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`AMENDED COMPLAINT
`Case No. 8:19-cv-02192-JLS-ADS
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