Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 1 of 15
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` Randall T. Garteiser (CA State Bar No. 231821)
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`rgarteiser@ghiplaw.com
`Christopher A. Honea (CA State Bar No. 232473)
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`chonea@ghiplaw.com
`M. Scott Fuller (TX State Bar No. 24036607)
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`sfuller@ghiplaw.com
`GARTEISER HONEA
`795 Folsom St., Floor 1, San Francisco, CA 94107
`119 W Ferguson, Tyler, TX 75702
`Telephone: (415) 785-3762
`Facsimile: (888) 908-4400
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`Attorneys for Plaintiff,
`CELLSPIN SOFT INC.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
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`CELLSPIN SOFT, INC.,
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`Plaintiff,
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`v.
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`GARMIN INTERNATIONAL, INC. and
`GARMIN USA, INC.,
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`Defendants.
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`
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`Case No. 4:20-cv-3673
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`ORIGINAL COMPLAINT FOR
`INFRINGEMENT OF U.S. PATENT
`NO. 9,258,698
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`DEMAND FOR JURY TRIAL
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`NATURE OF THE ACTION AND BACKGROUND
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`1. This is a patent infringement action to stop Defendants’ infringement of United States
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`Patent No. 9,258,698 entitled “Automatic Multimedia Upload for Publishing Data and
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`Multimedia Content” (the “’698 patent” or the “Patents-in-Suit”).
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`2. The instant Complaint is being filed pursuant to the Court’s Orders and the agreement
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`of the Parties (Cellspin and Garmin) for the purpose of streamlining the earlier-filed
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`litigation now pending in the N.D. Cal. as 4:17-cv-05934-YGR (the “Ongoing Action”). As
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`the Court and the Parties have previously discussed and agreed as part of the Ongoing
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`Action, the claims and defenses of the Parties (Cellspin and Garmin) with respect to the
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 2 of 15
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`asserted ’698 Patent are being severed into this new, separate action. This action is to be
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`immediately STAYED pending appeal of the recent Final Written Decisions in the IPR
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`actions filed by Canon and Panasonic. Subsequent to the filing of this Complaint, Cellspin
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`will file papers in the Ongoing Action dismissing the claims relating to the ’698 Patent, and
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`all such future litigation efforts between the Parties relating to the ’698 Patent shall be
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`carried out under this present cause number, as necessary.
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`3. The allegations set forth below are identical to those in the effective pleading in the
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`Ongoing Action, but are limited to only the ’698 Patent. Plaintiff will supplement to identify
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`new accused instrumentalities, which may have entered the market after the filing of the
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`effective pleading in the Ongoing Action, in the event this present action resumes after
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`successful appeal.
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`4. Plaintiff, Cellspin Soft, Inc. (“Cellspin”), is a California corporation with an office and
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`THE PARTIES
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`place business at 1410 Mercy Street, Mountain View, California 94041.
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`5. Upon information and belief, Defendant, Garmin International, Inc. (“Garmin
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`International”), is a corporation organized and existing under the laws of the State of Kansas,
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`with its principal place of business at 1200 East 151st Street, Olathe, Kansas 66062. Garmin
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`International has already been served with process and is being served with this Amended
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`Complaint via ECF.
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`6. Upon information and belief, Defendant, Garmin USA, Inc. (“Garmin USA”), is a
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`corporation organized and existing under the laws of the State of Kansas, with its principal
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`place of business at 1200 East 151st Street, Olathe, Kansas 66062. Garmin USA has already
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`been served with process and is being served with this Amended Complaint via ECF.
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`7. Defendants Garmin International and Garmin USA are collectively referred to herein
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`as “Garmin.”
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`8. This action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq.,
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`JURISDICTION AND VENUE
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`including 35 U.S.C. §§ 271, 281, 283, and 284. This Court has subject matter jurisdiction
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 3 of 15
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`over this case for patent infringement, including pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`9. Plaintiff is the assignee of the Patents-in-Suit with all right, title and interest to bring
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`the claims herein comprising those for past and present infringement, including to recover
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`damages therefor.
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`10. The Court has personal jurisdiction over Garmin, including because Garmin has
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`minimum contacts within the State of California; Garmin has purposefully availed itself of
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`the privileges of conducting business in the State of California; Garmin regularly conducts
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`business within the State of California; and Plaintiff’s cause of action arises directly from
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`by virtue of Garmin’s infringing methods and products, which are at least practiced, made,
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`used, offered for sale, and sold in the State of California. Garmin is subject to this Court’s
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`specific and general personal jurisdiction, pursuant to due process and the California Long
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`Arm Statute, due at least to its continuous and systematic business contacts in California.
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`Further, on information and belief, Garmin is subject to the Court’s specific jurisdiction,
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`including because Garmin has committed patent infringement in the State of California,
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`including as detailed herein. In addition, Garmin induces infringement of the Patents-in-Suit
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`by customers and/or infringing users located in California. Further, on information and
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`belief, Garmin regularly conducts and/or solicits business, engages in other persistent
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`courses of conduct, and/or derives substantial revenue from goods and services provided to
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`persons and/or entities in California.
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`11. Upon information and belief, Venue is proper in this District pursuant to 28 U.S.C. §§
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`1391 and 1400(b), including in view of Garmin’s established kiosks throughout this District
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`and California.
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`THE PATENTS-IN-SUIT
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`12. Plaintiff refers to and incorporates herein the allegations in the above paragraphs.
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`13. The claims of the Patents-in-Suit, including the asserted claims, when viewed as a
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`whole, including as an ordered combination, are not merely the recitation of well-
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`understood, routine, or conventional technologies or components. The claimed inventions
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 4 of 15
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`were not well-known, routine, or conventional at the time of the invention, over ten years
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`ago, and represent specific improvements over the prior art and prior existing systems and
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`methods.
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`14. At the time of the patented inventions, publishing captured data from a data capture
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`device to a web service was cumbersome and inefficient.
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`15. At the time of the priority date of the Patents-in-Suit (December 2007), the same year
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`the world’s first prominent mobile “smartphone” was released, and 6 months before the
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`world’s first prominent mobile “app store” (see History of the iPhone on Wikipedia at
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`https://en.wikipedia.org/wiki/History_of_iPhone & App Store (iOS) on Wikipedia at
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`https://en.wikipedia.org/wiki/App_Store_(iOS)), it was a cumbersome and time consuming
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`process to use a data capture device to acquire data, send that data to a mobile device with an
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`internet connection, and the mobile device to upload that wirelessly received data to a
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`website, especially for large data such as pictures or video data.
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`16. The most common and practical way to transfer large data was to physically plug a
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`data capture device into, or transfer a memory card from a data capture device to, a
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`computer, upload the data on the capture device or memory card to the computer, and further
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`upload the data from the computer to a web service. See, e.g., ’698 at 1:45-55. In the case of
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`using a 2007 mobile phone, the software on both the data capture device and mobile phone
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`that established a paired connection and potentially transferred large data was extremely
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`under developed and not the intended or foreseeable use of the mobile phone. Further, HTTP
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`transfers of data received over the paired wireless connection to web services was non-
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`existent. Mobile phones of that time exclusively used SMS,1 MMS,2 or email-based
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`communication methods (such as POP3 or IMAP3 to transfer data that was acquired by the
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`1
` Short Message Service (SMS) is a text messaging service component of most telephone, World Wide Web,
`and mobile device systems. It uses standardized communication protocols to enable mobile devices to
`exchange short text messages. See https://en.wikipedia.org/wiki/SMS.
`2
` Multimedia Messaging Service (MMS) is a standard way to send messages that include multimedia content
`See
`to
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`from
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`mobile
`phone
`over
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`network.
`https://en.wikipedia.org/wiki/Multimedia_Messaging_Service.
`3
` See https://en.wikipedia.org/wiki/Email#Types.
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 5 of 15
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`mobile phone. It was not until 2009 or later when the leading tech companies, such as
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`Facebook and Google, started releasing HTTP APIs for developers to utilize a HTTP transfer
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`protocol
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`for mobile
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`devices.
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`See
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`https://developers.facebook.com/docs/graph-
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`api/changelog/archive;
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`http://mashable.com/
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`2009/05/19/twitter-share-
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`images/#K9kEHwxammq0. Even in 2009 when Facebook and Google HTTP APIs were
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`released, the released HTTP APIs were only used for data that was acquired by the mobile
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`phone, and not for the data that was received wirelessly over the secure paired connection
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`from a physically separate data capture device. Applying HTTP to a data in transit and on
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`intermediary mobile device was not developed until the inventions of the Patents-in-Suit.
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`17. Including as of the priority date of the Patents-in-Suit, there have been many, albeit
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`vastly inferior, means outside of the claimed invention for achieving the ends of acquiring
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`and transferring data for publication, including on the Internet. For example, as noted in the
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`specification,
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`Typically, the user would capture an image using a digital camera or a video
`camera, store the image on a memory device of the digital camera, and transfer
`the image to a computing device such as a personal computer (PC). In order to
`transfer the image to the PC, the user would transfer the image off-line to the
`PC, use a cable such as a universal serial bus (USB) or a memory stick and plug
`the cable into the PC. The user would then manually upload the image onto a
`website which takes time and may be inconvenient for the user.
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`See, e.g., ‘689 at 1:45-55. Another inferior method would be to have the capture device
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`simply forward data to a mobile device as captured. This example is inferior including
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`because, without a paired connection, there is no assurance that the mobile device is capable
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`(e.g., on and sufficiently near) of receiving the data. Such constant and inefficient
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`broadcasting would quickly drain the battery of the capture device. Another inferior method
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`for posting data from a capture device onto the Internet is to have a capture device with built
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`in mobile wireless Internet, for example cellular, capability. As noted in the specification,
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`“[t]he digital data capture device is physically separated from the BT enabled mobile
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`device.” See, e.g., ’698 at 2:10-11. This example is inferior including because, especially at
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`the time of the patent priority date in 2007 but also today, it makes the combined apparatus
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`bulky, expensive in terms of hardware, and expensive in terms of requiring a user to
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 6 of 15
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`purchase an extra and/or separate cellular service for the data capture device.
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`18. Prior art methods for posting data from a data capture device onto the Internet were
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`inferior. Back at the time of invention, capture devices such as cameras had only rudimentary
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`wireless capabilities as exemplified by the U.S. Patent Application No. 2003/015,796 to
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`Kennedy (“Kennedy”) and ancillary prior art addressed extensively during prosecution of
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`certain Patents-in-Suit and related patents. As noted by the inventors during prosecution of
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`the related ‘794 patent, in every day scenarios, the computer attaches a hypertext transfer
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`protocol (HTTP)_header and user ID to the data generated by the computer (“native data”),
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`and the existing home wireless routers did not apply website user information or apply HTTP
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`to the data sent over the wireless network from the computer to the home wireless router.
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`However, the claimed invention improves and builds on this, including because the claimed
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`mobile device is configured to send a HTTP request comprising the website user information
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`and the non-native data, such that the mobile device is acting as more than just a normal
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`home wireless router. According to the inventors, the wireless pairing established is therefore
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`very important for the transfer of non-native data that is acquired by a physically separate
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`device and then transferred to the mobile device over the trusted paired wireless connection.
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`19. Including at the time of the invention, data capture devices posed a number of specific
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`challenges associated with publishing data to a web service from a capture device using a
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`mobile device. The process to transfer new data from a data capture device to a web service
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`was cumbersome and time consuming for the user. Further, data capture devices typically
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`house small batteries, so users would be obligated to constantly charge batteries. The
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`technology embodied in the Patents-in-Suit solved these, and other, problems. The claimed
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`inventions comprise superior ways to achieve the ends of uploading data to the Internet via a
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`mobile device. The claimed processes of the asserted claims seamlessly transfer data from a
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`data capture device to a web service with little to no user intervention using a mobile device
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`with a wireless internet connection as the center piece doing most of the heavy lifting.
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`Making changes to the data in transit, at the mobile device, and not at the data capture device
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`where the data originated from, results in a much-improved user experience making the
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 7 of 15
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`process much easier on the user and improving data capture device battery life. The method
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`of receiving the data at the mobile device, attaching user identifying information and HTTP
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`methods to the data relieves the data capture device or web service of performing those steps
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`which results in a seamless and improved user experience over the previous methods.
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`20. Among other things, the inventors of the Patents-in-Suit wanted to post onto the
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`Internet content captured while a capture device, such a camera, was capturing data, for
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`example photographs, in “real time” situations, for example, when the capture device was in
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`remote areas, adverse conditions or on the move. As noted in the specification, “[a] user may
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`need to capture and publish data and multimedia content on the Internet in real time.” See,
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`e.g., ’698 at 1:45-46. As further noted in the specification, “there is a need for a method and
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`system to utilize a digital data capture device in conjunction with a mobile device for
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`automatically detecting capture of data and multimedia content, transferring the captured
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`data and multimedia content to the mobile device, and publishing the data and multimedia
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`content on one or more websites automatically or with minimal user intervention.” See, e.g.,
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`’698 at 1:56-62. But existing technology offered only unacceptably inferior solutions of
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`posting to the Internet content captured from a capture device in “real time” situations.
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`21. The claims of the Patents-in-Suit are directed to specific improvements in computer
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`and networking functionality and capabilities. Among other things, the claimed inventions
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`improve functionality of data capture devices and methods, systems and networks
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`comprising those devices. Including as noted in the Patents-in-Suit, the claimed technologies
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`comprise innovative systems and processes which use less power than those existing at the
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`time, and allow for multiple efficiencies resulting in a better user experience and reduced
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`costs. The Patents-in-Suit thus provided concrete applications that improved computer and
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`networking technology, including for publishing directly to a web service from a data
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`capture device.
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`22. Additionally, the inventions of the asserted claims of the Patents-in-Suit comprise
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`improvements in improving battery life on the data capture device, including that they reduce
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`the processing done by the device and thus reduce battery consumption. Particularly
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 8 of 15
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`applicable to wireless data capture devices small in size, such as petite fitness tracking
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`devices, battery life plays a major role in the user experience. The Patents-in-Suit allow for a
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`data capture device to be in a low power state to conserve battery life, and send an event
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`notification to the mobile device to initiate a higher power consumption state during a brief
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`communication period, and then revert back to the lower power consumption state. This
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`saves a tremendous amount of power, including because the application on the mobile
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`device, or the Bluetooth client, is charged with the majority of listening, rather than the data
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`capture device, or the Bluetooth server, which results in much better battery life for the data
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`capture device, including since there is “[a] file event listener in the client application 203
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`[which] listens for the signal from the digital data capture device 201. ’698 at 5:4-6
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`(emphasis added). Similarly, the Patents-in-Suit allow for a data capture device to be in a
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`low power state to conserve battery life because in certain claimed embodiment the
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`application on the mobile device with the internet connection, is charged with polling the
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`data capture device for new data to transfer.
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`23. In sum, including as noted above, the claimed technologies of the Patents-in-Suit
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`improved, inter alia, prior computer and networking technology, including in connection
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`with:
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`a. Improving and increasing efficiencies of the claimed inventions, including over
`inferior alternative means for achieving the same or similar ends of uploading
`content, including by reducing or eliminating the cumbersome steps of previous
`methods of data transfer to the Internet and providing the ability to upload or
`transfer the captured data at a time subsequent to the capture of the data where a
`connection to the Internet may not be available to the data capture device. See,
`e.g., ’698 at 1:45-62 & 4:59-5:7.
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`b. Leveraging the capabilities of mobile devices, including their Internet
`connection capabilities (through use of custom hardware and/or software),
`including by shifting the transfer of data from the data capture device to the
`mobile device, to greatly enhance the functionality of Internet incapable data
`capture devices, including because the mobile device, with its larger storage,
`may then store the captured data for upload or transfer to the web service via the
`Internet at a later time. See, e.g., ’698 at 2:33-41, 5:23-61, 6:7-52, 9:42-65, &
`10:16-67.
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`c. Uploading captured data from data capture devices to the Internet while
`avoiding the cost, memory usage, complexity, hardware (e.g., cellular antenna),
`physical size, and battery consumption of an Internet accessible mobile device,
`including without the data capture device being capable of wireless Internet
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 9 of 15
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`connections or being capable of communicating in Internet accessible protocols
`such as HTTP. See, e.g., ’698 at 2:53-61, 5:8-16, 5:60-6:14, 7:34-38, 7:67-8:5,
`8:28-9:31.
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`d. Minimizing power usage by the data capture device, including to minimize the
`need to change batteries or recharge the device. See, e.g., ’698 at 5:3-5.
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`e. Using event notification, polling and request/return communication protocols
`over an already paired connection to have the benefits from an efficient or
`automated upload system while conserving resources such as batteries by
`avoiding the data capture device broadcasting captured data when an
`intermediate mobile device is unavailable (e.g., off or out of Bluetooth range) or
`incapable of receiving captured data for uploading to the Internet. See, e.g., ’698
`at 4:59-5:7 & 5:17-22.
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`f. Applying HTTP in transit and on an intermediary device. See, e.g., ’698 at 9:66-
`10:14.
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`24. The claimed inventions also provide computer and network efficiency at least because
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`they allow data capture devices to have the useful and improved claimed sharing
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`functionality without the need to include expensive and battery consuming electronics,
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`cellular antenna, paying for separate cellular service, and extra software and data processing
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`required on the data capture device. The inventors did more than simply apply current
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`technology to an existing problem. Their invention, as embodied in the asserted claims, was
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`a significant advancement in mobile data capture and sharing technology. The inventions
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`covered by the asserted claims comprise utilization of the mobile Internet to create a novel
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`architecture enabling data captured by non-Internet enabled capture devices to quickly, easily
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`and automatically be uploaded to the Internet, and more specifically to what is referred to
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`today as “the cloud” and “social media.” Additionally, the claimed inventions also improve
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`pairing identification, different ways to transfer of new-data between paired devices (event
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`notification, polling, mobile initiated request response), and use of HTTP and adding user
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`information to the wirelessly received new-data on the intermediary mobile device, when the
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`new-data is in transit to the website.
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`25. These noted improvements over the prior art represent meaningful limitations and/or
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`inventive concepts based upon the state of the art over a decade ago. Further, including in
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`view of these specific improvements, the inventions of the asserted claims, when such claims
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`are viewed as a whole and in ordered combination, are not routine, well-understood,
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` ORIGINAL COMPLAINT FOR INFRINGEMENT OF U.S. PATENT NO. 9,258,698
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 10 of 15
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`conventional, generic, existing, commonly used, well known, previously known, typical, and
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`the like over a decade ago, including because, until inventions of the asserted claims of the
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`Patents-in-Suit, the claimed inventions were not existing or even considered in the field.
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`26. The asserted claims, including as a whole and where applicable in ordered
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`combination, comprise, inter alia, a non-conventional and non-generic arrangement of
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`communications between a data capture device and a Bluetooth enabled mobile device that is
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`a technical improvement to the communications between the devices and web services,
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`including those improvements noted above.
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`27. The claimed inventions are necessarily rooted in computer technology, i.e., portable
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`monitoring device technology, and comprise improvement over prior technologies in order to
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`overcome the problems, including those noted above, specifically arising in the realm of
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`computer networks. The claimed solutions amount to an inventive concept for resolving the
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`particular problems and inefficiencies noted above, including in connection publishing data
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`from a data capture device to the Internet described.
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`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 9,258,698
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`28. Plaintiff refers to and incorporates herein the allegations in the above paragraphs.
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`29. U.S. Patent No. 9,258,698 was duly and legally issued by the USPTO on February 9,
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`2016 after full and fair examination. See Exhibit C.
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`30. Claims of the ’698 Patent comprise, generally, methods, devices, systems, and
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`computer-readable media comprising digital camera devices having a short-range wireless
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`capability to connect with a cellular phone; acquiring new-media after establishing a secure
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`wireless connection between the camera and the cellular phone; creating a new-media file
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`using the new-media; receiving a data transfer request for the new-media file initiated by a
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`mobile software application on the cellular phone over the wireless connection after storing
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`the created new-media file in memory of the camera; and transferring the new-media file to
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`be stored on the cellular phone, over the wireless connection, wherein the cellular phone is
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`configured to use HTTP to upload the received new-media file along with user information
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`to a user media publishing website.
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 11 of 15
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`31. Garmin has infringed, and is now infringing, the ’698 patent, including at least claims
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`1, 3, 4, 5, 7, 8, 10, 11, 12, 13, 15, 16, 17, 18, 19, and 20, in this judicial district, the State of
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`California, and elsewhere, in violation of 35 U.S.C. § 271 through actions comprising the
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`making, using, offering for sale, and/or selling, without authority from Plaintiff, devices,
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`systems, and/or computer-readable media for enabling connection between data capture
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`devices and other wireless devices, such as a cellular phone, acquiring new data on the data
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`capture device, and transferring the data from Garmin data capture devices to web servers
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`via wireless mobile devices. On information and belief, Garmin practices, and/or induces
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`others to practice, the claimed methods, and/or makes, uses, offers for sale, and/or sells,
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`and/or induces others to use, the claimed devices, systems, and computer-readable media,
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`including camera and other media devices, including DSLR cameras, point-and-click
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`cameras, digital cameras, and other digital media devices, designed to capture digital media,
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`e.g., images, photographs, audio, video, etc., including related data such as GPS coordinates,
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`timestamp, etc., as specified herein, comprising wireless functionality, with such products
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`comprising the Garmin Dash Cam 45, Garmin Dash Cam 55, Garmin Dash Cam 65W,
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`Garmin Drive Assist 51 LMT-S, Garmin VIRB 360, Garmin VIRB Ultra 30, Garmin VIRB
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`X, and Garmin VIRB XE, including when used in conjunction with Garmin mobile
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`applications (including iOS and Android versions thereof) comprising Garmin VIRB,
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`including when used in conjunction with websites comprising media publishing sites, such as
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`social media websites.
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`32. Without limitation, the accused Garmin devices, including software which practices
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`said methods, support wireless protocols, including short-range wireless protocols, including
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`wireless networking or Bluetooth protocols, comprising transferring data from digital camera
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`devices to websites via applications on cellular phones, including via its cameras and other
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`media devices. The accused Garmin devices, systems, computer-readable media, and
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`methods comprise the capability to establish a secure wireless connection with a cellular
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`phone. Once the connection between the Garmin device and the cellular phone is established,
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`the Garmin devices acquire new-media (e.g., photos, audio, and/or videos, and related data),
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`Case 4:20-cv-03673-YGR Document 1 Filed 06/02/20 Page 12 of 15
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`create a new-media file using the acquired new-media, and transfer the new-media file to the
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`cellular phone in response to receiving a data transfer request for the new-media file initiated
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`by the Garmin application on the cellular phone, over the established wireless connection,
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`after storing the created new-media file in the memory of the Garmin device. The Garmin
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`devices transfer the new-media file to the cellular phone so that it is stored, over the
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`established wireless connection, wherein the cellular phone is configured to use HTTP to
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`upload the received new-media file, along with the user’s account information, to a media
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`publishing website for the user, including social media, news, database, Garmin’s websites,
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`or other websites. In addition, and in the alternative, to Garmin’s making, offering for sale,
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`and/or selling of the Garmin devices and applications, upon information and belief, at least
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`through Garmin’s hardware, software, and efforts to test, demonstrate, and otherwise use
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`Garmin devices, Garmin has used the claimed devices, systems, and computer-readable
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`media via at least the use of the Garmin devices, comprising at least the foregoing steps.
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`33. Garmin has had notice of its infringement of the ’698 patent pursuant to notifications
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`from Plaintiff comprising letters mailed on June 15, 2017 and August 31, 2017.
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`34. Additionally, or in the alternative, Garmin has induced, and continues to induce,
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`infringement of the ’698 Patent in this judicial district, the State of California, and elsewhere,
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`by intentionally inducing direct infringement of the ’698 Patent, including by knowingly and
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`actively aiding or abetting infringement by users, by and through at least instructing and
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`encouraging the use of the Garmin products and software noted above. Such aiding and
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`abetting comprises providing devices, software, websites, and/or instructions regarding the
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`use and/or operation of the Garmin devices, applications, and websites in an infringing
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`manner, and further including providing the accused Garmin devices and applications to
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`users who, in turn, use the claimed devices, systems, and computer-readable media,
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`including as noted above. Further, the direct infringement of the claimed methods by users
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`that occurs in connection with Garmin’s applications and/or websites occurs under the
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`direction or control of Garmin, including Garmin software and hardware, including because
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`user devices perform said steps in order to receive the benefits of Garmin’s websites and/or
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` ORIGINAL COMPLAINT