`
`
`
`
`
`
`Edward R. Nelson (Pro Hac Vice to be submitted)
`Texas Bar No. 00797142
`Ryan P. Griffin (Pro Hac Vice to be submitted)
`Texas Bar No. 24053687
`Christopher G. Granaghan (Pro Hac Vice to be submitted)
`Texas Bar No. 24078585
`ed@nbafirm.com
`ryan@nbafirm.com
`chris@nbafirm.com
`NELSON BUMGARDNER ALBRITTON P.C.
`3131 West Seventh Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
`
`Christopher D. Banys (SBN 230038)
`Richard C. Lin (SBN 209233)
`Jennifer L. Gilbert (SBN 255820)
`cdb@banyspc.com
`rcl@banyspc.com
`jlg@banyspc.com
`BANYS, P.C.
`1030 Duane Avenue
`Santa Clara, CA 95054
`Telephone: (650) 308-8505
`Facsimile: (650) 353-2202
`
`Attorneys for Plaintiff
`FIRSTFACE CO., LTD.
`
`
`
`UNITED STATES DISTRICT COURT
`
` NORTHERN DISTRICT OF CALIFORNIA
`
`
`
`
`CASE NO. 18-CV-2245
`
`ORIGINAL COMPLAINT
`FOR PATENT INFRINGEMENT
`
`DEMAND FOR JURY TRIAL
`
`
`
`
`FIRSTFACE CO., LTD.,
`
`Plaintiff,
`
`
`v.
`
`
`APPLE INC.,
`
`Defendant.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`CASE NO.: 18-CV-2245
`
`
`
`
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 2 of 63
`
`
`
`
`Plaintiff Firstface Co., Ltd. files this Original Complaint against Apple Inc. for infringement of
`U.S. Patent No. 8,831,557 (“the ’557 patent”), U.S. Patent No. 9,633,373 (“the ’373 patent”), and U.S.
`Patent No. 9,779,419 (“the ’419 patent”).
`
`THE PARTIES
`1.
`Firstface Co., Ltd. (“Firstface”) is a corporation organized and existing under the laws of
`the Republic of Korea with a principal place of business at 22F, Seoul City Tower, 110, Huam ro, Jung-
`Gu, Seoul, 04637, Korea.
`2.
`Apple Inc. (“Apple”) is a California corporation with its principal place of business in
`Cupertino, California, within the Northern District of California. This Defendant may be served with
`process through its agent, CT Corporation System, 818 West Seventh Street, Suite 930, Los Angeles,
`California 90017. Apple does business in the State of California and in the Northern District of
`California.
`
` JURISDICTION AND VENUE
`3.
`This action arises under the patent laws of the United States, namely 35 U.S.C. §§ 271,
`281, and 284-285, among others.
`4.
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`5.
`Venue is proper in this judicial district under 28 U.S.C. § 1400(b). Apple resides in this
`district, has committed acts of infringement in this district, and has a regular and established place of
`business in this district.
`6.
`Apple is subject to this Court’s specific and general personal jurisdiction pursuant to due
`process and/or the California Long Arm Statute, due at least to its substantial business in this State and
`judicial district, including: (1) at least part of its infringing activities alleged herein; and (2) regularly
`doing or soliciting business, engaging in other persistent conduct, and/or deriving substantial revenue
`from goods sold and services provided to California residents.
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 8,831,557)
`Firstface incorporates paragraphs 1 through 6 herein by reference.
`
`7.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`1
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`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 3 of 63
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`8.
`Firstface is the assignee of the ’557 patent, entitled “Method, System, and Mobile
`Communication Terminal for Performing Specific Function When Mobile Communication Terminal Is
`Activated,” with ownership of all substantial rights in the ’557 patent, including the right to exclude
`others and to enforce, sue, and recover damages for past, present, and future infringements. A true and
`correct copy of the ’557 patent is attached as Exhibit A.
`9.
`The ’557 patent is valid, enforceable, and was duly issued in full compliance with Title 35
`of the United States Code.
`10.
`Apple has directly infringed and/or indirectly infringed, and continues to directly infringe
`and/or indirectly infringe, one or more claims of the ’557 patent in this judicial district and elsewhere in
`California and the United States, without the consent or authorization of Firstface, including at least
`claims 1, 8, 9, and 15 by, among other things, making, using, offering for sale, selling, and/or importing
`Apple mobile devices that support fingerprint authentication. Such Apple mobile devices include iPhone
`5s, iPhone 6, iPhone 6 Plus, iPhone 6s Plus, iPhone SE, iPhone 7, iPhone 7 Plus, iPhone 8, iPhone 8 Plus,
`iPad (2017 version, a/k/a the iPad (5th generation)), iPad (2018 version, a/k/a the iPad (6th generation)),
`iPad Air 2, iPad mini 3, iPad mini 4, iPad Pro (12.9 inch) (1st generation), iPad Pro (9.7 inch) (1st
`generation), iPad Pro (12.9 inch) (2nd generation), and iPad Pro (10.5 inch) (2nd generation). These
`devices are collectively referred to in this Count as the “Accused Products.”
`11.
`Apple directly infringes the apparatus claims of the ’557 patent by making, using, offering
`to sell, selling, and/or importing the Accused Products. Apple also directly infringes the ’557 patent by
`making, using, selling, offering to sell, and/or importing the Accused Products to practice the claimed
`methods. Apple is therefore liable for direct infringement.
`12.
`Specifically, each of the Accused Products has a display unit and an activation button (or
`“home button”) that, when pressed, switches the display from an off state to an on state. Each of the
`Accused Products also contains a user identification unit that uses fingerprint recognition to identify the
`user simultaneously with switching the display from the off state to the on state. The user identification
`function recognizes a user by comparing a fingerprint acquired by the activation button with fingerprint
`information of a user stored in the device.
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`2
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`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 4 of 63
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`13.
`Additionally, Apple is liable for indirect infringement of the ’557 patent because it
`induces and/or contributes to the direct infringement of the patent by its customers and other end users.
`14.
`Apple learned of the ’557 patent in early 2015 when Firstface presented Apple with an
`opportunity to purchase and/or license Firstface’s patent portfolio, including the ’557 patent. Apple also
`has knowledge of the ’557 patent at least based on filing and service of this Complaint.
`15.
`Despite having knowledge of the ’557 patent, Apple has specifically intended, and
`continues to specifically intend, for persons who acquire and use the Accused Products, including its
`customers, to use such devices in a manner that infringes the ’557 patent. This is evident when Apple
`encourages and instructs customers and other end users in the use and operation of the Accused Products,
`including use of the activation button to turn on the display and unlock the device using fingerprint
`authentication.
`16.
`In particular, despite having knowledge of the ’557 patent, Apple has provided, and
`continues to provide, instructional materials, such as user guides, owner manuals, and similar online
`resources (available via https://support.apple.com, for instance) that specifically teach and encourage
`customers and other end users to use the Accused Products in an infringing manner. By providing such
`instructions, Apple knows (and has known), or should know (and should have known), that its actions
`have actively induced, and continue to actively induce, infringement.
`17.
`Additionally, Apple knows, and has known, that the Accused Products include proprietary
`hardware components and software instructions that work in concert to perform specific, intended
`functions. Such specific, intended functions, carried out by these hardware and software combinations,
`are a material part of the inventions of the ’557 patent and are not staple articles of commerce suitable for
`substantial non-infringing uses.
`18.
`Specifically, each Accused Product contains memory and a processor that are specifically
`programmed and/or configured to implement the functionality described in paragraph 12, which infringes
`the ’557 patent. Apple is, thus, liable for contributory infringement.
`19.
`Firstface has been damaged as a result of Apple’s infringing conduct described in this
`Count. Apple is, thus, liable to Firstface in an amount that adequately compensates it for Apple’s
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`infringements, which, by law, cannot be less than a reasonable royalty, together with interest and costs as
`fixed by this Court under 35 U.S.C. § 284.
`20.
`Despite having knowledge of the ’557 patent, and knowledge that it is potentially directly
`and/or indirectly infringing claims of the ’557 patent, Apple has nevertheless continued its infringing
`conduct in an egregious manner. On information and belief, Apple reviewed the claims of the ’557
`patent, yet continued to manufacture and sell infringing products. At the very least, Apple was willfully
`blind to the ’557 patent and its application to the Accused Products. For at least these reasons, Apple’s
`infringing activities have been, and continue to be, willful, wanton, and deliberate in disregard of
`Firstface’s rights with respect to the ’557 patent, justifying enhanced damages under 35 U.S.C. § 284.
`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO. 9,633,373)
`21.
`Firstface incorporates paragraphs 1 through 20 herein by reference.
`22.
`Firstface is the assignee of the ’373 patent, entitled “Activating Display and Performing
`Additional Function in Mobile Terminal With One-Time User Input,” with ownership of all substantial
`rights in the ’373 patent, including the right to exclude others and to enforce, sue, and recover damages
`for past, present, and future infringements. A true and correct copy of the ’373 patent is attached as
`Exhibit B.
`23.
`The ’373 patent is valid, enforceable, and was duly issued in full compliance with Title 35
`of the United States Code.
`24.
`Apple has directly infringed and/or indirectly infringed, and continues to directly infringe
`and/or indirectly infringe, one or more claims of the ’373 patent in this judicial district and elsewhere in
`California and the United States, without the consent or authorization of Firstface, including at least
`claims 1-2, 4-6, and 11-14, by, among other things, making, using, offering for sale, selling, and/or
`importing Apple mobile devices that support fingerprint authentication and Siri functionality, including
`iPhone 5s, iPhone 6, iPhone 6 Plus, iPhone 6s Plus, iPhone SE, iPhone 7, iPhone 7 Plus, iPhone 8, iPhone
`8 Plus, iPad (2017 version, a/k/a the iPad (5th generation)), iPad (2018 version, a/k/a the iPad (6th
`generation)), iPad Air 2, iPad mini 3, iPad mini 4, iPad Pro (12.9 inch) (1st generation), iPad Pro (9.7
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`4
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`inch) (1st generation), iPad Pro (12.9 inch) (2nd generation), and iPad Pro (10.5 inch) (2nd generation).
`In addition, Apple has directly infringed and/or indirectly infringed, and continues to directly infringe
`and/or indirectly infringe, at least claims 10 and 18 of the ’373 patent in this judicial district and
`elsewhere in California and the United States, by, among other things, making, using, offering for sale,
`selling and/or importing Apple smartphones that support fingerprint authentication and Siri functionality,
`including iPhone 5s, iPhone 6, iPhone 6 Plus, iPhone 6s Plus, iPhone SE, iPhone 7, iPhone 7 Plus, iPhone
`8, and iPhone 8 Plus. The devices listed in this paragraph are collectively referred to in this Count as the
`“Accused Products.”
`25.
`Apple directly infringes the apparatus claims of the ’373 patent by making, using, offering
`to sell, selling, and/or importing the Accused Products. Apple also directly infringes the ’373 patent by
`making, using, selling, offering to sell, and/or importing the Accused Products to practice the claimed
`methods. Apple is therefore liable for direct infringement.
`26.
`Specifically, each of the Accused Products (many of which are smartphones) has a touch
`screen display, a camera, a power button configured to turn on and off the device by pressing, and an
`activation button (or “home button”) separate from the power button and located outside the touchscreen
`display that, when pressed, turns on the touch screen display and can initiate one or more additional
`functions of the device. Each Accused Product includes a fingerprint authentication function (performed
`by a user identification module and configured in user settings) and a Siri function (a hands-free
`function). Upon pressing of the activation button (sensed by an activation sensor), each Accused Product
`is configured to turn on the touch screen display and perform fingerprint authentication (a first function).
`A lock screen is displayed on the touch screen display while the fingerprint authentication is performed.
`If the fingerprint authentication authenticates the user, the Accused Product is configured to release the
`lock state. If the fingerprint authentication fails to authenticate the user, the Accused Product is
`configured to continue the lock state and display a message (e.g., a “Try Again” message) on the touch
`screen display. In addition, upon pressing of the activation button for longer than a reference time
`period, each Accused Product is configured to activate the Siri functionality (a second function) after
`turning on the touch screen display.
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`27.
`Apple is also liable for indirect infringement of the ’373 patent because it induces and/or
`contributes to the direct infringement of the patent by its customers and other end users.
`28.
`Apple has knowledge of the ’373 patent at least based on filing and service of this
`Complaint.
`29.
`Despite having knowledge of the ’373 patent, Apple has specifically intended, and
`continues to specifically intend, for persons who acquire and use the Accused Products, including its
`customers, to use such devices in a manner that infringes the ’373 patent. This is evident when Apple
`encourages and instructs customers and other end users in the use and operation of the Accused Products,
`including use of the activation button to turn on the display, unlock the device using fingerprint
`authentication, and activate Siri.
`30.
`In particular, despite having knowledge of the ’373 patent, Apple has provided, and
`continues to provide, instructional materials, such as user guides, owner manuals, and similar online
`resources (available via https://support.apple.com, for instance) that specifically teach and encourage
`customers and other end users to use the Accused Products in an infringing manner. By providing such
`instructions, Apple knows (and has known), or should know (and should have known), that its actions
`have actively induced, and continue to actively induce, infringement.
`31.
`Additionally, Apple knows, and has known, that the Accused Products include proprietary
`hardware components and software instructions that work in concert to perform specific, intended
`functions. Such specific, intended functions, carried out by these hardware and software combinations,
`are a material part of the inventions of the ’373 patent and are not staple articles of commerce suitable for
`substantial non-infringing uses.
`32.
`Specifically, each Accused Product contains a memory and processor that are specifically
`programmed and/or configured to implement the functionality described in paragraph 26, which infringes
`the ’373 patent. Apple is, thus, liable for contributory infringement.
`33.
`Firstface has been damaged as a result of Apple’s infringing conduct described in this
`Count. Apple is, thus, liable to Firstface in an amount that adequately compensates it for Apple’s
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`infringements, which, by law, cannot be less than a reasonable royalty, together with interest and costs as
`fixed by this Court under 35 U.S.C. § 284.
`
`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO. 9,779,419)
`34.
`Firstface incorporates paragraphs 1-33 herein by reference.
`35.
`Firstface is the assignee of the ’419 patent, entitled “Activating Display and Performing
`User Authentication in Mobile Terminal With One-Time User Input,” with ownership of all substantial
`rights in the ’419 patent, including the right to exclude others and to enforce, sue, and recover damages
`for past, present, and future infringements. A true and correct copy of the ’419 patent is attached as
`Exhibit C.
`36.
`The ’419 patent is valid, enforceable, and was duly issued in full compliance with Title 35
`of the United States Code.
`37.
`Apple has directly infringed and/or indirectly infringed, and continues to directly infringe
`and/or indirectly infringe, one or more claims of the ’419 patent in this judicial district and elsewhere in
`California and the United States, without the consent or authorization of Firstface, including at least
`claims 1-4, 6-7, 10, 12-13, and 15-17, by, among other things, making, using, offering for sale, selling,
`and/or importing Apple mobile devices that support fingerprint authentication and Siri functionality.
`Such Apple mobile devices include iPhone 5s, iPhone 6, iPhone 6 Plus, iPhone 6s Plus, iPhone SE,
`iPhone 7, iPhone 7 Plus, iPhone 8, iPhone 8 Plus, iPad (2017 version, a/k/a the iPad (5th generation)),
`iPad (2018 version, a/k/a the iPad (6th generation)), iPad Air 2, iPad mini 3, iPad mini 4, iPad Pro (12.9
`inch) (1st generation), iPad Pro (9.7 inch) (1st generation), iPad Pro (12.9 inch) (2nd generation), and
`iPad Pro (10.5 inch) (2nd generation). In addition, Apple has directly infringed and/or indirectly
`infringed, and continues to directly infringe and/or indirectly infringe, at least claim 9 of the ’419 patent
`in this judicial district and elsewhere in California and the United States, by, among other things, making,
`using, offering for sale, selling and/or importing Apple smartphones that support fingerprint
`authentication and Siri functionality, including iPhone 5s, iPhone 6, iPhone 6 Plus, iPhone 6s Plus,
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`iPhone SE, iPhone 7, iPhone 7 Plus, iPhone 8, and iPhone 8 Plus. The devices listed in this paragraph are
`collectively referred to in this Count as the “Accused Products.”
`38.
`Apple directly infringes the apparatus claims of the ’419 patent by making, using, offering
`to sell, selling, and/or importing the Accused Products. Apple also directly infringes the ’419 patent by
`making, using, selling, offering to sell, and/or importing the Accused Products to practice the claimed
`methods. Apple is therefore liable for direct infringement.
`39.
`Specifically, each of the Accused Products (many of which are smartphones) has a touch
`screen display, a camera, a power button that turns on and off the device by pressing, and an activation
`button separate from the power button and located outside the touchscreen display that, when pressed,
`turns on the touch screen display. Each Accused Product includes a fingerprint authentication function
`(performed by a user identification module and configured in user settings) and a Siri function (a hands-
`free operation and an operation that involves playing a sound). Upon pressing of the activation button
`(sensed by an activation sensor), each Accused Product is configured to turn on the touch screen display
`and perform fingerprint authentication. A lock screen is displayed on the touch screen display while the
`fingerprint authentication is performed. If the fingerprint authentication authenticates the user, the
`Accused Product is configured to release the lock state. If the fingerprint authentication fails to
`authenticate the user, the Accused Product is configured to continue the lock state and display a message
`(e.g., a “Try Again” message) on the touch screen display. In addition, upon pressing of the activation
`button for longer than a reference time period, each Accused Product is configured to activate the Siri
`functionality after turning on the touch screen display.
`40.
`Apple is also liable for indirect infringement of the ’419 patent because it induces and/or
`contributes to the direct infringement of the patent by its customers and other end users.
`41.
`Apple has knowledge of the ’419 based on filing and service of this Complaint.
`42.
`Despite having knowledge of the ’419 patent, Apple has specifically intended, and
`continues to specifically intend, for persons who acquire and use the Accused Products, including its
`customers, to use such devices in a manner that infringes the ’419 patent. This is evident when Apple
`encourages and instructs customers and other end users in the use and operation of the Accused Products,
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
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`including use of the activation button to turn on the display, unlock the device using fingerprint
`authentication, and activate Siri.
`43.
`In particular, despite having knowledge of the ’419 patent, Apple has provided, and
`continues to provide, instructional materials, such as user guides, owner manuals, and similar online
`resources (available via https://support.apple.com, for instance) that specifically teach and encourage
`customers and other end users to use the Accused Products in an infringing manner. By providing such
`instructions, Apple knows (and has known), or should know (and should have known), that its actions
`have actively induced, and continue to actively induce, infringement.
`44.
`Additionally, Apple knows, and has known, that the Accused Products include proprietary
`hardware components and software instructions that work in concert to perform specific, intended
`functions. Such specific, intended functions, carried out by these hardware and software combinations,
`are a material part of the inventions of the ’419 patent and are not staple articles of commerce suitable for
`substantial non-infringing uses.
`45.
`Specifically, each Accused Product contains a memory and processor that are specifically
`programmed and/or configured to implement the functionality described in paragraph 39, which infringes
`the ’419 patent. Apple is, thus, liable for contributory infringement.
`46.
`Firstface has been damaged as a result of Apple’s infringing conduct described in this
`Count. Apple is, thus, liable to Firstface in an amount that adequately compensates it for Apple’s
`infringements, which, by law, cannot be less than a reasonable royalty, together with interest and costs as
`fixed by this Court under 35 U.S.C. § 284.
`
`JURY DEMAND
`Firstface hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of Civil
`Procedure.
`
`PRAYER FOR RELIEF
`Firstface requests that the Court find in its favor against Apple, and that the Court grant Firstface
`the following relief:
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 11 of 63
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`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`Judgment that one or more claims of the ’557, ’373, and ’419 patents have been infringed,
`either literally and/or under the doctrine of equivalents, by Apple and/or by others whose
`infringements have been induced by Apple and/or by others to whose infringements Apple
`contributed;
`
`Judgment that Apple account for and pay to Firstface all damages to, and costs incurred
`by, Firstface because of Apple’s infringing activities and other conduct complained of
`herein;
`Judgment that Apple account for and pay to Firstface a reasonable, ongoing, post-
`judgment royalty because of Apple’s infringing activities and other conduct complained of
`herein;
`That Apple’s infringement of the ’557 patent be found willful from the time that Apple
`became aware of the infringing nature of its products, and that the Court award treble
`damages pursuant to 35 U.S.C. § 284;
`That Firstface be granted pre-judgment and post-judgment interest on the damages caused
`by Apple’s infringing activities and other conduct complained of herein; and
`That Firstface be granted such other and further relief as the Court may deem just and
`proper under the circumstances.
`
`
`
`
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`
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`
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`
`
`Dated: April 13, 2018
`
`
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`
`
` Respectfully submitted,
`
`/s/ Christopher D. Banys______
`
`Edward R. Nelson (Pro Hac Vice to be submitted)
`Texas Bar No. 00797142
`Ryan P. Griffin (Pro Hac Vice to be submitted)
`Texas Bar No. 24053687
`Christopher G. Granaghan (Pro Hac Vice to be
`submitted)
`Texas Bar No. 24078585
`ed@nbafirm.com
`ryan@nbafirm.com
`chris@nbafirm.com
`NELSON BUMGARDNER ALBRITTON P.C.
`3131 West Seventh Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
`
`Christopher D. Banys (SBN 230038)
`Richard C. Lin (SBN 209233)
`Jennifer L. Gilbert (SBN 255820)
`cdb@banyspc.com
`rcl@banyspc.com
`jlg@banyspc.com
`BANYS, P.C.
`1030 Duane Avenue
`Santa Clara, CA 95054
`Telephone: (650) 308-8505
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`10
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`
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`CASE NO.: 18-CV-2245
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`1 2 3 4 5 6 7 8 9
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`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 12 of 63
`
`Facsimile: (650) 353-2202
`
`
`
` Attorneys for Plaintiff FIRSTFACE CO., LTD.
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`11
`
`
`
`CASE NO.: 18-CV-2245
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
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`18
`19
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`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 13 of 63
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`
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`Exhibit “A”
`
`
`
`US008831557B2
`
`(12) United States Patent
`Jung et al.
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 8,831,557 B2
`Sep. 9, 2014
`
`(54) METHOD, SYSTEM, AND MOBILE
`COMMUNICATION TERMINAL FOR
`PERFORMING SPECIFIC FUNCTION WHEN
`MOBILE COMMUNICATION TERMINALIS
`ACTIVATED
`
`(*) Notice:
`
`(75) Inventors: Jae Lark Jung, Goyang-si (KR):
`Kyoung Duck Bae, Seoul (KR)
`(73) Assignee: IdeaZZan Company, Inc., Seoul (KR)
`Subject to any disclaimer, the term of this
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 0 days.
`(21) Appl. No.: 13/590,483
`(22) Filed:
`Aug. 21, 2012
`
`(65)
`
`(30)
`
`Prior Publication Data
`US 2013/O102273 A1
`Apr. 25, 2013
`
`Foreign Application Priority Data
`
`Oct. 19, 2011 (KR) ........................ 10-2011-O106839
`
`(2006.01)
`(2006.01)
`(2009.01)
`(2009.01)
`(2006.01)
`
`(51) Int. Cl.
`H04M II/04
`H04M 1/725
`HO4W 4/22
`HO4W 4/O2
`HO4M 1/67
`(52) U.S. Cl.
`CPC ............ H04M 1/72519 (2013.01); H04W 4/22
`(2013.01); H04W 4/02 (2013.01); H04M
`2250/52 (2013.01); H04M I/7258 (2013.01);
`H04M I/67 (2013.01)
`USPC ........................................ 455/404.2:455/566
`(58) Field of Classification Search
`CPC .................................. H04W 4/02; H04W 4/22
`
`USPC ............................................... 455/404.2, 566
`See application file for complete search history.
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`6,636,732 B1 * 10/2003 Boling et al. .............. 455,404.1
`7,668,829 B2* 2/2010 Chu et al. ...
`... 455,412.1
`8,538,370 B2 * 9/2013 Ray et al. ...........
`... 455,404.1
`2003/0018395 A1
`1/2003 Crinkovich et al. ............. TOOf 11
`2006/0142071 A1* 6/2006 Stephens ............
`455,575..1
`2008/006661.0 A1
`3/2008 Chu et al. ........................ 84.609
`2008/0070622 A1
`3/2008 Lee ............................ 455,556.1
`2010.0102939 A1
`4/2010 Stewart
`2012/005283.6 A1
`3/2012 Buratti et al. .............. 455,404.2
`2012/0302200 A1* 11/2012 Esbensen .......
`... 455,404.2
`2013/0102273 A1* 4/2013 Jung et al. ...
`... 455,404.2
`2013/0102363 A1* 4/2013 Jung et al. ..................... 455,566
`
`
`
`FOREIGN PATENT DOCUMENTS
`
`1998-085.647 A 12/1998
`KR
`10-2001-0026243 A
`4/2001
`KR
`10-2005-00794.75 A
`8, 2005
`KR
`10-2010-0027855. A
`3, 2010
`KR
`* cited by examiner
`
`Primary Examiner — Charles Shedrick
`(74) Attorney, Agent, or Firm — The PL Law Group, PLLC
`
`ABSTRACT
`(57)
`Provided is a mobile communication terminal including a
`display unit and an activation button configured to Switch
`from an inactive state, which is an OFF state of the display
`unit, to an active state, which is an ON state of the display unit,
`wherein a predetermined operation is performed simulta
`neously with Switching to the active state by pressing the
`activation button.
`
`15 Claims, 5 Drawing Sheets
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 14 of 63
`
`
`
`U.S. Patent
`
`Sep. 9, 2014
`
`Sheet 1 of 5
`
`US 8,831,557 B2
`
`FIG. 1
`
`100
`
`
`
`130
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 15 of 63
`
`
`
`U.S. Patent
`
`Sep. 9, 2014
`
`Sheet 2 of 5
`
`US 8,831,557 B2
`
`FIG 2
`
`
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 16 of 63
`
`
`
`U.S. Patent
`
`Sep. 9, 2014
`
`Sheet 3 of 5
`
`US 8,831,557 B2
`
`FIG 3A
`
`
`
`Activation sensing unit
`
`Health sensing unit
`
`Health information transmission init
`
`FIG. 3B
`
`
`
`Camera activation eierrerit
`
`Eyebai detection element
`
`Health information acquisition element
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 17 of 63
`
`
`
`U.S. Patent
`
`Sep. 9, 2014
`
`Sheet 4 of 5
`
`US 8,831,557 B2
`
`FIG. 4A
`
`
`
`
`
`FIG. 4B
`
`FIG. 5
`
`
`
`Activation sensing init
`
`iser identification
`
`it
`
`Carera activation eierrent
`
`iris detection element
`
`Riser identification eierrett
`
`Activation sensing unit
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 18 of 63
`
`Location infortation collection unit
`
`location infortation trainst tission init
`
`
`
`U.S. Patent
`
`Sep. 9, 2014
`
`Sheet 5 of 5
`
`US 8,831,557 B2
`
`FIG. 6
`
`O
`
`Communication
`tfit
`
`24.
`
`*
`
`Y-w
`
`
`
`2----
`
`Application providing Erit
`
`2O ---
`
`Activation sensing unit
`
`23.-----
`
`Application driving unit
`
`250
`
`Case 3:18-cv-02245-JD Document 1 Filed 04/13/18 Page 19 of 63
`
`
`
`US 8,831,557 B2
`
`1.
`METHOD, SYSTEM, AND MOBILE
`COMMUNICATION TERMINAL FOR
`PERFORMING SPECIFIC FUNCTION WHEN
`MOBILE COMMUNICATION TERMINALIS
`ACTIVATED
`
`CROSS-REFERENCE TO RELATED
`APPLICATION
`
`This application claims the benefit of Korean Patent Appli
`cation No. 10-2011-0106839, filed on Oct. 19, 2011, and all
`the benefits accruing therefrom under 35 U.S.C. S 119 which
`is hereby incorporated by reference as if fully set forth herein.
`
`10
`
`BACKGROUND
`
`15
`
`1. Field
`The disclosure relates to a method, a system, and a mobile
`communication terminal for performing a specific function
`when a mobile communication terminal is activated, and
`more particularly to a method, a system, and a mobile com
`munication terminal for performing various functions
`according to the number of presses or a press time of a button
`for Switching from an inactive state to an active state.
`2. Description of the Related Art
`Recently, various terminals, for example, Such as Smart
`phones, mobile phones, personal digital assistants (PDAs),
`and web pads, having not only communication functions but
`also various other functions have come into wide use. These
`terminals have rapidly been gene