`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
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`HUMANEYES TECHS., LTD.,
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`JURY TRIAL DEMANDED
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`Defendants.
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`Plaintiff,
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`SONY ELECS., ]NC., SONY CORP., SONY )
`CORP. or AMERICA, SONY MOBILE
`)
`COMMS. AB, SONY MOBILE COMMS.
`)
`(USA), INC.,
`
`Plaintiff HumanEyes Technologies, Ltd., by and through its attorneys, for its Complaint
`
`for Patent Infringement against Defendants Sony Electronics Inc., Sony Corporation, Sony
`
`Corporation of America, Sony Mobile Communications AB, and Sony Mobile Communications
`
`(USA) Inc., alleges as follows, upon personal knowledge with respect to its own acts, and upon
`
`information and belief with respect to the circumstances and fact of others:
`
`PARTIES
`
`1.
`
`HumanEyes Technologies, Ltd. (“HumanEyes”) is a company organized under
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`the laws of Israel having its principal place of business located at 1-4 High Tech Village,
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`Edmond Safra Campus, The Hebrew University, Givat Ram, 91390 Jerusalem, Israel.
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`HumanEyes Technologies, Inc. is controlled by and is a wholly-owned subsidiary of HumanEyes
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`Technologies, Ltd. and is a corporation organized and existing under the laws of the State of
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`Delaware, with its principle place of business at 366 North Broadway, Suite 410—C1, Jericho,
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`New York, 11753.
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`2.
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`On information and belief, Sony Corporation (“Sony Corp.”) is a corporation
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`existing and organized under the laws of Japan with its principal place of business at 1-7-1
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`Konan, Minato-ku, Tokyo 108-0075, Japan.
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`3.
`
`On information and belief, Sony Corporation of America (“SCA”) is a subsidiary
`
`of Sony Corp. and is a corporation organized and existing under the laws of the State of New
`
`York, with its principal place of business at 550 Madison Avenue, 27"‘ Floor, New York, NY
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`10022-3211. SCA is registered to do business in Delaware. Its registered agent for service of
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`process in Delaware is The Corporation Trust Company, Corporation Trust Center, 1209 Orange
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`Street, Wilmington, DE 19801.
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`4.
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`On information and belief, Sony Electronics Inc. (“SEI”) is a wholly-owned
`
`subsidiary of SCA, is an indirect subsidiary of Sony Corp., and is a Delaware corporation with
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`its principal place of business located at 16530 Via Esprillo, San Diego, CA 92127-1708. SEI’s
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`registered agent for service of process is Corporation Service Company, 2711 Centerville Road,
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`Suite 400, Wilmington, DE 19808.
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`5.
`
`On information and belief, Sony Mobile Communications AB (“Sony Mobile
`
`AB”) is a subsidiary of Sony Corp. and is a company organized and existing under the laws of
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`Sweden with its principal place of business at 202 Hammersmith Rd, London W6 7DN, United
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`Kingdom.
`
`6.
`
`On information and belief, Sony Mobile Communications (USA) Inc. (“Sony
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`Mobile (USA)”) is an indirect subsidiary of Sony Corp. and is a Delaware corporation with its
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`principal place of business located at 3333 Piedmont Road, Suite 600, Atlanta, Georgia 30305.
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`Sony Mobile (USA)’s registered agent for service of process is Capitol Services, Inc., 1675
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`South State Street, Suite B, Dover, DE, 19901.
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`7.
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`On information and belief, Sony Corp., SCA, SEI, Sony Mobile AB, and Sony
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`Mobile (USA), (collectively, “Sony”) individually and/or collectively and in concert, are
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`engaged in the design, manufacture, importation into the United States, sale for importation, and
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`sale after importation of the Accused Products (defined below).
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`JURISDICTION AND VENUE
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`8.
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`This civil action for patent infringement arises under the patent laws of the United
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`States, 35 U.S.C. § 100 et seq., including in particular under 35 U.S.C. § 271. This Court has
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`subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and l338(a).
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`9.
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`Sony Corp. is subject to personal jurisdiction in this Court because, upon
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`information and belief, Sony Corp. does and has done substantial business in this district,
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`including both independently and through and with its subsidiaries and various commercial
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`arrangements by placing its products, including those that infringe HumanEyes’ patents, into the
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`stream of commerce, which stream is directed at the State of Delaware and this district, with the
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`knowledge and/or understanding that such products would be sold in the State of Delaware and
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`this district.
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`10.
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`On information and belief, Sony Corp. has sufficient minimum contacts with the
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`district that an exercise of personal jurisdiction over Sony Corp. would not offend traditional
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`notions of fair play and substantial justice and would be appropriate under Delaware Code Title
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`10, Section 3104.
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`ll.
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`SCA is subject to personal jurisdiction in this Court because, upon information
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`and belief, SCA does and has done substantial business in this district, including both
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`independently and through and with its subsidiaries and various commercial arrangements by
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`placing its products, including those that infringe HumanEyes’ patents, into the stream of
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`commerce, which stream is directed at the State of Delaware and this district, with the
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`knowledge and/or understanding that such products would be sold in the State of Delaware and
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`this district.
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`12.
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`On information and belief, SCA has sufficient minimum contacts with the district
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`that an exercise of personal jurisdiction over SCA would not offend traditional notions of fair
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`play and substantial justice and would be appropriate under Delaware Code Title 10, Section
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`3 104.
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`13.
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`SE1 is incorporated in Delaware and, therefore, resides in and is subject to
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`personal jurisdiction in this judicial district.
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`14.
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`Sony Mobile AB is subject to personal jurisdiction in this Court because, upon
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`information and belief, Sony Mobile AB does and has done substantial business in this district,
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`including both independently and in concert with Sony Corp. and its subsidiaries and through
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`various commercial arrangements by placing its products, including those that infringe
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`Humar1Eyes’ patents, into the stream of commerce, which stream is directed at the State of
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`Delaware and this district, with the knowledge and/or understanding that such products would be
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`sold in the State of Delaware and this district.
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`15.
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`On information and belief, Sony Mobile AB has sufficient minimum contacts
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`with the district that an exercise of personal jurisdiction over Sony Mobile AB would not offend
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`traditional notions of fair play and substantial justice and would be appropriate under Delaware
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`Code Title 10, Section 3104.
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`16.
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`Sony Mobile (USA) is incorporated in Delaware and, therefore, resides in and is
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`subject to personal jurisdiction in this judicial district.
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`17.
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`Venue is proper in this judicial district under 28 U.S.C. §§ 139l(b) and (c) and/or
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`and 1400(b).
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`BACKGROUND AS TO ALL COUNTS
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`18.
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`Conventional methods of generating 3D images require special, expensive double
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`lens cameras. In 1998, Professor SlunuelPe1eg, a world-renowned figure in Computer Vision,
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`and members of his research team proposed an innovative, new method for generating 3D
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`panoramic images by combining portions of multiple images recorded by an ordinary camera.
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`This breakthrough has made it possible to bring inexpensive 3D photography to standard digital
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`cameras and mobile devices. Professor Peleg and his co—inventors were awarded patent
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`protection by the U.S. Patent and Trademark Office for that technology in U.S. Patent Nos.
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`6,665,003 and 7,477,284 (collectively, the “Asserted Patents”).
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`19.
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`In 2000, HumanEyes Technologies, Ltd. (“HumanEyes”) was founded to further
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`develop and commercialize products that realize the innovative potential of Professor Peleg and
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`his team’s discoveries in generating and displaying 3D mosaic images and related technologies.
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`HumanEyes, the exclusive licensee to Professor Peleg’s 3D stereo panoramic patents, applies
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`that patented vision to provide a complete, end-to-end solution for creating and printing 3D
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`photographic effects.
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`20.
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`Inventor an_d HumanEyes co-founder Shmuel Peleg is widely recognized as a
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`leading scholar and researcher in the field of Computer Vision, with over 127 publications and
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`16 U.S. Patents.
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`21.
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`Professor Peleg’s prominence in the field of Computer Vision is well-known to
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`Sony. Sony Corporation Research Engineer Dr. Kenji Tanaka has cited to Professor Peleg’s
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`work in at least three of his own publications and described Professor Peleg as “one of the most
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`famous people in this field” during correspondence between Dr. Tanaka and Professor Peleg in
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`2004. Professor Peleg’s works have also been cited by Sony and/or the PTO examiner in at least
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`5 of Sony’s U.S. patents (U.S. Patent Nos. 7,542,606; 7,764,283; 7,831,086; 7,840,095; and
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`8,086,072) and at least 7 of Sony’s published U.S. Patent Applications (U.S. Patent Application
`
`Pub. Nos. 2011/0122953, 2011/0123131, 2011/0286526, 2011/0293014, 2010/0289881,
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`2011/0293195, 2012/0019725).
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`22.
`
`Professor Peleg and others at HumanEyes have discussed Professor Pe1eg’s
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`breakthrough work on 3D panorama mosaic imaging with employees at Sony—including at least
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`Dr. Tanaka, Toshiyuki Ogura, and Atsushi Iizuka at Sony Corporation; marketing director Mary
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`Abram at Sony Electronics Inc.; and Senior Vice President of Sony Corporation of America’s
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`“Sony 3D Technology Center” Buzz Hays—since at least December, 2004.
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`THE ASSERTED PATENTS
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`23.
`
`United States Patent No. 6,665,003 (’003), entitled “System and Method for
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`Generating and Displaying Panoramic Images and Movies,” issued on December 16, 2003, to
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`inventors Shmuel Peleg, Moshe Ben—Ezra, and Robert S. Rosenschein. Yissum Research
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`Development Company of the Hebrew University of Jerusalem was assigned all right, title, and
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`interest in the ’003 patent by the named inventors and is presently owner. HumanEyes is the
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`exclusive licensee of the ’003 patent, with all substantial rights and interest in practicing,
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`sublicensing, and enforcement. A true and correct copy of the ’003 patent is attached to this
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`Complaint as Exhibit A.
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`24.
`
`U.S. Patent No. 7,477,284 (’284), entitled “System and Method for Capturing and
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`Viewing Stereoscopic Panoramic Images,” issued on January 13, 2009, to inventors Shmuel
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`Peleg, Moshe Ben-Ezra, and Yael Pritch. Yissum Research Development Company of the
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`Hebrew University of Jerusalem was assigned all right, title, and interest in the ’284 patent by
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`the named inventors and is presently owner. HumanEyes is the exclusive licensee of the ’284
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`patent, with all substantial rights and interest in practicing, sublicensing, and enforcement. A
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`true and correct copy of the ’284 patent is attached to this Complaint as Exhibit B.
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`25.
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`HumanEyes is the exclusive licensee of the ’003 and ’284- patents, with all
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`substantial rights and interest in practicing, sublicensing, and enforcing each.
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`THE ACCUSED PRODUCTS
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`26.
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`The Accused Products are cameras and mobile devices and associated firmware
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`and/or sofiwarel that, together or independently, are capable of generating 3D panoramic mosaic
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`images.
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`27.
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`On information and belief, Sony’s 3D Sweep Panorama mode and/or Sweep
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`Multi-Angle mode and those cameras and mobile devices that are sold with or may be adapted
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`for use with the 3D Sweep Panorama mode and/or Sweep Multi-Angle mode—including but not
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`limited to Cyber-shot (DSC) models HX7V, HX9V, HXIOV, HX2OV/B, HX30V/B, HXIOOV,
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`HXZOOV, TX9, TXIO, TX20, TX55, TX66, TXIOOV, TXZOOV, WX5, WX9, WX10, WXSO,
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`WXl50; DSLR (01 series) models NEX-3, NEX-C3, NEX-5, NEX—5N, NEX-7, 01560, $80,
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`or33L, 085, 065V, 065V, a65VK, d77V, and o[77VQ; and mobile device (Xperia) models active,
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`arc, are S, ion, neo, neo V, mini pro, pro, ray, and Live with Walkman—infringe at least one
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`claim of the Asserted Patents.
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`COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,665,003
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`28.
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`HumanEyes incorporates by reference paragraphs 1 through 27 of this Complaint
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`as if fully set forth herein.
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`1 The associated firmware and/or software include, for example, operating systems, user
`interfaces, and application software, and the firmware associated with an image sensor.
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`29.
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`Upon information and belief, Sony has infringed and continues to infringe and/or
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`induce infi-ingement of one or more claims of the ’003 patent in violation of 35 U.S.C. § 271(a),
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`(b) and/or (c), literally or under the doctrine of equivalents, by making, using, offering for sale,
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`and selling in the United States and by importing into the United States, without authority, the
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`Accused Products.
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`30.
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`On information and belief, Sony directly infringes and/or will infringe the ’003
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`patent by making, using, selling, offering for sale, and importing the Accused Products
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`practicing at least one claim of the ’003 patent.
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`31.
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`On information and belief, Sony has knowledge of the ’0O3 patent, at least
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`because Sony was provided with a copy of this Complaint.
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`32.
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`On information and belief, Sony Corp. has had knowledge of the ’003 patent
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`since at least May 13, 2009 because the ’003 patent is cited and discussed in Sony Corp.’s
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`Singapore Patent Application No. 200903332-5 and its U.S. counterpart, U.S. Patent Application
`
`No. 12/775,024, which is assigned to Sony Corp.
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`33.
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`Upon information and belief, SCA, SE1, Sony Mobile AB, and Sony Mobile
`
`(USA) have had constructive knowledge of the ’003 patent since at least on or around May 13,
`
`2009, at least because Sony Corp. had knowledge of the ’003 patent since then.
`
`34.
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`Given the prominence of Professor Peleg’s work and Sony’s knowledge of the
`
`patents, upon information and belief, Sony either (a) has knowledge that making, using, selling,
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`offering for sale, and importing the Accused Products constitute infringement of the ’003 patent,
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`or (b) subjectively believes that there has been and continues to be a high risk that making, using,
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`selling, offering for sale, and importing the Accused Products constitute infiingement of the ’003
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`{006l7962;v1 }
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`patent and has taken deliberate steps to avoid determining whether the acts actually constitute
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`infringement.
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`35.
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`Sony has made, used, sold, offered for sale, and imported and continues to make,
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`use, sell, offer for sale, and import the Accused Products despite an objectively high likelihood
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`that its actions, individually and collectively, constitute infringement of the ’OO3 patent.
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`Moreover, upon information and belief, the risk that its actions constitute infringement of a valid
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`U.S. patent was either actually known to Sony or, given the prominence of Professor Pe1eg’s
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`work and Sony’s knowledge of the patents and of HumanEyes’ work back to at least 2004, is and
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`was so clear that it should have been known to Sony.
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`36.
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`On infonnation and belief, Sony indirectly infringes the ’OO3 patent by actively
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`inducing the infringement of at least one claim of the ’OO3 patent, including without limitation by
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`knowingly inducing infringement by end users of the Accused Products.
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`37.
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`On information and belief, Sony contributes to the infringement of at least one
`
`claim of the ’OO3 patent because Sony knows that the Accused Products are made for use in
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`infringement and are not staple articles of commerce suitable for substantial non-infringing use.
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`38.
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`HumanEyes has been and continues to be damaged by Sony’s infringement of the
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`’OO3 patent in an amount to be determined at trial.
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`39.
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`Upon information and belief, Sony’s infringement of the ’OO3 patent has been and
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`continues to be willful, entitling HumanEyes to enhanced damages pursuant to 35 U.S.C. § 284.
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`40.
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`Upon information and belief, Sony’s actions make this an exceptional case
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`pursuant to 35 U.S.C. § 285.
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`{O06l7962;vl }
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`COUNT II: INFRINGEMENT OF U.S. PATENT NO. 7 477 284
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`41.
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`HumanEyes incorporates by reference paragraphs 1 through 40 of this Complaint
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`as if fully set forth herein.
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`42.
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`Upon information and belief, Sony has infringed and continues to infringe and/or
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`induce infringement of one or more claims of the ’284 patent in violation of 35 U.S.C. § 271(a),
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`(b) and/or (c), literally or under the doctrine of equivalents, by making, using, offering for sale,
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`and selling in the United States and by importing into the United States, without authority, the
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`Accused Products.
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`43.
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`On information and belief, Sony directly infringes and/or will infringe the ’284
`
`patent by making, using, selling, offering for sale, and importing the Accused Products
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`practicing at least one claim of the ’284 patent.
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`44.
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`On information and belief, Sony currently has knowledge of the ’284 patent, at
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`least because Sony was provided with a copy of this Complaint.
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`45.
`
`On information and belief, Sony Corp. and SEI have had knowledge of the ’284
`
`patent since at least April 1 1, 2011 because the ’284 patent was cited and discussed by the PTO
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`examiner in an April 11, 2011 non-final rejection during the prosecution of U.S. Patent No.
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`8,086,072 assigned to Sony Corp. and SEI.
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`46.
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`Upon information and belief, SCA, Sony Mobile AB, and Sony Mobile (USA)
`
`have had constructive knowledge of the ’284 patent since at least on or around April 11, 2011 at
`
`least because Sony Corp. and SE1 had knowledge since then.
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`47.
`
`Given the prominence of Professor Peleg’s work and Sony’s knowledge of the
`
`patents, upon information and belief, Sony either (a) has knowledge that making, using, selling,
`
`offering for sale, and importing the Accused Products constitute infringement of the ’284 patent,
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`{00617962;v1 }
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`l0
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`or (b) subjectively believes that there has been and continues to be a high risk that making, using,
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`selling, offering for sale, and importing the Accused Products constitute infiingement of the ’284
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`patent and has taken deliberate steps to avoid determining whether the acts actually constitute
`
`infringement.
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`48.
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`Sony has made, used, sold, offered for sale, and imported and continues to make,
`
`use, sell, offer for sale, and import the Accused Products despite an objectively high likelihood
`
`that its actions, individually and collectively, constitute infringement of the ’284 patent.
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`Moreover, upon information and belief, the risk that its actions constitute infringement of a valid
`
`U.S. patent was either actually known to Sony or, given the prominence of Professor Peleg’s
`
`work and Sony’s knowledge of the patents, is and was so clear that it should have been known to
`
`Sony.
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`49.
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`On information and belief, Sony indirectly infringes the ’284 patent by actively
`
`inducing the infringement of the ’284 patent, including without limitation by end users of the
`
`Accused Products.
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`50.
`
`On information and belief, Sony contributes to the infringement of the ’284 patent
`
`because Sony knows that the Accused Products are made for use in infringement and are not
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`staple articles of commerce suitable for substantial non-infringing use.
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`51.
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`HumanEyes has been and continues to be damaged by Sony’s infringement of the
`
`’284 patent in an amount to be determined at trial.
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`52.
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`Upon information and belief, Sony’s infringement of the ’284 patent has been and
`
`continues to be Wlllflll, entitling HumanEyes to enhanced damages pursuant to 35 U.S.C. § 284.
`
`53.
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`Upon information and belief, Sony’s actions make this an exceptional case
`
`pursuant to 35 U.S.C. § 285.
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`l 1
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`DEMAND FOR JURY TRIAL
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`54.
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`Pursuant to Federal Rule of Civil Procedure 38(b), Human]-Eyes demands a trial
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`by jury.
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`PRAYER FOR RELIEF
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`WHEREFORE, HumanEyes respectfully prays that this Court enter judgment in its favor
`
`as follows:
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`a) declaring that Sony has directly infiinged, induced infringement of, and/or
`
`contributed to the infringement of one or more claims of the Asserted Patents;
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`b) awarding HumanEyes all damages adequate to compensate for Sony’s
`
`infringement, and in no event less than a reasonably royalty for Sony’s acts of infringement,
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`including all pre-judgment and post—j udgment interest at the maximum rate allowed by law; and
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`c) awarding HumanEyes treble damages pursuant to 35 U.S.C. § 284 as a result of
`
`Sony’s willful conduct;
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`(1) declaring this to be an exceptional case and awarding HumanEyes its attorneys’
`
`fees pursuant to 35 U.S.C. § 285; and
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`e) awarding HumanEyes any further and additional relief as the Court may deem just
`
`and equitable.
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`{00617962;v1 }
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`12
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`ASHBY & GEDDES
`
`TJHO»; 9)‘!/41 AK
`
`Steven J. Balick (ID. #2114)
`Tiffany Geyer Lydon (I.D. #3950)
`Andrew C. Mayo (ID. #5207)
`500 Delaware Avenue, 8”‘ Floor
`P.O. Box 1150
`
`Wilmington, Delaware 19899
`(302) 654-1888
`sba1ick@ashby-geddes.com
`tlydon@ashby-geddes.com
`amayo@ashby-geddes.com
`
`Attorneysfor Plaintiff
`
`Of Counsel:
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`Matthew D. Powers
`
`Steven S. Cherensky
`Paul T. Ehrlich
`Stefani C. Smith
`
`Robert L. Gerrity
`TENSEGRITY LAW GROUP LLP
`
`555 Twin Dolphin Drive, Suite 360
`Redwood Shores, CA 94065
`(650) 802-6000
`
`Dated: March 29, 2012
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`{00617962;v1 }
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`1 3