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`Plaintiff,
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`LBT IP I LLC,
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`APPLE INC.,
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`v.
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`Defendant.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`Civil Action No. _____________
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff LBT IP I LLC (“LBT”) files this complaint for patent infringement against
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`Defendant Apple Inc. (“Apple”).
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`PARTIES
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`1.
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`Plaintiff LBT is a limited liability company organized and existing under the laws
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`of Delaware with its principal place of business at 455 Elm Street, Suite 100, Graham, Texas
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`76450. LBT is the owner by assignment of the following U.S. patents (collectively, the “Asserted
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`Patents”):
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`a. U.S. Patent No. 8,497,774, titled “Apparatus and Method for Adjusting Refresh
`Rate of Location Coordinates of a Tracking Device” (the “’774 Patent”) (a copy
`of which is attached as Exhibit A);
`
`b. U.S. Patent No. 8,542,113, titled “Apparatus and Method for Determining
`Location and Tracking Coordinates of a Tracking Device” (the “’113 Patent”) (a
`copy of which is attached as Exhibit B);
`
`c. U.S. Patent No. 8,102,256, titled “Apparatus and Method for Determining
`Location and Tracking Coordinates of a Tracking Device” (the “’256 Patent”) (a
`copy of which is attached as Exhibit C);
`
`d. U.S. Patent No. 8,421,618, titled “Apparatus and Method for Determining
`Location and Tracking Coordinates of a Tracking Device” (the “’618 Patent”) (a
`copy of which is attached as Exhibit D); and
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`e. U.S. Patent No. 8,421,619, titled “Apparatus and Method for Determining
`Location and Tracking Coordinates of a Tracking Device” (the “’619 Patent”) (a
`copy of which is attached as Exhibit E).
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`Upon information and belief, Defendant Apple is a California corporation with a
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`2.
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`regular and established place of business at 125 Christiana Mall, Newark, DE 19702. Apple may
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`be served with process through its registered agent for service of process in Delaware, The
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`Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE
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`19801.
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`3.
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`Apple directly and/or indirectly makes, imports, distributes, markets, sells and/or
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`offers to sell throughout the United States, including in this judicial district, products and/or
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`services (“the Accused Products”) that infringe one or more claims of the Asserted Patents as
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`described below. The Accused Products include all Apple devices, including iPhones and iPads,
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`that have a low power mode, core location feature and/or facedown detection mode as more full
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`described below.
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`JURISDICTION AND VENUE
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`4.
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`This is an action for patent infringement, arising under the patent laws of the
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`United States, 35 U.S.C. §§ 1, et seq.
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`5.
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. §§
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`1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over Apple because it has substantial,
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`continuing, and ongoing contacts with this judicial district, and sells, distributes, and/or offers to
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`sell into this judicial district the Accused Products through the Apple Store in Newark, DE,
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`through the apple.com website and through third-party vendors.
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`7.
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`Upon information and belief, venue is proper in this judicial district pursuant to
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`28 U.S.C. §§1391(b)-(c) and § 1400(b) because Apple transacts business in this judicial district
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`and because it is subject to personal jurisdiction in this judicial district.
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`The Asserted Patents
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`8.
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`Each of the Asserted Patents generally claims improvements in battery
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`conservation of portable electronic devices. Filed between 2008 and 2012, they were originally
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`assigned to Location Based Technologies, Inc., who commercialized the claimed technology in
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`its PocketFinder GPS devices.
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`9.
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`Battery conservation has become a critical aspect of portable electronic devices,
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`with many consumers rating it as a high priority in purchasing decisions. According to a recent
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`Consumer Reports article, “[t]o some smartphone users, battery life is the single most important
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`factor in choosing a device.” See https://www.consumerreports.org/smartphones/smartphones-
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`with-the-best-battery-life/, accessed on May 31, 2019 (emphasis added).
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`10.
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`The Asserted Patents improve battery life through systems and methods that
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`monitor various signals and inputs received by the portable electronic device and using those
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`signals and inputs to control battery consumption. Each of the claimed systems and methods
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`improve the operation of computer systems in the context of portable electronic devices and
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`represent unconventional uses of technology as of the Asserted Patents’ respective filing dates.
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`See, for example, Ex. A at col. 2, l. 46 – col. 3, l. 51; Ex. B at col. 2, l, 45 – col. 3, l. 21; Ex. C at
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`col. 2, l. 40 – col. 3, l. 15; Ex. D at col. 2, l. 44 – col. 3, l. 20; Ex. E at col. 2, l. 44 – col. 3, l. 20
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`(describing inventive aspects of the various patents and their improvements over the prior art).
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`11.
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`As a result of the improvements claimed by the Asserted Patents, the battery life
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`for Apple’s Accused Products has been extended to the point that Apple’s iPhone home page
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`advertising its newest model, the iPhone XR, mentions only one feature: “The longest battery life
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`ever in an iPhone.” See https://www.apple.com/iphone/, accessed on May 31, 2019.
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`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 8,497,774
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`12.
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`LBT re-alleges and incorporates herein by reference the allegations stated in
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`paragraphs 1-11 of this Complaint.
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`13.
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`Apple has infringed and is continuing to infringe, literally or through the doctrine
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`of equivalents, directly, jointly, or indirectly, contributorily and/or through the inducement of
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`others, one or more claims of the ’774 Patent, by making, using, offering to sell and/or selling in
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`this judicial district and elsewhere within the United States and/or importing into the United
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`States its Accused Products, constituting infringement under 35 U.S.C. § 271 (a), (b), (c) and/or
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`(g).
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`14.
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`Apple’s direct infringement includes using the system of at least claims 1, 4, 5, 8,
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`13, and 15 of the ’774 Patent. Specifically, Apple’s direct infringement includes making, using,
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`selling, offering to sell and/or importing a system by which it monitors and adjusts battery
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`consumption in the manner claimed in the above-identified claims.
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`15.
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`For example, the Accused Products include a “low power mode” that reduces or
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`stops certain background activity, including background activity related to transceiver circuitry
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`and/or processor circuitry associated with the Accused Products’ GPS functionality, in order to
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`conserve battery life.
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`16.
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`As a result of the activities described above, Apple is liable for direct
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`infringement of the above-identified claims of the ’774 Patent under 35 U.S.C. § 271(a).
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`17.
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`To the extent any factfinder concludes that Apple does not literally satisfy any
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`element of the claims of the ’774 Patent, those elements are met under the Doctrine of
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`Equivalents.
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`18.
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`Alternatively and in addition to its liability for direct infringement of the above-
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`identified claims of the ’774 Patent, Apple is also liable for indirectly infringing the above-
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`identified claims of the ’774 Patent in this judicial district and elsewhere in the United States by
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`inducing direct infringement in violation of 35 U.S.C. § 271(b) and by contributing to direct
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`infringement in violation of 35 U.S.C. § 271(c).
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`19.
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`Apple has been aware of the ’774 Patent and the infringing nature of its Accused
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`Products since June 24, 2019 when LBT sent a letter to Apple giving it actual notice of the
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`infringement.
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`20.
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`The direct infringement induced or contributed to by Apple includes at least the
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`use of the Accused Products by Apple’s customers.
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`21.
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`Apple encourages continued direct infringement of the above-identified claims of
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`the ’774 Patent by at least providing on its website and in the Accused Products themselves
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`instructions for conducting the directly infringing use.
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`22.
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`Apple induces continued infringement by at least encouraging and instructing its
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`customers to provide some or all of the claimed elements, including instructing them on the use
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`of the low power mode, with the knowledge that that such use constitutes infringement of the
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`’774 Patent.
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`23.
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`Apple contributes to direct infringement of the asserted claims of the ’774 Patent
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`by providing its customers with the necessary software and instructions to operate the Accused
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`Products, including instructions related to the low power mode. The low power mode is not a
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`staple article of commerce and has no substantial non-infringing uses. It is specifically designed
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`to work with the Accused Products and its only purpose is to operate in a manner that directly
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`infringes the asserted claims of the ’774 Patent.
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`COUNT II – INFRINGEMENT OF U.S. PATENT NO. 8,542,113
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`24.
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`LBT re-alleges and incorporates herein by reference the allegations stated in
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`paragraphs 1-23 of this Complaint.
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`25.
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`Apple has infringed and is continuing to infringe, literally or through the doctrine
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`of equivalents, directly, jointly, or indirectly, contributorily and/or through the inducement of
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`others, one or more claims of the ’113 Patent, by making, using, offering to sell and/or selling in
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`this judicial district and elsewhere within the United States and/or importing into the United
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`States its Accused Products, constituting infringement under 35 U.S.C. § 271 (a), (b), (c) and/or
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`(g).
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`26.
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`Apple’s direct infringement includes using the methods and systems of at least
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`claims 1-4, 7-14, and 17-18 of the ’113 Patent. Specifically, Apple’s direct infringement includes
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`making, using, selling, offering to sell and/or importing Accused Products that adjust the power
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`level of location tracking circuitry based on the strength of certain location-related signals in the
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`manner claimed in the above-identified claims.
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`27.
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`For example, the Accused Products include a “core location” feature that reduces
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`or stops certain background activity, including background activity related to transceiver
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`circuitry and/or processor circuitry associated with the Accused Products’ GPS functionality, in
`
`order to conserve battery life.
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`28.
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`As a result of the activities described above, Apple is liable for direct
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`infringement of the above-identified claims of the ’113 Patent under 35 U.S.C. § 271(a).
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`29.
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`To the extent any factfinder concludes that Apple does not literally satisfy any
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`element of the claims of the ’113 Patent, those elements are met under the Doctrine of
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`Equivalents.
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`30.
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`Alternatively and in addition to its liability for direct infringement of the above-
`
`identified claims of the ’113 Patent, Apple is also liable for indirectly infringing the above-
`
`identified claims of the ’113 Patent in this judicial district and elsewhere in the United States by
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`inducing direct infringement in violation of 35 U.S.C. § 271(b) and by contributing to direct
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`infringement in violation of 35 U.S.C. § 271(c).
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`31.
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`Apple has been aware of the ’113 Patent and the infringing nature of its Accused
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`Products since June 24, 2019 when LBT sent a letter to Apple giving it actual notice of the
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`infringement.
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`32.
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`The direct infringement induced or contributed to by Apple includes at least the
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`use of the Accused Products by Apple’s customers.
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`33.
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`Apple encourages continued direct infringement of the above-identified claims of
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`the ’113 Patent by at least providing on its website and in the Accused Products themselves
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`instructions for conducting the directly infringing use.
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`34.
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`Apple induces continued infringement by at least encouraging and instructing its
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`customers to perform some or all of the claimed steps, including instructing them on the use of
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`the low power mode, with the knowledge that that such use constitutes infringement of the ’113
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`Patent.
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`35.
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`Apple contributes to direct infringement of the asserted claims of the ’113 Patent
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`by providing its customers with the necessary software and instructions to operate the Accused
`
`Products, including instructions related to the core location functionality. The core location
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`functionality is not a staple article of commerce and has no substantial non-infringing uses. It is
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`specifically designed to work with the Accused Products and its only purpose is to operate in a
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`manner that directly infringes the asserted claims of the ’113 Patent.
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`COUNT III – INFRINGEMENT OF U.S. PATENT NO. 8,102,256
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`36.
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`LBT re-alleges and incorporates herein by reference the allegations stated in
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`paragraphs 1-35 of this Complaint.
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`37.
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`Apple has infringed and is continuing to infringe, literally or through the doctrine
`
`of equivalents, directly, jointly, or indirectly, contributorily and/or through the inducement of
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`others, one or more claims of the ’256 Patent, by making, using, offering to sell and/or selling in
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`this judicial district and elsewhere within the United States and/or importing into the United
`
`States its Accused Products, constituting infringement under 35 U.S.C. § 271 (a), (b), (c) and/or
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`(g).
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`38.
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`Apple’s direct infringement includes using the systems of claim 10 of the ’256
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`Patent. Specifically, Apple’s direct infringement includes making, using, selling, offering to sell
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`and/or importing a system by which it monitors and adjusts battery consumption in the manner
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`claimed in the above-identified claim.
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`39.
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`For example, the Accused Products include a “facedown detection mode” that
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`uses an accelerometer to generate displacement vectors that are used to reduce or stop certain
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`background activity, including background activity associated with the Accused Products’ GPS
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`functionality, in order to conserve battery life.
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`40.
`
`As a result of the activities described above, Apple is liable for direct
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`infringement of the above-identified claim of the ’256 Patent under 35 U.S.C. § 271(a).
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`41.
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`To the extent any factfinder concludes that Apple does not literally satisfy any
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`element of the asserted claim of the ’256 Patent, those elements are met under the Doctrine of
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`Equivalents.
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`42.
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`Alternatively and in addition to its liability for direct infringement of the above-
`
`identified claim of the ’256 Patent, Apple is also liable for indirectly infringing the above-
`
`identified claim of the ’256 Patent in this judicial district and elsewhere in the United States by
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`inducing direct infringement in violation of 35 U.S.C. § 271(b) and by contributing to direct
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`infringement in violation of 35 U.S.C. § 271(c).
`
`43.
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`Apple has been aware of the ’256 Patent and the infringing nature of its Accused
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`Products since June 24, 2019 when LBT sent a letter to Apple giving it actual notice of the
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`infringement.
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`44.
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`The direct infringement induced or contributed to by Apple includes at least the
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`use of the Accused Products by Apple’s customers.
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`45.
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`Apple encourages continued direct infringement of the above-identified claim of
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`the ’256 Patent by at least providing on its website and in the Accused Products themselves
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`instructions for conducting the directly infringing use.
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`46.
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`Apple induces continued infringement by at least encouraging and instructing its
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`customers to meet some or all of the claimed elements, including instructing them on the use of
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`the facedown detection mode, with the knowledge that that such use constitutes infringement of
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`the ’256 Patent.
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`47.
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`Apple contributes to direct infringement of the asserted claim of the ’256 Patent
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`by providing its customers with the necessary software and instructions to operate the Accused
`
`Products, including instructions related to the facedown detection mode. The facedown detection
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`mode is not a staple article of commerce and has no substantial non-infringing uses. It is
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`specifically designed to work with the Accused Products and its only purpose is to operate in a
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`manner that directly infringes the asserted claim of the ’256 Patent.
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`COUNT IV – INFRINGEMENT OF U.S. PATENT NO. 8,421,618
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`48.
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`LBT re-alleges and incorporates herein by reference the allegations stated in
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`paragraphs 1-47 of this Complaint.
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`49.
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`Apple has infringed and is continuing to infringe, literally or through the doctrine
`
`of equivalents, directly, jointly, or indirectly, contributorily and/or through the inducement of
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`others, one or more claims of the ’618 Patent, by making, using, offering to sell and/or selling in
`
`this judicial district and elsewhere within the United States and/or importing into the United
`
`States its Accused Products, constituting infringement under 35 U.S.C. § 271 (a), (b), (c) and/or
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`(g).
`
`50.
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`Apple’s direct infringement includes using the systems and methods of claims 1,
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`9-16, and 19-24 of the ’618 Patent. Specifically, Apple’s direct infringement includes making,
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`using, selling, offering to sell and/or importing devices that monitor and adjust battery
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`consumption in the manner claimed in the above-identified claim.
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`51.
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`For example, the Accused Products include a facedown detection mode that uses
`
`an accelerometer to generate displacement vectors that are used to reduce or stop certain
`
`background activity, including background activity related to transceiver circuitry and/or
`
`processor circuitry associated with the Accused Products’ GPS functionality, in order to
`
`conserve battery life.
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`52.
`
`As a result of the activities described above, Apple is liable for direct
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`infringement of the above-identified claims of the ’618 Patent under 35 U.S.C. § 271(a).
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`53.
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`To the extent any factfinder concludes that Apple does not literally satisfy any
`
`element of the claims of the ’618 Patent, those elements are met under the Doctrine of
`
`Equivalents.
`
`54.
`
`Alternatively and in addition to its liability for direct infringement of the above-
`
`identified claims of the ’618 Patent, Apple is also liable for indirectly infringing the above-
`
`identified claims of the ’618 Patent in this judicial district and elsewhere in the United States by
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`inducing direct infringement in violation of 35 U.S.C. § 271(b) and by contributing to direct
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`infringement in violation of 35 U.S.C. § 271(c).
`
`55.
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`Apple has been aware of the ’618 Patent and the infringing nature of its Accused
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`Products since June 24, 2019 when LBT sent a letter to Apple giving it actual notice of the
`
`infringement.
`
`56.
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`The direct infringement induced or contributed to by Apple includes at least the
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`use of the Accused Products by Apple’s customers.
`
`57.
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`Apple encourages continued direct infringement of the above-identified claims of
`
`the ’618 Patent by at least providing on its website and in the Accused Products themselves
`
`instructions for conducting the directly infringing use.
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`58.
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`Apple induces continued infringement by at least encouraging and instructing its
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`customers to perform some or all of the claimed steps, including instructing them on the use of
`
`the facedown detection mode, with the knowledge that that such use constitutes infringement of
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`the ’618 Patent.
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`59.
`
`Apple contributes to direct infringement of the asserted claims of the ’618 Patent
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`by providing its customers with the necessary software and instructions to operate the Accused
`
`Products, including instructions related to the facedown detection mode. The facedown detection
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`11
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`mode is not a staple article of commerce and has no substantial non-infringing uses. It is
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`specifically designed to work with the Accused Products and its only purpose is to operate in a
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`manner that directly infringes the asserted claims of the ’618 Patent.
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`COUNT V – INFRINGEMENT OF U.S. PATENT NO. 8,421,619
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`60.
`
`LBT re-alleges and incorporates herein by reference the allegations stated in
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`paragraphs 1-59 of this Complaint.
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`61.
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`Apple has infringed and is continuing to infringe, literally or through the doctrine
`
`of equivalents, directly, jointly, or indirectly, contributorily and/or through the inducement of
`
`others, one or more claims of the ’619 Patent, by making, using, offering to sell and/or selling in
`
`this judicial district and elsewhere within the United States and/or importing into the United
`
`States its Accused Products, constituting infringement under 35 U.S.C. § 271 (a), (b), (c) and/or
`
`(g).
`
`62.
`
`Apple’s direct infringement includes using the systems and methods of claims 1,
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`3, 5-7, 11, 12, and 14-17 of the ’619 Patent. Specifically, Apple’s direct infringement includes
`
`making, using, selling, offering to sell and/or importing devices that monitor and adjust battery
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`consumption in the manner claimed in the above-identified claims.
`
`63.
`
`For example, the Accused Products include a facedown detection mode that uses
`
`an accelerometer to generate displacement vectors that are used to reduce or stop certain
`
`background activity, including background activity related to transceiver circuitry and/or
`
`processor circuitry associated with the Accused Products’ GPS functionality, in order to
`
`conserve battery life.
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`64.
`
`As a result of the activities described above, Apple is liable for direct
`
`infringement of the above-identified claims of the ’619 Patent under 35 U.S.C. § 271(a).
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`65.
`
`To the extent any factfinder concludes that Apple does not literally satisfy any
`
`element of the claims of the ’619 Patent, those elements are met under the Doctrine of
`
`Equivalents.
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`66.
`
`Alternatively and in addition to its liability for direct infringement of the above-
`
`identified claims of the ’619 Patent, Apple is also liable for indirectly infringing the above-
`
`identified claims of the ’619 Patent in this judicial district and elsewhere in the United States by
`
`inducing direct infringement in violation of 35 U.S.C. § 271(b) and by contributing to direct
`
`infringement in violation of 35 U.S.C. § 271(c).
`
`67.
`
`Apple has been aware of the ’619 Patent and the infringing nature of its Accused
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`Products since June 24, 2019 when LBT sent a letter to Apple giving it actual notice of the
`
`infringement.
`
`68.
`
`The direct infringement induced or contributed to by Apple includes at least the
`
`use of the Accused Products by Apple’s customers.
`
`69.
`
`Apple encourages continued direct infringement of the above-identified claims of
`
`the ’619 Patent by at least providing on its website and in the Accused Products themselves
`
`instructions for conducting the directly infringing use.
`
`70.
`
`Apple induces continued infringement by at least encouraging and instructing its
`
`customers to perform some or all of the claimed steps, including instructing them on the use of
`
`the facedown detection mode, with the knowledge that that such use constitutes infringement of
`
`the ’619 Patent.
`
`71.
`
`Apple contributes to direct infringement of the asserted claims of the ’619 Patent
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`by providing its customers with the necessary software and instructions to operate the Accused
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`Products, including instructions related to the low power mode. The facedown detection mode is
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`not a staple article of commerce and has no substantial non-infringing uses. It is specifically
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`designed to work with the Accused Products and its only purpose is to operate in a manner that
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`directly infringes the asserted claims of the ’619 Patent.
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`DAMAGES
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`72.
`
`Apple’s acts of infringement have caused damage to LBT and LBT is entitled to
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`recover from Apple the damages it has sustained as a result of Apple’s wrongful acts in an
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`amount subject to proof at trial. Apple’s infringement of LBT’s exclusive rights under the
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`Asserted Patents will continue to damage LBT, causing irreparable harm for which there is no
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`adequate remedy at law, unless enjoined by this Court. Apple’s ongoing infringement is willful
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`and deliberate, as Apple became aware of the infringing nature of its Accused Products prior to
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`the filing of this Complaint, entitling LBT to increased damages and reasonable attorneys’ fees
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`for post-complaint infringement pursuant to 35 U.S.C. §§ 284 and 285.
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`PRAYER FOR RELIEF
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`WHEREFORE, LBT prays that it has judgment against Defendant Apple Inc. for the
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`following:
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`(1)
`
`(2)
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`Adjudging that Defendant Apple Inc. has infringed the Asserted Patents;
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`Permanently enjoining and restraining Defendant Apple Inc. and its agents,
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`servants, employees, affiliates, divisions, and subsidiaries, and those in association, active
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`concert or participation with any of them, from further acts of infringement, contributory
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`infringement or inducement of infringement of any asserted claim of the Asserted Patents;
`
`(3)
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`A judicial decree that Defendant Apple Inc. pay an ongoing royalty in an amount
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`to be determined for continued infringement after the date of judgment;
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`(4)
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`Awarding damages to LBT, together with both pre-judgment and post-judgment
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`interest;
`
`(5)
`
`(6)
`
`(7)
`
`expenses; and
`
`Awarding increased damages pursuant to 35 U.S.C. § 284;
`
`Finding this action constitutes an exceptional case pursuant to 35 U.S.C. § 285;
`
`Awarding LBT all of its costs in this action, including attorneys’ fees and
`
`(8)
`
`Awarding such other and further relief, at law or in equity, to which LBT is justly
`
`entitled.
`
`JURY DEMAND
`
`LBT hereby demands a jury trial on all issues so triable.
`
`
`
`
`
`Dated: July 1, 2019
`
`Of Counsel:
`
`Brian S. Seal
`Thomas G. Southard
`BUTZEL LONG
`1909 K. Street N.W. Suite 500
`Washington, DC 20006
`Telephone: (202) 454-2800
`seal@butzel.com
`southard@butzel.com
`
`
`YOUNG CONAWAY STARGATT & TAYLOR LLP
`/s/ Karen L. Pascale
`
`
`
`Karen L. Pascale (#2903) [kpascale@ycst.com]
`Robert M. Vrana (#5666) [rvrana@ycst.com]
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`Telephone: (302) 571-6600
`
`Attorneys for Plaintiff LBT IP I LLC
`
` 01:24673101.1
`
`15
`
`
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