Case 1:16-cv-04586-LTS Document 22-7 Filed 01/31/17 Page 1 of 3
`Case: l:16-cv-06915 Document#: 1Filed: 07/01/16 Page 18 of 20 PagelD #:18
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`COUNT III- INFRINGEMENT OF U.S. PATENT NO. 6.430.603
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`61.
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`The allegations set forth inthe foregoing paragraphs 1through 60 are hereby re¬
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`alleged and incorporated herein by reference.
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`62.
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`Upon information and belief, in violation of 35 U.S.C. § 271, Defendant has
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`directly infringed and continues to directly infringe, literally or under the doctrine of equivalents,
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`or has indirectly infringed and continues to indirectly infringe, one or more claims of the '603
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`Patent by making, using, offering for sale, selling, or importing devices or systems, inthis judicial
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`district and elsewhere in the United States (directly or through intermediaries), that perform the
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`steps of schedulingthe presentation ofvideo or still-image content at selectedtime slots on selected
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`electronic displays, that are provided at various geographic locations and interconnected by a
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`network, receiving video or still-image content from a content provider, communicating scheduled
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`content to respective server devices associated with corresponding selected electronic displays and
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`initiating display of the content at selected times on corresponding selected electronic displays of
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`the network, where split screen images can be displayed as claimed in at least claims 42 and 43 of
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`the '603 Patent, without the authority of T-Rex Property AB.
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`63.
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`More specifically, the infringing devices and systems include Defendant's digital
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`signage network.
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`64.
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`Upon information and belief, Defendant has directly infringed and continues to
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`directly infringe one or more claims of the '603 Patent, including at least claims 42 and 43, by
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`operating its digital network in Illinois and elsewhere in the United States.
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`65.
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`Upon information and belief, Defendant has indirectly infringed and continues to
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`indirectly infringe one or more claims of the '603 Patent, including at least claims 42 and 43, by
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`marketing, promoting, soliciting, offering to sell, and selling its digital network in Illinois and
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`elsewhere in the United States that when used as intended and directed by Defendant, infringes at
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`least claims 42 and 43 of the '603 Patent, either literally or under the doctrine of equivalents.
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`Case 1:16-cv-04586-LTS Document 22-7 Filed 01/31/17 Page 2 of 3
`Case: l:l6-cv-06915 Document#: 1Filed: 07/01/16 Page 19 of 20 PagelD #:19
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`66.
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`Defendant has had knowledge of the '603 Patent since at least the date that this
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`Complaint was served.
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`67.
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`Because of Defendant's infringing activities, T-Rex Property AB has suffered
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`damages and will continue to suffer damages in the future. T-Rex Property AB is entitled to
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`recover from Defendant the damages sustained by T-Rex Property AB as a result of Defendant's
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`wrongful acts in an amount subject to proof at trial, which, by law, cannot be less than a reasonable
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`royalty, together with interest and costs as fixed by this Court under 35 U.S.C. § 284.
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`Plaintiff T-Rex Property AB hereby requests a trial by jury pursuant to Rule 38 of the
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`JURY DEMAND
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`Federal Rules of Civil Procedure.
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`PRAYER FOR RELIEF
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`Plaintiff T-Rex Property AB respectfully requests that the Court find in its favor and
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`against Defendant, and that the Court grant Plaintiff the following relief:
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`A.
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`an adjudication that Defendant has infringed the '470 Patent, the '334 Patent, and
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`the '603 Patent;
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`B.
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`an award of damages to be paid by Defendant adequate to compensate Plaintiff for
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`Defendant's past infringement of the'470 Patent, the '334 Patent, and the '603 Patent and any
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`continuing or
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`future infringement
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`through the date such judgment
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`is entered,
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`including
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`prejudgment and post-judgment interest, costs, expenses and an accounting of all infringing acts
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`including, but not limited to, those acts not presented at trial;
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`C.
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`an injunction ordering Defendant to pay an ongoing royalty in an amount to be
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`determined for any continued infringement after the date judgment is entered; and,
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`D.
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`an award to Plaintiff of such further relief at law or in equity as the Court deems
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`just and proper, including, but not limited to costs, fees, expenses, interest, and/or attorneys' fees.
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`Case 1:16-cv-04586-LTS Document 22-7 Filed 01/31/17 Page 3 of 3
`Case: l:l6-cv-06915 Document#: 1Filed: 07/01/16 Page 20 of 20 PagelD #:20
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`Dated: July 1,2016
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`Respectfully submitted,
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`/s/ William C. Spence_
`William Cory Spence
`Jacob Robert Graham
`SPENCE, P.C.
`405 N. Wabash Ave., Suite P2E
`Chicago, Illinois 60611
`312-704-8882
`William.Spence@spencepc.com
`Jacob.Graham@spencepc.com
`Counselfor Plaintiff
`T-Rex Property AB
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