Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 1 of 19
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
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`CASE NO.
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`Intellectual Ventures I LLC and
`Intellectual Ventures II LLC,
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`Plaintiffs,
`
`v.
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`Motorola Mobility LLC,
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`Defendant.
`________________________________________/
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiffs Intellectual Ventures I LLC and Intellectual Ventures II LLC hereby sue
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`Motorola Mobility LLC (“Motorola Mobility”) and allege as follows:
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`THE PARTIES
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`1.
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`Intellectual Ventures I LLC (“Intellectual Ventures I”) is a Delaware limited
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`liability company having its principal place of business located at 3150 139th Avenue SE,
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`Bellevue, Washington, 98005.
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`2.
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`Intellectual Ventures II LLC (“Intellectual Ventures II”) is a Delaware limited
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`liability company having its principal place of business located at 3150 139th Avenue SE,
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`Bellevue, Washington, 98005.
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`3.
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`Upon information and belief, Motorola Mobility is a Delaware limited liability
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`company with its principal place of business at 600 North U.S. Highway 45, Libertyville, Illinois
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`60048 as well as substantial operations at 8000 W. Sunrise Blvd., Plantation, Florida 33322. On
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`information and belief, Motorola Mobility has substantial ties to this district. See, e.g., Motorola
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 1
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`

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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 2 of 19
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`Mobility, Inc. v. Apple Inc., Case No. 10-CV-23580, Dkt. No. 47, which details Motorola
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`Mobility’s substantial ties to the district.
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`JURISDICTION AND VENUE
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`4.
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`This is a civil action for patent infringement under the Patent Laws of the United
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`States, 35 U.S.C. § 1 et. seq. This Court has subject matter jurisdiction under 28 U.S.C. §§1331
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`and 1138(a).
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`5.
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`This Court has general personal jurisdiction over Motorola Mobility because it is
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`engaged in substantial and not isolated activity in this judicial district. This Court has specific
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`jurisdiction over Motorola Mobility because it has committed acts giving rise to this action and
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`has established minimum contacts within this judicial district such that the exercise of
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`jurisdiction over Motorola Mobility would not offend traditional notions of fair play and
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`substantial justice.
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`6.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b)-(c) and
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`1400(b) because Motorola Mobility has conducted business in this district and/or provided
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`services to its customers within this judicial district, and has committed acts of patent
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`infringement within this district giving rise to this action.
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`INTELLECTUAL VENTURES AND THE PATENTS-IN-SUIT
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`7.
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`Intellectual Ventures Management, LLC (“Intellectual Ventures”) was founded in
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`2000. Since its founding, Intellectual Ventures has been deeply involved in the business of
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`invention. Intellectual Ventures creates inventions and files patent applications for those
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`inventions; collaborates with others to develop and patent inventions; and acquires and licenses
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`patents from individual inventors, universities and other institutions. A significant aspect of
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`2
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 2
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 3 of 19
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`Intellectual Ventures' business is managing the Plaintiffs in this case, Intellectual Ventures I and
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`Intellectual Ventures II.
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`8.
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`Intellectual Ventures' business includes purchasing important inventions from
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`individual inventors and institutions and then licensing the inventions to those who need them.
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`Through this business, Intellectual Ventures allows inventors to reap a financial reward from
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`their innovations, which is frequently difficult for individual inventors to do. To date, Intellectual
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`Ventures has acquired more than 70,000 IP assets and, in the process, has paid individual
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`inventors hundreds of millions of dollars for their inventions. Intellectual Ventures, in turn, has
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`earned more than $3 billion by licensing these patents to some of the world's most innovative
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`and successful technology companies who continue to use them to make computer equipment,
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`software, semiconductor devices, and a host of other products.
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`9.
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`Intellectual Ventures also creates inventions. Intellectual Ventures has a staff of
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`scientists and engineers who develop ideas in a broad range of fields, including agriculture,
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`computer hardware, life sciences, medical devices, semiconductors, and software. Intellectual
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`Ventures has invested millions of dollars developing such ideas and has filed hundreds of patent
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`applications on its inventions every year, making it one of the top patent filers in the world.
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`Intellectual Ventures has also invested in laboratory facilities to assist with the development and
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`testing of new ideas.
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`10.
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`Intellectual Ventures also creates inventions by collaborating with inventors and
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`research institutions around the world. For example, Intellectual Ventures has developed
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`inventions by selecting a technical challenge, requesting proposals for inventions to solve the
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`challenge from inventors and institutions, selecting the most promising ideas, rewarding the
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`inventors and institutions for their contributions, and filing patent applications on the ideas.
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`3
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 3
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 4 of 19
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`Intellectual Ventures has invested millions of dollars in this way and has created a network of
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`more than 4,000 inventors worldwide.
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`11.
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`On August 4, 1998, U.S. Patent No. 5,790,793 (“the ’793 Patent”), titled “Method
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`and System To Create, Transmit, Receive and Process Information, Including An Address To
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`Further Information,” was duly and lawfully issued by the United States patent and Trademark
`
`Office (“PTO”). A copy of the ’793 Patent is attached hereto as Exhibit A.
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`12.
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`Intellectual Ventures I is the owner and assignee of all right, title and interest in
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`and to the ’793 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
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`13.
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`On November 14, 2006, U. S. Patent No. 7,136,392 (“the ’392 Patent”), titled
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`“System and Method For Ordering Data Messages Having Differing Levels of Priority For
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`Transmission Over A Shared Communication Channel,” was duly and lawfully issued by the
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`PTO. A copy of the ’392 Patent is attached hereto as Exhibit B.
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`14.
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`Intellectual Ventures I is the owner and assignee of all right, title and interest in
`
`and to the ’392 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
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`15.
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`On September 19, 2000, U.S. Patent No. 6,121,960, (“the ’960 Patent”), titled
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`“Touch Screen Systems and Methods,” was duly and lawfully issued by the PTO. A copy of the
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`’960 Patent is attached hereto as Exhibit C.
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`16.
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`Intellectual Ventures II is the owner and assignee of all right, title and interest in
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`and to the ’960 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
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`4
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 4
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 5 of 19
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`17.
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`On June 3, 2008, U.S. Patent No. 7,382,771 (“the ’771 Patent”), titled “Mobile
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`Wireless Hotspot System,” was duly and lawfully issued by the PTO. A copy of the ’771 Patent
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`is attached hereto as Exhibit D.
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`18.
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`Intellectual Ventures II is the owner and assignee of all right, title and interest in
`
`and to the ’771 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
`
`19.
`
`On July 21, 2009, U.S. Patent No. 7,564,784 (“the ’784 Patent”), titled “Method
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`and Arrangement For Transferring Information In A Packet Radio Service,” was duly and
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`lawfully issued by the PTO. A copy of the ’784 Patent is attached hereto as Exhibit E.
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`20.
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`Intellectual Ventures I is the owner and assignee of all right, title and interest in
`
`and to the ’784 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
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`21.
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`On January 2, 2001, U.S. Patent No. 6,170,073 (“the ’073 Patent”), titled
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`“Method And Apparatus For Error Detection In Digital Communications,” was duly and
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`lawfully issued by the PTO. A copy of the ’073 Patent is attached hereto as Exhibit F.
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`22.
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`Intellectual Ventures I is the owner and assignee of all right, title and interest in
`
`and to the ’073 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
`
`23.
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`On December 7, 2010, U.S. Patent No. 7,848,353 (“the ’353 Patent”), titled
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`“Method, Communication System And Communication Unit For Synchronisation For Multi-
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`Rate Communication,” was duly and lawfully issued by the PTO. A copy of the ’353 Patent is
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`attached hereto as Exhibit G.
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`5
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 5
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`

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`24.
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`Intellectual Ventures II is the owner and assignee of all right, title and interest in
`
`and to the ’353 Patent and holds the right to sue and recover damages for infringement thereof,
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`including past damages.
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 5,790,793
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`25.
`
`26.
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`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
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`Intellectual Ventures I is informed and believes, and thereon alleges, that
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`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
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`the doctrine of equivalents, at least claim 30 of the ’793 Patent by making, using, selling,
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`offering to sell and/or importing products implementing multimedia messaging service (“MMS”)
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`technology, including but not limited to the Photon Q 4G LTE, Atrix HD and Electrify M.
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`27.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claim 30 of the ’793
`
`Patent by inducing others to infringe and/or contributing to the infringement of others, including
`
`third party users of such products in this judicial district and elsewhere in the United States.
`
`Specifically, Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
`
`Mobility has actively induced and continues to induce the infringement of at least claim 30 of the
`
`’793 Patent at least by actively inducing the infringing use of such products by third party users
`
`in the United States. Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility knew or should have known that its conduct would induce others to use the
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`MMS functionality in a manner that infringes the ’793 Patent. Intellectual Ventures I is
`
`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`continue to infringe the ’793 Patent in violation of 35 U.S.C. § 271(a) by using the infringing
`
`6
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 6
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 7 of 19
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`products. Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
`
`Mobility through at least its website at https://www.motorola.com, its online user manuals,
`
`marketing materials and help materials actively induced its customers to infringe the ’793 Patent.
`
`28.
`
` Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
`
`claim 30 of the ’793 Patent by importing, selling and/or offering to sell within the United States
`
`infringing products that constitute a material part of the claimed invention and are not staple
`
`articles of commerce suitable for substantial non-infringing use. Intellectual Ventures I is
`
`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’793 Patent in violation of 35 U.S.C. § 271(a) by using the infringing system and
`
`services.
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`29.
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`Intellectual Ventures I has provided written notice via a letter dated June 18, 2013
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`from counsel for Intellectual Ventures I to Renny Hwang and Brett Roesslein advising Motorola
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`Mobility of its infringement of at least claim 30, and Motorola Mobility also has written notice
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`of its infringement by virtue of the filing and service of this Complaint.
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`30.
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`Intellectual Ventures I has suffered damages as a result of Motorola Mobility’s
`
`infringement of the ’793 Patent in an amount to be proven at trial.
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`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 7,136,392
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`31.
`
`32.
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`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
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`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claim 9 of the ’392 Patent by making, using, selling, offering
`
`7
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 7
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`to sell and/or importing products that implement and/or are compliant with the 802.11n Wi-Fi
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`standard, including but not limited to the Photon Q 4G LTE, Atrix HD and Electrify M.
`
`33.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claim 9 of the ’392 Patent
`
`by inducing others to infringe and/or contributing to the infringement of others, including third
`
`party users of its products in this judicial district and elsewhere in the United States.
`
`Specifically, Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
`
`Mobility has actively induced and continues to induce the infringement of at least claim 9 of the
`
`’392 Patent at least by actively inducing the infringing use of its products by third party users in
`
`the United States. Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility knew or should have known that its conduct would induce others to use the
`
`Wi-Fi functionality in a manner that infringes the ’392 Patent. Intellectual Ventures I is
`
`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’392 Patent in violation of 35 U.S.C. § 271(a) by using the infringing products.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola Mobility
`
`through at least its website at https://www.motorola.com, its online user manuals, marketing
`
`materials and help materials actively induced its customers to infringe the ’392 Patent.
`
`34.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
`
`claim 9 of the ’392 Patent by importing, selling and/or offering to sell within the United States
`
`infringing products that constitute a material part of the claimed invention and are not staple
`
`articles of commerce suitable for substantial non-infringing use. Intellectual Ventures I is
`
`8
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 8
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 9 of 19
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`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’392 Patent in violation of 35 U.S.C. § 271(a) by using the infringing products.
`
`35.
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`Intellectual Ventures I has provided written notice via a letter dated June 18, 2013
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`from counsel for Intellectual Ventures I to Renny Hwang and Brett Roesslein advising Motorola
`
`Mobility of its infringement of at least claim 9, and Motorola Mobility also has written notice of
`
`its infringement by virtue of the filing and service of this Complaint.
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`36.
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`Intellectual Ventures I has suffered damages as a result of Motorola Mobility’s
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`infringement of the ’392 Patent in an amount to be proven at trial.
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`COUNT III
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`INFRINGEMENT OF U.S. PATENT NO. 6,121,960
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`37.
`
`38.
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`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
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`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claim 19 of the ’960 Patent by making, using, selling,
`
`offering to sell and/or importing products with the Android operating system, including but not
`
`limited to the Photon Q 4G LTE, Atrix HD and Electrify M.
`
`39.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claim 19 of the ’960
`
`Patent by inducing others to infringe and/or contributing to the infringement of others, including
`
`third party users of its products in this judicial district and elsewhere in the United States.
`
`Specifically, Intellectual Ventures II is informed and believes, and thereon alleges, that Motorola
`
`Mobility has actively induced and continues to induce the infringement of at least claim 19 of the
`
`’960 Patent at least by actively inducing the infringing use of its products by third party users in
`
`9
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 9
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`the United States. Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility knew or should have known that its conduct would induce others to use its
`
`Android based products in a manner that infringes the ’960 Patent. Intellectual Ventures II is
`
`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’960 Patent in violation of 35 U.S.C. § 271(a) by using the infringing products.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that Motorola Mobility
`
`through at least its website at https://www.motorola.com, its online user manuals, marketing
`
`materials and help materials actively induced its customers to infringe the ’960 Patent.
`
`40.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
`
`claim 19 of the ’960 Patent by importing, selling and/or offering to sell within the United States
`
`infringing systems and services that constitute a material part of the claimed invention and are
`
`not staple articles of commerce suitable for substantial non-infringing use. Intellectual Ventures
`
`II is informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’960 Patent in violation of 35 U.S.C. § 271(a) by using the infringing system.
`
`41.
`
`Intellectual Ventures II has provided written notice via a letter dated June 18,
`
`2013 from counsel for Intellectual Ventures II to Renny Hwang and Brett Roesslein advising
`
`Motorola Mobility of its infringement of at least claim 19, and Motorola Mobility also has
`
`written notice of its infringement by virtue of the filing and service of this Complaint.
`
`42.
`
`Intellectual Ventures II has suffered damages as a result of Motorola Mobility’s
`
`infringement of the ’960 Patent in an amount to be proven at trial.
`
`10
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 10
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`COUNT IV
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`INFRINGEMENT OF U.S. PATENT NO. 7,382,771
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`43.
`
`44.
`
`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claim 1 of the ’771 Patent by making, using, selling, offering
`
`to sell and/or importing products that provide Wi-Fi Internet access to other devices (i.e.,
`
`"hotspot" functionality), including but not limited to the Photon Q 4G LTE, Atrix HD and
`
`Electrify M.
`
`45.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claim 1 of the ’771 Patent
`
`by inducing others to infringe and/or contributing to the infringement of others, including third
`
`party users of such products in this judicial district and elsewhere in the United States.
`
`Specifically, Intellectual Ventures II is informed and believes, and thereon alleges, that Motorola
`
`Mobility has actively induced and continues to induce the infringement of at least claim 1 of the
`
`’771 Patent at least by actively inducing the infringing use of such products in the United States.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that Motorola Mobility
`
`knew or should have known that its conduct would induce others to use the hotspot functionality
`
`in a manner that infringes the ’771 Patent. Intellectual Ventures II is informed and believes, and
`
`thereon alleges, that these third parties have infringed and will infringe the ’771 Patent in
`
`violation of 35 U.S.C. § 271(a) by using the infringing products. Intellectual Ventures II is
`
`informed and believes, and thereon alleges, that Motorola Mobility through at least its website at
`
`11
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 11
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 12 of 19
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`https://www.motorola.com, its online user manuals, marketing materials and help materials
`
`actively induced its customers to infringe the ’771 Patent.
`
`46.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
`
`claim 1 of the ’771 Patent by importing, selling and/or offering to sell within the United States
`
`infringing systems and services that constitute a material part of the claimed invention and are
`
`not staple articles of commerce suitable for substantial non-infringing use. Intellectual Ventures
`
`II is informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’771 Patent in violation of 35 U.S.C. § 271(a) by using the infringing system.
`
`47.
`
`Intellectual Ventures II has provided written notice via a letter dated June 18,
`
`2013 from counsel for Intellectual Ventures II to Renny Hwang and Brett Roesslein advising
`
`Motorola Mobility of its infringement of at least claim 1, and Motorola Mobility also has written
`
`notice of its infringement by virtue of the filing and service of this Complaint.
`
`48.
`
`Intellectual Ventures II has suffered damages as a result of Commerce’s
`
`infringement of the ’771 Patent in an amount to be proven at trial.
`
`COUNT V
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`INFRINGEMENT OF U.S. PATENT NO. 7,564,784
`
`49.
`
`50.
`
`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claims 1 and 7 of the ’784 Patent by making, using, selling,
`
`offering to sell and/or importing all products implementing GPRS and/or compliant with 3GPP
`
`GPRS specifications, including but not limited to the Photon Q 4G LTE and Atrix HD.
`
`12
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 12
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 13 of 19
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`51.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claims 1 and 7 of the ’784
`
`Patent by inducing others to infringe and/or contributing to the infringement of others, including
`
`third party users of its products in this judicial district and elsewhere in the United States.
`
`Specifically, Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
`
`Mobility has actively induced and continues to induce the infringement of at least claims 1 and 7
`
`of the ’784 Patent at least by actively inducing the infringing use of its products by third party
`
`users in the United States. Intellectual Ventures I is informed and believes, and thereon alleges,
`
`that Motorola Mobility knew or should have known that its conduct would induce others to use
`
`GPRS and 3GPP GPRS standard compliant products in a manner that infringes the ’784 Patent.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that these third parties have
`
`infringed and will infringe the ’784 Patent in violation of 35 U.S.C. § 271(a) by using the
`
`infringing products. Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility through at least its website at https://www.motorola.com, its online user
`
`manuals, marketing materials and help materials actively induced its customers to infringe the
`
`’784 Patent.
`
`52.
`
`Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
`
`claims 1 and 7 of the ’784 Patent by importing, selling and/or offering to sell within the United
`
`States infringing products that constitute a material part of the claimed invention and are not
`
`staple articles of commerce suitable for substantial non-infringing use. Intellectual Ventures I is
`
`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’784 Patent in violation of 35 U.S.C. § 271(a) by using the infringing system.
`
`13
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 13
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 14 of 19
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`53.
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`Intellectual Ventures I has provided written notice via a letter dated June 18, 2013
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`from counsel for Intellectual Ventures I to Renny Hwang and Brett Roesslein advising Motorola
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`Mobility of its infringement of at least claims 1 and 7, and Motorola Mobility also has written
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`notice of its infringement by virtue of the filing and service of this Complaint.
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`54.
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`Intellectual Ventures I has suffered damages as a result of Motorola Mobility’s
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`infringement of the ’784 Patent in an amount to be proven at trial.
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`COUNT VI
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`INFRINGEMENT OF U.S. PATENT NO. 6,170,073
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`55.
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`56.
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`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
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`Intellectual Ventures I is informed and believes, and thereon alleges, that
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`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claim 35 of the ’073 Patent by making, using, selling,
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`offering for sale and/or importing products implementing and/or compliant with at least 3GPP
`
`and/or 4G LTE standards, including but not limited to the Photon Q 4G LTE, Atrix HD and
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`Electrify M.
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`57.
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`Intellectual Ventures I is informed and believes, and thereon alleges, that
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`Motorola Mobility also has and continues to indirectly infringe at least claim 35 of the ’073
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`Patent by inducing others to infringe and/or contributing to the infringement of others, including
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`third party users of its products in this judicial district and elsewhere in the United States.
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`Specifically, Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
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`Mobility has actively induced and continues to induce the infringement of at least claim 35 of the
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`’073 Patent at least by actively inducing the infringing use of its products by third party users in
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`the United States. Intellectual Ventures I is informed and believes, and thereon alleges, that
`
`14
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 14
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`

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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 15 of 19
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`Motorola Mobility knew or should have known that its conduct would induce others to use 3GPP
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`and 4G LTE standard compliant products in a manner that infringes the ’073 Patent. Intellectual
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`Ventures I is informed and believes, and thereon alleges, that these third parties have infringed
`
`and will infringe the ’073 Patent in violation of 35 U.S.C. § 271(a) by using the infringing
`
`products. Intellectual Ventures I is informed and believes, and thereon alleges, that Motorola
`
`Mobility through at least its website at https://www.motorola.com, its online user manuals,
`
`marketing materials and help materials actively induced its customers to infringe the ’073 Patent.
`
`58.
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`Intellectual Ventures I is informed and believes, and thereon alleges, that
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`Motorola Mobility has contributorily infringed and continues to contributorily infringe at least
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`claim 35 of the ’073 Patent by importing, selling and/or offering to sell within the United States
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`infringing products that constitute a material part of the claimed invention and are not staple
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`articles of commerce suitable for substantial non-infringing use. Intellectual Ventures I is
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`informed and believes, and thereon alleges, that these third parties have infringed and will
`
`infringe the ’073 Patent in violation of 35 U.S.C. § 271(a) by using the infringing products.
`
`59.
`
`Intellectual Ventures I has provided written notice via a letter dated June 18, 2013
`
`from counsel for Intellectual Ventures I to Renny Hwang and Brett Roesslein advising Motorola
`
`Mobility of its infringement of at least claim 35, and Motorola Mobility also has written notice
`
`of its infringement by virtue of the filing and service of this Complaint.
`
`60.
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`Intellectual Ventures I has suffered damages as a result of Motorola Mobility’s
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`infringement of the ’073 Patent in an amount to be proven at trial.
`
`COUNT VII
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`INFRINGEMENT OF U.S. PATENT NO. 7,848,353
`
`61.
`
`Paragraphs 1-24 are reincorporated by reference as if fully set forth herein.
`
`15
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`Petitioner Motorola Mobility LLC - Exhibit 1007 - Page 15
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`Case 0:13-cv-61358-RSR Document 1 Entered on FLSD Docket 06/19/2013 Page 16 of 19
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`62.
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`Intellectual Ventures II is informed and believes, and thereon alleges, that
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`Motorola Mobility has directly infringed and continues to directly infringe, literally and/or under
`
`the doctrine of equivalents, at least claims 1 and 21 of the ’353 Patent by making, using, selling,
`
`offering to sell and/or importing products compliant with and/or implementing the LTE standard,
`
`including but not limited to the Photon Q 4G LTE, Atrix HD and Electrify M.
`
`63.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility also has and continues to indirectly infringe at least claims 1 and 21 of the
`
`’353 Patent by inducing others to infringe and/or contributing to the infringement of others,
`
`including third party users of such products in this judicial district and elsewhere in the United
`
`States. Specifically, Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has actively induced and continues to induce the infringement of at least
`
`claims 1 and 21 of the ’353 Patent at least by actively inducing the infringing use of such
`
`products in the United States. Intellectual Ventures II is informed and believes, and thereon
`
`alleges, that Motorola Mobility knew or should have known that its conduct would induce others
`
`to use its LTE standard compliant products in a manner that infringes the ’353 Patent.
`
`Intellectual Ventures II is informed and believes, and thereon alleges, that these third parties
`
`have infringed and will infringe the ’353 Patent in violation of 35 U.S.C. § 271(a) by using the
`
`infringing products. Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility through at least its website at https://www.motorola.com, its online user
`
`manuals, marketing materials and help materials actively induced its customers to infringe the
`
`’353 Patent.
`
`64.
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`Intellectual Ventures II is informed and believes, and thereon alleges, that
`
`Motorola Mobility has contributorily infringed and continues to contributor