Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 1 of 22
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
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`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD., a Canadian Limited
`Company,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`Civil Action No.
`__________
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`IPR2018-00354
`COLLECTIVE EX1015 Page 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`
`IRONBURG INVENTIONS LTD. a
`United Kingdom Limited Company,
`
`Plaintiff,
`
`vs.
`
`COLLECTIVE MINDS GAMING
`CO. LTD., a Canadian Limited
`Company,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`Civil Action No.
`__________
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`IPR2018-00354
`COLLECTIVE EX1015 Page 1
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 2 of 22
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`Plaintiff Ironburg Inventions Ltd. (“Plaintiff”), by and through counsel, files
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`this Complaint for patent infringement and demand for jury trial against Defendant
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`Collective Minds Gaming Co. Ltd. (“Defendant”).
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`Plaintiff alleges as follows:
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`PARTIES
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`1.
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`Plaintiff Ironburg Inventions Ltd. (“Ironburg”) is a company organized and
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`existing under the laws of the United Kingdom having its principal place of
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`business at 10 Market Place, Wincanton, BA9 9LP, Great Britain.
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`2.
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`Ironburg conducts business in the United States by and through Scuf
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`Gaming International, LLC (“Scuf Gaming”), a Georgia-based manufacturer,
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`wholesaler, retailer, and restorer of custom video game equipment and accessories,
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`including video game controllers (“gaming controllers”), which include Plaintiff’s
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`patented technology.
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`3.
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`On information and belief, Defendant Collective Minds Gaming Co. Ltd.
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`(“Collective Minds”) is a company organized and existing under the laws of
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`Canada, having a place of business at 8515 Place Devonshire, Suite 205, Mount
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`Royal, Quebec H4P 2K1, Canada.
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`JURISDICTION AND VENUE
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`4.
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`This is a complaint for patent infringement arising under the patent laws of
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`the United States, 35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction
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`under 28 U.S.C. §§1331 and 1338(a).
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`5.
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`Defendant has committed acts and continues to commit acts within this
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`District giving rise to this action, and venue is proper under 28 U.S.C. § 1391(b)
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`and §1400(b).
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`6.
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`On February 4, 2014, United States Patent No. 8,641,525 (hereafter the “
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`'525 Patent”) entitled, “CONTROLLER FOR VIDEO GAME CONSOLE,” was
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`duly and legally issued to Plaintiff Ironburg. A copy of the '525 Patent is annexed
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`hereto as Exhibit A.
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`7.
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`On July 28, 2015, United States Patent No. 9,089,770 (hereafter the “ '770
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`Patent”) entitled, “CONTROLLER FOR VIDEO GAME CONSOLE,” which is a
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`continuation of the '525 Patent, was duly and legally issued to Plaintiff Ironburg.
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`A copy of the '770 Patent is annexed hereto as Exhibit B.
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`8.
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`On March 22, 2016, United States Patent No. 9,289,688 (hereafter the “ '688
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`Patent”) entitled, “GAMES CONTROLLER,” was duly and legally issued to
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`Plaintiff Ironburg. A copy of the '688 Patent is annexed hereto as Exhibit C.
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`9.
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`On May 31, 2016, United States Patent No. 9,352, 229 (hereinafter the “'229
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`Patent”) entitled “CONTROLLER FOR A GAMESCONSOLE,” was duly and
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`legally issued to Ironburg. A copy of the '229 Patent is annexed hereto as
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`Exhibit D.
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`10. On April 12, 2016, United States Patent No. 9,308,450 (hereinafter the “'450
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`Patent”) entitled “GAME CONTROLLER,” was duly and legally issued to
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`Ironburg. A copy of the '450 Patent is annexed hereto as Exhibit E.
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`11. Plaintiff Ironburg is the owner and assignee of record of the 525, the '770,
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`the '688, the '229 and the '450 Patents (together the “Patents-in-Suit”).
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`FACTUAL BACKGROUND
`12. As part of its business, Plaintiff licenses its patents, including to Scuf
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`Gaming and Microsoft Corporation.
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`13. Defendant is presently making, using, importing, marketing, selling, and/or
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`offering to sell gaming controller products, including but not limited to
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`Defendant’s Strike Pack product and Defendant’s Trigger Grips product1, in this
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`District and elsewhere in the United States, which products are intended to be used,
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`per instructions that Defendant provides to its customers, to modify Microsoft
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`Xbox One gaming controllers, with the result being that the modified Xbox One
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`gaming controllers incorporate one or more of Plaintiff’s patented technologies.
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`1 Pictures from Defendant’s website of Defendant’s Strike Pack product
`(http://www.collectiveminds.ca/cm00030.html) and of Defendant’s Trigger Grips
`product (http://www.collectiveminds.ca/cm00090.html), and which include
`instructions for using those products to modify Xbox One gaming controllers, are
`annexed hereto as Exhibit F.
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`14. At least as early as March 4, 2016, in written and oral communications with
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`Collective Minds, Ironburg notified Collective Minds that its marketing of gaming
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`controller products, including Collective Minds’ Strike Pack product and Trigger
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`Grips product, when used as intended to modify Xbox One gaming controllers,
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`resulted in gaming controllers that infringed Ironburg’s gaming controller patents.
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`In those pre-suit communications with Collective Minds, Ironburg specifically
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`identified various claims in patents and then-pending patent applications as being
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`met by Xbox One gaming controllers modified with Collective Minds gaming
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`controller products as follows:
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`
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`On March 4, 2016
`o Claim 20 of the '525 Patent (related to Collective Minds’ Strike
`
`Pack)
`o Claim 1 of the '770 Patent (related to Collective Minds’ Strike
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`Pack)
`o Claim 1 of the then-pending patent application for the yet-to-
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`be-issued '450 Patent (related to Collective Minds’ Trigger
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`Grips)
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`
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`On March 29, 2016
`o Claim 1 of the '688 Patent (related to Collective Minds’ Strike
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`Pack)
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`
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`On April 15, 2016
`o Claim 1 of the just-issued '450 Patent (related to Collective
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`Minds’ Trigger Grips)
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`On October 25, 2016
`o Claim 24 of the '229 Patent (related to Collective Minds’ Strike
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`Pack)
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`15. Despite the repeated notice that Ironburg provided Collective Minds
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`regarding the '525, '770, '688, '229 and '450 Patents being infringed as a result of
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`Collective Minds’ marketing of its gaming controller products, Collective Minds
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`still continues to market those gaming controller products in the U.S., including
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`through its website, and still continues to have U.S. retailers like GameStop,
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`BestBuy USA, Amazon.com and EBGames sell those gaming controller products.
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`See, e.g., http://www.collectivemindss.ca/index.html.
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`COUNT I
`(Direct and Induced Infringement of U.S. Patent No. 8,641,525)
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`16. Plaintiff repeats and realleges Paragraphs 1 through 15 of this complaint as
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`if fully set forth herein.
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`17. Gaming controller products made, used and sold by the Defendant, including
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`Defendant’s Strike Pack, when used as intended to modify Xbox One gaming
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`controllers, including with instructions from Defendant on how its customers
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`should modify the controllers, result in a modified gaming controller (“Strike Pack
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`Modified Controller”).
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`18. Each and every claim in the '525 patent is directed to a gaming controller.
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`There are only two independent claims in the '525 patent: Claims 1 and 20. They
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`are similar, but Claim 1 includes a limitation that Claim 20 does not (Claim 20
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`does not specify that an element is resilient and flexible). Claims 1 and 20 include
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`the following claim elements: (1) an outer case, (2) a front control, (3) shaped to be
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`held in the hand of a user such that the user's thumb is positioned to operate the
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`front control, and (4) two back controls with elongated members. The Strike Pack
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`Modified Controller is a hand held controller that includes the aforementioned
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`claim elements, viz., (1) an outer case, (2) a front control, (3) shaped to be held in
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`the hand of a user such that the user's thumb is positioned to operate the front
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`control, and (4) two back controls with elongated members. The remaining claims
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`of the patent include the elements of Claim 1 and add additional limitations. For
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`example, Claim 12 further requires that the elongate members are parallel to one
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`another, and Claim 15 further requires a switch mechanism disposed between each
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`of the elongate members and an outer surface of the back of the controller. The
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`Strike Pack Modified Controller includes each element of exemplary Claims 1, 20
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`and 12, 15. Plaintiff contends that the infringement is literal, but reserves the right
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`to rely on the doctrine of equivalents.
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`19. Defendant directly infringes the '525 patent by making the Strike Pack
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`Modified Controller and advertising it to customers in the United States. See, e.g.,
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`Exhibit F; see also www.collectivemindss.ca/index.html.
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`20. Defendant’s customers directly infringe the '525 patent by making and using
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`the Strike Pack Modified Controller in the United States.
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`21. Defendant has induced and continues to induce its customers to directly
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`infringe the '525 patent. Defendant (i) knew and still knows that that patent exists,
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`(ii) knew and still knows that the acts it has induced and still is inducing (i.e. its
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`customers’ modifications to create Strike Pack Modified Controllers using
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`Defendant’s instructions) would cause infringement of that patent, and (iii)
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`intended and still intends that those acts of inducement occur with the desired
`
`result (i.e. Xbox One gaming controllers being modified to create Strike Pack
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`Modified Controllers, with infringement resulting therefrom).
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`22. Defendant’s acts which cause infringement of the '525 Patent have caused
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`and will continue to cause Plaintiff substantial and irreparable injury, for which
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`Plaintiff is entitled to receive injunctive relief and damages adequate to
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`compensate Plaintiff for such infringement.
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`23. Plaintiff is entitled to damages under 35 U.S.C. § 284 for Defendant’s acts to
`
`cause infringement of one or more claims of the '525 Patent.
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`COUNT II
`(Direct and Induced Infringement of U.S. Patent No. 9,089,770)
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`24. Plaintiff repeats and realleges Paragraphs 1 through 23 of this complaint as
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`if fully set forth herein.
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`25. Gaming controller products made, used and sold by the Defendant, including
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`Defendant’s Strike Pack, when used as intended to modify Xbox One gaming
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`controllers, including with instructions from Defendant on how its customers
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`should modify the controllers, result in a Strike Pack Modified Controller.
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`26. Each and every claim in the '770 patent is directed to a gaming controller.
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`There is only one independent claim in the '770 patent: Claim 1. Claim 1 includes
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`the following claim elements: (1) an outer case, (2) two back controls with
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`elongated members, (3) the first back control extending at least half the distance
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`between the top and bottom of the controller, and (4) the second back control also
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`extending at least half the distance between the top and bottom of the controller.
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`The Strike Pack Modified Controller is a hand held controller that includes the
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`aforementioned claim elements, viz., (1) an outer case, (2) two back controls with
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`elongated members, (3) the first back control extending at least half the distance
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`between the top and bottom of the controller, and (4) the second back control also
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`extending at least half the distance between the top and bottom of the controller.
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`The remaining claims of the patent include the elements of Claim 1 and add
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`additional limitations. For example, Claim 13 further requires a switch mechanism
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`disposed between each of the elongate members and an outer surface of the back of
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`the controller. The Strike Pack Modified Controller includes each element of
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`exemplary Claims 1 and 13. Plaintiff contends that the infringement is literal, but
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`reserves the right to rely on the doctrine of equivalents.
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`27. Defendant directly infringes the '770 patent by making the Strike Pack
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`Modified Controller and advertising it to customers in the United States. See, e.g.,
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`Exhibit F; see also www.collectivemindss.ca/index.html.
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`28. Defendant’s customers directly infringe the '770 patent by making and using
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`the Strike Pack Modified Controller in the United States.
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`29. Defendant has induced and continues to induce its customers to directly
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`infringe the '770 patent. Defendant (i) knew and still knows that that patent exists,
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`(ii) knew and still knows that the acts it has induced and still is inducing (i.e. its
`
`customers’ modifications to create Strike Pack Modified Controllers using
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`Defendant’s instructions) would cause infringement of that patent, and (iii)
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`intended and still intends that those acts of inducement occur with the desired
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`result (i.e. Xbox One gaming controllers being modified to create Strike Pack
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`Modified Controllers, with infringement resulting therefrom).
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`30. Defendant’s acts which cause infringement of the '770 Patent have caused
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`and will continue to cause Plaintiff substantial and irreparable injury, for which
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`Plaintiff is entitled to receive injunctive relief and damages adequate to
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`compensate Plaintiff for such infringement.
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`31. Plaintiff is entitled to damages under 35 U.S.C. § 284 for Defendant’s acts to
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`cause infringement of one or more claims of the '770 Patent.
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`COUNT III
`(Direct and Induced Infringement of U.S. Patent No. 9,289,688)
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`32. Plaintiff repeats and realleges Paragraphs 1 through 31 of this complaint as
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`if fully set forth herein.
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`33. Gaming controller products made, used and sold by the Defendant, including
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`Defendant’s Strike Pack, when used as intended to modify Xbox One gaming
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`controllers, including with instructions from Defendant on how its customers
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`should modify the controllers, result in a Strike Pack Modified Controller.
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`34. Each and every claim in the '688 patent is directed to a gaming controller.
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`There are only two independent claims in the '688 patent: Claims 1 and 30. They
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`are similar, but Claim 1 is directed to a controller with certain features and
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`controls, and Claim 30 is directed to features and controls. Claim 1 includes the
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`following claim elements: (1) an outer case, (2) multiple controls on the front and
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`top of the case, (3) the case shaped to be held in two hands with the user's thumbs
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`operating the top controls and index fingers operating the front controls, (4) at least
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`one additional back control with an elongate member that is operable by the user’s
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`middle, ring or little finger, (5) and the elongate member has one side disposed
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`proximate an outer surface of the case and the opposite side is non-parallel with
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`that outer surface. The Strike Pack Modified Controller is a hand held controller
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`that includes the aforementioned claim elements, viz., (1) an outer case, (2)
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`multiple controls on the front and top of the case, (3) the case shaped to be held in
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`two hands with the user's thumbs operating the top controls and index fingers
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`operating the front controls, (4) at least one additional back control with an
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`elongate member that is operable by the user’s middle, ring or little finger, (5) and
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`the elongate member has one side disposed proximate an outer surface of the case
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`and the opposite side is non-parallel with that outer surface. The remaining claims
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`of the patent include the elements of Claim 1 and add additional limitations. The
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`Strike Pack Modified Controller includes each element of exemplary Claim 1.
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`Plaintiff contends that the infringement is literal, but reserves the right to rely on
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`the doctrine of equivalents.
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`35. Defendant directly infringes the '688 patent by making the Strike Pack
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`Modified Controller and advertising it to customers in the United States. See, e.g.,
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`Exhibit F; see also www.collectivemindss.ca/index.html.
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`36. Defendant’s customers directly infringe the '688 patent by making and using
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`the Strike Pack Modified Controller in the United States.
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`37. Defendant has induced and continues to induce its customers to directly
`
`infringe the '688 patent. Defendant (i) knew and still knows that that patent exists,
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`(ii) knew and still knows that the acts it has induced and still is inducing (i.e. its
`
`customers’ modifications to create Strike Pack Modified Controllers using
`
`Defendant’s instructions) would cause infringement of that patent, and (iii)
`
`intended and still intends that those acts of inducement occur with the desired
`
`result (i.e. Xbox One gaming controllers being modified to create Strike Pack
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`Modified Controllers, with infringement resulting therefrom).
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`38. Defendant’s acts which cause infringement of the '688 Patent have caused
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`and will continue to cause Plaintiff substantial and irreparable injury, for which
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`Plaintiff is entitled to receive injunctive relief and damages adequate to
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`compensate Plaintiff for such infringement.
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`39. Plaintiff is entitled to damages under 35 U.S.C. § 284 for Defendant’s acts to
`
`cause infringement of one or more claims of the '688 Patent.
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`///
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`COUNT IV
`(Direct and Induced Infringement Of U.S. Patent No. 9,352,229)
`40. Plaintiff repeats and realleges Paragraphs 1 through 39 of this complaint as
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`if fully set forth herein.
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`41. Gaming controller products made, used and sold by the Defendant, including
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`Defendant’s Strike Pack, when used as intended to modify Xbox One gaming
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`controllers, including with instructions from Defendant on how its customers
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`should modify the controllers, result in a Strike Pack Modified Controller.
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`42. Each and every claim in the '229 patent is directed to a gaming controller.
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`There are only two independent claim in the '229 patent: Claims 1 and 24. They
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`are similar, but Claim 24 also includes an element for a mounting plate on the back
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`of the controller. Claim 1 includes the following claim elements: (1) an outer
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`case, (2) multiple controls on the front and top of the case, (3) the case is shaped to
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`be held in two hands with the user's thumbs operating the top controls and index
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`fingers operating the front controls, (4) at least one additional back control with an
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`elongate member that is operable by the user’s middle finger, (5) the additional
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`control is inherently resilient and flexible and can be displaced by the user to
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`activate a control function, and (6) the elongate member is at least partially
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`disposed in a respective channel located on the back of the outer case (the channel
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`being elongated along a longitudinal dimension of the elongate member). The
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`Strike Pack Modified Controller is a hand held controller that includes the
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`aforementioned claim elements, viz., (1) an outer case, (2) multiple controls on the
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`front and top of the case, (3) the case is shaped to be held in two hands with the
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`user's thumbs operating the top controls and index fingers operating the front
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`controls, (4) at least one additional back control with an elongate member that is
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`operable by the user’s middle finger, (5) the additional control is inherently
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`resilient and flexible and can be displaced by the user to activate a control function,
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`and (6) the elongate member is at least partially disposed in a respective channel
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`located on the back of the outer case (the channel being elongated along a
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`longitudinal dimension of the elongate member). The Strike Pack Modified
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`Controller also includes the additional aforementioned claim element of a
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`mounting plate on the back of the controller. The remaining claims of the patent
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`include the elements of Claim 1 and add additional limitations. The Strike Pack
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`Modified Controller includes each element of exemplary Claims 1 and 24.
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`Plaintiff contends that the infringement is literal, but reserves the right to rely on
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`the doctrine of equivalents.
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`43. Defendant directly infringes the '229 patent by making the Strike Pack
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`Modified Controller and advertising it to customers in the United States. See, e.g.,
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`Exhibit F; see also www.collectivemindss.ca/index.html.
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`44. Defendant’s customers directly infringe the '229 patent by making and using
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`the Strike Pack Modified Controller in the United States.
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`45. Defendant has induced and continues to induce its customers to directly
`
`infringe the '229 patent. Defendant (i) knew and still knows that that patent exists,
`
`(ii) knew and still knows that the acts it has induced and still is inducing (i.e. its
`
`customers’ modifications to create Strike Pack Modified Controllers using
`
`Defendant’s instructions) would cause infringement of that patent, and (iii)
`
`intended and still intends that those acts of inducement occur with the desired
`
`result (i.e. Xbox One gaming controllers being modified to create Strike Pack
`
`Modified Controllers, with infringement resulting therefrom).
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`46. Defendant’s acts which cause infringement of the '229 Patent have caused
`
`and will continue to cause Plaintiff substantial and irreparable injury, for which
`
`Plaintiff is entitled to receive injunctive relief and damages adequate to
`
`compensate Plaintiff for such infringement.
`
`47. Plaintiff is entitled to damages under 35 U.S.C. § 284 for Defendant’s acts to
`
`cause infringement of one or more claims of the '229 Patent.
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`COUNT V
`(Direct and Induced Infringement of U.S. Patent No. 9,289,688)
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`48. Plaintiff repeats and realleges Paragraphs 1 through 47 of this complaint as
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`if fully set forth herein.
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`49. Gaming controller products made, used and sold by the Defendant, including
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`Defendant’s Trigger Grips, when used as intended to modify Xbox One gaming
`
`controllers, including with instructions from Defendant on how its customers
`
`should modify the controllers, result in a modified gaming controller (“Trigger
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`Grips Modified Controller”).
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`50. Each and every claim in the '450 patent is directed to a gaming controller.
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`There is only one independent claim in the '450 patent: Claim 1. Claim 1 includes
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`the following claim elements: (1) a chassis with an outer wall that includes an
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`outer surface of the controller, (2) a trigger that extends through that outer wall and
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`moves relative to the chassis, (3) a strike plate that is connected to and moves with
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`the trigger, (4) a screw that goes through that outer wall and contacts the strike
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`plate to adjustably define a command initiation point, and (5) the command
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`initiation point is one end of a range of motion of the trigger. The Trigger Grips
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`Modified Controller is a hand held controller that includes the aforementioned
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`claim elements, viz., (1) a chassis with an outer wall that includes an outer surface
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`of the controller, (2) a trigger that extends through that outer wall and moves
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`relative to the chassis, (3) a strike plate that is connected to and moves with the
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`trigger, (4) a screw that goes through that outer wall and contacts the strike plate to
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`adjustably define a command initiation point, and (5) the command initiation point
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`IPR2018-00354
`COLLECTIVE EX1015 Page 17
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 18 of 22
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`is one end of a range of motion of the trigger. The remaining claims of the patent
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`include the elements of Claim 1 and add additional limitations. The Trigger Grips
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`Modified Controller includes each element of exemplary Claim 1. Plaintiff
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`contends that the infringement is literal, but reserves the right to rely on the
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`doctrine of equivalents.
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`51. Defendant directly infringes the '450 patent by making the Strike Pack
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`Modified Controller and advertising it to customers in the United States. See, e.g.,
`
`Exhibit F; see also www.collectivemindss.ca/index.html.
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`52. Defendant’s customers directly infringe the '450 patent by making and using
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`the Strike Pack Modified Controller in the United States.
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`53. Defendant has induced and continues to induce its customers to directly
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`infringe the '450 patent. Defendant (i) knew and still knows that that patent exists,
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`(ii) knew and still knows that the acts it has induced and still is inducing (i.e. its
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`customers’ modifications to create Trigger Grips Modified Controllers using
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`Defendant’s instructions) would cause infringement of that patent, and (iii)
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`intended and still intends that those acts of inducement occur with the desired
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`result (i.e. Xbox One gaming controllers being modified to create Trigger Grips
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`Modified Controllers, with infringement resulting therefrom).
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`54. Defendant’s acts which cause infringement of the '450 Patent have caused
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`IPR2018-00354
`COLLECTIVE EX1015 Page 18
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 19 of 22
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`and will continue to cause Plaintiff substantial and irreparable injury, for which
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`Plaintiff is entitled to receive injunctive relief and damages adequate to
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`compensate Plaintiff for such infringement.
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`55. Plaintiff is entitled to damages under 35 U.S.C. § 284 for Defendant’s acts to
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`cause infringement of one or more claims of the '450 Patent.
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`INCREASED DAMAGES UNDER 35 U.S.C. § 284
`56. Plaintiff repeats and realleges Paragraphs 1 through 55 of this Complaint as
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`if fully set forth herein.
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`57. Plaintiff is entitled to increased or enhanced damages under 35 U.S.C.
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`Section 284 for ongoing egregious and willful misconduct. Collective Minds’
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`infringement and inducing infringement has been and is willful and its conduct has
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`been and is egregious.
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`58. Collective Minds’ egregious and willful misconduct includes but is not
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`limited to the continued, deliberate sale of gaming controller products, including
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`the Strike Pack and Trigger Grips, and instructing its customers to use those
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`products to modify Xbox One gaming controllers, despite repeated and ever
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`increasing notifications and cease and desist demands from Ironburg that Xbox
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`One controllers modified with those products infringe at least four Ironburg
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`patents. Collective Minds’ egregious conduct is beyond what is found in a typical
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`IPR2018-00354
`COLLECTIVE EX1015 Page 19
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 20 of 22
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`patent case.
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`59. Collective Minds has and continues to sell the accused controller products
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`and to instruct its customers to use those products to modify Xbox One gaming
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`controllers despite actual knowledge that such modified controllers actually
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`infringe at least the four patents at issue in this suit.
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`60. Additionally, Collective Minds acted despite a high likelihood that its
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`actions, including but not limited to its marketing and sales of its Strike Pack and
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`Trigger Grips products, together with Collective Minds’ instructions to its
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`customers, constituted infringement and inducement to infringe of the Patents-in-
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`Suit. Collective Minds acted despite the fact that the risk of such infringement
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`should have been known to the Collective Minds and was actually known to
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`Collective Minds. Collective Minds’ infringement and inducement, including but
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`not limited to its marketing and sales of the Strike Pack and Trigger Grips and
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`instructing its customers to use those products to modify Xbox One gaming
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`controllers, has been with actual notice of infringement of each of the Patents-in-
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`Suit, including as a result of Ironburg’s communications with Collective Minds
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`regarding Defendant’s Strike Pack and Trigger Grips products and Ironburg’s
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`patents and patent applications.
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`///
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`IPR2018-00354
`COLLECTIVE EX1015 Page 20
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 21 of 22
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`REQUEST FOR RELIEF
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`WHEREFORE, Plaintiff respectfully requests that this Court grant the
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`following relief:
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`A. The entry of judgment declaring that Defendant has induced infringed
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`each of the Patents-in-Suit;
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`B. An award of all available damages, including, but not limited to any lost
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`profits from Defendant’s inducing infringement of the Patents-in-Suit, but in any
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`event not less than a reasonable royalty, together with pre-judgment and post-
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`judgment interest;
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`C. An injunction restraining Defendant and its affiliates, subsidiaries,
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`officers, directors, agents, servants, employees, representatives, licensees,
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`successors, assigns, and all those acting for them and on their behalf, from further
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`inducing infringement of the Patents-in-Suit, as well as any other contributions to
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`infringement of the Patents-in-Suit;
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`D. The entry of an order declaring that this is an exceptional case and
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`awarding Plaintiff its costs, expenses, and reasonable attorney fees under 35 U.S.C.
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`§ 285 and all other applicable statutes, rules, and common law;
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`E. An award of enhanced and treble damages under 35 U.S.C. § 284 for
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`Defendant's egregious conduct beyond what is found in a typical patent case; AND
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`IPR2018-00354
`COLLECTIVE EX1015 Page 21
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`Case 1:16-cv-04110-TWT Document 1 Filed 11/02/16 Page 22 of 22
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`F. An order awarding Plaintiff any such other relief as the Court may deem
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`just and proper under the circumstances.
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`DEMAND FOR JURY TRIAL
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`Plaintiff demands trial by jury on all claims and issues so triable.
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`Dated: November 2, 2016
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`
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`317887093.1
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`Respectfully submitted,
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`
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`By: /s/ Cynthia R. Parks
`Cynthia R. Parks
`GA Bar No. 563929
`PARKS IP LAW LLC
`730 Peachtree St. NE, Suite 600
`Atlanta, GA 30308
`Telephone: (678) 365-4444
`Facsimile: (678) 365-4450
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`Of Counsel:
`Robert D. Becker
`CA Bar No. 160648
`MANATT, PHELPS & PHILLIPS, LLP
`1841 Page Mill Road, Suite 200
`Palo Alto, CA 94304
`Telephone: (650) 812-1300
`Facsimile: (650) 213-0260
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`Attorneys for Plaintiff
`IRONBURG INVENTIONS LTD.
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`IPR2018-00354
`COLLECTIVE EX1015 Page 22
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