IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`UNILOC USA, INC. and
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`UNILOC LUXEMBOURG, S.A.,
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`Plaintiffs,
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`v.
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`LG ELECTRONICS U.S.A., INC.,
`LG ELECTRONICS MOBILECOMM
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`U.S.A. INC. AND
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`LG ELECTRONICS, INC.,
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`Defendants.
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`Civil Action No.
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`PATENT CASE
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
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`
`
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`Plaintiffs, Uniloc USA, Inc. (“Uniloc USA”) and Uniloc Luxembourg, S.A. (“Uniloc
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`Luxembourg”) (together, “Uniloc”), for their complaint against defendants LG Electronics
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`U.S.A., Inc. (“LGE USA”), LG Electronics Mobilecomm U.S.A., Inc. (“LGE Mobilecomm”),
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`and LG Electronics, Inc., (“LG Korea”) (collectively, “LG”), allege as follows:
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`
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`THE PARTIES
`
`1.
`
`Uniloc USA is a Texas corporation having a principal place of business at Legacy
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`Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024. Uniloc USA also
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`maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
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`2.
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`Uniloc Luxembourg is a Luxembourg public limited liability company having a
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`principal place of business at 15, Rue Edward Steichen, 4th Floor, L-2540, Luxembourg (R.C.S.
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`Luxembourg B159161).
`
`Patent Owner EX2001
`LG Electronics v. Uniloc 2017 LLC
`IPR2019-01530
`
`
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`§
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`UNILOC USA, INC. and
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`§
`UNILOC LUXEMBOURG, S.A.,
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`§
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`§
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`Plaintiffs,
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`§
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`§
`v.
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`§
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`§
`LG ELECTRONICS U.S.A., INC.,
`LG ELECTRONICS MOBILECOMM
`§
`U.S.A. INC. AND
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`
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`§
`LG ELECTRONICS, INC.,
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`§
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`Defendants.
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`§
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`§
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`Civil Action No.
`
`PATENT CASE
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`Plaintiffs, Uniloc USA, Inc. (“Uniloc USA”) and Uniloc Luxembourg, S.A. (“Uniloc
`
`Luxembourg”) (together, “Uniloc”), for their complaint against defendants LG Electronics
`
`U.S.A., Inc. (“LGE USA”), LG Electronics Mobilecomm U.S.A., Inc. (“LGE Mobilecomm”),
`
`and LG Electronics, Inc., (“LG Korea”) (collectively, “LG”), allege as follows:
`
`
`
`THE PARTIES
`
`1.
`
`Uniloc USA is a Texas corporation having a principal place of business at Legacy
`
`Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024. Uniloc USA also
`
`maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
`
`2.
`
`Uniloc Luxembourg is a Luxembourg public limited liability company having a
`
`principal place of business at 15, Rue Edward Steichen, 4th Floor, L-2540, Luxembourg (R.C.S.
`
`Luxembourg B159161).
`
`Patent Owner EX2001
`LG Electronics v. Uniloc 2017 LLC
`IPR2019-01530
`
`
`
`3.
`
`LGE USA is a Delaware corporation having a regular and established place of
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`business at 2151-2155 Eagle Parkway, Fort Worth, Texas 76177. LGE USA offers its products
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`and/or services, including those accused herein of infringement, to customers and potential
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`customers located in Texas and in the judicial Northern District of Texas. LGE USA may be
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`served with process through its registered agent for service in Texas: United States Corporation
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`Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
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`4.
`
`LGE Mobilecomm is a California corporation having a regular and established
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`place of business in San Diego, California. LGE Mobilecomm offers its products and/or services,
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`including those accused herein of infringement, to customers and potential customers located in
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`Texas and in the judicial Northern District of Texas.
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`5.
`
`LG Korea is a corporation organized under the laws of Korea with a principal
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`place of business at LG Twin Tower 128, Yeoui-daero, Yeongdeungpo-gu, Seoul, Korea. LG
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`Korea is in the business of manufacturing and selling electronic goods, including cellular
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`telephones, tablets, laptops and televisions.
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`
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`JURISDICTION
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`6.
`
`Uniloc brings this action for patent infringement under the patent laws of the
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`United States, 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28
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`U.S.C. §§ 1331, and 1338(a).
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 6,993,049)
`
`Uniloc incorporates paragraphs 1-6 above by reference.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,993,049
`
`7.
`
`8.
`
`(“the ’049 Patent”), entitled COMMUNICATION SYSTEM, which issued on January 31, 2006.
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`A copy of the ’049 Patent is attached as Exhibit A.
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`2
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`
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`9.
`
`Uniloc USA is the exclusive licensee of the ’049 Patent, with ownership of all
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`substantial rights, including the right to grant sublicenses, to exclude others, and to enforce and
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`recover past damages for infringement.
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`10.
`
`The ’049 Patent describes in detail and claims in various ways inventions in
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`systems and devices developed by Koninklijke Philips Electronics N.V. for improved
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`communication of data there between using polling of secondary devices by a primary device.
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`11.
`
`The ’049 Patent describes problems and shortcomings in the then-existing field of
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`communications between devices and describes and claims novel and inventive technological
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`improvements and solutions to such problems and shortcomings. The technological
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`improvements and solutions described and claimed in the ’049 Patent were not conventional or
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`generic at the time of their respective inventions but involved novel and non-obvious approaches
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`to the problems and shortcomings prevalent in the art at the time.
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`12.
`
`The inventions claimed in the ’049 Patent involve and cover more than just the
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`performance of well-understood, routine and/or conventional activities known to the industry
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`prior to the invention of such novel and non-obvious systems and devices by the ’049 Patent
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`inventor.
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`13.
`
`The inventions claimed in the ’049 Patent represent technological solutions to
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`technological problems. The written description of the ’049 Patent describes in technical detail
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`each of the limitations of the claims, allowing a person of ordinary skill in the art to understand
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`what the limitations cover and how the non-conventional and non-generic combination of claim
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`elements differ markedly from and improved upon what may have been considered conventional
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`or generic.
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`3
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`14.
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`LG imports, uses, offers for sale, and sells in the United States electronic devices
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`that utilize Bluetooth Low Energy version 4.0 and above. Such devices include: LG V30, LG
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`V30+, LG Aristo 2, LG Tribute Dynasty, LG X charge, LG Q6, LG G6+, LG G6, LG Rebel 3,
`
`LG Fiesta 2, LG V20, LG Wine, LG X venture, LG Stylo 3, LG Stylo 3 Plus Titan, LG Stylo 3
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`Plus, LG Tribute HD, LG Rebel 2, LG Fiesta, LG K20 plus, LG Grace, LG K3, LG Stylo, LG
`
`phoenix 3, LG Risio 2, LG K8, LG Stylo 2 V, LG K20, LG K20 V, LG Exalt, LG Aristo, LG
`
`G5, LG Stylo 2, LG Fortune, LG X power, LG K10, LG G Vista, LG Escape 3, LG Stylo 2 Plus,
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`LG Classic, LG Rebel, LG Treasure, LG X style, LG Premier, LG K7, LG G4, LG K4, LG
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`Optimus Zone 3, LG K8 V, LG Phoenix 2, LG Tribute 5, LG V10, Tribute 5, Nexus 5X, LG
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`Spree, LG G Vista 2, LG Leon, LG Escape 2, LG Sunrise L15G, LG Lucky, G Flex 2, LG
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`Destiny, LG Sunset, LG Power, LG Access, G Flex, LG Volt 2, LG G Stylo, LG Lancet, LG
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`Tribute 2, LG Logos, LG Transpyre, LG Optimus F60, LG G3, LG Ultimate 2, LG Tribute, LG
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`G3 Vigor, LG Realm, LG Optimus L70, LG F90, LG Volt, LG Optimus Fuel, LG Lucid 3, LG
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`Optimus L90, LG Optimus Zone 2, LG Optimus F3Q, LG F7, LG Nexus 5, LG G2, LG Optimus
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`F6, LG Enact, LG Optimus Quest, LG Optimus F3, LG Optimus F7, LG Optimus F5, Optimus G
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`Pro, Lucid 2, LG Nexus 4, LG Optimus REGARD, LG Mach, LG Optimus G, LG Escape, LG
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`Spectrum 2, LG Intuition, LG Motion 4G, LG laptops such as, , LG-13Z980-A.AAS5U1,
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`13Z980-A.AAS7U1, 13Z980-U.AAW5U1, 14Z980-A.AAS7U1, 14Z980-U.AAW5U1, 15Z980-
`
`U.AAS5U1, 15Z980-A.AAS7U1, 15Z980-A.AAS8U1, 15Z980-R.AAS9U1, 13Z970-
`
`A.AAS5U1, 13Z970-U.AAW5U1, 14Z970-A.AAS5U1, 14Z970-A.AAS7U1, 15Z970-
`
`A.AAS7U1, 15Z970-U.AAS5U1, 15Z975-A.AAS7U1, 13Z975-A.AAS7U1, 15Z975-
`
`A.AAS5U1, LG wireless speakers such as, , 4.1 ch Sound Bar Surround System with Wireless
`
`Surround Sound Speakers, 2.1 ch High Resolution Audio Sound Bar, 7.1ch 700W Wi-Fi
`
`4
`
`
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`Streaming Array Sound Bar with Wireless Subwoofer, NP8540 Music Flow H5 Wireless
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`Speaker, NP8340 Music Flow H3 Wireless Speaker, NP7550 20W 2.0ch P7 Music Flow
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`Portable Speaker, LAS851M 4.1ch 320W Music Flow Wi-Fi Streaming Sound Bar with
`
`Wireless Subwoofer, LAS751M 4.1ch 360W Music Flow Wi-Fi Streaming Sound Bar with
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`Wireless Subwoofer, NP8740 Music Flow H7 Wi-Fi Streaming Speaker, NP5550B Music Flow
`
`P5 Portable Bluetooth Speaker, LAS855M 4.1ch 360W Music Flow Wireless Curved Sound Bar
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`with Wireless Subwoofer, NP8350B Music Flow H4 Wi-Fi Streaming Portable Speaker, SoloG
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`Portable Bluetooth Speaker, ZeroG Levitating Portable Bluetooth Speaker with Subwoofer,
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`LOUDR Portable Hi-Fi Speaker System with Bluetooth Connectivity, NP7550 20W 2.0ch P7
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`Music Flow Portable Speaker, PBS-C510 LG Sound360 Bluetooth® Speaker, NP5550B Music
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`Flow P5 Portable Bluetooth Speaker, NP8350B Music Flow H4 Wi-Fi Streaming Portable
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`Speaker, SJ4R 4.1 ch Sound Bar Surround System with Wireless Surround Sound Speakers,
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`LAS475B 2.1ch 300W Sound Bar with Wireless Subwoofer and Bluetooth® Connectivity, SJ9
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`5.1.2 ch High Resolution Audio Sound Bar with Dolby Atmos, SJC8 4.1 ch High Resolution
`
`Audio Sound Bar, SJ8 4.1 ch High Resolution Audio Sound Bar, SJ7 Sound Bar Flex with
`
`Wireless Subwoofer, SJ6B 2.1 ch High Resolution Audio Sound Bar, SJ5Y-S 2.1 ch High
`
`Resolution Audio Sound Bar, SJ4Y-S 2.1 ch High Resolution Audio Sound Bar, SH7B 360W
`
`4.1ch Music Flow Wi-Fi Streaming Sound Bar with Wireless Subwoofer, SH2 100W 2.1ch
`
`Sound Bar with Bluetooth® Connectivity, LASC47 2.1 ch High Resolution Audio Sound Bar,
`
`LASC27 100W 2.0 ch Sound Bar with Bluetooth® Connectivity, LAS260B 100W 2.0 ch Sound
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`Bar with Bluetooth® Connectivity, SJ2 160W 2.1ch Sound Bar with Bluetooth® Connectivity,
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`SJ4Y 2.1 ch High Resolution Audio Sound Bar, SH5B 320W 2.1ch Sound Bar with Wireless
`
`Subwoofer and Bluetooth® Connectivity, SH4 2.1ch 300W Sound Bar with Wireless Subwoofer
`
`5
`
`
`
`and Bluetooth® Connectivity, SH6 4.0ch Music Flow Wi-Fi Streaming Sound Bar with Dual
`
`Bass Ports, SH3K 2.1ch 300W Soundbar with Wireless Subwoofer, LAS950M 7.1ch 700W Wi-
`
`Fi Streaming Array Sound Bar with Wireless Subwoofer, HF85JA Ultra Short Throw Laser
`
`Smart Home Theater Projector, PH30JG HD LED Portable MiniBeam Projector w/ up to 4 hour
`
`battery life, HF80JA Laser Smart Home Theater Projector, PF1000UW Ultra Short Throw LED
`
`Home Theater Projector with webOS Smart TV and Magic Remote, PF1500W LED Home
`
`Theater Projector with webOS Smart TV and Magic Remote, PH450UG Ultra Short Throw LED
`
`Projector with Embedded Battery, PW1500 1500 Lumen Minibeam LED Projector With Screen
`
`Share and Bluetooth Sound Out, PH550 Minibeam LED Projector with Built-In Battery,
`
`Bluetooth Sound Out and Screen Share, PH150G LED Projector with Embedded Battery and
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`Screen Share, PV150G Minibeam LED Projector with Embedded Battery, PF1000UA Ultra
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`Short Throw LED Home Theater Projector with Digital TV Tuner, PH450U Ultra Short Throw
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`LED Projector with Embedded Battery and Digital TV Tuner, and PH150B Portable HD LED
`
`Projector (collectively “Accused Infringing Devices”).
`
`15.
`
`The Accused Infringing Devices are electronic devices that implement
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`communications systems wherein a first or primary device broadcasts messages including data to
`
`a second or secondary device to poll the second or secondary device that responds to the first or
`
`primary device when the second or secondary device has data to transmit to the first or primary
`
`device.
`
`16.
`
`LG has infringed, and continues to infringe, claims of the ’049 Patent in the
`
`United States, including at least claims 2-6 and 8-9, by making, using, offering for sale, selling
`
`and/or importing the Accused Infringing Devices in violation of 35 U.S.C. § 271(a).
`
`6
`
`
`
`17.
`
`LG has also infringed, and continues to infringe, at least claims 2-6 and 8-9 of the
`
`’049 Patent by actively inducing others to use, offer for sale, and sell the Accused Infringing
`
`Devices. LG’s customers who use those devices in accordance with LG’s instructions infringe at
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`least claims 2-6 and 8-9 of the ’049 Patent, in violation of 35 U.S.C. § 271(a). LG intentionally
`
`instructs its customers to infringe through training videos, demonstrations, brochures, installation
`
`and user guides, such as those located at:
`
`•
`
`•
`
`•
`
`•
`
`www.lg.com
`
`https://developer.android.com/guide/topics/connectivity/bluetooth-le.html
`
`http://www.lg.com/us/support-mobile/lg-H820-Silver
`
`http://www.lg.com/us/support/manuals-documents
`
`LG is thereby liable for infringement of the ’049 Patent under 35 U.S.C. § 271(b).
`
`18.
`
`LG has also infringed, and continues to infringe, at least claims 2-6 and 8-9 of the
`
`’049 patent by offering to commercially distribute, commercially distributing, or importing the
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`Accused Infringing Devices which devices are used in practicing the processes, or using the
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`systems, of the ’049 patent, and constitute a material part of the invention. LG knows portions of
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`the Accused Devices to be especially made or especially adapted for use in infringement of the
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`’049 patent, not a staple article, and not a commodity of commerce suitable for substantial
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`noninfringing use. LG is thereby liable for infringement of the ’049 Patent under 35 U.S.C. §
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`271(c).
`
`19.
`
`LG will have been on notice of the ’049 Patent since, at the latest, the service of
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`this complaint upon it. By the time of trial, LG will have known and intended (since receiving
`
`such notice) that its continued actions would actively induce and contribute to the infringement
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`of at least claims 2-6 and 8-9 of the ’049 Patent.
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`7
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`20.
`
`LG may have infringed the ’049 Patent through other software and devices
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`utilizing the same or reasonably similar functionality, including other versions of the Accused
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`Infringing Devices.
`
`21.
`
`Uniloc has been damaged by LG’s infringement of the ’049 Patent.
`
`PRAYER FOR RELIEF
`
`Uniloc requests that the Court enter judgment against LG:
`
`(A)
`
`declaring that LG has infringed the ’049 Patent;
`
`(B)
`
`awarding Uniloc its damages suffered as a result of LG’s infringement of the ’049
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`Patent;
`
`(C)
`
`awarding Uniloc its costs, attorneys’ fees, expenses, and interest, and
`
`(D)
`
`granting Uniloc such further relief as the Court finds appropriate.
`
`DEMAND FOR JURY TRIAL
`
`Uniloc demands trial by jury, under Fed. R. Civ. P. 38.
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`8
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`
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`Date: March 9, 2018
`
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`Respectfully submitted,
`
`
`
`
`
`/s/ Edward R. Nelson III
`James J. Foster
`Massachusetts State Bar No. 553285
`Kevin Gannon
`Massachusetts State Bar No. 640931
`Aaron Jacobs
`Massachusetts State Bar No. 677545
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`Email: jfoster@princelobel.com
`Email: kgannon@princelobel.com
`Email: ajacobs@princelobel.com
`
`Edward R. Nelson III
`ed@nbafirm.com
`Texas State Bar No. 00797142
`Anthony M. Vecchione
`anthony@nbafirm.com
`Texas State Bar No. 24061270
`NELSON BUMGARDNER ALBRITTON P.C.
`3131 West 7th Street, Suite 300
`Fort Worth, TX 76107
`Tel: (817) 377-9111
`Fax: (817) 377-3485
`
`ATTORNEYS FOR THE PLAINTIFFS
`
`
`9
`
`
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