`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`Plaintiff,
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`PARUS HOLDINGS INC.,
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`
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`v.
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`APPLE INC.,
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`
`
`Defendant.
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`Civil Action No. 6:19-cv-00432-ADA
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`
`JURY TRIAL DEMANDED
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`
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`PARUS HOLDING INC.’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Parus Holdings Inc. (“Parus” or “Plaintiff”) for its First Amended Complaint for
`
`
`
`
`
`
`Patent infringement (“Amended Complaint”) against Apple Inc. (“Apple” or “Defendant”),
`
`hereby alleges as follows:
`
`THE PARTIES
`
`1.
`
`Plaintiff Parus Holdings Inc. is Delaware corporation having its principal place of
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`business at 3000 Lakeside Drive, Suite 110S, Bannockburn, IL 60015.
`
`2.
`
`Parus is the owner by assignment of U.S. Patent No. 7,076,431 (“the ’431
`
`Patent”) (attached as Exhibit 1) and U.S. Patent No. 9,451,084 (“the ’084 Patent”) (attached as
`
`Exhibit 2).
`
`3.
`
`Defendant Apple Inc. is a California corporation with a principal place of
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`business at One Apple Park Way, Cupertino, California 95014.
`
`4.
`
`Apple is registered to do business in Texas.
`
`
`
`5.
`
`Apple has regular and established places of business in this District, including, at
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`3121 Palm Way, Austin, Texas, 2901 S. Capital of Texas Hwy., Austin, TX, and 12535 Riata
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`Vista Circle, Austin, Texas, and 5501 West Parmer Lane, Austin, Texas. Apple employs
`
`thousands of people, including hundreds of engineers, who work at these locations in Texas. The
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`work done at these Apple locations in Texas includes work related to Apple’s iPhones, iPads,
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`iPods and Mac products.
`
`6.
`
`Apple also operates brick-and-mortar Apple Stores at Barton Creek Square,
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`Austin, Texas and at Apple Domain Northside, Austin, Texas. Apple uses, offers for sale and
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`sells Apple’s iPhones, iPads, iPods and Mac products that include Siri functionality at these
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`Apple Stores.
`
`7.
`
`On information and belief, Apple can be served through its registered agent, CT
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`Corporation System, 818 W. Seventh Street, Suite 930, Los Angeles, California, 90017.
`
`8.
`
`Apple has placed or contributed to placing infringing products like the iPhone X
`
`into the stream of commerce via an established distribution channel knowing or understanding
`
`that such products would be sold and used in the United States, including in the Western District
`
`of Texas. On information and belief, Apple also has derived substantial revenues from
`
`infringing acts in the Western District of Texas, including from the sale and use of infringing
`
`products like the iPhone X.
`
`9.
`
`Defendant had constructive notice of the ’431 Patent based on Parus’s marking at
`
`least as of June 18, 2007.
`
`10.
`
`Defendant had constructive notice of the ’084 Patent based on Parus’s marking at
`
`least as of February 21, 2018.
`
`2
`
`
`
`JURISDICTION AND VENUE
`
`11.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, Title 35 of the United States Code. Accordingly, this Court has subject matter
`
`jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`12.
`
`This Court has specific personal jurisdiction over Defendant at least in part
`
`because Defendant conducts business in this Judicial District. Parus’s causes of action arise, at
`
`least in part, from Defendant’s contacts with and activities in the State of Texas and this Judicial
`
`District. Upon information and belief, each Defendant has committed acts of infringement
`
`within the State of Texas and this Judicial District by, inter alia, directly and/or indirectly using,
`
`selling, offering to sell, or importing products that infringe one or more claims of the ’431 Patent
`
`and/or the ’084 Patent.
`
`13.
`
`Defendant has committed acts within this District giving rise to this action, and
`
`have established sufficient minimum contacts with the State of Texas such that the exercise of
`
`jurisdiction would not offend traditional notions of fair play and substantial justice.
`
`14.
`
`Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b), (c), and
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`1400(d) because (1) Defendant has done and continues to do business in this Judicial District,
`
`and (2) Defendant has committed and continues to commit acts of patent infringement in this
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`Judicial District by, inter alia, directly and/or indirectly using, selling, offering to sell, or
`
`importing products that infringe one or more claims of the ’431 Patent and/or the ’084 Patent.
`
`COUNT I
`
`APPLE’S INFRINGEMENT OF U.S. PATENT NO. 7,076,431
`
`Parus restates and incorporates by reference all of the allegations made in the
`
`15.
`
`preceding paragraphs as though fully set forth herein.
`
`3
`
`
`
`16.
`
`Parus is the owner, by assignment, of U.S. Patent No. 7,076,431. A true copy of
`
`U.S. Patent No. 7,076,431 granted by the U.S. Patent & Trademark Office is attached as Exhibit
`
`1.
`
`17.
`
`Defendant Apple has directly infringed, and is continuing to directly infringe,
`
`literally or under the doctrine of equivalents, at least independent claim 1 of Parus’s ’431 Patent
`
`by making, using, selling, and/or offering for sale its Apple smartphone devices with Siri in the
`
`United States, in violation of 35 U.S.C. § 271(a).
`
`18.
`
`At least as of the filing of the original complaint, Defendant Apple has knowledge
`
`of the ’431 Patent.
`
`19.
`
`Further, on information and belief, Apple had and/or has a policy or practice of
`
`not reviewing the patents of others (including instructing its employees to not review the patents
`
`of others), and has thus remained willfully ignorant of Parus’s patent rights. See, e.g., Apple
`
`Ordered to Pay $370 Million Because Its Engineers Ignored Patents When They Built Face
`
`Time, Yahoo Finance, Nov. 7, 2012 (quoting VirnetX attorney during closing arguments as
`
`saying “Apple says they don’t infringe. But Apple developers testified that they didn’t pay any
`
`attention to anyone’s patents when developing their system.”).
`
`20.
`
`Defendant Apple’s acts of direct infringement of the ’431 Patent are willful, and
`
`have caused and will continue to cause substantial damage and irreparable harm to Parus, and
`
`Parus has no adequate remedy at law.
`
`21.
`
`Various products with Siri made or sold by Apple directly infringe at least
`
`independent claim 1 of the ’431 Patent. Those Apple products include at least the Apple iPhone
`
`X or later models, the Apple iPhone 6s or later models, iPad Pro 12.9 inch (3rd Generation), iPad
`
`Pro 11-inch, iPad Pro 12.9-inch (2nd Generation), iPad Pro 10.5 inch, iPad Pro 9.7 inch, iPad (6th
`
`4
`
`
`
`Generation), all Apple iWatches, all HomePods, CarPlay, MacBook Pro (15 inch, 2018),
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`MacBook Pro (13-inch, 2018, Four Thunderbolt 3 Ports), MacBook Air (Retina, 13-inch, 2018),
`
`and iMac Pro. (Apple Accused Products). See e.g., https://support.apple.com/en-us/HT209014.
`
`22.
`
`Each of the Apple Accused Products in conjunction with Siri is a system for
`
`retrieving information from pre-selected web sites by uttering speech commands into a voice
`
`enabled device and providing users with retrieved information in an audio form via said voice
`
`enabled device as required by claim 1 of the ’431 Patent. As a way of illustration, the Apple
`
`iPhone X with Siri is a voice enabled device that allows users to utter speech commands into a
`
`voice enabled device and provide users with retrieved information from pre-selected web sites in
`
`an audio form via said voice enabled device:
`
`
`
`
`
`
`See e.g., https://support.apple.com/en-us/HT204389.
`
`
`23.
`
`Siri allows the user to communicate with the iPhone X using voice recognition
`
`and speech synthesis.
`
`5
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`
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`See e.g., https://machinelearning.apple.com/2017/08/06/siri-voices.html.
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`
`
`6
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`
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`See e.g., https://machinelearning.apple.com/2017/10/01/hey-siri.html.
`
`
`24.
`
`Further, the Apple iPhone X uses the cloud to perform natural language
`
`
`
`processing to understand the user’s spoken commands.
`
`
`
`7
`
`
`
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`without-endangering-user-privacy.
`
`
`
`
`25.
`
`The Apple iPhone X in conjunction with Siri acquires information from and/or via
`
`one or more sources maintaining a listing of web sites. For example, the Apple iPhone X in
`
`conjunction with Siri uses a list of web sites that have been already crawled to obtain
`
`information.
`
`
`
`
`
`
`See e.g., https://support.apple.com/en-us/HT204683.
`
`
`26.
`
`The Apple iPhone X in conjunction with Siri is a voice-enabled device for
`
`providing information retrieved from the web sites to the user in an audio form via the voice-
`
`enabled device.
`
`
`
`8
`
`
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`
`
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`See e.g., https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/.
`
`
`27.
`
`The Apple Products in conjunction with Siri includes a computer, said computer
`
`operatively connected to the internet.
`
`28.
`
`For example, the Apple iPhone X has a computer (i.e. microprocessor) in the A11
`
`integrated circuit. https://support.apple.com/kb/sp770?locale=en_US. The A11 integrated
`
`circuit is operatively coupled to the internet. Id. As an additional example, and alternatively, the
`
`Apple iPhone X with built-in Siri has access to computing hardware that processes questions
`
`asked of Siri including 32 powerful HP servers with a total of 1024 cores and 32 terrabytes of
`
`RAM a piece1. Specifically, each instance of Siri is made up of 4 HP c7k enclosures made up of
`
`8 HP server blades each, with memory upgrades to 1TB of RAM. The company also says its
`
`text-to-speech can run on “both general and special purpose microprocessors, and any one or
`
`more processors of any kind of digital computer,” indicating high sophistication and
`
`optimization.
`
`
`1 https://www.cultofmac.com/264381/hardware-siri-runs-puts-new-mac-pro-shame/.
`
`
`9
`
`
`
`
`
`
`
`See e.g., https://www.cultofmac.com/264381/hardware-siri-runs-puts-new-mac-pro-shame/.
`
`29.
`
`Further, the computer is operatively connected to the internet and operatively
`
`connected to the cloud:
`
`See e.g., https://support.apple.com/en-us/HT204389.
`
`30.
`
`The Apple Accused Products in conjunction with Siri includes a voice enabled
`
`device operatively connected to said computer, said voice enabled device configured to receive
`
`speech commands from users. For example, the Apple iPhone X with built-in Siri (controlled by
`
`AI models in the cloud) includes a voice enabled device operatively connected to the computing
`
`10
`
`
`
`hardware, the voice enabled device (the microphone on the Apple iPhone X and associated
`
`processing power) is configured to receive speech commands from users. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/.
`
`31.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`speaker-independent speech recognition device, said speaker-independent speech recognition
`
`device operatively connected to said computer and to said voice enabled device. For example,
`
`the Apple iPhone X with built-in Siri (controlled by AI models in the cloud) includes at least one
`
`speaker-independent speech recognition device, said speaker-independent speech recognition
`
`device operatively connected to the computing hardware and to the voice enabled Apple iPhone
`
`X. See e.g., https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/.
`
`32.
`
`The Apple Accused Products in conjunction with Siri includes at least one speech
`
`synthesis device, said speech synthesis device operatively connected to said computer and to said
`
`voice enabled device. For example, the Apple iPhone X in conjunction with Siri can handle
`
`voice commands on the device itself or with help from the cloud. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/.
`
`33.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`instruction set for identifying said information to be retrieved, said instruction set being
`
`associated with said computer, said instruction set comprising. For example, the Apple iPhone X
`
`includes at least one instruction set for identifying the information to be retrieved, the instruction
`
`set being associated with the computer. Because the Apple iPhone X in conjunction with Siri
`
`can handle voice commands on the device itself or with collaboration with the cloud, there is an
`
`instruction set for identifying the information to be retrieved, the instruction set being associated
`
`with the computer.
`
`11
`
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`without-endangering-user-privacy.
`
`
`
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy
`
`34.
`
`The Apple Accused Products in conjunction with Siri includes a plurality of pre-
`
`selected web site addresses, each said web site address identifying a web site containing said
`
`information to be retrieved. For example, the Apple iPhone X includes a plurality of pre-
`
`selected web site addresses, and each pre-selected web site address identifying a web site where
`
`the information may be retrieved. These websites have previously been crawled and pre-selected
`
`by Applebot:
`
`12
`
`
`
`
`
`
`
`See e.g., https://9to5mac.com/2015/05/06/apple-search-engine-applebot/.
`
`See e.g., https://support.apple.com/en-us/HT204683.
`
`35.
`
`Further, the Apple iPhone X in conjunction with Siri uses Google and Bing to
`
`assist with finding a plurality of pre-selected web site addresses, each said web site address
`
`identifying a web site containing said information to be retrieved.
`
`See e.g., https://www.fastcompany.com/40475434/siri-may-be-the-big-winner-in-apples-switch-
`
`to-google-for-web-search.
`
`
`
`13
`
`
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40475434/siri-may-be-the-big-winner-in-apples-switch-
`
`to-google-for-web-search.
`
`36.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`recognition grammar associated with said computer, each said recognition grammar
`
`corresponding to each said instruction set and corresponding to a speech command. For
`
`example, since the Apple iPhone X in conjunction with Siri can handle voice commands on the
`
`device itself or with help from the cloud, there is a recognition grammar corresponding to each
`
`instruction set and corresponding speech command.
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy.
`
`14
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy.
`
`37.
`
`The Apple Accused Products in conjunction with Siri includes said speech
`
`command comprising an information request selectable by the user. For example, the Apple
`
`iPhone X in conjunction with Siri is a system for retrieving information from web sites by
`
`uttering speech commands into a voice enabled device. Therefore, the speech commands
`
`comprise information requests selectable by the user.
`
`See e.g., https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/; see also
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151.
`
`
`
`15
`
`
`
`38.
`
`The Apple Accused Products in conjunction with Siri includes said speaker-
`
`independent speech recognition device configured to receive from users via said voice enabled
`
`device said speech command and to select the corresponding recognition grammar upon
`
`receiving said speech command. For example, the Apple iPhone X includes the speaker-
`
`independent speech recognition device that is configured to receive from users via the voice
`
`enabled device the speech command and to select the corresponding recognition grammar upon
`
`receiving the speech command. Because the Apple iPhone X in conjunction with Siri can handle
`
`voice commands on the device itself or in collaboration with the cloud, there is a recognition
`
`grammar corresponding to each instruction set and corresponding speech command. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/;
`
`https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-without-
`
`endangering-user-privacy; https://www.fastcompany.com/40443055/apple-explains-how-its-
`
`making-siri-smart-without-endangering-user-privacy.
`
`39.
`
`The Apple Accused Products in conjunction with Siri includes said computer
`
`configured to retrieve said instruction set corresponding to said recognition grammar selected by
`
`said speaker-independent speech recognition device. For example, the Apple iPhone X includes
`
`computer hardware configured to retrieve the instruction set corresponding to the recognition
`
`grammar selected by the speaker-independent speech recognition device. Because the Apple
`
`iPhone X in conjunction with Siri can handle voice commands on the device itself or in
`
`collaboration with the cloud, a POSITA would understand that there is a recognition grammar
`
`corresponding to each instruction set and corresponding speech command. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/;
`
`https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-without-
`
`16
`
`
`
`endangering-user-privacy; https://www.fastcompany.com/40443055/apple-explains-how-its-
`
`making-siri-smart-without-endangering-user-privacy.
`
`40.
`
`The Apple Accused Products in conjunction with Siri includes said computer
`
`further configured to access at least one of said plurality of web sites identified by said
`
`instruction set to obtain said information to be retrieved, aid computer configured to first access
`
`said first web site of said plurality of web sites and, if said information to be retrieved is not
`
`found at said first web site, said computer configured to sequentially access said plurality of web
`
`sites until said information to be retrieved is found or until said plurality of web sites has been
`
`accessed. For example, the Apple iPhone X with built-in Siri is a system for retrieving
`
`information from pre-selected web sites by uttering speech commands into a voice enabled
`
`device. Apple references Siri on its website as the virtual assistant that recognizes voice
`
`commands and executes the requested functions. Siri uses various sources for obtaining
`
`information, by delegating searches to search engines (Bing or Google), by using other websites
`
`such as Yelp, or by accessing any one of several applications on the device. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/;
`
`https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-without-
`
`endangering-user-privacy; https://www.fastcompany.com/40443055/apple-explains-how-its-
`
`making-siri-smart-without-endangering-user-privacy.
`
`41.
`
`Further, the Apple iPhone X in conjunction with Siri uses Applebot to crawl a
`
`plurality of web sites.
`
`17
`
`
`
`
`
`
`
`See e.g., https://9to5mac.com/2015/05/06/apple-search-engine-applebot/.
`
`See e.g., https://support.apple.com/en-us/HT204683.
`
`42.
`
`In addition to Applebot, the Apple iPhone X in conjunction with Siri uses Google
`
`and Bing for searches as well. See e.g., https://www.fastcompany.com/40475434/siri-may-be-
`
`the-big-winner-in-apples-switch-to-google-for-web-search;
`
`https://www.fastcompany.com/40475434/siri-may-be-the-big-winner-in-apples-switch-to-
`
`google-for-web-search.
`
`43.
`
`The Apple Accused Products in conjunction with Siri includes said speech
`
`synthesis device configured to produce an audio message containing any retrieved information
`
`from said pre-selected web sites, and said speech synthesis device further configured to transmit
`
`said audio message to said users via said voice enabled device. For example, the Apple iPhone
`
`X includes the speech synthesis device configured to produce an audio message containing any
`
`retrieved information from the pre-selected web sites, and the speech synthesis device further
`
`18
`
`
`
`configured to transmit said audio message to said users via said voice enabled device. Because
`
`the Apple iPhone X in conjunction with Siri can handle voice commands on the device itself or
`
`in collaboration with the cloud, there is a recognition grammar corresponding to each instruction
`
`set and corresponding speech command. See e.g., https://www.macworld.co.uk/how-
`
`to/iosapps/use-siri-iphone-ipad-3495151/; https://www.macworld.co.uk/how-to/iosapps/use-siri-
`
`iphone-ipad-3495151/; https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-
`
`3495151/; https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/;
`
`https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-without-
`
`endangering-user-privacy; https://www.fastcompany.com/40443055/apple-explains-how-its-
`
`making-siri-smart-without-endangering-user-privacy.
`
`44.
`
`In addition to directly infringing the ’431 Patent, Defendant Apple indirectly
`
`infringes the ’431 Patent pursuant to 35 U.S.C. § 271(b). Defendant Apple has had knowledge
`
`of the ’431 Patent since at least the filing of the original complaint. By the time of trial,
`
`Defendant Apple will have known and intended (since receiving such notice) that their continued
`
`actions would actively induce the infringement of the claims of the ’431 Patent.
`
`45.
`
` Defendant Apple indirectly infringes the ’431 Patent by instructing, directing
`
`and/or requiring others, including customers, purchasers, users and developers, to perform one or
`
`more of the steps of the method claims, either literally or under the doctrine of equivalents, of the
`
`’431 Patent, where all the steps of the method claims are performed by either Apple, its
`
`customers, purchasers, users, and developers, or some combination thereof. Apple knew or
`
`should have known that it was inducing others, including customers, purchasers, users, and
`
`developers, to infringe by practicing, either themselves or in conjunction with Apple, one or
`
`more method claims of the ’431 Patent.
`
`19
`
`
`
`46.
`
`Upon information and belief, Defendant Apple knowingly and actively aided and
`
`abetted the direct infringement of the ’431 Patent by instructing and encouraging its customers,
`
`purchasers, users, and developers to use the ’431 Patent methods and technology. These
`
`instructions of encouragement include, but are not limited to, using the Apple Accused Products
`
`as described in the claims of the ’431 Patent, in advertising and promoting the use of the ’431
`
`Patent’s claimed technology, and as further described above.
`
`47.
`
`Defendant Apple has also infringed, and continues to infringe, claims of the ’431
`
`Patent by offering to commercially distribute, commercially distributing, making and/or
`
`importing the Apple Accused Products, which are used in practicing the process, or using the
`
`systems, of the ’431 Patent, and constitute a material part of the invention. Defendant Apple
`
`knows the components in the Apple Accused Products to be especially made or especially
`
`adapted for use in infringement of the ’431 Patent, not a staple article, and not a commodity of
`
`commerce suitable for substantial noninfringing use. For example, the ordinary way of using the
`
`Apple Accused Products infringes the patent claims, and as such, is especially adapted for use in
`
`infringement as set forth above. Accordingly, Defendant Apple has been, and currently is,
`
`contributorily infringing the ’431 Patent, in violation of 35 U.S.C. § 271(c).
`
`
`
`48.
`
`COUNT II
`
`APPLE’S INFRINGEMENT OF U.S. PATENT NO. 9,451,084
`
`Parus restates and incorporates by reference all of the allegations made in the
`
`preceding paragraphs as though fully set forth herein.
`
`49.
`
`Parus is the owner, by assignment, of U.S. Patent No. 9,451,084. A true copy of
`
`U.S. Patent No. 9,451,084 granted by the U.S. Patent & Trademark Office is attached as Exhibit
`
`2.
`
`20
`
`
`
`50.
`
`Defendant Apple has directly infringed, and is continuing to directly infringe,
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`literally or under the doctrine of equivalents, at least independent claim 1 of Parus’s ’084 Patent
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`by making, using, selling, and/or offering for sale its Apple smartphone devices with Siri in the
`
`United States, in violation of 35 U.S.C. § 271(a).
`
`51.
`
`At least as of the filing of the original complaint, Defendant Apple has knowledge
`
`of the ’084 Patent.
`
`52.
`
`Further, on information and belief, Apple had and/or has a policy or practice of
`
`not reviewing the patents of others (including instructing its employees to not review the patents
`
`of others), and has thus remained willfully ignorant of Parus’s patent rights. See, e.g., Apple
`
`Ordered to Pay $370 Million Because Its Engineers Ignored Patents When They Built Face
`
`Time, Yahoo Finance, Nov. 7, 2012 (quoting VirnetX attorney during closing arguments as
`
`saying “Apple says they don’t infringe. But Apple developers testified that they didn’t pay any
`
`attention to anyone’s patents when developing their system.”).
`
`53.
`
`Defendant Apple’s acts of direct infringement of the ’084 Patent are willful, and
`
`have caused and will continue to cause substantial damage and irreparable harm to Parus, and
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`Parus has no adequate remedy at law.
`
`54.
`
`The Apple Accused Products in conjunction with Siri is a system for acquiring
`
`information from one or more sources maintaining a listing of web sites by receiving speech
`
`commands uttered by users into a voice-enabled device and for providing information retrieved
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`from the web sites to the users in an audio form via the voice-enabled device. For example, the
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`Apple iPhone X in conjunction with Siri is a voice enabled device:
`
`21
`
`
`
`See e.g., https://support.apple.com/en-us/HT204389; see also,
`
`https://machinelearning.apple.com/2017/08/06/siri-voices.html;
`
`https://machinelearning.apple.com/2017/10/01/hey-siri.html.
`
`
`
`55.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`computing device, the computing device operatively coupled to one or more networks. For
`
`example, the Apple iPhone X has a computer (i.e. microprocessor) in the A11 integrated circuit.
`
`https://support.apple.com/kb/sp770?locale=en_US. The A11 integrated circuit is operatively
`
`coupled to the internet. Id.
`
`56.
`
`As an additional example, and alternatively, the Apple iPhone X with built-in Siri
`
`has access to computing hardware that processes questions asked of Siri including 32 powerful
`
`22
`
`
`
`HP servers with a total of 1024 cores and 32 terrabytes of RAM a piece2. Specifically, each
`
`instance of Siri is made up of 4 HP c7k enclosures made up of 8 HP server blades each, with
`
`memory upgrades to 1TB of RAM. The company also says its text-to-speech can run on “both
`
`general and special purpose microprocessors, and any one or more processors of any kind of
`
`digital computer,” indicating high sophistication and optimization.
`
`See e.g., https://www.cultofmac.com/264381/hardware-siri-runs-puts-new-mac-pro-shame/.
`
`57.
`
`Further, the Apple iPhone X in conjunction with Siri is a computing device
`
`operatively coupled to one or more networks.
`
`
`
`
`2 https://www.cultofmac.com/264381/hardware-siri-runs-puts-new-mac-pro-shame/.
`
`
`23
`
`
`
`
`
`See e.g., https://support.apple.com/en-us/HT204389; see also https://support.apple.com/en-
`
`us/HT204389.
`
`58.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`speaker-independent speech-recognition device, the speaker-independent speech-recognition
`
`device operatively connected to the computing device and configured to receive the speech
`
`commands. For example, the Apple iPhone X in conjunction with Siri is a speaker-independent
`
`speech-recognition device, the speaker-independent speech-recognition device operatively
`
`connected to the computing device and configured to receive the speech commands. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/use-siri-iphone-ipad-3495151/;
`
`https://machinelearning.apple.com/2017/10/01/hey-siri.html.
`
`59.
`
`The Apple iPhone X in conjunction with Siri can receive and process voice
`
`commands on the device itself or in collaboration with the cloud (via the speech recognition and
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`AI models).
`
`24
`
`
`
`
`
`
`
`
`
`See e.g., https://www.jameco.com/Jameco/workshop/howitworks/how-siri-works.html.
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy.
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy; see also https://machinelearning.apple.com/2017/10/01/hey-
`
`siri.html; https://machinelearning.apple.com/2017/10/01/hey-siri.html.
`
`25
`
`
`
`60.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`speech-synthesis device, the speech-synthesis device operatively connected to the computing
`
`device. For example, the Apple iPhone X in conjunction with Siri can handle voice commands
`
`on the device itself or with help from the cloud. See e.g., https://www.macworld.co.uk/how-
`
`to/iosapps/use-siri-iphone-ipad-3495151/; https://www.fastcompany.com/40443055/apple-
`
`explains-how-its-making-siri-smart-without-endangering-user-privacy;
`
`https://machinelearning.apple.com/2017/10/01/hey-siri.html;
`
`https://machinelearning.apple.com/2017/10/01/hey-siri.html;
`
`https://machinelearning.apple.com/2017/10/01/hey-siri.html.
`
`61.
`
`The Apple Accused Products in conjunction with Siri includes a memory
`
`operatively associated with the computing device with at least one instruction set for identifying
`
`the information to be retrieved, the instruction set being associated with the computing device,
`
`the instruction set comprising. For example, the Apple iPhone X in conjunction with Siri is a
`
`computing device that includes a memory. For example, each of the iPhone models are offered
`
`with different memory capacities:
`
`26
`
`
`
`
`
`See e.g., https://support.apple.com/kb/SP779?viewlocale=en_US&locale=en_US.
`
`62.
`
`The Apple Accused Products in conjunction with Siri includes a plurality of web
`
`site addresses for the listing of web sites, each web site address identifying a web site containing
`
`information relevant to a search request to be retrieved. For example, the Apple iPhone X in
`
`conjunction with Siri includes a plurality of web site addresses, each web site address identifying
`
`a web site containing the information to be retrieved. These websites have previously been
`
`crawled by Applebot:
`
`27
`
`
`
`See e.g., https://9to5mac.com/2015/05/06/apple-search-engine-applebot/.
`
`
`
`
`
`See e.g., https://support.apple.com/en-us/HT204683.
`
`63.
`
`Further, the Apple iPhoneX in conjunction with Siri uses Google and Bing to
`
`assist with finding a plurality of web site addresses, each said web site address identifying a web
`
`site containing said information to be retrieved.
`
`See e.g., https://www.fastcompany.com/40475434/siri-may-be-the-big-winner-in-apples-switch-
`
`to-google-for-web-search.
`
`
`
`28
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40475434/siri-may-be-the-big-winner-in-apples-switch-
`
`to-google-for-web-search.
`
`64.
`
`The Apple Accused Products in conjunction with Siri includes at least one
`
`recognition grammar associated with the computing device, each recognition grammar
`
`corresponding to each instruction set and corresponding to a speech command, the speech
`
`command comprising an information request provided by the user, the speaker-independent
`
`speech-recognition device configured to receive the speech command from the users via the
`
`voice-enabled device and to select the corresponding recognition grammar upon receiving the
`
`speech command. For example, because the Apple iPhone X in conjunction with Siri can handle
`
`voice commands on the device itself or with help from the cloud, there is a recognition grammar
`
`corresponding to each said instruction set and corresponding speech command.
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy.
`
`
`
`29
`
`
`
`
`
`See e.g., https://www.fastcompany.com/40443055/apple-explains-how-its-making-siri-smart-
`
`without-endangering-user-privacy.
`
`65.
`
`Further, the Apple iPhone X in conjunction with Siri is a system for retrieving
`
`information from web sites by uttering speech commands into a voice enabled device.
`
`Therefore, the speech commands comprise information requests selectable by the user. See e.g.,
`
`https://www.macworld.co.uk/how-to/iosapps/