Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 1 of 35 Page ID #:1
`
`
`RYAN E. HATCH
`California Bar No. 235577
`ryan@ryanehatch.com
`Law Office of Ryan E. Hatch, P.C.
`13323 Washington Blvd., Suite 100
`Los Angeles, CA 90066
`Telephone: 310-279-5076
`DAVID A. SKEELS (pro hac vice forthcoming)
`Texas Bar No. 24041925
`dskeels@whitakerchalk.com
`ENRIQUE SANCHEZ, JR. (pro hac vice forthcoming)
`Texas Bar No. 24068961
`rsanchez@whitakerchalk.com
`WHITAKER CHALK SWINDLE & SCHWARTZ PLLC
`301 Commerce Street, Suite 3500
`Fort Worth, Texas 76102
`Telephone: 817-878-0500
`Facsimile: 817-878-0501
`CABRACH J. CONNOR (pro hac vice forthcoming)
`Texas Bar No. 24036390
`cab@connorkudlaclee.com
`JENNIFER TATUM LEE (pro hac vice forthcoming)
`Texas Bar No. 24046950
`jennifer@connorkudlaclee.com
`KEVIN S. KUDLAC (pro hac vice forthcoming)
`Texas Bar No. 00790089
`kevin@connorkudlaclee.com
`CONNOR KUDLAC LEE PLLC
`609 Castle Ridge Road, Suite 450
`Austin, Texas 78746
`Telephone: 512-777-1254
`Facsimile: 888-387-1134
`Attorneys for PINN, Inc.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`PINN, INC.,
`Plaintiff,
`
`v.
`APPLE INC.,
`Defendant.
`
`CASE NO. 8:19-cv-1805
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`DEMAND FOR JURY TRIAL
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 2 of 35 Page ID #:2
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`Pinn, Inc. files this Complaint against Apple, Inc. for infringement of U.S.
`Patent No. 9,807,491 (the “’491 Patent”).
`Pinn hereby provides notice of additional patent claims that have been
`published in connection with U.S. Pat. App. Ser. Nos. 15/563,937 and 15/694,736.
`In the case of the ’937 Application, Pinn has paid all required issue fees. Upon
`issuance, Plaintiff intends to amend this Complaint to assert forthcoming U.S. Patent
`Nos. 10,___,___ and 10,___,___.
`
`PARTIES
`
`1.
`Pinn, Inc. (“Pinn” or “Plaintiff”) is a California Corporation with its
`headquarters and principal place of business at 192 Technology Drive, Suite V, Irvine,
`California 92618.
`
`2.
`Defendant Apple Inc. (“Apple” or “Defendant”) is a corporation
`incorporated under the laws of California with its principal place of business at 1
`Infinite Loop, Cupertino, California 95014.
`3.
`Apple may be served through its registered agent: CT Corporation
`System, 818 West Seventh Street, Suite 930, Los Angeles, California 90017.
`JURISDICTION AND VENUE
`
`
`4.
`Pinn brings this action for patent infringement under the patent laws of
`the United States, including 35 U.S.C. §§ 154, 271, 281, and 283-285. This Court has
`
`subject-matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`5.
`Apple is subject to the general and specific personal jurisdiction of this
`Court, based upon its regularly conducted business in the State of California and in
`the Central District of California (“District”), including conduct giving rise to this
`action.
`6.
`Apple conducts business and has committed, and continues to commit,
`acts of direct and indirect infringement in California, within this District, and
`throughout the United States, by, among other things, making, using, selling, or
`offering for sale in the United States, and/or importing into the United States,
`
`
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 3 of 35 Page ID #:3
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`electronic devices and systems with wireless earbuds that embody one or more of the
`inventions claimed in the ’491 Patent.
`7.
`Apple maintains regular and established places of business in this
`District, where it promotes, sells, offers for sale, uses, provides technical support for,
`develops, and demonstrates infringing products, including the Apple offices in Culver
`City and retail stores in Brea, Cerritos, Costa Mesa, Glendale, Los Angeles,
`Manhattan Beach, Mission Viejo, Newport Beach, Palm Desert, Pasadena, Rancho
`Cucamonga, San Luis Obispo, Santa Barbara, Santa Monica, and Thousand Oaks.
`
`8.
`Apple sells infringing devices and systems and provides customer
`service and technical support to retailers, customers, and other end users in this
`District.
`
`9.
`Apple has established sufficient contacts with this forum such that the
`exercise of jurisdiction over Defendant comports with traditional notions of fair play
`and substantial justice.
`10. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1400(b).
`11.
`In other patent infringement matters, Apple has admitted that it maintains
`a regular and established place of business, and that venue is proper, in this District.
`
`
`See, e.g., Limestone Memory Sys. LLC v. Defendant, Inc., Case No. 8:15-cv-01274
`(C.D. Cal.) (Dkt. 27, ¶ 6); Data Scape Ltd. v. Defendant Inc., Case No. 2:18-cv-10659
`
`(C.D. Cal.) (Dkt. 18, ¶ 5).
`
`THE PINN PATENTS
`12. Defendant has infringed and continues to infringe one or more claims of
`Pinn’s ’491 Patent. Defendant has also practiced and continues to practice the
`claimed subject matter set forth in published claims of U.S. Pat. App. Ser. Nos.
`15/563,937 (the “’937 App.”) and 15/694,736 (the “’736 App.”). The ’491 Patent and
`U.S. Patent Nos. 10,___,___ and 10,___,___ (which will soon issue from the ’937
`App. and ’736 App.) may be referred to as the Patents in Suit or collectively as the
`Asserted Patents.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 4 of 35 Page ID #:4
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`13. Generally speaking, the Asserted Patents claim methods, apparatuses,
`and systems relating to a personal wireless media station having a wireless earbud and
`main body, wherein the wireless earbud is capable of pairing with a device, such as a
`smartphone, to receive and play audio data, and capable of connecting to an electric
`circuit in the main body, for wired communication with the main body when plugged
`into a connection hole of the main body.
`14. Pinn is the assignee of all right, title, and interest in and to each of the
`Asserted Patents and has the exclusive right to assert all causes of action arising under,
`
`or that may arise under, the Asserted Patents, including the right to pursue and recover
`any and all monetary and equitable remedies for infringement.
`The ’491 Patent: “Electronic Device with Wireless Earbud”
`
`15. On October 31, 2017, the United States Patent and Trademark Office
`(“USPTO”) issued the ’491 Patent following a full examination of U.S. Pat. App. Ser.
`No. 15/625,935, which was filed October 2, 2017, and claims priority to PCT App.
`No. PCT/US2016/025936 (filed on April 4, 2016) and U.S. Prov. App. No.
`62/142,978 (filed April 3, 2015).
`16. Exhibit A is a true and correct copy of the ’491 Patent.
`
`
`17. The ’491 Patent describes a personal wireless media station that includes
`a main body and wireless earbud.
`
`18.
`In reference to one disclosed embodiment, the ’491 Patent describes an
`apparatus comprising a main body, a wireless earbud configured for plugging into a
`connection hole of the main body to form a single integrated body, a user input button,
`at least one processor, and at least one memory.
`19. Claim 1 of the ’491 Patent recites:
`1. An apparatus comprising:
`
`
`a main body comprising a connection hole, a user
`input button, at least one processor and at least one
`memory; and
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 5 of 35 Page ID #:5
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`a wireless earbud configured for plugging into the
`connection hole of the main body to form a single
`integrated body with the main body,
`wherein
`the wireless earbud has wireless
`communication capability for wirelessly pairing with a
`smartphone and is configured to receive audio data from
`the smartphone and to play audio using the audio data
`from the smartphone when wirelessly paired with the
`smartphone,
`wherein in addition to wireless communication
`capability for wireless pairing with the smartphone, the
`wireless earbud comprises an earbud connector for
`connecting with an electric circuit of the main body for
`wired communication capability with the main body
`when plugged into the connection hole,
`wherein, when wireless earbud is plugged into the
`connection hole, the wireless earbud is configured to
`
`perform wired two-way data communication with the
`main body,
`wherein the at least one processor of the main body
`is configured to execute computer program instructions
`stored in the at least one memory
`for initiating the wireless pairing with the
`smartphone in response to pressing of the user
`input button provided on the main body,
`
`for initiating battery charging of the wireless
`earbud in response to the wireless earbud's
`plugging into the connection hole, and
`
`for turning off the wireless pairing with the
`smartphone when the wireless earbud is being
`charged.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 6 of 35 Page ID #:6
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`20. Figure 2 illustrates certain exemplary uses of an embodiment of the ’491
`Patent:
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`21. The technologies and innovations recited in the claims of the ’491 Patent,
`including Claim 1, provide inventive concepts and do not claim an abstract idea. The
`
`individual elements of the claims of the ’491 Patent are not well-understood, routine,
`or conventional. Instead, the claims of the ’491 Patent are directed to unconventional,
`inventive concepts that implement technical solutions to solve various problems,
`including problems unique to wireless earbud pairing, and that enhance the operation
`and functionality of wireless earbuds. As one example, the ’491 Patent provides a
`technical solution that eliminates the need to have unobstructed access to a
`smartphone’s inputs and outputs and facilitates pairing between the smartphone and
`the wireless earbud. See, e.g., ’491 Patent at 1:14-26.
`22. The technological solutions taught by the ’491 Patent provide advantages
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 7 of 35 Page ID #:7
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`over, and improvements to, the state of the art at the time. For example, the teachings
`of the ’491 Patent improve the performance of a wireless earbud system by
`simplifying the pairing process and by providing a mechanism for charging wireless
`earbuds when away from a traditional power source.
`23. The inventions and the limitations recited in the claims of the ’491
`Patent, whether alone or in combination with other limitations, embody a number of
`inventive concepts. For example, claim 1 of the ’491 Patent describes a consumer
`product or system featuring distributed intelligence and that features an earbud that
`
`communicates wirelessly with a smartphone and communicates via wired two-way
`communication with the main body. The main body is configured to initiate wireless
`pairing with a smartphone when a user presses the input button on the main body.
`
`When plugged into the connection holes, the wireless earbuds are configured such
`that the earbud batteries are charged by the main body and perform two-way data
`communication with the main body. See, e.g., ’491 Patent at 1:45-49.
`U.S. Pat. App. Ser. No. 15/563,937: “Mobile System with Wireless Earbud”
`24. Mr. Kim filed the ’937 App. on October 2, 2017, as a national stage entry
`of PCT App. No. PCT/US2016/025936 (filed April 4, 2016) and claims priority from
`
`
`U.S. Prov. App. Nos. 62/199,943 (filed July 31, 2015) and 62/142,978 (filed April 3,
`2015).
`
`25. The USPTO published the ’937 App. on May 10, 2018.
`26. Since May 10, 2018, all papers in the ’937 App. file have been available
`to the public.
`27. On August 28, 2019, the USPTO allowed claims 23-60 of the ’937 App.
`(sometimes referred to as the “’937 App. Published Claims”).
`28. On September 3, 2019, Pinn paid the issue fee.
`29. The ’937 App. Published Claims will issue in a form substantially
`identical to the claims listed in Exhibit B.
`30. Original claim 23 of the ’937 App. (final claim 1 in the patent to issue)
`
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 8 of 35 Page ID #:8
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`recites:
`
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`
` A mobile system comprising:
`a base station comprising a connection hole, a user
`input button, at least one processor, at least one memory,
`and circuitry; and
`a wireless earbud configured for plugging into the
`connection hole of the base station to form an integrated
`body with the base station,
`wherein the system is capable of wirelessly pairing
`with a smartphone for the wireless earbud to receive
`audio data originated from the smartphone,
`wherein, in response to pressing of the user input
`button, the at least one processor is configured to execute
`computer program instructions stored in the at least one
`memory to initiate processing for the wireless pairing
`with the smartphone such that the wireless earbud
`
`receives audio data originated from the smartphone and
`plays audio using the audio data from the smartphone,
`wherein, in response to plugging the wireless
`earbud into the connection hole, the at least one processor
`is configured to execute computer program instructions
`stored in the at least one memory to initiate charging of a
`battery of the wireless earbud,
`wherein, when the wireless earbud is plugged into
`the connection hole of the base station, the wireless
`
`earbud is configured to electrically connect with the
`circuitry of the base station and further configured to
`
`performing wired data communication with the base
`station.
`
`31. The particular combination of elements in claim 23 of the ’937 App. was
`not well-understood, routine, or conventional to persons of skill in the art at the time
`of the invention. Instead, the ’937 App. Published Claims are directed to
`unconventional, inventive concepts disclosed in the specification.
`32. Whether alone or in combination with other limitations, the claimed
`inventions and limitations recited in the ’937 App. Published Claims embody a
`number of inventive concepts. Claim 23, for example, describes, among other things,
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 9 of 35 Page ID #:9
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`a mobile system having distributed intelligence and that enables wireless pairing of
`an earbud and smartphone in response to pressing a user input button and a base
`station featuring a connection hole into which an earbud is plugged for charging and
`wired data communication.
`33. For example, in one embodiment described in original claim 43 of the
`’937 App., “the at least one processor is configured to execute computer program
`instructions stored in the at least one memory to turn off the wireless pairing while
`the wireless earbud is being charged.”
`
`34. As illustrated in Figure 1 (excerpted below), the earbud connector of the
`wireless earbud is mateable with the main body connector of the main body. The
`specification further describes: “The wireless earbud and the main body form a single
`
`integrated body when the earbud connector and the main body connector are
`connected with each other.”
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`U.S. Pat. App. Ser. No. 15/694,736:
`“Personal Media System Including Base Station and Wireless Earbud”
`
`35.
` Mr. Kim filed the ’736 App. on September 1, 2017, as a continuation of
`U.S. Pat. App. Ser. No. 15/625,935 (filed June 16, 2017), which is a continuation of
`PCT App. No. PCT/US2016/025936 (filed April 4, 2016), claiming priority to U.S.
`Prov. App. No. 62/142,978.
`
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 10 of 35 Page ID #:10
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`36. The USPTO published the ’736 App. on December 28, 2017.
`37. Since December 28, 2017, all papers in the ’736 App. file have been
`available to the public.
`38. On June 19, 2019, the USPTO allowed claims 1-29 of the ’736 App.
`(sometimes referred to as the “’736 App. Published Claims”).
`39. The ’736 App. Published Claims are expected to issue in a form
`substantially identical to the claims listed in Exhibit C.
`40. Claim 1 of the ’736 App. recites:
`
` A
`
` mobile system comprising:
`a mobile base station comprising a connection
`hole, a user input button, at least one processor, at least
`one memory, and circuitry; and
`
`a wireless earbud configured for plugging into the
`connection hole of the mobile bases station to form an
`integrated body with the mobile base station,
`wherein, while the wireless earbud in plugged in
`the connection hole of the mobile base station, the
`wireless earbud is configured to electrically connect with
`the circuitry of the mobile base station and further
`configured to perform wired data communication with
`the mobile base station,
`
`wherein, while the wireless earbud is plugged in
`the connection hole of the mobile base station, the
`
`circuitry of the mobile base station is configured to obtain
`characteristics of the wireless earbud and send the
`characteristics to the at least one processor,
`wherein, while the wireless earbud is plugged in
`the connection hole of the mobile base station, the at least
`one processor is configured to execute computer program
`instructions stored in the at least one memory to initiate
`charging of a battery of the wireless earbud,
`wherein
`the wireless earbud has wireless
`communication for wireless pairing with a smartphone to
`perform data communication with the smartphone,
`wherein the mobile system is configured to
`generate sound when a mobile application installed on the
`smartphone is searching for the mobile system while the
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`COMPLAINT – CASE NO 8:19-CV-1805
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`wireless earbud is paired with the smartphone,
`wherein, in response to pressing of the user input
`button of the mobile base station, the at least one
`processor is configured to execute computer program
`instructions stored in the at least one memory to initiate
`processing for the wireless pairing,
`wherein the wireless earbud is not capable of
`wirelessly sending data to the mobile base station.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 11 of 35 Page ID #:11
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`41. The particular combination of elements recited in claim 1 of the ’736
`App. was not well-understood, routine, or conventional to persons of skill in the art
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`at the time of the invention. Instead, the claimed subject matter is directed to
`unconventional, inventive concepts disclosed in the specification.
`42. Whether alone or in combination with other limitations, the claimed
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`inventions and limitations recited in the ’736 App. Published Claims embody a
`number of inventive concepts. Claim 1, for example, describes, among other things,
`a mobile system featuring distributed intelligence, that enables wireless pairing of an
`earbud and smartphone to perform data communication with the smartphone, and
`enables emission of sound when a mobile application installed on the smartphone is
`searching for the mobile system while the earbud is paired.
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`43. The specification of the ’736 App. describes at least one embodiment
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`that features an application for finding a personal wireless media station within the
`station’s communication range and for monitoring and controlling various features of
`the personal wireless media station, such as battery level.
`44.
`In at least one embodiment of the device finder, Pinn Finder beeps and
`blinks when the mobile app is searching for the Pinn device.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`PINN, INC.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 12 of 35 Page ID #:12
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`45. Pinn was founded by Seung Jin (“Sean”) Kim in 2015, with a vision
`toward designing and developing wearable technology that enhances the smartphone
`experience and eliminates frustrating phone problems like trying to locate and retrieve
`your phone quickly to answer an incoming call.
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`46. Pinn is headquartered, and Mr. Kim resides, in Irvine, California.
`47. Pinn’s product inventory, company files, and documents relating to the
`Patents in Suit and claims in this lawsuit are located in Irvine.
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`48. Sean Kim received a bachelor’s degree in Music Composition and
`Orchestra Conduction from Seoul National University in 2003. In addition to being
`an accomplished composer, Mr. Kim is an entrepreneur and inventor.
`49. While serving as an IP and business consultant to Deca International
`Corporation, Mr. Kim developed and helped Deca commercialize a variety of GPS-
`based golf rangefinders, voice-based products, and laser-based rangefinders.
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`50. After Deca, Mr. Kim worked with AQ Corporation, a mobile nearfield
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`communication company. He assisted AQ in developing its intellectual property
`assets and helped direct AQ’s research and development efforts. While at AQ, Mr.
`Kim worked on the design of an interactive, event-specific digital signage platform
`for use on mobile devices, called Anniver.
`51. Recognizing the need for a personal media system with simplified
`operation and structure, Mr. Kim conceived of the Pinn device in 2014 and founded
`Pinn Inc. the following year to develop a first-generation wearable product that would
`provide consumers with an easier way to use their smartphones, by simplifying and
`enhancing the wireless capabilities and operation of the device. Mr. Kim recognized
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`that a system having distributed intelligence and processing, along with an integrated
`modular design, would improve ease of use and functionality.
`52. The USPTO recognized Mr. Kim’s innovations by granting the first of
`his Pinn patents, the ’491 Patent, in 2017.
`53. Pinn proved Mr. Kim’s concept in October 2015 and successfully
`launched the Pinn product soon after. Pinn became available to the public in 2017.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 13 of 35 Page ID #:13
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`54. Pinn includes a wireless earbud that is docked and integrated into the
`Pinn clip or main body.
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`55. Pinn wirelessly connects to a user’s smartphone via Bluetooth.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`APPLE AIRPODS WIRELESS MEDIA SYSTEM
`56. Apple makes, has made, uses, sells, and offers for sale in the United
`States and imports into the United States various versions of a wireless media system
`that practice the Pinn Patents in Suit: Apple AirPods 1st Gen., AirPods 2nd Gen., and
`Powerbeats Pro.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 14 of 35 Page ID #:14
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`COMPLAINT – CASE NO 8:19-CV-1805
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`57. Apple started selling the first generation AirPods in or around December
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`2016.
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`58. Apple started selling the second generation AirPods in or around March
`of 2019.
`59.
`In normal operation, AirPods connect via Bluetooth to Apple’s iPhone
`or Apple Watch products, and “sound switches seamlessly between the devices.” See
`www.apple.com/airpods/.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 15 of 35 Page ID #:15
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`COMPLAINT – CASE NO 8:19-CV-1805
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`60. To use Apple AirPods, Apple encourages users to use a compatible
`Apple device:
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`https://support.apple.com/en-us/HT207010
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 16 of 35 Page ID #:16
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`61. Apple AirPods include a charging case that features a connection hole
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`for each earbud.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`62. When AirPod earbuds are plugged in a connection hole of the base
`station, they form an integrated body with the case.
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`63.
`In normal charging operation, the AirPod earbuds connect via electrical
`connector to an electric circuit in the main body of the case and receive a charging
`signal.
`64. Electrical contacts for charging the AirPod earbuds are located in the
`connection hole for each earbud.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 17 of 35 Page ID #:17
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`65. The Apple AirPod case main body features a user input button.
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`66. The main body of the Apple AirPod case comprises at least one processor
`and at least one memory.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 18 of 35 Page ID #:18
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`67. At least one processor of the AirPod main body executes instructions for
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`initiating Bluetooth pairing in response to pressing the user input button.
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`68. At least one processor of the AirPod main body executes instructions for
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`initiating battery charging of the wireless earbuds when placed in the connection hole
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`and for turning off Bluetooth pairing when an earbud is being charged.
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`69.
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`play audio using the audio data from the smartphone.
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`70. The main body of the Apple AirPod case comprises at least three
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`integrated circuits: an MCU with memory and connectivity, a charging IC, and a
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 19 of 35 Page ID #:19
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`COMPLAINT – CASE NO 8:19-CV-1805
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`Page 19
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`71. Apple’s AirPods are configured to perform wired two-way data
`communication with the charging case.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 20 of 35 Page ID #:20
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 21 of 35 Page ID #:21
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`72. Apple AirPods are configured to provide battery status to a smartphone
`for display on a mobile application of the smartphone.
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`COMPLAINT – CASE NO 8:19-CV-1805
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`73. Mobile applications on an iPhone or other compatible smartphone may
`be used to control AirPod functions. For example, a user may use the Siri mobile
`assistant application to adjust volume.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 22 of 35 Page ID #:22
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`COMPLAINT – CASE NO 8:19-CV-1805
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`74. AirPod earbuds do not pair with the charging case.
`75. AirPod earbuds are incapable of wirelessly communicating with the
`mobile base station.
`76. Apple sells AirPods with a mobile base station that includes a connection
`hole, a user input button, at least one processor, at least one memory, and circuitry.
`The AirPod system is designed and intended to be used by plugging the earbuds into
`connection holes of the base station for charging and two-way wired data
`communication.
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`77. At least one processor in the AirPod base station controls shut down and
`charging of the earbuds when they are plugged in the connection holes.
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`Case 8:19-cv-01805 Document 1 Filed 09/20/19 Page 23 of 35 Page ID #:23
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`78. Apple’s Find My AirPods feature provides the option to play a sound
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`NOTICE
`79.
`In October 2016, on behalf of Pinn, Mr. Kim contacted Apple by e-mail
`and provided information about Pinn, its technology, and the inventions claimed in
`the Patents in Suit.
`80.
`In emails to Adrian Perica and Tim Cook, Mr. Kim provided details
`about Pinn, Inc., a link to Pinn’s website, and documentation about the Pinn.
`81. On October 22, 2017, Mr. Perica responded by stating, “Thanks for
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`COMPLAINT – CASE NO 8:19-CV-1805
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`reaching out, but this is a pass for us.”
`82. Mr. Kim provided a list of Pinn’s intellectual property assets