Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 1 of 16
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff,
`
`MYPAQ HOLDINGS LTD.,
`
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`
`
`Defendants.
`
`CIVIL ACTION NO. 6:21-CV-00398
`
`
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S ORIGINAL COMPLAINT FOR
`PATENT INFRINGEMENT AND JURY DEMAND
`
`Plaintiff MyPAQ Holdings Ltd. (“MyPAQ”) files this Original Complaint for Patent
`
`
`
`
`
`
`
`
`Infringement and Jury Demand against Defendants Samsung Electronics Co., Ltd., and Samsung
`
`Electronics America, Inc. (together, “Defendants” or “Samsung”). Plaintiff alleges infringement of
`
`United States Patent Number 7,403,399 (the “’399 Patent”), United States Patent Number 7,675,759
`
`(the “’759 Patent”), United States Patent Number 7,978,489 (the “’489 Patent”), and United States
`
`Patent Number 8,477,514 (the “’514 Patent”) (collectively, the “Patents”) as follows:
`
`I. PARTIES
`
`1.
`
`MyPAQ is a corporation organized and existing under the laws of the Republic of
`
`Seychelles with a principal place of business at 303 Aarti Chambers, Victoria Mahe, Republic of
`
`Seychelles. MyPAQ is the assignee of each of the Patents.
`
`2.
`
`Defendant Samsung Electronics Co., Ltd. is a foreign corporation organized and
`
`existing under the laws of the Republic of Korea with a principal place of business at 129, Samsung-
`
`ro, Yeongtong-gu, Suwon-si, Gyeonggi-Do, Korea 443-742.
`
`3.
`
`Defendant Samsung Electronics America, Inc. is a wholly owned subsidiary
`
`corporation of Samsung Electronics Co., Ltd., organized and existing under the laws of New York
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 1 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 2 of 16
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`with a principal place of business at 105 Challenger Road, Ridgefield Park, New Jersey 07660 and
`
`offices and/or other facilities in Texas at least at 12100 Samsung Boulevard, Austin, Texas 78754 and
`
`6625 Excellence Way, Plano, Texas 75023. Samsung Electronics America, Inc. may be served with
`
`process through its registered agent with the Texas Secretary of State, CT Corporation System, 1999
`
`Bryan Street, Suite 900, Dallas, Texas 75201.
`
`4.
`
`Further, Defendant Samsung Electronics America, Inc. merged with Samsung
`
`Telecommunications America LLC in January 2015. Koninklijke KPN N.V. v. Samsung Telecomms. Am.
`
`LLC, et al., Case No. 2:14-cv-01165-JRG (E.D. Tex.) at Dkt. 34. Prior to such merger, Samsung
`
`Telecommunications America LLC was involved in the sales and distribution of Samsung-branded
`
`consumer electronics products in the United States.
`
`5.
`
`On information and belief, Defendant Samsung Electronics America, Inc. is liable for
`
`any act for which Samsung Telecommunications America LLC otherwise would be or would have
`
`been liable, including for any infringement alleged in this matter, and references herein to Samsung
`
`Electronics America, Inc. should be understood to encompass such acts by Samsung
`
`Telecommunications America LLC.
`
`II. JURISDICTION
`
`6.
`
`This action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq.,
`
`including 35 U.S.C. §§ 271, 281, 284, and 285. This is a patent infringement lawsuit over which this
`
`Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`7.
`
`This United States District Court for the Western District of Texas has general and
`
`specific personal jurisdiction over Defendants because Defendants are present in, and transact and
`
`conduct business in and with residents of, this District and the State of Texas.
`
`8.
`
`MyPAQ’s causes of action arise, at least in part, from Defendants’ contacts with and
`
`activities in this District and the State of Texas.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 2 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 3 of 16
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`9.
`
`Defendants have committed acts that infringe the Patents within this District and the
`
`State of Texas by making, using, selling, offering for sale, and/or importing in or into this District and
`
`elsewhere in the State of Texas infringing products. Defendants make, use, sell, offer for sale, ship,
`
`distribute, advertise, promote, and/or otherwise commercialize such infringing products in this
`
`District and the State of Texas. Defendants regularly conduct and solicit business in, engage in other
`
`persistent courses of conduct in, and/or derive substantial revenue from goods and services provided
`
`to residents of this District and the State of Texas.
`
`III. VENUE
`
`10.
`
`Venue is proper in this District against Samsung Electronics Co., Ltd. because venue
`
`in a patent infringement action against a foreign defendant is proper in any judicial district. Brunette
`
`Mach. Works, Ltd. v. Kochum Indus., Inc., 406 U.S. 706, 711–714 (1972), cited by TC Heartland LLC v.
`
`Kraft Foods Grp. Brands LLC, 137 S. Ct. 1514, 1520 n.2 (2017); see also In re HTC Corp., 889 F.3d 1349,
`
`1354 (Fed. Cir. 2018) (citing Brunette Mach. Works, 406 U.S. at 706).
`
`11.
`
`Venue is proper in this District against Samsung Electronics America, Inc. because
`
`Samsung Electronics America, Inc. has physical offices located in this District that are regular and
`
`established places of business and belong to it. See In re Cray Inc., 871 F.3d 1355 (Fed. Cir. 2017).
`
`12.
`
`For example, Samsung Electronics America, Inc. maintains regular and established
`
`offices in the Western District of Texas, including at 12100 Samsung Boulevard, Austin, Texas 78754.
`
`13.
`
`Further, on information and belief, Samsung Electronics Co., Ltd. directs and controls
`
`the actions of Samsung Electronics America, Inc. such that it too maintains regular and established
`
`offices in the Western District of Texas, including at 12100 Samsung Boulevard, Austin, Texas 78754.
`
`14.
`
`Samsung Electronics Co., Ltd. also owns and operates a manufacturing facility at the
`
`same address in Austin, Texas, 12100 Samsung Boulevard.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 3 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 4 of 16
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`15.
`
`In addition, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`have placed, or contributed to placing, infringing products 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.
`
`16.
`
`On information and belief, Samsung Electronics Co., Ltd. and Samsung Electronics
`
`America, Inc. have authorized retailers that offer and sell products on their behalf in this District,
`
`including products accused of infringement herein. On information and belief, these include Target,
`
`e.g., at 5401 Bosque Boulevard, Waco, Texas 76710; Best Buy, e.g., at 4627 South Jack Kultgen
`
`Expressway, Waco, Texas 76706; AT&T, e.g., at 4330 West Waco Drive, Waco, Texas 76710; T-
`
`Mobile, e.g., at 100 North New Road, Suite 110, Waco, Texas 76710; and Verizon, e.g., at 1820 South
`
`Valley Mills Drive, Waco, Texas 76711, among others.
`
`17.
`
`On information and belief, Samsung Electronics Co., Ltd. and Samsung Electronics
`
`America, Inc. have each derived substantial revenue from infringing acts in the Western District of
`
`Texas, including from the sale and use of infringing products.
`
`18.
`
`Venue is proper under 28 U.S.C. § 1391(b)–(c) and 28 U.S.C. § 1400.
`
`IV. UNITED STATES PATENT NUMBER 7,403,399
`
`19.
`
`United States Patent Number 7,403,399 is titled “Active Primary-Sided Circuit
`
`Arrangement for a Switch-Mode Power Supply” and was filed on March 30, 2006. The ’399 Patent
`
`claims priority to German Patent Application Number 10 2005 014 746, which was filed on March
`
`31, 2005. A true and correct copy of the ’399 Patent is attached as Exhibit A and is publicly available
`
`at https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=7403399.
`
`20.
`
`21.
`
`The ’399 Patent claims patent-eligible subject matter and is valid and enforceable.
`
`Claim 1 of the ’399 Patent reads:
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 4 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 5 of 16
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`Circuit arrangement for a switch-mode power supply, wherein the switch-
`mode power supply has a primary side, which can be connected to a supply
`voltage, and a secondary side, which can be connected to a consumer,
`
`wherein the circuit arrangement (100) comprises a primary-sided
`switch (102), a control circuit (104) for controlling the primary-sided
`switch (102) and additional active, primary-sided components (106,
`108, 110),
`
`
`
`wherein said control circuit (104) is formed by a first integrated
`semiconductor chip and the primary-sided switch (102) and the
`additional components (106, 108, 110), are integrated in at least one
`additional semiconductor chip, said semiconductor chip being separate
`from the control circuit and arranged on a circuit carrier (112) shared
`with the control circuit.
`
`Claim 2 reads:
`
`Circuit arrangement according to claim 1, wherein the control circuit (104), the
`primary-sided switch (102) and the additional primary-sided components (106,
`108, 110) are accommodated in a shared housing (118).
`
`Claim 4 reads:
`
`Circuit arrangement according to claim 2, wherein the housing (118) is
`executed as a housing that can be surface-mounted for surface-mount
`technologies.
`
`
`
`22.
`
`23.
`
`24.
`
`Claim 5 reads:
`
`Circuit arrangement according to claim 1, wherein the circuit carrier is
`executed as a leadframe (112).
`
`25.
`
`Claim 6 reads:
`
`26.
`
`
`
`Circuit arrangement according to claim 1, wherein a metallization of the circuit
`carrier (112) has cooling areas that are formed for removing heat.
`
`Claim 13 reads:
`
`Switch-mode power supply having a primary side, which can be connected to
`a supply voltage, and a secondary side, which can be connected to a consumer,
`
`said switch-mode power supply comprising a circuit arrangement
`which comprises a primary-sided switch, a control circuit for
`controlling the primary-sided switch and additional active, primary-
`sided components,
`
`
`
`
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 5 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 6 of 16
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`integrated
`is formed by a first
`wherein said control circuit
`semiconductor chip and the primary-sided switch and the additional
`components, are integrated in at least one additional semiconductor
`chip, said semiconductor chip being separate from the control circuit
`and arranged on a circuit carrier shared with the control circuit.
`
`27.
`
`The ’399 Patent’s named inventors are Stefan Morbe and Michael Bothe.
`
`28. MyPAQ owns all rights, title, and interest in and to the invention of the ’399 Patent
`
`
`
`and its underlying patent applications by written assignments recorded with the United States Patent
`
`and Trademark Office. On May 18, 2006, as recorded with the United States Patent and Trademark
`
`Office on June 19, 2006, Stefan Morbe and Michael Bothe assigned their interests in the ’399 Patent
`
`to FRIWO Mobile Power GmbH. On May 26, 2008, as recorded with the United States Patent and
`
`Trademark Office on February 23, 2009, FRIWO Mobile Power GmbH changed its name to Power
`
`Systems Technologies GmbH. Power Systems Technologies GmbH assigned its interests in the ’399
`
`Patent to MyPAQ on March 26, 2021, as recorded with the United States Patent and Trademark
`
`Office on April 8, 2021.
`
`29.
`
`As a result, MyPAQ is the exclusive owner by assignment of all rights, title, and interest
`
`in the ’399 Patent, including the right to bring this suit for damages, and including the right to sue and
`
`recover all past, present, and future damages for infringement of the ’399 Patent.
`
`30.
`
`Defendants are not licensed to the ’399 Patent, either expressly or implicitly, nor do
`
`they enjoy or benefit from any rights in or to the ’399 Patent whatsoever.
`
`V. UNITED STATES PATENT NUMBER 7,675,759
`
`United States Patent Number 7,675,759 is titled “Power System with Power
`
`31.
`
`Converters Having an Adaptive Controller” and was filed on February 23, 2007. The ’759 Patent
`
`claims priority to United States Patent Application Number 11/607,325, which was filed on December
`
`1, 2006. A true and correct copy of the ’759 Patent is attached as Exhibit B and is publicly available
`
`at https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=7675759.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 6 of 16
`
`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 7 of 16
`
`The ’759 Patent claims patent-eligible subject matter and is valid and enforceable.
`
`Claim 1 of the ’759 Patent reads:
`
`A power converter coupled to a power system controller configured to receive
`a signal indicating a system operational state of a load coupled thereto,
`comprising:
`
`
`a power switch configured to conduct for a duty cycle to provide a
`regulated output characteristic at an output thereof; and
`
` controller configured to receive a command from said power system
`controller to enter a power converter operational state as a function of
`said signal indicating said system operational state, said controller
`further configured to provide a signal to control said duty cycle of said
`power switch as a function of said output characteristic and in
`accordance with said command, thereby regulating an internal
`operating characteristic of said power converter to improve an
`operating efficiency thereof as a function of said system operational
`state.
`
`Claim 3 of the ’759 Patent reads:
`
` a
`
`The power converter as recited in claim 1 wherein said power system controller
`is configured to receive a signal indicating a power converter status of said
`power converter, said power converter operational state being a function of
`said power converter status.
`
`Claim 6 of the ’759 Patent reads:
`
`32.
`
`33.
`
`34.
`
`35.
`
`A power system coupled to a load, comprising:
`
`
`
`a power system controller configured to receive a signal indicating a
`system operational state of said load and to select a power converter
`operational state as a function thereof; and
`
` power converter, including:
`
`a power switch configured to conduct for a duty cycle to
`provide a regulated output characteristic at an output thereof,
`and
`
` controller configured to receive a command from said power
`system controller to enter said power converter operational
`state and to provide a signal to control said duty cycle of said
`power switch as a function of said output characteristic and in
`accordance with said command, thereby regulating an internal
`
` a
`
` a
`
`
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 7 of 16
`
`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 8 of 16
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`operating characteristic of said power converter to improve an
`operating efficiency thereof as a function of said system
`operational state.
`
`
`The ’759 Patent’s named inventors are Daniel A. Artusi, Ross Fosler, and Allen F.
`
`36.
`
`Rozman.
`
`37. MyPAQ owns all rights, title, and interest in and to the invention of the ’759 Patent
`
`and its underlying patent applications by written assignments recorded in the United States Patent and
`
`Trademark Office. On March 8, 2007, as recorded with the United States Patent and Trademark Office
`
`on April 18, 2007, Daniel A. Artusi, Ross Fosler, and Allen F. Rozman assigned their interests in the
`
`’759 Patent to ColdWatt, Inc. On April 7, 2008, as recorded with the United States Patent and
`
`Trademark Office on February 4, 2009, ColdWatt, Inc. merged with Flextronics International USA,
`
`Inc. Flextronics International USA, Inc. assigned its interests in the ’759 Patent to MyPAQ on March
`
`26, 2021, as recorded with the United States Patent and Trademark Office on April 8, 2021.
`
`38.
`
`As a result, MyPAQ is the exclusive owner by assignment of all rights, title, and interest
`
`in the ’759 Patent, including the right to bring this suit for damages, and including the right to sue and
`
`recover all past, present, and future damages for infringement of the ’759 Patent.
`
`39.
`
`Defendants are not licensed to the ’759 Patent, either expressly or implicitly, nor do
`
`they enjoy or benefit from any rights in or to the ’759 Patent whatsoever.
`
`VI. UNITED STATES PATENT NUMBER 7,978,489
`
`United States Patent Number 7,978,489 is titled “Integrated Power Converters” and
`
`40.
`
`was filed on August 4, 2008. The ’489 Patent claims priority to United States Provisional Patent
`
`Application Number 60/963,477, which was filed on August 3, 2007. A true and correct copy of the
`
`’489
`
`Patent
`
`is
`
`attached
`
`as
`
`Exhibit C
`
`and
`
`is
`
`publicly
`
`available
`
`at
`
`https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=7978489.
`
`41.
`
`The ’489 Patent claims patent-eligible subject matter and is valid and enforceable.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 8 of 16
`
`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 9 of 16
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`42.
`
`Claim 43 of the ’489 Patent reads:
`
`A power supply adapter comprising:
`
`
`a power converter circuit configured to generate a regulated voltage
`signal, the power converter circuit including,
`
` a
`
` a
`
` a
`
` rectifier coupled with AC power blades;
`
` regulator circuit coupled with the rectifier;
`
` transformer coupled with the regulator circuit, the transformer
`including a primary and a secondary, the transformer being coupled
`with the regulator circuit via the primary; and
`
`a flexible contact coupled with each of a first and a second printed
`circuit board and flexibly biased to couple with a proximate end of the
`AC power blades.
`
`Claim 53 of the ’489 Patent reads:
`
`The adapter of claim 43, wherein the flexible contact comprises a metallic
`conductor.
`
`Claim 54 of the ’489 Patent reads:
`
`43.
`
`44.
`
`The adapter of claim 43, wherein the flexible contact is configured to
`electrically couple an AC power source from the AC power blades to the
`power converter circuit.
`
`45.
`
`Claim 60 of the ’489 Patent reads:
`
`The adapter of claim 43, wherein the connector receptacle comprises a
`universal serial bus (USB) connector receptacle.
`
`46.
`
`The ’489 Patent’s named inventors are Mark Telefus, Bahman Sharifipour, Rowell
`
`
`
`
`
`
`
`Gapuz, Richard Sy, HongWei Du, and Bob Roohparvar.
`
`47. MyPAQ owns all rights, title, and interest in and to the invention of the ’489 Patent
`
`and its underlying patent applications by written assignments recorded with the United States Patent
`
`and Trademark Office. In 2013, as recorded with the United States Patent and Trademark Office on
`
`October 28, 2016, Mark Telefus, Bahman Sharifipour, Rowell Gapuz, and HongWei Du assigned their
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 9 of 16
`
`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 10 of 16
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`interests in the ’489 Patent to Flextronics AP, LLC. The remaining inventors, Bob Roohparvar and
`
`Richard Sy, assigned their interests in the ’489 Patent to Flextronics AP, LLC in June 2020, as recorded
`
`with the United States Patent and Trademark Office on March 25, 2021. Flextronics AP, LLC assigned
`
`its interests in the ’489 Patent to MyPAQ on March 19, 2021, as recorded with the United States
`
`Patent and Trademark Office on April 8, 2021.
`
`48.
`
`As a result, MyPAQ is the exclusive owner by assignment of all rights, title, and interest
`
`in the ’489 Patent, including the right to bring this suit for damages, and including the right to sue and
`
`recover all past, present, and future damages for infringement of the ’489 Patent.
`
`49.
`
`Defendants are not licensed to the ’489 Patent, either expressly or implicitly, nor do
`
`they enjoy or benefit from any rights in or to the ’489 Patent whatsoever.
`
`VII. UNITED STATES PATENT NUMBER 8,477,514
`
`United States Patent Number 8,477,514 is titled “Power System with Power
`
`50.
`
`Converters Having an Adaptive Controller” and was filed on February 22, 2010. The ’514 Patent
`
`claims priority to United States Patent Application Number 11/607,325, which was filed on December
`
`1, 2006. A true and correct copy of the ’514 Patent is attached as Exhibit D and is publicly available
`
`at https://pdfpiw.uspto.gov/.piw?PageNum=0&docid=8477514.
`
`The ’514 Patent claims patent-eligible subject matter and is valid and enforceable.
`
`Claim 1 of the ’514 Patent reads:
`
`A power converter coupled to a load, comprising:
`
`
`a power switch configured to conduct for a duty cycle to provide an
`output characteristic at an output thereof; and
`
` a
`
` power converter controller configured to receive a signal from said
`load indicating a system operational state of said load and control an
`internal operating characteristic of said power converter as a function
`of said signal.
`
`Claim 5 of the ’514 Patent reads:
`
`51.
`
`52.
`
`53.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 10 of 16
`
`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 11 of 16
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`The power converter as recited in claim 1 wherein said internal operating
`characteristic is selected from the group consisting of:
`
`
`a gate drive voltage level of said power switch of said power converter,
`
` a
`
` switching frequency of said power converter, and
`
`
`an internal direct current bus voltage of said power converter.
`
`
`
`54.
`
`The ’514 Patent’s named inventors are Daniel A. Artusi, Ross Fosler, and Allen F.
`
`Rozman.
`
`55. MyPAQ owns all rights, title, and interest in and to the invention of the ’514 Patent
`
`and its underlying patent applications by written assignments recorded with the United States Patent
`
`and Trademark Office. On April 7, 2008, as recorded with the United States Patent and Trademark
`
`Office on May 4, 2020, Flextronics International USA, Inc. merged with ColdWatt, Inc. In May and
`
`June 2008, Daniel A. Artusi, Ross Fosler, and Allen F. Rozman assigned their interests in the ’514
`
`Patent to ColdWatt, Inc., which had merged with Flextronics International USA, Inc. Flextronics
`
`International USA, Inc. assigned its interests in the ’514 Patent to MyPAQ on March 26, 2021, as
`
`recorded with the United States Patent and Trademark Office on April 8, 2021.
`
`56.
`
`MyPAQ is the exclusive owner by assignment of all rights, title, and interest in the ’514
`
`Patent, including the right to bring this suit for damages, and including the right to sue and recover all
`
`past, present, and future damages for infringement of the ’514 Patent.
`
`57.
`
`Defendants are not licensed to the ’514 Patent, either expressly or implicitly, nor do
`
`they enjoy or benefit from any rights in or to the ’514 Patent whatsoever.
`
`VIII. THE ACCUSED INSTRUMENTALITIES
`
`58.
`
`Defendants manufacture, use, and sell infringing devices and products, including but
`
`not limited to the following Samsung chargers: the EP-TA12JBEUGUJ (the “TA12”), the EP-
`
`TA800XBEGUS (the “TA800”), and the EP-TA845XBEGUS (the “TA845” and, collectively, the
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 11 of 16
`
`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 12 of 16
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`“Accused Instrumentalities”), which practice (1) the ’399 Patent, including but not limited to Claims
`
`1, 2, 4, 5, 6, and 13; (2) the ’759 Patent, including but not limited to Claims 1, 3, and 6; (3) the ’489
`
`Patent, including but not limited to Claims 43, 53, 54, and 60; and/or (4) the ’514 Patent, including
`
`but not limited to Claims 1 and 5.
`
`59.
`
`The Accused Instrumentalities implement circuitry and power blade connectors that
`
`infringe the Patents.
`
`60.
`
`For example, the Accused Instrumentalities are power supply adapters with power
`
`converter circuits, which include a rectifier coupled with AC power blades, a regulator circuit coupled
`
`with the rectifier, a transformer coupled with the regulator circuit, and a flexible contact coupled with
`
`each of a first and a second printed circuit board and flexibly biased to couple with a proximate end
`
`of the AC power blades.
`
`IX. COUNT 1: DIRECT INFRINGEMENT
`
`All previous paragraphs are incorporated herein as if fully set forth.
`
`Defendants have directly infringed and continue to directly infringe the Patents under
`
`61.
`
`62.
`
`35 U.S.C. §§ 271(a) and 271(g) by making, using, selling, offering to sell, and/or importing in or into
`
`the United States the Accused Instrumentalities that practice the Patents.
`
`63.
`
`As further described in the claim charts attached as Exhibits E–H, the Accused
`
`Instrumentalities directly infringe each element of at least Claims 1, 2, 4, 5, 6, and 13 of the ’399 Patent;
`
`Claims 1, 3, and 6 of the ’759 Patent; Claims 43, 53, 54, and 60 of the ’489 Patent; and/or Claims 1
`
`and 5 of the ’514 Patent.
`
`64.
`
`Upon information and belief, Defendants manufacture the Accused Instrumentalities
`
`at facilities in Vietnam, China, India, and South Korea. Defendants market, sell, offer to sell, and
`
`import the Accused Instrumentalities in and into the United States.
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 12 of 16
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`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 13 of 16
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`65.
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`Defendants market and/or offer to sell the Accused Instrumentalities, for example, to
`
`customers directly through their website:
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`Samsung, https://www.samsung.com/us/mobile/mobile-accessories/tablets/travel-charger-11pin-
`
`ep-ta12jbeuguj/ (last visited April 23, 2021).
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`
`
`
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`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 13 of 16
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`

`

`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 14 of 16
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`Samsung, https://www.samsung.com/us/business/mobile/mobile-accessories/phones/25w-usb-c-
`
`fast-charging-wall-charger-black-ep-ta800xbegus/ (last visited April 23, 2021).
`
`Samsung, https://www.samsung.com/us/business/mobile/mobile-accessories/phones/45w-usb-c-
`
`
`
`fast-charging-wall-charger-black-ep-ta845xbegus/ (last visited April 23, 2021).
`
`X. JURY DEMAND
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`66.
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`Plaintiff hereby demands a trial by jury on all issues so triable.
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`XI. PRAYER FOR RELIEF
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`Plaintiff requests the following relief:
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`A.
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`A judgment that Defendants have directly infringed, either literally and/or
`
`67.
`
`
`
`under the doctrine of equivalents, and continue to directly infringe the Patents;
`
`
`
`B.
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`A judgment and order requiring Defendants to pay Plaintiff damages under
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`35 U.S.C. § 284, and supplemental damages for any continuing post-verdict infringement through
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`entry of the final judgment with an accounting as needed;
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`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 14 of 16
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`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 15 of 16
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`C.
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`A judgment that this is an exceptional case within the meaning of 35 U.S.C.
`
`§ 285 and Plaintiff is therefore entitled to reasonable attorneys’ fees;
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`D.
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`A judgment and order requiring Defendants to pay Plaintiff pre-judgment and
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`post-judgment interest on the damages awarded;
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`E.
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`F.
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`H.
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`A judgment and order awarding a compulsory ongoing royalty;
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`A judgment and order awarding Plaintiff costs associated with this action; and
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`Such other and further relief as the Court deems just and equitable.
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`
`
`Dated: April 23, 2021
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`
`
`
`Respectfully submitted,
`
`
`
`
`
`By: /s/ Charles Ainsworth
`Charles Ainsworth
`State Bar No. 00783521
`Robert Christopher Bunt
`State Bar No. 00787165
`PARKER, BUNT & AINSWORTH, P.C.
`100 E. Ferguson, Suite 418
`Tyler, Texas 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
`
`Alfonso G. Chan (Texas 24012408)
`Michael W. Shore (Texas 18294915)
`Samuel E. Joyner (Texas 24036865)
`Halima Shukri Ndai (Texas 24105486)
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`achan@shorechan.com
`mshore@shorechan.com
`sjoyner@shorechan.com
`hndai@shorechan.com
`
`Brian D. Melton (Texas 24010620)
`Krisina J. Zuñiga (Texas 24098664)
`SUSMAN GODFREY LLP
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 15 of 16
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`

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`Case 6:21-cv-00398 Document 1 Filed 04/23/21 Page 16 of 16
`
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Tel: (713) 651-9366
`Fax: (713) 654-6666
`bmelton@susmangodfrey.com
`kzuniga@susmangodfrey.com
`
`Steven M. Shepard (New York 5291232)
`SUSMAN GODFREY LLP
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`Fax: (212) 336-8340
`sshepard@susmangodfrey.com
`
`
`COUNSEL FOR PLAINTIFF
`
`
`
`
`
`MyPAQ, Exhibit 2002
`IPR2022-00311
`Page 16 of 16
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`