Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 1 of 57
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
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`MULLEN INDUSTRIES LLC,
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` Plaintiff,
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`v.
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`APPLE INC.,
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` Defendant.
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`
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`Case No. 6:22-cv-00145
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Mullen Industries LLC (“Mullen Industries” or “Plaintiff”) for its Complaint
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`against Defendant Apple Inc. (“Apple” or “Defendant”) for patent infringement under 35 U.S.C.
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`§ 271 relating to U.S. Patent Nos. 11,246,024 (the “’024 Patent”), 11,234,117 (the “’117 Patent”),
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`11,190,633 (the “’633 Patent”), 11,122,418 (the “’418 Patent”), 11,109,218 (the “’218 Patent”),
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`11,096,039 (the “’039 Patent”), 9,635,540 (the “’540 Patent”), 9,204,283 (the “’283 Patent”), and
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`8,374,575 (the “’575 Patent” and collectively, the “Patents-in-Suit”) alleges as follows:
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`INTRODUCTION
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`1.
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`The Patents-in-Suit are directed to technological advancements and security
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`improvements in regards to server systems and mobile devices including cellular phones, tablets,
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`and smart watches. The Patents-in-Suit and additional patent pending technology arose from the
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`research and development of Jeff Mullen and his company Mullen Industries LLC.
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`2.
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`Jeff Mullen is an inventor, technologist, electrical and computer engineer, MBA
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`graduate, and founder of multiple companies.
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`3.
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`Jeff Mullen has innovated prolifically across a wide array of technologies since the
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`early 2000s, including, for example, with regard to wireless and cellular communications systems
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`1
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 1 of 57
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`

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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 2 of 57
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`and devices, security improvements regarding the same, augmented reality and virtual reality
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`devices, and autonomous defense systems.
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`4.
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`By way of example, the Patents-in-Suit identify problems that existed in the art of
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`mobile devices and global positioning system technology. See, e.g., ’418 Patent at 1:28-33. To
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`address these problems, the Patents-in-Suit disclose technological advancements and security
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`improvements in regards to, for example, “systems and methods … for locating cellular phones …
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`[and] for allowing a user of a cellular phone … to locate the position of a different user’s cellular
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`phone … based upon requestor-assigned access rights.” See, e.g., ’418 Patent at 1:37-43.
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`5.
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`The Patents-in-Suit teach, for example, that “[i]n order for users to be identified by
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`other users’ cell phones or locating devices a user profile may need to be stored remotely from
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`such devices. In such instances user profiles would be used as the locating identifier and the
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`devices into which these profiles are logged into (recognized by) would allow for the user to be
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`located.” Id. at 9:53-65; see also 2:59-3:13, 11:3-24, 12:42-13:3.
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`6.
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`The Patents-in-Suit disclose, for example, a backend server system that
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`communicates with mobile devices to provide location-based services and features. For example,
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`the Patents-in-Suit teach a mobile device that can receive and display location information
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`regarding another mobile device by “contact[ing] the remote database, hav[ing] his/her identity
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`recognized, hav[ing] his/her access rights for the requested user location determined, and, if the
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`requesting user has the correct access rights, be[ing] provided with the requested user’s location.”
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`Id. at 5:11-44.
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`7.
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`The Patents-in-Suit describe additional technological advancements and security
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`improvements in regards to server systems and mobile devices. For example, the Patents-in-Suit
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`describe that “different types of access levels may be provided that allow a user to filter location
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`2
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 2 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 3 of 57
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`information to a different user.” See id. at 1:49-54. Such access rights can vary, for example, by
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`time (e.g., location is only accessible for a certain amount of time) or place (e.g., only an
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`approximate location, but not an exact location, may be accessed). Id. at 1:55-2:2.
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`8.
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`As additional examples, the Patents-in-Suit solve technical challenges related to
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`receiving and providing event notifications and location-based information, such as location
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`markers on a map, navigable directions, and distance information, on mobile devices with small
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`display screens. E.g., id. at 2:22-34, 8:6-21; ’633 Patent at 1:47-2:11.
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`9.
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`Jeff Mullen’s patented innovations have been widely cited by others. By way of
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`example, the Patents-in-Suit have been cited by others over 100 times in U.S. Patent Office
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`proceedings, including in multiple proceedings involving Apple.
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`10.
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`For example, on February 26, 2019, Apple cited Jeff Mullen’s ’575, ’283, and ’540
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`Patents directed to “Systems and Methods for Locating Cellular Phones and Security Measures for
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`the Same.” Each has a priority date of March 25, 2002—approximately ten years earlier than the
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`earliest possible priority date of Apple’s U.S. Patent Appln. No. 16/147,028 (U.S. Pub. No.
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`2019/0273652) directed to the same or similar location-based technologies now deployed in every
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`Apple iPhone, iPad, Watch, and iPod touch device, and by Apple’s iCloud server system.1
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`11.
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`As another example, on information and belief Apple has possessed knowledge of
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`Jeff Mullen’s inventions at least as early as June 22, 2011 when the U.S. Patent Office cited
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`Mullen’s related U.S. Pub. No. 2006/0252431, which contains the same disclosure as Mullen’s
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`’575, ’283, and ’540 Patents, to Apple in Apple’s U.S. Appln. No. 12/185,598 (U.S. Pub. No.
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`2010/0029302).
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`1 E.g., https://www.apple.com/icloud/find-my/; https://support.apple.com/en-us/HT210514;
`https://support.apple.com/guide/watch/find-people-apd1132106dc/watchos.
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`3
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 3 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 4 of 57
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`MULLEN INDUSTRIES LLC
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`THE PARTIES
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`12.
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`Plaintiff Mullen Industries LLC is a limited liability company organized and
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`existing under the laws of the State of Delaware.
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`APPLE INC.
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`13.
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`Apple is a California corporation and maintains a place of business located at One
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`Apple Park Way, Cupertino, California 95014, and may be served with process through its
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`registered agent, CT Corporation System at 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`14.
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`Apple does business in Texas, directly and through intermediaries, and offers its
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`products and/or services, including those accused herein of infringement, to customers and
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`potential customers located in Texas, including in this District.
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`15.
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`On information and belief, Apple maintains regular and established places of
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`business within this District including at least the following locations: 12545 Riata Vista Circle,
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`Austin, Texas 78727; 6900 W. Parmer Lane, Austin, Texas 78729; 12801 Delcour Drive, Austin,
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`Texas 78727; 3121 Palm Way, Austin, Texas 78758; 2901 S. Capital of Texas Highway, Austin,
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`Texas 78746. Upon information and belief, Apple employs individuals in this District involved in
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`the research, development, sales, and marketing of its products and services that infringe the
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`Patents-in-Suit.
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`JURISDICTION AND VENUE
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`16.
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`This is an action for patent infringement arising under the patent laws of the United
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`States, 35 U.S.C. §§ 1, et seq. This Court has exclusive subject matter jurisdiction over this action
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`under 28 U.S.C. §§ 1331 and 1338(a).
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`17.
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`This Court has personal jurisdiction over Apple. Apple regularly conducts business
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`and has committed acts of patent infringement within this District and the State of Texas that give
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`4
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 4 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 5 of 57
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`rise to this action and has established minimum contacts with this forum such that exercise of
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`jurisdiction over Apple would not offend traditional notions of fair play and substantial justice.
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`Apple has committed and continues to commit acts of infringement in this District and State by,
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`among other things, offering to sell, selling, using, importing, and making products and services
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`that infringe the Patents-in-Suit.
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`18.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400. Apple is
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`registered to do business in Texas and, upon information and belief, Apple has transacted business
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`in this District, has committed acts of direct infringement in this District, and has regular and
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`established places of business in this District as set forth above.
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`19.
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`On information and belief, Apple has thousands of employees based in the Western
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`District of Texas and does business in this District and across the State of Texas.2
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`20.
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`On information and belief, Apple’s employees in this District include, for example,
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`Software Engineers, Senior Software Engineers, Software Quality Engineers, iCloud Support
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`Engineers, and iCloud Site Support Engineers. Accordingly, on information and belief, witnesses
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`and documents relevant to this action are located in this District.
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`21.
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`For example, Apple currently employs in the Austin metropolitan area several
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`witnesses relevant to Apple’s infringement of the Patents-in-Suit including, for example, a
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`2 See e.g., Apple checks in with 192-room hotel for billion-dollar Northwest Austin campus,
`published May 20, 2020 (https://austin.culturemap.com/news/city-life/05-20-20-apple-adds-
`surprising-element-to-1-billion-campus-in-northwest-austin/); Apple bites into North Austin with
`new $1 billion
`campus and 5,000 potential
`jobs, published Dec. 13, 2018
`(https://austin.culturemap.com/news/city-life/12-13-18-apple-bites-into-north-austin-with-new-1-
`billion-campus-and-5000-jobs/); Apple Press Release, Apple expands in Austin, published
`November 20, 2019 (https://www.apple.com/newsroom/2019/11/apple-expands-in-austin/); Apple
`getting big tax rebate from Williamson County with Austin expansion, published Dec. 18, 2018
`(https://www.kvue.com/article/news/local/apple-could-get-big-tax-break-from-
`williamsoncounty-with-austin-expansion/269-623955430).
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`5
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 5 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 6 of 57
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`Software Engineer working on “Cloud Infrastructure,” a “Senior Software Engineer – Data
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`Science and Machine Learning” that “[l]ead[s] AppleCare in a large cross-functional initiative”
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`involving “iCloud,” a Software Quality Engineer providing “iCloud” support, an “iCloud Support
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`Engineer,” and an “iCloud Site Support Engineer” that “[r]esolve[s] iCloud technical requests from
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`call center reports,” “[a]nalyze[s] and identif[ies] trending or emerging issues with end users,” and
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`“[m]anage[s] community forums and postings.”3
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`22.
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`Apple also continues to expand its presence in this District including with regard to
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`technology areas relevant to Apple’s infringement of the Patents-in-Suit. For example, Apple
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`currently has 600+ job openings in the Austin metropolitan area.4
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`23.
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`In one example, Apple has listed a job opening in Austin, Texas for an “iCloud
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`Support Engineering Readiness Project Manager,” with responsibilities including serving as “the
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`liason between Apple’s contact centers, Engineering, Product Marketing, and Operations in order
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`to provide the best possible customer support experience” in “[p]roduct areas of responsibility”
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`including Apple “iCloud” and Apple “Find My.”5
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`24.
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`As another example, Apple has listed a job opening in Austin, Texas for an
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`“Enterprise Application / Platform Software Engineer” to join the “Apple Identity Management
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`team that’s responsible for all of Apple’s identity and access management” including with regard
`
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`3 See https://www.linkedin.com/in/semchyshyn/, https://www.linkedin.com/in/saurabh-mathur-
`865573b/, https://www.linkedin.com/in/kevin-kissane-2361527a/,
`https://www.linkedin.com/in/chris-heckendorn-36a58216/, https://www.linkedin.com/in/reagan-
`sterner/ (as to each, last accessed January 7, 2022).
`4 Careers at Apple, https://jobs.apple.com/en-us/search?sort=relevance&location=austin-metro-
`area-AUSMETRO (last accessed January 7, 2022).
`5 Careers at Apple, https://jobs.apple.com/en-us/details/200305125/icloud-support-engineering-
`readiness-project-manager?team=CUST (last accessed January 7, 2022).
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`6
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 6 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 7 of 57
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`to Apple “iCloud” and the “security standards for protecting customer data with innovative
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`software solutions.”6
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`25.
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`As another example, Apple has listed a job opening in Austin, Texas for an “SOLR
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`Engineer / Developer” to work on the Apple team that provides “data stores as a service … working
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`with iCloud.”7
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`26.
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`Venue in this District is also proper because Jeff Mullen, the sole member of the
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`Plaintiff and the inventor of all of the Patents-in-Suit, resides in Glenshaw, Pennsylvania, and this
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`District is more convenient for him than, for example, the Northern District of California.
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`27.
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`Apple is subject to this Court’s jurisdiction pursuant to due process and the Texas
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`Long Arm Statute due at least to its substantial business in this State and District, including (a) at
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`least part of its past infringing activities, (b) regularly doing or soliciting business in Texas, and/or
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`(c) engaging in persistent conduct and/or deriving substantial revenue from goods and services
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`provided to customers in Texas.
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`THE PATENTS-IN-SUIT
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`28.
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`On January 25, 2022, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,234,117 (the “’117 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of
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`the ’117 Patent is attached hereto as Exhibit 1.
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`29.
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`On November 30, 2021, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,190,633 (the “’633 Patent”) entitled “Systems and Methods for
`
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`6 Careers at Apple, https://jobs.apple.com/en-us/details/200329128/enterprise-application-
`platform-software-engineer?team=SFTWR (last accessed January 7, 2022).
`7
`Careers
`at
`Apple,
`https://jobs.apple.com/en-us/details/200263877/solr-engineer-
`developer?team=SFTWR (last accessed January 7, 2022).
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`7
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 7 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 8 of 57
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`Providing Remote Incoming Call Notification for Cellular Phones.” A true and correct copy of
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`the ’633 Patent is attached hereto as Exhibit 2.
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`30.
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`On September 14, 2021, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,122,418 (the “’418 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of the
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`’418 Patent is attached hereto as Exhibit 3.
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`31.
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`On August 31, 2021, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,109,218 (the “’218 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of the
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`’218 Patent is attached hereto as Exhibit 4.
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`32.
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`On August 17, 2021, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,096,039 (the “’039 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of the
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`’039 Patent is attached hereto as Exhibit 5.
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`33.
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`On April 25, 2017, the United States Patent and Trademark Office duly and legally
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`issued U.S. Patent No. 9,635,540 (the “’540 Patent”) entitled “Systems and Methods for Locating
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`Cellular Phones and Security Measures for the Same.” A true and correct copy of the ’540 Patent
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`is attached hereto as Exhibit 6.
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`34.
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`On December 1, 2015, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 9,204,283 (the “’283 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of the
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`’283 Patent is attached hereto as Exhibit 7.
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`8
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 8 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 9 of 57
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`35.
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`On February 12, 2013, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 8,374,575 (the “’575 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of the
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`’575 Patent is attached hereto as Exhibit 8.
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`36.
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`On February 8, 2022, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent No. 11,246,024 (the “’024 Patent”) entitled “Systems and Methods for
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`Locating Cellular Phones and Security Measures for the Same.” A true and correct copy of
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`the ’024 Patent is attached hereto as Exhibit 9.
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`37. Mullen Industries LLC is the sole and exclusive owner of all right, title, and interest
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`in and to the Patents-in-Suit, and holds the exclusive right to take all actions necessary to enforce
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`its rights to the Patents-in-Suit, including the filing of this action. Mullen Industries LLC also has
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`the right to recover all damages for past, present, and future infringement of the Patents-in-Suit.
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`38.
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`Pursuant to and because Plaintiff and Jeff Mullen have complied with 35 U.S.C. §§
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`286 and 287(a), Plaintiff is entitled to six years of past damages for Apple’s infringement. Plaintiff
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`is also entitled to damages for Apple’s continuing infringement from the present until the
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`expiration of the last to expire of the Patents-in-Suit.
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`COUNT I
`INFRINGEMENT OF U.S. PATENT NO. 11,234,117
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`39.
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`All of the preceding paragraphs of this Complaint are incorporated by reference as
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`if fully set forth herein.
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`40.
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`Plaintiff has not licensed or otherwise authorized Apple to make, use, offer for sale,
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`sell, export, or import any products that embody the inventions of the ’117 Patent.
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`41.
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`Apple has and continues to directly infringe the ’117 Patent, either literally or under
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`the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making,
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`9
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 9 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 10 of 57
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`using, offering to sell, selling, exporting from, and/or importing into the United States products
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`that satisfy each and every limitation of one or more claims of the ’117 Patent.
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`42.
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`On information and belief, Apple’s products that infringe the ’117 Patent include
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`at least the following versions and variants of Apple’s iPhones: Apple iPhone 13 Pro Max, iPhone
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`13 Pro, iPhone 13, iPhone 13 mini, iPhone 12 Pro Max, iPhone 12 Pro, iPhone 12, iPhone 12 mini,
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`iPhone SE (2nd generation), iPhone 11 Pro, iPhone 11 Pro Max, iPhone 11, iPhone XS, iPhone
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`XS Max, iPhone XR, iPhone X, iPhone 8, iPhone 8 Plus, iPhone 7, iPhone 7 Plus, iPhone 6s,
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`iPhone 6s Plus, iPhone 6, iPhone 6 Plus, iPhone SE (1st generation).
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`43.
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`On information and belief, Apple’s products that infringe the ’117 Patent include
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`at least the following versions and variants of Apple’s iPads: Apple iPad Pro 12.9-inch (5th
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`generation), iPad Pro 11-inch (3rd generation), iPad Pro 12.9-inch (4th generation), iPad Pro 11-
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`inch (2nd generation), iPad Pro 12.9-inch (3rd generation), iPad Pro 11-inch, iPad Pro 12.9-inch
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`(2nd generation), iPad Pro (10.5-inch), iPad Pro (9.7-inch), iPad Pro (12.9-inch), iPad Air (4th
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`generation), iPad Air (3rd generation), iPad Air 2, iPad Air, iPad mini (6th generation), iPad mini
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`(5th generation), iPad mini 4, iPad mini 3, iPad mini 2, iPad (9th generation), iPad (8th generation),
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`iPad (7th generation), iPad (6th generation), iPad (5th generation).
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`44.
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`On information and belief, Apple’s products that infringe the ’117 Patent include
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`at least the following versions and variants of Apple’s Watches: Apple Watch Series 7 (GPS +
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`Cellular) Aluminum, Watch Nike Series 7 (GPS + Cellular), Watch Series 7 (GPS + Cellular)
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`Stainless Steel, Watch Hermès Series 7 (GPS + Cellular), Watch Edition Series 7 (GPS + Cellular)
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`Titanium, Watch Series 6 (GPS + Cellular) Aluminum, Watch Nike Series 6 (GPS + Cellular),
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`Watch Series 6 (GPS + Cellular) Stainless Steel, Watch Hermès Series 6 (GPS + Cellular), Watch
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`Edition Series 6 (GPS + Cellular) Titanium, Watch SE (GPS + Cellular) Aluminum, Watch Nike
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`10
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 10 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 11 of 57
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`SE (GPS + Cellular), Watch Series 5 (GPS + Cellular) Aluminum, Watch Nike Series 5 (GPS +
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`Cellular), Watch Series 5 (GPS + Cellular) Stainless Steel, Watch Hermès Series 5 (GPS +
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`Cellular), Watch Edition Series 5 (GPS + Cellular) Titanium, Watch Edition Series 5 (GPS +
`
`Cellular) Ceramic, Watch Series 4 (GPS + Cellular) Aluminum, Watch Nike+ Series 4 (GPS +
`
`Cellular), Watch Series 4 (GPS + Cellular) Stainless Steel, Watch Hermès Series 4 (GPS +
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`Cellular), Watch Series 3 (GPS + Cellular) Aluminum, Watch Nike+ Series 3 (GPS + Cellular),
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`Watch Series 3 (GPS + Cellular) Stainless Steel, Watch Hermès Series 3 (GPS + Cellular), Watch
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`Edition Series 3 (GPS + Cellular). Collectively, the Apple products that infringe the ’117 Patent
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`are referred to as the “’117 Accused Products.”
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`45.
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`Apple has and continues to directly infringe at least independent claims 1, 15, 29,
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`42, and 73 of the ’117 Patent. For example, Apple has and continues to directly infringe claim 1
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`of the ’117 Patent by making, using, offering to sell, selling, and/or importing into the United
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`States the ’117 Accused Products, each of which comprises a wireless telephone.
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`46.
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`For example, each Apple
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`iPhone
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`is capable of supporting
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`telephonic
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`communications over cellular networks including 5G and LTE. E.g.:8,9
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`8 https://support.apple.com/en-us/HT201296.
`9 https://support.apple.com/kb/SP851?locale=en_US (iPhone 13 – Technical Specifications).
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`11
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 11 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 12 of 57
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`Each cellular-capable Apple iPad is likewise capable of supporting telephonic
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`47.
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`communications over cellular networks including 5G and LTE. Each cellular-capable Apple iPad
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`is capable of making telephone calls over a cellular network using, for example, Apple’s FaceTime
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`application. E.g.:10,11,12
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`
`
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`10 https://support.apple.com/en-us/HT201471.
`11 https://support.apple.com/kb/SP844?locale=en_US (iPad Pro, 12.9-inch (5th generation) –
`Technical Specifications).
`12 https://support.apple.com/guide/ipad/make-and-receive-calls-ipad6b71e29e/ipados.
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`12
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`Petitioner Apple, Inc.
`Exhibit 1030 - Page 12 of 57
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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 13 of 57
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`48.
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`Each cellular-capable Apple Watch is also capable of supporting telephonic
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`communications over cellular networks including LTE and UMTS. E.g.:13,14,15
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`
`13 https://support.apple.com/en-us/HT204507.
`14 https://support.apple.com/kb/SP860?locale=en_US (Apple Watch Series 7 – Technical
`Specifications).
`15 https://support.apple.com/guide/watch/make-phone-calls-apdc38d7a95e/watchos;
`https://support.apple.com/en-us/HT205547; https://www.imore.com/how-make-facetime-call-
`apple-watch.
`
`13
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 13 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 14 of 57
`
`
`
`
`
`
`
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` Each of the ’117 Accused Products comprises a processor. For example, each
`
`
`
`49.
`
`Apple iPhone 13 includes an A15 Bionic system-on-chip. E.g.:16,17
`
`
`
`
`16 https://support.apple.com/kb/SP851?locale=en_US (iPhone 13 – Technical Specifications).
`17 https://www.techinsights.com/blog/teardown/apple-iphone-13-pro-teardown.
`
`14
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 14 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 15 of 57
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`
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`50.
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`As another example, each cellular-capable Apple iPad Pro, 12.9 inch (5th
`
`generation) includes an M1 system-on-chip. E.g.:18,19
`
`
`
`
`
`
`
`
`
`
`18 https://support.apple.com/kb/SP844?locale=en_US (iPad Pro, 12.9-inch (5th generation) –
`Technical Specifications).
`19 https://www.techinsights.com/blog/teardown/apple-ipad-pro-teardown.
`
`15
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 15 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 16 of 57
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`
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`51.
`
`As another example, each cellular-capable Apple Watch Series 7 includes an Apple
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`S7 system-on-chip. E.g.:20,21
`
`
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`
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`52.
`
`Each of the ’117 Accused Products comprises a positioning system for determining
`
`a location of the device. For example, each Apple iPhone, cellular-capable Apple iPad, and
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`cellular-capable Apple Watch includes a global positioning system.22
`
`53.
`
`Each of the ’117 Accused Products comprises memory storing programming. For
`
`example, each Apple iPhone, cellular-capable Apple iPad, and cellular-capable Apple Watch
`
`includes memory storing programming capable of providing location-based services and features
`
`including, for example, Apple Find My or Find My Friends and Apple Maps (Apple iPhones and
`
`
`20 https://support.apple.com/kb/SP860?locale=en_US (Apple Watch Series 7 – Technical
`Specifications).
`21 https://www.ifixit.com/Teardown/Apple+Watch+Series+7+Teardown/145524.
`22 E.g., https://support.apple.com/kb/SP851?locale=en_US
`(iPhone 13 – Technical
`Specifications); https://support.apple.com/kb/SP844?locale=en_US (iPad Pro, 12.9-inch (5th
`generation) – Technical Specifications); https://support.apple.com/kb/SP860?locale=en_US
`(Apple Watch Series 7 – Technical Specifications).
`
`16
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 16 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 17 of 57
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`
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`iPads), or Apple Find People and Apple Maps (Apple Watches). E.g.:23,24
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`
`
`
`
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`
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`23 https://www.apple.com/icloud/find-my/; https://www.apple.com/apple-watch-series-7/.
`24 https://www.apple.com/maps/.
`
`
`
`17
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 17 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 18 of 57
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`
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`Each of the ’117 Accused Products comprises programming capable of providing
`
`
`
`54.
`
`the location of the device to a remote server. For example, each Apple iPhone, cellular-capable
`
`Apple iPad, and cellular-capable Apple Watch programmed with Apple Find My, Find My
`
`Friends, or Find People is capable of providing the location of the iPhone, iPad, or Watch,
`
`respectively, to an Apple iCloud server. E.g.:25,26
`
`
`
`
`
`
`25 https://support.apple.com/en-us/HT210514; https://www.apple.com/icloud/find-my/;
`https://support.apple.com/guide/watch/find-people-
`apd1132106dc/watchos#:~:text=Open%20the%20Find%20People%20app%20on%20your%20A
`pple%20Watch%20to,return%20to%20your%20friends%20list.
`26 https://www.apple.com/icloud/; https://www.apple.com/legal/privacy/data/en/location-
`services/; https://www.apple.com/legal/privacy/law-enforcement-guidelines-us.pdf.
`
`18
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 18 of 57
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`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 19 of 57
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`55.
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`Each of the ’117 Accused Products comprises programming capable of instructing
`
`said remote server to change a list of users on said remote server for a profile associated with said
`
`device that are allowed to access said location by way of said remote server providing said location
`
`from said remote server to at least one of said users of said list of users, wherein each user of said
`
`list of users is representative of one of a plurality of wireless telephones. For example, each Apple
`
`iPhone, cellular-capable Apple iPad, and cellular-capable Apple Watch programmed with Apple
`
`Find My, Find My Friends, or Find People includes options to add and/or remove individuals who
`
`can access the iPhone’s, iPad’s, or Watch’s location from Apple’s iCloud server. Such options,
`
`when selected, instruct Apple’s iCloud server to change in a profile associated with the device a
`
`19
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 19 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 20 of 57
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`
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`list of users authorized to view the device’s location data, where each such authorized user is
`
`associated with a wireless telephone (iPhone, iPad, or Watch).27
`
`56.
`
`Each Apple iPhone, cellular-capable Apple iPad, and cellular-capable Apple Watch
`
`programmed with Apple Find My, Find My Friends, or Find People includes, for example, an
`
`option to share the device’s location (e.g., “Share My Location”) with a user of another device,
`
`which when selected instructs Apple’s iCloud server to add the selected user to the list of users
`
`authorized to view the device’s location data. As another example, each such device is capable of
`
`displaying an option to share the device’s location when another device shares its location with
`
`the device (e.g., option to “Share” the device’s location with a device associated with a user),
`
`which when selected instructs Apple’s iCloud server to add the selected user to the list of users
`
`authorized to view the device’s location data. As additional examples, each such device is capable
`
`of displaying options to stop sharing the device’s location with everyone, or a particular user.
`
`E.g.:28
`
`
`
`
`27 https://support.apple.com/en-us/HT210514; https://www.apple.com/icloud/find-my/.
`28 Id.
`
`20
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 20 of 57
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`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 21 of 57
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`57.
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`Each of the ’117 Accused Products comprises programming capable of receiving
`
`and displaying directional information to one of said plurality of wireless telephones, wherein said
`
`directional information is representative of directions between said location and a second location
`
`associated with said one of said plurality of wireless telephones. For example, each Apple iPhone,
`
`cellular-capable Apple iPad, and cellular-capable Apple Watch programmed with Apple Maps and
`
`Apple Find My, Find My Friends, or Find People is capable of displaying the locations of the
`
`wireless telephones associated with the device user’s friends, and upon selection of one of such
`
`wireless telephones, displaying an option to receive and display directions from the location of the
`
`iPhone, iPad, or Watch to the selected wireless telephone. E.g.:29
`
`
`
`29 Id.
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`
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`21
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 21 of 57
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`

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`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 22 of 57
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`58.
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`Plaintiff has suffered damages as a result of Apple’s infringement of the ’117 Patent
`
`in an amount to be proved at trial.
`
`59.
`
`Plaintiff should be awarded damages in accordance with 35 U.S.C. §§ 271, 281,
`
`and 284, in an amount adequate to compensate for Apple’s infringement of the ’117 Patent, but in
`
`no event less than a reasonable royalty for the use made of the inventions by Apple together with
`
`interest and costs as fixed by the Court.
`
`COUNT II
`INFRINGEMENT OF U.S. PATENT NO. 11,190,633
`
`60.
`
`Plaintiff references and incorporates by reference the preceding paragraphs of this
`
`Complaint as if fully set forth herein.
`
`61.
`
`Plaintiff has not licensed or otherwise authorized Apple to make, use, offer for sale,
`
`sell, export, or import any products that embody the inventions of the ’633 Patent.
`
`62.
`
`Apple has and continues to directly infringe the ’633 Patent, either literally or under
`
`the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making,
`
`using, offering to sell, selling, exporting from, and/or importing into the United States products
`
`22
`
`Petitioner Apple, Inc.
`Exhibit 1030 - Page 22 of 57
`
`

`

`Case 6:22-cv-00145-ADA Document 1 Filed 02/09/22 Page 23 of 57
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`
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`that satisfy each and every limitation of one or more claims of the ’633 Patent.
`
`63.
`
`On information and belief, Apple’s products that infringe the ’633 Patent include
`
`at least the following versions and variants of Apple’s Watches: Apple Watch Series 7 (GPS and
`
`GPS + Cellular Aluminum), Watch Nike Serie