IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`Plaintiff,
`
`
`
`v.
`
`IMAGE PROCESSING TECHNOLOGIES,
`LLC,
`
`
`
`
`
`LG ELECTRONICS, INC., and
`LG ELECTRONICS USA, INC.,
`
`
`
`
`
`Defendants.
`
`
`
`
`Civil No. 2:22-cv-00077
`
`JURY TRIAL DEMANDED
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Image Processing Technologies, LLC (“Plaintiff” or “IPT”) files this Complaint
`
`for Patent Infringement against Defendants LG Electronics, Inc. (“LGE”) and LG Electronics
`
`USA, Inc. (“LG USA”) (LGE and LG USA collectively, “LG” or “Defendants”) alleging as
`
`follows:
`
`PARTIES
`
`1.
`
`Plaintiff Image Processing Technologies, LLC is a limited liability company duly
`
`formed under the laws of the State of Florida with a place of business at 75 Montebello Road,
`
`Ste. 104, Suffern, New York 10901.
`
`2.
`
`Upon information and belief, Defendant LG Electronics, Inc. is a company
`
`organized under the laws of Korea with a principal place of business at LG Twin Tower 128,
`
`Yeoui-daero, Yeongdeungpo-gu, Seoul, Korea 07336, and may be served with process pursuant
`
`to the provisions of the Hague Convention. LGE manufactures various products, including
`
`smartphones, and ships the products to the United States for sale and distribution within this
`
`country, both directly and through its subsidiaries.
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`
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`PAGE 1
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`Petitioner LG Ex-1016, 0001
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`

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`3.
`
`Upon information and belief, Defendant LG Electronics USA, Inc. is a corporation
`
`organized under the laws of the State of Delaware, with a principal place of business at 111 Sylvan
`
`Ave., Englewood Cliffs, New Jersey 07632. LG USA is a wholly-owned subsidiary of LGE.
`
`LG USA sells various LG products in the United States, including smartphones. LG USA may be
`
`served with process through its registered agent in the State of Texas, United States Corporation
`
`Co., 211 East 7th St., Ste. 620, Austin, Texas 78701.
`
`4.
`
`On information and belief, LG has regular and established places of business at
`
`2153-2155 Eagle Pkwy., Fort Worth, Texas 76177 and 14901 Beach St., Fort Worth, Texas 76177,
`
`both in Denton County, Texas.
`
`JURISDICTION AND VENUE
`
`5.
`
`This action arises under the patent laws of the United States, 35 U.S.C. § 101, et
`
`seq. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`6.
`
`LGE is subject to specific and general personal jurisdiction in this Court. This
`
`Court has personal jurisdiction over LGE because LGE has engaged in continuous, systematic,
`
`and substantial activities within this State, including substantial marketing and sales of products
`
`and services within this State and District. Furthermore, upon information and belief, this Court
`
`has personal jurisdiction over LGE because LGE has committed acts of infringement giving rise
`
`to IPT’s claims for patent infringement within and directed to this District.
`
`7.
`
`Upon information and belief, LGE has conducted, and does conduct, substantial
`
`business in this forum, directly and/or through subsidiaries, agents, representatives, or
`
`intermediaries, including but not limited to: (i) at least a portion of the acts of infringement alleged
`
`herein; (ii) purposefully and voluntarily placing one or more infringing products and services into
`
`the stream of commerce with the expectation that they will be purchased by consumers in this
`
`forum; and/or (iii) regularly doing or soliciting business, engaging in other persistent courses of
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 2
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`Petitioner LG Ex-1016, 0002
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`

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`conduct, or deriving substantial revenue from goods and services provided to individuals in Texas
`
`and in this District. Thus, LGE is subject to this Court’s specific and general personal jurisdiction
`
`pursuant to due process and the Texas Long-Arm Statute. To the extent LGE is not subject to
`
`jurisdiction in any State’s courts of general jurisdiction, this Court has personal jurisdiction over
`
`LGE pursuant to Federal Rule of Civil Procedure 4(k)(2) because IPT’s claims arise under federal
`
`law and exercising jurisdiction is consistent with the United States Constitution and laws.
`
`8.
`
`LGE is a foreign company that does not reside in the United States. Therefore,
`
`venue is proper in this District as to LGE under 28 U.S.C. § 1391(c)(3).
`
`9.
`
`To the extent that there is no district in which an action may otherwise be brought
`
`against LGE, venue is proper in this District as to LGE under 28 U.S.C. § 1391(b)(3) because LGE
`
`is subject to personal jurisdiction in this Court.
`
`10.
`
`LG USA is subject to specific and general personal jurisdiction in this Court. The
`
`Court has personal jurisdiction over LG USA because it has engaged in continuous, systematic,
`
`and substantial activities within this State, including substantial marketing and sales of products
`
`and services within this State and District. Furthermore, upon information and belief, this Court
`
`has personal jurisdiction over LG USA because LG USA has committed acts of infringement
`
`giving rise to IPT’s claims for patent infringement within and directed to this District.
`
`11.
`
`Upon information and belief, LG USA has conducted and does conduct substantial
`
`business in this forum, directly and/or through subsidiaries, agents, representatives, or
`
`intermediaries, such substantial business including but not limited to: (i) at least a portion of the
`
`acts of infringement alleged herein; (ii) purposefully and voluntarily placing one or more
`
`infringing products and services into the stream of commerce with the expectation that they will
`
`be purchased by consumers in this forum; and/or (iii) regularly doing or soliciting business,
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 3
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`Petitioner LG Ex-1016, 0003
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`

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`engaging in other persistent courses of conduct, or deriving substantial revenue from goods and
`
`services provided to individuals in Texas and in this District. Thus, LG USA is subject to this
`
`Court’s specific and general personal jurisdiction pursuant to due process and the Texas Long-Arm
`
`Statute.
`
`12.
`
`The exercise of personal jurisdiction over LGE and LG USA would not offend
`
`traditional notions of fair play and substantial justice.
`
`13.
`
`Upon information and belief, LG USA has committed acts of infringement in this
`
`District and has regular and established places of business within this District under 28 U.S.C.
`
`§ 1400(b). Thus, venue is proper in this District as to LG USA under 28 U.S.C. § 1400(b).
`
`14.
`
`LG maintains a permanent physical presence within this District. For example, it
`
`maintains regular and established places of business in Denton County, Texas at 2153-2155 Eagle
`
`Pkwy., Fort Worth, Texas 76177 and 14901 Beach St., Fort Worth, Texas 76177.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 4
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`Petitioner LG Ex-1016, 0004
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`

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`15.
`
`Exemplar images of LG’s regular and established places of business at 2153-2155
`
`Eagle Pkwy., Fort Worth, Texas 76177 are below:
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`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 5
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`Petitioner LG Ex-1016, 0005
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`

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`16.
`
`Exemplar images of LG’s regular and established places of business at 14901
`
`Beach St., Fort Worth, Texas 76177 are below:
`
`17.
`
`LG’s locations in this District, including at least those identified in paragraphs 4
`
`and 14–16 above, are regular and established places of business under 28 U.S.C. § 1391, 28 U.S.C.
`
`§ 1400(b), and In re Cray, Inc., 871 F.3d 1355, 1360 (Fed. Cir. 2017).
`
`
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`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 6
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`Petitioner LG Ex-1016, 0006
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`

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`a.
`
`LG’s locations in this District, including at least those identified in
`
`paragraphs 4 and 14–16 above, are physical, geographical locations in this District. Each
`
`office location comprises one or more buildings or office spaces from which the business
`
`of LG is carried out. The locations are set apart for the purpose of carrying out LG’s
`
`business, including but not limited to, making, using, selling, offering for sale, and/or
`
`supporting infringing products. Indeed, LG itself advertises its physical locations in this
`
`District as places of its business, and it features commercial signage at these locations.
`
`b.
`
`LG’s locations in this District, including at least those identified in
`
`paragraphs 4 and 14–16 above, are regular and established. LG features commercial
`
`signage at the locations identified in paragraphs 4 and 14–16 above, identifying each
`
`location as a regular and established place of LG’s business.
`
`c.
`
`LG’s locations in this District, including at least those identified in
`
`paragraphs 4 and 14–16 above, are places of business of LG. LG conducts business from
`
`its locations in this District, including at least those identified in paragraphs 4 and 14–16
`
`above, including but not limited to, making, using, selling, offering for sale, and/or
`
`supporting infringing products.
`
`d.
`
`LG’s locations in this District, including at least those identified in
`
`paragraphs 4 and 14–16 above, are physical, geographical location(s) in this District from
`
`which LG carries out its business.
`
`e.
`
`LG employees work at LG’s locations, including at least those identified in
`
`paragraphs 4 and 14–16 above. Upon information and belief, these LG employees are
`
`regularly and physically present at LG’s locations, including at least those identified in
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 7
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`Petitioner LG Ex-1016, 0007
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`

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`paragraphs 4 and 14–16 above, during business hours and they are conducting LG’s
`
`business while working there.
`
`f.
`
`LG owns, and pays taxes on, at least the locations identified in paragraphs 4
`
`and 14–16 above in Denton County, Texas.
`
`FACTUAL ALLEGATIONS
`
`PATENT-IN-SUIT
`
`18.
`
`U.S. Patent No. 6,959,293 (“the ’293 Patent”) is entitled “Method and Device for
`
`Automatic Visual Perception.” The United States Patent and Trademark Office duly and legally
`
`issued the ’293 Patent on October 25, 2005, from U.S. Patent Application No. 09/792,436, filed
`
`on February 23, 2001.
`
`19.
`
`IPT is the current owner of all rights, title, and interest in and to the ’293 Patent,
`
`including the right to sue for past damages.
`
`20.
`
`A true and correct copy of the ’293 Patent is attached hereto as Exhibit A and is
`
`incorporated by reference herein.
`
`21.
`
`The ’293 Patent generally relates to methods and devices for automatic visual
`
`perception, and more particularly to methods and devices for processing image signals using one
`
`or more self-adapting histogram calculation units capable of implementing anticipation and
`
`learning modes. Such devices can be termed electronic spatio-temporal neurons, and are
`
`particularly useful for image processing. In such image processing, the electronic device
`
`constitutes histograms of certain parameters and uses them in visual perception in order to acquire,
`
`manipulate and process statistical information. The inventions claimed and described in the
`
`’293 Patent provide visual perception devices and methods for automatically detecting an event
`
`occurring in a space with respect to at least one parameter.
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 8
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`Petitioner LG Ex-1016, 0008
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`22.
`
`Claim 1 is illustrative of the claimed invention of the ’293 Patent. It is directed to:
`
`1. A visual perception processor for automatically detecting an event
`occurring in a multidimensional space (i, j) evolving over time with respect to at
`least one digitized parameter in the form of a digital signal on a data bus, said digital
`signal being in the form of a succession aijT of binary numbers associated with
`synchronization signals enabling
`to define a given
`instant (T) of
`the
`multidimensional space and the position (i, j) in this space, the visual perception
`processor comprising:
`the data bus;
`a control unit;
`a time coincidences bus carrying at least a time coincidence signal; and
`at least two histogram calculation units for the treatment of the at least one
`parameter,
`the histogram calculation units being configured to form a histogram
`representative of the parameter as a function of a validation signal
`and to determine by classification a binary classification signal
`resulting from a comparison of the parameter and a selection
`criterion C, wherein the classification signal is sent to the time
`coincidences bus, and wherein the validation signal is produced
`from time coincidences signals from the time coincidence bus so
`that the calculation of the histogram depends on the classification
`signals carried by the time coincidence bus.
`
`23.
`
`Numerous companies enjoy a license the ’293 Patent, including well-known
`
`
`
`camera and mobile phone manufacturers.
`
`DEFENDANTS’ KNOWLEDGE OF THE PATENT
`
`24.
`
`25.
`
`LG had knowledge of the ’293 Patent prior to the filing of this suit.
`
`On or about March 25, 2015, IPT sent a letter to LG through IPT’s licensing agent,
`
`identifying the ’293 Patent and offering LG a license to the ’293 Patent. A true and correct copy
`
`of the March 25, 2015 letter, not including attachments, is attached hereto as Exhibit B. LG
`
`confirmed receipt of the letter via email on June 26, 2015. A true and correct copy of the June 26,
`
`2015 confirmation email is attached hereto as Exhibit C.
`
`26.
`
`On or about December 29, 2015, IPT sent another letter to LG through IPT’s
`
`licensing agent, again identifying the ’293 Patent, and stating that “Image Processing believes LG
`
`is infringing at least U.S. Patent No. 6,959,293 through its business activities that are directed to
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 9
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`Petitioner LG Ex-1016, 0009
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`

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`the United States regarding facial detection algorithms and products that include facial detection
`
`technology.” A true and correct copy of the December 29, 2015 letter, not including enclosures,
`
`is attached hereto as Exhibit D.
`
`27.
`
`On or about January 18, 2016, IPT and LG entered into a Confidentiality
`
`Agreement to protect confidential information exchanged between IPT and LG for “assessing the
`
`appropriateness of obtaining a license from Image Processing and negotiating the terms of such
`
`license with Image Processing.” A true and correct copy of the January 18, 2016 Confidentiality
`
`Agreement is attached hereto as Exhibit E.
`
`28.
`
`On or about March 17, 2016, IPT sent another letter to LG through IPT’s licensing
`
`agent identifying the ’293 Patent, again notifying LG of LG’s infringement. Specifically, in the
`
`March 17, 2016 letter, IPT asserted that LG infringed the ’293 Patent both directly and indirectly.
`
`IPT again offered LG a “non-exclusive license to the IPT portfolio” on “fair and reasonable terms.”
`
`A true and correct copy of the March 17, 2016 letter, not including attachments, is attached hereto
`
`as Exhibit F.
`
`29.
`
`In or about the Spring of 2017, IPT’s representatives met in-person with LG in
`
`Korea. During this meeting, IPT’s representatives again notified LG of the ’293 Patent as well as
`
`LG’s infringement of the ’293 Patent.
`
`30.
`
`On or about December 15, 2017, IPT sent another letter to LG through IPT’s
`
`licensing agent, informing LG of the status of IPT’s litigation with Samsung Electronics America,
`
`Inc. and pending Inter Partes Reviews (“IPRs”). IPT expressly informed LG that “Claim 1 of the
`
`’293 Patent has already survived Samsung’s validity challenges” and that the “PTAB denied [sic]
`
`to institute trial.” IPT asserted that “[w]e continue to believe that LG infringes at least Claim 1 of
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 10
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`Petitioner LG Ex-1016, 0010
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`

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`the ’293 Patent.” And again, IPT invited LG to license the ’293 Patent. A true and correct copy
`
`of the December 15, 2017 letter is attached hereto as Exhibit G.
`
`31.
`
`On or about March 29, 2018, IPT sent another letter to LG through IPT’s licensing
`
`agent, again informing LG that “Claim 1 of the ’293 Patent survived Samsung’s IPR challenge”
`
`and that “[w]e continue to believe that LG infringes Claim 1 of the ’293 Patent.” IPT also attached
`
`to its March 29, 2018 a claim chart illustrating LG’s infringement of claim 1 of the ’293 Patent.
`
`A true and correct copy of the March 29, 2018 letter, not including attachments, is attached hereto
`
`as Exhibit H.
`
`32.
`
`During the period of approximately 2020–2021, IPT engaged in a series of emails
`
`and telephone calls with LG, during which IPT again informed LG of the ’293 Patent and offered
`
`LG a license to IPT’s Patents.
`
`33.
`
`For example, on or about July 23, 2021, IPT again provided representatives of LG
`
`with a copy of the claim chart illustrating LG’s infringement of claim 1 of the ’293 Patent that IPT
`
`previously provided to LG on or about March 29, 2018.
`
`34.
`
`For another example, on or about September 7, 2021, IPT had a telephone
`
`conference with one or more representatives of LG regarding at least LG’s infringement of claim 1
`
`of the ’293 Patent.
`
`35.
`
`Despite IPT’s continuous correspondence and meetings with LG, LG refused to
`
`take a license to the ’293 Patent and refused to cease its infringing activity. Instead, LG proceeded
`
`with its infringing business activities with disregard to IPT’s patent rights. As a result, LG’s
`
`infringing conduct is deliberate, purposeful, and willful.
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`
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`PAGE 11
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`Petitioner LG Ex-1016, 0011
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`

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`THE ACCUSED PRODUCTS
`
`36.
`
`LG manufactures and sells a variety of consumer electronics, including certain
`
`mobile phones and tablets with one or more cameras. Defendants’ mobile phones with one or
`
`more cameras have been widely available for sale in the United States.
`
`37.
`
`Defendants’ infringing products include at least their smartphones and tablets
`
`running the Android OS, or substantially similar technology, made, used, sold, or offered for sale
`
`in the United States, or imported into the United States (the “Accused Products”). In particular,
`
`Defendants’ infringing products include at least the LG G7 ThinQ GSM smartphone.
`
`38.
`
`Defendants continue to advertise the Accused Products on the LG.com website,1
`
`including making available numerous user guides for the Accused Products and features.2
`
`39.
`
`The Accused Products include different features such as “Face Detection” and an
`
`“AI CAM” capability. The AI CAM is a camera that recognizes specified targets, such as puppies,
`
`food, landscapes, people, and more to suggest the best filters for a specific scene.
`
`COUNT I: INFRINGEMENT OF THE ’293 PATENT
`
`40.
`
`IPT incorporates by reference and realleges paragraphs 1 through 39 as if
`
`specifically set forth herein.
`
`41.
`
`In violation of 35 U.S.C. § 271(a), Defendants LGE and LG USA are and have been
`
`directly infringing one or more of the claims of the ’293 Patent, including at least Claim 1, by
`
`
`1 LG, LG Mobile Phones: Browse LG Dual Screen™ Phones, 5G Smartphones & More,
`https://www.lg.com/us/cell-phones (last visited Mar. 4, 2022).
`
`2 E.g., LG, LG LMG710VMX.AUCLPL: Support, Manuals, Warranty & More,
`https://www.lg.com/us/support/product/lg-LMG710VMX.AUCLPL (last visited Mar. 4, 2022);
`LG,
`LG
`LMG710TMR.ATMORP:
`Support, Manuals, Warranty & More,
`https://www.lg.com/us/support/product/lg-LMG710TMR.ATMORP (last visited Mar. 4, 2022);
`LG,
`LGG710PM.ASPRWU:
`Support,
`Manuals,
`Warranty
`&
`More,
`https://www.lg.com/us/support/product/lg-LGG710PM.ASPRWU (last visited Mar. 4, 2022).
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
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`PAGE 12
`
`Petitioner LG Ex-1016, 0012
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`

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`making, using, selling, and/or offering for sale in the United States, without authority, the Accused
`
`Products, including but not limited to smartphones and tablets, such as the LG G7 ThinQ GSM
`
`smartphone.
`
`42.
`
`Defendants LGE and LG USA are infringing claims of the ’293 Patent, including
`
`at least Claim 1, literally and/or under the doctrine of equivalents.
`
`43.
`
`Upon information and belief, the Accused Products, including at least the LG G7
`
`ThinQ GSM smartphone, run at least Android OS versions 8 through 10.
`
`44.
`
`The Accused Products include a processor. For example, the LG G7 ThinQ GSM
`
`smartphone includes a Qualcomm SDM845 Snapdragon 845 (10 nm) processor.
`
`45.
`
`Upon information and belief, Snapdragon 845 features the Qualcomm Spectra 280
`
`Image Signal Processor (“ISP”), which Qualcomm claims is designed to deliver a premium camera
`
`and XR experience, with a high-performance capture of up to 16 MP at 60 images per second.
`
`46.
`
`Upon information and belief, Snapdragon 845 includes a Qualcomm Kryo™ 385
`
`CPU built on ARM Cortex technology.
`
`47.
`
`The Accused Products also include one or more cameras. For example, the LG G7
`
`ThinQ GSM smartphone includes (i) a 16 MP, f/1.6, 30mm (standard), 1/3.1”, 1.0µm, PDAF,
`
`Laser AF, OIS camera, (ii) a 16 MP, f/1.9, 16mm (ultrawide), 1/3.1”, no AF camera, and (iii) an 8
`
`MP, f/1.9, 26mm (wide) camera.3
`
`
`3 GSMArena, LG G7 ThinQ – Full Phone specifications, https://www.gsmarena.com/lg_g7_thinq-
`9115.php (last visited Mar. 4, 2022).
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 13
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`Petitioner LG Ex-1016, 0013
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`

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`
`
`48.
`
`Upon information and belief, the Accused Products include an image processing
`
`system configured to receive an image signal that consists of a series of frames of pixel data. The
`
`image signal is received from the Accused Products’ front and/or rear camera(s).
`
`49.
`
`Upon information and belief, the processor of the Accused Products is for
`
`automatically detecting an event occurring in a multidimensional space (i, j) evolving over time
`
`with respect to at least one digitized parameter in the form of a digital signal on a data bus, said
`
`digital signal being in the form of a succession aijT of binary numbers associated with
`
`synchronization signals enabling to define a given instant (T) of the multidimensional space and
`
`the position (i, j) in this space.
`
`50.
`
`Upon information and belief, the Accused Products detect an event occurring in a
`
`multidimensional space evolving over time with respect to at least one digitized parameter in the
`
`form of a digital signal on a data bus. An event (e.g., an occurrence of a person’s face) is detected
`
`based on a multidimensional image occurring over time with respect to several digitized
`
`parameters (e.g., brightness, color) transferred over a camera bus.
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 14
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`Petitioner LG Ex-1016, 0014
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`

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`4
`
`51.
`
`Upon information and belief, the Accused Products contain a processor that
`
`contains an ARM core and/or other processing hardware that calculates a histogram.
`
`52.
`
`Upon information and belief, the Accused Products include a data bus, control unit,
`
`controller coupled to a controller bus and a transfer bus, and a time coincidences bus carrying at
`
`least a time coincidence signal.
`
`
`4 LG Mobile Global, LG G7 ThinQ: Main Tutorial (AI CAM + Super Wide Angle Camera),
`YOUTUBE (July 18, 2018), https://www.youtube.com/watch?v=4KJMnEBv0WM.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
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`PAGE 15
`
`Petitioner LG Ex-1016, 0015
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`

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`5
`
`53.
`
`Upon information and belief, the Accused Products comprise at least two histogram
`
`calculation units for the treatment of at least one parameter, the histogram calculation units being
`
`configured to form a histogram representative of the parameter as a function of a validation signal
`
`and to determine by classification a binary classification signal resulting from a comparison of the
`
`parameter and a selection criterion C. The Accused Products generate histograms based on the
`
`classification values of pixels in subsequent frames of the image signal and adjust the face location
`
`based on the histograms generated based on these subsequent frames.
`
`54.
`
`Upon information and belief, the Accused Products come with firmware and a
`
`number of files pre-installed, including, among other files, “Libfilterpack_facedetect.so,” which
`
`uses histogram calculation units to form histograms, to recognize faces.
`
`
`5 iFixit,
`Teardown,
`ThinQ
`G7
`LG
`https://www.ifixit.com/Teardown/LG+G7+ThinQ+Teardown/110419 (last visited Mar. 4, 2022).
`
`COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE 16
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`Petitioner LG Ex-1016, 0016
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`

`

`55.
`
`Upon information and belief, the Accused Products generate a histogram based on
`
`classification values in a first frame, identify a target—for example, a face—from the histogram,
`
`and determine the target’s location based on the generated histogram.
`
`56.
`
`Upon information and belief, the Accused Products generate histograms based on
`
`classification values of pixels in subsequent frames and adjust the target location based on the
`
`histograms generated on these subsequent frames.
`
`57.
`
`Upon information and belief, the Accused Products send classification signals to
`
`the time coincidences bus.
`
`58.
`
`Upon information and belief, the Accused Products produce validation signals from
`
`time coincidences signals from the time coincidence bus so that the calculation of the histogram
`
`depends on the classification signals carried by the time coincidence bus.
`
`59.
`
`In violation of 35 U.S.C. § 271(b), Defendants are and have been infringing one or
`
`more of the claims of the ’293 Patent, including at least Claim 1, indirectly by inducing the
`
`infringement of at least Claim 1 of the ’293 Patent by third parties, including for example LG
`
`customers and/or end-users of the Accused Products, in this District and elsewhere in the United
`
`States. Direct infringement by, for example, LG customers and/or end-users of the Accused
`
`Products occurs by the use of the Accused Products, including at least the LG G7 ThinQ GSM
`
`smartphone.
`
`60.
`
`Upon information and belief, Defendants provide instructive materials and
`
`information concerning the operation and use of the Accused Products,6 including at least the AI
`
`
`6 E.g., LG, LG LMG710VMX.AUCLPL: Support, Manuals, Warranty & More,
`https://www.lg.com/us/support/product/lg-LMG710VMX.AUCLPL (last visited Mar. 4, 2022);
`LG,
`LG
`LMG710TMR.ATMORP:
`Support, Manuals, Warranty & More,
`https://www.lg.com/us/support/product/lg-LMG710TMR.ATMORP (last visited Mar. 4, 2022);
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`PAGE 17
`
`Petitioner LG Ex-1016, 0017
`
`

`

`CAM capability,7 to induce third parties, including LG customers and/or end-users of the Accused
`
`Products, to use the Accused Products, including at least the LG G7 ThinQ GSM smartphone, in
`
`a manner that would infringe at least Claim 1 of the ’293 Patent.
`
`61.
`
`Upon information and belief, Defendants also market, advertise and sell the
`
`Accused Products on the LG.com website, make available user guides for the Accused Products,
`
`and offer technical support and instructions for the Accused Products, including at least the LG
`
`G7 ThinQ GSM smartphone. These acts instruct third parties, including LG customers and/or end-
`
`users of the Accused Products, to use the Accused Products in a manner that infringes one or more
`
`claims of the ’293 Patent, including at least Claim 1.
`
`62.
`
`For example, Defendants provide an Owner’s Manual for the LG G7 ThinQ GSM
`
`smartphone on the LG.com website.8 The manual instructs third parties, including LG customers
`
`and/or end-users of the Accused Products, in the use of the Accused Products, including at least
`
`the LG G7 ThinQ GSM smartphone.
`
`63.
`
`Defendants offer technical support for the Accused Products, including at least the
`
`LG G7 ThinQ GSM smartphone, on the lg.com website.9
`
`
`More,
`&
`Warranty
`Manuals,
`Support,
`LG,
`LGG710PM.ASPRWU:
`https://www.lg.com/us/support/product/lg-LGG710PM.ASPRWU (last visited Mar. 4, 2022).
`
`7 E.g., LG, LG G7 ThinQ – Camera Overview and Settings, https://www.lg.com/us/support/help-
`library/lg-g7-thinq-camera-overview-and-settings-CT10000027-20150726477193 (last visited
`Mar. 4, 2022).
`
`8 E.g., LG, User Guide: LG G7 ThinQ LM-G710TM, available at https://gscs-
`b2c.lge.com/downloadFile?fileId=EnTAsmzn9Y5WNZqf0T7sQ (last accessed Mar. 4, 2022).
`
`9 LG, Product Support: Help Library, https://www.lg.com/us/support/help-library (last visited
`Mar. 4, 2022).
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`PAGE 18
`
`Petitioner LG Ex-1016, 0018
`
`

`

`64.
`
`For example, below is a screenshot of the product page for the LG G7 ThinQ GSM
`
`smartphone, including links for manuals, a help library, video tutorials, requests for repairs, and
`
`other support options.10
`
`~ (cid:157)
`'-'-.t•
`
`0
`0 ""Pl ~ - 'w e pt,c,,a
`l) Po'ltl a ~
`G t.Mw..-, 11 ~
`
`'9 LMGnon.,9, ~tfftllb<i.
`n .. (lc,Q
`
`OVE.RVIEW
`
`SPECS
`
`REVIEWS
`
`5UPPOlilT
`
`We're here to support you with our product.
`V,tw .L.M£U.lillM Ptoduc:t $i.lP9()tt
`
`~
`.., .........
`
`Warranty Information
`,_,,,'"-'Jfactl#•
`
`~
`
`Register Your Product
`GlttN...ictritfl~....,,..
`
`l(NINM(),111()
`
`lf.UNMOMf)
`
`a
`---- --- t-i,:yq,,Ato,.-,rooan
`
`Manuals and Downloads
`
`Help Library
`
`l(AIINUl)la)
`
`l{~....._)
`
`~
`
`W1
`
`Video Tutorials
`1,Mr,tfl,:,.t(lonu...l . . . . . J'IN'I.Ollll'OIMi
`
`lt,l,JlNMOMI[)
`
`ii:il··Hhi
`
`~
`
`Request a Repair
`
`-~
`
`~
`
`Other Support Options
`MOl"t,-.-~i.o~
`
`\(./UINMQil'
`
`)
`
`l.(AflN~)
`
`C
`
`r.
`
`_,,
`
`I
`
`
`
`65.
`
`Upon information and belief, Defendants also publish tutorials on YouTube
`
`instructing third parties, including LG customers and/or end-users, in the use of Accused Products,
`
`including at least the LG G7 ThinQ GSM smartphone11 and the AI CAM capability12 to
`
`automatically recognize the target object, such as a face.
`
`
`10 LG, LG G7 ThinQ™ Smartphone for T-Mobile | LMG710TM, https://www.lg.com/us/cell-
`phones/lg-LMG710TM-g7-thinq-tmobile (last visited Mar. 4, 2022) (select “Support” tab).
`
`11 E.g., LG Mobile Global, LG G7 ThinQ Playlist, YOUTUBE (last updated Nov. 5, 2018),
`(last
`https://www.youtube.com/playlist?list=PLShKiWbiCfxYMXgvW2WloDSzX6ZsIpJfR
`visited March 4, 2022).
`
`12 E.g., LG Mobile Global, LG G7 ThinQ: Main Tutorial (AI CAM), YOUTUBE (July 16, 2018),
`https://www.youtube.com/watch?v=SuEktB1Gp54.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`PAGE 19
`
`Petitioner LG Ex-1016, 0019
`
`

`

`66.
`
`For example, below is a screenshot from a YouTube video published by Defendants
`
`entitled “LG G7 ThinQ: Main Tutorial (AI CAM)” instructing third parties, including LG
`
`customers and/or end-users, in the use of the Accused Products, including at least the LG G7 ThinQ
`
`GSM smartphone in a manner that infringes one or more claims of the ’293 Patent, including at
`
`least Claim 1.13
`
`
`
`67.
`
`Defendants knew or should have known of the ’293 Patent through a series of
`
`correspondence and meetings expressly notifying LG of the ’293 Patent and LG’s infringement
`
`thereof. As a result, not only did LG know of its infringement, but LG knew it infringed the
`
`’293 Patent at least as early as March 25, 2015. Despite this knowledge, LG continued to induce
`
`third parties, including LG customers and/or end-users of the Accused Products, and LG knew or
`
`should have known that those acts would induce actual infringement by third parties, including
`
`LG customers and/or end-users of the Accused Products, of one or more of the claims of the
`
`’293 Patent, including at least Claim 1.
`
`68.
`
`Defendants also have actual knowledge of the ’293 Patent at least as of the date of
`
`filing of this Complaint.
`
`
`13 Id.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`PAGE 20
`
`Petitioner LG Ex-1016, 0020
`
`

`

`69.
`
`Defendants have taken active steps to encourage third parties, including LG
`
`customers and/or end-users of the Accused Products, to use the Accused Products in a manner that
`
`infringes one or more claims of the ’293 Patent, including at least Claim 1. These steps include
`
`advertising the Accused Products, including at least the LG G7 ThinQ GSM smartphone, with an
`
`emphasis on the AI CAM capability,14 publishing instructional manuals on the use of the Accused
`
`Products, including at least the LG G7 ThinQ GSM smartphone,15 in a manner that infringes one
`
`or more claims of the ’293 Patent, including at least Claim 1, and publishing videos to instruct,
`
`encourage, and assist in the same.16
`
`70.
`
`Defendants also publish extensive technical support on the LG.com website for
`
`third parties, including LG customers and/or end-us