CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 1 of 16
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MINNESOTA
`
`
`REDMON JEANG LLC,
`
`
`Plaintiff,
`
`
`Court File No. 0:22-cv-02749-ECT-LIB
`
`
`FIRST AMENDED COMPLAINT
`FOR PATENT INFRINGEMENT
`
`
`
`TURNSIGNL, INC. and
`TURNSIGNL FOUNDATION,
`
`
`v.
`
`Defendants.
`
`
`
`
`
`
`Plaintiff Redmon Jeang LLC (“Plaintiff” or “Redmon”), by and through its
`
`undersigned counsel, alleges,  on knowledge as to its own actions and otherwise upon
`
`information and belief, by way of this First Amended Complaint for Patent Infringement
`
`against Defendants TurnSignl, Inc. and TurnSignl Foundation (collectively, “Defendants”
`
`or “TurnSignl”) as follows:
`
`THE PARTIES
`
`1.
`
`Redmon is a limited liability company organized under the laws of the State
`
`of Texas having a principal place of business at 2709 Dublin Road, Plano, Texas 75094.
`
`2.
`
`Upon information and belief, Defendant TurnSignl, Inc. is a corporation
`
`organized and existing under the laws of the State of Delaware, and Defendant TurnSignl
`
`Foundation is a nonprofit corporation organized and existing under the laws of the State of
`
`Minnesota.
`
`3.
`
`Upon information and belief, Defendants’ principal place of business is at:
`
`1317 Marshall Street NE, Minneapolis, Minnesota 55413; 34 13th Avenue NE,
`
`TurnSignl - Exhibit 1038
`Page 1 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 2 of 16
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`Minneapolis, Minnesota 55413; and/or 620 Wentworth Avenue W, Mendota Heights,
`
`Minnesota 55118.
`
`4.
`
`Defendants may be served via their registered agents: Andre Creighton, 1317
`
`Marshall Street NE, Minneapolis, Minnesota 55413 and/or Michael Nathan, 620
`
`Wentworth Avenue West, Mendota Heights, Minnesota 55118.
`
`JURISDICTION AND VENUE
`
`5.
`
`This is an action for patent infringement under 35 U.S.C. § 271. This Court
`
`has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331 and 1338(a).
`
`6.
`
`This Court has personal jurisdiction over Defendants because their principal
`
`place of operations is in the State of Minnesota and, according to the turnsignl.com website,
`
`Defendants are currently offering their products in the State of Minnesota.
`
`7.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391(b) and 1400(b)
`
`because Defendants have committed acts of infringement in this District by selling,
`
`offering to sell, and using infringing products within this District.
`
`BACKGROUND
`
`8.
`
`On September 13, 2022, U.S. Patent No. 11,443,395 (the “’395 Patent”),
`
`entitled “Mobile Legal Counsel System and Method,” was duly and legally issued by the
`
`United States Patent and Trademark Office (“USPTO”) to Redmon, as assignee of named
`
`inventors Clayton K. Redmon and Wei Wei Jeang. A true and correct copy of the ’395
`
`Patent is attached as Exhibit 1.
`
`9.
`
`On November 8, 2022, U.S. Patent No. 11,494,861 (the “’861 Patent”),
`
`entitled “Mobile Legal Counsel System and Method,” was duly and legally issued by the
`
`2 
`
`TurnSignl - Exhibit 1038
`Page 2 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 3 of 16
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`USPTO to Redmon, as assignee of named inventors Clayton K. Redmon and Wei Wei
`
`Jeang. A true and correct copy of the ’861 Patent is attached as Exhibit 2.
`
`10. On November 8, 2022, U.S. Patent No. 11,494,862 (the “’862 Patent”),
`
`entitled “Mobile Legal Counsel System and Method,” was duly and legally issued by the
`
`USPTO to Redmon, as assignee of named inventors Clayton K. Redmon and Wei Wei
`
`Jeang. A true and correct copy of the ’862 Patent is attached as Exhibit 3.
`
`11. Redmon is the sole owner of all right, title, and interest in and to the ’395
`
`Patent, the ’861 Patent, and the ’862 Patent (collectively, the “Redmon Patents”) with full
`
`right to bring suit to enforce the Redmon Patents, including the right to recover for past
`
`infringement damages.
`
`12.
`
`The named inventors, Clayton K. Redmon and Wei Wei Jeang, recognized a
`
`need to defuse and de-escalate tense situations between the police and members of the
`
`general public so that the loss of innocent lives can be avoided or reduced.
`
`13.
`
`The Redmon Patents describe and claim a mobile lawyer system or method
`
`for summoning an attorney during a traffic stop, quickly and virtually, whenever a need
`
`arises to help defuse the situation, run interference, and provide legal advice.
`
`14. Redmon is also the assignee and sole owner with exclusive right, title, and
`
`interest in U.S. Patent Application No. 16/892,277 (the “’277 Patent Application”), entitled
`
`“Mobile Legal Counsel System and Method.” The ’277 Patent Application has been
`
`allowed by the United States Patent and Trademark Office and the issue fee has been paid.
`
`A true and correct copy of the ’277 Patent Application Notice of Allowance is attached as
`
`Exhibit 4.
`
`3 
`
`TurnSignl - Exhibit 1038
`Page 3 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 4 of 16
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`15. Defendants operate a website at turnsignl.com that describes on various
`
`webpages a “TurnSignl App” providing “on-demand guidance from an attorney to get you
`
`home safe” that “should be used during a traffic stop.”
`
`16. According to the webpage turnsignl.com, “TurnSignl connects you via live
`
`video chat to expert legal support at the press of a button, and a recording of the encounter
`
`is immediately saved to your personal cloud.” That webpage states that TurnSignl works
`
`by allowing a user to (1) Connect in Real-Time, (2) Start Recording, (3) Video Chat with
`
`Attorney, and (4) Get Home Safe.
`
`17. According to the webpage turnsignl.com/about, the TurnSignl App “is an on-
`
`demand, real-time service that provides 24/7 legal guidance from an attorney to drivers
`
`while their camera records the interaction. When drivers are stopped by law enforcement
`
`officers or involved in a car accident, they can access live video chat with an attorney at
`
`the press of a button or voice command. TurnSignl attorneys are vetted and trained to de-
`
`escalate interactions between police, drivers, and passengers.”
`
`18. According to the webpage turnsignl.com/faq, the TurnSignl App is available
`
`monthly for $6.99/month or annually for $60/year but, through a partnership with
`
`TurnSignl Foundation, is free for those who cannot afford it.
`
`COUNT 1
`
`PATENT INFRINGEMENT OF U.S. PATENT NO. 11,443,395
`
`19.
`
`Plaintiff repeats every allegation of the above paragraphs as though fully set
`
`forth herein.
`
`4 
`
`TurnSignl - Exhibit 1038
`Page 4 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 5 of 16
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`20.
`
`Each claim of the ’395 Patent is valid and enforceable, and each enjoys a
`
`statutory presumption of validity pursuant to 35 U.S.C. § 282.
`
`21. Defendants, without authorization or license, have been and are currently
`
`infringing one or more claims of the ’395 Patent in violation of 35 U.S.C. § 271.
`
`22. Claim 1 is exemplary of the inventions claimed in the ’395 Patent:
`
`1. A mobile lawyer system for use during a traffic stop
`comprising:
`
`a mobile device having at least one video camera configured
`for mounting inside the passenger compartment of a vehicle
`and capture video images of a driver of the vehicle;
`
`the mobile device further incorporating a display screen
`viewable by the driver of the vehicle;
`
`a remote server and a database configured to store information
`about a plurality of lawyers licensed in at least one jurisdiction;
`
`the mobile device executing a mobile application configured,
`upon command from the driver of the vehicle, to communicate
`with the remote server, wherein the remote server is configured
`to automatically determine a
`location of
`the vehicle,
`automatically identify a jurisdiction associated with the vehicle
`location, automatically identify at least one lawyer licensed in
`the identified jurisdiction, and immediately automatically
`directly notify the at least one identified lawyer for assistance;
`and
`
`the display screen of the mobile device configured to live-
`stream a video image of the at least one identified lawyer for
`presentation to the driver of the vehicle, and the at least one
`video camera is configured to automatically live-stream video
`captured by the at least one video camera for viewing by the at
`least one identified lawyer and for storage in the remote
`database, where the at least one mobile device being
`configured to automatically enable bi-directional audio and
`video communication between the at least one identified
`lawyer and the at least one passenger.
`
`5 
`
`TurnSignl - Exhibit 1038
`Page 5 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 6 of 16
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`23. Defendants have directly infringed, literally or under the doctrine of
`
`equivalents, and will continue to directly infringe, at least claim 1 of the ’395 Patent by
`
`making, using, selling, offering to sell, or importing into the United States products or
`
`services that embody or practice the system covered by one or more claims of the ’395
`
`Patent, including Defendants’ TurnSignl mobile application system (collectively referred
`
`to as the “Accused System”).
`
`24.
`
`The Accused System is a mobile lawyer system for use during a traffic stop
`
`that includes a mobile device having a video camera and a display screen. The video camera
`
`is configured to be mounted inside the passenger compartment of a vehicle for capturing
`
`video images of a driver of the vehicle. The display screen is viewable by the driver of the
`
`vehicle.
`
`25.
`
`The Accused System includes a remote server and a database configured to
`
`store information about a plurality of lawyers licensed in at least one jurisdiction.
`
`26.
`
`The Accused System includes a mobile application executed by the mobile
`
`device that is configured, upon command from the driver of the vehicle, to communicate
`
`with the remote server, wherein the remote server is configured to automatically determine
`
`a location of the vehicle, automatically identify a jurisdiction associated with the vehicle
`
`location, automatically identify at least one lawyer licensed in the identified jurisdiction,
`
`and immediately automatically directly notify the at least one identified lawyer for
`
`assistance.
`
`27.
`
`The Accused System includes a mobile device with a display screen
`
`configured to live-stream a video image of at least one identified lawyer for presentation
`
`6 
`
`TurnSignl - Exhibit 1038
`Page 6 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 7 of 16
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`to the driver of the vehicle, and the at least one video camera is configured to automatically
`
`live-stream video captured by the at least one video camera for viewing by the at least one
`
`identified lawyer and for storage in the remote database, where the at least one mobile
`
`device being configured to automatically enable bi-directional audio and video
`
`communication between the at least one identified lawyer and the at least one passenger.
`
`28. Defendants have had knowledge and notice of the ’395 Patent and
`
`Defendants’ infringement of the ’395 Patent, at minimum, as a result of the filing of this
`
`lawsuit.
`
`29. Redmon expressly reserves the right to investigate and allege any actions by
`
`Defendants that render this an exceptional case and any post-filing conduct that constitutes
`
`willful infringement, induced infringement, or contributory infringement by Defendants.
`
`30. Defendants’ acts of infringement have caused and will continue to cause
`
`substantial and irreparable damage to Redmon.
`
`31. As a result of the infringement of the ’395 Patent by Defendants, Redmon
`
`has been damaged.
`
`32. Redmon is entitled to injunctive relief under 35 U.S.C. § 283.
`
`33.
`
`In addition to injunctive relief, Redmon is entitled to recover damages
`
`pursuant to 35 U.S.C. § 284 in an amount adequate to compensate Redmon for the
`
`infringement, but in no event less than a reasonable royalty.
`
`7 
`
`TurnSignl - Exhibit 1038
`Page 7 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 8 of 16
`
`COUNT 2
`
`PATENT INFRINGEMENT OF U.S. PATENT NO. 11,494,861
`
`34.
`
`Plaintiff repeats every allegation of the above paragraphs as though fully set
`
`forth herein.
`
`35.
`
`Each claim of the ’861 Patent is valid and enforceable, and each enjoys a
`
`statutory presumption of validity pursuant to 35 U.S.C. § 282.
`
`36. Defendants, without authorization or license, have been and are currently
`
`infringing one or more claims of the ’861 Patent in violation of 35 U.S.C. § 271.
`
`37. Claim 1 is exemplary of the inventions claimed in the ’861 Patent:
`
`1. A mobile lawyer system for a user subscriber, the system
`comprising:
`
`a remote server and a remote database;
`
`at least one video camera;
`
`at least one display screen;
`
`in
`a mobile device executing a mobile application
`communication with the at least one video camera and the at
`least one display screen, and configured, upon command from
`the user subscriber,
`to automatically and
`immediately
`communicate a current location of the mobile device to the
`remote server, the remote server being configured to:
`
`automatically search a plurality of information records
`associated with a plurality of lawyers stored in the remote
`database;
`
`automatically identify at least one lawyer licensed in a
`jurisdiction that correspond to the current location of the
`mobile device;
`
`8 
`
`TurnSignl - Exhibit 1038
`Page 8 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 9 of 16
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`automatically transmit at least one notification to at least one
`computing device associated with the identified at least one
`lawyer;
`
`receive an acceptance of legal representation engagement from
`the computing device associated with the at least one lawyer;
`and
`
`automatically and immediately set up a video communication
`session between the computing device associated with the at
`least one lawyer and the mobile device, so that live video data
`of the user subscriber is automatically transmitted to the
`computing device associated with the at least one lawyer and
`live video data of the at least one lawyer is automatically
`transmitted to the display screen; and
`
`during the video communication session, the at least one
`display screen being configured to stream live video data of the
`at least one lawyer, and the at least one video camera being
`configured to capture and live-stream video of the user
`subscriber and surroundings to the computing device for
`viewing by the at least one lawyer and for storage in the remote
`database.
`
`38. Defendants have directly infringed, literally or under the doctrine of
`
`equivalents, and will continue to directly infringe, at least claim 1 of the ’861 Patent by
`
`making, using, selling, offering to sell, or importing into the United States products or
`
`services that embody or practice the system covered by one or more claims of the ’861
`
`Patent, including the Accused System.
`
`39.
`
`The Accused System is a mobile lawyer system for a user subscriber that
`
`includes a remote server and a remote database, at least one video camera, and at least one
`
`display screen.
`
`40.
`
`The Accused System includes a mobile application executed by a mobile
`
`device that is in communication with the video camera and the display screen, and that is
`
`9 
`
`TurnSignl - Exhibit 1038
`Page 9 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 10 of 16
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`configured, upon command from the user subscriber, to automatically and immediately
`
`communicate a current location of the mobile device to the remote server.
`
`41.
`
`The remote server of the Accused System is configured to automatically
`
`search a plurality of information records associated with a plurality of lawyers stored in the
`
`remote database; automatically identify at least one lawyer licensed in a jurisdiction that
`
`corresponds to the current location of the mobile device; automatically transmit at least one
`
`notification to at least one computing device associated with the identified at least one
`
`lawyer; receive an acceptance of legal representation engagement from the computing
`
`device associated with the at least one lawyer; and automatically and immediately set up a
`
`video communication session between the computing device associated with the at least
`
`one lawyer and the mobile device, so that live video data of the user subscriber is
`
`automatically transmitted to the computing device associated with the at least one lawyer
`
`and live video data of the at least one lawyer is automatically transmitted to the display
`
`screen.
`
`42. During the video communication session, the display screen of the Accused
`
`System is configured to stream live video data of the lawyer, and the video camera of the
`
`Accused System is configured to capture and live-stream video of the user subscriber and
`
`surroundings to the computing device for viewing by the lawyer and for storage in the
`
`remote database.
`
`43. Defendants have had knowledge and notice of the ’861 Patent and
`
`Defendants’ infringement of the ’861 Patent, at minimum, as a result of the filing of this
`
`lawsuit.
`
`10 
`
`TurnSignl - Exhibit 1038
`Page 10 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 11 of 16
`
`44. Redmon expressly reserves the right to investigate and allege any actions by
`
`Defendants that render this an exceptional case and any post-filing conduct that constitutes
`
`willful infringement, induced infringement, or contributory infringement by Defendants.
`
`45. Defendants’ acts of infringement have caused and will continue to cause
`
`substantial and irreparable damage to Redmon.
`
`46. As a result of the infringement of the ’861 Patent by Defendants, Redmon
`
`has been damaged.
`
`47. Redmon is entitled to injunctive relief under 35 U.S.C. § 283.
`
`48.
`
`In addition to injunctive relief, Redmon is entitled to recover damages
`
`pursuant to 35 U.S.C. § 284 in an amount adequate to compensate Redmon for the
`
`infringement, but in no event less than a reasonable royalty.
`
`COUNT 3
`
`PATENT INFRINGEMENT OF U.S. PATENT NO. 11,494,862
`
`49.
`
`Plaintiff repeats every allegation of the above paragraphs as though fully set
`
`forth herein.
`
`50.
`
`Each claim of the ’862 Patent is valid and enforceable, and each enjoys a
`
`statutory presumption of validity pursuant to 35 U.S.C. § 282.
`
`51. Defendants, without authorization or license, have been and are currently
`
`infringing one or more claims of the ’862 Patent in violation of 35 U.S.C. § 271.
`
`52. Claim 1 is exemplary of the inventions claimed in the ’862 Patent:
`
`1. A mobile lawyer system, the system comprising:
`
`a remote server and a remote database;
`
`11 
`
`TurnSignl - Exhibit 1038
`Page 11 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 12 of 16
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`at least one video camera;
`
`at least one display screen;
`
`in
`a mobile device executing a mobile application
`communication with the at least one video camera and the at
`least one display screen, and configured, upon a one-click
`command from a user of the mobile device, to automatically
`and immediately communicate a current location of the mobile
`device to the remote server, the remote server being configured
`to:
`
`automatically search a plurality of information records
`associated with a plurality of lawyers stored in the remote
`database;
`
`automatically identify at least one lawyer licensed in a
`jurisdiction that correspond to the current location of the
`mobile device;
`
`automatically transmit at least one notification to at least one
`computing device associated with the identified at least one
`lawyer;
`
`receive an acceptance of engagement from a selected one of
`the at least one computing device associated with a selected
`one of the identified at least one lawyer; and
`
`automatically and immediately set up a bi-directional video
`communication session between the selected one of the at least
`one computing device associated with the selected one of the
`at least one lawyer and the mobile device, so that live video
`data of the user is automatically transmitted to the selected
`computing device associated with the selected lawyer and live
`video data of the selected lawyer is automatically transmitted
`to the at least one display screen;
`
`automatically and immediately enable the at least one display
`screen to stream live video data of the selected lawyer, and the
`at least one video camera capture and stream live video of the
`user and surroundings to the computing device for viewing by
`the selected lawyer; and
`
`automatically and immediately enable live video data from the
`mobile device and the selected computing device to be
`
`12 
`
`TurnSignl - Exhibit 1038
`Page 12 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 13 of 16
`
`transmitted to the remote server and database for secure
`storage.
`
`53. Defendants have directly infringed, literally or under the doctrine of
`
`equivalents, and will continue to directly infringe, at least claim 1 of the ’862 Patent by
`
`making, using, selling, offering to sell, or importing into the United States products or
`
`services that embody or practice the system covered by one or more claims of the ’395
`
`Patent, including the Accused System.
`
`54.
`
`The Accused System is a mobile lawyer system that includes a remote server
`
`and a remote database, at least one video camera, and at least one display screen.
`
`55.
`
`The Accused System includes a mobile application executed by a mobile
`
`device that is in communication with the video camera and the display screen, and that is
`
`configured, upon a one-click command from a user of the mobile device, to automatically
`
`and immediately communicate a current location of the mobile device to the remote server.
`
`56.
`
`The remote server of the Accused System is configured to automatically
`
`search a plurality of information records associated with a plurality of lawyers stored in the
`
`remote database; automatically identify at least one lawyer licensed in a jurisdiction that
`
`corresponds to the current location of the mobile device; automatically transmit at least one
`
`notification to at least one computing device associated with the identified lawyer; receive
`
`an acceptance of engagement from a selected one of the computing device associated with
`
`a selected one of the identified lawyer; and automatically and immediately set up a bi-
`
`directional video communication session between the selected computing device
`
`associated with the selected lawyer and the mobile device, so that live video data of the
`
`13 
`
`TurnSignl - Exhibit 1038
`Page 13 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 14 of 16
`
`user is automatically transmitted to the selected computing device associated with the
`
`selected lawyer and live video data of the selected lawyer is automatically transmitted to
`
`the display screen.
`
`57.
`
`The Accused System automatically and immediately enables the display
`
`screen to stream live video data of the selected lawyer, and the video camera captures and
`
`streams live video of the user and surroundings to the computing device for viewing by the
`
`selected lawyer; and automatically and immediately enables live video data from the
`
`mobile device and the selected computing device to be transmitted to the remote server and
`
`database for secure storage.
`
`58. Defendants have had knowledge and notice of the ’862 Patent and
`
`Defendants’ infringement of the ’862 Patent, at minimum, as a result of the filing of this
`
`lawsuit.
`
`59. Redmon expressly reserves the right to investigate and allege any actions by
`
`Defendants that render this an exceptional case and any post-filing conduct that constitutes
`
`willful infringement, induced infringement, or contributory infringement by Defendants.
`
`60. Defendants’ acts of infringement have caused and will continue to cause
`
`substantial and irreparable damage to Redmon.
`
`61. As a result of the infringement of the ’862 Patent by Defendants, Redmon
`
`has been damaged.
`
`62. Redmon is entitled to injunctive relief under 35 U.S.C. § 283.
`
`14 
`
`TurnSignl - Exhibit 1038
`Page 14 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 15 of 16
`
`63.
`
`In addition to injunctive relief, Redmon is entitled to recover damages
`
`pursuant to 35 U.S.C. § 284 in an amount adequate to compensate Redmon for the
`
`infringement, but in no event less than a reasonable royalty.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff prays for entry of judgment against Defendants as
`
`follows:
`
`A.
`
`A judgment that Defendants have infringed and continue to infringe the ’395
`
`Patent, the ’861 Patent, and the ’862 Patent;
`
`B.
`
`That Defendants provide to Redmon an accounting of all gains, profits, and
`
`advantages derived by Defendants’ infringement of the ’395 Patent, the ’861 Patent, and
`
`the ’862 Patent; and that Redmon be awarded damages adequate to compensate it for the
`
`wrongful infringement by Defendants in accordance with 35 U.S.C. § 284;
`
`C.
`
`That Redmon be awarded any other supplemental damages and interest on
`
`all damages and costs of court;
`
`D.
`
`That the Court permanently enjoin Defendants and all those in privity with
`
`Defendants from making, having made, selling, offering for sale, distributing, or using
`
`products that infringe the ’395 Patent, the ’861 Patent, and the ’862 Patent, including the
`
`Accused System, in the United States; and
`
`E.
`
`That Redmon be awarded such other and further relief and all remedies
`
`available at law.
`
`15 
`
`TurnSignl - Exhibit 1038
`Page 15 of 58
`
`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8 Filed 11/14/22 Page 16 of 16
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff demands a
`
`trial by jury on all questions of fact.
`
`
`Date: November 14, 2022
`
`
`
`
`
`
`
`FOX ROTHSCHILD LLP
`
`
`
`By: s/Elizabeth A. Patton
`
`Elizabeth A. Patton (#391431)
`
`
`222 South Ninth Street, Suite 2000
`Minneapolis, MN 55402
`Telephone: 612-607-7000
`epatton@foxrothschild.com
`
`Amy E. LaValle (pro hac vice)
`MUNCK WILSON MANDALA, LLP
`12770 Coit Road, Suite 600
`Dallas, TX 75251
`Telephone: 972-628-3600
`alavalle@munckwilson.com
`
`ATTORNEYS FOR PLAINTIFF
`REDMON JEANG LLC
`
`16 
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`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 1 of 8
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`Exhibit 1
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`TurnSignl - Exhibit 1038
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`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 2 of 8
`I 1111111111111111 1111111111 111111111111111 IIIII IIIII IIIII lll111111111111111
`USOl 1443395B2
`
`02) United States Patent
`Redmon et al.
`
`(IO) Patent No.: US 11,443,395 B2
`Sep.13,2022
`(45) Date of Patent:
`
`(54) MOBILE LEGAL COUNSEL SYSTEM AND
`METHOD
`
`(71) Applicant: Redmon Jeang LLC, Parker, TX (US)
`
`(72)
`
`Inventors: Clayton K. Redmon, Grand Prairie,
`TX (US) ; Wei Wei Jeang, Parker, TX
`(US)
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`6/2006 8ulriss
`7,061,521 82
`9,288,446 82 * 3/2016 Mokashi
`(Continued)
`
`H04N 7/ 18
`
`FOREIGN PATENT DOCUMENTS
`
`205071154
`2015052896 Al
`
`* 3/2016
`4/2015
`
`OTHER PUBLICAfIONS
`
`International Search Report and Written Opinion received in Patent
`Cooperation Treaty Application No. PCT/US2017/042838, dated
`Nov. 8, 2017, 11 pages.
`
`Primary Examiner - Phung-Hoang J Nguyen
`(74) Attorney, Agent, or Firm - Wei Wei Jeang; Grable
`Martin Fulton PLLC
`
`ABSTRACT
`(57)
`A Mobile Lawyer system includes a 360 degree HD video
`camera configured for mounting inside the passenger com(cid:173)
`partment of a vehicle; a display screen configured for
`mounting inside the passenger compartment of a vehicle;
`and a Mobile Lawyer App downloaded and installed on a
`mobile telephone in communication with the video camera
`and display screen, configured, upon command from a user,
`to notify an attorney located remotely via a cellular and/or
`computer network, and to display a video image of the
`remote attorney on the display screen ( or the screen of the
`mobile telephone), and to live-stream a 360 degree video
`captured by the video camera to the Internet for viewing by
`the remote attorney and for cloud storage. The introduction
`of a lawyer on-demand into a police encounter can help to
`defuse and de-escalate the situation. The lawyer can serve as
`a live observer, witness, and intermediary who can provide
`live legal guidance to the user.
`
`8 Claims, 2 Drawing Sheets
`
`( *) Notice:
`
`Subject to any disclaimer, the term ofthis
`patent is extended or adjusted under 35
`U.S.C. 154(b) by O days.
`
`CN
`WO
`
`(21) Appl. No.: 15/644,524
`
`(22) Filed:
`
`Jul. 7, 2017
`
`(65)
`
`Prior Publication Data
`
`US 2018/0025453 Al
`
`Jan. 25, 2018
`
`Related U.S. Application Data
`
`(60)
`
`Provisional application No. 62/364,300, filed on Jul.
`19, 2016.
`
`(51)
`
`(52)
`
`Int. Cl.
`G06Q 50118
`H04N 7115
`H04W4/40
`H04L 65/1069
`H04L 67/12
`
`(2012.01)
`(2006.01)
`(2018.01)
`(2022.01)
`(2022.01)
`(Continued)
`
`U.S. Cl.
`CPC ........... G06Q 50/18 (2013.01); B64C 39/024
`(2013.01); B64D 47/08 (2013.01); G06F
`3/04842 (2013 .01 ); H04L 65/1069 (2013.01);
`H04L 67112 (2013.01); H04N 71147
`(2013.01); H04N 71155 (2013.01); H04W 4/40
`(2018.02);
`
`(58)
`
`(Continued)
`Field of Classification Search
`CPC combination set(s) only.
`See application file for complete search history.
`
`REn •;,c,;srn
`REC,Ji:IT
`
`., 30
`
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`M
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`~~:11, 1 1.J\Wf~"-•.~)
`
`~ r . .EC~Ll',~~ 1;5-~k ~ ,6
`RE,li.;mro
`
`9/29/2022 11:43:33
`
`Page 1 of 7
`
`TurnSignl - Exhibit 1038
`Page 18 of 58
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`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 3 of 8
`
`US 11,443,395 B2
`Page 2
`
`2005/0128283 Al*
`
`6/2005 Bulriss
`
`2011 /0119197 Al*
`
`5/20 ll Turchin
`
`2012/0204029 Al*
`
`8/2012 Trabucco
`
`.... H04N7/ l47
`348/ 14.l
`.... G06Q 10/ 10
`705/311
`.... H04N7/147
`713/168
`......... G06Q 50/18
`705/311
`....... G06K 9/00832
`348/ 148
`2015/0371456 Al* 12/2015 Moore, Jr ......... ..... G07C 5/008
`701/1
`. ........... G06F 17/30477
`707/769
`6/2016 Hassan Zureikat .. H04N 5/2252
`348/144
`8/2016 Oami .... ........... . G06K 9/00832
`l/2018 Kelts .
`. ..... G06Q 30/018
`...... G06Q 10/ 10
`l/2018 Thorpe
`
`(51)
`
`Int. CI.
`B64C 39/02
`B64D 47/08
`G06F 3/04842
`H04N 7114
`H04L 67102
`H04L 67152
`(52) U.S. Cl.
`CPC .. B64C 2201/122 (2013.01); B64C 2201/127
`(2013.01); H04L 67/02 (2013.01); H04L 67118
`(2013.01)
`
`(2006.01)
`(2006.01)
`(2022.01)
`(2006.01)
`(2022.01)
`(2022.01)
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`
`2002/0002469 Al *
`
`l/2002 Hillstrom ....... ....... G06Q 10/10
`705/ l.l
`
`2014/0214702 Al*
`
`7/2014 Becker
`
`2015/0015706 Al*
`
`l/2015 Hatori
`
`2016/0140179 Al*
`
`5/2016 Yuen .
`
`2016/0173742 Al*
`
`2016/0239714 Al*
`2018/0012324 Al*
`2018/0018831 Al*
`* cited by examiner
`
`9/29/2022 11:43:33
`
`Page 2 of 7
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`TurnSignl - Exhibit 1038
`Page 19 of 58
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`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 4 of 8
`
`U.S. Patent
`
`Sep.13,2022
`
`Sheet 1 of 2
`
`US 11,443,395 B2
`
`_______ , , ,
`
`28
`.... / /
`
`,
`
`,
`
`.,,.@::::·
`
`10
`{
`
`12
`
`= = ~
`
`18
`/ /
`
`0
`
`~
`26
`
`FIG. 1
`
`9/29/2022 11:43:33
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`Page 3 of 7
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`TurnSignl - Exhibit 1038
`Page 20 of 58
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`

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`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 5 of 8
`
`U.S. Patent
`
`Sep.13,2022
`
`Sheet 2 of 2
`
`US 11,443,395 B2
`
`SER RECEIVE U
`
`REQUES T
`
`30
`
`/ /
`I,/
`
`l
`
`EXECUTE
`MOBILE LAWY ER APP
`
`v·/
`
`32
`
`STARTVID
`EO
`
`LIVE-STRE AM
`
`34
`
`/ /
`
`36
`
`/
`
`/
`
`STORE VIDEO DATA
`
`- USER
`DETERMINE
`
`JURISDICT ION
`
`/
`v/
`
`38
`
`
`IDENTIFY SU !TABLE
`LAWYER
`(S)
`
`40
`
`/
`/ /
`
`_F'/G.
`
`2
`
`SEND ALERT
`TO LAWYER{S)
`
`42
`
`__,../
`
`1,
`
`RECEIVE REPLY
`FROM LAWYER{S)
`
`44
`
`_/..,
`
`46
`
`SELECT ONE LAWYER
`
`, ..
`LIVE-STREAM
`VIDEO DATA
`TO LAWYER
`
`48
`
`/
`
`'
`DISPLAY LAWYER
`IMAGE & NAME
`ON MONITOR
`
`50
`
`/
`
`•
`
`ENABLE LAWYER
`AUDIO
`
`/
`
`,.
`
`CONTINUE VIDEO
`LIVE-STREAM
`
`V
`
`52
`
`54
`
`,,
`RECEIVE USER
`REQUEST TO
`END SESSION
`
`56
`
`V
`
`9/29/2022 11:43:33
`
`Page 4 of 7
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`TurnSignl - Exhibit 1038
`Page 21 of 58
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`

`

`CASE 0:22-cv-02749-JWB-LIB Doc. 8-1 Filed 11/14/22 Page 6 of 8
`
`US 11,443,395 B2
`
`1
`MOBILE LEGAL COUNSEL SYSTEM AND
`METHOD
`
`RELATED APPLICATION
`
`This disclosure claims the benefit of U.S. Provisional
`Patent Application No. 62/364,300 filed on Jul. 19, 2016,
`which is hereby incorporated by reference in its entirety.
`
`FIELD
`
`This disclosure relates to mobile software applications,
`and more particularly to a mobile legal counsel system and
`method, so that an attorney c