IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`UNM RAINFOREST INNOVATIONS,
`
`
`
`
`
`Plaintiff,
`Civil Action No. 1:23-cv-00424
`
`
`
`
`v.
`
`
`JURY TRIAL DEMANDED
`TOYOTA MOTOR NORTH AMERICA,
`INC., TOYOTA MOTOR SALES, U.S.A.,
`INC., and TOYOTA MOTOR
`ENGINEERING & MANUFACTURING
`NORTH AMERICA, INC.
`
`
`Defendants
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`UNM Rainforest Innovations (“UNMRI”) files this Original Complaint for Patent
`
`Infringement and Jury Demand against Toyota Motor North America, Inc., Toyota Motor
`
`Sales, U.S.A., Inc., and Toyota Motor Engineering & Manufacturing North America, Inc.
`
`(collectively, “Toyota”). UNMRI alleges
`
`infringement of United States Patent
`
`Number 8,265,096 (“’096 Patent”) as follows.
`
`PRELIMINARY STATEMENT
`
`1.
`
`The University of New Mexico (“UNM”) is a public educational institution
`
`based in Albuquerque, New Mexico, and serves as the State of New Mexico’s flagship
`
`research institution. UNM serves over 25,000 students and comprises over 1,700 faculty
`
`members across its main campus in Albuquerque and branch campuses in Gallup, Los
`
`Alamos, Rio Rancho, Taos, and Los Lunas, New Mexico. Over the past 20 years, UNM
`
`researchers have disclosed over 1,700 new inventions resulting in over 500 issued United
`
`States patents. This action is for patent infringement and just compensation for unlicensed
`
`1
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 1 of 13
`
`
`FOR THE EASTERN DISTRICT OF TEXAS
`UNM RAINFOREST INNOVATIONS,
`
`
`
`
`
`Plaintiff,
`Civil Action No. 1:23-cv-00424
`
`
`
`
`v.
`
`
`JURY TRIAL DEMANDED
`TOYOTA MOTOR NORTH AMERICA,
`INC., TOYOTA MOTOR SALES, U.S.A.,
`INC., and TOYOTA MOTOR
`ENGINEERING & MANUFACTURING
`NORTH AMERICA, INC.
`
`
`Defendants
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`UNM Rainforest Innovations (“UNMRI”) files this Original Complaint for Patent
`
`Infringement and Jury Demand against Toyota Motor North America, Inc., Toyota Motor
`
`Sales, U.S.A., Inc., and Toyota Motor Engineering & Manufacturing North America, Inc.
`
`(collectively, “Toyota”). UNMRI alleges
`
`infringement of United States Patent
`
`Number 8,265,096 (“’096 Patent”) as follows.
`
`PRELIMINARY STATEMENT
`
`1.
`
`The University of New Mexico (“UNM”) is a public educational institution
`
`based in Albuquerque, New Mexico, and serves as the State of New Mexico’s flagship
`
`research institution. UNM serves over 25,000 students and comprises over 1,700 faculty
`
`members across its main campus in Albuquerque and branch campuses in Gallup, Los
`
`Alamos, Rio Rancho, Taos, and Los Lunas, New Mexico. Over the past 20 years, UNM
`
`researchers have disclosed over 1,700 new inventions resulting in over 500 issued United
`
`States patents. This action is for patent infringement and just compensation for unlicensed
`
`1
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 1 of 13
`
`
`
`deployment of in-vehicle Wi-Fi configured to operate on and with the IEEE 802.11ac or
`
`IEEE 802.11ax wireless networking standard(s) in violation of the ’096 Patent.
`
`THE PARTIES
`
`2.
`
`Plaintiff UNMRI is a New Mexico nonprofit research park corporation
`
`formed, owned, and controlled entirely by the Board of Regents of the University of New
`
`Mexico (“UNM”).
`
`3.
`
`UNMRI’s mission includes nurturing inventions researched and developed
`
`at UNM, promoting technological collaboration between UNM and other universities and
`
`research institutes, and thereby catalyzing economic development in the State of New
`
`Mexico.
`
`4.
`
`UNMRI furthers its mission by licensing and, if necessary, enforcing its
`
`inventions and reinvesting proceeds into continued research and development at and
`
`technological collaboration with UNM, for the benefit of and for the State of New Mexico
`
`and the United States.
`
`5.
`
`UNMRI is located at the UNM Lobo Rainforest Building, 101 Broadway
`
`Boulevard, Suite 1100, Albuquerque, New Mexico 87102.
`
`6.
`
`Plaintiff UNMRI, UNM, and the Board of Regents of UNM are arms of the
`
`State of New Mexico and enjoy sovereign immunity under common law, statutes, and
`
`constitutions of the United States and the State of New Mexico including, but not limited
`
`to, the Eleventh Amendment of the United States Constitution and Article 12 of the New
`
`Mexico Constitution. See Regents of University of New Mexico v. Knight, 321 F.3d 1111
`
`2
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 2 of 13
`
`
`
`(Fed. Cir. 2003); STC.UNM v. Quest Diagnostics Inc., CIV 17-1123 MV/KBM, 2019 WL
`
`1091390, at *1 (D.N.M. Mar. 8, 2019).
`
`7.
`
`By filing this lawsuit or prosecuting this action, Plaintiff UNMRI does not
`
`waive, either expressly or implicitly, its sovereign immunity, the sovereign immunity of
`
`UNM or its Board of Regents, or the sovereign immunity enjoyed by any arm of the State
`
`of New Mexico under the laws of the United States or the State of New Mexico, to any
`
`inter partes review, ex parte reexamination, or other post-grant proceeding at the United
`
`States Patent and Trademark Office or its Patent Trial and Appeal Board, to any other
`
`administrative actions or proceedings whatsoever, to any noncompulsory counterclaims,
`
`or to any other federal or state proceedings whatsoever, whether initiated by Defendants or
`
`an entity other than Defendants.
`
`8.
`
`Toyota Motor Corporation is an automobile manufacturer incorporated under
`
`the Commercial Code of Japan and existing under its Companies Act. Toyota Motor
`
`Corporation operated through 569 consolidated subsidiaries and 168 associates and joint
`
`ventures as of March 31, 2023, and its principal executive offices are located at 1 Toyota-
`
`cho, Toyota City, Aichi Prefecture 471-8571, Japan.
`
`9.
`
`Defendant Toyota Motor North America, Inc. is a corporation with its
`
`principal place of business at 6565 Headquarters Drive, Plano, Texas 75024. Toyota Motor
`
`North America, Inc. brings together Toyota Motor Corporation’s marketing, sales,
`
`engineering, and manufacturing arms in North America on one shared campus. Toyota
`
`Motor North America, Inc. can be served with process through its registered agent, C T
`
`Corporation System, at 1999 Bryan Street, Suite 900 Dallas, Texas 75201.
`
`3
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 3 of 13
`
`
`
`10. Defendant Toyota Motor Sales, U.S.A., Inc. is a corporation with a place of
`
`business located at 6565 Headquarters Drive, Plano, Texas 75024. Toyota Motor Sales,
`
`U.S.A., Inc., can be served with process through its registered agent, C T Corporation
`
`System, at 1999 Bryan Street, Suite 900 Dallas, Texas 75201.
`
`11. Defendant Toyota Motor Engineering & Manufacturing North America, Inc.
`
`is a corporation with a place of business located at 6565 Headquarters Drive, Plano, Texas
`
`75024. Toyota Motor Engineering & Manufacturing North America, Inc. can be served
`
`with process through its registered agent, C T Corporation System, at 1999 Bryan Street,
`
`Suite 900 Dallas, Texas 75201.
`
`12.
`
`Toyota is in the business of making, using, marketing, distributing, selling,
`
`and encouraging the sale and use of, both in the United States and abroad, automobiles
`
`with built-in Wi-Fi hotspot/access points and other systems and features which are
`
`configured to operate on or with the IEEE 802.11ac or IEEE 802.11ax wireless networking
`
`standard(s), including at least the following automobiles: 2022 Toyota Tundra, 2022
`
`Toyota Tundra Hybrid, 2023 Toyota bZ4X, 2023 Toyota Corolla, 2023 Toyota Corolla
`
`Hybrid, 2023 Toyota Corolla Cross, 2023 Toyota Corolla Cross Hybrid, 2023 Toyota
`
`Corolla Hatchback, 2023 Toyota Highlander, 2023 Toyota Highlander Hybrid, 2023
`
`Toyota Mirai, 2023 Toyota Prius, 2023 Toyota Prius Prime, 2023 Toyota RAV4, 2023
`
`Toyota RAV4 Hybrid, 2023 Toyota RAV4 Prime, 2023 Toyota Sequoia Hybrid, 2023
`
`Toyota Crown, 2023 Toyota Tundra, 2023 Toyota Tundra Hybrid, 2023 Toyota Venza
`
`Hybrid, 2024 Toyota Corolla, 2024 Toyota Corolla Hybrid, 2024 Toyota Corolla
`
`4
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 4 of 13
`
`
`
`Hatchback, 2024 Toyota Grand Highlander, 2024 Toyota Grand Highlander Hybrid, 2024
`
`Toyota Tundra, and 2024 Toyota Tundra Hybrid.
`
`13. On information and belief, on consolidated basis, Toyota Motor Corporation
`
`recorded unit sales of about eight million eight hundred twenty-two thousand (8,822,000)
`
`automobiles during the 12-month period ending on March 31, 2023, of which at least 30%
`
`occurred in the United States. On information and belief, Toyota made or recorded unit
`
`sales in excess of two million (2,000,000) automobiles in the United States during the 12-
`
`month period ending on March 31, 2023.
`
`JURISDICTION
`
`14.
`
`This action arises under the Patent Laws of the United States, 35 U.S.C. § 1,
`
`et seq., including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This is a patent infringement
`
`lawsuit over which this Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`15.
`
`This United States District Court for the Eastern District of Texas has general
`
`and specific personal jurisdiction over Defendants because Defendants are present in and
`
`transact and conduct business in and with residents of this District and the State of Texas.
`
`16. UNMRI’s causes of action arise, at least in part, from Defendants’ contacts
`
`with and activities in this District and the State of Texas.
`
`17.
`
`Toyota has committed acts of infringing the ’096 Patent within this District
`
`and the State of Texas by making, using, selling, offering for sale, and/or importing in or
`
`into this District and elsewhere in the State of Texas products made by practicing the
`
`claimed method of the ’096 Patent. Toyota, directly and through intermediaries, makes,
`
`5
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 5 of 13
`
`
`
`uses, sells, offers for sale, ships, distributes, advertises, promotes, and/or otherwise
`
`commercializes such infringing products in this District and the State of Texas. Toyota
`
`regularly conducts and solicits business in, engages in other persistent courses of conduct
`
`in, and derives substantial revenue from goods and services provided to residents of this
`
`District and the State of Texas.
`
`VENUE
`
`18. Venue is proper for Toyota in this District because venue in a patent
`
`infringement action against a foreign defendant is proper in any judicial district and
`
`because Toyota maintains a regular and established place of business in this District located
`
`at 6565 Headquarters Drive, Plano, TX 75024. TC Heartland LLC v. Kraft Foods Grp.
`
`Brands LLC, 137 S. Ct. 1514, 1520 n.2 (2017) (citing Brunette Mach. Works, Ltd. v.
`
`Kochum Indus., Inc., 406 U.S. 706, 711–714 (1972)).
`
`19. UNMRI does not waive its sovereign immunity as to any venue, including
`
`district courts and administrative tribunals, other than this Court, namely the United States
`
`District Court for the Eastern District of Texas.
`
`UNITED STATES PATENT NUMBER 8,265,096
`
`20. United States Patent Number 8,265,096 (“’096 Patent”) is titled “Method for
`
`Constructing Frame Structures.” The ’096 Patent issued on September 11, 2012, from
`
`United States Patent Application Number 12/168,855, which was filed on July 7, 2008, and
`
`claims priority to United States Provisional Patent Application Number 60/929,798, which
`
`was filed on July 12, 2007, and United States Provisional Patent Application Number
`
`6
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 6 of 13
`
`
`
`60/973,157, which was filed on September 17, 2007. A true and correct copy of the ’096
`
`Patent is attached as Exhibit A1.
`
`21.
`
`The ’096 Patent claims patent-eligible subject matter and is valid and
`
`enforceable. Claim 8 of the ’096 Patent is an independent claim and recites:
`
`A method of constructing a frame structure for data
`transmission, the method comprising:
`generating a first section comprising data configured in a first
`format compatible with a first communication system using
`symbols;
`generating a second section following the first section, the
`second section comprising data configured in a second format
`compatible with a second communication system using
`symbols, wherein the first communication system’s symbols
`and the second communication system's symbols co-exist in
`one transmission scheme and wherein the second
`communication system has pilot symbols that are denser than
`those in the first communication system;
`generating at least one non-data section containing
`information describing an aspect of data in at least one of the
`first section and the second section; and
`combining the first section, the second section and the at least
`one non-data section to form the frame structure.
`
`22.
`
`The ’096 Patent’s named inventors are Yan-Xiu Zheng, Ren-Jr Chen, Chang-
`
`Lung Hsiao, and Pang-An Ting.
`
`23.
`
`The ’096 Patent’s original patentee was Industrial Technology Research
`
`Institute (“ITRI”), which acquired exclusive ownership of the patented invention by written
`
`assignments from Yan-Xiu Zheng, Ren-Jr Chen, Chang-Lung Hsiao, and Pang-An Ting,
`
`recorded in the United States Patent and Trademark Office (“USPTO”) on or about April
`
`16, 2009.
`
`7
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 7 of 13
`
`
`
`24.
`
`Thereafter, ITRI conveyed to Sino Matrix Technology, Inc. (“SMT”) all
`
`rights, title, and interest in and to the ’096 Patent, including the right to sue and recover for
`
`past infringements, by written assignment recorded in the USPTO on or about March 14,
`
`2018.
`
`25.
`
`Thereafter, SMT conveyed to Plaintiff all rights, title, and interest in and to
`
`the ’096 Patent, including the right to sue and recover for past infringements, by written
`
`assignment recorded in the USPTO on or about September 11, 2018.
`
`26. On information and belief, Toyota is not licensed to the ’096 Patent, either
`
`expressly or implicitly. Before filing suit, UNMRI notified Toyota of the ’096 Patent and
`
`its applicability to technology capable of operation on or with the IEEE 802.11ac wireless
`
`networking standard. Despite months to do so, Toyota failed to provide any evidence of
`
`use of only licensed parts.
`
`THE ACCUSED INSTRUMENTALITIES
`
`27.
`
`Toyota designs, manufactures, imports, uses, sells, offers for sale, markets,
`
`and distributes products and processes, including automobiles with built-in Wi-Fi
`
`hotspot/access points and other systems and features, which are configured to operate on
`
`or with the IEEE 802.11ac or IEEE 802.11ax wireless networking standard(s).
`
`28.
`
`Toyota’s “Accused Instrumentalities” include all products and processes
`
`configured to operate on or with the IEEE 802.11ac or IEEE 802.11ax wireless networking
`
`standard(s) (referred to in this complaint as “Wi-Fi 5/6 Networks”).
`
`29.
`
`The Accused Instrumentalities include, but are not necessarily limited to, the
`
`following products: 2022 Toyota Tundra, 2022 Toyota Tundra Hybrid, 2023 Toyota bZ4X,
`
`8
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 8 of 13
`
`
`
`2023 Toyota Corolla, 2023 Toyota Corolla Hybrid, 2023 Toyota Corolla Cross, 2023
`
`Toyota Corolla Cross Hybrid, 2023 Toyota Corolla Hatchback, 2023 Toyota Highlander,
`
`2023 Toyota Highlander Hybrid, 2023 Toyota Mirai, 2023 Toyota Prius, 2023 Toyota Prius
`
`Prime, 2023 Toyota RAV4, 2023 Toyota RAV4 Hybrid, 2023 Toyota RAV4 Prime, 2023
`
`Toyota Sequoia Hybrid, 2023 Toyota Crown, 2023 Toyota Tundra, 2023 Toyota Tundra
`
`Hybrid, 2023 Toyota Venza Hybrid, 2024 Toyota Corolla, 2024 Toyota Corolla Hybrid,
`
`2024 Toyota Corolla Hatchback, 2024 Toyota Grand Highlander, 2024 Toyota Grand
`
`Highlander Hybrid, 2024 Toyota Tundra, and 2024 Toyota Tundra Hybrid; and any other
`
`automobile configured to operate on or with a Wi-Fi 5/6 Network—regardless of make
`
`(e.g., Toyota, Lexus), model year (e.g., 2017–2029), or model (e.g., 4Runner, Avalon,
`
`Avalon Hybrid, bZ4X, C-HR, Camry, Camry Hybrid, Corolla, Corolla Cross, Corolla
`
`Hatchback, Corolla Hybrid, Grand Highlander, Highlander, Hilander Hybrid, Mirai, Prius,
`
`Prius Prime, RAV4, RAV4 Hybrid, RAV4 Prime, Sequoia, Sienna, Sienna Hybrid,
`
`Tacoma, Toyota Crown, Tundra, Tundra Hybrid, Venza, ES 250, ES 300H, ES 350, GX
`
`460, IS 300, IS 350, IS 500, LC 500, LC 500C, LC 500H, LS 500, LS 500 AWD, LS 500
`
`AWD F Sport, LS 500 F Sport, LS 500 RWD, LS 500H, LX 600, NX 250, NX 300, NX
`
`300H, NX 350, NX 350H, NX 450H+, RC 350, RC F, RX 350, RX 350H, RX 350L, RX
`
`450H, RX 450H+, RX 450HL, RX 500H, RZ450E, TX 350, TX 550H, TX 550H+, UX
`
`200, UX 250H).
`
`9
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 9 of 13
`
`
`
`DIRECT, INDUCED, AND CONTRIBUTORY INFRINGEMENT OF
`THE ’096 PATENT
`
`30.
`
`Toyota’s Accused Instrumentalities capable of operation on or with a
`
`Wi-Fi 5/6 Network employ the patented frame structure for data transmission in which
`
`legacy communication format and very high throughput communication format are
`
`combined into a unitary frame structure. Exhibit A2 is an exemplary chart illustrating this
`
`and how at least one claim of the ’096 Patent covers an Accused Instrumentality.
`
`31.
`
`Toyota has and continues to directly infringe the ’096 Patent, literally and
`
`alternately under the doctrine of equivalents, by making, using, selling, offering for sale,
`
`and importing in or into the United States one or more apparatuses that embody and
`
`practice at least claim 8 of the ’096 Patent in violation of 35 U.S.C. § 271(a) including, but
`
`not limited to, Toyota’s Accused Instrumentalities capable of operation on or compatible
`
`with a Wi-Fi 5/6 Network.
`
`32.
`
`Toyota, likewise, with knowledge of the ’096 Patent and without authority,
`
`has actively induced and continues to actively induce infringement of at least claim 8 of
`
`the ’096 Patent under 35 U.S.C. § 271(b), by intentionally inducing the infringing use, offer
`
`for sale, and/or sale of the Accused Instrumentalities by and with Wi-Fi 5/6 Networks and
`
`their operators and end-users. Each Accused Instrumentality employs the patented frame
`
`structure for data transmission in either the legacy format or the VHT format within a single
`
`frame. The Accused Instrumentalities are designed to be used by and with Wi-Fi 5/6
`
`Networks and their operators in an infringing manner that practices the ’096 Patent.
`
`10
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 10 of 13
`
`
`
`Similarly, the Accused Instrumentalities are configured to be used by end-users of
`
`Wi-Fi 5/6 Networks in an infringing manner that practices the ’096 Patent.
`
`33.
`
`Toyota actively induces Wi-Fi 5/6 Network operators and end-users to
`
`practice the ’096 Patent, without authority, by, inter alia, designing and introducing into
`
`the stream of commerce the Accused Instrumentalities, which employ the patented frame
`
`structure for data transmission. Toyota encourages infringing use of the Accused
`
`Instrumentalities by the Wi-Fi 5/6 Network operators and end-users by, for example,
`
`publishing manuals, videos, and promotional literature describing and instructing in the
`
`operation of the Accused Instrumentalities in an infringing manner. At the encouragement
`
`by and direction of Toyota, the Wi-Fi 5/6 Network operators sell and offer for sale Accused
`
`Instrumentalities to end-users to be used in an infringing manner. Toyota provides and
`
`promotes services, functionality, subscriptions, discounts, and incentives to encourage end-
`
`users to connect multiple mobile devices to each Accused Instrumentality via Wi-Fi 5/6
`
`Networks in order to access the internet. Such conduct results in induced infringements of
`
`at least claim 8 of the ’096 Patent when the Accused Instrumentalities are used for their
`
`intended purpose.
`
`34.
`
`Toyota, likewise, is liable for contributory infringement. Toyota, with
`
`knowledge of the ’096 Patent and without authority, has offered to sell, sold, and imported
`
`into the United States the Accused Instrumentalities for use in practicing the patented
`
`apparatus and methods embodied in at least claim 8, which use constitutes a material part
`
`of the claimed invention. Toyota offered to sell, sold, and imported into the United States
`
`the Accused Instrumentalities knowing that each is especially made or adapted for use in
`
`11
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 11 of 13
`
`
`
`infringing the ’096 Patent, and that each is not a staple article or commodity of commerce
`
`suitable for substantial non-infringing use as packaged, advertised, or sold because the
`
`Accused Instrumentalities are pre-configured by Toyota to employ the patented frame
`
`structure for data transmission.
`
`35.
`
`Toyota’s direct, indirect, and contributory infringement of the ’096 Patent
`
`has caused, and will continue to cause, substantial and irreparable damage to UNMRI.
`
`UNMRI is, therefore, entitled to an award of damages adequate to compensate for Toyota’s
`
`infringement of the ’096 Patent, but not less than a reasonable royalty, together with pre-
`
`and post-judgment interest and costs as fixed by the Court under 35 U.S.C. § 284.
`
`JURY DEMAND
`
`36.
`
`Plaintiff UNMRI hereby demands a trial by jury for all causes of action.
`
`PRAYER FOR RELIEF
`
`Plaintiff requests the following relief:
`
`A judgment that Defendants have directly infringed either literally and/or
`
`37.
`
`A.
`
`under the doctrine of equivalents and continue to directly infringe the ’096 Patent.
`
`B.
`
`A judgment that Defendants have induced infringement and continue to
`
`induce infringement of the ’096 Patent.
`
`C.
`
`A judgment that Defendants have contributorily infringed and continue to
`
`contributorily infringe the ’096 Patent.
`
`D.
`
`A judgment and order requiring Defendants to pay Plaintiff damages under
`
`35 U.S.C. § 284, including treble damages for willful infringement as provided by
`
`12
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 12 of 13
`
`
`
`35 U.S.C. § 284, and supplemental damages for any continuing post-verdict infringement
`
`through entry of the final judgment with an accounting as needed.
`
`E.
`
`A judgment that this is an exceptional case within the meaning of 35 U.S.C.
`
`§ 285 and Plaintiff is, therefore, entitled to reasonable attorneys’ fees.
`
`F.
`
`A judgment and order requiring Defendants to pay Plaintiff pre-judgment
`
`and post-judgment interest on the damages awarded.
`
`G.
`
`H.
`
`A judgment and order awarding a compulsory ongoing royalty.
`
`A judgment granting a preliminary and permanent injunction that restrains
`
`and enjoins Defendants, its officers, directors, employees, agents, servants, parents,
`
`subsidiaries, successors, assigns, and all those in privity, concert or participation with
`
`Defendants from directly or indirectly infringing the ’096 Patent.
`
`I. Such other and further relief as the Court deems just and equitable.
`
`DATED: September 18, 2023
`
`
`
`
`Michael W. Shore (Texas 18294915)
`Chijioke E. Offor (Texas 24065840)
`THE SHORE FIRM LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`mshore@shorefirm.com
`coffor@shorefirm.com
`
`Counsel for Plaintiff
`UNM Rainforest Innovations
`
`
`
` Respectfully submitted,
`
`By: /s/ Chijioke E. Offor
`
`Charles L. Ainsworth (Texas 00783521)
`Robert Christopher Bunt (Texas 00787165)
`PARKER, BUNT & AINSWORTH, P.C.
`100 East Ferguson, Suite 418
`Tyler, Texas 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
`
`
`Counsel for Plaintiff
`UNM Rainforest Innovations
`
`13
`
`Exhibit 1022
`Panasonic v. UNM
`IPR2024-00364
`Page 13 of 13
`
`
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