Case 2:24-cv-00644 Document 1 Filed 08/08/24 Page 1 of 30 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CIVIL ACTION NO. 2:24-cv-644
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`JURY TRIAL DEMANDED
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`§§§§§§§§§
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`§§§§§
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`Stratasys, Inc.,
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`Plaintiff,
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`v.
`Shenzhen Tuozhu Technology Co., Ltd.,
`Shanghai Lunkuo Technology Co., Ltd.,
`Bambulab Limited,
`Beijing Tiertime Technology Co., Ltd.
`Beijing Yinhua Laser Rapid Prototyping and
`Mould Technology Co. Ltd., and
`Tuozhu Technology Limited
`
`Defendants.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Stratasys, Inc. (“Plaintiff” or “Stratasys”), by and through its undersigned counsel,
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`brings this complaint for patent infringement against Defendants Shenzhen Tuozhu Technology
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`Co., Ltd., Shanghai Lunkuo Technology Co., Ltd., Bambulab Limited, Beijing Tiertime
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`Technology Co., Ltd., Beijing Yinhua Laser Rapid Prototyping and Mould Technology Co. Ltd.,
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`and Tuozhu Technology Limited (collectively, “Bambu Lab” or “Defendants”) and would
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`respectfully show the Court as follows:
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`I.
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`PARTIES
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`1.
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`Stratasys is one of the pioneers in the field of three-dimensional (3D) printing
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`technology, founded in 1988. Plaintiff Stratasys, Inc. is a Delaware corporation with its place of
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`business located at 7665 Commerce Way, Eden Prairie, Minnesota.
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`2.
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`On information and belief, Defendant Shenzhen Tuozhu Technology Co., Ltd. (深
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`圳拓竹科技有限公司, hereafter, “Shenzhen Tuozhu”) is a company organized and existing under
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`1
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`Shenzhen Tuozhu 1024
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`the laws of the People’s Republic of China. On information and belief, Shenzhen Tuozhu operates
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`under the brand name “Bambu Lab” and holds itself forth under the English name Shenzhen
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`Bambu Lab Co., Ltd. That name does not appear separately in China’s National Enterprise Credit
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`Information Publicity System.
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`3.
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`On information and belief, Defendant Shanghai Lunkuo Technology Co., Ltd. (上
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`海轮廓科技有限公司, hereafter, “Shanghai Lunkuo”) is a company organized and existing under
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`the laws of the People’s Republic of China. On information and belief, Shanghai Lunkuo conducts
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`business, either directly or through its agents, on an ongoing basis in this judicial district and
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`elsewhere in the United States. On information and belief, Shanghai Lunkuo holds itself forth
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`under the English name Shanghai Contour Technology Co., Ltd. That name does not appear
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`separately in China’s National Enterprise Credit Information Publicity System, as Lunkuo is a
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`phonetic spelling of the Chinese word that translates to Contour.
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`4.
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`On information and belief, Defendant Bambulab Limited is a company organized
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`and existing under the laws of Hong Kong SAR, China, and is a wholly-owned subsidiary of
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`Shenzhen Tuozhu Technology Co., Ltd.
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`5.
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`On information and belief, Defendant Beijing Tiertime Technology Co., Ltd. (北
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`京太尔时代科技有限公司), is a company organized and existing under the laws of the People’s
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`Republic of China.
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`6.
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`On information and belief, Defendant Beijing Yinhua Laser Rapid Prototyping and
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`Mould Technology Co. Ltd. (北京殷华激光快速成形与模具技术有限公司), is a company
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`organized and existing under the laws of the People’s Republic of China.
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`7.
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`On information and belief, Defendant Tuozhu Technology Limited, is a company
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`organized and existing under the laws of Hong Kong SAR, China, and is a wholly-owned
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`subsidiary of Shenzhen Tuozhu Technology Co., Ltd.
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`II.
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`JURISDICTION AND VENUE
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`8.
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`This is a civil action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. §§ 1 et seq. Accordingly, this Court has subject matter jurisdiction over
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`this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`9.
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`This Court has personal jurisdiction over Defendants at least because they (1) have
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`committed acts of patent infringement and contributed to and induced acts of patent infringement
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`by others in this District; (2) regularly did business or solicited business in this District; (3) engaged
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`in other persistent courses of conduct and derived substantial revenue by its offering of infringing
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`products and services and providing infringing products and services in this District; and (4)
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`purposefully established substantial, systematic, and continuous contacts with this District and
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`should have reasonably expected to be subject to suit here by its offering of infringing products
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`and services and providing infringing products and services in this District.
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`10.
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`Defendants conduct business, either directly or through its agents, on an ongoing
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`basis in this judicial district and elsewhere in the United States. On information and belief,
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`Defendants are responsible for the research, development, and manufacturing of Bambu-branded
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`products imported, sold, offered for sale, and/or used in the United States, including Bambu’s
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`three-dimensional (3D) printing products in this District.
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`11.
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`Defendants have sold their 3D printers and 3D-printer related products within this
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`judicial district via their online store at https://store.bambulab.com/products.
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`12.
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`Defendants, directly and through subsidiaries or intermediaries (including
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`distributors, retailers, and others), have purposefully and voluntarily placed their infringing
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`products into this district and into the stream of commerce with the intention and expectation that
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`the infringing products will be purchased for use in this district. Defendants have imported, offered
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`for sale and sold, and continue to import, offer for sale and sell, infringing products for delivery
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`and use in this district.
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`13.
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`Venue is proper in this district under at least 28 U.S.C. §§ 1391(b), (c) and/or
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`1400(b). Venue in this district is proper for Defendants at least because they are foreign entities
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`that have committed acts of infringement in this district as detailed throughout this complaint.
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`III. BACKGROUND OF THE DISPUTE
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`14.
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`Stratasys was founded in 1988 and is a pioneer in the field of three-dimensional
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`printing. Stratasys was the original innovator in the field of fused deposition modeling (also
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`known as material extrusion 3D printing), which is an additive manufacturing process that prints
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`three-dimensional objects from computer models by building up layers of one or more extruded
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`materials onto a platform using a device that has come to be generally known as a 3D printer.
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`Stratasys has commercialized this technology (which it refers to as its “FDM” technology), and
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`continues to do so today, selling Stratasys FDM® printers and filament, along with an ecosystem
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`of software, accessories and services.
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`15.
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`Stratasys is an indirectly wholly-owned subsidiary of Stratasys Ltd. Stratasys Ltd.
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`is a publicly owned company organized under the laws of Israel, that is publicly traded in the
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`United States on the NASDAQ (ticker symbol: SSYS).
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`16.
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`Stratasys’s printers are backed by its proprietary technologies. Stratasys hold
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`approximately 2,600 patents and pending patents internationally, and its 3D printing systems
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`utilize its patented extrusion-based FDM®, inkjet-based PolyJet™, powder-bed-based SAF®,
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`photopolymer-based P3™, and stereolithography technologies to enable the production of
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`prototypes, tools used for production, and manufactured goods directly from 3D CAD files or other
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`3D content.
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`17.
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`In 2012, Stratasys, Inc. merged with Objet Ltd. to form the corporate entity
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`Stratasys Ltd. Today, Stratasys Ltd. and its subsidiaries, including Stratasys, Inc., have more than
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`1,900 employees worldwide, hold approximately 2,600 granted or pending patents globally, and
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`have received numerous awards for technology and leadership.
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`18.
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`Over the years, other companies began to make and sell 3D printers that incorporate
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`features and capabilities involving the extrusion of materials in additive layers to form 3D objects.
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`For example, by 2022, Defendants began making and selling its “Bambu Lab” branded printers.
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`On information and belief, the Bambu Lab printers are sold in the United States through direct
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`sales over the Internet and through resellers.
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`19.
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`On information and belief, Defendants have sold their printers, including their
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`Bambu Lab A1 3D printer, A1 mini 3D printer, P1P 3D printer, X1-Carbon 3D printer, P1S 3D
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`printer and X1E 3D printer. Defendants also make available and distribute marketing,
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`instructional, and support materials to customers through their website, and maintains a technical
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`support staff that provides support to customers, including through their website.
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`20.
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`On information and belief, Defendants’ printers (including their Bambu Lab A1 3D
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`printer, A1 mini 3D printer, P1P 3D printer, X1-Carbon (“X1C”) 3D printer, P1S 3D printer and
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`X1E 3D printer) transmit data to Defendants’ servers or servers operated by third parties under
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`Defendants’ control. This includes, but is not limited to, Defendants’ servers that may be located
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`in China.
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`21.
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`In fact, Defendants have acknowledged that their printers have security concerns.
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`In a November 2022 blog post, Defendants’ representative stated that: “We admit that the security
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`design of the whole Bambu Lab system was not the best from the very beginning. The honest
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`reason is simply that the initial team has a background in robotics, but very little experience in
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`network security. We now understand, thanks to the community contributions, that we have
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`underestimated this issue, and there is no excuse for this.” https://blog.bambulab.com/answering-
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`network-security-concerns/.
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`IV. CAUSES OF ACTION
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`COUNT 1: U.S. Patent No. 9,421,713
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`22.
`
`Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs
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`as if fully set forth herein.
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`23.
`
`On August 23, 2016, the United States Patent Office (USPTO) duly and lawfully
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`issued United States Patent No. 9,421,713, entitled “Additive Manufacturing Method For Printing
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`Three-Dimensional Parts With Purge Towers.” By assignment, duly recorded with the USPTO,
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`Stratasys owns all substantial rights to the ’713 Patent, including the right to sue and recover
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`damages for all infringement.
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`24.
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`The ’713 Patent generally relates to additive three-dimensional printing with purge
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`towers.
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`25.
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`Bambu Lab has directly infringed, and continues to directly infringe the ’713 Patent
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`in violation of 35 U.S.C. 271(a) by using in the United States, without authorization, the accused
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`products that practice various claims of the ’713 Patent literally or under the doctrine of
`
`equivalents. Those products include, for example, Bambu’s X1C, X1E, and P1S, and P1P printers.
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`26.
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`As a non-limiting example, the Accused ’713 Products meet every element of at
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`least Claim 1 of the ’713 Patent literally or under the doctrine of equivalents. Claim 1 recites:
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`1. A method for printing a three-dimensional part with an additive
`manufacturing system, the method comprising:
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`printing layers of the three-dimensional part and of a support
`structure for the three-dimensional part from multiple print heads
`or deposition lines using a layer-based, additive manufacturing
`technique;
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`switching the print heads or deposition line between stand-by
`modes and operating modes in-between the printing of the layers
`of the three-dimensional part and the support structure;
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`performing a purge operation for each print head or deposition line
`switched to the operating mode, the purge operation comprising
`printing at least one purge tower in a layer-by-layer manner,
`wherein the layers of the at least one purge tower are printed from
`the print head or deposition line switched to the operating mode.
`
`27.
`
` For example, Bambu Lab makes, uses, sells and offers to sell various additive
`
`manufacturing systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, and A1 mini
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`which are used for printing three-dimensional parts. Bambu Lab’s 3D printers print layers of a 3D
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`part using an Automatic Material System (AMS), which supports multiple filament spools each
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`having an independent deposition line operatively coupled to the print head of the 3D printer.
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`Furthermore, Bambu Labs distributes Bambu Studio for use in conjunction with its 3D printers.
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`Bambu Studio includes use of support material (as needed) in its slicer software, and it instructs
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`the 3D printer to switch deposition lines between printing of part material and printing of support
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`material. In addition, the Bambu Studio slicer software instructs the Bambu Labs 3D printers to
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`perform a purge operation to a prime tower when a deposition line is switched between the part
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`material and the support material. Bambu Lab thus directly infringed and continues to directly
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`infringe each limitation of at least Claim 1 of the ’713 Patent by using, in the United States, without
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`authorization the Accused ’713 Products.
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`28.
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`To the extent Defendants do not perform each and every limitation of the claims of
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`the ’713 Patent, Defendants jointly infringe those claims. In particular, Defendants direct or
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`control its users of the Accused ’713 Products to perform one or more limitations of the claims
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`nationwide through its own websites, applications, and manuals, and expects and intends that the
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`Accused ’713 Products will be so used. For example, Defendants require customers and users to
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`use the accused products through the applications Defendants produce and distribute for use.
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`Defendants further require users of the accused products to agree to extensive terms and
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`conditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’
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`technology to print and manufacture tangible items.
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`29.
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`Defendants also indirectly infringe at least Claim 1 of the ’713 Patent in violation
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`of 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
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`parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
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`providers, in the United States with knowledge and specific intent that its efforts would result in
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`the direct infringement of the ’713 Patent. For example, Defendants actively induce infringement
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`of the ’713 Patent by designing, manufacturing, selling, or distributing the Accused ’713 Products
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`and then training its customers and users on the use of those products and the accompanying
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`applications, including through the creation and dissemination of supporting materials,
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`maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
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`Handy),
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`instructions,
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`product manuals,
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`and
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`technical
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`information.
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`
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`See
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`https://wiki.bambulab.com/en/home. As another example, Defendants actively
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`induces
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`infringement of the ’713 Patent by instructing, encouraging, or requiring their subsidiaries and
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`affiliates in the United States to use, sell, offer for sale in the United States, and importing into the
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`United States, without authorization, the accused products that practice various claims of the ’713
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`Patent, such as any Bambu Lab printer that is used in combination with the corresponding
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`applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet another
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`example, Defendants actively induce infringement of the ’713 Patent through the creation and
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`dissemination of promotional and marketing materials and
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`instructional videos. See
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`https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with the
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`knowledge and the specific intent that its efforts would result in the direct infringement of the ’713
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`Patent.
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`30.
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`Defendants were put on notice of their direct and indirect infringement of the ’713
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`Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
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`have knowledge of the ’713 Patent and knowledge of how Defendants induce third parties to
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`infringe that patent at least as early as August 5, 2024.
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`31.
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`Defendants are also liable for contributory infringement of the ’713 Patent under
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`35 U.S.C. 271(c) by selling or offering for sale the Accused ’713 Products and/or other components
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`(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
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`Accused ’713 Products and/or other components (e.g., filament, automatic material system, build
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`plates, etc.) in the United States with knowledge that they are especially designed or adapted to
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`operate in a manner that infringes the ’713 Patent and are not a staple article or commodity of
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`commerce suitable for substantially non-infringing use. Defendants contribute to infringement of
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`the ’713 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’713 Products
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`and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
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`parties.
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`32.
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`Defendants also have had knowledge of how Defendants infringe the ’713 Patent
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`at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants have
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`knowledge of the ’713 Patent and knowledge of how Defendants contribute to third parties’
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`infringement of that patent at least as early as August 5, 2024.
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`33.
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`Defendants’ infringement of the ’713 Patent has been and continues to be willful.
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`At least as early as August 5, 2024, Defendants were notified of their infringing acts and
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`deliberately continued to infringe the ’713 Patent despite knowing of the existence of the patent
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`and how Defendants infringe. Further, Defendants have deliberately continued to encourage
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`others’ infringement of the ’713 Patent, including by continuing to disseminate its marketing and
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`technical materials to customers.
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`34.
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`Defendants’ acts of infringement have injured and damaged Stratasys and will
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`continue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
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`the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amount
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`to be proven at trial.
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`35.
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`Defendants’ infringement has damaged and will continue to damage Stratasys
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`irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
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`damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the
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`’713 Patent.
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`36.
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`Stratasys is entitled to all damages to which it otherwise is entitled because it has
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`complied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the
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`’713 Patent.
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`COUNT 2: U.S. Patent No. 9,592,660
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`37.
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`Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs
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`as if fully set forth herein.
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`38.
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`Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs
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`as if fully set forth herein.
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`39.
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`On March 14, 2017, the United States Patent Office (USPTO) duly and lawfully
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`issued United States Patent No. 9,592,660, entitled “Heated Build Platform And System For Three-
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`Dimensional Printing Methods.” By assignment, duly recorded with the USPTO, Stratasys owns
`
`all substantial rights to the ’660 Patent, including the right to sue and recover damages for all
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`infringement.
`
`40.
`
`The ’660 Patent generally relates to a base for printing 3D objects using high
`
`temperature thermoplastics using additive manufacturing methods.
`
`41.
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`Bambu Lab has directly infringed, and continues to directly infringe the ’660 Patent
`
`in violation of 35 U.S.C. 271(a) by using, selling, offering for sale in the United States, and
`
`importing into the United States, without authorization, the accused products that practice various
`
`claims of the ’660 Patent literally or under the doctrine of equivalents. Those products include,
`
`for example, Bambu’s X1C, X1E, and P1S, P1P, A1 and A1 mini printers.
`
`42.
`
`As a non-limiting example, the Accused ’660 Products meet every element of at
`
`least Claim 1 of the ’660 Patent literally or under the doctrine of equivalents. Claim 1 recites:
`
`1. A build apparatus for printing a 3D object of thermoplastics
`employing additive manufacturing methods, the apparatus
`comprising:
`
`a build platform with a temperature control unit configured to
`control heating of the build platform;
`
`a thermally conductive plate disposed adjacent to the build
`platform; and
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`a polymer coating attached to a surface of the thermally conductive
`plate which is capable of (i) facilitating adhesion to the 3D object
`during printing and (ii) permitting removal of the 3D object once
`the 3D object has been formed and cooled without chemically or
`mechanically removing the polymer coating from 3D object and
`without damaging the polymer coating, the thermally conductive
`plate, or the 3D object, wherein the polymer coating is not a
`polymer tape.
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`43.
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` For example, Bambu Lab makes, uses, sells and offers to sell various additive
`
`manufacturing systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, and A1 mini,
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`which are used for printing three-dimensional parts using thermoplastic filaments. The Bambu
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`printers have a heated build platform (i.e., heatbed). In addition, Bambu sells thermally
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`conductive build plates with their 3D printers, such as the Bambu Engineering Plate, Textured PEI
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`Plate, and High Temperature Plate, that are placed on the heatbed for fabrication of the 3D part.
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`These build plates are made by coating a polymer (e.g., polyetherimide) onto a steel sheet, which
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`facilitates adhesion of the 3D part to the build plate. The 3D object is removable from the build
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`plate without chemically or mechanically removing the polymer coating and without damaging
`
`the polymer coating, such as by flexing the build plate after the 3D object has cooled. Bambu Lab
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`thus directly infringed and continues to directly infringe each limitation of at least Claim 1 of the
`
`’660 Patent by using, selling, offering for sale in the United States, and importing into the United
`
`States, without authorization the Accused ’660 Products.
`
`44.
`
`To the extent Defendants do not perform each and every limitation of the claims of
`
`the ’660 Patent, Defendants jointly infringe those claims. In particular, Bambu Lab directs or
`
`controls its users of the Accused ’660 Products to perform one or more limitations of the claims
`
`nationwide through its own websites, applications, and manuals, and expects and intends that the
`
`Accused ’660 Products will be so used. For example, Defendants require customers and users to
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`use the accused products through the applications Defendants produce and distribute for use.
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`Defendants further require users of the accused products to agree to extensive terms and
`
`conditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’
`
`technology to print and manufacture tangible items.
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`45.
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`Defendants also indirectly infringe at least Claim 1 of the ’660 Patent in violation
`
`of 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
`
`parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
`
`providers, in the United States with knowledge and specific intent that its efforts would result in
`
`the direct infringement of the ’660 Patent. For example, Defendants actively induce infringement
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`of the ’660 Patent by designing, manufacturing, selling, or distributing the Accused ’660 Products
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`and then training its customers and users on the use of those products and the accompanying
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`applications, including through the creation and dissemination of supporting materials,
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`maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
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`Handy),
`
`instructions,
`
`product manuals,
`
`and
`
`technical
`
`information.
`
`
`
`See
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`https://wiki.bambulab.com/en/home. As another example, Defendants actively
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`induces
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`infringement of the ’660 Patent by instructing, encouraging, or requiring their subsidiaries and
`
`affiliates in the United States to use, sell, offer for sale in the United States, and importing into the
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`United States, without authorization, the accused products that practice various claims of the ’660
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`Patent, such as any Bambu Lab printer that is used in combination with the corresponding
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`applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet another
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`example, Defendants actively induce infringement of the ’660 Patent through the creation and
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`dissemination of promotional and marketing materials and
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`instructional videos. See
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`https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with the
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`knowledge and the specific intent that its efforts would result in the direct infringement of the ’660
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`Patent.
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`46.
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`Defendants were put on notice of their direct and indirect infringement of the ’660
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`Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
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`have knowledge of the ’660 Patent and knowledge of how Defendants induce third parties to
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`infringe that patent at least as early as August 5, 2024.
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`47.
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`Defendants are also liable for contributory infringement of the ’660 Patent under
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`35 U.S.C. 271(c) by selling or offering for sale the Accused ’660 Products and/or other components
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`(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
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`Accused ’660 Products and/or other components (e.g., filament, automatic material system, build
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`plates, etc.) in the United States with knowledge that they are especially designed or adapted to
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`operate in a manner that infringes the ’660 Patent and are not a staple article or commodity of
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`commerce suitable for substantially non-infringing use. Defendants contribute to infringement of
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`the ’660 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’660 Products
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`and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
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`parties.
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`48.
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`Defendants also have had knowledge of how Defendants infringe the ’660 Patent
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`at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants have
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`knowledge of the ’660 Patent and knowledge of how Defendants contribute to third parties’
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`infringement of that patent at least as early as August 5, 2024.
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`49.
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`Defendants’ infringement of the ’660 Patent has been and continues to be willful.
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`At least as early as August 5, 2024, Defendants were notified of their infringing acts and
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`deliberately continued to infringe the ’660 Patent despite knowing of the existence of the patent
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`and how Defendants infringe. Further, Defendants have deliberately continued to encourage
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`others’ infringement of the ’660 Patent, including by continuing to disseminate its marketing and
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`technical materials to customers.
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`50.
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`Defendants’ acts of infringement have injured and damaged Stratasys and will
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`continue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
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`the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amount
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`to be proven at trial.
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`51.
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`Defendants’ infringement has damaged and will continue to damage Stratasys
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`irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
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`damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the
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`’660 Patent.
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`52.
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`Stratasys is entitled to all damages to which it otherwise is entitled because it has
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`complied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the
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`’660 Patent.
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`COUNT 3: U.S. Patent No. 7,555,357
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`53.
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`Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs
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`as if fully set forth herein.
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`54.
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`Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs
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`as if fully set forth herein.
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`55.
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`On June 30, 2009, the United States Patent Office (USPTO) duly and lawfully
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`issued United States Patent No. 7,555,357, entitled “Method For Building Three-Dimensional
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`Objects With Extrusion-Based Layer Deposition Systems.” By assignment, duly recorded with the
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`USPTO, Stratasys owns all substantial rights to the ’357 Patent, including the right to sue and
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`recover damages for all infringement.
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`56.
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`The ’357 Patent generally relates to methods of forming three-dimensional objects
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`using an extrusion-based layered deposition system that generates a build path for building a layer
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`of the three-dimensional object where the build path defines a void region.
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`57.
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`Bambu Lab has directly infringed, and continues to directly infringe the ’357 Patent
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`in violation of 35 U.S.C. 271(a) by using in the United States, without authorization, the accused
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`products that practice various claims of the ’357 Patent literally or under the doctrine of
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`equivalents. Those products include, for example, Bambu’s X1C, X1E, and P1S, P1P, A1 and A1
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`mini printers.
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`58.
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`As a non-limiting example, the Accused ’357 Products meet every element of at
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`least Claim 15 of the ’357 Patent literally or under the doctrine of equivalents. Claim 15 recites:
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`15. A method of forming a three-dimensional object using an
`extrusion-based layered deposition system, the method comprising:
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`generating a build path for building a layer of the three-
`dimensional object with a plurality of first deposition roads based
`on a first road width resolution, wherein the build path defines a
`void region having dimensions that are smaller than the first road
`width resolution along at least one axis; and
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`generating a remnant path in the void region for filling at least
`[part] of a cavity corresponding to the defined void region with a
`second deposition road based on deposition rates that are
`configured to vary based on the dimensions of the void region.
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`59.
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` For example, Bambu Lab makes, uses, sells and offers to sell various extrusion-
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`based layered deposition systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, and
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`A1 mini, which are used for printing three-dimensional parts. A 3D model of the 3D object to be
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`printed is loaded into Bambu Studio and sliced to generate a .3mf file, which is the file format used
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`for the printer to be able to print the model. The .3mf file contains instructions for executing build
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`paths (e.g., “roads,” “walls,” etc.) during the printing of the object. These instructions are provided
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`to a Bambu Lab 3D printer and executed by the printer to, for example, generate void regions
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`formed using walls of one width that that are filled in with remnant paths of another width. For
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`example, the Bambu Lab Wiki describes the concept of wall distribution count as a parameter for
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`adjusting a number of and width of walls. For example, widths of a wall are modified to fill a void
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`formed between other walls. Bambu Lab thus directly infringed and continues