Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 1 of 14 Page|D #: 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`V.
`
`C.A. N0.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA,
`INC., SAMSUNG TELECOMl\/IUNICATIONS
`AMERICA, LLC
`
`Defendants.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT
`
`Plaintiif Arendi S.A.R.L.
`
`(“Arendi”) for its Complaint against Defendants hereby"
`
`demands a jury trial and alleges as follows:
`
`Related Actions
`
`1.
`
`This case is related to two cases previously consolidated before Judge Stark, 09-
`
`cv—001 19 (D. Del.) (LPS) and 11-cv—00260 (D. Del.) (LPS), both of which settled after extensive
`
`dispositive motion practice. This case is also related to the other actions filed simultaneously by
`
`Arendi today, which involve the same patents-in-suit and common facts.
`
`The Parties and Accused Products
`
`2.
`
`Plaintiff Arendi is a corporation organized under the laws of Luxembourg with its
`
`principal place of business in Luxembourg.
`
`3.
`
`On information and belief, Defendant Samsung Electronics Co., Ltd. (“Samsung
`
`Electronics”) is a corporation organized under the laws of the Republic of Korea and has its
`
`principal place of business at 1320-10, Seocho 2-dong, Seocho-gu, Seoul 137- 857, Republic of
`
`Korea.
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 1 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 2 of 14 Page|D #: 2
`
`4.
`
`On information and belief, Defendant Samsung Electronics America,
`
`Inc.
`
`(“Samsung America”) is a New York corporation and has its principal place of business at 85
`
`Challenger Road, Ridgefield Park, New Jersey 07660. Samsung America is doing business in
`
`this judicial district and its registered agent for service of process is CT Corporation System, 111
`
`Eighth Avenue, New York, New York 10011.
`
`5.
`
`On information and belief, Defendant Samsung Telecommunications America,
`
`LLC (“Samsung Telecommunications”) is a Delaware limited liability company with its
`
`principal place of business at
`
`"1301 East Lookout Drive, Richardson, Texas 75081. On
`
`information and belief, Samsung Telecommunications markets, sells, or offers for sale a variety
`
`of personal and business communications devices in the United States and in this judicial district,
`
`including cell phones and tablets. Samsung illlectronics, Samsung America and Samsung
`
`Telecommunications are collectively referred to herein as “Samsung.”
`
`6.
`
`Samsung transacts substantial business, either directly or through its agents, on an
`
`ongoing basis in this judicial district and elsewhere in the United States.
`
`7.
`
`Samsung makes, uses, imports, offers to sell, and sells (and/or has made, used,
`
`imported, offered to sell, and sold) in the United States and in this judicial district, the Samsung
`
`B5752, Samsung Galaxy S II (Samsung-SGH-1727), Samsung Galaxy Note II (Samsung—SGH-
`
`1717), Samsung Tab 2 10.1 (Samsung-SGH-1497) and other mobile phones, smartphones,
`
`computers and tablet devices containing the same or similar information handling technology
`
`disclosed in the asserted patents described herein (collectively, the “Accused Products”).
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 2 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 3 of 14 Page|D #: 3
`
`Nature of the Action
`
`8.
`
`This is a civil action for infiingement of United States Patents No. 7,917,843 (the
`
`“‘843 Patent”), No. 7,496,854 (the ‘“854 Patent”), and No. 8,306,993 (the ‘“993 Patent”). This
`
`action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.
`
`Jurisdiction and Venue
`
`9.
`
`This Court has jurisdiction over the subject matter of this action pursuant to 28
`
`U.S.C. §§ 1331 and 1338(a).
`
`10.
`
`Personal jurisdiction is proper in this district because, among other reasons,
`
`Samsung has a continuous presence in this District, Samsung committed acts of infringement in
`
`this District and a substantial part of the events or omissions giving rise to this claim occurred in
`
`this District. Samsung placed, and continues to place, Accused Products into the stream of
`
`commerce, through an established distribution channel, with the knowledge and/or understanding
`
`that such products are used and sold in this District. This causes injury to Arendi in this District.
`
`On information and belief, Defendants derive substantial revenue fi‘O1’11 the sale of Accused
`
`Products distributed within the District, and derive substantial revenue from interstate and
`
`international commerce.
`
`11.
`
`Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b) and (c), and
`
`1400(b), because Samsung committed acts of infringement in this district and a substantial part
`
`of the events or omissions giving rise to this claim occurred in this District.
`
`The Patents-In-Suit
`
`12.
`
`United States Patent No. 7,917,843, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legally
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 3 of 115
`
`

`
`Case 1:12-cv—O1598-UNA Document 1 Filed 11/29/12 Page 4 of 14 PageID #: 4
`
`issued on March 29, 2011, by the United States Patent and Trademark Office. A copy of the ‘843
`
`Patent is attached hereto as Exhibit A.
`
`13.
`
`United States Patent No. 7,496,854, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from a Computer Program,” was duly and legally
`
`issued on February 24, 2009, by the United States Patent and Trademark Office. A copy of the
`
`‘854 Patent is attached hereto as Exhibit B.
`
`14.
`
`United States Patent No. 8,306,993, entitled “Method, System and Computer
`
`Readable Medium for Addressing Handling from an Operating System,” was duly and legally
`
`issued on November 6, 2012, by the United States Patent and Trademark Office. A copy of the
`
`‘993 Patent is attached hereto as Exhibit C.
`
`15.
`
`Arendi is the exclusive owner of all rights, title, and interest in the ‘843 Patent,
`
`‘SS4 Patent, and ‘993 Patent, including the right to bring this suit for injunctive relief and
`
`damages.
`
`16.
`
`The ‘843 Patent, ‘854 Patent, and ‘993 Patent are valid and enforceable.
`
`BACKGROUND
`
`17.
`
`Arendi filed suit in this District against Microsoft Corporation and Dell Inc. for
`
`infringement of the ‘854 Patent on February 24, 2009. 09—cv-00119 (D. Del.) (LPS). Thecase
`
`was assigned to the Honorable Leonard P. Stark, who held two Markman Hearings, on February
`
`25, 2011 and November 21, 2011, and denied several summary judgment motions. The case was
`
`resolved by settlement and dismissed on November 29, 2011.
`
`18.
`
`Arendi filed suit in this District against l\/Iicrosoft Corporation for infiingement of
`
`the ‘843 Patent on March 29, 2011. 11—cv~00260 (D. Del.) (LPS). The case was assigned to the
`
`Honorable Leonard P. Stark, who consolidated the 11-cv-260 case With the above-referenced
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 4 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 5 of 14 Page|D #: 5
`
`case on May 10, 2011. After Judge Stark held a Markman Hearing on November 21, 2011, this
`
`case was also resolved by settlement and dismissed on November 29, 201 l.
`
`COUNT I
`
`(Infringement of United States Patent No. 7,917,843)
`
`19.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`20.
`
`Samsung has infringed and continues to infringe the ‘843 patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 1 and 23, literally or under the doctrine of equivalents,
`
`by making, using, selling, and/or offering for sale in the United States, and/or importing into the
`
`United States, Accused Products, Without authorization. On information and belief, Samsung
`
`has also infiinged and continues to infringe at least claims 2, 8, 13, 14, 15, 16, 17, 20, 21, 23, 24,
`
`30, 35, 36, 37, 38, 39, 42, 43 of tlie ‘843 patent under 35 U.S.C. § 271, literally or under the
`
`doctrine of equivalents, by making, using, selling, and/or offering for sale in the United States,
`
`and/or importing iI1to the United States, Accused Products, without authorization.
`
`21.
`
`Samsung’s acts of infiingement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`Wrongful acts in an amount subject to proof at trial. Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘843 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`22.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`Samsung’s customers, have infringed, and continue to infringe, one or more claims of the ‘843
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products.
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 5 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 6 of 14 Page|D #: 6
`
`23.
`
`Samsung has had knowledge of and notice of the ‘843 patent and its infringement
`
`at least since the filing of this complaint.
`
`24.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`after the filing of this complaint, Samsung is inducing infringement of one or more claims of the
`
`‘843 patent under 35 U.S.C. § 271 (b), including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`‘843 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States the Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to — either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or import the Accused Products supplied by Samsung to infringe the ‘843 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infiingement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infringing uses thereof.
`
`25.
`
`Samsu.ng’s acts of induced infringement have caused damage to Arendi and
`
`Arendi
`
`is entitled to recover from Samsung the damages it has sustained as a result of
`
`Defendants’ wrongful acts in an amount subject
`
`to proof at
`
`trial.
`
`Samsung’s induced
`
`infringement of Arendi’s exclusive rights under the ‘843 patent have damaged, and continue to
`
`damage, Arendi, causing irreparable harm for which there is no adequate remedy at law, unless
`
`the infugernent is enjoined by this Court.
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 6 of 115
`
`

`
`Case 1:12-cv—O1598-UNA Document 1 Filed 11/29/12 Page 7 of 14 PageID #: 7
`
`26.
`
`In addition to the foregoing and/or in tlie alternative, at least since the filing of
`
`this complaint, Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘843 patent under 35 U.S.C. § 27l(c).
`
`27.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products afier
`
`the filing of this complaint, Samsung is contributing to the infringement of one or more claims of
`
`the ‘843 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
`
`to the infringement of the ‘843 patent by selling, offering to sell and/or importing into the United
`
`States Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘843 Patent;
`
`with the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
`
`infringing information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfiinging use.
`
`28.
`
`Samsung’s acts of contributory infringement have caused damage to Arendi and
`
`Arendi
`
`is entitled to recover from Samsung the damages it has sustained as a result of
`
`Defendants’ wrongful acts in an amount subject to proof at trial.
`
`Samsung’s contributory
`
`infringement of Arendi’s exclusive rights under the ‘843 patent have damaged, and continue to
`
`damage, Arendi, causing irreparable harm for which there is no adequate remedy at law, unless
`
`the infringement is enjoined by this Court.
`
`COUNT II
`
`(Infringement of United States Patent No. 7,496,854)
`
`29.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 7 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 8 of 14 Page|D #: 8
`
`30.
`
`Samsung has infringed and continues to infringe the ‘854 Patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 57, 73, and 79, literally or under the doctrine of
`
`equivalents, by making, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization. On information and
`
`belief, Samsung has also infringed and continues to infringe at least claims 19, 20, 22, 23, 24, 25,
`
`26, 28, 29, 30, 31, 32, 34, 35, 60, 61, 62, 63, 64, 65, 72, 76, 77, 78, 82, 83, and 84 ofthe ‘854
`
`patent under 35 U.S.C. § 271, literally or under the doctrine of equivalents, by making, using,
`
`selling, and/or offering for sale in the United States, and/or importing into the United States,
`
`Accused Products, without authorization
`
`31.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infiingement of Arer1di’s
`
`exclusive rights under the ‘854 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infiingement is
`
`enjoined by this Court.
`
`32.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`Samsung’s customers, have infringed, and continue to infringe, one or more claims of the ‘854
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, and/or importing into the United States, Accused Products.
`
`33.
`
`Samsung has had knowledge of and notice of the ‘854 patent and its infringement
`
`34.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`alter the filing of this complaint, Samsung is inducing infringement of one or more claims of the
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 8 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 9 of 14 Page|D #: 9
`
`‘854 patent under 35 U.S.C. § 271, including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`‘854 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to — either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or import the Accused Products supplied by Samsung to infringe the ‘854 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infringement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infringing uses thereof.
`
`35.
`
`Sa1nsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial. Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘854 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`36.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint, Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘8S4 patent under 35 U.S.C. § 271(c).
`
`37.
`
`To the extent Samsmg continues to sell or otherwise supply Accused Products alter
`
`the filing of this complaint, Samsung is contributing to the infringement of one or more claims of
`
`the ‘854 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
`
`9
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 9 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 10 of 14 Page|D #: 10
`
`to the infringement ofthe ‘854 patent by selling, offering to sell and/or importing into the United
`
`States Accused Products after the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘854 Patent;
`
`with the knowledge that third parties, including its customers, will continue to — either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
`
`infringing information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfiinging use.
`
`38.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`SaInsung’s infringement of Arendi’s
`
`exclusive rights under the ‘854 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infiingement is
`
`enjoined by this Court.
`
`COUNT III
`
`(Infringement of United States Patent No. 8,306,993)
`
`39.
`
`The preceding paragraphs are incorporated by reference as if stated fully herein.
`
`40.
`
`Samsung has infringed and continues to infringe the ‘993 Patent under 35 U.S.C.
`
`§ 271, including but not limited to claims 1, 9 and 17, literally or under the doctrine of
`
`equivalents, by nialdng, using, selling, and/or offering for sale in the United States, and/or
`
`importing into the United States, Accused Products, without authorization. On information and
`
`belief, Sa...sung has also iifiinged and continues to infringe at least claims 2, 4, 5, 6, 7, 8, 10, 12,
`
`13, 14, 15, 16, 18, 20, 21, 24, 22, and 23 of the ‘993 patent under 35 U.S.C. § 271, literally or
`
`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
`
`States, and/or irnporting into the United States, Accused Products, Without authorization.
`
`10
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 10 of 115
`
`

`
`Case 1:12-cv—O1598-UNA Document 1 Filed 11/29/12 Page 11 of 14 PageID #: 11
`
`41.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infringement of A.rendi’s
`
`exclusive rights under the ‘993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`42.
`
`In addition to the foregoing and/or in the alternative, third parties, including
`
`Samsung’s customers, have infringed, and continue to infiinge, one or more claims of the ‘993
`
`patent under 35 U.S.C. § 271 by making, using, selling, and/or offering for sale in the United
`
`States, andfor importing into the United States, Accused Products.
`
`43.
`
`Samsung has had knowledge of and notice of the ‘993 patent and its infringement
`
`at least since the filing of this complaint.
`
`44.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products
`
`after the filing of this complaint, Samsung is inducing infiingement of one or more claims of the
`
`‘993 patent under 35 U.S.C. § 271, including on information and belief at least the claims set
`
`forth above. Samsung is actively, knowingly, and intentionally inducing infringement of the
`
`‘993 patent by practicing the methods set forth therein and by selling, offering to sell and/or
`
`importing into the United States Accused Products after the filing of this complaint; with the
`
`knowledge and specific intent that third parties, including its customers, will continue to ~« either
`
`alone or in combination with Samsung — practice the patented methods, and use, sell, offer for
`
`sale, and/or import the A eused Products supplied by Sarnsung to imfinge the ‘993 patent; and
`
`with the knowledge and specific intent to encourage and facilitate the infringement through the
`
`dissemination of the Accused Products and/or the creation and dissemination of promotional and
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 11 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 12 of 14 Page|D #: 12
`
`marketing materials, supporting materials,
`
`instructions, product manuals, and/or technical
`
`information relating to the Accused Products and infiinging uses thereof.
`
`45.
`
`Samsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`Wrongful acts in an amount subject to proof at trial.
`
`Samsung’s infringement of Arendi’s
`
`exclusive rights under the ‘993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infringement is
`
`enjoined by this Court.
`
`46.
`
`In addition to the foregoing and/or in the alternative, at least since the filing of
`
`this complaint Samsung has knowingly contributed to the infringement of one or more claims of
`
`the ‘993 patent under 35 U.S.C. § 271(0).
`
`47.
`
`To the extent Samsung continues to sell or otherwise supply Accused Products after
`
`the filing of this complaint, Samsung is contributing to the infringement of one or more claims of
`
`the ‘993 patent by third parties, under 35 U.S.C. § 271(c), including on information and belief at
`
`least the claims set forth above. Samsung is actively, knowingly, and intentionally contributing
`
`to the infringement of the ‘993 patent by selling, offering to sell andfor importing into the United
`
`States Accused Products afier the filing of this complaint; with the knowledge that the Accused
`
`Products are especially designed or adapted to operate in a manner that infringes the ‘993 Patent;
`
`with the knowledge that third parties, including its customers, will continue to e either alone or in
`
`combination with Samsung — practice the patented methods; and with the knowledge that the
`
`hifiinging information handling technology in the Accused Products is not a staple article of
`
`commerce suitable for substantial noninfringing use.
`
`48.
`
`Sa;tnsung’s acts of infringement have caused damage to Arendi and Arendi is
`
`entitled to recover from Samsung the damages it has sustained as a result of Defendants’
`
`12
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 12 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1 Filed 11/29/12 Page 13 of 14 Page|D #: 13
`
`wrongful acts in an amount subject to proof at trial.
`
`Sarnsung’s infringement of Arendi’s
`
`exclusive rights under the ‘993 patent have damaged, and continue to damage, Arendi, causing
`
`irreparable harm for which there is no adequate remedy at law, unless the infiingement is
`
`enjoined by this Court.
`
`Prayer for Refief
`
`WHEREFORE, Arendi prays for judgment as follows:
`
`A.
`
`B.
`
`Declaring that Samsung has infringed the ‘843, ‘854 and ‘993 Patents;
`
`Awarding the damages arising out of Samsung’s infiingement of the ‘843, ‘S54,
`
`and ‘993 Patents, including enhanced damages pursuant to 35 U.S.C. § 284, to Arendi, together
`
`with prejudgment and post—judgrnent interest, in an amount according to proof;
`
`C.
`
`Permanently enjoining Samsung, its officers, agents, and employees, and those
`
`persons in active concert or participation with any of them, and its successors and
`
`assigns,
`
`from infiingement,
`
`inducement of infiringement, and contributory
`
`infringement of the ’843, ‘854 and ‘993 Patents, including but not limited to
`
`making, using, selling, andfor offering for sale within the United States, and/or
`
`importing in the United States, any devices, products, software, or methods that
`
`infringe the ‘843, ‘854 and ‘993 Patents before the expiration of these patents;
`
`D.
`
`Awarding attorney’s fees to Arendi pursuant to 35 U.S.C. § 285 or as otherwise
`
`permitted by law;
`
`E.
`
`Awarding such other costs and further relief as the Court may deem just and
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 13 of 115
`
`

`
`Case 1:12-cv—O1598-UNA Document 1 Filed 11/29/12 Page 14 of 14 PageID #: 14
`
`JURY DEMAND
`
`Arendi hereby demands a tiial by jury on all issues so triable.
`
`PROCTOR HEYMAN LLP
`
`/s/ Neal C. Belgam
`Neal C. Belgam (# 2721)
`Email: nbelgam@proctorhey1nan.co1n
`Melissa N. Donimirski (# 4701)
`E—mai1: 1ndonin1irs1<1'@proctorheymaI1.o0m
`Dawn Kultz Crompton (# 5579)
`E—mai1: dcrompton@proctorheyman.com
`300 Delaware Avenue, Suite 200
`
`Wilmington, DE 19801
`(302) 472-7300
`
`Attorneys for Plaintiff Arendi S.A.R.L.
`
`OF COUNSEL:
`
`SUSMAN GODFREY, L.L.P.
`Stephen D. Susman
`E—mai1: ssusman@sus1nangodfrey.com
`Seth D. Ard
`
`E—mai1: sard@susmangodfrey.com
`560 Lexington Avenue, 15*“ Floor
`New York, NY 10022
`(212) 336-8330
`
`SUSMAN GODFREY, L.L.P.
`
`Harry P. Susman
`E—mai1: hsusman@susmangodfiey.com
`Lexie G. White
`
`E—mai1: lwl1ite@susmangodfrey.com
`I000 Louisanna Street, Suite 5100
`Houston, TX 77002
`212-651-9366
`
`Dated: November 29, 2012
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 14 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1-1 Filed 11/29/12 Page 1 of 32 Page|D #: 15
`
`Exhibit A
`
`Arendi S.A.R.L.-EX.2001
`
`Arendi S.A.R.L.-Ex.2001
`Page 15 of 115
`
`

`
`Case 1:12-cv-01598-UNA Document 1-1 Filed 11/29/12 Paie 2 of732 Pa|gie|D #: 16
`l||||||
`HllllllllllllllllllllIlllllllllllllllllll
`llllllllllllllllllllll
`
`US0079l7843B2
`
`(12; United States Patent
`Hedloy
`
`(10) Patent N0.:
`(45) Date of Patent:
`
`US 7,917,843 B2
`*Mar. 29, 2011
`
`l\t[ETHOD, SYSTEMAND COM?UTER
`READABLE MEDIUM FOR ADDRESSING
`HANDLING FROM A COMPUTER PROGRAM
`
`Inventor: Atle Hedloy, Madrid (ES)
`
`Assignee: Arendi S.A.R.L., Luxembourg (LU)
`
`Notice:
`
`Subject to any disclaimer, the term ofthis
`patent is extended or adjusted under 35
`Use. 154(0) by 394 days.
`
`This patent is subject to a terminal dis-
`claimer.
`
`App]. No.: 12I182,048
`
`Filed:
`
`Jul. 29, 2008
`
`Prior Publication Data
`
`US 2008lD3l3 l 59 Al
`
`Dec. 18, 2008
`
`Related US. Application Data
`
`Continuation of application No. 09/923,134, filed on
`Aug. 6, 2001, now Pat. No. 7,496,854, which is a
`continuation of application No. 09/189,626, filed on _
`Nov. 10, 1998, now Pat. No. 6,323,853.
`
`(30)
`
`Foreign Application Priority Data
`
`sep. 3, 1998
`
`(N0) ........................................ 984066
`
`(51) 1m.c1.
`G06F17/00
`(52) U.S.Cl.
`
`(2005.01)
`715.l'230;715/234;7l5/711;715/752;
`715/825; 7151853
`7] 5/230
`(58) Field of Classification Search
`See application file for complete search history.
`
`(56)
`
`References Cited
`
`U.S. PATENT DOCUMENTS
`3,350,695 A
`I0/1957 Kaufrnan et al.
`(Continued)
`
`340/172.5
`
`FOREIGN PATENT DOCUMENTS
`0 093 250 A2
`9/1983
`
`(Continued)
`
`OTHER PUBLICATIONS
`
`Person et 211., “Special Edition Using Microsoft Word 97” by Que
`Publisher Pub. date Dec. 16, 1996. pp. 475-514.‘
`
`(Continued)
`
`Primary Examiner — Doug Hutton
`Assistant Examiner — Quoc A Tran
`(74) Attorney, Agent, or firm — Sunstein Kann Murphy &
`Timbers LLP
`
`(57)
`
`ABSTRACT
`
`A method, system and computer readable medium for pro-
`viding for providing a function item, such as a key, button,
`icon, or menu, tied to a user operation in a computer, whereby
`a single click on the function it in a window or program on
`a computer screen, or one single selection in a menu in a
`progarn, initiates retrieval of name and addresses and/or
`other person or company related information, while the user
`works simultaneously in another program, e.g., a word pro-
`cessor. The click on the function item initiates a program
`connected to the button to search 2 database or file available
`on or through the computer, containing the person, company
`oraddress related data, in orderto look up data corresponding
`to What the user types, or partly typed, e.g., name and/or
`address in the word processor, the correct data from the data-
`base, data related to the typed data, e.g., the name of the
`person, company, or the traditional or electronic address, or
`other person, or company, or address related data, and alter-
`natively the persons, companies, or addresses, are displayed
`and possibly entered into the word processor, if such related
`data exists.
`
`44 Claims, 14 Drawing Sheets
`
`W Nflfimdflword-Dohlnarlfl
`!EliI<ll
`Elillfil
`IE“
`3 El:-ET
`‘I3
`-I-1-I-2-I-3+4-1-5-I-6-I-1-I a-:-s-I-1o-I-11-M2-t-13~:-|4-:-15-I-
`
`'I'§*I'-5‘I'3'l'2'l'1'l'Im
`
`Ki I
`
`Arendi S.A.R.L.-Ex.2001
`Page 16 of 115
`
`

`
`Case 1:12—cv—O1598—UNA Document 1-1 Filed 11/29/12 Page 3 of 32 PageID #: 17
`
`US 7,917,843 B2
`Page 2
`
`364/900
`.. 364/900
`.. 395/157
`364/419.14
`364/419.07
`.. 395/600
`.. 395/159
`.. 379/67
`
`..
`
`..
`.
`
`709/203
`. 707/102
`. 709/202
`705/ 10
`. 705/408
`. 709/223
`, 707/505
`705/14
`706/11
`705/14
`706/60
`. 345/337
`705/27
`. 707/201
`. 707/513
`. 345/339
`435/108
`379855.02
`707/534
`..
`705/ 14
`. 707/5117
`
`.
`
`Witek et a1.
`I-Iorvitz et a1.
`Horvitz et 8.1.
`Roth et 211.
`.
`..
`I-Iaiimet :11.
`I_a1:1dsman et a1.
`Hedloy ....... ..
`Onishi et al.
`Shajfer at 81.
`HB.C11ZI.II1OV1ICh et a1.
`Angles et a1.
`Nishiyama et ai.
`Abu-1-Iakima
`
`7/2000
`5,085,226 A
`7/2000
`5,092,074 A
`8/2000
`5,108,586 A
`11/2000
`5,151,584 A
`I/2001
`5,178,411 B1
`1/2001
`6,182,133 B1
`2/2001
`6,192,380 B1
`3/2001
`6,208,975 B1
`5/2001
`5,233,570 B1
`6/2001
`5,253,188 131
`7/2001
`6,260,035 B1
`7/2001
`6,262,730 B1
`9/2001
`6,285,987 B1
`10/2001
`5,304,881 B1
`11/2001
`5,317,751 B1
`11/2001
`5,323,853 B1
`1/2002
`6,338,957 B2
`4/2002
`6,373,940 B2
`4/2002
`6.377.965 B1
`5/2002
`5,385,592 B1
`7/2002
`5,421,693 B1
`12/2002
`6,499,021 131
`11/2003
`5,551,217 131
`5/2004
`6,738,615 B1
`11/2004
`5,825,407 Bl
`5/2006
`7,039,599 B2
`5/2006
`7,051,019 B1
`11/2006
`7,135,853 B1
`12/2006
`7,155,451 B1
`5/2007
`7,215,292 B1
`9/2007
`7,272,504 B1
`fl2009
`7,495,854 B2
`3/2009
`7,505,974 132
`3/2009
`7,509,349 B2
`5/2002
`2002/0054092 A1
`Hedloy .
`12/2002
`2002/0188583 A1
`Lyfle et al.
`2/2003
`Shanahan et a1.
`2003/0033288 A1
`3/2006
`2005/0047544 A1
`Bocking et a1.
`10/2007
`2007/0244907 A1
`Hedloy
`12/2008
`2008/0313159 Al
`Hedloy .
`8/2010 Hedloy .
`2010/0211500 A2‘
`11.2010 Hedloy
`2010/0281354 A1
`FOREIGN PATENT DOCIJMENTS
`1 630 642
`312006
`2196454
`4/1988
`2 318 703
`4/1998
`W0 97/21183
`6/1997
`W0 98/1689!)
`4/1998
`WO 98119259
`5/1998
`W0 98/34391
`3/1998
`
`Merriman et a1.
`Land et 31.
`Knhda et a1.
`Torres
`Snapper et a1.
`Hedloy
`I-Icdloy .
`Gropper
`
`OTHER PUBLICATIONS
`
`Plotkin, David, AdziressforSuccms, Bay Area Computer Currents, p.
`35-38, Mar. 21, 1995.
`C'1"AGS(1) Manual Page.
`Wilson, Eve, Guiding Lawyers: lvfapping Law into Hypertext, Arti-
`ficial lntelligence Review 6, pp. 161-189, 1992.
`MacwEEK Report, Aug. 8, 1995.
`Langberg, Mike, Show ofPotential Apple Breaks‘ New Ground by
`Displaying What '5 on its Drawing Baum’ ‘Innovation is at the Heart
`ofFl7haI We Do’, San Jose Mercury News, Aug. 7, 1996, 13. 1C.
`Anind K. Dey, ct 111., Cybem*Des1<: The Use of Perception in Context»
`Aware Computing, PUI Workshop Submission, Proc. Of 1997 Work-
`shop on Perceptual User Interfaces (PUI '97), pp. 26-27, Oct. 1997.
`Dey, Anind K,,C0r.1texz‘-Aware Computing: The CyberDe5‘kPrq;'ecr,
`Future Conzqmting Environments, AAA1 ’98 Spring Symposium,
`Stanford University, pp. 51-55. Mar. 23~2S, 1998.
`Anind K. Dey, et 21., Cj2berDe.1'/12' A Frameworkfor Providing Self-
`Integrating Conten‘-Aware Services, KnowIedge—Basea’Systems, vol.
`11, No. 1,pp. 3.13, Sep. 1998.
`L. Nancy Garrett, eta.1., Intermea’1‘a.'Issues', Strategies, and Tactics in
`the Design ofa Hyermcdia Document System, pp. 163- 174, © 1986.
`Langberg, Mike, ‘Innovation Is at the Heart ofW}1at WeDo', Apple
`Break: New Ground b