Case 2:15-cv-01219-JRG-RSP Document 1 Filed 07/02/15 Page 1 of 15 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`PerdiemCo LLC
`
`Plaintiff,
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`v.
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`LiveViewGPS, Inc.
`
`Defendant.
`
`Docket No. 2:15-cv-1219
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`JURY TRIAL DEMANDED
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`COMPLAINT
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`Plaintiff PerdiemCo LLC (“PerDiem”) files this complaint against LiveViewGPS, Inc.
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`(“LiveViewGPS” or “Defendant”) for infringement of U.S. Patent Nos. 8,223,012 (“the ’012
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`patent”), 8,493,207 (“the ’207 patent”), 8,717,166 (“the ’166 patent”), 9,003,499 (“the ’499
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`patent”), and 9,071,931 (“the ’931 patent”) (collectively, “patents-in-suit”), hereby alleges as
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`follows:
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`Nature of the Suit
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`1.
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`This is a claim for patent infringement arising under the patent laws of the United
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`States, Title 35 of the United States Code.
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`The Parties
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`2.
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`PerDiem is a Texas limited liability company with its principal place of business
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`at 505 E Travis Street, Suite 205, Marshall, TX 75670-4258.
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`3.
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`Darrell Diem, the inventor of the patents-in-suit and Chief Technology Officer of
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`PerDiem, served in the Air Force for four years as an electronics technician. After being
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`06371.00001/6937587.1
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`honorably discharged, Mr. Diem worked his way through college to earn degrees in physics and
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`math from Marquette University. Mr. Diem also obtained a Masters of Business Administration
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`from Michigan State, and a Masters of Arts in Pastoral Ministries from St. Thomas University,
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`Miami, Florida. Mr. Diem has worked for Motorola, Harris Corporation, Time Domain, and
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`other leading technology companies. Mr. Diem currently teaches computers to students at St.
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`John the Baptist Catholic School, where he is a Deacon.
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`4.
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`Mr. Diem conceived the inventions in the patents-in-suit when his daughter’s car
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`broke down on a long road trip. Mr. Diem wanted to convey location information for his
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`daughter in an efficient way that would still protect her privacy. Mr. Diem’s inventions, which
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`have a wide range of significant applications, are widely used today.
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`5.
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`LiveViewGPS is a corporation organized and existing under the laws of the state
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`of California, with its principal place of business at 29021 Avenue Sherman, Ste. 103, Valencia,
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`CA 91355. LiveViewGPS can be served with process through its registered agent George
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`Karonis, 29021 Avenue Sherman, Ste. 103, Valencia, CA 91355.
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`6.
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`Defendant makes, uses, sells, offers for sale, and/or imports products and services
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`that infringe patents owned by PerDiem, including without limitation, the LiveView GPS
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`tracking system, the Live Trac Platform, the Live Trac GPS Tracking Platform, and the Live
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`Trac Vehicle Tracking Systems (collectively, “Accused Products”), either directly or indirectly
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`through its subsidiaries or affiliates, to customers throughout the United States, including in this
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`District.
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`Jurisdiction and Venue
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`7.
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`This Court has jurisdiction over the subject matter of this action pursuant to 28
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`U.S.C. §§ 1331 and 1338(a).
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`8.
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`Defendant maintains continuous and systematic contacts within this District by
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`selling and offering for sale products and services to customers within this District, and by
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`offering for sale products and services that are used within this District.
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`9.
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`This Court has specific personal jurisdiction over Defendant pursuant to due
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`process and the Texas Long Arm Statute because Defendant, directly or through intermediaries,
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`has conducted and conducts substantial business in this forum, including but not limited to: (i)
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`engaging in at least part of the infringing acts alleged herein; (ii) purposefully and voluntarily
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`placing one or more infringing products or services into the stream of commerce with the
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`expectation that they will be purchased and/or used by consumers in this forum; and/or (iii)
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`regularly doing or soliciting business, engaging in other persistent courses of conduct, or
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`deriving substantial revenue from goods and services provided to individuals in Texas and in this
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`District. Venue is proper in this Court under 28 U.S.C. §§ 1391(b)-(d) and 1400(b) for the
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`reasons set forth above.
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`The Patents-In-Suit
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`10.
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`The ’012 patent, entitled “System and Method for Conveying Object Location
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`Information,” was duly and legally issued by the United States Patent and Trademark Office on
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`July 17, 2012. A copy of the ’012 patent is attached hereto as Exhibit A.
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`11.
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`The ’207 patent, entitled “Location Information Sharing System and Method for
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`Conveying Location Information based on User Authorization,” was duly and legally issued by
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`the United States Patent and Trademark Office on July 23, 2013. A copy of the ’207 patent is
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`attached hereto as Exhibit B.
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`12.
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`The ’166 patent, entitled “System and Method for Conveying Location
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`Information via a Plurality of Information-Sharing Environments” was duly and legally issued by
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`the United States Patent and Trademark Office on May 6, 2014. A copy of the ’166 patent is
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`attached hereto as Exhibit C.
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`13.
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`The ’499 patent, entitled “System and Method for Conveying Event Information
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`Based on Varying Levels of Administrative Privilege Under Multiple Levels of Access Controls”
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`was duly and legally issued by the United States Patent and Trademark Office on April 7, 2015.
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`A copy of the ’499 patent is attached hereto as Exhibit D.
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`14.
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`The ’931 patent, entitled “Location Tracking System with Interfaces for Setting
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`Group Zones, Events and Alerts Based on Multiple Levels of Administrative Privileges” was
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`duly and legally issued by the United States Patent and Trademark Office on June 30, 2015. A
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`copy of the ’931 patent is attached hereto as Exhibit E.
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`15.
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`PerDiem is the exclusive owner of all rights, title, and interest in the ’012 patent,
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`the ’207 patent, the ’166 patent, the ’499 patent, and the ’931 patent, and has the right to bring
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`this suit to recover damages for any current or past infringement of these patents.
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`16.
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`The family of the patents-in-suit have been cited in other patents owned by many
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`companies in a variety of industries including, Honeywell, Bank of America, Fatdoor, EMC
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`Corporation, General Motors, Blackbird Technology, and Allure Energy.
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`Count I
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`Infringement of the ’012 Patent
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`17.
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`Paragraphs 1 through 16 are incorporated by reference as if fully stated herein.
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`18.
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`The ’012 patent is valid and enforceable.
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`19.
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`Defendant has infringed, and continues to infringe, one or more claims of the ’012
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`patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by
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`making, using, selling, and/or offering for sale in the United States, and/or importing into the
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`United States, products and/or services encompassed by those claims, including for example, by
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`making, using, selling, offering for sale, and/or importing the Accused Products.
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`20.
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`Third parties, including Defendant’s customers, have infringed, and continue to
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`infringe, one or more claims of the ’012 patent under 35 U.S.C. § 271(a), either literally and/or
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`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
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`States, and/or importing into the United States, the Accused Products.
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`21.
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`Defendant has knowledge and notice of the ’012 patent and its infringement at
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`least through the filing and service of the Complaint in this action.
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`22.
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`Defendant has induced infringement, and continues to induce infringement, of one
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`or more claims of the ’012 patent under 35 U.S.C. § 271(b). Defendant actively, knowingly, and
`
`intentionally induced, and continues to actively, knowingly, and intentionally induce,
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`infringement of the ’012 patent by selling or otherwise supplying the Accused Products with the
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`knowledge and intent that third parties will use, sell, and/or offer for sale in the United States,
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`and/or import into the United States the Accused Products for their intended purpose to infringe
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`the ’012 patent; and with the knowledge and intent to encourage and facilitate the infringement
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`through the dissemination of the Accused Products and/or the creation and dissemination of
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`documentation and technical information related to the Accused Products.
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`23.
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`Defendant has contributed to the infringement by third parties, including
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`Defendant’s customers, and continues to contribute to infringement by third parties, including
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`Defendant’s customers, of one or more claims of the ’012 patent under 35 U.S.C. § 271(c), by
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`selling and/or offering for sale in the United States and/or importing into the United States the
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`Accused Products knowing that those products constitute a material part of the inventions of the
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`’012 patent, knowing that those products are especially made or adapted to infringe the ’012
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`patent, and knowing that those products are not staple articles of commerce suitable for
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`substantial noninfringing use.
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`24.
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`PerDiem has been and continues to be damaged by Defendant’s infringement of
`
`the ’012 patent.
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`25.
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`Since having knowledge of the ’012 patent, Defendant knew or should have
`
`known that, without taking a license to the patents-in-suit, its actions continue to infringe one or
`
`more claims of the ’012 patent. Therefore, Defendant’s infringement has and will continue to be
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`willful.
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`26.
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`Defendant’s conduct in infringing the ’012 patent renders this case exceptional
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`within the meaning of 35 U.S.C. § 285.
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`Count II
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`Infringement of the ’207 Patent
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`27.
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`Paragraphs 1 through 26 are incorporated by reference as if fully stated herein.
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`28.
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`The ’207 patent is valid and enforceable.
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`29.
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`Defendant has infringed, and continues to infringe, one or more claims of the ’207
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`patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by
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`making, using, selling, and/or offering for sale in the United States, and/or importing into the
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`United States, products and/or services encompassed by those claims, including for example, by
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`making, using, selling, offering for sale, and/or importing the Accused Products.
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`30.
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`Third parties, including Defendant’s customers, have infringed, and continue to
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`infringe, one or more claims of the ’207 patent under 35 U.S.C. § 271(a), either literally and/or
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`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
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`States, and/or importing into the United States, the Accused Products.
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`31.
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`Defendant has knowledge and notice of the ’207 patent and its infringement at
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`least through the filing and service of the Complaint in this action.
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`32.
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`Defendant has induced infringement, and continue to induce infringement, of one
`
`or more claims of the ’207 patent under 35 U.S.C. § 271(b). Defendant actively, knowingly, and
`
`intentionally induced, and continues to actively, knowingly, and intentionally induce,
`
`infringement of the ’207 patent by selling or otherwise supplying the Accused Products with the
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`knowledge and intent that third parties will use, sell, and/or offer for sale in the United States,
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`and/or import into the United States the Accused Products for their intended purpose to infringe
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`the ’207 patent; and with the knowledge and intent to encourage and facilitate the infringement
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`through the dissemination of the Accused Products and/or the creation and dissemination of
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`documentation and technical information related to the Accused Products.
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`33.
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`Defendant has contributed to the infringement by third parties, including
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`Defendant’s customers, and continues to contribute to infringement by third parties, including
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`Defendant’s customers, of one or more claims of the ’207 patent under 35 U.S.C. § 271(c), by
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`selling and/or offering for sale in the United States and/or importing into the United States the
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`Accused Products knowing that those products constitute a material part of the inventions of the
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`’207 patent, knowing that those products are especially made or adapted to infringe the ’207
`
`patent, and knowing that those products are not staple articles of commerce suitable for
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`substantial noninfringing use.
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`34.
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`PerDiem has been and continues to be damaged by Defendant’s infringement of
`
`the ’207 patent.
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`35.
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`Since having knowledge of the ’207 patent, Defendant knew or should have
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`known that, without taking a license to the patents-in-suit, its actions continue to infringe one or
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`more claims of the ’207 patent. Therefore, Defendant’s infringement has and will continue to be
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`willful.
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`36.
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`Defendant’s conduct in infringing the ’207 patent renders this case exceptional
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`within the meaning of 35 U.S.C. § 285.
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`Count III
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`Infringement of the ’166 Patent
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`37.
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`Paragraphs 1 through 36 are incorporated by reference as if fully stated herein.
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`38.
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`The ’166 patent is valid and enforceable.
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`39.
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`Defendant has infringed, and continues to infringe, one or more claims of the ’166
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`patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by
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`making, using, selling, and/or offering for sale in the United States, and/or importing into the
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`United States, products and/or services encompassed by those claims, including for example, by
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`making, using, selling, offering for sale, and/or importing the Accused Products.
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`40.
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`Third parties, including Defendant’s customers, have infringed, and continue to
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`infringe, one or more claims of the ’166 patent under 35 U.S.C. § 271(a), either literally and/or
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`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
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`States, and/or importing into the United States, the Accused Products.
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`41.
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`Defendant has knowledge and notice of the ’166 patent and its infringement at
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`least through the filing and service of the Complaint in this action.
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`42.
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`Defendant has induced infringement, and continues to induce infringement, of one
`
`or more claims of the ’166 patent under 35 U.S.C. § 271(b). Defendant actively, knowingly, and
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`intentionally induced, and continues to actively, knowingly, and intentionally induce,
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`infringement of the ’166 patent by selling or otherwise supplying the Accused Products with the
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`knowledge and intent that third parties will use, sell, and/or offer for sale in the United States,
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`and/or import into the United States the Accused Products for their intended purpose to infringe
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`the ’166 patent; and with the knowledge and intent to encourage and facilitate the infringement
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`through the dissemination of the Accused Products and/or the creation and dissemination of
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`documentation and technical information related to the Accused Products.
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`43.
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`Defendant has contributed to the infringement by third parties, including
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`Defendant’s customers, and continues to contribute to infringement by third parties, including
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`Defendant’s customers, of one or more claims of the ’166 patent under 35 U.S.C. § 271(c), by
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`selling and/or offering for sale in the United States and/or importing into the United States the
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`Accused Products knowing that those products constitute a material part of the inventions of the
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`’166 patent, knowing that those products are especially made or adapted to infringe the ’166
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`patent, and knowing that those products are not staple articles of commerce suitable for
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`substantial noninfringing use.
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`44.
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`PerDiem has been and continues to be damaged by Defendant’s infringement of
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`the ’166 patent.
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`45.
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`Since having knowledge of the ’166 patent, Defendant knew or should have
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`known that, without taking a license to the patents-in-suit, its actions continue to infringe one or
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`more claims of the ’166 patent. Therefore, Defendant’s infringement has and will continue to be
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`willful.
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`46.
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`Defendant’s conduct in infringing the ’166 patent renders this case exceptional
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`within the meaning of 35 U.S.C. § 285.
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`Count IV
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`Infringement of the ’499 Patent
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`47.
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`Paragraphs 1 through 46 are incorporated by reference as if fully stated herein.
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`48.
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`The ’499 patent is valid and enforceable.
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`49.
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`Defendant has infringed, and continues to infringe, one or more claims of the ’499
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`patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by
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`making, using, selling, and/or offering for sale in the United States, and/or importing into the
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`United States, products and/or services encompassed by those claims, including for example, by
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`making, using, selling, offering for sale, and/or importing the Accused Products.
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`50.
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`Third parties, including Defendant’s customers, have infringed, and continue to
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`infringe, one or more claims of the ’499 patent under 35 U.S.C. § 271(a), either literally and/or
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`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
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`States, and/or importing into the United States, the Accused Products.
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`51.
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`Defendant has knowledge and notice of the ’499 patent and its infringement at
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`least through the filing and service of the Complaint in this action.
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`52.
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`Defendant has induced infringement, and continues to induce infringement, of one
`
`or more claims of the ’499 patent under 35 U.S.C. § 271(b). Defendant actively, knowingly, and
`
`intentionally induced, and continues to actively, knowingly, and intentionally induce,
`
`infringement of the ’499 patent by selling or otherwise supplying the Accused Products with the
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`knowledge and intent that third parties will use, sell, and/or offer for sale in the United States,
`
`and/or import into the United States the Accused Products for their intended purpose to infringe
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`the ’499 patent; and with the knowledge and intent to encourage and facilitate the infringement
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`through the dissemination of the Accused Products and/or the creation and dissemination of
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`documentation and technical information related to the Accused Products.
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`53.
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`Defendant has contributed to the infringement by third parties, including
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`Defendant’s customers, and continues to contribute to infringement by third parties, including
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`Defendant’s customers, of one or more claims of the ’499 patent under 35 U.S.C. § 271(c), by
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`selling and/or offering for sale in the United States and/or importing into the United States the
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`Accused Products knowing that those products constitute a material part of the inventions of the
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`’499 patent, knowing that those products are especially made or adapted to infringe the ’499
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`patent, and knowing that those products are not staple articles of commerce suitable for
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`substantial noninfringing use.
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`54.
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`PerDiem has been and continues to be damaged by Defendant’s infringement of
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`the ’499 patent.
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`55.
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`Since having knowledge of the ’499 patent, Defendant knew or should have
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`known that, without taking a license to the patents-in-suit, its actions continue to infringe one or
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`more claims of the ’499 patent. Therefore, Defendant’s infringement has and will continue to be
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`willful.
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`56.
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`Defendant’s conduct in infringing the ’499 patent renders this case exceptional
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`within the meaning of 35 U.S.C. § 285.
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`Count V
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`Infringement of the ’931 Patent
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`57.
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`Paragraphs 1 through 56 are incorporated by reference as if fully stated herein.
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`58.
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`The ’931 patent is valid and enforceable.
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`59.
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`Defendant has infringed, and continues to infringe, one or more claims of the ’931
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`patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by
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`making, using, selling, and/or offering for sale in the United States, and/or importing into the
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`06371.00001/6937587.1
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`United States, products and/or services encompassed by those claims, including for example, by
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`making, using, selling, offering for sale, and/or importing the Accused Products.
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`60.
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`Third parties, including Defendant’s customers, have infringed, and continue to
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`infringe, one or more claims of the ’931 patent under 35 U.S.C. § 271(a), either literally and/or
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`under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United
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`States, and/or importing into the United States, the Accused Products.
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`61.
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`Defendant has knowledge and notice of the ’931 patent and its infringement at
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`least through the filing and service of the Complaint in this action.
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`62.
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`Defendant has induced infringement, and continues to induce infringement, of one
`
`or more claims of the ’931 patent under 35 U.S.C. § 271(b). Defendant actively, knowingly, and
`
`intentionally induced, and continues to actively, knowingly, and intentionally induce,
`
`infringement of the ’931 patent by selling or otherwise supplying the Accused Products with the
`
`knowledge and intent that third parties will use, sell, and/or offer for sale in the United States,
`
`and/or import into the United States the Accused Products for their intended purpose to infringe
`
`the ’931 patent; and with the knowledge and intent to encourage and facilitate the infringement
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`through the dissemination of the Accused Products and/or the creation and dissemination of
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`documentation and technical information related to the Accused Products.
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`63.
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`Defendant has contributed to the infringement by third parties, including
`
`Defendant’s customers, and continues to contribute to infringement by third parties, including
`
`Defendant’s customers, of one or more claims of the ’931 patent under 35 U.S.C. § 271(c), by
`
`selling and/or offering for sale in the United States and/or importing into the United States the
`
`Accused Products knowing that those products constitute a material part of the inventions of the
`
`’931 patent, knowing that those products are especially made or adapted to infringe the ’931
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`06371.00001/6937587.1
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`patent, and knowing that those products are not staple articles of commerce suitable for
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`substantial noninfringing use.
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`64.
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`PerDiem has been and continues to be damaged by Defendant’s infringement of
`
`the ’931 patent.
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`65.
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`Since having knowledge of the ’931 patent, Defendant knew or should have
`
`known that, without taking a license to the patents-in-suit, its actions continue to infringe one or
`
`more claims of the ’931 patent. Therefore, Defendant’s infringement has and will continue to be
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`willful.
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`66.
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`Defendant’s conduct in infringing the ’931 patent renders this case exceptional
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`within the meaning of 35 U.S.C. § 285.
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`Prayer for Relief
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`WHEREFORE, PerDiem prays for judgment as follows:
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`A.
`
`B.
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`That Defendant has infringed each of the patents-in-suit;
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`That PerDiem be awarded all damages adequate to compensate it for Defendant’s
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`infringement of the patents-in-suit, such damages to be determined by a jury with pre-judgment
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`and post-judgment interest;
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`C.
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`D.
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`A judgment that the infringement was willful and that such damages be trebled;
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`An order permanently enjoining Defendant and its officers, agents, servants and
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`employees, privies, and all persons in concert or participation with it, from further infringement
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`of the patents-in-suit;
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`E.
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`That this case be declared an exceptional case within the meaning of 35 U.S.C.
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`§ 285 and that PerDiem be awarded attorney fees, costs, and expenses incurred in connection
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`with this action; and
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`06371.00001/6937587.1
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`Case 2:15-cv-01219-JRG-RSP Document 1 Filed 07/02/15 Page 14 of 15 PageID #: 14
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`F.
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`That PerDiem be awarded such other and further relief as this Court deems just
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`and proper.
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`Demand for Jury Trial
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`PerDiem hereby demands a trial by jury on all issues so triable.
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`Case 2:15-cv-01219-JRG-RSP Document 1 Filed 07/02/15 Page 15 of 15 PageID #: 15
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` Respectfully Submitted,
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` /s/ J. Mark Mann
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`J. Mark Mann
`State Bar No. 12926150
`Mark@TheMannFirm.com
`G. Blake Thompson
`State Bar No. 24042033
`Blake@TheMannFirm.com
`MANN | TINDEL | THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`Telephone: (903) 657-8540
`Facsimile: (903) 657-6003
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`Alan L. Whitehurst
`Marissa R. Ducca
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`777 6th Street, NW 11th Floor
`Washington, DC 20001
`Telephone: 202-538-8000
`Facsimile: 202-538-8100
`alanwhitehurst@quinnemanuel.com
`marissaducca@quinnemanuel.com
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`Attorneys for PerdiemCo LLC
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`DATED: July 2, 2015
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`06371.00001/6937587.1
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`15
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