Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 1 of 13 Page ID #:1
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`
`Randall J. Sunshine (SBN 137363)
`rsunshine@linerlaw.com
`Ryan E. Hatch (SBN 235577)
`rhatch@linerlaw.com
`Jason L. Haas (SBN 217290)
`jhaas@linerlaw.com
`LINER LLP
`1100 Glendon Avenue, 14th Floor
`Los Angeles, California 90024.3503
`Telephone: (310) 500-3500
`Facsimile:
`(310) 500-3501
`
`Attorneys for Plaintiff
`SIGNAL IP, INC.
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
` Case No. 14-cv-3113
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
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`JURY TRIAL DEMANDED
`
`Plaintiff,
`
`SIGNAL IP, INC., a California
`corporation,
`
`
`vs.
`
`VOLKSWAGEN GROUP OF
`AMERICA, INC., d/b/a. AUDI OF
`AMERICA, INC., a New Jersey
`corporation; AUDI OF AMERICA,
`LLC, a Delaware limited liability
`company; BENTLEY MOTORS, INC.,
`a Delaware Corporation,
`
`Defendants.
`
`
`
`
`Plaintiff Signal IP, Inc. (“Signal IP” or “Plaintiff”) brings this Complaint
`against Defendants Volkswagen Group of America, Inc., d/b/a Audi of America,
`Inc., Audi of America, LLC, and Bentley Motors, Inc. (collectively, “Defendants”),
`alleging as follows:
`
`PARTIES
`Plaintiff Signal IP is a California corporation with its principal place of
`1.
`business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025.
`On information and belief, Defendant Volkswagen Group of America,
`2.
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Case No. 14-cv-3113
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 2 of 13 Page ID #:2
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`Inc., d/b/a Audi of America, Inc. is a New Jersey corporation with its principal place
`of business at 2200 Ferdinand Porsche Drive, Herndon, VA 20171.
`On information and belief, Defendant Audi of America, LLC is a
`3.
`Delaware limited liability company with its principal place of business at 2200
`Ferdinand Porsche Drive, Herndon, VA 20171.
`On information and belief, Defendant Bentley Motors, Inc. is a
`4.
`Delaware corporation with its principal place of business at 2200 Ferdinand Porsche
`Drive, Herndon, VA 20171.
`On information and belief, Defendants are part of an integrated
`5.
`automotive group that manufactures and distributes cars under brand names
`including “Audi”, “Volkswagen”, and “Bentley.”
`JURISDICTION, VENUE AND JOINDER
`This action arises under the patent laws of the United States, Title 35 of
`6.
`the United States Code. This Court has subject matter jurisdiction pursuant to 28
`U.S.C. §§ 1331 and 1338(a).
`This Court has personal jurisdiction over Defendants. Defendants have
`7.
`conducted extensive commercial activities and continue to conduct extensive
`commercial activities within the State of California. Defendants are registered to do
`business in California. Additionally, on information and belief, Defendants, directly
`and/or through intermediaries (including Defendants’ entities, subsidiaries,
`distributors, sales agents, partners and others), distribute, offer for sale, sell, and/or
`advertise their products (including but not limited to the products and services that
`are accused of infringement in this lawsuit) in the United States, in the State of
`California, and in this judicial district, under the “Audi”, “Volkswagen”, and
`“Bentley” brand names. Defendants have purposefully and voluntarily placed one
`or more of their infringing products and services into the stream of commerce with
`the expectation that the products and services will be purchased or used by
`customers in California and within this judicial district. Accordingly, Defendants
`Case No. 14-cv-3113
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 3 of 13 Page ID #:3
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`have infringed Signal IP’s patents within the State of California and in this judicial
`district as alleged in more detail below.
`Venue is proper in this district under 28 U.S.C. §§ 1391 and 1400(b).
`8.
`BACKGROUND
`Signal IP, Inc. is a California corporation with a principal place of
`9.
`business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. It is the
`owner of the entire right, title and interest in and to U.S. Patent Nos. 5,714,927;
`5,732,375; 5,954,775; 6,434,486; 6,775,601; and 6,012,007 (the “Patents-in-Suit”).
`10. On information and belief, Defendants are direct or indirect
`subsidiaries of global car manufacturer and distributor Volkswagen AG, which is
`headquartered in Germany. Volkswagen AG manufactures and distributes cars
`under brand names including “Audi”, “Volkswagen”, and “Bentley.”
`FIRST CLAIM FOR RELIEF
`(Infringement of the ‘927 Patent)
`11. Plaintiff incorporates paragraphs 1 through 10 of this complaint as if set
`forth in full herein.
`12. Signal IP is the owner of the entire right, title, and interest in and to
`U.S. Patent No. 5,714,927 (the ‘927 Patent), entitled “Method of Improving Zone of
`Coverage Response of Automotive Radar.” The ‘927 Patent was duly and legally
`issued by the U.S. Patent and Trademark Office on February 3, 1998. A true and
`correct copy of the ‘927 Patent is attached as Exhibit A.
`13. Defendants have directly infringed and continue to infringe, literally
`and/or under the doctrine of equivalents, the ‘927 Patent by making, using, offering
`for sale, and/or selling in the United States certain methods or systems disclosed and
`claimed in the ‘927 Patent, including but not limited to the Side Assist system, used
`in products including but not limited to the Audi A3, A4, A4 Allroad, A4
`Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet, S6,
`S7, S8, SQ5, RS5, and RS7, and the Volkswagen CC, Touareg, Phaeton, and
`Case No. 14-cv-3113
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 4 of 13 Page ID #:4
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`Touareg Hybrid.
`14. Defendants have contributorily infringed and are currently
`contributorily infringing the ‘927 Patent by making, using, offering for sale, and/or
`selling in the United States certain methods or systems disclosed and claimed in the
`‘927 Patent, including but not limited to the Side Assist system, used in products
`including but not limited to the Audi A3, A4, A4 Allroad, A4 Sedan/Avant, A5, A6,
`A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet, S6, S7, S8, SQ5, RS5, and
`RS7, and the Volkswagen CC, Touareg, Phaeton, and Touareg Hybrid.
`15. Defendants have actively induced and are actively inducing the
`infringement of the ‘927 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems disclosed and claimed in the ‘927
`Patent, including but not limited to the Side Assist system, used in products
`including but not limited to the Audi A3, A4, A4 Allroad, A4 Sedan/Avant, A5, A6,
`A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet, S6, S7, S8, SQ5, RS5, and
`RS7, and the Volkswagen CC, Touareg, Phaeton, and Touareg Hybrid.
`16. Defendants’ infringement of the ‘927 Patent has been and continues to
`be willful, rendering this case exceptional within the meaning of 35 U.S.C. § 285.
`17. Unless enjoined by this Court, Defendants will continue to infringe the
`‘927 Patent.
`18. As a direct and proximate result of the Defendants’ conduct, Plaintiff
`has suffered, and will continue to suffer, irreparable injury for which it has no
`adequate remedy at law. Plaintiff also has been damaged and, until an injunction
`issues, will continue to be damaged in an amount yet to be determined.
`SECOND CLAIM FOR RELIEF
`(Infringement of the ‘375 Patent)
`19. Plaintiff incorporates paragraphs 1 through 18 of this complaint as if set
`forth in full herein.
`20. Signal IP is the owner of the entire right, title, and interest in and to
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`COMPLAINT FOR PATENT INFRINGEMENT
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`U.S. Patent No. 5,732,375 (the ‘375 Patent), entitled “Method of Inhibiting or
`Allowing Airbag Deployment.” The ‘375 Patent was duly and legally issued by the
`U.S. Patent and Trademark Office on March 24, 1998. A true and correct copy of
`the ‘375 Patent is attached as Exhibit B.
`21. Defendants have directly infringed and continue to infringe, literally
`and/or under the doctrine of equivalents, the ‘375 Patent by making, using, offering
`for sale, and/or selling in the United States certain methods or systems disclosed and
`claimed in the ‘375 Patent, including but not limited to the Seat Occupancy Sensor,
`used in products including but not limited to the Audi A6 and S6.
`22. Defendants have contributorily infringed and are currently
`contributorily infringing the ‘375 Patent by making, using, offering for sale, and/or
`selling in the United States certain methods or systems disclosed and claimed in the
`‘375 Patent, including but not limited to the Seat Occupancy Sensor, used in
`products including but not limited to the Audi A6 and S6.
`23. Defendants have actively induced and are actively inducing the
`infringement of the ‘375 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems disclosed and claimed in the ‘375
`Patent, including but not limited to the Seat Occupancy Sensor, used in products
`including but not limited to the Audi A6 and S6.
`24. Defendants’ infringement of the ‘375 Patent has been and continues to
`be willful, rendering this case exceptional within the meaning of 35 U.S.C. § 285.
`25. Unless enjoined by this Court, Defendants will continue to infringe the
`‘375 Patent.
`26. As a direct and proximate result of the Defendants’ conduct, Plaintiff
`has suffered, and will continue to suffer, irreparable injury for which it has no
`adequate remedy at law. Plaintiff also has been damaged and, until an injunction
`issues, will continue to be damaged in an amount yet to be determined.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case No. 14-cv-3113
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`THIRD CLAIM FOR RELIEF
`(Infringement of the ‘486 Patent)
`27. Plaintiff incorporates paragraphs 1 through 26 of this complaint as if set
`forth in full herein.
`28. Signal IP is the owner of the entire right, title, and interest in and to
`U.S. Patent No. 6,434,486 (the ‘486 Patent), entitled “Technique for Limiting the
`Range of an Object Sensing System in a Vehicle.” The ‘486 Patent duly and legally
`issued by the U.S. Patent and Trademark Office on August 13, 2002. A true and
`correct copy of the ‘486 Patent is attached as Exhibit C.
`29. Defendants have directly infringed and continue to infringe, literally
`and/or under the doctrine of equivalents, the ‘486 Patent by making, using, offering
`for sale, and/or selling in the United States certain methods or systems disclosed and
`claimed in the ‘486 Patent, including but not limited to collision prevention or
`avoidance systems, including but not limited to the (1) Adaptive Cruise Control
`system, used in products including but not limited to the Audi A3, A4, A4 Allroad,
`A4 Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet,
`S6, S7, S8, and SQ5; and (2) the Front Assist system, used in products including but
`not limited to the Volkswagen CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan,
`Jetta SportWagen, Passat Sedan, Passat Wagon, Touareg, Jetta Hybrid, Phaeton, and
`Touareg Hybrid.
`30. Defendants have contributorily infringed and are currently
`contributorily infringing the ‘486 Patent by making, using, offering for sale, and/or
`selling in the United States certain methods or systems disclosed and claimed in the
`‘486 Patent, including but not limited to collision prevention or avoidance systems,
`including but not limited to the (1) Adaptive Cruise Control system, used in
`products including but not limited to the Audi A3, A4, A4 Allroad, A4
`Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet, S6,
`S7, S8, and SQ5; and (2) the Front Assist system, used in products including but not
`Case No. 14-cv-3113
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`limited to the Volkswagen CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan, Jetta
`SportWagen, Passat Sedan, Passat Wagon, Touareg, Jetta Hybrid, Phaeton, and
`Touareg Hybrid.
`31. Defendants have actively induced and are actively inducing the
`infringement of the ‘486 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems disclosed and claimed in the ‘486
`Patent, including but not limited to collision prevention or avoidance systems,
`including but not limited to the (1) Adaptive Cruise Control system, used in
`products including but not limited to the Audi A3, A4, A4 Allroad, A4
`Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, Q5 Hybrid, S4, S5, S5 Cabriolet, S6,
`S7, S8, and SQ5; and (2) the Front Assist system, used in products including but not
`limited to the Volkswagen CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan, Jetta
`SportWagen, Passat Sedan, Passat Wagon, Touareg, Jetta Hybrid, Phaeton, and
`Touareg Hybrid.
`32. Defendants’ infringement of the ‘486 Patent has been and continues to
`be willful, rendering this case exceptional within the meaning of 35 U.S.C. § 285.
`33. Unless enjoined by this Court, Defendants will continue to infringe the
`‘486 Patent.
`34. As a direct and proximate result of the Defendants’ conduct, Plaintiff
`has suffered, and will continue to suffer, irreparable injury for which it has no
`adequate remedy at law. Plaintiff also has been damaged and, until an injunction
`issues, will continue to be damaged in an amount yet to be determined.
`FOURTH CLAIM FOR RELIEF
`(Infringement of the ‘601 Patent)
`35. Plaintiff incorporates paragraphs 1 through 34 of this complaint as if set
`forth in full herein.
`36. Signal IP is the owner of the entire right, title, and interest in and to
`U.S. Patent No. 6,775,601 (the ‘601 Patent), entitled “Method and Control System
`Case No. 14-cv-3113
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 8 of 13 Page ID #:8
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`for Controlling Propulsion in a Hybrid Vehicle.” The ‘601 Patent was duly and
`legally issued by the U.S. Patent and Trademark Office on August 10, 2004. A true
`and correct copy of the ‘601 Patent is attached as Exhibit D.
`37. Defendants have directly infringed and continue to infringe, literally
`and/or under the doctrine of equivalents, the ‘601 Patent by making, using, offering
`for sale, and/or selling in the United States certain methods or systems for hybrid
`vehicles disclosed and claimed in the ‘601 Patent, including but not limited to the
`Audi Q5 Hybrid, and the Volkswagen Jetta Hybrid and Touareg Hybrid.
`38. Defendants have contributorily infringed and are currently
`contributorily infringing the ‘601 Patent by making, using, offering for sale, and/or
`selling in the United States certain methods or systems disclosed and claimed in the
`‘601 Patent, including but not limited to the Audi Q5 Hybrid, and the Volkswagen
`Jetta Hybrid and Touareg Hybrid.
`39. Defendants have actively induced and are actively inducing the
`infringement of the ‘601 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems disclosed and claimed in the ‘601
`Patent, including but not limited to the Audi Q5 Hybrid, and the Volkswagen Jetta
`Hybrid and Touareg Hybrid.
`40. Defendants’ infringement of the ‘601 Patent has been and continues to
`be willful, rendering this case exceptional within the meaning of 35 U.S.C. § 285.
`41. Unless enjoined by this Court, Defendants will continue to infringe on
`the ‘601 Patent.
`42. As a direct and proximate result of the Defendants’ conduct, Plaintiff
`has suffered, and will continue to suffer, irreparable injury for which it has no
`adequate remedy at law. Plaintiff also has been damaged and, until an injunction
`issues, will continue to be damaged in an amount yet to be determined.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`FIFTH CLAIM FOR RELIEF
`(Infringement of the ‘007 Patent)
`43. Plaintiff incorporates paragraphs 1 through 42 of this complaint as if set
`forth in full herein.
`44. Signal IP is the owner of the entire right, title, and interest in and to
`U.S. Patent No. 6,012,007 (the ‘007 Patent), entitled “Occupant Detection Method
`and Apparatus for Air Bag System.” The ‘007 Patent was duly and legally issued by
`the U.S. Patent and Trademark Office on January 4, 2000. A true and correct copy
`of the ‘007 Patent is attached as Exhibit E.
`45. Defendants have directly infringed and continue to infringe, literally
`and/or under the doctrine of equivalents, the ‘007 Patent by making, using, offering
`for sale, and/or selling in the United States certain methods or systems disclosed and
`claimed in the ‘007 Patent, including but not limited to the Passenger Occupant
`Detection system, used in products including but not limited to the Audi A3, A4, A4
`Allroad, A4 Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, R8, TT, Q5 Hybrid, S4, S5,
`S5 Cabriolet, S6, S7, S8, and SQ5, and the Volkswagen Beetle, Beetle Convertible,
`Beetle Coupe, CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan, Jetta
`SportWagen, Passat Sedan, Passat Wagon, Tiguan, Touareg, Jetta Hybrid, and
`Touareg Hybrid.
`46. Defendants have contributorily infringed and are currently
`contributorily infringing the ‘007 Patent by making, using, offering for sale, and/or
`selling in the United States certain methods or systems disclosed and claimed in the
`‘007 Patent, including but not limited to the Passenger Occupant Detection system,
`used in products including but not limited to the Audi A3, A4, A4 Allroad, A4
`Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, R8, TT, Q5 Hybrid, S4, S5, S5
`Cabriolet, S6, S7, S8, and SQ5, and the Volkswagen Beetle, Beetle Convertible,
`Beetle Coupe, CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan, Jetta
`SportWagen, Passat Sedan, Passat Wagon, Tiguan, Touareg, Jetta Hybrid, and
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 10 of 13 Page ID #:10
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`Touareg Hybrid.
`47. Defendants have actively induced and are actively inducing the
`infringement of the ‘007 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems disclosed and claimed in the ‘007
`Patent, including but not limited to the Passenger Occupant Detection system, used
`in products including but not limited to the Audi A3, A4, A4 Allroad, A4
`Sedan/Avant, A5, A6, A7, A8, Q3, Q5, Q7, R8, TT, Q5 Hybrid, S4, S5, S5
`Cabriolet, S6, S7, S8, and SQ5, and the Volkswagen Beetle, Beetle Convertible,
`Beetle Coupe, CC, Eos, Golf, Golf GTI, Golf R, Jetta, Jetta Sedan, Jetta
`SportWagen, Passat Sedan, Passat Wagon, Tiguan, Touareg, Jetta Hybrid, and
`Touareg Hybrid.
`48. Defendants’ infringement of the ‘007 Patent has been and continues to
`be willful, rendering this case exceptional within the meaning of 35 U.S.C. § 285.
`49. Unless enjoined by this Court, Defendants will continue to infringe on
`the ‘007 Patent.
`50. As a direct and proximate result of the Defendants’ conduct, Plaintiff
`has suffered, and will continue to suffer, irreparable injury for which it has no
`adequate remedy at law. Plaintiff also has been damaged and, until an injunction
`issues, will continue to be damaged in an amount yet to be determined.
`SIXTH CLAIM FOR RELIEF
`(Infringement of the ‘775 Patent)
`51. Plaintiff incorporates paragraphs 1 through 50 of this complaint as if set
`forth in full herein.
`52. Signal IP is the owner of the entire right, title, and interest in and to
`U.S. Patent No. 5,954,775 (the ‘775 Patent), entitled “Dual Rate Communication
`Protocol.” The ‘775 Patent was duly and legally issued by the U.S. Patent and
`Trademark Office on September 21, 1999. A true and correct copy of the ‘775
`Patent is attached as Exhibit G.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`53. Defendants have directly infringed, literally and/or under the doctrine
`of equivalents, the ‘775 Patent by making, using, offering for sale, and/or selling in
`the United States certain methods or systems for vehicles disclosed and claimed in
`the ‘775 Patent, including but not limited to the FlexRay communication protocol,
`used in products including but not limited to the Audi A6, A7, and A8, and the
`Bentley Continental GT and Continential GTC.
`54. Defendants have contributorily infringed the ‘775 Patent by making,
`using, offering for sale, and/or selling in the United States certain methods or
`systems disclosed and claimed in the ‘775 Patent, including but not limited to the
`FlexRay communication protocol, used in products including but not limited to the
`Audi A6, A7, and A8, and the Bentley Continental GT and Continential GTC.
`55. Defendants have actively induced infringement of the ‘775 Patent by
`making, using, offering for sale, and/or selling in the United States certain methods
`or systems disclosed and claimed in the ‘775 Patent, including but not limited to the
`FlexRay communication protocol, used in products including but not limited to the
`Audi A6, A7, and A8, and the Bentley Continental GT and Continential GTC.
`56. As a direct and proximate result of Defendants’ conduct, Plaintiff has
`suffered irreparable injury for which it has no adequate remedy at law. Plaintiff also
`has been damaged in an amount yet to be determined.
`PRAYER FOR RELIEF
`Wherefore, Signal IP respectfully requests that the Court enter judgment
`against Defendants as follows:
`That Defendants have directly infringed the Patents-in-Suit;
`1.
`2.
`That Defendants have contributorily infringed the Patents-in-Suit;
`3.
`That Defendants have induced the infringement of the Patents-in-Suit;
`4.
`That Defendants’ infringement be adjudged willful and deliberate;
`5.
`That Defendants and their affiliates, subsidiaries, officers, directors,
`employees, agents, representatives, successors, assigns, and all those acting in
`Case No. 14-cv-3113
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`11
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 12 of 13 Page ID #:12
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`concert, participation, or privity with them or on their behalf, including customers,
`be enjoined from infringing, inducing others to infringe or contributing to the
`infringement of the Patents-in-Suit;
`For damages, according to proof, for Defendants’ infringement,
`6.
`together with pre-judgment and post-judgment interest, as allowed by law and that
`such damages be trebled as provided by 35 U.S.C. § 284;
`That this Court determine that this is an exceptional case under 35
`7.
`U.S.C. § 285 and an award of attorneys’ fees and costs to Signal IP is warranted;
`and
`
`For such other and further relief as the Court may deem just and proper.
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`LINER LLP
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`By:
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`/s/ Ryan E. Hatch
`Randall J. Sunshine
`Ryan E. Hatch
`Jason L. Haas
`Attorneys for Plaintiff SIGNAL IP, INC.
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`8.
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`Dated: April 23, 2014
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`12
`COMPLAINT FOR PATENT INFRINGEMENT
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`Case No. 14-cv-3113
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`Case 2:14-cv-03113-JAK-JEM Document 1 Filed 04/23/14 Page 13 of 13 Page ID #:13
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`JURY DEMAND
`Pursuant to Federal Rules of Civil Procedure Rule 38(b), Plaintiff Signal
`
`IP, Inc. respectfully demands a jury trial on any and all issues triable as of right
`by a jury in this action.
`
`Dated: April 23, 2014
`
`LINER LLP
`
`By:
`
`/s/ Ryan E. Hatch
`Randall J. Sunshine
`Ryan E. Hatch
`Jason L. Haas
`Attorneys for Plaintiff SIGNAL IP, INC.
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Case No. 14-cv-3113
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