Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 1 of 14 Page ID #:1
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`
`Steven Ritcheson
`Insight, PLC
`578 Washington Boulevard #503
`Marina del Rey, California 90291
`Phone: (424) 289-9191
`swritcheson@insightplc.com
`
`Howard L. Wernow
`(pro hac vice forthcoming)
`Sand, Sebolt & Wernow Co., LPa
`Aegis Tower - Suite 1100
`4940 Munson Street, N. W.
`Canton, Ohio 44718
`Phone: (330) 244-1174
`howard.wernow@sswip.com
`
`Attorneys for Plaintiff
`FURY TECHNOLOGIES LLC
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`FURY TECHNOLOGIES LLC,
`
`
`Civil Action No.:
` Plaintiff,
`
`
`
`TRIAL BY JURY DEMANDED
` v.
`
`DJI TECHNOLOGY, INC.,
`
` Defendant.
`
`
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Now comes Plaintiff, Fury Technologies LLC (“Plaintiff” or “Fury”), by and
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`through undersigned counsel, and respectfully alleges, states, and prays as follows:
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`1
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Steven Ritcheson
`Insight, PLC
`578 Washington Boulevard #503
`Marina del Rey, California 90291
`Phone: (424) 289-9191
`swritcheson@insightplc.com
`
`Howard L. Wernow
`(pro hac vice forthcoming)
`Sand, Sebolt & Wernow Co., LPa
`Aegis Tower - Suite 1100
`4940 Munson Street, N. W.
`Canton, Ohio 44718
`Phone: (330) 244-1174
`howard.wernow@sswip.com
`
`Attorneys for Plaintiff
`FURY TECHNOLOGIES LLC
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`FURY TECHNOLOGIES LLC,
`
`
`Civil Action No.:
` Plaintiff,
`
`
`
`TRIAL BY JURY DEMANDED
` v.
`
`DJI TECHNOLOGY, INC.,
`
` Defendant.
`
`
`COMPLAINT FOR INFRINGEMENT OF PATENT
`
`Now comes Plaintiff, Fury Technologies LLC (“Plaintiff” or “Fury”), by and
`
`through undersigned counsel, and respectfully alleges, states, and prays as follows:
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`1
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 2 of 14 Page ID #:2
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement under the Patent Laws of the
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`United States, Title 35 United States Code (“U.S.C.”) to prevent and enjoin
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`Defendant DJI Technology, Inc. (hereinafter “Defendant”), from infringing and
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`profiting, in an illegal and unauthorized manner, and without authorization and/or
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`consent from Plaintiff from U.S. Patent No 8,965,598 (“the ‘598 Patent”) and U.S.
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`Patent No. 9,352,833 (“the ‘833 Patent”) (collectively the “Patents-in-Suit”), which
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`are attached hereto as Exhibits A and B, respectively, and incorporated herein by
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`reference, and pursuant to 35 U.S.C. §271, and to recover damages, attorney’s fees,
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`and costs.
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`THE PARTIES
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`2.
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`Plaintiff is a Texas limited liability company with its principal place of
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`business at 6009 West Parker Road – Suite 149-1089, Plano, Texas 75093.
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`3.
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`Upon information and belief, Defendant is a corporation organized
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`under the laws of California, having a principal place of business at 201 South
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`Victory Boulevard, Burbank, California 91502. Upon information and belief,
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`Defendant may be served with process c/o CT Corporation System, 818 West
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`Seventh Street – Suite 930, Los Angeles, California 90017.
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`4.
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`Plaintiff is further informed and believes, and on that basis alleges, that
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`Defendant operates the website enterprise.dji.com. Defendant derives a portion of
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`its revenue from sales and distribution via electronic transactions conducted on and
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 3 of 14 Page ID #:3
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`using at least, but not limited to, its Internet website located at enterprise.dji.com,
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`and its incorporated and/or related systems (collectively the “DJI Website”).
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`Plaintiff is informed and believes, and on that basis alleges, that, at all times relevant
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`hereto, Defendant has done and continues to do business in this judicial district,
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`including, but not limited to, providing products/services to customers located in
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`this judicial district by way of the DJI Website.
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`JURISDICTION AND VENUE
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`5.
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`This is an action for patent infringement in violation of the Patent Act
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`of the United States, 35 U.S.C. §§1 et seq.
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`6.
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`The Court has subject matter jurisdiction over this action pursuant to 28
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`U.S.C. §§1331 and 1338(a).
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`7.
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`This Court has personal jurisdiction over Defendant by virtue of its
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`systematic and continuous contacts with this jurisdiction and its residence in this
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`District, as well as because of the injury to Plaintiff, and the cause of action Plaintiff
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`has risen in this District, as alleged herein.
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`8.
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`Defendant is subject to this Court’s specific and general personal
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`jurisdiction pursuant to its substantial business in this forum, including: (i) at least a
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`portion of the infringements alleged herein; (ii) regularly doing or soliciting
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`business, engaging in other persistent courses of conduct, and/or deriving substantial
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`revenue from goods and services provided to individuals in this forum state and in
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`this judicial District; and (iii) being incorporated in this District.
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 4 of 14 Page ID #:4
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`9.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §1400(b)
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`because Defendant resides in this District under the Supreme Court’s opinion in TC
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`Heartland v. Kraft Foods Group Brands LLC, 137 S. Ct. 1514 (2017) through its
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`incorporation, and regular and established place of business in this District.
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`FACTUAL ALLEGATIONS
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`10. On February 24, 2015, the United States Patent and Trademark Office
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`(“USPTO”) duly and legally issued the ‘598 Patent, entitled “AUTOMATIC
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`FLIGHT CONTROL FOR UAV BASED SOLID MODELING” after a full and fair
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`examination. The ‘598 Patent is attached hereto as Exhibit A and incorporated
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`herein as if fully rewritten.
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`11. Plaintiff is presently the owner of the ‘598 Patent, having received all
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`right, title and interest in and to the ‘598 Patent from the previous assignee of
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`record. Plaintiff possesses all rights of recovery under the ‘598 Patent, including the
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`exclusive right to recover for past infringement.
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`12. To the extent required, Plaintiff has complied with all marking
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`requirements under 35 U.S.C. § 287.
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`13. The invention claimed in the ‘598 Patent comprises an automatic
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`unmanned aerial vehicle (UAV) flight control system for solid modeling.
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`14. Claim 1 of the ‘598 Patent recites an automatic aerial vehicle (UAV)
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`flight control system for solid modeling.
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`15. Claim 1 of the ‘598 Patent states:
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 5 of 14 Page ID #:5
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`“1. An automatic unmanned aerial vehicle (UAV) flight
`control system for Solid modeling, the system comprising:
`a UAV with an onboard camera;
`a controller capable of communication with a flight control
`module of the UAV, the controller configured to:
`determine an initial movement path based on an estimate
`of a structure to be modeled;
`capture images of the structure to be modeled;
`form surface hypotheses for unobserved surfaces based
`on the captured images;
`determine missing Surface information from the Surface
`hypotheses; and
`determine a least impact path for the UAV based on the
`missing Surface information and desired flight param-
`eters.” See Exhibit A.
`
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`16. Defendant commercializes, inter alia, methods that perform all the steps
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`recited in at least one claim of the ‘598 Patent. More particularly, Defendant
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`commercializes, inter alia, methods that perform all the steps recited in Claim 1 of
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`the ‘598 Patent. Specifically, Defendant makes, uses, sells, offers for sale, or
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`imports a UAV device that encompasses that which is covered by Claim 1 of the
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`‘598 Patent.
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`17. On May 31, 2016, the United States Patent and Trademark Office
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`(“USPTO”) duly and legally issued the ‘833 Patent, entitled “AUTOMATIC
`
`FLIGHT CONTROL FOR UAV BASED SOLID MODELING” after a full and fair
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`examination. The ‘833 Patent is attached hereto as Exhibit B and incorporated
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`herein as if fully rewritten.
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`5
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 6 of 14 Page ID #:6
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`18. Plaintiff is presently the owner of the ‘833 Patent, having received all
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`right, title and interest in and to the ‘833 Patent from the previous assignee of
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`record. Plaintiff possesses all rights of recovery under the ‘833 Patent, including the
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`exclusive right to recover for past infringement.
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`19. To the extent required, Plaintiff has complied with all marking
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`requirements under 35 U.S.C. § 287.
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`20. The invention claimed in the ‘833 Patent comprises an automatic
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`unmanned aerial vehicle (UAV) flight control system for solid modeling.
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`21. Claim 11 of the ‘833 Patent recites an unmanned aerial vehicle (UAV)
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`system for 3D modeling.
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`22. Claim 11 of the ‘833 Patent states:
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`“11. An unmanned aerial vehicle (UAV) system for 3D
`modeling, the system comprising:
`a UAV capable of communication with a controller, the
`UAV configured to:
`receive an initial movement path from the controller,
`wherein the initial movement path is based on an
`estimate of a structure to be modeled;
`capture one or more images of the structure to be mod-
`eled, wherein the one or more images are captured by
`one or more cameras onboard the UAV:
`transmit the captured one or more images to the control-
`ler, wherein the captured one or more images are used
`to form a surface hypotheses for unobserved surfaces,
`and wherein missing surface information is deter-
`mined from the surface hypotheses; and
`receive a least impact path for the UAV from the con-
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 7 of 14 Page ID #:7
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`troller, wherein the least impact path is based on the
`missing surface information and desired flight param-
`eters.” See Exhibit B.
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`23. Defendant commercializes, inter alia, methods that perform all the steps
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`recited in at least one claim of the ‘833 Patent. More particularly, Defendant
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`commercializes, inter alia, methods that perform all the steps recited in Claim 11 of
`
`the ‘833 Patent. Specifically, Defendant makes, uses, sells, offers for sale, or
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`imports a UAV device that encompasses that which is covered by Claim 11 of the
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`‘833 Patent.
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`DEFENDANT’S PRODUCT(S)
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`24. Defendant offers solutions, such as the “DJI Construction Solution”
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`(the “Accused System”), flight control system for solid modeling.
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`25. A non-limiting and exemplary claim chart comparing the Accused
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`System to Claim 1 of the ‘598 Patent is attached hereto as Exhibit C and is
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`incorporated herein as if fully rewritten.
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`26. As recited in Claim 1, a system, at least in internal testing and usage,
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`utilized by the Accused System practices an automatic unmanned aerial vehicle
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`(UAV) flight control system for solid modeling. See Exhibit C.
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`27. As recited in one step of Claim 1, the system, at least in internal testing
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`and usage, utilized by the Accused System comprises a UAV with an onboard
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`camera. See Exhibit C.
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 8 of 14 Page ID #:8
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`28. As recited in another step of Claim 1, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a controller capable of
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`communications with a flight control module of the UAV. See Exhibit C.
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`29. As recited in another step of Claim 1, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a controller which
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`determines an initial movement path based on an estimate of a structure to be
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`modeled. See Exhibit C.
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`30. As recited in another step of Claim 1, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a controller which
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`capture images of the structure to be modeled. See Exhibit C.
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`31. As recited in another step of Claim 1, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a controller which
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`forms surface hypotheses for unobserved surfaces based on the captured images and
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`determines missing surface information from the surface hypotheses. See Exhibit C.
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`32. As recited in another step of Claim 1, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a controller which
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`determines a least impact path for the UAV based on the missing surface
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`information and desired flight parameters. See Exhibit C.
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`33. The elements described in the preceding paragraphs are covered by at
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`least Claim 1 of the ‘598 Patent. Thus, Defendant’s use of the Accused System is
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`enabled by the method described in the ‘598 Patent.
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`8
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 9 of 14 Page ID #:9
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`34. A non-limiting and exemplary claim chart comparing the Accused
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`System to Claim 11 of the ‘833 Patent is attached hereto as Exhibit D and is
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`incorporated herein as if fully rewritten.
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`35. As recited in Claim 11, a system, at least in internal testing and usage,
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`utilized by the Accused System is an unmanned aerial vehicle (UAV) system for 3D
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`modeling. See Exhibit D.
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`36. As recited in one step of Claim 11, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a UAV capable of
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`communication with a controller. See Exhibit D.
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`37. As recited in another step of Claim 11, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a UAV which receives
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`an initial movement path from the controller wherein the initial movement path is
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`based on an estimate of a structure to be modeled. See Exhibit D.
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`38. As recited in another step of Claim 11, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a UAV which captures
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`one or more images of the structure to be modeled wherein the one or more images
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`are captured by one or more cameras onboard the UAV. See Exhibit D.
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`39. As recited in another step of Claim 11, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a UAV which
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`transmits the captured one or more images to the controller, wherein the captured
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`one or more images are used to form a surface hypotheses for unobserved surfaces,
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 10 of 14 Page ID #:10
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`and wherein missing surface information is determined from the surface hypotheses.
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`See Exhibit D.
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`40. As recited in another step of Claim 11, the system, at least in internal
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`testing and usage, utilized by the Accused System comprises a UAV which receives
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`a least impact path for the UAV from the controller, wherein the least impact path is
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`based on the missing surface information and desired flight parameters. See Exhibit
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`D.
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`41. The elements described in the preceding paragraphs are covered by at
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`least Claim 11 of the ‘833 Patent. Thus, Defendant’s use of the Accused System is
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`enabled by the method described in the ‘833 Patent.
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`INFRINGEMENT OF THE PATENTS-IN-SUIT
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`42. Plaintiff realleges and incorporates by reference all of the allegations
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`set forth in the preceding paragraphs
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`43.
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` In violation of 35 U.S.C. § 271, Defendant is now, and has been
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`directly infringing the ‘598 Patent and the ‘833 Patent.
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`44. Defendant has had knowledge of infringement of the ‘598 Patent and
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`the ‘833 Patent at least as of the service of the present Complaint.
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`45.
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` Defendant has directly infringed and continues to directly infringe at
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`least one claim of the ‘598 Patent and the ‘833 Patent by using, at least through
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`internal testing or otherwise, the Accused Product without authority in the United
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`States, and will continue to do so unless enjoined by this Court. As a direct and
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`10
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 11 of 14 Page ID #:11
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`proximate result of Defendant’s direct infringement of the ‘598 Patent and the ‘833
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`Patent, Plaintiff has been and continues to be damaged.
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`46. Defendant has induced others to infringe the ‘598 Patent and the
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`‘833Patent by encouraging infringement, knowing that the acts Defendant induced
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`constituted patent infringement, and its encouraging acts actually resulted in direct
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`patent infringement.
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`47. By engaging in the conduct described herein, Defendant has injured
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`Plaintiff and is thus liable for infringement of the ‘598 Patent and the ‘833 Patent,
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`pursuant to 35 U.S.C. § 271.
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`48. Defendant has committed these acts of infringement without license or
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`authorization.
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`49. As a result of Defendant’s infringement of the ‘598 Patent and the ‘833
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`Patent, Plaintiff has suffered monetary damages and is entitled to a monetary
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`judgment in an amount adequate to compensate for Defendant’s past infringement,
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`together with interests and costs.
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`50. Plaintiff will continue to suffer damages in the future unless
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`Defendant’s infringing activities are enjoined by this Court. As such, Plaintiff is
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`entitled to compensation for any continuing and/or future infringement up until the
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`date that Defendant is finally and permanently enjoined from further infringement.
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`51. Plaintiff reserves the right to modify its infringement theories as
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`discovery progresses in this case; it shall not be estopped for infringement
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`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 12 of 14 Page ID #:12
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`contention or claim construction purposes by the claim charts that it provides with
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`this Complaint. The claim charts depicted in Exhibits C and D are intended to
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`satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil
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`Procedure and does not represent Plaintiff’s preliminary or final infringement
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`contentions or preliminary or final claim construction positions.
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`DEMAND FOR JURY TRIAL
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`52. Plaintiff demands a trial by jury of any and all causes of action.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff prays for the following relief:
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`a. That Defendant be adjudged to have directly infringed the ‘598 Patent and
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`the ‘833 Patent either literally or under the doctrine of equivalents;
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`b. An accounting of all infringing sales and damages including, but not
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`limited to, those sales and damages not presented at trial;
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`c. That Defendant, its officers, directors, agents, servants, employees,
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`attorneys, affiliates, divisions, branches, parents, and those persons in active concert
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`or participation with any of them, be permanently restrained and enjoined from
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`directly infringing the ‘598 Patent and the ‘833 Patent;
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`d. An award of damages pursuant to 35 U.S.C. §284 sufficient to compensate
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`Plaintiff for the Defendant’s past infringement and any continuing or future
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`infringement up until the date that Defendant is finally and permanently enjoined
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`from further infringement, including compensatory damages;
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`12
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 13 of 14 Page ID #:13
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`e. An assessment of pre-judgment and post-judgment interest and costs
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`against Defendant, together with an award of such interest and costs, in accordance
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`with 35 U.S.C. §284;
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`f. That Defendant be directed to pay enhanced damages, including Plaintiff’s
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`attorneys’ fees incurred in connection with this lawsuit pursuant to 35 U.S.C. §285;
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`and
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`g. That Plaintiff be granted such other and further relief as this Court may
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`deem just and proper.
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`Dated: April 27, 2020
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`Respectfully submitted,
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`/s/
`Steven Ritcheson
`Insight, PLC
`578 Washington Boulevard #503
`Marina del Rey, California 90291
`Phone: (424) 289-9191
`swritcheson@insightplc.com
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`ATTORNEYS FOR PLAINTIFF
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`Together with:
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`SAND, SEBOLT & WERNOW CO.,
`LPA
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`Howard L. Wernow
`(pro hac vice forthcoming)
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`Aegis Tower - Suite 1100
`4940 Munson Street, N. W.
`Canton, Ohio 44718
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`13
`COMPLAINT FOR INFRINGEMENT OF PATENT
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`Case 2:20-cv-03827-SVW-RAO Document 1 Filed 04/27/20 Page 14 of 14 Page ID #:14
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`Phone: 330-244-1174
`Fax: 330-244-1173
`Email: Howard.Wernow@sswip.com
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`14
`COMPLAINT FOR INFRINGEMENT OF PATENT
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