`
`VENABLE LLP
`Frank C. Cimino, Jr. (pro hac vice)
`FCCimino@venable.com
`Megan S. Woodworth (pro hac vice)
`MSWoodworth@venable.com
`Charles J. Monterio, Jr. (pro hac vice)
`CJMonterio@venable.com
`600 Massachusetts Ave., NW
`Washington, D.C. 20001
`Telephone: (202) 344-4000
`Facsimile: (202) 344-8300
`
`William A. Hector (SBN 298490)
`wahector@venable.com
`101 California Street, Suite 3800
`San Francisco, CA 94111
`Telephone: (415) 653-3750
`Facsimile: (415) 653-3755
`
`Attorneys for Plaintiff
`Viavi Solutions Inc.
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
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`VIAVI SOLUTIONS INC.,
`
`Case No. 3:19-cv-07578
`
`Plaintiff,
`
`v.
`
`OPTRONTEC INC., LG INNOTEK CO.,
`LTD., LG ELECTRONICS, INC., and LG
`ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`COMPLAINT
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`DEMAND FOR JURY TRIAL
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`COMPLAINT
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`Plaintiff Viavi Solutions Inc. (“Viavi”) hereby makes this complaint against
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`Defendants Optrontec Inc. (“Optrontec”), LG Innotek Co., Ltd. (“LG Innotek”), LG
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`Electronics, Inc. (“LG Electronics”), and LG Electronics U.S.A., Inc. (“LG Electronics USA”)
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`(LG Innotek, LG Electronics and LG Electronics USA will collectively be referred to as the
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`“LG Defendants” and all defendants will be referred to as “Defendants”) as follows:
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`CASE NO. 3:19-cv-07578
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`-1-
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`COMPLAINT
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`101 CALIFORNIA STREET, SUITE 3800
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`VENABLE LLP
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`SAN FRANCISCO, CA94111
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`415.653.3750
`
`
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 2 of 10
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`NATURE OF ACTION
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`1.
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`This is a patent infringement action. Viavi seeks damages and injunctive relief
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`for Defendants’ infringement of Viavi’s patented technology in the United States.
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`INTRADISTRICT ASSIGNMENT
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`2.
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`This is an Intellectual Property action and shall be assigned on a district-wide
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`basis pursuant to Civil L.R. 3-2(c) and this Court’s Assignment Plan.
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`FACTUAL BACKGROUND
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`3.
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`Viavi, formerly part of JDS Uniphase Corporation, is a pioneer and world leader
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`in the fields of three-dimensional (3D) motion sensing technology, light management, and
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`optical coatings, among others.
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`4.
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`The inventions disclosed in U.S. Patent Nos. 9,588,269 (“the ’269 patent”),
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`9,945,995 (“the ’995 patent”), and 10,222,526 (“the ’526 patent”) (collectively “the Asserted
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`Patents”) (Exhibits 1-3) and exemplified in Viavi’s state-of the art optical filters are indicative of
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`Viavi’s status as a world leader in 3D motion sensing technology.
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`5.
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`In a typical gesture-recognition system, a light source emits near-infrared light
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`towards a user. An optical filter is used to transmit the emitted light that is reflected by the user
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`to the 3D image sensor, while substantially blocking ambient light. A 3D image sensor then
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`detects the emitted light to provide a 3D image of the user. A processing system then analyzes
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`the 3D image to recognize a gesture made by the user.
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`6.
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`The inventors of the Asserted Patents conceived of a superior optical filter for
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`such a use. The patented filter design provides a deep suppression of unwanted ambient light, so
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`that the filters can be used under a wide variety of extreme light conditions. The patented filter
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`design uses hydrogenated silicon material (which has a relatively high refractive index over the
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`near-infrared wavelength range) to achieve superior optical performance, a desired reduction in
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`filter thickness, and a reduced center wavelength shift with a change in incidence angle. Viavi
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`has invested years of research and development into its 3D motion sensing technology, and has
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`been awarded several related patents, including the Asserted Patents, for its efforts.
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`CASE NO. 3:19-cv-07578
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`-2-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 3 of 10
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`7.
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`As described in the Asserted Patents, Viavi’s filter design offers improvements
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`over those previously known in the art. For example, it uses less layers, has thinner coatings and
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`therefore costs less to produce and is smaller in size than prior filters. In addition, the reduction
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`in center wavelength shift helps to reduce light transmission outside of the filter’s designed
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`passband, thereby increasing signal to noise ratios allowing for better system performance.
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`8.
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`Based on these inventions, Viavi was the first company to offer a commercial
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`optical filter using hydrogenated silicon for 3D motion sensing. Viavi has enjoyed significant
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`commercial success with its patented filter design, and that success is reflective of the electronic
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`consumer product industry recognizing and replicating features of Viavi’s patented technology.
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`In fact, Viavi’s innovative optical filters won the 2017 Fierce Innovation Award for the Telecom
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`category, which seeks to recognize “groundbreaking solutions” and “the most evolutionary and
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`revolutionary technologies” in the industry. Exhibit 4. Through multiple generations of
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`increasing performance and decreasing cost, Viavi has remained the industry’s leading supplier
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`of high-performance filters for motion sensing systems in consumer electronics.
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`9.
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`Mobile device manufacturers like LG Electronics, and its suppliers including LG
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`Innotek and Optrontec, have incorporated Viavi’s patented filter design into their optical filters
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`to produce high-end mobile phones featuring facial and gesture recognition technology.
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`LG DEFENDANTS’ INFRINGING PRODUCTS
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`10.
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` On information and belief, LG Electronics and LG Electronics USA makes, uses,
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`offers for sale, sells, and imports into the United States, mobile phones such as at least the LG
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`G8 ThinQ mobile phone with 3D motion sensing and gesture recognition modules that include
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`the patented technology.
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`11.
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`On information and belief, LG Electronics’ G8 ThinQ mobile phone contains 3D
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`camera modules made by LG Innotek, which include optical filters supplied by Optrontec.
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`12.
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`LG Innotek has publicly referred to its 3D application in its 3D module as “Time
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`of Flight” or “ToF,” and has publicly stated that LG Electronics’ G8ThinQ mobile phone would
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`house its ToF 3D module to implement gesture recognition technology. Exhibit 5.
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`CASE NO. 3:19-cv-07578
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`-3-
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 4 of 10
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`OPTRONTEC’S INFRINGING OPTICAL FILTER
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`13.
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`On information and belief, LG Innotek sources the optical filters for its 3D
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`module from Optrontec. Exhibit 6. Optrontec itself has publicly stated it is “the only producer
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`of bandpass filters for 3D sensing using the ToF method” and it “has the only 3D sensing filter
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`production technology in Korea,” where LG Electronics’ G8 ThinQ mobile phone and its
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`components are manufactured. Exhibits 7, 8, and 9. According to Optrontec, its “camera image
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`sensor filter (IR filter) and optical lenses are sold to global smartphone manufacturers such as
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`Samsung Electronics and LG Electronics” (Exhibit 7), and it is the “exclusive supplier of the
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`optical filter to Samsung and LG Electronics.” Exhibit 6.
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`14.
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`On information and belief, Defendants knew or were willfully blind to the
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`Asserted Patents and of the infringing nature of the Optrontec filters discussed in more detail
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`below, in view of the ongoing litigation between Viavi and Optrontec concerning infringement
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`of foreign counterparts to the Asserted Patents in the Republic of Korea (Case No. 2019 KaHap
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`514417).
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`PARTIES
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`15.
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`Viavi is a Delaware corporation with its principal place of business and
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`headquarters in this District at 6001 America Center Drive, Sixth Floor, San Jose, California
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`95002. Viavi also maintains its state-of-the-art research and development facility and a major
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`production facility in this District in Santa Rosa, California.
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`16.
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`On information and belief, Optrontec is a company organized under the laws of
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`the Republic of Korea, with its principal place of business and headquarters located at 19-15
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`Pyeongsan-ro 8beon-gil, Uichang-gu, Changwon, Gyeongnam, 51398, Republic of Korea.
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`17.
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`On information and belief, LG Electronics is a Korean corporation with its
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`principal place of business and headquarters located at LG Electronics Twin Towers, 128 Yeoui-
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`daero, Yeongdeungpo-gu, Seoul 07336, Republic of Korea.
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`18.
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`On information and belief, LG Electronics USA, which is a wholly owned
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`subsidiary of LG Electronics, is a Delaware corporation with its principal place of business and
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`headquarters located at 1000 Sylvan Avenue, Englewood Cliffs, NJ 07632. LG Electronics USA
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`CASE NO. 3:19-cv-07578
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`-4-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 5 of 10
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`is in the business of, among other things, marketing mobile phones including the LG G8 ThinQ
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`mobile phones in the United States, and providing sales and marketing support for those phones
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`in the United States on behalf of LG Electronics. To aid with its mission, LG Electronics USA
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`operates the LG Silicon Valley Lab in this District, which according to LG Electronics USA is
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`focused on LG Electronics’ next generation of consumer electronic products. Exhibit 10.
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`19.
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`On information and belief, LG Innotek is a Korean corporation with its principal
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`place of business and headquarters located at 17F, LG Seoulstation Bldg., 98 Huam-ro, Jung-gu,
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`Seoul, 04637 Republic of Korea. On information and belief, LG Electronics is the parent and
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`majority shareholder of LG Innotek.
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`JURISDICTION AND VENUE
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`20.
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`This action arises under the United States Patent Act, codified at 35 U.S.C. § 1 et
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`seq., and in particular, 35 U.S.C. §§ 271 and 281-285.
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`21.
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`This Court has original jurisdiction over the subject matter of this action under 28
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`U.S.C. §§ 1331 and 1338(a) because the claims arise under the patent laws of the United States.
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`22.
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`This Court has personal jurisdiction over LG Electronics USA because it has the
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`minimum contacts with this District such that the exercise of jurisdiction over them would not
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`offend traditional notions of fair play and substantial justice. LG Electronics USA is present
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`within California and this District, conducts regular and systematic business in California and
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`this District, has purposefully availed itself of the privileges of conducting business in California
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`and this District, has transacted and continues to transact business in this District, has committed
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`acts of infringement in this District, continues to commit acts of infringement in this District, and
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`Viavi’s cause of action arises directly from LG Electronics USA’s contacts and activities in
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`California and this District.
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`23.
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`Venue is proper for LG Electronics USA under 28 U.S.C. §§ 1391(b), 1391(c),
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`and 1400(b) because LG Electronics USA has a regular and established place of business in this
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`District. It also has transacted and continues to transact business in this District, advertise and
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`solicit business in this District, and has committed and continues to commit acts of infringement
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`in this District.
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`CASE NO. 3:19-cv-07578
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`-5-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 6 of 10
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`24.
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`This Court has personal jurisdiction over Optrontec, LG Innotek, and LG
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`Electronics because they deliver goods (e.g., the optical filters, camera modules and mobile
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`phones) into the stream of commerce with the expectation that those goods will be offered for
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`sale and sold in the United States generally and in California and this District specifically. In
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`other words, Optrontec sold its optical filter to LG Innotek with the expectation that LG Innotek
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`would combine it into LG Innotek’s 3D module, which would then be incorporated by LG
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`Electronics into the LG G8 ThinQ mobile phone with the expectation and knowledge – by all of
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`the foreign Defendants – that the mobile phone would be offered for sale and sold in the United
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`States generally and in California and this District specifically. By knowingly putting the mobile
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`phone into the stream of commerce in this District, Optrontec, LG Innotek, and LG Electronics
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`have purposefully availed themselves of the privileges of conducting business in the United
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`States, California and this District, and sought the protection and benefits from the laws of the
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`United States and California and thus have subjected themselves to personal jurisdiction here.
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`25.
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`This Court also has personal jurisdiction over LG Electronics because it operates
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`in concert and exercises such control over the activities of LG Electronics USA that LG
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`Electronics has purposefully availed itself to California and this District through acting as LG
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`Electronics USA’s alter ego, who is subject to personal jurisdiction in this District.
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`26.
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`This Court has venue over Optrontec, LG Innotek, and LG Electronics under 28
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`U.S.C. § 1391 because, among other reasons, Optrontec, LG Innotek, and LG Electronics are
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`foreign corporations that do not reside in the United States and therefore may be sued in any
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`United States judicial district, including this District.
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`FIRST CLAIM FOR RELIEF
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`(Infringement of U.S. Patent No. 9,588,269)
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`27.
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`Viavi incorporates by reference the allegations contained in paragraphs 1 through
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`26 above.
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`28.
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`The ’269 patent entitled “Optical Filter and Sensor System” issued on March 7,
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`2017. A copy of the ’269 patent is attached as Exhibit 1. Viavi is the assignee of all rights, titles
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`CASE NO. 3:19-cv-07578
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`-6-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 7 of 10
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`and interests in and to the ’269 patent, and holds the right to sue and recover for past, present and
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`future infringement thereof.
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`29.
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`On information and belief, in the United States and this District, at least one or
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`more of the LG Defendants have directly infringed, and continue to directly infringe, by making,
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`using, selling, offering for sale and/or importing into the United States products that infringe at
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`least one claim of the ’269 patent, e.g., claim 1, including without limitation, its LG G8 ThinQ
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`mobile phone. The LG Defendants are liable for their infringement of the ’269 patent in
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`violation of 35 U.S.C. § 271(a).
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`30.
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`On information and belief, Defendants are further liable for actively inducing
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`infringement of the ’269 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
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`steps to encourage and facilitate direct infringement by others, including the one or more LG
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`Defendants and its customers that directly infringe the ’269 patent.
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`31.
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`Viavi has been damaged by Defendants’ infringement, and will continue to be
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`damaged by Defendants’ infringement, of the ’269 patent, and thus is entitled to recover
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`damages from Defendants to compensate it for the infringement.
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`32.
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`Viavi is entitled to damages adequate to compensate it for the infringement but in
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`no event less than a reasonable royalty.
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`33.
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`Defendants intend to continue their unlawful infringing activity, and Viavi
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`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
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`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
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`infringing activities.
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`34.
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`Defendants’ past infringement and/or continuing infringement has been deliberate
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`and willful.
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`SECOND CLAIM FOR RELIEF
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`(Infringement of U.S. Patent No. 9,945,995)
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`35.
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`Viavi incorporates by reference the allegations contained in paragraphs 1 through
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`34 above.
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`CASE NO. 3:19-cv-07578
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`-7-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 8 of 10
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`36.
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`The ’995 patent entitled “Optical Filter and Sensor System” issued on April 17,
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`2018. A copy of the ’995 patent is attached as Exhibit 2. Viavi is the assignee of all rights, titles
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`and interests in and to the ’995 patent, and holds the right to sue and recover for past, present and
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`future infringement thereof.
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`37.
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`On information and belief, at least one or more of the LG Defendants in violation
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`of 35 U.S.C. § 271(g) are and have been directly infringing the ’995 patent by importing into the
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`United States or offering to sell, selling or using within the United States products which are
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`made by a process claimed in at least one claim of the ’995 patent, e.g., claim 1, in the United
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`States, including without limitation, the LG G8 ThinQ mobile phone.
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`38.
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`On information and belief, Defendants are liable for actively inducing
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`infringement of the ’995 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
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`steps to encourage and facilitate direct infringement by others, including the one or more LG
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`Defendants that directly infringe the ’995 patent.
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`39.
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`Viavi has been damaged by Defendants’ infringement, and will continue to be
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`damaged by Defendants’ infringement, of the ’995 patent, and thus is entitled to recover
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`damages from Defendants to compensate it for the infringement.
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`40.
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`Viavi is entitled to damages adequate to compensate it for the infringement but in
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`no event less than a reasonable royalty.
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`41.
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`Defendants intend to continue their unlawful infringing activity, and Viavi
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`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
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`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
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`infringing activities.
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`42.
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`Defendants’ past infringement and/or continuing infringement has been deliberate
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`and willful.
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`THIRD CLAIM FOR RELIEF
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`(Infringement of U.S. Patent No. 10,222,526)
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`43.
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`Viavi incorporates by reference the allegations contained in paragraphs 1 through
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`42 above.
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`CASE NO. 3:19-cv-07578
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`-8-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 9 of 10
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`44.
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`The ’526 patent entitled “Optical Filter and Sensor System” issued on March 5,
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`2019. A copy of the ’526 patent is attached as Exhibit 3. Viavi is the assignee of all rights, titles
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`and interests in and to the ’526 patent, and holds the right to sue and recover for past, present and
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`future infringement thereof.
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`45.
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`On information and belief, in the United States and this District, at least one or
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`more of the LG Defendants have directly infringed, and continue to directly infringe, by making,
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`using, selling, offering for sale and/or importing into the United States products that infringe at
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`least one claim of the ’526 patent, e.g., claim 27, including without limitation, its LG G8 ThinQ
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`mobile phone. The LG Defendants are liable for their infringement of the ’526 patent in
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`violation of 35 U.S.C. § 271(a).
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`46.
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`On information and belief, Defendants are further liable for actively inducing
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`infringement of the ’526 patent in violation of 35 U.S.C. § 271(b) by knowingly taking active
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`steps to encourage and facilitate direct infringement by others, including the one or more LG
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`Defendants and its customers that directly infringe the ’526 patent.
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`47.
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`Viavi has been damaged by Defendants’ infringement, and will continue to be
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`damaged by Defendants’ infringement, of the ’526 patent, and thus is entitled to recover
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`damages from Defendants to compensate it for the infringement.
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`48.
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`Viavi is entitled to damages adequate to compensate it for the infringement but in
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`no event less than a reasonable royalty.
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`49.
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`Defendants intend to continue their unlawful infringing activity, and Viavi
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`continues to and will continue to suffer irreparable harm – for which there is no adequate remedy
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`at law from such unlawful infringing activities unless this Court enjoins Defendants from further
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`infringing activities.
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`50.
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`Defendants’ past infringement and/or continuing infringement has been deliberate
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`and willful.
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`JURY DEMAND
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`51.
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`Pursuant to Fed. R. Civ. P. Rule 38(b), Viavi hereby demands a trial by jury on all
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`issues and claims so triable.
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`CASE NO. 3:19-cv-07578
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`-9-
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`COMPLAINT
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`Case 4:19-cv-07578-JSW Document 1 Filed 11/18/19 Page 10 of 10
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`PRAYER FOR RELIEF
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`WHEREFORE, Viavi respectfully prays for the following relief:
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`1.
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`Pursuant to 35 U.S.C. § 271, a Judgement that Defendants infringe and have
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`infringed at least one claim of the ’269 patent, at least one claim of the ’995 patent, and/or at
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`least one claim of the ’526 patent;
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`2.
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`Pursuant to 35 U.S.C. § 283, a permanent injunction prohibiting Defendants from
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`further acts of infringement of the ’269 patent, the ’995 patent, and the ’526 patent;
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`3.
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`Pursuant to 35 U.S.C. § 284, compensatory damages, past and future, amounting
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`to no less than reasonable royalties, prejudgment interest, and/or any other available damages
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`based on any form of recoverable economic injury sustained by Viavi as a result of Defendants’
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`infringement;
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`4.
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`Pursuant to 35 U.S.C. § 285, an award of any other supplemental damages
`
`including Viavi’s costs and attorneys’ fees incurred in this action; and
`
`5.
`
`For such other relief as this Court deems just and proper.
`
`Dated: November 18, 2019
`
`VENABLE LLP
`
`By:
`
`/s/ William A. Hector
`Frank C. Cimino, Jr. (pro hac vice)
`FCCimino@venable.com
`Megan S. Woodworth (pro hac vice)
`MSWoodworth@venable.com
`Charles J. Monterio, Jr. (pro hac vice)
`CJMonterio@venable.com
`VENABLE LLP
`600 Massachusetts Avenue, NW
`Washington, D.C. 20001
`Telephone: (202) 344-4569
`Facsimile: (202) 344-8300
`
`William A. Hector
`WAHector@venable.com
`101 California Street, Suite 3800
`San Francisco, CA 94111
`Telephone: (415) 653-3738
`Facsimile: (415) 653-3755
`
`Attorneys for Viavi Solutions Inc.
`
`CASE NO. 3:19-cv-07578
`
`-10-
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