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`Terrence Mazura (Bar No. 101075)
`tmazura@euslaw.com
`414 West Fourth Street
`Second Floor
`Santa Ana, California 92701
`Telephone: 714.550.5011
`
`George Moschopoulos (Bar No. 249905)
`GeorgeM@logmapc.com
`Law Office of George Moschopoulos, APC
`34197 Pacific Coast Highway, Suite 100
`Dana Point, CA 92629
`Telephone: 949.498.5413
`Facsimile: 949.272.0428
`
`Gary E. Shoffner (Bar No. 73663)
`ges@shoffnerlawfirm.com
`414 West Fourth Street
`Second Floor
`Santa Ana, California 92701
`Telephone: (714) 550-5010
`Attorneys for the Plaintiff RICMIC LLC
`
`
`RICMIC LLC, a California limited
`liability company,
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
` Case No.:
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`DEMAND FOR JURY TRIAL
`PURSUANT TO FED. RULE CIV.
`PROCEDURE 38(B) AND LOCAL
`RULE 38.1
`
`
`Plaintiff,
`
`v.
`VIGIL HEALTH SOLUTIONS, INC., a
`British Columbia corporation; SAN
`DIEGO HEBREW HOMES, a California
`corporation dba SEACREST VILLAGE
`RETIREMENT COMMUNITIES,
`Defendants.
`
`
`
`
`Complaint for Patent Infringement
`
`-1-
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`
`
`
`
`'22
`
`CV190
`
`MSB
`
`BEN
`
`

`

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`Plaintiff, RICMIC LLC, alleges and incorporates by reference each exhibit attached
`to this complaint as follows:
`JURISDICTION AND VENUE
`
`1. This is an action seeking damages and other relief arising out of
`infringement by defendant of U.S. Patent No. 9,305,450 B2 (“the ‘450 patent”), and
`U.S. Patent No. 10,380,873 B1 (“the ‘873 patent”) (collectively, the “Asserted Patents”),
`which disclose an "Interactive Wireless Life Safety Communications System," some
`embodiments of which are commonly called a “nurse call” system.
`This Court has subject matter jurisdiction over this action pursuant to 28
`2.
`U.S.C. §§1331 and 1338(a) because the claims arise under the patent laws of the United
`States, 35 U.S.C. §§1, et seq.
`This Court has personal jurisdiction over defendant SAN DIEGO HEBREW
`3.
`HOMES, a California corporation dba SEACREST VILLAGE RETIREMENT
`COMMUNITIES (“Seacrest”), which conducts continuous and systematic business in
`California, including in this judicial district. Defendant Seacrest imports and uses the
`infringing products at issue in this case, including the Vigil Wireless Nurse Call System,
`Vitality Wireless Call System, Memory Care System and Essential Core system and
`hybrid combinations of those various systems (collectively, “Vigil Platform”) within this
`judicial district and elsewhere. Further, defendant Seacrest has notice of the Asserted
`Patents and uses, induces its customers' use of, and/or contributes to its customers' use of
`the infringing products at issue in this case and performance of one or more patented
`methods of the Asserted Patents in this judicial district. Venue is proper within this
`judicial district under 28 U.S.C. §1400(b) because Defendant Seacrest has committed acts
`of infringement in this judicial district and has a regular and established place of business
`within this judicial district at 211 Saxony Rd., Encinitas, California 92024.
`This Court has personal jurisdiction over defendant VIGIL HEALTH
`4.
`SOULTIONS INC. (“Vigil”), which on information and belief conducts continuous and
`
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`Complaint for Patent Infringement
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`systematic business in California, including in this judicial district by selling infringing
`products to defendant Seacrest. Defendant Vigil exports into this judicial district and on
`information and belief, sells, offers to sell and uses the infringing products at issue in this
`case, including the Vigil Platform within this judicial district. Further, Vigil has notice of
`the Asserted Patents and uses, induces its customers' use of, and/or contributes to its
`customers' use of the infringing products at issue in this case and performance of one or
`more patented methods of the Asserted Patents in this judicial district. Venue is proper
`within this judicial district under 28 U.S.C. §1391(c)(3) because Defendant Vigil is a
`foreign corporation that has committed acts of infringement in this judicial district as
`described in this Complaint and is otherwise subject to personal jurisdiction in this
`judicial district.
`
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`PARTIES
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`5. Plaintiff RICMIC LLC (“RICMIC”) is a California limited liability company
`in good standing with its principal place of business in Orange County in the Central
`District of California. RICMIC is the owner of the Asserted Patents and the assignee of
`all claims for damages and infringement of each of the Asserted Patents.
`6. Plaintiff is informed and believes and thereon alleges that defendant San
`Diego Hebrew Homes doing business as Seacrest Village Retirement Communities is a
`corporation organized under the laws of the State of California with its principal place of
`business in San Diego County in the city of Encinitas, California.
`7. Plaintiff is informed and believes and thereon alleges that defendant Vigil, is a
`corporation organized under the laws of British Columbia, Canada with its principal
`place of business at 2102 - 4464 Markham Street, Victoria British Columbia V8Z 7X8.
`
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`Complaint for Patent Infringement
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`THE ASSERTED PATENTS AND GENERAL ALLEGATIONS
`
`8. Michael Halverson, the sole named inventor of the Asserted Patents, is a
`member and one of the managers of plaintiff, RICMIC LLC. The “Interactive Wireless
`Life Safety Communications System” technology described in the Asserted Patents
`generally disclose a communication system among patients/residents (via patient
`associated monitoring and alerting devices), caregivers and administrators, typically
`deployed in an assisted living or memory care facility – and commonly referred to as
`“nurse call” system. One embodiment of the invention comprises a network of
`patient/resident “monitor/alerting” devices (such as pendants, pull cords, smoke alarms
`and door sensors) connected to a central communications server over a first
`communications network, and caregiver devices (such as tablets or smart phones)
`connected to the same central server over a different, second communications network,
`whereby alarm signals originating at patient/resident monitor/alerting devices or location
`monitoring devices (e.g., door sensors) in response to detection of alarm conditions are
`received by the central server, recorded and broadcasted by the central server as alarm
`notifications to specific caregiver devices with information about the alarm condition
`and variably about the patient, as shown in the drawing below of the user interface on a
`caregiver device.
`
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`Complaint for Patent Infringement
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`-4-
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`The embodiment described enables caregivers to respond to the alarm notifications via
`an “action status response” (e.g., select between “Responding Now” and “Not
`Responding”) and to communicate with other caregivers, residents and administrators
`via the central server, thereby providing feedback and alert response status updates to
`administrators and other caregivers, and also enables coordinated caregiver response to
`the emergency alert, resulting in enhanced resident safety, all of which are
`improvements over existing nurse call systems that lack the above-described interaction,
`information exchange and bi-directional communication described in plaintiff’s
`invention. The patented invention provides substantial information delivery benefits,
`logging, recording and reporting functionality, and overcomes other functional and
`technical limitations inherent in one-way pager, two-way radio and cellular phone
`“nurse call” and other call systems commonly used in assisted living facilities.
`9. On April 5, 2016, the ‘450 patent, titled “Interactive Wireless Life Safety
`Communications System,” was duly and lawfully issued by the United States Patent and
`
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`Complaint for Patent Infringement
`
`-5-
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`Trademark Office (“USPTO”). The entire right, title, and interest in and to the ‘450
`patent, including all rights to past damages, has been assigned to RICMIC LLC in an
`assignment recorded with the USPTO. A true and correct copy of the ‘450 patent is
`attached to this complaint as Exhibit A.
`10. On August 13, 2019, the ‘873 patent, titled “Interactive Wireless Life
`Safety Communications System,” was duly and lawfully issued by the United States
`Patent and Trademark Office (“USPTO”). The ‘873 patent is a continuation of
`application No. 15/299,080, filed on Oct. 20, 2016, now Pat. No. 10,311,707, which is a
`continuation of application No. 15/058,002, filed on Mar. 1, 2016, now abandoned,
`which is a continuation of application No. 14/468,837, filed on Aug. 26, 2014, now Pat.
`No. 9,305,450, which is a continuation of application No. 13/611,426, filed on Sep. 12,
`2012, now abandoned. The entire right, title, and interest in and to the ‘873 patent,
`including all rights to past damages, has been assigned to RICMIC LLC in an
`assignment recorded with the USPTO. A true and correct copy of the ‘873 patent is
`attached to this complaint as Exhibit B.
`11. RICMIC and its licensees have fully complied with the requirements of 35
`U.S.C. §287(a) by affixing the word “patent” or the abbreviation “pat.” together with the
`number of the patent on all apparatuses manufactured or sold by RICMIC and its
`licensees that practice the patented inventions disclosed by the ‘450 patent. On
`information and belief, the marking requirements of 35 U.S.C. §287(a) have also been
`satisfied through but not limited to defendant Vigil’s actual knowledge of the ‘450 and
`‘873 patents and its infringement of the ‘450 and ‘873 patents.
`12. Defendant Vigil and/or its parent, divisions, subsidiaries, managers and/or
`agents are engaged in the business of making, using, offering for sale and/or selling
`Vigil Platform systems to defendant Seacrest and others that employ the “Vigil Mobile”
`alert notification tool supplied by Vigil. (collectively, the “Accused Instrumentalities” or
`“Vigil Platform”). The various systems comprising the Vigil Platform embody the
`patented inventions disclosed and claimed in the Asserted Patents. A preliminary list of
`
`
`
`Complaint for Patent Infringement
`
`-6-
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`infringing Vigil Platform systems includes without limitation and on information and
`belief, Vigil Nurse Call System, Vitality Wireless Call Systems, Vigil Memory Care
`System and cloud based Essential Core System when such systems are configured with
`or to utilize the Vigil Mobile tool.
`
`
`FIRST CLAIM FOR RELIEF
`PATENT INFRINGEMENT
`(Infringement of the ‘450 Patent)
`
`13. Plaintiff repeats and re-alleges each and every allegation of paragraphs 1
`through 12 as though fully set forth in this paragraph.
`14. Defendant Vigil is a provider of communications systems, including nurse call
`systems, to the senior living and healthcare markets and industries. On information and
`belief, Vigil makes, sells and/or offers to sell and otherwise markets, designs,
`recommends, installs, maintains and uses the Vigil Platform in San Diego County,
`among other U.S. geographical locations, without authority to do so. Defendant Seacrest
`uses the Vigil Platform in its Encinitas, California facilities and elsewhere.
`15. The Vigil Platform is comprised of each of the elements configured as
`described by Claim 1 and other claims in the ‘450 patent including patient/resident and
`facility monitoring devices as part of a first communications network connected to a
`central communications server, and a second wireless network different from the first
`communications network over which smart phone-like wireless caregiver/notification
`devices are connected to the central server to effect and practice the functionality and
`methods claimed in the 450 patent; namely, for example, bi-directional
`communications, real time coordination of caregiver services, logging and reporting of
`alerts and alert notifications to all designated caregivers and groups, transmitting
`caregiver action status and other responses to all or selected caregiver devices,
`transmittal of alert and patient/resident graphical identification, demographic
`
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`Complaint for Patent Infringement
`
`-7-
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`information, medical information and GPS locations to caregivers, progressive
`escalation of an alarm signal until the triggered alert transmitting device is manually
`reset and text (SMS) and voice communications as claimed in the ‘450 patent, all of
`which are significant improvements over and exceed the capabilities of nurse call
`systems based on one-way pagers, two-way radios and cellphones used in nurse call
`systems that do not practice RICMIC’s invention as disclosed in the Asserted Patents.
`16. Among the improvements over prior art are that the ‘450 Patent: (1) solves
`the problem of knowing which caregiver, if any, is responding to an alarm signal; (2)
`prevents “alarm fatigue” among caregivers and ensures attention to the alarm condition,
`thereby enhancing resident safety; (3) provides substantially more information to
`caregivers about resident safety conditions; (4) improves interactivity between alert
`events and caregiver responses; (5) improves interactivity between administrators,
`managers, caregiver and service staff; (6) avoids technological limitations presented by
`prior art systems such as interference with life-critical equipment, unreliable network
`coverage, limited audio fidelity, disruptive volume levels and unintentional disclosure of
`confidential information; and (7) avoids wasting personnel resources by multiple staff
`needlessly responding to alarm signals.
`17. Exhibit C to this Complaint is incorporated here and describes a non-limiting
`example of defendants Vigil’s and Seacrest’s infringement of Claim 1 of the ‘450 patent,
`based on plaintiff RICMIC’s current information and belief. RICMIC makes this
`preliminary and exemplary identification of infringed claims without the benefit of
`discovery or claim construction in this action, and expressly reserves the right to
`augment, supplement, and revise its allegations and contentions based on additional
`information obtained through discovery or otherwise, pursuant to the Federal Rules of
`Civil Procedure, to this Court’s Local Rules and any applicable Patent Local Rules,
`and/or as is otherwise appropriate.
`18. Defendant Seacrest’s import and use and defendant Vigil’s making, selling
`and/or offering for sale and use of the Vigil Platform as alleged literally and/or through
`
`
`
`Complaint for Patent Infringement
`
`-8-
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`the doctrine of equivalents, infringes Claim 1 and other claims embodied in the ‘450
`patent under 35 U.S.C. §271(a), and defendants will continue to infringe unless enjoined
`by this Court. Defendants’ continuing infringement has caused and will continue to
`cause plaintiff irreparable harm for which there is no adequate legal remedy in that such
`continuing infringement undermines plaintiff’s ongoing efforts to sell or exclusively
`license the Asserted Patents and other related patents for full value or at all because
`without an injunction RICMIC is unable to exercise its fundamental right to exclude
`others from practicing the Asserted Patents. Further, considering the balance of
`hardship as between plaintiff RICMIC and defendants, an injunction is warranted
`because, among other things, RICMIC has sold its business and products that practiced
`the Asserted Patents, leaving the Asserted Patents as RICMIC’s sole remaining asset, the
`devaluation of which by, on information and belief, pervasive industry infringement,
`including by Vigil and Seacrest, diminishes the value and marketability of the Asserted
`Patents resulting in significant hardship to RICMIC. The public interest will not be
`disserved by a permanent injunction but will instead be served because, among other
`things, infringers who are enjoined will have an incentive to design around the Asserted
`Patents, thereby advancing innovation that benefits the public. Moreover, a permanent
`injunction allows RICMIC to continue innovating knowing that its right to exclude
`others from practicing the Asserted Patents is intact and RICMIC’s continuing
`innovation is economically justified and benefits the public interest.
`
`
`SECOND CLAIM FOR RELIEF
`PATENT INFRINGEMENT
`(Infringement of the ‘873 Patent)
`
`19. Plaintiff repeats and re-alleges each and every allegation of paragraphs 1
`through 18 as though fully set forth in this paragraph.
`
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`Complaint for Patent Infringement
`
`-9-
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`20. The Vigil Platform is comprised of each of the elements configured as
`described by Claim 1 and other claims in the ‘873 patent including patient/resident and
`facility monitoring devices as part of a first communications network connected to a
`central communications server, and a second wireless network different from the first
`communications network over which smart phone-like wireless caregiver/notification
`devices are connected to the central server to effect and practice the functionality and
`methods claimed in the ‘873 patent; namely, for example, bi-directional
`communications, real time coordination of caregiver services, logging and reporting of
`alerts and alert notifications to all designated caregivers and groups, transmitting
`caregiver action status and other responses to all or selected caregiver devices,
`transmittal of alert and patient/resident graphical identification, demographic
`information, medical information and GPS locations to caregivers, progressive
`escalation of an alarm signal until the triggered alert transmitting device is manually
`reset and text (SMS) and voice communications as claimed in the ‘873 patent, all of
`which are significant improvements over and exceed the capabilities of nurse call
`systems based on one-way pagers, two-way radios and cellphones used in nurse call
`systems that do not practice RICMIC’s invention as disclosed in the Asserted Patents.
`21. Among improvements over prior art are that the ‘873 Patent: (1) solves the
`problem of knowing which caregiver, if any, is responding to an alarm signal; (2)
`prevents “alarm fatigue” among caregivers and otherwise ensures attention to the alarm
`condition, thereby enhancing resident safety; (3) provides substantially more
`information to caregivers about resident safety conditions; (4) improves interactivity
`between alert events and caregiver responses; (5) improves interactivity between
`administrators, managers, caregiver and service staff; (6) avoids technological
`limitations presented by prior art systems such as interference with life-critical
`equipment, unreliable network coverage, limited audio fidelity, disruptive volume levels
`and unintentional disclosure of confidential information; and (7) avoids wasting
`personnel resources by multiple staff needlessly responding to alarm signals.
`
`
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`Complaint for Patent Infringement
`
`-10-
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`22. Exhibit D to this Complaint describes a non-limiting example of defendants
`Vigil’s and Seacrest’s infringement of Claim 1 of the 873 Patent, based on plaintiff
`RICMIC’s current information and belief. RICMIC makes this preliminary and
`exemplary identification of infringed claims without the benefit of discovery or claim
`construction in this action, and expressly reserves the right to augment, supplement, and
`revise its contentions based on additional information obtained through discovery or
`otherwise, pursuant to the Federal Rules of Civil Procedure, to this Court’s Local Rules
`and any applicable Patent Local Rules, and/or as is otherwise appropriate.
`23. Defendant Seacrest’s import and use and defendant Vigil’s making, selling
`and/or offering for sale and use of the Vigil Platform as alleged literally and/or through
`the doctrine of equivalents, infringes Claim 1 and other claims embodied in the ‘873
`patent under 35 U.S.C. §271(a), and defendants will continue to infringe unless enjoined
`by this Court. Defendants’ continuing infringement has caused and will continue to
`cause plaintiff irreparable harm for which there is no adequate legal remedy in that such
`continuing infringement undermines plaintiff’s ongoing efforts to sell or exclusively
`license the Asserted Patents and other related patents for full value or at all because
`without an injunction RICMIC is unable to exercise its fundamental right to exclude
`others from practicing the Asserted Patents. Further, considering the balance of
`hardship as between plaintiff RICMIC and defendants, an injunction is warranted
`because, among other things, RICMIC has sold its business and products that practiced
`the Asserted Patents, leaving the Asserted Patents as RICMIC’s sole remaining asset, the
`devaluation of which by, on information and belief, pervasive industry infringement,
`including by Vigil and Seacrest, diminishes the value and marketability of the Asserted
`Patents resulting in significant hardship to RICMIC. The public interest will not be
`disserved by a permanent injunction but will instead be served because, among other
`things, infringers who are enjoined will have an incentive to design around the Asserted
`Patents, thereby advancing innovation that benefits the public. Moreover, a permanent
`injunction allows RICMIC to continue innovating knowing that its right to exclude
`
`
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`Complaint for Patent Infringement
`
`-11-
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`others from practicing the Asserted Patents is intact and RICMIC’s continuing
`innovation is economically justified and benefits the public interest.
`
`PRAYER FOR RELIEF
`
` WHEREFORE, Plaintiff RICMIC LLC requests judgment against defendants as
`follows:
`1. Issuance of preliminary and permanent injunctions against defendant Vigil’s
`continuing infringement by restraining and enjoining Vigil from making, selling,
`offering to sell and using Vigil Platform systems configured with Vigil Mobile in the
`United States;
`2. Issuance of preliminary and permanent injunctions against defendant
`Seacrest’s continuing infringement by restraining and enjoining Vigil from importing,
`selling and offering to sell Vigil Platform systems configured with Vigil Mobile in the
`United States;
`3. That RICMIC LLC be awarded damages against both defendants for all
`damages suffered by RICMIC LLC as a result of defendants’ patent infringement in an
`amount not less than a reasonable royalty as provided by 35 U.S.C. § 284;
`4. An accounting for all damages not presented at trial;
`5. That RICMIC be awarded costs of suit;
`6. That RICMIC LLC be awarded such other and further relief as the Court may
`deem just and proper.
`
`Date: February 7, 2022
`
`
`
`
`
`Mazura Law Firm
`
`By: s/ Terrence Mazura
`Terrence Mazura
`tmazura@euslaw.com
`
`
`
`
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`Complaint for Patent Infringement
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`Case 3:22-cv-00190-BEN-MSB Document 1 Filed 02/09/22 PageID.96 Page 13 of 13
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`Date: February 7, 2022
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`Date: February 7, 2022
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`Law Office of George Moschopoulos, APC
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`By: s/ George Moschopoulos
`George Moschopoulos
`GeorgeM@logmapc.com
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`Shoffner Law Firm
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`By: s/ Gary E. Shoffner
`Gary E. Shoffner
`ges@shoffnerlawfirm.com
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`DEMAND FOR JURY TRIAL
`Pursuant to the Seventh Amendment to the U.S Constitution, Rule 38(b) of the
`Federal Rules of Civil Procedure and Southern District of California Local Rule
` 38.1, Plaintiff hereby demands a trial by jury of any issues triable of right by a jury.
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`Date: February 7, 2022
`Mazura Law Firm
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`By: s/ Terrence Mazura
`Terrence Mazura
`tmazura@euslaw.com
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`Law Office of George Moschopoulos, APC
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`Date: February 7, 2022
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`Date: February 7, 2022
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`By: s/ George Moschopoulos
`George Moschopoulos
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`Shoffner Law Firm
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`By: s/ Gary E. Shoffner
`Gary E. Shoffner
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`Complaint for Patent Infringement
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`-13-
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