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Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 1 of 13
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
`
`
`Civil Action No.:
`
`ZOO DIGITAL LIMITED, a Great Britain company,
`
` Plaintiff,
`
` v.
`
`ADOBE, INC., a Delaware corporation,
`
` Defendant.
`
`
`
`COMPLAINT FOR INFRINGEMENT OF PATENT
`
`
`
`Now comes Plaintiff, ZOO Digital Limited (“Plaintiff” or “ZOO Digital”), by and through
`
`undersigned counsel, and respectfully alleges, states, and prays as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This is an action for patent infringement under the Patent Laws of the United States,
`
`Title 35 United States Code (“U.S.C.”) to prevent and enjoin Defendant Adobe, Inc. (hereinafter
`
`“Defendant”), from infringing and profiting, in an illegal and unauthorized manner, and without
`
`authorization and/or consent from Plaintiff from U.S. Patent No 7,574,103 (“the ‘103 Patent” or
`
`the “Patent-in-Suit”), which is attached hereto as Exhibit A and incorporated herein by reference,
`
`and pursuant to 35 U.S.C. §271, and to recover damages, attorney’s fees, and costs.
`
`THE PARTIES
`
`2.
`
`Plaintiff is a Great Britain company with its principal place of business at City Gate,
`
`8 St Mary’s Gate, Sheffield, S1 4LW, United Kingdom.
`
`3.
`
`Upon information and belief, Defendant is a corporation organized under the laws
`
`of Delaware, having a principal place of business at 345 Park Avenue, San Jose, California 95110-
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 2 of 13
`
`2704. Upon information and belief, Defendant may be served with process c/o Corporation Service
`
`Company, 1900 West Littleton Boulevard, Littleton, Colorado 80120.
`
`4.
`
` Defendant maintains a physical presence in this judicial district through its
`
`operation of its facility located at 707 Seventeenth Street, Denver, Colorado 80202.
`
`JURISDICTION AND VENUE
`
`5.
`
`This is an action for patent infringement in violation of the Patent Act of the United
`
`States, 35 U.S.C. §§1 et seq.
`
`6.
`
`The Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
`
`§§1331 and 1338(a).
`
`7.
`
`This Court has personal jurisdiction over Defendant by virtue of its systematic and
`
`continuous contacts with this jurisdiction and its residence in this District, as well as because of
`
`the injury to Plaintiff, and the cause of action Plaintiff has risen in this District, as alleged herein.
`
`8.
`
`Defendant has established minimum contacts with this forum such that exercise of
`
`jurisdiction over the Defendant would not offend traditional notions of fair play and substantial
`
`justice.
`
`9.
`
`Defendant is subject to this Court’s specific and general personal jurisdiction
`
`pursuant to its substantial business in this forum, including: (i) at least a portion of the
`
`infringements alleged herein; (ii) regularly doing or soliciting business, engaging in other
`
`persistent courses of conduct, and/or deriving substantial revenue from goods and services
`
`provided to individuals in this forum state and in this judicial District; and (iii) being physically
`
`located in this District.
`
`10.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. §1400(b) because
`
`Defendant resides in this District under the Supreme Court’s opinion in TC Heartland v. Kraft
`
`
`
`2
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 3 of 13
`
`Foods Group Brands LLC, 137 S. Ct. 1514 (2017) through its physically located, and regular and
`
`established place of business in this District.
`
`FACTUAL ALLEGATIONS
`
`11.
`
`On August 11, 2009, the United States Patent and Trademark Office (“USPTO”)
`
`duly and legally issued the ‘103 Patent, entitled “AUTHORING OF COMPLEX AUDIOVISUAL
`
`PRODUCTS” after a full and fair examination. The ‘103 Patent is attached hereto as Exhibit A
`
`and incorporated herein as if fully rewritten.
`
`12.
`
`Plaintiff is presently the owner of the ‘103 Patent, having received all right, title
`
`and interest in and to the ‘103 Patent. Plaintiff possesses all rights of recovery under the ‘103
`
`Patent, including the exclusive right to recover for past infringement.
`
`13.
`
`To the extent required, Plaintiff has complied with all marking requirements under
`
`35 U.S.C. § 287.
`
`14.
`
`One exemplary invention claimed in the ‘103 Patent comprises a computer platform
`
`comprising a storage medium storing thereon instructions that performs method steps of authoring
`
`complex audiovisual products.
`
`15.
`
`Claim 67 of the ‘103 Patent states:
`
`“67. A computing platform comprising a storage medium storing thereon computer
`executable instructions which when executed by the computing platform perform
`the steps of:
`
`defining a plurality of components, the components implicitly representing
`functional sections of audiovisual content with respect to one or more raw content
`objects for use in an audiovisual product, and a plurality of transitions that represent
`movements between the plurality of components;
`
`automatically expanding the plurality of components and the plurality of transitions
`to automatically generate a set of explicitly realised AV assets and an expanded
`intermediate datastructure of nodes and links, including expanding a component of
`the plurality of components to automatically generate a plurality of nodes, and
`expanding a transition of the plurality of transitions to automatically generate a
`3
`
`
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 4 of 13
`
`plurality of links, where each node is associated with an AV asset of the set, the
`links represent movement from one node to another and the intermediate
`datastructure represents a navigational structure of the audiovisual product; and
`
`creating the audiovisual product for a playback device in a predetermined output
`format, using the AV assets and the expanded intermediate datastructure of the
`nodes and the links, the created audiovisual product having a navigational structure
`corresponding to a structure represented by the intermediate datastructure.
`
`16.
`
`Claim 68 of the ‘103 Patent states:
`
`“68. A computing platform comprising a storage medium storing thereon
`computer executable instructions which when executed by the computing platform
`perform the steps of:
`creating a plurality of components representing parameterised sections of
`audiovisual content of a DVD-Video format datastructure, and a plurality of
`transitions representing movements between components;
`automatically expanding the plurality of components and the plurality of
`transitions to automatically generate a set of AV assets and an expanded
`datastructure of nodes and links, including expanding a component of the plurality
`of components to automatically generate a plurality of nodes, and expanding a
`transition of the plurality of transitions to automatically generate a plurality of links,
`where each node is associated with an AV asset of the set, the links represent
`movement from one node to another and the expanded datastructure represents a
`navigational structure of the DVD-Video format datastructure; and
`creating the DVD-Video format datastructure from the AV assets for a
`playback device, using the node sand links, the created DVD-video format
`datastructure having a navigational structure corresponding to a structure
`represented by the expanded datastructure.” Ex. A at Col.20:3-25.
`
`17.
`
`As identified in the ‘103 Patent, prior art systems had technological faults. Ex. A at
`
`
`
`Col.1:24-27.
`
`18. More particularly, the ‘103 Patent identifies that the prior art provided: “it is desired
`
`to assemble many small sections of raw audio and video content (i.e. sound clips and video clips)
`
`to form a finished audiovisual product, by way of an authoring process. However, in many
`
`environments a considerable degree of specialist knowledge and time must be invested in the
`
`authoring process in order to achieve a desirable finished audiovisual product. These problems are
`
`
`
`4
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 5 of 13
`
`exacerbated where the audiovisual product has a complex navigational structure or requires many
`
`separate raw content objects.” Ex. A at Col. 1:17-27.
`Further, “[a]lthough DVD-video discs and DVD-video players are becoming
`19.
`
`popular and widespread, at present only a limited range of content has been developed. In
`
`particular, a problem arises in that, although the DVD specification is very flexible, it is also very
`
`complex. The process of authoring content into a DVD-video compatible format is relatively
`
`expensive and time consuming. In practice, the flexibility and functions allowed in the DVD-video
`
`specification are compromised by the expensive and time consuming authoring task.
`
`Consequently, current DVD-video discs are relatively simple in their navigational complexity.
`
`Such simplicity can impede a user's enjoyment of a DVD-video disc, and also inhibits the
`
`development of new categories of DVD-video products.” Ex. A at Col.1:58-Col.2:3.
`To address this specific technical problem, Claims 67 and 68 in the ‘103 Patent
`20.
`
`comprises a non-abstract method for authoring of audiovisual content into a form compliant with
`
`a specification for DVD-video and able to be recorded on an optical disc recording medium. Ex.
`
`A at Col. 20:3-60.
`Claims 67 and 68 of the ‘103 Patent is a practical application and inventive step of
`21.
`
`technology that address the specific computer-centric problem of when needing to author complex
`
`audiovisual products.
` The ‘103 Patent indicates that one advantage of its invention is a method for
`22.
`
`creating an audio-visual product having a complex navigational structure and/or having many
`
`individual content objects, whilst reducing a time required for authoring and minimizing a need
`
`for highly skilled operators. Ex. A at Col.2:25-30.
`
`
`
`5
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 6 of 13
`
`23.
`
`The ‘103 Patent indicates that another advantage of its invention is a method for
`
`efficiently creating audio-visual products such as DVD-video products that run on commonly
`
`available DVD-video players. Ex. A at Col.2:33-36.
`Specifically, to overcome the computer-centric problems identified by the ‘103
`24.
`
`Patent, the method of Claim 68 in the ‘103 patent requires (a) creating a plurality of components
`
`representing parameterised sections of audiovisual content of a DVD-Video format data structure,
`
`and a plurality of transitions representing movements between components; (b) automatically
`
`expanding the plurality of components and the plurality of transitions to automatically generate a
`
`set of AV assets and an expanded datastructure of nodes and links, including expanding a
`
`component of the plurality of components to automatically generate a plurality of nodes, and
`
`expanding a transition of the plurality of transitions to automatically generate a plurality of links,
`
`where each node is associated with an AV asset of the set, the links represent movement from one
`
`node to another and the expanded datastructure represents a navigational structure of the DVD-
`
`Video format datastructure; and (c) creating the DVD-Video format datastructure from the AV
`
`assets for a playback device, using the nodes and links, the created DVD-video format
`
`datastructure having a navigational structure corresponding to a structure represented by the
`
`expanded datastructure. These specific elements, as combined, accomplish the desired result of
`
`reducing a time required for authoring and minimizing a need for highly skilled operators.
`
`25.
`
`26.
`
`Claim 67 of the ‘103 Patent includes similar specific elements as Claim 67.
`
`Further, these specific elements of Claim 67 and 68 also accomplish the desired
`
`results to overcome the then existing problems in the relevant field of audio-visual systems. Ancora
`
`Technologies, Inc. v. HTC America, Inc., 908 F.3d 1343, 1348 (Fed. Cir. 2018) (holding that
`
`improving computer security can be a non-abstract computer-functionality improvement if done
`
`
`
`6
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 7 of 13
`
`by a specific technique that departs from earlier approaches to solve a specific computer problem).
`
`See also Data Engine Techs. LLC v. Google LLC, 906 F.3d 999 (Fed. Cir. 2018); Core Wireless
`
`Licensing v. LG Elecs., Inc., 880 F.3d 1356 (Fed. Cir. 2018); Finjan, Inc. v. Blue Coat Sys., Inc.,
`
`879 F.3d 1299 (Fed. Cir. 2018); Uniloc USA, Inc. v. LG Electronics USA, Inc., 957 F.3d 1303
`
`(Fed. Cir. April 30, 2020)
`
`27.
`
`Claims need not articulate the advantages of the claimed combinations to be
`
`eligible. Uniloc USA, Inc. v. LG Elecs. USA, Inc., 957 F.3d 1303, 1309 (Fed. Cir. 2020)
`
`28.
`
`These specific elements of Claim 67 and 68 of the ‘103 Patent were an
`
`unconventional arrangement of elements because the prior art methodologies would require costly
`
`human intervention in the DVD creation. By adding the specific elements, Claim 67 and 68 of the
`
`‘103 Patent was able to unconventionally generate audio-visual content. Cellspin Soft, Inc. v.
`
`FitBit, Inc., 927 F.3d 1306 (Fed. Cir. 2019)
`
`29.
`
`Further, regarding the specific non-conventional and non-generic arrangements of
`
`known, conventional pieces to overcome an existing problem, Claims 67 and 68 in the ‘103 Patent
`
`provides a method for efficiently creating audio-visual products such as DVD-video products that
`
`run on commonly available DVD-video players, that would not preempt all ways of creating audio-
`
`visual content because of the use of automatically expanding the plurality of components and the
`
`plurality of transitions to automatically generate a set of AV assets and an expanded datastructure
`
`of nodes and links, including expanding a component of the plurality of components to
`
`automatically generate a plurality of nodes, and expanding a transition of the plurality of transitions
`
`to automatically generate a plurality of links, where each node is associated with an AV asset of
`
`the set, the links represent movement from one node to another and the expanded datastructure
`
`represents a navigational structure of the DVD-Video format datastructure, any of which could be
`
`
`
`7
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 8 of 13
`
`removed or performed differently to permit a method creating audio-visual content in a different
`
`way. Bascom Global Internet Servs., Inc. v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016);
`
`See also DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2014).
`
`30.
`
`Based on the allegations, it must be accepted as true at this stage, that Claims 67
`
`and 68 of the ‘103 Patent recites a specific, plausibly inventive way of creating audio-visual
`
`content and using specific protocols rather than the general idea of automatic content creation.
`
`Cellspin Soft, Inc. v. Fitbit, Inc., 927 F.3d 1306, 1319 (Fed. Cir. 2019), cert. denied sub nom.
`
`Garmin USA, Inc. v. Cellspin Soft, Inc., 140 S. Ct. 907, 205 L. Ed. 2d 459 (2020).
`
`31.
`
`Alternatively, there is at least a question of fact that must survive the pleading stage
`
`as to whether these specific elements of Claim 67 and 68 of the ‘103 Patent were an unconventional
`
`arrangement of elements. Aatrix Software, Inc. v. Green Shades Software, Inc., 882 F.3d 1121
`
`(Fed. Cir. 2018) See also Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018), cert. denied, 140
`
`S. Ct. 911, 205 L. Ed. 2d 454 (2020).
`
`32.
`
`Claim 68 of the ‘103 Patent recites a non-abstract device that performs method
`
`steps for creating audio-visual content.
`
`33.
`
`Claim 68 of the ‘103 Patent provides the practical application of a device that
`
`performs method steps for creating audio-visual content.
`
`34.
`
`Defendant commercializes, inter alia, methods that perform all the steps recited in
`
`at least one claim of the ‘103 Patent. More particularly, Defendant commercializes, inter alia,
`
`methods that perform all the steps recited in Claim 67 and/or 68 of the ‘103 Patent. Specifically,
`
`Defendant makes, uses, sells, offers for sale, or imports a method that encompasses that which is
`
`covered by Claim 67 and/or 68 of the ‘103 Patent.
`
`
`
`
`
`8
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 9 of 13
`
`DEFENDANT’S PRODUCT(S)
`
`35.
`
`Defendant offers solutions, such as the “Adobe Premiere Pro CC and Encore”
`
`system (the “Accused Product”)1, that enables audio-visual content creation. A non-limiting and
`
`exemplary claim chart comparing the Accused Product of Claim 67 and 68 of the ‘103 Patent is
`
`attached hereto as Exhibit B and is incorporated herein as if fully rewritten.
`
`36.
`
`As recited in claim 67, a system, at least in internal testing and usage, utilized by
`
`the Accused Product practices defining a plurality of components, the components implicitly
`
`representing functional sections of audiovisual content with respect to one or more raw content
`
`objects for use in an audiovisual product, and a plurality of transitions that represent movements
`
`between the plurality of components. See Ex. B.
`
`37.
`
`As recited in claim 67, a system, at least in internal testing and usage, utilized by
`
`the Accused Product practices automatically expanding the plurality of components and the
`
`plurality of transitions to automatically generate a set of explicitly realised AV assets and an
`
`expanded intermediate datastructure of nodes and links, including expanding a component of the
`
`plurality of components to automatically generate a plurality of nodes, and expanding a transition
`
`of the plurality of transitions to automatically generate a plurality of links, where each node is
`
`associated with an AV asset of the set, the links represent movement from one node to another and
`
`the intermediate datastructure represents a navigational structure of the audiovisual product. See
`
`Ex. B.
`
`38.
`
`As recited in Claim 67, a system, at least in internal testing and usage, utilized by
`
`the Accused Product practices creating the audiovisual product for a playback device in a
`
`predetermined output format, using the AV assets and the expanded intermediate datastructure of
`
`
`1 The Accused Product is just one of the products provided by Defendant, and Plaintiff’s investigation is on-going as
`to additional products to be included as an Accused Product that may be added at a later date
`9
`
`
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 10 of 13
`
`the nodes and the links, the created audiovisual product having a navigational structure
`
`corresponding to a structure represented by the intermediate datastructure. See Ex. B.
`
`39.
`
`As recited in Claim 68, a system, at least in internal testing and usage, utilized by
`
`the Accused Product practices creating a plurality of components representing parameterised
`
`sections of audiovisual content of a DVD-Video format datastructure, and a plurality of transitions
`
`representing movements between components. See Ex. B.
`
`40.
`
`As recited in one step of Claim 68, the system, at least in internal testing and usage,
`
`utilized by the Accused Product practices automatically expanding the plurality of components
`
`and the plurality of transitions to automatically generate a set of AV assets and an expanded
`
`datastructure of nodes and links, including expanding a component of the plurality of components
`
`to automatically generate a plurality of nodes, and expanding a transition of the plurality of
`
`transitions to automatically generate a plurality of links, where each node is associated with an AV
`
`asset of the set, the links represent movement from one node to another and the expanded
`
`datastructure represents a navigational structure of the DVD-Video format datastructure. See Ex.
`
`B.
`
`41.
`
`As recited in another step of Claim 68, the system, at least in internal testing and
`
`usage, utilized by the Accused Product practices creating the DVD-Video format datastructure
`
`from the AV assets for a playback device, using the nodes and links, the created DVD-video format
`
`datastructure having a navigational structure corresponding to a structure represented by the
`
`expanded datastructure. See Ex. B.
`
`42.
`
`The elements described in the preceding paragraphs are covered by at least Claim
`
`67 and 68 of the ‘103 Patent. Thus, Defendant’s use of the Accused Product is enabled by the
`
`method described in the ‘103 Patent.
`
`
`
`10
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 11 of 13
`
`INFRINGEMENT OF THE PATENT-IN-SUIT
`
`43.
`
`Plaintiff realleges and incorporates by reference all of the allegations set forth in
`
`the preceding paragraphs
`
`44.
`
` In violation of 35 U.S.C. § 271, Defendant is now, and has been directly infringing,
`
`either literally or under the doctrine of equivalents, the ‘103 Patent.
`
`45.
`
`Defendant has had knowledge of infringement of the ‘103 Patent at least as of the
`
`service of the present Complaint.
`
`46.
`
` Defendant has directly infringed and continues to directly infringe, either literally
`
`or under the doctrine of equivalents at least one claim of the ‘103 Patent, namely Claim 67 and/or
`
`68, by using, at least through internal testing or otherwise, the Accused Product without authority
`
`in the United States, and will continue to do so unless enjoined by this Court. As a direct and
`
`proximate result of Defendant’s direct infringement of the ‘103 Patent, Plaintiff has been and
`
`continues to be damaged.
`
`47.
`
`Defendant has induced others to infringe the ‘103 Patent by controlling or
`
`encouraging infringement, knowing that the acts Defendant induced constituted patent
`
`infringement, and its encouraging acts actually resulted in direct patent infringement.
`
`48.
`
`By engaging in the conduct described herein, Defendant has injured Plaintiff and is
`
`thus liable for infringement of the ‘103 Patent, pursuant to 35 U.S.C. § 271.
`
`49.
`
`Defendant has committed these acts of infringement without license or
`
`authorization.
`
`50.
`
`As a result of Defendant’s infringement of the ‘103 Patent, Plaintiff has suffered
`
`monetary damages and is entitled to a monetary judgment in an amount adequate to compensate
`
`for Defendant’s past infringement, together with interests and costs.
`
`
`
`11
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 12 of 13
`
`51.
`
`Plaintiff will continue to suffer damages in the future unless Defendant’s infringing
`
`activities are enjoined by this Court. As such, Plaintiff is entitled to compensation for any
`
`continuing and/or future infringement up until the date that Defendant is finally and permanently
`
`enjoined from further infringement.
`
`52.
`
`Plaintiff reserves the right to modify its infringement theories as discovery
`
`progresses in this case; it shall not be estopped for infringement contention or claim construction
`
`purposes by the claim charts that it provides with this Complaint. The claim chart depicted in
`
`Exhibit B is intended to satisfy the notice requirements of Rule 8(a)(2) of the Federal Rule of Civil
`
`Procedure and does not represent Plaintiff’s preliminary or final infringement contentions or
`
`preliminary or final claim construction positions.
`
`DEMAND FOR JURY TRIAL
`
`53.
`
`Plaintiff demands a trial by jury of any and all causes of action.
`
`
`
`WHEREFORE, Plaintiff prays for the following relief:
`
`PRAYER FOR RELIEF
`
`a. That Defendant be adjudged to have directly infringed the ‘103 Patent either literally
`
`or under the doctrine of equivalents;
`
`b. An accounting of all infringing sales and damages including, but not limited to, those
`
`sales and damages not presented at trial;
`
`c. That Defendant, its officers, directors, agents, servants, employees, attorneys, affiliates,
`
`divisions, branches, parents, and those persons in active concert or participation with any of them,
`
`be permanently restrained and enjoined from directly infringing the ‘103 Patent;
`
`d. An award of damages pursuant to 35 U.S.C. §284 sufficient to compensate Plaintiff for
`
`the Defendant’s past infringement and any continuing or future infringement up until the date that
`
`
`
`12
`
`

`

`Case 1:21-cv-01693-MEH Document 1 Filed 06/21/21 USDC Colorado Page 13 of 13
`
`Defendant is finally and permanently enjoined from further infringement, including compensatory
`
`damages;
`
`e. An assessment of pre-judgment and post-judgment interest and costs against
`
`Defendant, together with an award of such interest and costs, in accordance with 35 U.S.C. §284;
`
`f. That Defendant be directed to pay enhanced damages, including Plaintiff’s attorneys’
`
`fees incurred in connection with this lawsuit pursuant to 35 U.S.C. §285; and
`
`g. That Plaintiff be granted such other and further relief as this Court may deem just and
`
`proper.
`
`Dated: June 21, 2021
`
`Respectfully submitted,
`
`s/ Howard L. Wernow
`Howard L. Wernow
`Andrew S. Curfman
`Sand, Sebolt & Wernow Co., LPA
`Aegis Tower – Suite 1100
`4940 Munson Street NW
`Canton, Ohio 44718
`Telephone: (330) 244-1174
`Email: howard.wernow@sswip.com
`Email: andrew.curfman@sswip.com
`Attorney for Plaintiff ZOO Digital Limited
`
`
`
`
`
`13
`
`

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