Case: 1:20-cv-03872 Document #: 1 Filed: 07/01/20 Page 1 of 15 PageID #:1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`SCRIPT TRANSFORM LLC,
`
`Plaintiff,
`
`v.
`
`Civil Action No. 1:20-cv-3872
`
`MOTOROLA MOBILITY LLC,
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Script Transform LLC (“Script Transform” or “Plaintiff”), for its Complaint
`
`against Defendant Motorola Mobility LLC, (referred to herein as “Motorola” or “Defendant”),
`
`alleges the following:
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`NATURE OF THE ACTION
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`1.
`
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2.
`
`Plaintiff Script Transform is a limited liability company organized under the laws
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`of the state of Delaware with a place of business at 261 West 35th Street, Suite No. 1003, New
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`York, New York 10001.
`
`3.
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`Upon information and belief, Motorola is a corporation organized under the laws
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`of the state of Delaware with a place of business at 222 W. Merchandise Mart Plaza, Chicago,
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`Illinois 60654. Upon information and belief, Motorola sells, offers to sell, and/or uses products
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`and services throughout the United States, including in this judicial district, and introduces
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`infringing products and services into the stream of commerce knowing that they would be sold
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`and/or used in this judicial district and elsewhere in the United States.
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`JURISDICTION AND VENUE
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`4.
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`This is an action for patent infringement arising under the Patent Laws of the
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`United States, Title 35 of the United States Code.
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`5.
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`6.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
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`Venue with respect to Defendant Motorola is proper in this District under
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`28 U.S.C. § 1400(b) because, upon information and belief, Defendant maintains a regular and
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`established place of business in this District, its principal place of business at 222 W.
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`Merchandise Mart Plaza, Chicago, Illinois 60654, and has committed infringing acts in this
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`District through its sales of the Accused Instrumentalities in this District. Venue with respect to
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`Defendant Motorola is also proper in this District under 28 U.S.C. § 1391(b)(2) because
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`Motorola sells and offers to sell products and services throughout the United States, including in
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`this District, and introduces products and services into the stream of commerce and effectuates
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`these sales knowing that the products and services would be sold in this District and elsewhere in
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`the United States.
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`7.
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`This Court has personal jurisdiction over Motorola. Motorola is amenable to
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`service of summons for this action. Furthermore, personal jurisdiction over Motorola in this
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`action comports with due process. Motorola has conducted and regularly conducts business
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`within the United States and this District. Motorola has purposefully availed itself of the
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`privileges of conducting business in the United States, and more specifically in the State of
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`Illinois and in this District. Motorola has sought protection and benefit from the laws of the
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`State of Illinois by placing infringing products into the stream of commerce through an
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`established distribution channel with the awareness and/or intent that they will be purchased by
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`consumers in this District.
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`8.
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`Motorola – directly or through intermediaries (including distributors, retailers,
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`and others), subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sells
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`its products in the United States and this District. Motorola has purposefully and voluntarily
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`placed one or more of its infringing products into the stream of commerce with the awareness
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`and/or intent that they will be purchased by consumers in this District. Motorola knowingly and
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`purposefully ships infringing products into and within this District through an established
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`distribution channel. These infringing products have been and continue to be purchased by
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`consumers in this District. Upon information and belief, through those activities, Motorola has
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`committed the tort of patent infringement in this District.
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`9.
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`On information and belief, Defendant Motorola is subject to this Court’s general
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`and specific personal jurisdiction because Motorola has sufficient minimum contacts within the
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`State of Illinois and this District, pursuant to due process and/or the Illinois long-arm statute,
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`because Defendant Motorola purposefully availed itself of the privileges of conducting business
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`in the State of Illinois and in this District, because Defendant Motorola regularly conducts and
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`solicits business within the State of Illinois and within this District, and because Plaintiff’s
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`causes of action arise directly from Defendant’s business contacts and other activities in the State
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`of Illinois and this District. Having purposefully availed itself of the privilege of conducting
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`business within this District, Defendant Motorola should reasonably and fairly anticipate being
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`brought into court here.
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`BACKGROUND
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`The Invention
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`10.
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`Simon Sung Lee is the inventor of U.S. Patent No. 9,191,629 (“the ’629 patent”).
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`A true and correct copy of the ’629 patent is attached as Exhibit A.
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`11.
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`The ’629 patent resulted from the pioneering efforts of Mr. Lee (hereinafter “the
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`Inventor”) in the area of video-enabled baby monitoring technologies. These efforts resulted in
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`the development of a method and apparatus for a baby monitoring system including video
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`enhancement capability operable at various frequencies in 2012. This system improved upon
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`existing solutions, increasing energy efficiency of the monitoring system while also providing
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`improved control over system functionality. At the time of these pioneering efforts, the most
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`widely implemented technology used to address baby monitoring needs comprised always
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`providing video and audio recordings of a baby. In that type of system, the audio and video
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`transmission would persist perpetually unless power to the system was cut off. The Inventor
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`conceived of the inventions claimed in the ’629 patent as a way to allow a user to disable the
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`video features of the system while allowing the audio features to persist, decreasing the energy
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`usage of the system and allowing a user to enact extended control of the functionality of the
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`monitoring system.
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`Advantage Over the Prior Art
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`12.
`
`The patented invention disclosed in the ’629 patent, provides many advantages
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`over the prior art, and in particular improved the operations and function of baby monitoring
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`video capture and transmission technologies. (See ’629 patent at 4:32-50.) One advantage of the
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`patented invention is that it includes a unique video-off button feature which may be utilized to
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`turn off the display screen on a receiver unit and simultaneously turn off an infrared light
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`transmission source found in a transmitter unit. (See ’629 patent at 4:32-37.) This advantage
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`allows a user to control the system so as to only enable the functionality desired. For example,
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`the user may only want to cause the transmission of audio signals from the transmitter. As such,
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`the user does not require video transmission or the use of an infrared light source for image
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`capture and can therefore disable these unneeded features.
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`13.
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`Another advantage of the patented invention is the increased energy efficiency of
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`the system as a result of the above-described video-off control. Specifically, because the user
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`can disable the video and infrared features of the invention, the energy efficiency of the system is
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`improved because energy is no longer spent to power the unneeded features. (See ’629 patent at
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`6:19-26.)
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`14.
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`Another advantage of the patented invention is that the time duration of released
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`frequencies from the infrared light is decreased due to the permitted disabling of the infrared
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`source. (See ’629 patent at 6:24-26.)
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`15.
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`Because of these significant advantages that can be achieved through the use of
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`the patented invention, Script Transform believes that the ’629 patent presents significant
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`commercial value for companies like Motorola.
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`Technological Innovation
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`16.
`
`The patented invention disclosed in the ’629 patent resolves technical problems
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`related to audio and video enabled baby monitoring systems, particularly problems related to the
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`utilization of user control to govern certain video functions of the system. As the ’629 patent
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`explains, one of the limitations of the prior art as regards the baby monitoring system was that
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`users would typically be unable to use a single video-off control to disable and re-enable certain
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`video functions found within baby monitoring systems, wasting energy. (See ’629 patent at
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`4:32-37.)
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`17.
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`The claims of the ’629 patent do not merely recite the performance of some well-
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`known business practice from the pre-Internet world along with the requirement to perform it on
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`the Internet. Instead, the claims of the ’629 patent recite inventive concepts that are deeply
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`rooted in engineering technology, and overcome problems specifically arising out of how to
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`control the video functions of a baby monitoring system and do so in a way that improves energy
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`efficiency.
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`18.
`
`In addition, the claims of the ’629 patent recite inventive concepts that improve
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`the functioning of baby monitoring systems, particularly the recitation of the video-off
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`functionality that gives a user more control over the system while providing improved energy
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`efficiency; a concept that prior baby monitoring systems lacked.
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`19. Moreover, the claims of the ’629 patent recite inventive concepts that are not
`
`merely routine or conventional use of audio and video baby monitoring technologies. Instead,
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`the patented invention disclosed in the ’629 patent provides a new and novel solution to specific
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`problems related to improving the energy and resource efficiency of baby monitoring systems.
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`20.
`
`And finally, the patented invention disclosed in the ’629 patent does not preempt
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`all the ways that baby monitoring technologies may be used to improve the efficiency and degree
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`of control afforded to users of a baby monitoring system, nor does the ’629 patent preempt any
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`other well-known or prior art technology.
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`21.
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`Accordingly, the claims in the ’629 patent recite a combination of elements
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`sufficient to ensure that the claim in substance and in practice amounts to significantly more than
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`a patent-ineligible abstract idea.
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`COUNT I – INFRINGEMENT OF U.S. PATENT NO. 9,191,629
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`22.
`
`The allegations set forth in the foregoing paragraphs 1 through 21 are
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`incorporated into this First Claim for Relief.
`
`23.
`
`On November 17, 2015, the ’629 patent was duly and legally issued by the United
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`States Patent and Trademark Office under the title “Baby monitoring system including video
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`enhancement capability operable at various frequencies.” The application leading to the ’629
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`patent was filed on June 18, 2013. A true and correct copy of the ’629 patent is attached hereto
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`as Exhibit A.
`
`24.
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`Script Transform is the assignee and owner of the right, title and interest in and to
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`the ’629 patent, including the right to assert all causes of action arising under said patent and the
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`right to any remedies for infringement of it.
`
`25.
`
`Upon information and belief, Motorola directly infringes and continues to directly
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`infringe at least claim 1 of the ’629 patent, in the United States, under 35 U.S.C. § 271(a),
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`literally or under the doctrine of equivalents, by, among other things, by making, using, selling,
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`offering to sell, importing and/or providing and/or causing to be used technologies for a video-
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`enabled baby monitoring systems which include at least two separate units, which by way of
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`example include the MBP36XL and other models available online at the Motorola store (See
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`https://www.motorolastore.com/baby-monitors/video-monitoring; see also
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`https://www.motorolastore.com/baby-monitors/video-monitoring/motorola-mbp36xl.html, all
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`last accessed and downloaded June 11, 2020, along with related systems and software for access
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`and use of such systems (the “Accused Instrumentalities”) as in claim 1 of the ’629 patent. (See
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`Script Transform’s Claim Chart for claim 1 of the ’629 patent, Ex. B at 1-16.) Motorola
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`describes the MBP36XL as one to use to “[k]eep an eye on things . . . and clearly communicate
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`with your partner or child,” and that the system contains a “Portable, Rechargeable Camera,” and
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`an “Ergonomic Parent Unit with 5-Inch Diagonal Color Screen.” (Source:
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`https://www.motorolastore.com/baby-monitors/video-monitoring/motorola-mbp36xl.html, last
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`accessed and downloaded June 11, 2020.)
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`26.
`
`On information and belief, Defendant Motorola is a for-profit organization with
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`revenues of approximately $7.34 billion U.S.D. per year. Moreover, Defendant, its employees
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`and/or agents make, use, sell, offer to sell, import, and/or provide and/or cause to be used the
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`Accused Instrumentalities for Defendant’s partners and customers, leading to direct or indirect
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`revenues and profit. On information and belief, without the availability of infringing tools such
`
`as the Accused Instrumentalities, Defendant would be at a disadvantage in the marketplace and
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`would generate less revenue and profit overall.
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`27.
`
`In particular, claim 1 of the ’629 patent generally recites a video-enabled baby
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`monitoring system which includes at least two separate units comprising: a transmitter unit
`
`including a camera feature which captures motion, a sound sensor which captures sound, and an
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`infrared light source capable of providing sufficient light for imaging when necessary, wherein
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`said transmitter unit also includes microprocessors which generate a series of video signal codes
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`and audio signal codes which are transmitted at a specific radio frequency to a dedicated receiver
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`unit; and a receiver unit including a display screen, where said receiver unit receives said signal
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`codes from said transmitter and provides a displayed image, in combination with corresponding
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`sound, or provides the sound alone, wherein said receiver unit includes a video-off button which
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`enables a user to simultaneously turn off said display screen, and to turn off said camera feature,
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`and said infrared light source of said transmitter remotely, whereby sound is transmitted to said
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`receiver without video. (Ex. B at 9-16.)
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`28.
`
`Exemplary infringement analysis showing infringement of claim 1 of the ’629
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`patent is set forth in Exhibit B. This infringement analysis is necessarily preliminary, as it is
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`provided in advance of any discovery provided by Motorola with respect to the ’629 patent.
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`Script Transform reserves all rights to amend, supplement and modify this preliminary
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`infringement analysis. Nothing in the attached chart should be construed as any express or
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`implied contention or admission regarding the construction of any term or phrase of the claims of
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`the ’629 patent.
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`29. Motorola provides video-enabled baby monitoring systems which include at least
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`two separate units. (Ex. B at 9.) Motorola provides a line of Video Baby Monitor products that
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`includes, for example, the MBP36XL. (See https://www.motorolastore.com/baby-
`
`monitors/video-monitoring; last accessed and downloaded June 11, 2020.) Motorola describes
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`the MBP36XL as a system to use to “[k]eep an eye on things . . . and clearly communicate with
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`your partner or child,” and that the system contains a two separate units: a “Portable,
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`Rechargeable Camera,” and an “Ergonomic Parent Unit with 5-Inch Diagonal Color Screen.”
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`(Source: https://www.motorolastore.com/baby-monitors/video-monitoring/motorola-
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`mbp36xl.html, last accessed and downloaded June 11, 2020.)
`
`30.
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`Additionally, the Motorola systems include a transmitter unit including a camera
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`feature which captures motion, a sound sensor which captures sound, and an infrared light source
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`capable of providing sufficient light for imaging when necessary. (Ex. B at 10.) For example,
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`the MBP36XL system includes, as a transmitter unit, a “Baby Unit” that includes a camera lens,
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`infrared LEDs for night vision, and a microphone to capture sound. (See https://assets.ctfassets.
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`net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP
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`36XL_IFU_US_EN_Version_2_170208.pdf at 5, last accessed and downloaded June 11, 2020.)
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`31.
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`The Motorola systems also include wherein the said transmitter unit also includes
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`microprocessors which generate a series of video signal codes and audio signal codes which are
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`transmitted at a specific radio frequency to a dedicated receiver unit. (Ex. B at 11-12.) For
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`example, the MBP36XL system is described as allowing two-way communication between the
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`camera and tablet through the use of 2.4 GHz FHSS wireless technology for local viewing. (See
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`https://www.motorolastore.com/baby-monitors/video-monitoring/motorola-mbp36xl.html, last
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`accessed and downloaded June 11, 2020.)
`
`32.
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`In addition, the Motorola systems includes a receiver unit including a display
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`screen. (Ex. B at 13.) For example, the MBP36XL system includes a “Parent Unit” that
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`includes an LCD screen display. (See https://assets.ctfassets.net/0dyo76hkwr49/
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`1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP36XL_IFU_US_EN
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`_Version_2_170208.pdf at 3, last accessed and downloaded June 11, 2020.)
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`33.
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`In the Motorola systems, said receiver unit receives said signal codes from said
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`transmitter and provides a displayed image, in combination with corresponding sound, or
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`provides the sound alone. (Ex. B at 13-15). For example, the “Parent Unit” of the MBP36XL
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`system can display and playback visual and audio information, respectively, captured by and
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`received from the “Baby Unit” through the use of 2.4 GHz FHSS wireless technology. (See
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`https://www.motorolastore.com/baby-monitors/video-monitoring/motorola-mbp36xl.html, last
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`accessed and downloaded June 11, 2020.)
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`34.
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`The Motorola systems further include wherein said receiver unit includes a video-
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`off button which enables a user to simultaneously turn off said display screen and to turn off said
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`camera feature and said infrared light source of said transmitter remotely. (Ex. B at 14-16.) For
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`example, the MBP36XL system includes a “VIDEO ON/OFF button” that when pressed “turn[s]
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`the LCD screen on or off, whilst still leaving the audio monitor on.” (Source:
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`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f935819
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`7849199588d67/MBP36XL_IFU_US_EN_Version_2_170208.pdf at 14, last accessed and
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`downloaded June 11, 2020.) Additionally, the Motorola MBP36XL “Parent Unit” (receiver unit)
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`provides a “Power Savings mode” that can be activated through the use of the system’s menu
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`options. (See id. at 13.) In this mode, the video will turn off, but the audio will stay on, but upon
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`the pressing of any key on the Motorola system, the video functionality will be turned back on.
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`(See id.)
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`35.
`
`Use of the Accused Instrumentalities by Defendant’s partners, customers, and/or
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`end users infringes claim 1 of the ’629 patent through a combination of features which
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`collectively practice each limitation of claim 1. (Ex. B at 10-17.)
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`36.
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`On information and belief, these Accused Instrumentalities are used marketed,
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`provided to, and/or used by or for each of Defendant’s partners, clients, customers, and end users
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`across the country and in this District.
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`37.
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`Defendant was made aware of the ’629 patent and its infringement thereof at least
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`as early the filing of this Complaint.
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`38.
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`Upon information and belief, since at least the time Defendant received notice,
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`Defendant has induced and continues to induce others to infringe at least one claim of the ’629
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`patent under 35 U.S.C. § 271(b) by, among other things, and with specific intent or willful
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`blindness, actively aiding and abetting others to infringe, including but not limited to each of
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`Defendant’s partners, clients, customers, and end users, whose use of the Accused
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`Instrumentalities constitutes direct infringement of at least one claim of the ’629 patent.
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`39.
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`In particular, Motorola’s actions that aid and abet others to infringe include
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`advertising and/or providing support services to partners contracted by Motorola or by
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`distributing the Accused Instrumentalities and providing instruction materials, training, and
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`services regarding the Accused Instrumentalities which actively induce a user of the Motorola
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`systems to infringe the Asserted Claims. For example, Motorola provides potential users with
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`detailed instruction materials on how to operate the Video Baby Monitor products in a way that
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`infringes at least one claim of the ’629 patent. (See
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`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f935819
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`7849199588d67/MBP36XL_IFU_US_EN_Version_2_170208.pdf, last accessed and
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`downloaded June 11, 2020.)
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`40.
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`In addition, on information and belief, Motorola encourages its employees,
`
`contract workers, customers, and other third parties to use the Accused Instrumentalities. (See
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`https://www.motorolastore.com/baby-monitors/video-monitoring;
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`https://motorolahome.com/home/baby/video-baby-monitors; and
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`https://www.motorola.com/us/motorola-baby-and-home-monitors; all last accessed and
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`downloaded June 11, 2020.)
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`41.
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`Additionally, on information and belief, Motorola promotes the Accused
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`Instrumentalities through advertising. (See https://www.motorolastore.com/baby-
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`monitors/video-monitoring; https://motorolahome.com/home/baby/video-baby-monitors;
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`https://www.youtube.com/watch?v=RoGm-_dpQvs; and
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`https://www.motorola.com/us/motorola-baby-and-home-monitors; all last accessed and
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`downloaded June 11, 2020.)
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`42. Motorola further provides technical support to help users of the Accused
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`Instrumentalities address technical concerns. (Source:
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`https://www.motorolastore.com/support/baby-monitors/video-monitoring; last accessed and
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`downloaded June 11, 2020.)
`
`43.
`
`Upon information and belief, Motorola has engaged in such actions with specific
`
`intent to cause infringement or with willful blindness to the resulting infringement because
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`Motorola has had actual knowledge of the ’629 patent and that its acts were inducing the
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`infringement of the ’629 patent since at least the date Motorola received notice by this Complaint
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`that such activities infringed the ’629 patent.
`
`44.
`
`Upon information and belief, Defendant is liable as a contributory infringer of the
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`’629 patent under 35 U.S.C. § 271(c) by offering to sell, selling and importing into the United
`
`States video-enabled baby monitoring technologies that include the features of the Asserted
`
`Claims which are especially made or adapted for use in an infringement of the ’629 patent.
`
`These Accused Instrumentalities are a material component for use in practicing the ’629 patent
`
`and are specifically made and are not a staple article of commerce suitable for substantial non-
`
`infringing use.
`
`45.
`
`Defendant Motorola was made aware of the ’629 patent and its infringement
`
`thereof at least as early as the filing and service of this Complaint. Despite Plaintiff’s notice to
`
`Motorola by this Complaint regarding the ʼ629 patent, the Defendant continues to infringe the
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`ʼ629 patent.
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`46.
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`Upon information and belief, since at least the time it received notice by this
`
`Complaint, Motorola’s infringement has been and continues to be willful.
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`47.
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`Plaintiff Script Transform has been harmed by each of Motorola’s infringing
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`activities with respect to the ʼ629 patent.
`
`48.
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`Script Transform reserves the right to modify its infringement theories as
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`discovery progresses in this case. It shall not be estopped for purposes of its infringement
`
`contentions or its claim constructions by the claim charts it provides with this Complaint. Script
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`Transform intends the claim chart (Exhibit B) for the ’629 patent to satisfy the notice
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`requirements of Rule 8(a)(2) of the Federal Rule of Civil Procedure. The claim chart is not
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`Script Transform’s preliminary or final infringement contentions or preliminary or final claim
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`construction positions.
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`JURY DEMAND
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`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Script Transform demands a
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`trial by jury on all issues triable as such.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff Script Transform demands judgment for itself and against
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`Motorola as follows:
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`A.
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`B.
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`An adjudication that the Motorola has infringed the ’629 patent;
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`An award of damages to be paid by Motorola adequate to compensate Script
`
`Transform for Motorola’s past infringement of the ’629 patent, and any continuing or future
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`infringement through the date such judgment is entered, including interest, costs, expenses and
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`an accounting of all infringing acts including, but not limited to, those acts not presented at trial;
`
`C.
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`A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of
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`Script Transform’s reasonable attorneys’ fees; and
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`Page 14 of 15
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`

`

`Case: 1:20-cv-03872 Document #: 1 Filed: 07/01/20 Page 15 of 15 PageID #:15
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`D.
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`An award to Script Transform of such further relief at law or in equity as the
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`Court deems just and proper.
`
`Dated: July 1, 2020
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`
`
`
`
`
`DEVLIN LAW FIRM LLC
`
`
`
`/s/ Cory Edwards
`Timothy Devlin (pro hac vice to be filed)
`tdevlin@devlinlawfirm.com
`Patrick R. Delaney (pro hac vice to be filed)
`pdelaney@devlinlawfirm.com
`Cory Edwards (No. 6329639)
`cedwards@devlinlawfirm.com
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`
`Attorneys for Plaintiff,
`Script Transform LLC
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`Page 15 of 15
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`