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Case: 1:21-cv-04632 Document #: 1 Filed: 08/30/21 Page 1 of 5 PageID #:1
`
`1:21<rt4fi32
`Feinerman / Mcshain
`RANDOM
`
`States District Court
`-rn District of Illinois
`
`KHAJA M M KHADER
`
`Vs.
`Samsung Electronics America, lnc.
`85 Challenger Road, Ridgefield Park,
`NJ 07660-2106, USA
`Ma i n Telephone(2O 1 ) 2294000Mai n Fax(20 t) 229-4039
`
`Microsoft
`Microsoft Corporation, One Microsoft Way
`Redmond, WA 98052-6399, USA
`
`1.
`
`2.
`
`3.
`
`FrLrr 7l
`
`AUO 30i),ii 4a
`?HgMrAF 6' ah6"'r-ocq1
`OITMT UE, DISTHIST g9UHT
`
`(Plaintiff )
`
`( Defendant )
`
`( Defendant )
`Facebook
`Beat Saber, and Facebook as it purchased the company in Nov, 201g
`1601 Willow Rd. Menlo Park, CA 94025, USA
`4. Valve Corporation,
`P.O. Box 1688, Bellevue, WA 98004.
`Registered office at 10400 NE 4th St., Bellevue,
`WA 98004, United States of America
`sou rceeno i ne@valvesoftwa re. com.
`
`( Defendant )
`
`( Defendant )
`
`1. I Khaja M. M. Kader S/o Late Sri. M. A. Wahab, resident of 1O-1-12Bt1t1tA, Masab
`Tank, Hyderabad, 500004, Telengana, lndia aged about 54 years, Phone and whatsapp:
`+91 98480 78692, Email: khajammk@gmail.com, is herewith filing a case arising from
`an incident that took place on September 14,2019 in Chicago, lllinois. I am a
`businessman, was in Chicago for a family reunion and business prospects from lndia.
`
`2. While in the US, I was introduced to virtual reality video games. On the eve of
`September 13,2019, I played virtual reality video games for the first time after observing
`the warning labels and learning about how to use the controls. The next morning, while
`visiting the Chicago zoo, I suffered a seizure and fainted, which led to hospitalization for
`two days. This is a very serious concern as the seizure did not happen when I was
`playing, it happened after 1 1 to 12 hours of playing, suppose I was driving or operating
`
`Cont..2
`
`

`

`Case: 1:21-cv-04632 Document #: 1 Filed: 08/30/21 Page 2 of 5 PageID #:2
`
`:2'.'.
`
`any heavy machinery, I could have injured myself and even lost my life and also I would
`have put others in danger, for example if I was driving at the time of having seizure and
`fainted I could have caused serious accident and injuries to others on road.
`
`3. After this incident my life has completely changed as the medication I am being given is
`like a sedative, I am unable to concentrate on my business nor I am able to drive and
`have to sleep for over 12 hours.
`
`4. I subsequently had to cancel my return flight to lndia as the doctors advised me not to
`travel for atleast 10 days. After returning home to tndia, my local doctors confirmed that
`the triggering event for the seizure was the effects of exposure to the virtual reality
`games.
`
`5. I had no history of seizures until this event. I was placed on Keppra to control the
`possibility of future seizures which had a major impact on my ability to think clearly,
`lethargy and the inability to concentrate for long periods of times, symptoms I did not
`suffer until after the seizure. Later the doctors in lndia changed the medicin e to Vatparin
`Chrono as I started having side effects with keppra.
`
`Samsung knowingly suppressed the information in 2018 when it released the Samsung
`Odyssey and Samsung Odyssey Plus and kept changing heatth warnings, in the first
`warning Samsung never stated that Samsung Odyssey and Samsung Odyssey plus
`can cause seizures neither they stated any warning about seizures, in the second and
`updated health warning Samsung stated that persons having history of seizures should
`not play or use and in the third health warning Samsung stated that 1 in 4000 may
`
`Cont..3
`
`

`

`Case: 1:21-cv-04632 Document #: 1 Filed: 08/30/21 Page 3 of 5 PageID #:3
`
`::3::
`
`experience seizures when using it.
`
`7. After suffering from seizure I researched and found out that Microsoft had issued a
`warning on 21st June, 2018, when Samsung was suppressing the seizures health
`warning on its labels even Microsoft did not bother to correct Samsung, despite both
`Samsung and Microsoft jointly developed the Samsung Electronics HMD Odyssey+ plus
`Windows Mixed Reality Headset with 2 Wireless Controllers.
`
`8' Surprisingly even today none of these companies mention that seizures can happen
`after few hours or next day or after few days, however certain epilepsy websites indicate
`the same and also clearly mention that virtual reality can cause problems even after
`days of use, some researchers even suggest that virtual reality can cause permanent
`damage to eyes and neurological issues, none of these warnings are stated on their
`labels or in health warnings of Samsung Electronics HMD odyssey+ plus windows
`Mixed Reality Headset with 2 Wireless Controllers devetoped jointly by Samsung and
`Windows and other virtual reality games manufactures in question such as Beat Saber,
`First Person Tennis and the blue, this establishes that these companies are hiding
`important information related to health issues, I request this honorable court to instruct
`Samsung Electronics HMD Odyssey+ Plus Windows Mixed Reality Headset with 2
`Wireless Controllers developed jointly by Samsung and Windows and other virtual reality
`games manufactures in question such as Beat Saber, First Person Tennis and the blue
`to disclose information or knowledge they have about seizures, fainting, neurological
`problems, eye problems faced by users and also indicate on which date they received
`such information and on which date they have updated their labels.
`
`9. Are these manufactures in question are disclosing all the health issues being faced by
`
`Cont..4
`
`

`

`Case: 1:21-cv-04632 Document #: 1 Filed: 08/30/21 Page 4 of 5 PageID #:4
`
`::4:.
`
`10. their respective users, which have come to their knowledge immediately on receipt of
`such information or they are knowingly suppressing the information in order to keep
`making profits at the cost of health and life of their customers.
`
`1 1. lt is very clear that the said manufactures in question are suppressing the information
`that the seizures can happen and a person can faint during seizures, after few hours or
`after few days of playing or using such devices or games, I gently request this honorable
`court to take this issue seriously and call for all information and knowledge they have till
`date from each and every manufacturer of such bad health effects of all devices,
`hardware's, software's, games etc. and instruct all the manufactures to clearly display
`the same on their labels and also educate their customers accordingly as this is a very
`serious issue which can cause accidents and even life of a person or persons if they get
`seizure and faint after few hours or few days of usage or playing such games, as
`suppose the person gets seizures during driving or operating any heavy equipment, he
`can cause accidents, harm himself and may also harm others on the road. I humbly
`request this honorable court to please do not let go this issue unchecked.
`
`12. My hospital bills and all normal reports attached as Annexure 1, which establishes that
`the cause of seizures was only virtual reality games.
`
`13. The health warnings changed from time to time and attached as Annexure 2.
`
`14. The scientific evidence establishing that virtual reality games cause seizures,
`neurological problems, permanent damage to eyes are attached herewith as annexure
`
`Cont..5
`
`

`

`Case: 1:21-cv-04632 Document #: 1 Filed: 08/30/21 Page 5 of 5 PageID #:5
`
`::5::
`
`15." My point is, when a plaintiff can win a six-figure jury award from a McDonald's hot coffee
`spill, it's no stretch to envision product claims based on allegations of illness and harm from
`users of virtual technology products"
`
`16. In view of the above negligence on the part of the virtual reality head gear, hardware,
`software and games manufactures cause of which ! got the seizures and my life completely
`changed after this event, wherein I am unable to drive, unable to concentrate on my business
`wherein I had developed products which could have benefitted me by millions of dollars of profit
`and further more this incident has caused major impact on my ability to think clearly, lethargy
`and the inability to concentrate for long periods of times, symptoms I did not suffer until after the
`seizure and fainting, in view of this suffering and irreparerable loss I sue the companies in
`question for US Dollors 5 Million.
`
`17. I humbly pray and request this honorable court to pass orders, instruct the defendants
`about disclosure of all health related issues which are in their knowledge and also the date from
`which they are awrae of the same and pass orders for paying compensation to me as this
`honorable court deems fit and appropriate.
`
`Thanking you in advance
`
`Sincerly
`
`}{h4:rY-
`
`KHAJA M. M. KHADER
`10-1 -12811 11lA, Masab Tank,
`Hyderabad - 500004, Telangana, lndia
`Email: khaiammk@omail.com
`Phone and Whatsapp: 91 9848078692
`
`

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