Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 1 of 7 PageID #:1
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
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`VDPP LLC,
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`v.
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`MOTOROLA MOBILITY LLC,
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`Defendant.
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`COMPLAINT
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`VDPP LLC (hereinafter, “VDPP”) brings this patent-infringement action against Motorola
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`Mobility LLC (hereinafter, “Motorola”).
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`Parties
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`1.
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`Plaintiff VDPP is an Oregon company with its principal place of business in
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`Corvallis, Oregon.
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`2.
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`Motorola is a Delaware company, having a regular and established place of
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`business in Chicago, Illinois.
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`Jurisdiction and Venue
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`This action arises under the patent laws of the United States, 35 U.S.C. §§ 101 et
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331
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`seq.
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`3.
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`4.
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`and 1338(a).
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`5.
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`This Court may exercise personal jurisdiction over Motorola. Motorola conducts
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
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`------------------------------------------------------x
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`VDPP LLC,
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`
`
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`
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`JURY TRIAL DEMANDED
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`
`
`Plaintiff,
`
`v.
`
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`MOTOROLA MOBILITY LLC,
`
`
`Defendant.
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`------------------------------------------------------x
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`
`COMPLAINT
`
`VDPP LLC (hereinafter, “VDPP”) brings this patent-infringement action against Motorola
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`Mobility LLC (hereinafter, “Motorola”).
`
`Parties
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`1.
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`Plaintiff VDPP is an Oregon company with its principal place of business in
`
`Corvallis, Oregon.
`
`2.
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`Motorola is a Delaware company, having a regular and established place of
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`business in Chicago, Illinois.
`
`Jurisdiction and Venue
`
`This action arises under the patent laws of the United States, 35 U.S.C. §§ 101 et
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`This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331
`
`seq.
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`3.
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`4.
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`and 1338(a).
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`5.
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`This Court may exercise personal jurisdiction over Motorola. Motorola conducts
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 2 of 7 PageID #:2
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`continuous and systematic business in Illinois and in this District. Motorola maintains corporate
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`offices in this District. This patent-infringement case arises directly from Motorola’s continuous
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`and systematic activity in this District. In short, this Court’s exercise of jurisdiction over Motorola
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`would be consistent with traditional notions of fair play and substantial justice.
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`6.
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`7.
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`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b)(2) and 1400(b).
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`Count 1: Infringement of U.S. Patent No. 11,039,123
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`VDPP is the exclusive owner of United States Patent No. 11,039,123 (the “’123
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`Patent”), which is attached hereto as “Exhibit 1.”
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`8.
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`9.
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`The ’123 Patent is valid and enforceable.
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`Motorola has been and is directly infringing the claims of the ‘123 patent. For
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`example, Motorola makes, uses, and sells the BLISS54-2, which infringes Claim 1 of the ’123
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`Patent. The BLISS54-2 includes (1) multiple video inputs that are stitched and displayed; (2) a
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`red-green-blue subpixel arrangement for each pixel, and; (3) a transparent (non-solid color) on-
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`screen display (OSD) or bridge frame that is blended with the picture and displayed. Motorola
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`makes other products that infringe the ’123 Patent. The infringing products include: laptops;
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`tablets; all-in-one computers; notebooks, and smartphones (all models referenced in this paragraph
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`9 are the “Accused Models”).
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`10.
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`Claim 1 of the ’123 Patent provides as follows: “An apparatus adapted to: obtain a
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`first image from a first video stream; obtain a second image from a second video stream, wherein
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`the first image is different from the second image; stitch together the first image and the second
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`image to generate a stitched image frame; generate a first modified image frame by removing a
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`first portion of the stitched image frame; generate a second modified image frame by removing a
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 3 of 7 PageID #:3
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`second portion of the stitched image frame; generate a third modified image frame by removing a
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`third portion of the stitched image frame; wherein the first modified image frame, the second
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`modified image frame, and the third modified image frame are different from each other; identify
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`a bridge frame that is a non-solid color; blend the first modified image frame with the bridge frame
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`to generate a first blended frame; blend the second modified image frame with the bridge frame to
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`generate a second blended frame; blend the third modified image frame with the bridge frame to
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`generate a third blended frame; display the first blended frame, the second blended frame, and the
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`third blended frame.” (Ex. 1 at 112:53-113:5.)
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`11.
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`The BLISS54-2 includes Picture-by-Picture (“PbP”). This means that the
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`BLISS54-2 can obtain a first image from a first video stream from an input port to the monitor.
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`12.
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`The BLISS54-2’s PbP allows the monitor to also obtain a second image from a
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`second video stream from an input port to the monitor. Since the two video streams can be
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`different, the first image is different from the second image. The BLISS54-2 can stitch together
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`the first image and the second image. This generates a stitched image.
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`13.
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`The BLISS54-2 removes the Green and Blue color from the stitched image frame
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`(leaving just Red) to generate a first modified image frame.
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`14.
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`The BLISS54-2 removes the Red and Blue color from the stitched image frame
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`(leaving just the Green) to generate a second modified image frame.
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`15.
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`The BLISS54-2 removes the Red and Green color from the stitched image frame
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`(leaving just the Blue) to generate a third modified image frame. The first modified image frame,
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`the second modified image frame, and the third modified image frame are different from each
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`other.
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 4 of 7 PageID #:4
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`16.
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`17.
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`The BLISS54-2 has a transparent menu that is a non-solid color.
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`The BLISS54-2 blends the first modified image frame with the bridge frame to
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`generate a first blended frame.
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`18.
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`The BLISS54-2 blends the second modified image frame with the bridge frame to
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`generate a second blended frame.
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`19.
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`The BLISS54-2 blends the third modified image frame with the bridge frame to
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`generate a third blended frame.
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`20.
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`The BLISS54-2 displays the first blended frame, the second blended frame, and the
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`third blended frame. The transparent menu blended with each of the underlying subpixel blended
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`frames is displayed.
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`Count 2: Infringement of U.S. Patent No. 9,426,452
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`The preceding paragraphs are incorporated herein by reference.
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`VDPP is the exclusive owner of U.S. Patent No. 9,426,452 (the “’452 Patent”),
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`21.
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`22.
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`which is attached hereto as “Exhibit 2.”
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`23.
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`24.
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`25.
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`The ’452 Patent is valid and enforceable.
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`The Accused Models infringe Claim 4 of the ’452 Patent.
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`Claim 2 provides, “An apparatus comprising: a storage adapted to: store one or
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`more image frames; and a processor adapted to: obtain a first image from a first video stream;
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`obtain a second image from a second video stream, wherein the first image is different from the
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`second image; stitch together the first image and the second image to generate a stitched image
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`frame; generate a first modified image frame by removing a first portion of the stitched image
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`frame; generate a second modified image frame by removing a second portion of the stitched image
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 5 of 7 PageID #:5
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`frame; generate a third modified image frame by removing a third portion of the stitched image
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`frame; wherein the first modified image frame, the second modified image frame, and the third
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`modified image frame are different from each other; identify a bridge frame; blend the first
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`modified image frame with the bridge frame to generate a first blended frame; blend the second
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`modified image frame with the bridge frame to generate a second blended frame; blend the third
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`modified image frame with the bridge frame to generate a third blended frame; overlay the first
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`blended frame, the second blended frame, and the third blended frame to generate a combined
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`frame; display the combined frame.”
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`26.
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`Claim 4 provides, “The apparatus of claim 2, wherein the bridge frame comprises
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`a non-solid color.”
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`27.
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`The BLISS54-2 includes PbP. This means BLISS54-2 can obtain a first image
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`from a first video stream from an input port to the monitor.
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`28.
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`The BLISS54-2’s PbP allows the monitor to also obtain a second image from a
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`second video stream from an input port to the monitor. Since the two video streams can be
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`different, the first image is different from the second image. The BLISS54-2 can stitch together
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`the first image and the second image. This generates a stitched image.
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`29.
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`The BLISS54-2 removes the Green and Blue color from the stitched image frame
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`(leaving just Red) to generate a first modified image frame.
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`30.
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`The BLISS54-2 removes the Red and Blue color from the stitched image frame
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`(leaving just the Green) to generate a second modified image frame.
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`31.
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`The BLISS54-2 removes the Red and Green color from the stitched image frame
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`(leaving just the Blue) to generate a third modified image frame. The first modified image frame,
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 6 of 7 PageID #:6
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`the second modified image frame, and the third modified image frame are different from each
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`other.
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`32.
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`33.
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`The BLISS54-2 has a transparent menu that is a non-solid color.
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`The BLISS54-2 blends the first modified image frame with the bridge frame to
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`generate a first blended frame.
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`34.
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`The BLISS54-2 blends the second modified image frame with the bridge frame to
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`generate a second blended frame.
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`35.
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`The BLISS54-2 blends the third modified image frame with the bridge frame to
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`generate a third blended frame.
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`36.
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`The BLISS54-2 displays the first blended frame, the second blended frame, and the
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`third blended frame. The transparent menu blended with each of the underlying subpixel blended
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`frames is displayed.
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`Prayer for Relief
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`WHEREFORE, VDPP prays for the following relief against Motorola: (a) Judgment that
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`Motorola has directly infringed the ’123 Patent and the ’452 Patent; (b) a reasonable royalty; (c)
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`pre-judgment interest and post-judgment interest at the maximum rate allowed by law; and (d)
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`such other and further relief as the Court may deem just and proper.
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`Demand for Jury Trial
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`VDPP demands a trial by jury on all matters and issues triable by jury.
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`Case: 1:22-cv-03280 Document #: 1 Filed: 06/23/22 Page 7 of 7 PageID #:7
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`Date: June 23, 2022
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`Respectfully Submitted,
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`/s/ Matthew M. Wawrzyn
`Matthew M. Wawrzyn (ARDC#6276135)
`matt@wawrzynlaw.com
`WAWRZYN LLC
`200 East Randolph Street, Suite 5100
`Chicago, IL 60601
`312.235.3120
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`Counsel for VDPP LLC
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