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`Case: IPR2018-01592
`Patent No.: 9,320,122
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`EXHIBIT 1004
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`PRIME WIRE & CABLE, INC.
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` Petitioner,
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`v.
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`CANTIGNY LIGHTING
`CONTROL, LLC.
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` Patent owner
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`JASCO PRODUCTS, INC.
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` Licensee
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 1 of 17 PagelD #:1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`CANTIGNY LIGHTING CONTROL, LLC
`
`Plaintiff,
`
`VS.
`
`Civil Action No. 16-cv-05794
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`JURY TRIAL DEMANDED
`
`JASCO PRODUCTS COMPANYLLCand
`AVI-ON LABS, INC.
`
`Defendant.
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`
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`COMPLAINT FOR PATENT INFRINGMENT
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`Plaintiff Cantigny Lighting Control, LLC complains of Defendants Jasco Products
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`Company LLC and Avi-On Labs,Inc. as follows:
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`THE PARTIES
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`1.
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`Plaintiff Cantigny Lighting Control, LLC (“Cantigny”) is an Illinois limited
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`liability company having a place of business at 2018 Dorset Drive, Wheaton,Illinois. Cantigny
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`holds total legal ownership of and has standing to sue for infringement of U.S. Patent No.
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`9,320,122, entitled “Programmable Light Timer and a Method of Implementing a Programmable
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`Light Timer,” whose inventor is John King (the “’122 Patent”, attached hereto as Exhibit A).
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`Cantigny also holds total legal ownership of and has standing to sue for infringement of U.S.
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`Patent No. 9,226,373, also entitled “Programmable Light Timer and a Method of Implementing a
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`Programmable Light Timer,” whose inventor is also John King (the ’373 Patent”, attached hereto
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`as Exhibit B). Jointly, these patents are referred to herein as the “Cantigny Patents.” Cantigny
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`was formed by Mr. King as a vehicle for the development of consumer products using his
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`inventionsin light timing technology.
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`EXHIBIT 1004 Page 1 of 17
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`EXHIBIT 1004 Page 1 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 2 of 17 PagelD #:2
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`2.
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`Defendant Jasco Products Company LLC (“Jasco”)
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`is
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`a limited liability
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`corporation having a principal place of business at 10 E. Memorial Rd., Oklahoma City, OK
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`73114. Cantigny contends that Jasco’s products infringe at least the °122 Patent and the °373
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`Patent as alleged below. Jasco has previously andis presently making, using,selling, offering for
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`sale, and/or importing into the United States products that infringe one or more claims of the
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`*122 and ’373 Patents. Jasco has also indirectly infringed the ’373 Patent.
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`3.
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`Avi-On Labs, Inc.
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`(“Avi-On”) is a corporation having a principal place of
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`business at 2570 Rasmussen Road, Suite 206, Park City, UT 84098. Avi-Onhas previously and
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`is presently making, using, selling, offering for sale and/or importing into the United States
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`products that infringe one or more claims of the *373 Patent, in collaboration with Jasco. Avi-On
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`has also indirectly infringed the ’373 Patent.
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`JURISDICTION AND VENUE
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`4.
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`This action arises under the patent laws of the United States, e.g., 35 U.S.C. §§
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`271, 281, 283-285. Subject matter jurisdiction exists under 28 U.S.C. §§ 1331 and 1338(a).
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`5.
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`Jasco has transacted business by making, using, selling, or offering to sell and
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`distributing products that infringe the Cantigny Patents. Such sales and offers to sell include
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`sales and offers to sell in this judicial district. Accordingly, this Court has personal jurisdiction
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`over Jasco. Avi-On hasalso transacted business by making,using,selling, or offering to sell and
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`distributing products that infringe the Cantigny Patents. Such sales and offers to sale include
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`sales and offers to sell in this judicial district. Accordingly, this Court has personal jurisdiction
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`over Avi-On. Venueis proper in this Court under 28 U.S.C. § 1391(c) and/or 1400(b).
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`EXHIBIT 1004 Page 2 of 17
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`EXHIBIT 1004 Page 2 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 3 of 17 PagelD #:3
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`FACTUAL BACKGROUND
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`6.
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`Jasco manufactures homeelectrical products for sale to the public. Avi-On creates
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`software for use with certain Jasco products, and offers Jasco wirelessly programmable products
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`for sale on their website.
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`7.
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`Jasco products include a number of homeelectrical timer products, including the
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`GE MyTouchSmart™ Indoor Plug-In Digital Timer, the GE MyTouchSmart™ Indoor/Outdoor
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`Plug-In Digital Timer, the GE MyTouchSmart™ In-Wall Digital Timer, the GE Digital Plug-In
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`TouchSmart™ Timer, and the GE In-Wall TouchSmart™ Digital Timer.
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`8.
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`Jasco also manufactures a number of Bluetooth enabled timer products, which are
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`used with the Avi-On software including the GE Plug-in Smart Switch, the GE Plug-in Smart
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`Dimmer, the GE Plug-in Outdoor Smart Switch, the GE In-Wall Smart Switch and the GE In-
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`Wall Smart Dimmer. These products are also offered for sale by Avi-On on the Avi-On website,
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`and operate with Avi-On software.
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`9.
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`The infringing products include three different types. The first type of infringing
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`product permits the user to set the time, and program separate on and off times. This feature is
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`present in the GE MyTouchSmart™ Indoor Plug-In Digital Timer, the GE MyTouchSmart™
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`Indoor/Outdoor Plug-In Digital Timer, and the GE MyTouchSmart™ In-Wall Digital Timer and
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`may include other Jasco products (the “Programmable Timers”). The second type of infringing
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`product permits the user to set the time and then select between multiple pre-stored timing
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`patterns. These are the GE MyTouchSmart™ Indoor Plug-In Digital Timer,
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`the GE
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`MyTouchSmart™ Indoor/Outdoor Plug-In Digital Timer, the GE Digital Plug-In TouchSmart™
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`Timer, and the GE In-Wall TouchSmart™ Digital Timer and may include other Jasco products
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`(the “Pre-Stored Timers”). Some products have both of these two feature sets. The third type of
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`EXHIBIT 1004 Page 3 of 17
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`EXHIBIT 1004 Page 3 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 4 of 17 PagelD #:4
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`infringing product
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`is wirelessly programmable timers, which permit a user to download a
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`program to them. These are the GE Plug-in Smart Switch, the GE Plug-in Smart Dimmer, the GE
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`Plug-in Outdoor Smart Switch, the GE In-Wall Smart Switch and the GE In-Wall Smart Dimmer
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`(the “Wireless Timers”), and may include other Jasco or Avi-Onproducts.
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`10.
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`Jasco makes, uses, sells, offers to sell and distributes its products to customers in
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`the United States.
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`11.
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`The infringing Jasco products include the Programmable Timers, the Pre-Stored
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`Timers, and the Wireless Timers.
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`12.
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`The infringing products sold and offered for sale by Avi-On are the Wireless
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`Timers, and Jasco makes, uses, sells and offers the Avi-On software forsale.
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`COUNTI
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`INFRINGEMENT OF THE °122 PATENT BY THE PROGRAMMABLETIMERS
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`13.|Cantigny hereby incorporates paragraphs 1-12 aboveby reference.
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`14.
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`Jasco has directly infringed and continues to directly infringe at least claims 1, 6
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`and 7 of the ’122 Patent through using, selling and/or importing the Programmable Timers. Jasco
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`offers the products for sale through their web site and other distribution channels throughout the
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`United States.
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`15.
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`Claim 1 is an infringed claim. Claim 1 is infringed by the Programmable Timers.
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`The exemplar of infringement is the MyTouchSmart™ In-Wall Digital Timer. The preamble of
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`claim 1
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`states: “A programmable light
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`timer
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`for
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`implementing a timing pattern,
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`the
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`programmable light timer comprising[.]” The MyTouchSmart™ In-Wall Digital Timer is a
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`programmable timer. The use described for the timer on the Jasco website is “replac[ing]
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`existing light switch.” Exhibit C, Features. Steps two and three of the setup description in Exhibit
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 5 of 17 PagelD #:5
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`D, demonstrate setting the time and setting custom on and off times, and states that “[alll
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`programmedtimes will run simultaneously in a 24 hour day.” (Exhibit D).
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`The product also explicitly describes controlling lights in step 4, the manual override.
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`The product is, therefore, a programmable light timer, which implements user-input timing
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`patterns.
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`16.
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`The first element of the claim is “an actuator on a user interface of the
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`programmable light timer enabling a selection of a time for the programmable light timer.” Step
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`2 of Exhibit B demonstrates using the actuators (the up and down arrows) toset the time.
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`The user interface is the set of control buttons and the display of the timer, as shown in
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`the picture accompanying step 2. The MyTouchSmart™ In-Wall Digital Timer therefore has an
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`actuator on the interface enabling selection of a time. These same actuators are used both to set
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`the clock time and to set the program times for the two available user programs.
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 6 of 17 PagelD #:6
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`17.
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`The second element of the claim is “a control circuit coupled to the actuator[.]”
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`The MyTouchSmart™In-Wall Digital Timer contains circuitry which controls the display of the
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`clock and the time for programs, and which is connectedto the actuators permitting the changing
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`of both clock time and program time. This circuitry meets the second elementofthe claim.
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`18. The third element of the claim is “a display coupled to the control circuit, wherein a
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`time selected by the actuator is provided on the display[.]” The MyTouchSmart™ In-Wall
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`Digital Timer includes an LCD display which showsthe time selected by the actuator both for
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`clock time and for selected program times. The time selected by the actuator is provided on the
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`display both during setting of the clock and the programmed “my on” and “my off” times.
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`19.
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`The fourth element of the claim is “a first button on the user interface of the
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`programmable light timer, wherein the first button is programmable to have an on time[.]” The
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`“my on” time buttons are each programmable to have an on time.
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`20.
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`The final element of the claim is “a second button on the user interface of the
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`programmable timer, wherein the second button is programmable to have an off time.” The “my
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`off” buttons are each programmable to have an off time.
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`21.
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`As each element of claim 1
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`is present in the MyTouchSmart™ In-Wall Digital
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`Timer, claim 1 of the ’122 is infringed by the MyTouchSmart™In-Wall Digital Timer. All of the
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`Programmable Timersinfringe this claim.
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`22.
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`Claim 6 calls for “The programmable light timer of claim 1 further comprising a
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`third button having a pre-stored timing pattern.” The GE MyTouchSmart™ Indoor Plug-In
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`Digital Timer and the GE MyTouchSmart™ Indoor/Outdoor Plug-In Digital Timer each have
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`such a third button, including programs such as “evening” or “morning”. These two products
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`also infringe claim 6.
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`EXHIBIT 1004 Page 6 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 7 of 17 PagelD #:7
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`23.
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`Claim 7 calls for “The programmable timer of claim 1 further comprising a switch
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`enabling overriding the timing pattern implemented by the programmablelight timer.” The ‘on’
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`switch on the MyTouchSmart™ In-Wall Digital Timer overrides the timing pattern. The
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`MyTouchSmart™In-Wall Digital Timerinfringes claim 7.
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`COUNTII
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`INFRINGEMENTOF THE ’122 PATENT BY THE PRE-STORED TIMERS
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`24.|Cantigny hereby incorporates paragraphs 1-23 above by reference.
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`25.
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`Jasco has also directly infringed and continuesto directly infringe at least claims
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`8, 9, 10, 11, 12, 13, and 14 of the ’122 Patent through using, selling and/or importing the
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`Programmable Timers. Jasco offers the products for sale through their web site and other
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`distribution channels throughout the United States.
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`26.
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`Claim 8 is an infringed claim. Claim 8 is infringed by the Pre-Stored Timers. The
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`exemplar of infringement
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`is the GE MyTouchSmart™ Indoor Plug-In Digital Timer. The
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`preamble of claim 1 states: “A programmable light timer for implementing a timing pattern, the
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`programmable light timer comprising[.]” The GE MyTouchSmart™ Indoor Plug-In Digital
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`Timeris a programmable timer. Like the other Jasco products, the use for the timer is to control
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`lighting products. Step II of the setup description in Exhibit E, demonstrates selection and use of
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`pre-stored programsthat “run individually or simultaneously” (Exhibit E).
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`EXHIBIT 1004 Page 7 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 8 of 17 PagelD #:8
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`The productis, therefore, a programmable light timer for implementing a timing pattern.
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`27.
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`The first element of the claim is “an actuator on a user interface of the
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`programmable light timer enabling a selection of a time for the programmable light timer.” Step
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`2 of Exhibit E demonstrates using the actuators (the up and down arrows)to set the time.
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`The user interface is the set of control buttons and the display of the timer, as shown in
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`the picture accompanying step 2. The GE MyTouchSmart™ Indoor Plug-In Digital Timer
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`therefore has an actuator on the interface enabling selection of a time. These same actuators are
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`used both to set the clock time andto set the program times for the user programs.
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`28.
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`The second element of the claim is “a control circuit coupled to the actuator[.]”
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`The GE MyTouchSmart™ Indoor Plug-In Digital Timer contains circuitry which controls the
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 9 of 17 PagelD #:9
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`display of the clock and the time for programs, and which is connected to the actuators
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`permitting the changing of both clock time and program time. This circuitry meets the second
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`element of the claim.
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`29. The third element of the claim is “a display coupled to the control circuit, wherein a
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`time selected by the actuator is provided on the display[.]” The GE MyTouchSmart™ Indoor
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`Plug-In Digital Timer includes an LCD display which showsthe time selected by the actuator
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`both for clock time and for selected program times. The time selected by the actuator is provided
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`on the display both during setting of the clock and the programmed “my on” and “my off” times.
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`30.
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`The fourth element of the claim is “a first button on the user interface of the
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`programmable light timer, the first button enabling the selection of a first pre-stored timing
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`pattern[.]” The “evening” button enables the selection of a preset schedule from 5 pm to
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`midnight.
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`31.
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`The final element of the claim is “a second button on the user interface of the
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`programmable timer, the second button enabling the selection of a second pre-stored timing
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`pattern.” The “morning” button enables the selection of a preset schedule from 5 am to 8 am.
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`32.
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`As each elementof claim 8 is present in the GE MyTouchSmart™Indoor Plug-In
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`Digital Timer, claim 8 of the ’122 is infringed by the GE MyTouchSmart™ Indoor Plug-In
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`Digital Timer. All of the Pre-Stored Timers infringe this claim.
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`33.
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`Claim 9 calls for “The programmable light timer of claim 8 further comprising a
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`third button that is user-programmable.” Each of the Pre-Stored Timers which include the my on
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`time and myoff time features also infringes this claim, as they have a third (and fourth) button
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`which is user-programmable. This includes the GE MyTouchSmart™ Indoor Plug-In Digital
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`Timer and the GE MyTouchSmart™Indoor/Outdoor Plug-In Digital Timer.
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`EXHIBIT 1004 Page 9 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 10 of 17 PagelD #:10
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`34.
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`Claim 10 calls for “The programmable light timer of claim 9 wherein the third
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`button is programmable with a user-programmable on time.” Each of the GE MyTouchSmart™
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`Indoor Plug-In Digital Timer and the GE MyTouchSmart™ Indoor/Outdoor Plug-In Digital
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`Timer has the my on time button, which is programmable with an on time. Each of the GE
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`MyTouchSmart™ Indoor Plug-In Digital Timer and the GE MyTouchSmart™ Indoor/Outdoor
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`Plug-In Digital Timer infringe claim 10.
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`35.
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`Claim 11 calls for “The programmable light timer of claim 10 further comprising
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`a fourth button that is user programmable.” Each of the GE MyTouchSmart™ Indoor Plug-In
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`Digital Timer and the GE MyTouchSmart™ Indoor/Outdoor Plug-In Digital Timer have a fourth
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`button that is programmable, the my off time button, and infringe claim 11.
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`36.
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`Claim 12 calls for “The programmable light timer of claim 11 wherein the fourth
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`button is programmable with a user programmable an off time.” The GE MyTouchSmart™
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`Indoor Plug-In Digital Timer and the GE MyTouchSmart™ Indoor/Outdoor Plug-In Digital
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`Timer myoff time button is so programmable, and they each infringe claim 12.
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`37.
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`Claim 13 calls for “The programmable light timer of claim 8 wherein the actuator
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`enables an up or down operation for selecting a time used by the programmable light timer.” All
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`of the Pre-Stored Timers contain this feature, with both clock time and program timesset using
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`the up and down arrowactuators in each product.
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`38.
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`Claim 14 calls for “The programmable light timer of claim 8 further comprising a
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`switch enabling overriding the timing pattern implemented by the programmable light timer.”
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`Each of the the GE Digital Plug-In TouchSmart™ Timer, and the GE In-Wall TouchSmart™
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`Digital Timerinclude this feature, with dedicated on and off buttons used to manually control the
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`device plugged into the timer.
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`10
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`EXHIBIT 1004 Page 10 of 17
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 11 of 17 PagelD #:11
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`COUNTII
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`INFRINGEMENTOF THE ’373 PATENT BY THE WIRELESS TIMERS
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`39.|Cantigny hereby incorporates paragraphs 1-38 abovebyreference.
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`40.
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`Jasco and Avi-On have infringed and continue to infringe, both directly and
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`indirectly under 35 U.S.C. §§ 271(b) and 271(c) (inducementand contributory infringement), at
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`least claims 1, 4, 5, 6, 7, 8, 10, 11, 12, 13, and 14 of the ’373 Patent through using,selling,
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`offering to sell and/or importing the Wireless Timers and the Avi-On software. Jasco offers the
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`products for sale through their web site and other distribution channels throughout the United
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`States. Jasco expressly instructs the use of the Avi-On software with the Wireless Timers,
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`specifically including iOS or Android and Bluetooth capability. Avi-Onalso sells and offers the
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`Wireless Timers for sale through their web site, and provides the software andinstructionsfor its
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`use for download, along with expressly instructing the use of iOS or Android devices with
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`Bluetooth capability for their control software. At least through service of this Complaint, Jasco
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`and Avi-On have knowledgeof the ’373 Patent, and notice of the reasonsfor infringement.
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`41.
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`Claim 1 is an infringed claim. The exemplar of infringement is the GE Plug-In
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`Smart Dimmer. The preamble of claim 1 states, “A programmablelight timer for implementing a
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`timing pattern, the programmable light timer comprising[.|” The GE Plug-In Smart Dimmeris a
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`device to “wirelessly control lights from your smartphoneor tablet,” and to “control, adjust
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`brightness and schedule table and floor lamps.” Exhibit F, Product Box for GE Plug-In Smart
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`Dimmer.It is programmable using the Avi-Onsoftware to load timing patterns into its memory,
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`via a Bluetooth connection from a Bluetooth device such as an Android product or iPhone. It
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`plugs into the wall and is a light timer between the wall circuit and the light, which is in turn
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`pluggedinto the socket on the side of the GE Plug-In Smart Dimmer.
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`11
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`42.
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`The first element of claim 1 calls for “a memory storing at least one timing
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`pattern, the at least one timing pattern having one or more on/off settings for a time period[.]”
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`The GE Plug-In Smart Dimmercontains memory whichstores the programs input from the Avi-
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`On software. This includes on andoff times, as well as days of the week for which the pattern
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`should be enabled.
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`43,
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`The second element of claim 1 calls for “a wireless communication circuit
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`configured to receive, using a wireless communication protocol, the at least one timing pattern
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`selected on a user interface of a wireless device having a corresponding wireless communication
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`circuit, the user interface enabling the selection of the at least one timing pattern[.]” The GE
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`Plug-In Smart Dimmercontains a Bluetooth communications circuit over which it receives the
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`12
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`Case: 1:16-cv-05794 Document#: 1 Filed: 06/02/16 Page 13 of 17 PagelD #:13
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`programming from the Avi-On wireless device, which may be used to select and send the
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`program (the timing pattern) to the GE Plug-In Smart Dimmer. Anyallowed wireless device also
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`contains the Bluetooth circuit required to connect to the GE Plug-In Smart Dimmer. Both Jasco
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`and Avi-On specifically teach and encourage the use of iOs and Android products to be used
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`with the Avi-On software and the Wireless Timers.
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`44.
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`The third element of claim 1 calls for “wherein the user interface is configured to
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`receive a security code enabling the downloading of the timing pattern to the memory using the
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`wireless communication protocol.” In the case of the Avi-On user interface, the Avi-On software
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`provides a login page, including a password. The password permits the downloading of timing
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`pattern to the GE Plug-In Smart Dimmeronceit is claimed by a given user.
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`AVION
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`Mere|e
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`Forgot password?
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`Other users may not download timing patterns to the device without the use of the proper login.
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`This is a security code enabling the downloadingofthe timing pattern.
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`45.
`
`As each element of claim 1 is present in the GE Plug-In Smart Dimmer,claim 1
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`of the ’373 Patent is infringed by the GE Plug-In Smart Dimmer. All of the Wireless Timers
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`infringe this claim.
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`13
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`46.
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`Claim 3 calls for “The programmable light timer of claim 1 wherein the user
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`interface enables the selection of dusk as an on time of the at least one timing pattern.” This is
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`permitted, as programs maybeset to begin or end at sunrise or sunset.
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`
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`Living Room Lamp
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`5
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`4
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`3
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`o
`7
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`8
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`9
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`: 14271 19
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`Claim 3 is infringed by the Wireless Timers.
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`47.
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`Claim 4 calls for “The programmable light
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`timer of claim 1 wherein the
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`programmable light timer does not include a display.” None of the Wireless Timers include a
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`display. All of the Wireless Timers infringe claim 4.
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`48.
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`The Wireless Timers permit the use of multiple schedules (up to 7) which may be
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`set to run on multiple days of the week, each of which may be separately determinedbythe user.
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`Assuch, the Wireless Timesalso infringe claim 5 which calls for “The programmable light timer
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`of claim 1 wherein the user interface enables the selection of a first on time anda first off time
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`for a first plurality of days of the week.”
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`49.
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`Claim 6 calls for “The programmable light timer of claim 5 wherein the user
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`interface enables the selection of a second on time and a second off time for a second plurality of
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`days of the week.” Because the Wireless Timers permit up to seven schedules to run, each of
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`which may cover multiple days of the week, they infringe claim 6 as well.
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`50.
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`Claim 7 calls for “The programmable light timer of claim 1 wherein the user
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`interface enables an astronomic time for one of the on time or the off time.” As sunrise and
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`sunset may be used as any ofstart or end times in the Wireless Timers, they also infringe this
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`claim.
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`51.
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`Claim 8 is an infringed claim. The exemplar of infringement is the GE Plug-In
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`Smart Dimmer. The preamble ofclaim 8 states, ““A programmablelight timer for implementing a
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`timing pattern, the programmable light timer comprising[.|” The GE Plug-In Smart Dimmeris a
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`device to “wirelessly control lights from your smartphone or tablet,” and to “control, adjust
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`brightness and schedule table and floor lamps.” Exhibit E, Product Box for GE Plug-In Smart
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`Dimmer. The GE Plug-In Smart Dimmer is programmable using the Avi-On software to load
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`timing patterns into its memory, via a Bluetooth connection from a Bluetooth device such as an
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`Android product or iPhone. It plugs into the wall and is a light timer between the wall circuit and
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`the light, which is in turn pluggedinto the socket on the side of the GE Plug-In Smart Dimmer.
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`52.
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`The first element of claim 8 calls for “a memory storing at least one timing
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`pattern, the at least one timing pattern having one or more on/off settings for a time period[.]” As
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`described above, the GE Plug-In Smart Dimmer contains memory which stores the programs
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`input from the Avi-On software. This includes on andoff times, as well as days of the week for
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`which the pattern should be enabled.
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`53.
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`The second element of claim 8 calls for “a wireless communication circuit
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`coupled to receive the at least one timing pattern[.|” The GE Plug-In Smart Dimmercontains a
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`Bluetooth communications circuit which is coupled to the memory, and over which it receives
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`the programming from the Avi-On wireless device, which may be usedto select and send the
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`program (the timing pattern) to the GE Plug-In Smart Dimmer.
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`54.
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`The third element of claim 8 calls for “a control circuit coupled to the wireless
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`communication circuit and enabling receiving the at least one timing pattern from a wireless
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`device, wherein the wireless device comprises a user interface configured to receive a security
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`code enabling the downloading of the timing pattern from the wireless device to the
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`programmable light
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`timer.” As described above,
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`the GE Plug-In Smart Dimmer receives
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`programs from the Avi-On software only once it has been claimed, and once the proper login is
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`entered. The control circuit in the GE Plug-In Smart Dimmerpermits the downloading of timing
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`pattern to the GE Plug-In Smart Dimmeronceit is claimed by a given user but precludes such
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`downloadsif the improper login is used, as described above.
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`55.
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`As each element of claim 8 is present in the GE Plug-In Smart Dimmer, claim 8
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`of the ’373 Patent is infringed by the GE Plug-In Smart Dimmer. All of the Wireless Timers
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`infringe this claim.
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`56.
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`Claims 10, 11, 12, 13 and 14 are also infringed by the Wireless Timers, as
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`described above in paragraphs 46 and 48-50.
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`57.
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`Additional products may infringe additional claims of the Cantigny Patents or
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`additional patents owned by Cantigny and be determined during discovery in this case. Cantigny
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`reserves the right to amendthe pleadingsto state additional claims for infringement.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff Cantigny asks this Court
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`to enter judgment against Jasco
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`Products, LLC and Avi-On Labs,Inc. and against their respective subsidiaries, affiliates, agents,
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`servants, employees and all persons in active concert or participation with it, granting the
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`followingrelief:
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`A.
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`An award of damages adequate to compensate Cantigny for the infringement that
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`has occurred,
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`together with prejudgment
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`interest from the date infringement
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`B.
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`C.
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`D.
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`began andstatutory costs;
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`An award to Cantignyof all remedies available under 35 U.S.C. § 284;
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`An award to Cantigny ofall remedies available under 35 U.S.C. § 285;
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`A permanent
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`injunction prohibiting further
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`infringement,
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`inducement and
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`contributory infringement of the Cantigny Patents; and,
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`E.
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`Such other and furtherrelief as this Court or a jury may deem properandjust.
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`JURY DEMAND
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`Cantigny demandsa trial by jury onall issuessotriable.
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`Dated:
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`June 2, 2016
`
`Cantigny Lighting Control, LLC
`
`
`William W. Flachsbart
`By:/s/ William W.Flachsbart
`William W.Flachsbart
`Robert P. Greenspoon
`FLACHSBART & GREENSPOON, LLC
`333 North Michigan Avenue, Ste 2700
`Chicago, IL 60601
`T: 312-551-9500
`F: 312-551-9501
`
`Attorneysfor Plaintiff
`Cantigny Lighting Control, LLC
`
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