Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 1 of 14 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Plaintiff,
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`Defendant.
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`Case No.:
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`§
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`§
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`§
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`COMPLAINT
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`GREE, INC.,
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`v.
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`SUPERCELL OY,
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`Plaintiff GREE, Inc. (“GREE” or “Plaintiff”) files this Complaint against Supercell Oy
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`(“Supercell” or “Defendant”). In this Complaint, GREE asserts U.S. Patent No. 10,518,177
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`(the “’177 patent”) against at least Supercell’s “Clash Royale” game. GREE alleges as follows:
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`PARTIES
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`1.
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`Plaintiff GREE is a corporation organized under the laws of Japan with a
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`principal place of business at 6-10-1, Roppongi, Roppongi Hills Mori Tower Minato-Ku,
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`Tokyo, Japan.
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`2.
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`Defendant Supercell Oy is a corporation organized under the laws of Finland,
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`with a principal place of business at Itämerenkatu 11-13, Helsinki, Uusimaa, 00180, Finland.
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`JURISDICTION AND VENUE
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`3.
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`This action arises under the patent laws of the United States, Title 35 of the
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`United States Code. Accordingly, this Court has jurisdiction over the subject matter of this
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`action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`4.
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`This Court has personal jurisdiction over Supercell because it has, directly or
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`through agents and/or intermediaries, committed acts within Texas, including within this
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 1 of 16
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`

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`District, giving rise to this action and/or has established minimum contacts with Texas and this
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`District such that the exercise of jurisdiction would not offend traditional notions of fair play
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`and substantial justice.
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`5.
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`Supercell regularly conducts business in Texas, including this District, and
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`purposefully avails itself of the privileges of conducting business in Texas. In particular,
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`Supercell, directly and/or through its agents and/or intermediaries, makes, uses, imports, offers
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`for sale, sells, and/or advertises its products and affiliated services in Texas, including this
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`District. Defendant has placed, and continues to place, infringing products into the stream of
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`commerce, via an established distribution channel, including iTunes and Google Play stores,
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`with the knowledge and/or understanding that such products are sold to and/or used by users in
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`the United States, including in Texas and specifically including this District.
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`6.
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`Alternatively, and/or in addition, this Court has jurisdiction over Supercell Oy
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`under Federal Rule of Civil Procedure 4(k)(2). This action arises from actions of Supercell Oy
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`directed toward the United States, including (1) committing at least a portion of the infringing
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`acts alleged herein and (2) regularly transacting business, soliciting business, and deriving
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`revenue from the sale of goods and services, including infringing goods and services, to
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`individuals in the United States. Therefore, Supercell Oy has purposefully availed itself of the
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`benefits of the United States, including the Eastern District of Texas, and the exercise of
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`jurisdiction over Supercell would not offend traditional notions of fair play and substantial
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`justice.
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`7.
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`Venue is proper in this District pursuant to 28 U.S.C. § 1391(c), as Supercell Oy
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`is not a resident of the United States.
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`- 2 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 2 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 3 of 14 PageID #: 3
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`GREE AND THE ASSERTED PATENT
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`8.
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`GREE is a global social media company that provides mobile content and
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`services, including games, entertainment, media, advertising, and investment services.
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`9.
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` Originally founded in 2004, GREE has long sought to develop and create
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`innovative solutions in gaming and social networking. GREE has sought to protect its
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`investments in innovation by obtaining patent protection. GREE currently hold patents
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`covering various improvements in digital and gaming technology in countries throughout the
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`world, including the United States.
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`10.
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`GREE is the owner by assignment of all right, title, and interest in and to the
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`’177 patent entitled “Game control method, system, and non-transitory computer-readable
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`recording medium,” which duly and legally issued at 12:00 a.m. Eastern Standard Time on
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`December 31, 2019.
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`11.
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`The ’177 patent describes and claims different aspects of innovative systems and
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`methods for controlling and presenting games to users on a computer or mobile device.
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`Specifically, the ʼ177 patent describes innovative systems and methods “that allow a wide
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`range of players to enjoy a group battle without regard for difference in level, degree of attack
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`strength, or the like and that, in a group battle limited to a time slot, improve the participation
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`rate throughout the set time slot.” U.S. Pat. App. Pub. 2015/0238862 at ¶ 0011.
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`12.
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`The specification of the ’177 patent explains that in conventional games, “the
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`participation rate of group members tends to increase in the last half of the time slot,” but that a
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`game provider “wants players to participate actively in the battle throughout the entire time set
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`for the group battle and to enjoy the game during the entire set time.” Id. at ¶¶ 0008-09. The
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`specification further explains that in conventional games, “a battle may be fought with
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`- 3 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 3 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 4 of 14 PageID #: 4
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`opponents having vastly dissimilar attack strengths” and that “beginners may therefore be
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`unsuccessful” and thus “may end up passively participating in a group battle.” Id. at ¶ 0010.
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`13.
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`To resolve these issues, the specification describes an innovative user interface
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`and game play that “divid[es] the battle into a plurality of time slots” and “set[s] a battle
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`condition of at least one of the time slots . . . to differ from a battle condition of a second time
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`slot . . . .” Id. at ¶ 0012. The specification further explains that “[b]y dividing the time slot of
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`the battle game into a plurality of time slots and setting the battle condition for each time slot, a
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`battle game that has conventionally been played under certain rules can be changed . . . .” Id. at
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`¶ 0013. The example is given of “setting a battle condition that is advantageous for a certain
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`target and by changing the battle condition in the time slot for the first half, for example, when
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`the participation rate in the time slot battle game is not high, an increase in the participation rate
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`of characters throughout the time slots can be expected.” Id.
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`14.
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`In addition, the specification explains that “circumstances that allow beginners
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`to enjoy the battle can be created by setting the battle conditions for example to increase the
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`attack strength of low-level characters, which correspond to beginners, and to favor beginners
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`in the first half in which the participation rate in the battle is not very high.” Id.
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`15.
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`The claims of the ’177 patent are rooted in computer technology and cannot be
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`performed without a computer. The claims are directed to specific improved graphical user
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`interfaces and functionality on computers and mobile devices, and are inextricably tied to
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`computer technology.
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`16.
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`A computer-implemented game using the particular visual presentation
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`described and claimed in the ʼ177 patent was not common or conventional in the art of
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`computer-implemented battle games at the time of the invention of the ʼ177 patent.
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`- 4 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 4 of 16
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`

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`Conventional card-based battle games did not include two terms with two distinct battle
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`conditions in the manner described and claimed in the ʼ177 patent. The particular user
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`interface and manner of conducting the game greatly enhanced the visual effect for users.
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`17.
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`These improvements over prior art and conventional gaming devices, systems,
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`and methods represent meaningful limitations and/or inventive concepts. Further, in view of
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`these specific improvements, the inventions of the asserted claims, when such claims are
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`viewed as a whole and in ordered combination, are not routine, well-understood, conventional,
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`generic, existing, commonly used, well-known, previously known, or typical.
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`GENERAL ALLEGATIONS
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`18.
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`Defendant Supercell makes, uses, sells, offers for sale, and/or imports into the
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`United States gaming systems, software, or methods for controlling games in which users do
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`battle, including Clash Royale.
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`19.
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`Clash Royale operates on computers and mobile devices, including those with
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`iOS and Android operating systems.
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`20.
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`Defendant Supercell operates, places into service, or otherwise controls a
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`plurality of servers worldwide, including in the United States, on which Supercell operates, and
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`its customers and other users use, software related to Clash Royale and on which Supercell
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`stores user data associated with the products.
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`21.
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`Clash Royale has millions of registered users worldwide, including in the United
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`States and Texas.
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`22.
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`Supercell has had knowledge of the ʼ177 patent at least since the date of filing of
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`this Complaint.
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`- 5 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 5 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 6 of 14 PageID #: 6
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`COUNT I—INFRINGEMENT OF THE ’177 PATENT
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`23.
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`GREE re-alleges and incorporates by reference each and every allegation
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`contained in the paragraphs 1-22 as if fully set forth herein.
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`Supercell directly infringes at least claim 1 of the ’177 patent by, without
`24.
`authority, making, using, importing, selling, or offering to sell Clash Royale in the United
`States, in violation of 35 U.S.C. § 271(a).
`For example, claim 1 of the ʼ177 patent recites:
`25.
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`[preamble] A non-transitory computer-readable recording medium storing
`instructions to be executed by one or a plurality of computers capable of being
`used by a player conducting a battle game, the instructions causing the one or a
`plurality of computers to execute steps of:
`[a] displaying, on a first field, a plurality of cards selected from a deck which is a
`stack of virtual cards;
`[b] during a first term of the battle game, conducting a battle to a first opponent
`character based on a parameter set on a card selected by a player’s operation
`under a first battle condition, wherein the first battle condition is not changed
`during the first term;
`[c] at a conclusion of the first term of the battle game, automatically initiating a
`second term of the battle game, and during the second term of the battle game
`continued from the first term, conducting the battle to a second opponent
`character based on the parameter set on the card selected by the player’s operation
`under a second battle condition, wherein the second battle condition is different
`from the first battle condition and is predetermined independent from a battle
`result of the first term, and the first opponent character and the second opponent
`character are same or different, and wherein the second battle condition is not
`changed during the second term; and
`[d] during a third term of the battle game continued from the second term,
`conducting the battle to a third opponent character based on the parameter set on
`the card selected by the player’s operation under a third battle condition, wherein
`the third battle condition is different from the second battle condition and is
`dependent on a battle result of the second term, and the second opponent character
`and the third opponent character are same or different, and wherein the third battle
`condition is not changed during the third term.
`To the extent the preamble is limiting, Clash Royale includes “[a] non-transitory
`26.
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`computer-readable recording medium storing instructions to be executed by one or a plurality
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`- 6 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 6 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 7 of 14 PageID #: 7
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`of computers capable of being used by a player conducting a battle game.” The Clash Royale
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`game allows users to “[d]uel players from around the world in real-time in both 1v1 and 2v2
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`Battles” using computers or mobile devices running the iOS or Android operating systems. See
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`https://itunes.apple.com/us/app/clash-royale/id1053012308?mt=8. An example is shown in the
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`annotated figure below.
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`27. With respect to element 1[a], Clash Royale displays on a first field, a plurality of
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`cards selected from a deck which is a stack of virtual cards.
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`
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`28. With respect to claim element 1[b], during a first term of the battle game, a
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`- 7 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 7 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 8 of 14 PageID #: 8
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`battle is conducted to a first opponent character based on a card selected by a player’s operation
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`under a first battle condition which is not changed during the first term. For example, in Clash
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`Royale, a battle is normally three minutes, and the first period of the battle is two minutes.
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`During that two minute period, elixir increases at a predetermined rate. Also, the battle does
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`not end if the Princess Towers are destroyed; instead the battle ends if the King’s Tower is
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`destroyed. An example is shown in the annotated figures below.
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`
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`29. With respect to claim element 1[c], a second term of the battle game is
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`automatically initiated after the first term. As explained above, a battle typically lasts for three
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`minutes, and at the end of two minutes (the first term), the second term (one minute) is
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`initiated. During the second term, the battle is conducted to a second opponent character based
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`on the parameter set on the card selected by the player’s operation under a second battle
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`condition which is different from the first battle condition and is independent of the battle result
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`of the first term, and the second condition does not change during the second term. Here, for
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`example, when the second term begins, the player’s elixir increases at double the rate of the
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`first term as shown in the figure below.
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`- 8 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 8 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 9 of 14 PageID #: 9
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`30. With respect to claim element 1[d], a third term of the battle game continues in
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`which a third opponent character is battled based on the parameter set on the card selected by
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`the player’s operation under a third battle condition that is different from the second battle
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`condition. For example, as shown below, if the King’s Towers of both players have not been
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`destroyed and the same number of Princess Towers of both players have been destroyed, Clash
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`Royale moves into a one-minute sudden-death overtime period, the ending of which is an
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`example of a third battle condition. Thus, the third term is dependent on a battle result of the
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`second term. Also, the third battle condition is not changed during the third term. Just as
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`during the second term, elixir increases at a rate of double the first term. An example of a third
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`battle condition is that if at least one of the Princess Towers remains after the second term, then
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`the battle ends if one Princess Tower or the King’s Tower is destroyed. Still another example
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`of a third battle condition is that if all Princess Towers are destroyed at that end of the second
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`term, the battle ends if the King’s Tower is destroyed.
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`- 9 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 9 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 10 of 14 PageID #: 10
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`31.
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`Supercell indirectly infringes the ’177 patent within the United States by
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`inducing infringement under 35 U.S.C. § 271(b). For example, since learning of the ’177
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`patent and by failing to cease offering Clash Royale, Supercell has knowingly and intentionally
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`induced Clash Royale users to directly infringe one or more claims of the ’177 patent, inter
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`alia, by (1) providing instructions or information, for example on publicly available websites
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`(see, e.g., https://supercell.helpshift.com/a/clash-royale/?p=web&l=en&s=battle and linked
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`pages), to explain how to use the Clash Royale application in an infringing manner, including
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`the use of the Clash Royale application in the manners described in the foregoing paragraphs,
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`which are expressly incorporated herein, and (2) touting infringing uses of Clash Royale in
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`advertisements, including but not limited to those listed on or available from their websites and
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`other mobile application marketplace websites.
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`32.
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`Supercell indirectly infringes the ’177 patent by contributing to the direct
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`infringement by end users under 35 U.S.C. § 271(c) by providing Clash Royale, which, as
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`evidenced by Supercell’s websites and advertisements (see, e.g.,
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`https://supercell.helpshift.com/a/clash-royale/?p=web&l=en&s=battle and linked pages), is
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`especially made for use in a manner that infringes one or more claims of the ʼ177 patent as
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`described herein and has no substantial non-infringing uses.
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`- 10 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 10 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 11 of 14 PageID #: 11
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`33.
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`GREE has been and continues to be injured by Supercell’s infringement of the
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`’177 patent. GREE is entitled to recover damages adequate to compensate it for Supercell’s
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`infringing activities in an amount to be determined at trial, but in no event less than a
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`reasonable royalty.
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`34.
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`Unless enjoined by this Court, Supercell’s acts of infringement will continue to
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`damage and cause irreparable harm to GREE.
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`35.
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`On information and belief, Supercell’s infringement of the ’177 patent has been
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`willful and deliberate. Supercell has known of the ’177 patent and its infringement thereof and
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`continued its unlawful actions nevertheless. On September 12, 2016, GREE sent a letter to
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`Supercell specifically identifying a foreign counterpart to the ʼ177 patent: JP5793592. At that
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`time, the application that issued as the ʼ177 patent was already pending. Additionally and/or
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`alternatively, Supercell has had knowledge of the application that issued as the ʼ177 patent
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`since at least June 28, 2017, when Supercell answered a Complaint served by GREE for
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`infringement of JP5793592, the Japanese counterpart of the ʼ177 patent in Civil Department 29
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`of the Tokyo District Court. GREE is therefore entitled to increased damages under 35 U.S.C.
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`§ 284 and attorneys’ fees and costs under 35 U.S.C. § 285.
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`PRAYER FOR RELIEF
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`WHEREFORE, GREE prays for relief in its favor, as follows:
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`A.
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`Enter a judgment that Defendant Supercell has infringed, and willfully infringed,
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`the ’177 patent.
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`B.
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`Grant a permanent injunction restraining and enjoining Defendant Supercell and
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`its officers, directors, agents, servants, employees, successors, assigns, parents, subsidiaries,
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`affiliated or related companies, and attorneys from directly or indirectly infringing the ’177
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`- 11 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 11 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 12 of 14 PageID #: 12
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`patent;
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`C.
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`Enter a declaration that this case is exceptional and correspondingly award GREE
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`attorney fees and costs under 35 U.S.C. § 285;
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`D.
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`Award damages, enhanced damages, costs, and prejudgment interest to GREE
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`under 35 U.S.C. § 284; and
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`E.
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`Grant such other and further relief as this Court may deem just and proper.
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`DEMAND FOR JURY TRIAL
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`
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`GREE hereby demands a jury trial on all issues appropriately triable by a jury.
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`DATED: December 30, 2019
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`GILLAM & SMITH, LLP
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`By /s/ Steven D. Moore
` MELISSA R. SMITH
`(Texas State Bar No. 24001351)
`HARRY L. GILLAM, JR.
`(Texas State Bar No. 07921800)
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`Email: melissa@gillamsmithlaw.com
`Email: gil@gillamsmithlaw.com
`
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`- 12 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 12 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 13 of 14 PageID #: 13
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`Of Counsel:
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`KILPATRICK TOWNSEND & STOCKTON LLP
`STEVEN D. MOORE (CA Bar No. 290875)
`TAYLOR J. PFINGST (CA Bar No. 316516)
`Two Embarcadero Center, Suite 1900
`San Francisco, CA 94111
`Telephone: (415) 576-0200
`Facsimile: (415) 576-0300
`Email: smoore@kilpatricktownsend.com
`Email: tpfingst@kilpatricktownsend.com
`
`NORRIS P. BOOTHE (State Bar No. 307702)
`1080 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 326-2400
`Facsimile: (650) 326-2422
`Email: nboothe@kilpatricktownsend.com
`
`JOHN C. ALEMANNI (NC Bar No. 22977)
`TAYLOR HIGGINS LUDLAM (NC Bar No.
`42377)
`4208 Six Forks Road
`Raleigh, NC 27609
`Telephone: (919) 420-1700
`Facsimile: (919) 420-1800
`Email: jalemanni@kilpatricktownsend.com
`Email: tludlam@kilpatricktownsend.com
`
`MICHAEL T. MORLOCK (GA Bar No. 647460)
`1100 Peachtree Street, NE
`Suite 2800
`Atlanta, Georgia 30309
`Telephone: (404) 815-6500
`Facsimile: (404) 815-6555
`Email: mmorlock@kilpatricktownsend.com
`
`ALTON L. ABSHER III (NC Bar No. 36579)
`1001 West Fourth Street
`Winston-Salem, NC 27101
`Telephone: (336) 607-7300
`Facsimile: (336) 607-7500
`Email: aabsher@kilpatricktownsend.com
`
`Attorneys for PLAINTIFF
`GREE, Inc.
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`- 13 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 13 of 16
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`

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`Case 2:19-cv-00413 Document 1 Filed 12/30/19 Page 14 of 14 PageID #: 14
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`CERTIFICATE OF SERVICE
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`I hereby certify that on December 30, 2019, all counsel of record who have consented to
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`electronic service are being served with a copy of this document via the Court’s CM/ECF system
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`pursuant to Local Rule CV-5(a)(3):
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`
`
`/s/ Melissa R. Smith
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`- 14 -
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`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 14 of 16
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`

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`JS 44 (Rev. 0(cid:21)(cid:18)(cid:20)(cid:28))
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`Case 2:19-cv-00413 Document 1-1 Filed 12/30/19 Page 1 of 2 PageID #: 15
`CIVIL COVER SHEET
`The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
`provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
`purpose of initiating the civil docket sheet.
`(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
`I. (a) PLAINTIFFS
`DEFENDANTS
`GREE, INC.
`SUPERCELL OY
`
`(b) County of Residence of First Listed Plaintiff
`Tokyo, Japan
`(EXCEPT IN U.S. PLAINTIFF CASES)
`
`(c) Attorneys (Firm Name, Address, and Telephone Number)
`Steven D. Moore (CA Bar No. 290875) Telephone: 415-576-0200
`Kilpatrick Townsend & Stockton LLP
`Two Embarcadero Center, Suite 1900, San Francisco, CA 94111
`II. BASIS OF JURISDICTION (Place an “X” in One Box Only)
`(cid:117) 1 U.S. Government
`(cid:117) 3 Federal Question
`Plaintiff
`(U.S. Government Not a Party)
`
`Helsinki, Finland
`County of Residence of First Listed Defendant
`(IN U.S. PLAINTIFF CASES ONLY)
`IN LAND CONDEMNATION CASES, USE THE LOCATION OF
`THE TRACT OF LAND INVOLVED.
`
`NOTE:
`
` Attorneys (If Known)
`
`III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
`(For Diversity Cases Only)
`and One Box for Defendant)
`PTF DEF
`PTF
` DEF
`(cid:117) 1
`(cid:117) 1
`(cid:117) 4
`(cid:117) 4
`
`Citizen of This State
`
`Incorporated or Principal Place
` of Business In This State
`
`(cid:117) 2 U.S. Government
`Defendant
`
`(cid:117) 4 Diversity
`(Indicate Citizenship of Parties in Item III)
`
`Citizen of Another State
`
`(cid:117) 2
`
`(cid:117) 2
`
`Incorporated and Principal Place
`of Business In Another State
`
`Citizen or Subject of a
` Foreign Country
`
`(cid:117) 3
`
`(cid:117) 3
`
`Foreign Nation
`
`(cid:117) 5
`
`(cid:117) 5
`
`(cid:117) 6
`
`(cid:117) 6
`
`IV. NATURE OF SUIT (Place an “X” in One Box Only)
`CONTRACT
`TORTS
` PERSONAL INJURY
`PERSONAL INJURY
`(cid:117) 110 Insurance
`(cid:117) 120 Marine
`(cid:117) 310 Airplane
`(cid:117) 365 Personal Injury -
`(cid:117) 130 Miller Act
`(cid:117) 315 Airplane Product
` Product Liability
`(cid:117) 140 Negotiable Instrument
` Liability
`(cid:117) 367 Health Care/
`(cid:117) 150 Recovery of Overpayment (cid:117) 320 Assault, Libel &
` Pharmaceutical
` & Enforcement of Judgment
` Slander
` Personal Injury
`(cid:117) 151 Medicare Act
`(cid:117) 330 Federal Employers’
` Product Liability
`(cid:117) 152 Recovery of Defaulted
` Liability
`(cid:117) 368 Asbestos Personal
` Student Loans
`(cid:117) 340 Marine
` Injury Product
` (Excludes Veterans)
`(cid:117) 345 Marine Product
` Liability
` PERSONAL PROPERTY
`LABOR
`(cid:117) 153 Recovery of Overpayment
` Liability
`(cid:117) 710 Fair Labor Standards
` of Veteran’s Benefits
`(cid:117) 350 Motor Vehicle
`(cid:117) 370 Other Fraud
` Act
`(cid:117) 160 Stockholders’ Suits
`(cid:117) 355 Motor Vehicle
`(cid:117) 371 Truth in Lending
`(cid:117) 720 Labor/Management
`(cid:117) 190 Other Contract
` Product Liability
`(cid:117) 380 Other Personal
` Relations
`(cid:117) 195 Contract Product Liability (cid:117) 360 Other Personal
` Property Damage
`(cid:117) 740 Railway Labor Act
`(cid:117) 196 Franchise
` Injury
`(cid:117) 385 Property Damage
`(cid:117) 751 Family and Medical
`(cid:117) 362 Personal Injury -
` Product Liability
` Leave Act
` Medical Malpractice
` PRISONER PETITIONS (cid:117) 790 Other Labor Litigation
` CIVIL RIGHTS
`Habeas Corpus:
`(cid:117) 791 Employee Retirement
`(cid:117) 440 Other Civil Rights
`(cid:117) 463 Alien Detainee
` Income Security Act
`(cid:117) 441 Voting
`(cid:117) 510 Motions to Vacate
`(cid:117) 442 Employment
` Sentence
`(cid:117) 443 Housing/
`(cid:117) 530 General
` Accommodations
`(cid:117) 445 Amer. w/Disabilities - (cid:117) 535 Death Penalty
`Other:
` Employment
`(cid:117) 446 Amer. w/Disabilities - (cid:117) 540 Mandamus & Other
` Other
`(cid:117) 550 Civil Rights
`(cid:117) 448 Education
`(cid:117) 555 Prison Condition
`(cid:117) 560 Civil Detainee -
` Conditions of
` Confinement
`
`Click here for: Nature of Suit Code Descriptions.
`BANKRUPTCY
`OTHER STATUTES
`FORFEITURE/PENALTY
`(cid:117) 422 Appeal 28 USC 158
`(cid:117) 375 False Claims Act
`(cid:117) 625 Drug Related Seizure
` of Property 21 USC 881 (cid:117) 423 Withdrawal
`(cid:117) 376 Qui Tam (31 USC
`(cid:117) 690 Other
` 28 USC 157
` 3729(a))
`(cid:117) 400 State Reapportionment
`PROPERTY RIGHTS
`(cid:117) 410 Antitrust
`(cid:117) 430 Banks and Banking
`(cid:117) 820 Copyrights
`(cid:117) 450 Commerce
`(cid:117) 830 Patent
`(cid:117) 460 Deportation
`(cid:117) 835 Patent - Abbreviated
`(cid:117) 470 Racketeer Influenced and
` New Drug Application
` Corrupt Organizations
`(cid:117) 840 Trademark
`SOCIAL SECURITY
`(cid:117) 480 Consumer Credit
`(cid:117) 485 Telephone Consumer
`(cid:117) 861 HIA (1395ff)
` Protection Act
`(cid:117) 862 Black Lung (923)
`(cid:117) 863 DIWC/DIWW (405(g)) (cid:117) 490 Cable/Sat TV
`(cid:117) 864 SSID Title XVI
`(cid:117) 850 Securities/Commodities/
`(cid:117) 865 RSI (405(g))
` Exchange
`(cid:117) 890 Other Statutory Actions
`(cid:117) 891 Agricultural Acts
`(cid:117) 893 Environmental Matters
`(cid:117) 895 Freedom of Information
` Act
`(cid:117) 896 Arbitration
`(cid:117) 899 Administrative Procedure
` Act/Review or Appeal of
` Agency Decision
`(cid:117) 950 Constitutionality of
` State Statutes
`
`FEDERAL TAX SUITS
`(cid:117) 870 Taxes (U.S. Plaintiff
` or Defendant)
`(cid:117) 871 IRS—Third Party
` 26 USC 7609
`
` REAL PROPERTY
`(cid:117) 210 Land Condemnation
`(cid:117) 220 Foreclosure
`(cid:117) 230 Rent Lease & Ejectment
`(cid:117) 240 Torts to Land
`(cid:117) 245 Tort Product Liability
`(cid:117) 290 All Other Real Property
`
`IMMIGRATION
`(cid:117) 462 Naturalization Application
`(cid:117) 465 Other Immigration
` Actions
`
`V. ORIGIN (Place an “X” in One Box Only)
`(cid:117) 1 Original
`(cid:117) 2 Removed from
`Proceeding
`State Court
`
`(cid:117) 3 Remanded from
`Appellate Court
`
`(cid:117) 4 Reinstated or
`Reopened
`
`(cid:117) 6 Multidistrict
`Litigation -
`Transfer
`
`(cid:117) 8 Multidistrict
` Litigation -
` Direct File
`
`(cid:117) 5 Transferred from
`Another District
`(specify)
`Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
`35 U.S.C. § et seq., 35 U.S.C. § 271
`Brief description of cause:
`Patent Infringement
`(cid:117) CHECK IF THIS IS A CLASS ACTION
`UNDER RULE 23, F.R.Cv.P.
`
`DEMAND $
`According to proof
`
`CHECK YES only if demanded in complaint:
`JURY DEMAND:
`(cid:117) Yes
`(cid:117) No
`
`(See instructions):
`
`JUDGE
`SIGNATURE OF ATTORNEY OF RECORD
`/s/ Melissa R. Smith
`
`DOCKET NUMBER
`
`VI. CAUSE OF ACTION
`
`VII. REQUESTED IN
`COMPLAINT:
`VIII. RELATED CASE(S)
`IF ANY
`
`DATE
`12/30/2019
`FOR OFFICE USE ONLY
`
`RECEIPT #
`
`AMOUNT
`
`APPLYING IFP
`
`JUDGE
`
`MAG. JUDGE
`
`Patent Owner Gree, Inc.
`Exhibit 2002 - Page 15 of 16
`
`

`

`Case 2:19-cv-00413 Document 1-1 Filed 12/30/19 Page 2 of 2 PageID #: 16
`JS 44 Reverse (Rev. 0(cid:21)(cid:18)(cid:20)(cid:28))
`
`INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
`Authority For Civil Cover Sheet
`
`The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
`required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
`required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
`Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
`
`I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
`only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
`then the official, giving both name and title.
`(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
`time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
`condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
`(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
`in this section "(see attachment)".
`
`(cid:44)(cid:44)(cid:17)
`
`(cid:44)(cid:44)(cid:44)(cid:17)
`
`(cid:44)(cid:57)(cid:17)
`
`(cid:57)(cid:17)
`
`Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
`in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
`United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
`United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
`Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
`to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
`precedence, and box 1 or 2 should be marked.
`Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
`citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
`cases.)
`
`Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
`section for each principal party.
`
`Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
`that is most applicable. Click here for: Nature of Suit Code Descriptions.
`
`Origin. Place an "X" in one of the seven boxes.
`Original Proceedings. (1) Cases which originate in the United States di