ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 1
`UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION NAVBLAZER, LLC, v. MOTOROLA MOBILITY LLC,
` Case No. 6:20-cv-100 JURY TRIAL DEMANDED
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT NavBlazer, LLC (“NavBlazer”) hereby files this Original Complaint for Patent Infringement against Motorola Mobility LLC (“Motorola”), and alleges, on information and belief, as follows: THE PARTIES 1. NavBlazer is a limited liability company organized and existing under the laws of the State of Florida with its principal place of business at 600 S. Dixie Highway, Suite 605, West Palm Beach, Florida 33401. 2. On information and belief, Motorola Mobility LLC is a Delaware limited liability company with its principal office located at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654. JURISDICTION AND VENUE 3. This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331, 1332, 1338, and 1367. 4. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 and 1400(b). Motorola is registered to do business in Texas, and upon information and belief, Motorola has transacted business in this District and has committed acts of direct and indirect infringement in this District by, among other things, importing, offering to sell, and selling products that infringe the asserted patents. On
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 1 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 2
`information and belief, Motorola has regular and established places of business in the District, including service centers in Austin, Waco, and San Antonio, Texas. On information and belief, these service centers are dedicated to the service and support of Motorola products, including the Accused Products1 On information and belief, Motorola also employs employees and advertises jobs in this District.2 5. This Court has personal jurisdiction over Motorola. Motorola has continuous and systematic business contacts with the state of Texas. Motorola, directly or through subsidiaries or intermediaries (including distributors, retailers, and others), conducts its business extensively throughout Texas, by shipping, distributing, making, using, offering for sale, selling, and advertising (including the provision of interactive web pages) its products and services in the state of Texas and the Western District of Texas. Motorola, directly and through subsidiaries or intermediaries (including distributors, retailers, and others), has purposefully and voluntarily placed infringing products and services into this district and into the stream of commerce with the intention and expectation that they will be purchased and used by consumers in this district. Motorola has offered and sold and continues to offer and sell these infringing products and services in this District, including at physical Motorola stores located within this district. Motorola and its customers also commit additional acts of direct infringement in this district with respect to each asserted patent through their infringing use of the accused devices, including Motorola’s servers, in this district, including when Motorola and its customers put the accused devices into service and receive a benefit, and Motorola is liable for these additional acts of direct infringement and indirect infringement in this district. 1 See, e.g., https://www.service-center-locator.com/motorola/texas/motorola-austin-texas.html. 2 See, e.g., https://lenovocareers.com/areas-mobile.html. Motorola Mobility LLC is a subsidiary of Lenovo Group Ltd.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 2 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 3
`Motorola has committed acts of infringement, both direct and indirect, in this district with respect to each asserted patent and has a regular and established place of business in this judicial district. U.S. PATENT NOS. 9,075,136 AND 9,885,782 6. NavBlazer is the owner, by assignment, of U.S. Patent No. 9,075,136 and 9,885,782, each entitled “VEHICLE OPERATOR AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD” (hereinafter collectively referred to as “the Patents-in-Suit”). 7. The patent application that issued as the ’782 Patent is a continuation application of U.S. Patent Application Ser. No. 09/259,957, filed March 1, 1999, and entitled “VEHICLE OPERATOR AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD”, now U.S. Pat. No. 9,075,136. U.S. Patent Application Ser. No. 09/259,957, filed March 1, 1999, claims priority to U.S. Provisional Patent Application Ser. No. 60/076,800, filed March 4, 1998, and entitled “VEHICLE OPERATOR AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD.” 8. The Patents-in-Suit are valid, enforceable, and were duly issued in full compliance with Title 35 of the United States Code. 9. The inventions described and claimed in the Patents-in-Suit were invented by Raymond Anthony Joao. 10. The priority date of each of the Patents-in-Suit is at least as early as March 4, 1998. 11. The Patents-in-Suit relate generally to an apparatus and method for providing a user with one or more possible travel routes to a destination, as well as additional information regarding the one or more possible travel routes, such as traffic conditions, road conditions, traffic flow, weather information and/or other useful information. 12. During prosecution of the ’782 Patent, the patent examiner considered whether the claims of the ’782 Patent were eligible under 35 USC §101 in view of the United States Supreme Court’s decision
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 3 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 4
`in Alice. The patent examiner found that the claims are in fact patent eligible under 35 USC §101 because all pending claims are directed to patent-eligible subject matter, none of the pending claims are directed to an abstract idea and there would be no preemption of the abstract idea or the field of the abstract idea. MOTOROLA’S PRODUCTS 13. Upon information and belief, Motorola sells, advertises, offers for sale, uses, or otherwise provides mobile devices that utilize the Android operating system including, but not limited to, the “Motorola Razr,” “Moto Z3,” “Moto Z4,” “Moto Z3 Play,” “Moto G Stylus,” “Moto G Power,” “Moto G6,” “Moto G6 Play,” “Moto G7,” “Moto E5,” “Moto E5 Play,” “Moto E6,” “Motorola One,” “Motorola One Hyper,” “Motorola One Action,” and “Motorola One Zoom” series of mobile devices (“Accused Instrumentalities”) that infringe the Patents-in Suit. COUNT I (Infringement of U.S. Patent No. 9,885,782) 14. Plaintiff incorporates the above paragraphs by reference. 15. Motorola has been on notice of the ’782 Patent at least as early as the date it received service of this Original Complaint. 16. Upon information and belief, Motorola has directly infringed and continues to directly infringe at least Claims 1, 2 and 7 of the ’782 Patent by making, using, importing, selling, and/or, offering for sale the Accused Instrumentalities. 17. Motorola, with knowledge of the ’782 Patent, also infringes at least Claims 1, 2 and 7 of the ’782 Patent by inducing others to infringe the ’782 Patent. In particular, Motorola intends to induce its
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 4 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 5
`customers to infringe the ’782 Patent by encouraging its customers to use the Accused Instrumentalities in a manner that results in infringement. 18. Motorola also induces others, including its customers, to infringe at least Claims 1, 2 and 7 of the ’782 Patent by providing technical support for the use of the Accused Instrumentalities. 19. Upon information and belief, at all times Motorola owns and controls the operation of the Accused Instrumentalities in accordance with an end user license agreement. 20. By way of example, the Accused Instrumentalities infringe Claim 1 of the ’782 Patent by use of a global positioning device, wherein the global positioning device determines a location of the apparatus or a location of a vehicle. Motorola’s “Moto G7” is a representative example of the Accused Instrumentalities and is a mobile device (apparatus). See Figure 1 below, which is a screenshot from Motorola’s website, showing a picture of the Moto G7.
` 3 https://www.motorola.com/us/products/moto-g-gen-7 - 2/10/20
` Figure 13 - Motorola’s Moto G7
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 5 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 6
` 4 https://support.motorola.com/us/en/products/cell-phones/moto-g-family/moto-g7/documents/MS137727 - 2/10/20
`21. The Moto G7 uses a global positioning device, wherein the global positioning device determines a location of the apparatus or a location of a vehicle. 22. See Figure 2 below, which is a screenshot from Motorola’s website, indicating the Moto G7 utilizes GPS and A-GPS. A GPS device is necessarily required to utilize GPS and A-GPS. Further, it is well known that GPS location technology determines a location of the apparatus on which the GPS device is installed or located.
` Figure 24 - Moto G7 Connectivity 23. See also Figure 3 below, which is a screenshot from Motorola’s website indicating that the Moto G7 is bundled with the Android 9 Pie operating system.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 6 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 7
` 5 https://www.motorola.com/us/products/moto-g-gen-7 - 2/10/20 6 Moto G7 User Guide – page 24
` Figure 35 - Moto G7 Specifications 24. See also Figure 4 below, which is an excerpt from the Moto G7 User Guide, attached herein as Exhibit A, indicating that the Moto G7 is preloaded with the Google Maps application.
` Figure 46 - Google Maps Application on the Moto G7
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 7 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 8
` 7 https://www.google.com/maps/about/#!#jump-link - 9/14/19
` 25. See also Figure 5 below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps. The blue arrow indicates the current location of the device.
` Figure 57 - Google Maps navigation display 26. The Moto G7 uses a processing device, wherein the processing device processes information regarding the location of the apparatus or the location of the vehicle and information regarding a destination, wherein the processing device determines or identifies a travel route to the destination on or along a road, a roadway, a highway, a parkway or an expressway. 27. See Figure 3, reproduced below, which is a screenshot from Motorola’s website indicating that it utilizes the Qualcomm Snapdragon 632 processor.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 8 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 9
` Figure 3 - Moto G7 processor 28. The processing device used in the Moto G7 is necessarily used to process the information regarding the location of the apparatus or vehicle and the destination, as well as to calculate the travel route to the destination using the Google Maps application that is included with the Moto G7. 29. See also Figure 5, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. The blue arrow indicates the current location of the device and the blue line identifies the route to the destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the destination.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 9 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 10
` Figure 5 - Google Maps navigation display 30. The Moto G7 uses a display device or a speaker, wherein the display device displays information regarding the travel route or the speaker provides audio information regarding the travel route. 31. See Figure 1, reproduced below, showing the display of the Moto G7.
` Figure 1 - Motorola’s Moto G7 32. See also Figure 5, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. The blue arrow
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 10 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 11
`indicates the current location of the device and the blue line identifies the route to the destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the destination.
` Figure 5 - Google Maps navigation display 33. The Moto G7 uses a receiver, wherein the receiver receives traffic information or information regarding a traffic condition. 34. See Figure 6 below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. Google Maps is described as providing “Real-time traffic updates” and the mock up of the navigation display shows traffic information being displayed at the bottom of the device display. The device running the Google Maps application, such as the Moto G7, must necessarily include a receiver for receiving real-time traffic information.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 11 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 12
` 8 https://www.google.com/maps/about/#!#jump-link - 9/14/19
` Figure 68 - Google Maps navigation display 35. The Moto G7 provides the traffic information or the information regarding a traffic condition via the display device or via the speaker. 36. See Figure 1, reproduced below, showing the display of the Moto G7.
` Figure 1 - Motorola’s Moto G7
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 12 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 13
` 37. See also Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. Google Maps is described as providing “Real-time traffic updates” and the mock up of the navigation display shows traffic information being displayed at the bottom of the device display.
` Figure 6 - Google Maps navigation display 38. By way of another example, the Accused Instrumentalities infringe Claim 7 of the ’782 Patent by use of an apparatus that “receives maintenance information associated with the travel route or maintenance information associated with a second travel route to the destination, and further wherein the apparatus provides the maintenance information associated with the travel route or the maintenance information associated with the second travel route via the display device or the speaker.” 39. See Figure 7 below, which is a screenshot from Google’s website explaining the meaning of various visual symbols used in the Google Maps application, which is included in the Moto G7. The visual symbols include symbols indication “road closures” and “construction,” both of which can be considered “maintenance information.” Figure 7 also indicates that “[f]or road closures, you’ll find a
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 13 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 14
` (Infringement of U.S. Patent No. 9,075,136) 40. Plaintiff incorporates the above paragraphs by reference. 41. Motorola has been on notice of the ’136 Patent at least as early as the date it received service of this Original Complaint. 42. Upon information and belief, Motorola has infringed and continues to infringe at least Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by making, using, importing, selling, and/or, offering for sale the Accused Instrumentalities.
` 9 https://support.google.com/maps/answer/3092439?hl=en&ref_topic=3093390 – 2/5/20
`dotted red line where the road is closed.” These symbols are visually displayed on the map that is displayed on the display device of the Accused Instrumentalities.
` Figure 79 - Visual Symbols in the Google Maps Application
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 14 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 15
`43. Motorola, with knowledge of the ’136 Patent, infringes at least Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by inducing others to infringe at least Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent. In particular, Motorola intends to induce its customers to infringe at least Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by encouraging its customers to use the Accused Instrumentalities in a manner that results in infringement. 44. Motorola also induces others, including its customers, to infringe at least Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by providing technical support for the use of the Accused Instrumentalities. 45. Upon information and belief, at all times Motorola owns and controls the operation of the Accused Instrumentalities in accordance with an end user license agreement. 46. By way of example, the Accused Instrumentalities infringe Claim 55 of the ’136 Patent by use of a global positioning device, wherein the global positioning device determines a location of the apparatus or a location of a vehicle. Motorola’s “Moto G7” is a representative example of the Accused Instrumentalities and is a mobile device (apparatus). See Figure 1, reproduced below, which is an excerpt from the Moto G7 Specification Sheet, attached herein as Exhibit A, showing a picture of the Moto G7.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 15 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 16
` Figure 1 - Motorola’s Moto G7 47. The Moto G7 uses a global positioning device, wherein the global positioning device determines a position or a location of a vehicle. 48. See Figure 2, reproduced below, which is a screenshot from Motorola’s website, indicating the Moto G7 utilizes GPS and A-GPS. A GPS device is necessarily required to utilize GPS and A-GPS. Further, it is well known that GPS location technology determines a location of the apparatus on which the GPS device is installed or located.
` Figure 2 - Moto G7 Specs 49. See also Figure 3, reproduced below, which is a screenshot from Motorola’s website indicating that the
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 16 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 17
`Moto G7 is bundled with the Android 9 Pie operating system.
` Figure 3 - Moto G7 Specifications 50. See also Figure 4, reproduced below, which is an excerpt from the Moto G7 User’s Manual, attached herein as Exhibit A, indicating that the Moto G7 is preloaded with the Google Maps application.
` Figure 4 - Google Maps Application on the Moto G7
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 17 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 18
`51. See also Figure 5, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps. The blue arrow indicates the current location of the device.
` Figure 5 - Google Maps navigation display 52. The Moto G7 uses a processing device, wherein the processing device processes information regarding the position or the location of the vehicle and information regarding a destination to which the vehicle can travel on at least one of a road, a roadway, a highway, a parkway, and an expressway, and further wherein the processing device determines or identifies a travel route to the destination. 53. See Figure 3, reproduced below, which is a screenshot from Motorola’s website indicating that it utilizes the Qualcomm Snapdragon 632 processor.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 18 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 19
` Figure 5 - Moto G7 processor 54. The processing device used in the Moto G7 is necessarily used to process the information regarding the location of the apparatus or vehicle and the destination, as well as to calculate the travel route to the destination using the Google Maps application that is included with the Moto G7. 55. See also Figure 5, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. The blue arrow indicates the current location of the device and the blue line identifies the route to the destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the destination.
`
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 19 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 20
`Figure 5 - Google Maps navigation display 56. The Moto G7 uses a display device or a speaker, wherein the display device displays information regarding the travel route or the speaker provides audio information regarding the travel route. 57. See Figure 1, reproduced below, showing the display of the Moto G7.
` Figure 1 - Motorola’s Moto G7 58. See also Figure 5, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. The blue arrow indicates the current location of the device and the blue line identifies the route to the destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the destination.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 20 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 21
` Figure 5 - Google Maps navigation display 59. The Moto G7 uses a receiver, wherein the receiver receives traffic information or information regarding a traffic condition, wherein the traffic information or the information regarding a traffic condition is transmitted from a computer, a transmitter, or a device, located at a location remote from the vehicle. 60. See Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up of the navigation display for Google Maps, which is included with the Moto G7. Google Maps is described as providing “Real-time traffic updates” and the mock up of the navigation display shows traffic information being displayed at the bottom of the device display. The device running the Google Maps application, such as the Moto G7, must necessarily include a receiver for receiving real-time traffic information.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 21 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 22
` Figure 6 - Google Maps navigation display 61. The Moto G7 provides the traffic information or the information regarding a traffic condition at the vehicle via the display device or via the speaker. 62. See Figure 1, reproduced below, showing the display of the Moto G7.
` Figure 1 - Motorola’s Moto G7 63. See also Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 22 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 23
`64. By way of another example, the Accused Instrumentalities infringe Claims 61 of the ’136 Patent by use of an apparatus that “receives maintenance information associated with the travel route or maintenance information associated with a second travel route to the destination, and further wherein the apparatus provides the maintenance information associated with the travel route or the maintenance information associated with the second travel route.” 65. See Figure 7, reproduced below, which is a screenshot from Google’s website explaining the meaning of various visual symbols used in the Google Maps application. The visual symbols include symbols indication “road closures” and “construction,” both of which can be considered “maintenance information.” Figure 7 also indicates that “[f]or road closures, you’ll find a dotted red line where the road is closed.” These symbols are visually displayed on the map that is displayed on the display device of the Accused Instrumentalities.
`of the navigation display for Google Maps, which is included with the Moto G7. Google Maps is described as providing “Real-time traffic updates” and the mock up of the navigation display shows traffic information being displayed at the bottom of the device display.
` Figure 6 - Google Maps navigation display
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 23 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 24
` Figure 7 - Visual Symbols in the Google Maps Application PRAYER FOR RELIEF WHEREFORE, NavBlazer respectfully requests the Court enter judgment against Motorola: 1. Declaring that Motorola has infringed each of the Patents-in-Suit; 2. Awarding NavBlazer its damages suffered as a result of Apple’s infringement of the Patents-in-Suit; 3. Awarding NavBlazer its costs, attorneys’ fees, expenses, and interest; 4. Awarding NavBlazer ongoing post-trial royalties; and 5. Granting NavBlazer such further relief as the Court finds appropriate.
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 24 of 25
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 25
`JURY DEMAND NavBlazer demands trial by jury, under Fed. R. Civ. P. 38. Dated: February 10, 2020 Respectfully Submitted /s/ Thomas Fasone III Thomas Fasone III Texas Bar No. 00785382 tfasone@ghiplaw.com M. Scott Fuller Texas Bar No. 24036607 sfuller@ghiplaw.com René A. Vazquez Pro Hac Vice Anticipated rvazquez@ghiplaw.com Randall T. Garteiser Pro Hac Vice Anticipated rgarteiser@ghiplaw.com Christopher A. Honea Pro Hac Vice Anticipated chonea@ghiplaw.com GARTEISER HONEA, PLLC 119 W. Ferguson Street Tyler, Texas 75702 Telephone: (903) 705-7420 Facsimile: (888) 908-4400 Raymond W. Mort, III Texas State Bar No. 00791308 raymort@austinlaw.com THE MORT LAW FIRM, PLLC 100 Congress Ave, Suite 2000 Austin, Texas 78701 Tel/Fax: (512) 865-7950 ATTORNEYS FOR NAVBLAZER LLC
`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 25 of 25
`
`
`
`
`
`
`
`