Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 1 of 14
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`VIRTUAL IMMERSION
`TECHNOLOGIES LLC,
`
`Plaintiff,
`
`v.
`
`MERCK AND CO., INC.
`
`
`Defendant.
`
`
`
`Civ. No. 6:20-cv-610
`
` JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Virtual Immersion Technologies LLC (“VIT” or “Plaintiff”), by and through its
`
`attorneys, hereby alleges for its Complaint on personal knowledge as to its own activities and on
`
`information and belief as to all other matters, as follows:
`
`NATURE OF THE ACTION
`
`1. This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2. Plaintiff Virtual Immersion Technologies LLC is a limited liability company
`
`organized under the laws of the State of Texas.
`
`3. VIT is the current assignee of United States Patent No. 6,409,599 (“the ’599
`
`patent” or “the patent-in-suit.”) On June 25, 2002, the United States Patent and Trademark
`
`Office duly and legally issued the ’599 patent. The ’599 patent is titled “Interactive Virtual
`
`Reality Performance Theater Entertainment System.” The application leading to the ’599 patent
`
`
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`- 1 -
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`VIRTUAL IMMERSION
`TECHNOLOGIES LLC,
`
`Plaintiff,
`
`v.
`
`MERCK AND CO., INC.
`
`
`Defendant.
`
`
`
`Civ. No. 6:20-cv-610
`
` JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Virtual Immersion Technologies LLC (“VIT” or “Plaintiff”), by and through its
`
`attorneys, hereby alleges for its Complaint on personal knowledge as to its own activities and on
`
`information and belief as to all other matters, as follows:
`
`NATURE OF THE ACTION
`
`1. This is an action for patent infringement arising under the Patent Laws of the
`
`United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`2. Plaintiff Virtual Immersion Technologies LLC is a limited liability company
`
`organized under the laws of the State of Texas.
`
`3. VIT is the current assignee of United States Patent No. 6,409,599 (“the ’599
`
`patent” or “the patent-in-suit.”) On June 25, 2002, the United States Patent and Trademark
`
`Office duly and legally issued the ’599 patent. The ’599 patent is titled “Interactive Virtual
`
`Reality Performance Theater Entertainment System.” The application leading to the ’599 patent
`
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 2 of 14
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`was filed on July 19, 1999. A true and correct copy of the ’599 patent is attached hereto as
`
`Exhibit A.
`
`4. On or around February 24, 2016, VIT acquired 100% ownership of all right, title
`
`and interest in the patent-in-suit, including the right to bring patent enforcement actions for
`
`damages accruing prior to February 24, 2016. The assignment to VIT of ownership of the
`
`patent-in-suit was recorded with the United States Patent & Trademark Office (“PTO”) on or
`
`around August 26, 2016.
`
`5. Defendant Merck and Co., Inc. (“Merck”) is a corporation organized and existing
`
`under the laws of New Jersey, with its principal place of business at 2000 Galloping Hill Road
`
`Kenilworth, NJ 07033, and on information and belief maintains a regular and established place
`
`of business at 1601 Trinity St., Austin, TX 78701.
`
`JURISDICTION AND VENUE
`
`6.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, Title 35, United States Code. Jurisdiction as to these claims is conferred on this
`
`Court by 35 U.S.C. §§ 1331 and 1338(a).
`
`7. Regarding Defendant Merck, venue is proper within this District under 28 U.S.C.
`
`§ 1400(b) because, on information and belief, Merck maintains a regular and established place of
`
`business in this District and has committed infringing acts in this District.
`
`8. Upon information and belief, Merck is subject to this Court’s general and specific
`
`personal jurisdiction because it has sufficient minimum contacts within the State of Texas and
`
`this District, pursuant to due process and/or the Texas Long-Arm Statute, because Defendant
`
`Merck purposefully availed itself of the privileges of conducting business in the State of Texas
`
`and in this District, because Merck regularly conducts and solicits business within the State of
`
`Texas and within this District, and because Plaintiff’s causes of action arise directly from
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 3 of 14
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`Merck’s business contacts and other activities in the State of Texas and this District. Having
`
`purposefully availed itself of the privilege of conducting business within this District, Merck
`
`should reasonably and fairly anticipate being brought into court here.
`
`9. Upon information and belief, Defendant Merck maintains at least one regular and
`
`established place of business in this District: at least part or all of a regional office (the “Austin
`
`Facility.”) The Austin Facility is located at 1601 Trinity St., Austin, TX 78701, within Travis
`
`County in this District.
`
`10. Currently, the Austin Facility is publicly associated with Merck. (Source:
`
`https://www.merck.com/about/featured-stories/austin.html and
`
`https://patch.com/texas/downtownaustin/merck-build-20m-it-hub-austin-creating-600-local-jobs,
`
`last accessed and downloaded July 6, 2020.) Based at least on these facts, the Austin Facility in
`
`Austin, Texas is believed to be a regular and established place of business that is associated
`
`directly Merck.
`
`11. Merck has committed and continues to commit acts of infringement within the
`
`state of Texas, as alleged herein. The Austin Facility has many employees and continues to
`
`expand the number of employees. (Source: See https://patch.com/texas/downtownaustin/merck-
`
`build-20m-it-hub-austin-creating-600-local-jobs and https://jobs.merck.com/us/en/search-results,
`
`last accessed and downloaded July 6, 2020) (listing open job positions at the Austin Facility.)
`
`12. Merck is utilizing virtual reality as a “core driver of innovation, user adoption ,
`
`and ROI [(return of investment)]” and to “improve our financial performance.” (Source:
`
`https://www.merck.com/about/featured-stories/austin.html, last accessed and downloaded July 6,
`
`2020.) For example, Merck realizes these benefits through the use of VR/AR headsets which has
`
`virtual reality functionality. (Source: See id.) On information and belief, Merck uses and
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 4 of 14
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`develops these virtual reality technologies within the state of Texas and this District. (Source:
`
`See https://www.merck.com/about/featured-stories/austin.html; and
`
`https://www.gdcvault.com/play/1024750/Immersive-Tech-in-Merck, last accessed and
`
`downloaded July 6, 2020.)
`
`13. As previously stated, Defendant currently uses virtual and augmented reality
`
`systems. (Source: see https://www.merck.com/about/featured-stories/austin.html; and
`
`https://www.gdcvault.com/play/1024750/Immersive-Tech-in-Merck, last accessed and
`
`downloaded July 6, 2020.) This technology includes an immersive virtual reality environment
`
`where participants and live performers can interact with each other and the environment via input
`
`and output devices for the performers and the participants. (See VIT’s Claim Chart for claim 9
`
`of the ʼ599 patent, Ex. B at 1-10.)
`
`14. As detailed in the paragraphs below, Defendant utilizes a virtual reality system
`
`and practice method for participants and performers to interact in an immersive virtual reality
`
`environment, which meets all the features of the asserted claim. (Id. at 1-10.)
`
`15.
`
`The Defendant’s method includes providing at least one performer input and
`
`output devices in electronic communication with the virtual environment and one or more
`
`participant input and output devices in electronic communication with the virtual environment.
`
`(Id. at 3-7.)
`
`16. Defendant’s method provides the virtual environment, which includes a video
`
`image of one or more live performers with audio communication between the one or more live
`
`performers and one or more participants. (Id. at 7-8.)
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`17.
`
`In the Defendant’s method, the one or more participants interact with the one or
`
`more live performers and the virtual environment resulting in an experience partially controlled
`
`by the one or more participants using an input device. (Id. at 8-10.)
`
`18. Defendant has derived substantial revenues from its infringing acts, including
`
`those of Merck occurring within Texas, including in this District.
`
`19. Merck is subject to the Court’s personal jurisdiction at least due to its utilization
`
`of the virtual reality system within Texas, including in this District.
`
`20. Merck has committed such purposeful acts or transactions in Texas and this
`
`District such that it reasonably should know and expect that it could be haled into court in this
`
`State because of such activities.
`
`21. As detailed in the paragraphs below, Merck supports the creation, maintenance
`
`and utilization of an immersive virtual reality system and practice method, which permits live
`
`performers and participants to interact with each other and the environment in the United States,
`
`including those infringing actions of Merck occurring within the state of Texas, including in this
`
`District.
`
`22. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`23. Venue is proper in this district under 28 U.S.C. § 1400(b) with respect to
`
`Defendant Merck. Defendant Merck maintains a regular and established place of business in this
`
`District and has committed infringing acts in this District.
`
`24. For the above reasons, personal jurisdiction exists and venue is proper in this
`
`Court for Defendant.
`
`PATENT INFRINGEMENT OF UNITED STATES PATENT NO. 6,409,599
`
`COUNT I
`
`25. Plaintiff incorporates the above paragraphs herein by reference.
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 6 of 14
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`26. The ’599 patent relates to a system and practice method in which participants
`
`interact with a computerized environment in addition to live and/or pre-recorded performers.
`
`(See Ex. A at 1:20-23.)1 The ’599 patent describes and enables immersive interactive virtual
`
`reality computer systems in which participants interact with a virtual reality environment and
`
`live performers using a variety of immersion and input devices.” (Id. at 1:23-26.)
`
`27. The claims of the ’599 patent are directed to tangible embodiments. Claim 9, for
`
`example, is a method claim, which clearly requires providing several input/output devices in
`
`electronic communication with an immersive virtual reality environment. (Id. at 18:61-20:12.)
`
`28. The claims of the ’599 patent are directed at providing a unique computing
`
`solution that addresses a problem particular to computerized virtual reality systems—providing
`
`an immersive interactive virtual reality system in which there exists three-way communication
`
`among and between participants, live performers and the virtual reality environment. (Id. at
`
`3:24-27.)
`
`29. Providing an immersive interactive virtual reality system with three-way
`
`communication in the manner claimed in the ’599 patent solved new challenges over the
`
`techniques and systems known in the art at the time. Thus, the claims of the ’599 patent contain
`
`inventive concepts, being both novel and unconventional, which are sufficient to render the ’599
`
`patent claims to be patent-eligible.
`
`30. Prior to the priority date of the ’599 patent, in systems, such as traditional virtual
`
`reality systems, figures or objects not controlled by participants moved autonomously or, if a
`
`
`1 Citations to patents in this Complaint refer to columns and lines within columns of any cited
`patent. For example, the citation referenced by this footnote refers to column 1, at lines 20
`through 23, in the ’599 patent.
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 7 of 14
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`participant had an opportunity to interact with such objects in the virtual reality environment, the
`
`objects were limited to computer generated images and not live performers. (Id. at 1:57-67.)
`
`31. Groups of participants have been entertained by graphically enhanced performers
`
`on stage or television. However, these instances occurred through non-immersion mediums
`
`without the enhancements of immersion-type devices or methods. (Id. at 2:5-9.)
`
`32. Early entertainment systems, which allowed participants to interact with a host
`
`and an environment using some input device, did not operate within an immersive virtual reality
`
`environment and therefore lacked its immersive effects and their impact on participants. (Id. at
`
`2:40-47.)
`
`33. The ʼ599 patent overcame these disadvantages by, for example, describing and
`
`enabling a system and method for delivering information “which provides three-way immersive
`
`interactive communication amongst and between” participants, an immersive environment and
`
`live performers. (Id. at 2:55-57.)
`
`34. The inventors of the claimed invention in the ’599 patent changed the focus from
`
`an interaction between individual participants and computer-generated graphical objects within a
`
`virtual reality environment to a three-way communication amongst and between participants, live
`
`or pre-recorded performers, and an immersive virtual reality environment. (Id. at 3:11-17.)
`
`The inclusion of three-way communication results in a synergistic effect, which creates an
`
`unparalleled experience. (Id. at 3:18-22.)
`
`35. Furthermore, the claimed invention of the ’599 patent represents an intrinsic
`
`improvement to the underlying computer technology involved. The claimed system includes a
`
`variety of audio and video components. (See, e.g., claim 1 of the ’599 patent.) The variety of
`
`audio and video components enable innovative mixing and switching techniques which allows
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 8 of 14
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`the system to present to each of the participants a virtual reality environment in which a live
`
`representation of the performers is superimposed within the environment. (Id. at 4:5-9.) The
`
`participants are able to view and interact with a novel display of both graphical data and live
`
`representations for an exciting experience. (Id. at 4:9-12.)
`
`36.
`
`The inventors of the ’599 patent took considerable personal risks to nurture and
`
`prove out the technology systems described in the ’599 patent, contributing substantially to
`
`today’s virtual reality industry explosion.
`
`37.
`
`The inventors of the ’599 patent have utilized the technology described by the
`
`’599 patent for more than ten years, shipping virtual reality systems to five continents and
`
`entertaining or educating an estimated 30 million people worldwide with their immersive virtual
`
`reality live theater attractions and promotions.
`
`38.
`
`The virtual reality theater technology created by the inventors has been
`
`recognized and awarded on an international scale, the products winning “Best New Product” and
`
`“Best of Show” at the International Association of Amusement Parks and Attractions global
`
`convention in Atlanta in November 2000, and again for ‘Best of Show’ in 2002 in Orlando, as
`
`well as national awards for graphics and creativity in the Print Media industry. The products and
`
`concepts have garnered dozens of feature articles in news media promoting clients and their
`
`products in a variety of industries.
`
`39.
`
`The inventors of the ’599 patent continue to have a direct interest in activities
`
`related to the ’599 patent, working closely with Plaintiff to identify and evaluate entities making
`
`use of the technology claimed by the ’599 patent without permission or license thereto.
`
`40.
`
`The inventions of the ’599 patent resolve technical problems related to virtualized
`
`interactive technology. For example, the inventions allow parties to interact in a virtual
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 9 of 14
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`environment in real time with one or more live performers and participants, which, on
`
`information and belief, is exclusively implemented using computer technology.
`
`41.
`
`The claims of the ’599 patent do not merely recite the performance of some
`
`method known from the pre-Internet world along with the requirement to perform it on the
`
`Internet. Instead, the claims of the ’599 patent recite inventive concepts that are rooted in
`
`computerized virtual reality technology, and overcome problems specifically arising in the realm
`
`of computerized virtual reality technologies.
`
`42.
`
`The claims of the ’599 patent recite an invention that is not merely the routine or
`
`conventional use of computerized communication technology. Instead, the invention makes it
`
`possible to interact with one or more live performers and/or participants in a virtualized
`
`environment, which does not require the physical presence of either the one or more performers,
`
`or participants in order for such interactions to take place. The ’599 patent claims thus specify
`
`how communication input, output, and system devices are manipulated to yield a virtual,
`
`interactive experience controlled in part by one or more participants.
`
`43.
`
`The technology claimed in the ’599 patent does not preempt all ways of using
`
`interactive communications technology, nor preempt the use of any well-known communications
`
`technology, nor preempt any other well-known or prior art technology.
`
`44. The ʼ599 patent claims are not directed to any “method of organizing human
`
`activity,” “fundamental economic practice long prevalent in our system of commerce,” nor are
`
`any of the claims “a building block of the modern economy.”
`
`45. The ʼ599 patent does not take a well-known or established business method or
`
`process and “apply it to a general purpose computer.” Instead, the specific systems and
`
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 10 of 14
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`processes described in the ʼ599 patent have no direct corollary to a process that predates the
`
`advent of the Internet.
`
`46. The ʼ599 patent claims are directed toward a solution rooted in computer
`
`technology and uses technology, unique to computers and networks, to overcome a problem
`
`specifically arising in the realm of computerized virtual reality technologies.
`
`47. The ʼ599 patent claims are not directed at a mere mathematical relationship or
`
`formula.
`
`48. The ʼ599 patent claims cannot be performed by a human, in the human mind, or
`
`by pen and paper.
`
`49.
`
` Accordingly, each claim of the ’599 patent recites a combination of elements
`
`sufficient to ensure that the claim in practice amounts to significantly more than a patent on an
`
`ineligible concept.
`
`50. Upon information and belief, Merck directly infringes and continues to directly
`
`infringe at least claim 9 of the ’599 patent, in the United States, under 35 U.S.C. § 271(a) by
`
`making, using, selling, offering to sell, importing and/or providing and/or causing to be used an
`
`interactive, real time, virtual reality systems system and its practice method (See Merck is
`
`utilizing virtual reality as a “core driver of innovation, user adoption , and ROI [(return of
`
`investment)]” and to “improve our financial performance.” Source:
`
`https://www.merck.com/about/featured-stories/austin.html, last accessed and downloaded July 6,
`
`2020), along with related systems and software for access and use of such systems and methods
`
`(the “Accused Instrumentalities”) as in claim 9 of the ’599 patent. (See VIT’s Claim Chart for
`
`claim 9 of the ’599 patent, Ex. B at 1-10.)
`
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`51. On information and belief, Defendant is a for-profit organization with revenues of
`
`approximately $42 billion U.S.D. per year. Moreover, Defendant, its employees and/or agents
`
`make, use, sell, offer to sell, import and/or provide and/or cause to be used the Accused
`
`Instrumentalities for Defendant’s partners and customers, leading to direct or indirect revenues
`
`and profit. As one example of indirect profit, Merck utilizes the system to reduce costs by
`
`increasing the speed of design and project time. On information and belief, without the
`
`availability of infringing tools such as the Accused Instrumentalities, Defendant would be at a
`
`disadvantage in the marketplace and would generate less revenue and profit overall.
`
`52.
`
`In particular, claim 9 of the ’599 patent generally recites a method of providing
`
`interactive communications between participants and performers comprising the steps of
`
`providing an immersive virtual reality environment; providing performer and participant input
`
`and output devices in communication with the immersive virtual reality environment; having the
`
`live performer interact with the participant and immersive virtual reality environment by
`
`including a live or prerecorded image of the live performer and audio communication between
`
`the live performer and the participant or between the participant and live performer or both;
`
`having the participant interact with the live performer producing an experience controlled by the
`
`participant and participant input device. (Id. at 3-10.)
`
`53. Merck provides a method of providing interactive communications between
`
`participants and performers. (Id. at 3-4.)
`
`54. The method provided by Merck includes providing an immersive virtual reality
`
`environment. (Id. at 4-5.)
`
`55. Merck’s method also includes providing at least one performer input device in
`
`electronic communication with said immersive virtual reality environment. (Id. at 5.)
`
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`56. Merck’s method further includes providing at least one participant input device in
`
`electronic communication with said immersive virtual reality environment. (Id. at 6.)
`
`57. Additionally, Merck’s method includes providing at least one performer output
`
`device in electronic communication with said immersive virtual reality environment. (Id. at 6-7.)
`
`58. Defendant’s method also includes providing at least one participant output device
`
`in electronic communication with said immersive virtual reality environment. (Id. at 7.)
`
`59. The method provided by Merck also includes having at least one live performer
`
`interact with at least one participant and said immersive virtual reality environment, by including
`
`with said virtual reality environment a live or prerecorded video image of said at least one live
`
`performer and audio communication between said at least one live performer and said at least
`
`one participant, or between said at least one participant and said at least one live performer, or
`
`both. (Id. at 7-8.)
`
`60. Merck’s method also includes having at least one participant interact with at least
`
`one such live performer and said immersive virtual reality environment, thereby resulting in an
`
`experience which is in part controlled by said at least one participant and said at least one
`
`participant input device. (Id. at 8-10.)
`
`61. Defendant was made aware of the ’599 patent and its infringement thereof at least
`
`as early as the filing and service of this Complaint. Despite Plaintiff’s notice to Merck by this
`
`Complaint regarding the ʼ599 patent, the Defendant continues to infringe the ʼ599 patent.
`
`62. Upon information and belief, since at least the time it received notice by this
`
`Complaint, Merck’s infringement has been and continues to be willful.
`
`63. Plaintiff VIT has been harmed by each of Merck’s infringing activities with
`
`respect to the ʼ599 patent.
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`64. VIT reserves the right to modify its infringement theories as discovery progresses
`
`in this case. It shall not be estopped for purposes of its infringement contentions or its claim
`
`constructions by the claim charts it provides with this Complaint. VIT intends the claim chart
`
`(Exhibit B) for the ’599 patent to satisfy the notice requirements of Rule 8(a)(2) of the Federal
`
`Rule of Civil Procedure. The claim chart is not VIT’s preliminary or final infringement
`
`contentions or preliminary or final claim construction positions.
`
`JURY DEMAND
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands a trial by
`
`jury on all issues triable as such.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff demands judgment for itself and against Defendant as follows:
`
`A.
`
`B.
`
`An adjudication that Defendant has infringed the ’599 patent;
`
`An award of damages to be paid by Defendant adequate to compensate Plaintiff
`
`for Defendant’s past infringement of the ’599 patent, and any continuing or future infringement
`
`through the date such judgment is entered, including interest, costs, expenses and an accounting
`
`of all infringing acts including, but not limited to, those acts not presented at trial;
`
`C.
`
`A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of
`
`Plaintiff’s reasonable attorneys’ fees; and
`
`D.
`
`An award to Plaintiff of such further relief at law or in equity as the Court deems
`
`just and proper.
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`Case 6:20-cv-00610 Document 1 Filed 07/06/20 Page 14 of 14
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`Dated: July 6, 2020
`
`
`
`
`DEVLIN LAW FIRM LLC
`
`
`
`/s/ Alex Chan
`Alex Chan (Texas Bar No. 24108051)
`achan@devlinlawfirm.com
`Timothy Devlin (pro hac vice to be filed)
`tdevlin@devlinlawfirm.com
`Patrick R. Delaney (pro hac vice to be filed)
`pdelaney@devlinlawfirm.com
`Cory Edwards (pro hac vice to be filed)
`cedwards@devlinlawfirm.com
`1526 Gilpin Ave.
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`
`Attorneys for Plaintiff
`Virtual Immersion Technologies LLC
`
`
`
`
`
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`
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