Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 1 of 15
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Cedar Lane Technologies Inc.,
`
`
`
`Case No. 6:20-cv-947
`
`Patent Case
`
`Jury Trial Demanded
`
`Plaintiff,
`
`v.
`
`Dish Network, L.L.C. ,
`
`Defendant.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Cedar Lane Technologies Inc. (“Plaintiff”), through its attorneys, complains of
`
`Dish Network, L.L.C. (“Defendant”), and alleges the following:
`
`PARTIES
`
`1.
`
`Plaintiff Cedar Lane Technologies Inc. is a corporation organized and existing
`
`under the laws of Canada that maintains its principal place of business at 560 Baker Street, Suite
`
`1, Nelson, BC V1L 4H9.
`
`2.
`
`Defendant Dish Network, L.L.C. is a corporation organized and existing under
`
`the laws of Colorado that maintains multiple established places of business in this District: (1) a
`
`customer call center, warehouse, service, and remanufacturing center in El Paso, Texas; (2) a
`
`micro digital broadcast operations center in Mustang Ridge, Texas; (3) a regional digital
`
`broadcast operations center in New Braunfels, Texas; and (4) property at 1285 Joe Battle
`
`Boulevard, El Paso, Texas.
`
`JURISDICTION
`
`3.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, Title 35 of the United States Code.
`
`
`
`1
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Cedar Lane Technologies Inc.,
`
`
`
`Case No. 6:20-cv-947
`
`Patent Case
`
`Jury Trial Demanded
`
`Plaintiff,
`
`v.
`
`Dish Network, L.L.C. ,
`
`Defendant.
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Cedar Lane Technologies Inc. (“Plaintiff”), through its attorneys, complains of
`
`Dish Network, L.L.C. (“Defendant”), and alleges the following:
`
`PARTIES
`
`1.
`
`Plaintiff Cedar Lane Technologies Inc. is a corporation organized and existing
`
`under the laws of Canada that maintains its principal place of business at 560 Baker Street, Suite
`
`1, Nelson, BC V1L 4H9.
`
`2.
`
`Defendant Dish Network, L.L.C. is a corporation organized and existing under
`
`the laws of Colorado that maintains multiple established places of business in this District: (1) a
`
`customer call center, warehouse, service, and remanufacturing center in El Paso, Texas; (2) a
`
`micro digital broadcast operations center in Mustang Ridge, Texas; (3) a regional digital
`
`broadcast operations center in New Braunfels, Texas; and (4) property at 1285 Joe Battle
`
`Boulevard, El Paso, Texas.
`
`JURISDICTION
`
`3.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, Title 35 of the United States Code.
`
`
`
`1
`
`
`
`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 2 of 15
`
`4.
`
`This Court has exclusive subject matter jurisdiction under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`5.
`
`This Court has personal jurisdiction over Defendant because it has engaged in
`
`systematic and continuous business activities in this District. As described below, Defendant has
`
`committed acts of patent infringement giving rise to this action within this District.
`
`VENUE
`
`6.
`
`Venue is proper in this District under 28 U.S.C. § 1400(b) because Defendant has
`
`committed acts of patent infringement in this District, and has an established place of business in
`
`this District.
`
`PATENTS-IN-SUIT
`
`7.
`
`Plaintiff is the assignee of all right, title and interest in United States Patent Nos.
`
`6,502,194; 6,526,411; 6,721,489; 7,173,177; 7,642,443; 8,165,867 (the “Patents-in-Suit”);
`
`including all rights to enforce and prosecute actions for infringement and to collect damages for
`
`all relevant times against infringers of the Patents-in-Suit. Accordingly, Plaintiff possesses the
`
`exclusive right and standing to prosecute the present action for infringement of the Patents-in-
`
`Suit by Defendant.
`
`THE ’194 PATENT
`
`8.
`
`The ’194 Patent is entitled “System for playback of network audio material on
`
`demand,” and issued 12/31/2002. The application leading to the ’194 Patent was filed on
`
`04/16/1999. A true and correct copy of the ’194 Patent is attached hereto as Exhibit 1 and
`
`incorporated herein by reference.
`
`9.
`
`The ’194 Patent is valid and enforceable.
`
`THE ’411 PATENT
`
`
`
`2
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 3 of 15
`
`10.
`
`The ’411 Patent is entitled “System and method for creating dynamic playlists,”
`
`and issued 02/25/2003. The application leading to the ’411 Patent was filed on 11/15/2000. A
`
`true and correct copy of the ’411 Patent is attached hereto as Exhibit 2 and incorporated herein
`
`by reference.
`
`11.
`
`The ’411 Patent is valid and enforceable.
`
`THE ’489 PATENT
`
`12.
`
`The ’489 Patent is entitled “Play list manager,” and issued 04/13/2004. The
`
`application leading to the ’489 Patent was filed on 03/08/2000. A true and correct copy of the
`
`’489 Patent is attached hereto as Exhibit 3 and incorporated herein by reference.
`
`13.
`
`The ’489 Patent is valid and enforceable.
`
`THE ’177 PATENT
`
`14.
`
`The ’177 Patent is entitled “User interface for simultaneous management of
`
`owned and unowned inventory,” and issued 02/06/2007. The application leading to the ’177
`
`Patent was filed on 10/29/2003. A true and correct copy of the ’177 Patent is attached hereto as
`
`Exhibit 4 and incorporated herein by reference.
`
`15.
`
`The ’177 Patent is valid and enforceable.
`
`THE ’443 PATENT
`
`16.
`
`The ’443 Patent is entitled “User interface for simultaneous management of
`
`owned and unowned inventory,” and issued 01/05/2010. The application leading to the ’443
`
`Patent was filed on 08/29/2006. A true and correct copy of the ’443 Patent is attached hereto as
`
`Exhibit 5 and incorporated herein by reference.
`
`17.
`
`The ’443 Patent is valid and enforceable.
`
`THE ’867 PATENT
`
`
`
`3
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 4 of 15
`
`18.
`
`The ’867 Patent is entitled “Methods for translating a device command,” and
`
`issued 04/24/2012. The application leading to the ’867 Patent was filed on 09/15/2000. A true
`
`and correct copy of the ’867 Patent is attached hereto as Exhibit 6 and incorporated herein by
`
`reference.
`
`19.
`
`The ’867 Patent is valid and enforceable.
`
`COUNT 1: INFRINGEMENT OF THE ’194 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`20.
`
`21.
`
`one or more claims of the ’194 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’194 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’194 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’194 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`22.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’194 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`23.
`
`Exhibit 7 includes charts comparing the Exemplary ’194 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’194 Patent. Accordingly, the Exemplary
`
`
`
`4
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 5 of 15
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`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’194
`
`Patent Claims.
`
`24.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 7.
`
`25.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`26.
`
`27.
`
`COUNT 2: INFRINGEMENT OF THE ’411 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`one or more claims of the ’411 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’411 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’411 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’411 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`28.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’411 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`
`
`29.
`
`Actual Knowledge of Infringement. The service of this Complaint upon
`
`Defendant constitutes actual knowledge of infringement as alleged here.
`
`
`
`5
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 6 of 15
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`30.
`
`Despite such actual knowledge, Defendant continues to make, use, test, sell,
`
`offer for sale, market, and/or import into the United States, products that infringe the ’411
`
`Patent. On information and belief, Defendant has also continued to sell the Exemplary
`
`Defendant Products and distribute product literature and website materials inducing end users
`
`and others to use its products in the customary and intended manner that infringes the ’411
`
`Patent. See Exhibit 8 (described below).
`
`31.
`
`Induced Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues to induce infringement of the ’411 Patent, literally or by
`
`the doctrine of equivalents, by selling Exemplary Defendant Products to their customers for
`
`use in end-user products in a manner that infringes one or more claims of the ’411 Patent.
`
`32.
`
`Contributory Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues materially contribute to their own customers infringement
`
`of the ’411 Patent, literally or by the doctrine of equivalents, by selling Exemplary Defendant
`
`Products to their customers for use in end-user products in a manner that infringes one or more
`
`claims of the ’411 Patent. The Exemplary Defendant Products are especially made or adapted
`
`for infringing the ’411 Patent and have no substantial non-infringing use. For example, in view
`
`of the preceding paragraphs, the Exemplary Defendant Products contain functionality which is
`
`material to at least one claim of the ’411 Patent.
`
`33.
`
`Exhibit 8 includes charts comparing the Exemplary ’411 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’411 Patent. Accordingly, the Exemplary
`
`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’411
`
`Patent Claims.
`
`
`
`6
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 7 of 15
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`34.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 8.
`
`35.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`36.
`
`37.
`
`COUNT 3: INFRINGEMENT OF THE ’489 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`one or more claims of the ’489 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’489 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’489 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’489 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`38.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’489 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`39.
`
`Exhibit 9 includes charts comparing the Exemplary ’489 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’489 Patent. Accordingly, the Exemplary
`
`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’489
`
`Patent Claims.
`
`
`
`7
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 8 of 15
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`40.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 9.
`
`41.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`42.
`
`43.
`
`COUNT 4: INFRINGEMENT OF THE ’177 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`one or more claims of the ’177 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’177 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’177 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’177 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`44.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’177 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`
`
`45.
`
`Actual Knowledge of Infringement. The service of this Complaint upon
`
`Defendant constitutes actual knowledge of infringement as alleged here.
`
`46.
`
`Despite such actual knowledge, Defendant continues to make, use, test, sell,
`
`offer for sale, market, and/or import into the United States, products that infringe the ’177
`
`Patent. On information and belief, Defendant has also continued to sell the Exemplary
`
`
`
`8
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 9 of 15
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`Defendant Products and distribute product literature and website materials inducing end users
`
`and others to use its products in the customary and intended manner that infringes the ’177
`
`Patent. See Exhibit 10 (described below).
`
`47.
`
`Induced Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues to induce infringement of the ’177 Patent, literally or by
`
`the doctrine of equivalents, by selling Exemplary Defendant Products to their customers for
`
`use in end-user products in a manner that infringes one or more claims of the ’177 Patent.
`
`48.
`
`Contributory Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues materially contribute to their own customers infringement
`
`of the ’177 Patent, literally or by the doctrine of equivalents, by selling Exemplary Defendant
`
`Products to their customers for use in end-user products in a manner that infringes one or more
`
`claims of the ’177 Patent. The Exemplary Defendant Products are especially made or adapted
`
`for infringing the ’177 Patent and have no substantial non-infringing use. For example, in view
`
`of the preceding paragraphs, the Exemplary Defendant Products contain functionality which is
`
`material to at least one claim of the ’177 Patent.
`
`49.
`
`Exhibit 10 includes charts comparing the Exemplary ’177 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’177 Patent. Accordingly, the Exemplary
`
`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’177
`
`Patent Claims.
`
`50.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 10.
`
`
`
`9
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 10 of 15
`
`51.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`52.
`
`53.
`
`COUNT 5: INFRINGEMENT OF THE ’443 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`one or more claims of the ’443 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’443 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’443 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’443 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`54.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’443 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`55.
`
`Exhibit 11 includes charts comparing the Exemplary ’443 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’443 Patent. Accordingly, the Exemplary
`
`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’443
`
`Patent Claims.
`
`56.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 11.
`
`
`
`10
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 11 of 15
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`57.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`58.
`
`59.
`
`COUNT 6: INFRINGEMENT OF THE ’867 PATENT
`
`Plaintiff incorporates the above paragraphs herein by reference.
`
`Direct Infringement. Defendant has been and continues to directly infringe
`
`one or more claims of the ’867 Patent in at least this District by making, using, offering to sell,
`
`selling and/or importing, without limitation, at least the Defendant products identified in the
`
`charts incorporated into this Count below (among the “Exemplary Defendant Products”) that
`
`infringe at least the exemplary claims of the ’867 Patent also identified in the charts
`
`incorporated into this Count below (the “Exemplary ’867 Patent Claims”) literally or by the
`
`doctrine of equivalents. On information and belief, numerous other devices that infringe the
`
`claims of the ’867 Patent have been made, used, sold, imported, and offered for sale by
`
`Defendant and/or its customers.
`
`60.
`
`Defendant also has and continues to directly infringe, literally or under the
`
`doctrine of equivalents, the Exemplary ’867 Patent Claims, by having its employees internally
`
`test and use these Exemplary Products.
`
`
`
`61.
`
`Actual Knowledge of Infringement. The service of this Complaint upon
`
`Defendant constitutes actual knowledge of infringement as alleged here.
`
`62.
`
`Despite such actual knowledge, Defendant continues to make, use, test, sell,
`
`offer for sale, market, and/or import into the United States, products that infringe the ’867
`
`Patent. On information and belief, Defendant has also continued to sell the Exemplary
`
`Defendant Products and distribute product literature and website materials inducing end users
`
`
`
`11
`
`
`
`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 12 of 15
`
`and others to use its products in the customary and intended manner that infringes the ’867
`
`Patent. See Exhibit 12 (described below).
`
`63.
`
`Induced Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues to induce infringement of the ’867 Patent, literally or by
`
`the doctrine of equivalents, by selling Exemplary Defendant Products to their customers for
`
`use in end-user products in a manner that infringes one or more claims of the ’867 Patent.
`
`64.
`
`Contributory Infringement. Defendant therefore actively, knowingly, and
`
`intentionally has been and continues materially contribute to their own customers infringement
`
`of the ’867 Patent, literally or by the doctrine of equivalents, by selling Exemplary Defendant
`
`Products to their customers for use in end-user products in a manner that infringes one or more
`
`claims of the ’867 Patent. The Exemplary Defendant Products are especially made or adapted
`
`for infringing the ’867 Patent and have no substantial non-infringing use. For example, in view
`
`of the preceding paragraphs, the Exemplary Defendant Products contain functionality which is
`
`material to at least one claim of the ’867 Patent.
`
`65.
`
`Exhibit 12 includes charts comparing the Exemplary ’867 Patent Claims to the
`
`Exemplary Defendant Products. As set forth in these charts, the Exemplary Defendant
`
`Products practice the technology claimed by the ’867 Patent. Accordingly, the Exemplary
`
`Defendant Products incorporated in these charts satisfy all elements of the Exemplary ’867
`
`Patent Claims.
`
`66.
`
`Plaintiff therefore incorporates by reference in its allegations herein the claim
`
`charts of Exhibit 12.
`
`67.
`
`Plaintiff is entitled to recover damages adequate to compensate for Defendants
`
`infringement.
`
`
`
`12
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 13 of 15
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`68.
`
`Under Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff respectfully
`
`JURY DEMAND
`
`requests a trial by jury on all issues so triable.
`
`WHEREFORE, Plaintiff respectfully requests the following relief:
`
`PRAYER FOR RELIEF
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`A judgment that the ’194 Patent is valid and enforceable
`
`A judgment that the ’411 Patent is valid and enforceable
`
`A judgment that the ’489 Patent is valid and enforceable
`
`A judgment that the ’177 Patent is valid and enforceable
`
`A judgment that the ’443 Patent is valid and enforceable
`
`A judgment that the ’867 Patent is valid and enforceable
`
`A judgment that Defendant has infringed directly one or more claims of the ’194
`
`Patent;
`
`H.
`
`A judgment that Defendant has infringed directly, contributorily, and/or induced
`
`I.
`
`J.
`
`infringement of one or more claims of the ’411 Patent;
`
`A judgment that Defendant has infringed directly one or more claims of the ’489
`
`Patent;
`
`A judgment that Defendant has infringed directly, contributorily, and/or induced
`
`infringement of one or more claims of the ’177 Patent;
`
`K.
`
`A judgment that Defendant has infringed directly one or more claims of the ’443
`
`Patent;
`
`L.
`
`A judgment that Defendant has infringed directly, contributorily, and/or induced
`
`infringement of one or more claims of the ’867 Patent;
`
`M.
`
`An accounting of all damages not presented at trial;
`
`
`
`13
`
`
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 14 of 15
`
`N.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’194 Patent.
`
`O.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’411 Patent.
`
`P.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’489 Patent.
`
`Q.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’177 Patent.
`
`R.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’443 Patent.
`
`S.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants past infringement with respect to the ’867 Patent.
`
`T.
`
`A judgment that awards Plaintiff all appropriate damages under 35 U.S.C. § 284
`
`for Defendants continuing or future infringement, up until the date such judgment
`
`is entered with respect to the ’411; ’177; ’867 Patents, including pre- or post-
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`judgment interest, costs, and disbursements as justified under 35 U.S.C. § 284;
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`U.
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`And, if necessary, to adequately compensate Plaintiff for Defendants infringement,
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`an accounting:
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`i.
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`that this case be declared exceptional within the meaning of 35 U.S.C. § 285
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`and that Plaintiff be awarded its reasonable attorneys fees against Defendant
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`that it incurs in prosecuting this action;
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`ii.
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`that Plaintiff be awarded costs, and expenses that it incurs in prosecuting this
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`action; and
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`14
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`Case 6:20-cv-00947-ADA Document 1 Filed 10/13/20 Page 15 of 15
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`iii.
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`that Plaintiff be awarded such further relief at law or in equity as the Court
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`deems just and proper.
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`Dated: October 13, 2020
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`Respectfully submitted,
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`
`/s/ Isaac Rabicoff
`Isaac Rabicoff
`Rabicoff Law LLC
`5680 King Centre Dr, Suite 645
`Alexandria, VA 22315
`(773) 669-4590
`isaac@rabilaw.com
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`Counsel for Plaintiff
`Cedar Lane Technologies Inc.
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`15
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