Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 1 of 17
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`SCANNING TECHNOLOGIES
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`INNOVATIONS LLC,
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`Plaintiff,
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`vs.
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`IDEABUD, LLC d/b/a TICKETBUD
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`Defendant.
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`_____________________________________ §
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`Case No: 6:21-cv-12
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`PATENT CASE
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`ORIGINAL COMPLAINT
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`Pursuant to F.R.C.P. 15(a)(1)(B), Plaintiff Scanning Technologies Innovations, LLC
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`(“Plaintiff” or “STI”) files this Original Complaint against Ideabud, LLC d/b/a Ticketbud
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`(“Defendant” or “Ideabud”) for infringement of United States Patent No. 10,600,101 (hereinafter
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`“the ‘101 Patent”).
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`PARTIES AND JURISDICTION
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`1.
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`This is an action for patent infringement under Title 35 of the United States Code.
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`Plaintiff is seeking injunctive relief as well as damages.
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`2.
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`Jurisdiction is proper in this Court pursuant to 28 U.S.C. §§ 1331 (Federal
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`Question) and 1338(a) (Patents) because this is a civil action for patent infringement arising
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`under the United States patent statutes.
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`3.
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`Plaintiff is a Texas limited liability company having an address of 1801 NE 123
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`St., Suite 314, Miami, FL 33181.
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`4.
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`On information and belief, Defendant is a Texas limited liability company
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`corporation having a place of business at 3300 N. Interstate Hwy. 35, Austin, TX 78705.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`PAGE | 1
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 2 of 17
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`5.
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`On information and belief, this Court has personal jurisdiction over Defendant
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`because Defendant has committed, and continues to commit, acts of infringement in this District,
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`has conducted business in this District, and/or has engaged in continuous and systematic
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`activities in this District.
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`6.
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`On information and belief, Defendant’s instrumentalities that are alleged herein
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`to infringe were and continue to be used, imported, offered for sale, and/or sold in this District.
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`VENUE
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`7.
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`Venue is proper in this District 28 U.S.C. §1400(b) because Defendant is deemed
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`to reside in this District. Alternatively, acts of infringement are occurring in this District and
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`Defendant has a regular and established place of business in this District.
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`COUNT I
`(INFRINGEMENT OF UNITED STATES PATENT NO. 10,600,101)
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`Plaintiff incorporates paragraphs 1 through 7 herein by reference.
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`This cause of action arises under the patent laws of the United States and, in
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`8.
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`9.
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`particular, under 35 U.S.C. §§ 271, et seq.
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`10.
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`Plaintiff is the owner by assignment of the ‘101 Patent with sole rights to enforce
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`the ‘101 Patent and sue infringers.
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`11.
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`A copy of the ‘101 Patent, titled “Systems and Methods for Indicating the
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`Existence of Accessible Information Pertaining to Articles of Commerce,” is attached hereto as
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`Exhibit A.
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`12.
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`The ‘101 Patent is valid, enforceable, and was duly issued in full compliance with
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`Title 35 of the United States Code.
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`13.
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`The ‘101 Patent describes systems and methods for downloading a look-up table
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`from a server database to a mobile device via a communication network. ‘101 Patent, Abstract.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 3 of 17
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`The look-up table is configured to store a plurality of code numbers associated with articles of
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`commerce and a plurality of information link indicators. Id. Each indicator is associated with a
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`respective code and article of commerce, and indicates the existence of a link to information
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`about the article of commerce. Id.
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`14.
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`The ‘101 Patent recognizes problems associated with prior systems including that
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`the mobile devices of prior systems take time to connect to the Internet in order to access product
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`information. ‘101 Patent, 1:59-67. Also, prior systems don’t readily indicate whether there is a
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`link to additional information about the product. Id.
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`15.
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`Thus, the ‘101 Patent recognized a need to allow a consumer to readily determine
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`whether product information is available for a product having an associated product code. ‘101
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`Patent, 2: 3:11. A further need existed for a mobile device to allow a consumer offline access to
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`immediately determine whether the product information was available. Id.
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`16.
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`In certain embodiments, the ‘101 Patent includes a mobile device that is
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`configured to download a look-up table from a server and store the look-up table in a local
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`database. ‘101 Patent, 2:35-48. In response to receiving scan information regarding a product
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`code, a processing device on the mobile device is configured to look up the code in the look-up
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`table to determine whether or not a link to information about the associated product is available.
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`Id.
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`17.
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`The ‘101 Patent solves problems with the art that are rooted in computer
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`technology and that are associated with inventory management and the retrieval of information
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`associated with articles of commerce. The ‘101 Patent claims do not merely recite the
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`performance of some business practice known from the pre-Internet world along with the
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`requirement to perform it on the Internet.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`18.
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`The improvements of the ‘101 Patent and the features recited in the claims in the
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`‘101 Patent provide improvements to conventional hardware and software systems and methods.
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`The improvements render the claimed invention of the ‘101 Patent non-generic in view of
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`conventional components.
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`19.
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`The improvements of the ‘101 Patent and the features recitations in the claims of
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`the ’101 Patent are not those that would be well-understood, routine or conventional to one of
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`ordinary skill in the art at the time of the invention.
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`20.
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`Upon information and belief, Defendant has infringed and continues to infringe
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`one or more claims, including at least Claim 1, of the ‘101 Patent by making, using, importing,
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`selling, and/or offering for sale an event ticket management system covered by one or more
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`claims of the ‘101 Patent. Defendant has infringed and continues to infringe the ‘101 Patent
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`directly in violation of 35 U.S.C. § 271.
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`21.
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`Defendant sells, offers to sell, and/or uses an inventory system including, without
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`limitation, the Ticketbud ticket management system, the Ticketbud Mobile app, any associated
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`hardware and software, and any similar products (collectively, “Product”), which infringe at
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`least Claim 1 of the ‘101 Patent.
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`22.
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`The Product provides an application for scanning barcodes to obtain a decoded
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`link, which contains information about an article of commerce. Among other things, the Product
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`provides an event ticket management solution in which a ticket can be scanned (e.g., by way of
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`a QR code present on the ticket) to obtain a decoded link, which contains information about an
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`article of commerce (e.g., to display information related to a ticket when the code is scanned).
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`Certain aspects of this element are illustrated in the screenshots below and/or those provided in
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`connection with other allegations herein.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`23.
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`The Product includes a mobile device comprising a portable handheld housing
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`and a communication interface configured to enable the mobile device to communicate with a
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`communication network. For example, the Product incorporates a handheld device (e.g., mobile
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`device with Product software) and a communication interface (i.e., cloud-based communication
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`interface and/or Internet) configured to enable the handheld device to communicate with a
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`communication network. Certain aspects of this element are illustrated in the screenshots below
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`and/or those provided in connection with other allegations herein.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`24.
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`The Product uses a signal processing device and a visual input device, the visual
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`input device affixed within the portable handheld housing. For example, a visual input device
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`(e.g., camera for scanning barcode) and signal processing device (i.e., processor of handheld
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`device) are affixed within the portable handheld housing (e.g., the housing of the mobile device).
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`The mobile device camera is used to scan a code and, via the Product’s server, obtain details
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`related to a particular product (e.g., details about the ticket and event associated with the ticket).
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`Certain aspects of this element are illustrated in the screenshots below and/or those provided in
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`connection with other allegations herein.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 9 of 17
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`25.
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`The Product comprises digital files associated with the mobile device. For
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`example, the Product application has digital files (e.g., code image files, logos, and digital
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`product information) associated with the mobile device. Certain aspects of this element are
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`illustrated in the screenshots below and/or those provided in connection with other allegations
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`herein.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`26.
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`The Product also includes a server in communication with the communication
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`network, the server comprising a server database configured to store a look-up table that includes
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`at least a plurality of bar codes associated with a plurality of articles of commerce. For example,
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`the Product app communicates with a server through the communication network. The server
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`has a look-up table (i.e., remote database storing ticket details, such as guestlists associating
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`guest details with a particular event). Also, the server database contains codes, each having
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`associated information about a particular article of commerce. Certain aspects of this element
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`are illustrated in the screenshots below and/or those provided in connection with other
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`allegations herein.
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 12 of 17
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`27.
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`The look-up table also stores a plurality of information link indicators, each
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`information link indicator associated with a respective bar code and article of commerce. For
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`example, the look-up table (i.e., remote database accessed by the Product app/software) also
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 13 of 17
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`stores a plurality of information link indicators (e.g., link indicating scanned product and/or
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`validation of scanned code details associated with the product, such as details associated with
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`the ticket and/or the event associated with the ticket) indicating information associated with a
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`respective code. Certain aspects of this element are illustrated in the screenshots below and/or
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`those provided in connection with other allegations herein.
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`28.
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`Each information link indicator is configured as a status signal indicating the
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`existence or absence of a link to information pertaining to a respective article of commerce, the
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`link being made to the information via the communication network. For example, each
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`information link which is obtained by scanning a code indicates a status signal indicating the
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`existence or absence of a link to information about a respective article of commerce (e.g., link
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`indicating validation of scanned QR code ticket and details associated with ticket). The
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`information associated with the link is retrieved through the communication network. Certain
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 14 of 17
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`aspects of this element are illustrated in the screenshots below and/or those provided in
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`connection with other allegations herein.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`29.
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`The visual input device is configured to scan an image of an article of commerce,
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`decode the image to obtain a code and forward data from the scanned image to the signal
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`processing device. For example, the visual input device (i.e., handheld device camera) is
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`configured to scan an image of a code associated with an article of commerce. After scanning
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`the code, the code is decoded using Product software, which may be located on the mobile
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`device, to retrieve information about the product. The information is forwarded to the signal
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`processing device (i.e., processor of mobile device). Certain aspects of this element are
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`illustrated in the screenshots below and/or those provided in connection with other allegations
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`herein.
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`30.
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`In response to receiving the bar code, the signal processing device (i.e., mobile
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`device) is configured to look up the code in the look-up table (i.e., Product database) to determine
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`from a respective information link (e.g., link to ticket/event information) whether or not
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 16 of 17
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`information pertaining to an article of commerce associated with the code (information about the
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`associated ticket/event) may be accessed via the communication network. Certain aspects of
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`this element are illustrated in the screenshots below and/or those provided in connection with
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`other allegations herein.
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`31.
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`Defendant’s actions complained of herein will continue unless Defendant is
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`enjoined by this court.
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`32.
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`Defendant’s actions complained of herein are causing irreparable harm and
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`monetary damage to Plaintiff and will continue to do so unless and until Defendant is enjoined
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`and restrained by this Court.
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`33.
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`Plaintiff is in compliance with 35 U.S.C. § 287.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff asks the Court to:
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`(a)
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`Enter judgment for Plaintiff on this Complaint on all causes of action asserted
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`herein;
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`(b)
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`Enter an Order enjoining Defendant, its agents, officers, servants, employees,
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`attorneys, and all persons in active concert or participation with Defendant who receive notice
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`of the order from further infringement of United States Patent No. 10,600,101 (or, in the
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`alternative, awarding Plaintiff a running royalty from the time of judgment going forward);
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`(c)
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`Award Plaintiff damages resulting from Defendant’s infringement in accordance
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`with 35 U.S.C. § 284;
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`Award Plaintiff pre-judgment and post-judgment interest and costs; and
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`Award Plaintiff such further relief to which the Court finds Plaintiff entitled under
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`(d)
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`(e)
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`law or equity.
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`PAGE | 16
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`Case 6:21-cv-00012-ADA Document 1 Filed 01/07/21 Page 17 of 17
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`Dated: January 7, 2021
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` Respectfully submitted,
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`/s/ Jay Johnson
`JAY JOHNSON
`State Bar No. 24067322
`D. BRADLEY KIZZIA
`State Bar No. 11547550
`KIZZIA JOHNSON, PLLC
`1910 Pacific Ave., Suite 13000
`Dallas, Texas 75201
`(214) 451-0164
`Fax: (214) 451-0165
`jay@kjpllc.com
`bkizzia@kjpllc.com
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`ATTORNEYS FOR PLAINTIFF
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`PLAINTIFF’S COMPLAINT AGAINST DEFENDANT IDEABUD, LLC d/b/a TICKETBUD
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`PAGE | 17
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