1 Randall J. Sunshine (SBN 137363) rsunshine@linerlaw.com 2 Ryan E. Hatch (SBN 235577) rhatch@linerlaw.com 3 Jason L. Haas (SBN 217290) jhaas@linerlaw.

com 4 LINER LLP 1100 Glendon Avenue, 14th Floor 5 Los Angeles, California 90024.3503 Telephone: (310) 500-3500 6 Facsimile: (310) 500-3501 7 Attorneys for Plaintiff SIGNAL IP, INC. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 SIGNAL IP, INC., a California 12 corporation, 13 14 vs. Plaintiff, Case No. 2:14-cv-02962 COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED

15 NISSAN NORTH AMERICA, INC., a California corporation, 16 Defendant. 17 18 Plaintiff Signal IP, Inc. (Signal IP or Plaintiff) brings this Complaint

19 against Defendant Nissan North America, Inc. (Nissan or Defendant), alleging 20 as follows: 21 22 1. PARTIES Plaintiff Signal IP is a California corporation with its principal place of

23 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. 24 2. On information and belief, Nissan North America, Inc. is a California 25 corporation with its principal place of business at 1 Nissan Way, Franklin, 26 Tennessee 37067. 27 28 3. JURISDICTION, VENUE AND JOINDER This action arises under the patent laws of the United States, Title 35 of
Case No. 2:14-cv-02962 COMPLAINT FOR PATENT INFRINGEMENT

1 the United States Code. This Court has subject matter jurisdiction pursuant to 28 2 U.S.C. 1331 and 1338(a). 3 4. This Court has personal jurisdiction over Defendant. Defendant has 4 conducted extensive commercial activities and continues to conduct extensive 5 commercial activities within the State of California. Defendant Nissan North 6 America, Inc. is a California Corporation and was headquartered in Gardena, CA 7 when it entered the market in the 1960s until approximately 2008. Defendant is 8 registered to do business in California. On information and belief, Defendant, 9 directly and/or through intermediaries (including Defendants entities, subsidiaries, 10 distributors, sales agents, partners and others), distributes, offers for sale, sells, 11 and/or advertises its products (including but not limited to the products and services 12 that are accused of infringement in this lawsuit) in the United States, in the State of 13 California, and in this judicial district, under the Nissan and Infiniti brand 14 names. Defendant has purposefully and voluntarily placed one or more of its 15 infringing products and services into the stream of commerce with the expectation 16 that the products and services will be purchased or used by customers in California 17 and within this judicial district. Accordingly, Defendant has infringed Signal IPs 18 patents within the State of California and in this judicial district as alleged in more 19 detail below. 20 21 22 6. 5. Venue is proper in this district under 28 U.S.C. 1391 and 1400(b). BACKGROUND Signal IP, Inc. is a California corporation with a principal place of

23 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. It is the 24 owner of the entire right, title and interest in and to U.S. Patent Nos. 5,714,927; 25 5,732,375; 6,434,486; 6,775,601; 6,012,007; and 5,463,374 (the Patents-in-Suit). 26 7. On information and belief, Defendant is a direct or indirect subsidiary 27 of global car manufacturer and distributor Nissan Motor Co. Ltd., (Nissan Motor), 28 which is headquartered in Japan. Nissan Motor manufactures and distributes 2
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

1 vehicles under the Nissan and Infiniti brand names. 2 3 4 8. 5 forth in full herein. 6 9. Signal IP is the owner of the entire right, title, and interest in and to 7 U.S. Patent No. 5,714,927 (the 927 Patent), entitled Method of Improving Zone of 8 Coverage Response of Automotive Radar. The 927 Patent was duly and legally 9 issued by the U.S. Patent and Trademark Office on February 3, 1998. A true and 10 correct copy of the 927 Patent is attached as Exhibit A. 11 10. Defendant has directly infringed and continues to infringe, literally 12 and/or under the doctrine of equivalents, the 927 Patent by making, using, offering 13 for sale, and/or selling in the United States certain methods or systems disclosed and 14 claimed in the 927 Patent, including but not limited to the Blind Spot Intervention 15 System and Blind Spot Warning System, used in products including but not limited 16 to the Nissan Quest, and the Infiniti Q50, Q70/M, Q60/JX, Q50 Hybrid, QX60 17 Hybrid, and QX70 Hybrid, and Infiniti Q50, Q70/M, QX50EX, QX60/JX, 18 Q80/X56, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 19 11. Defendant has contributorily infringed and is currently contributorily 20 infringing the 927 Patent by making, using, offering for sale, and/or selling in the 21 United States certain methods or systems disclosed and claimed in the 927 Patent, 22 including but not limited to the Blind Spot Intervention System and Blind Spot 23 Warning System, used in products including but not limited to the Nissan Quest, and 24 the Infiniti Q50, Q70/M, Q60/JX, Q50 Hybrid, QX60 Hybrid, and QX70 Hybrid, 25 and Infiniti Q50, Q70/M, QX50EX, QX60/JX, Q80/X56, Q50 Hybrid, QX60 26 Hybrid, and Q70 Hybrid. 27 12. Defendant has actively induced and is actively inducing the 28 infringement of the 927 Patent by making, using, offering for sale, and/or selling in 3
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

FIRST CLAIM FOR RELIEF (Infringement of the 927 Patent) Plaintiff incorporates paragraphs 1 through 7 of this complaint as if set

1 the United States certain methods or systems disclosed and claimed in the 927 2 Patent, including but not limited to the Blind Spot Intervention System and Blind 3 Spot Warning System, used in products including but not limited to the Nissan 4 Quest, and the Infiniti Q50, Q70/M, Q60/JX, Q50 Hybrid, QX60 Hybrid, and QX70 5 Hybrid, and Infiniti Q50, Q70/M, QX50EX, QX60/JX, Q80/X56, Q50 Hybrid, 6 QX60 Hybrid, and Q70 Hybrid. 7 13. Defendants infringement of the 927 Patent has been and continues to 8 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 9 14. Unless enjoined by this Court, Defendant will continue to infringe the 10 927 Patent. 11 15. As a direct and proximate result of the Defendants conduct, Plaintiff 12 has suffered, and will continue to suffer, irreparable injury for which it has no 13 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 14 issues, will continue to be damaged in an amount yet to be determined. 15 16 17 16. 18 forth in full herein. 19 17. Signal IP is the owner of the entire right, title, and interest in and to 20 U.S. Patent No. 5,732,375 (the 375 Patent), entitled Method of Inhibiting or 21 Allowing Airbag Deployment. The 375 Patent was duly and legally issued by the 22 U.S. Patent and Trademark Office on March 24, 1998. A true and correct copy of 23 the 375 Patent is attached as Exhibit B. 24 18. Defendant has directly infringed and continues to infringe, literally 25 and/or under the doctrine of equivalents, the 375 Patent by making, using, offering 26 for sale, and/or selling in the United States certain methods or systems disclosed and 27 claimed in the 375 Patent, including but not limited to the Occupant Classification 28 Sensor system, used in products including but not limited to the Nissan 370Z, 4
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

SECOND CLAIM FOR RELIEF (Infringement of the 375 Patent) Plaintiff incorporates paragraphs 1 through 15 of this complaint as if set

1 Altima, Cube, Juke, Leaf, Maxima, Murano, Pathfinder, Quest, Rogue, Sentra, 2 Altima Hybrid, and Pathfinder Hybrid, and Infiniti G Sedan, G/Q60, Q50, Q60 and 3 G37 Coupe and Convertible, Q70/M, QX50/EX, QX60/JX, QX70/FX, 4 QX80/QX56, M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 5 19. Defendant has contributorily infringed and is currently contributorily 6 infringing the 375 Patent by making, using, offering for sale, and/or selling in the 7 United States certain methods or systems disclosed and claimed in the 375 Patent, 8 including but not limited to the Occupant Classification Sensor system, used in 9 products including but not limited to the Nissan 370Z, Altima, Cube, Juke, Leaf, 10 Maxima, Murano, Pathfinder, Quest, Rogue, Sentra, Altima Hybrid, and Pathfinder 11 Hybrid, and Infiniti G Sedan, G/Q60, Q50, Q60 and G37 Coupe and Convertible, 12 Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h Hybrid, Q50 Hybrid, 13 QX60 Hybrid, and Q70 Hybrid. 14 20. Defendant has actively induced and is actively inducing the 15 infringement of the 375 Patent by making, using, offering for sale, and/or selling in 16 the United States certain methods or systems disclosed and claimed in the 375 17 Patent, including but not limited to the Occupant Classification Sensor system, used 18 in products including but not limited to the Nissan 370Z, Altima, Cube, Juke, Leaf, 19 Maxima, Murano, Pathfinder, Quest, Rogue, Sentra, Altima Hybrid, and Pathfinder 20 Hybrid, and Infiniti G Sedan, G/Q60, Q50, Q60 and G37 Coupe and Convertible, 21 Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h Hybrid, Q50 Hybrid, 22 QX60 Hybrid, and Q70 Hybrid. 23 21. Defendants infringement of the 375 Patent has been and continues to 24 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 25 22. Unless enjoined by this Court, Defendant will continue to infringe the 26 375 Patent. 27 23. As a direct and proximate result of the Defendants conduct, Plaintiff 28 has suffered, and will continue to suffer, irreparable injury for which it has no 5
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

1 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 2 issues, will continue to be damaged in an amount yet to be determined. 3 4 5 24. 6 forth in full herein. 7 25. Signal IP is the owner of the entire right, title, and interest in and to 8 U.S. Patent No. 6,434,486 (the 486 Patent), entitled Technique for Limiting the 9 Range of an Object Sensing System in a Vehicle. The 486 Patent duly and legally 10 issued by the U.S. Patent and Trademark Office on August 13, 2002. A true and 11 correct copy of the 486 Patent is attached as Exhibit C. 12 26. Defendant has directly infringed and continues to infringe, literally 13 and/or under the doctrine of equivalents, the 486 Patent by making, using, offering 14 for sale, and/or selling in the United States certain methods or systems disclosed and 15 claimed in the 486 Patent, including but not limited to the (1) Moving Object 16 Detection system, used in products including but not limited to the Nissan Altima, 17 Juke, Murano, Pathfinder, Quest, Rogue, Versa, Altima Hybrid, and Pathfinder 18 Hybrid, and the Infiniti Q50, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, Q50 19 Hybrid, and QX60 Hybrid; (2) the Forward Collision Warning System, used in 20 products including but not limited to the Nissan Murano and Rogue, and Infiniti 21 G/Q60, Q50, Q60 and G37 Coupe and Convertible, Q70/M, QX50/EX, QX60/JX, 22 QX70/FX, QX80/QX56, M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 23 Hybrid; and (3) the Backup Collision Intervention system, used in products 24 including but not limited to the Infiniti Q50, QX60/JX, QX80/QX56, Q50 Hybrid, 25 and QX60 Hybrid. 26 27. Defendant has contributorily infringed and is currently contributorily 27 infringing the 486 Patent by making, using, offering for sale, and/or selling in the 28 United States certain methods or systems disclosed and claimed in the 486 Patent, 6
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

THIRD CLAIM FOR RELIEF (Infringement of the 486 Patent) Plaintiff incorporates paragraphs 1 through 23 of this complaint as if set

1 including but not limited to the (1) Moving Object Detection system, used in 2 products including but not limited to the Nissan Altima, Juke, Murano, Pathfinder, 3 Quest, Rogue, Versa, Altima Hybrid, and Pathfinder Hybrid, and the Infiniti Q50, 4 QX50/EX, QX60/JX, QX70/FX, QX80/QX56, Q50 Hybrid, and QX60 Hybrid; (2) 5 the Forward Collision Warning System, used in products including but not limited 6 to the Nissan Murano and Rogue, and Infiniti G/Q60, Q50, Q60 and G37 Coupe and 7 Convertible, Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h Hybrid, 8 Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid; and (3) the Backup Collision 9 Intervention system, used in products including but not limited to the Infiniti Q50, 10 QX60/JX, QX80/QX56, Q50 Hybrid, and QX60 Hybrid. 11 28. Defendant has actively induced and is actively inducing the 12 infringement of the 486 Patent by making, using, offering for sale, and/or selling in 13 the United States certain methods or systems disclosed and claimed in the 486 14 Patent, including but not limited to the (1) Moving Object Detection system, used in 15 products including but not limited to the Nissan Altima, Juke, Murano, Pathfinder, 16 Quest, Rogue, Versa, Altima Hybrid, and Pathfinder Hybrid, and the Infiniti Q50, 17 QX50/EX, QX60/JX, QX70/FX, QX80/QX56, Q50 Hybrid, and QX60 Hybrid; (2) 18 the Forward Collision Warning System, used in products including but not limited 19 to the Nissan Murano and Rogue, and Infiniti G/Q60, Q50, Q60 and G37 Coupe and 20 Convertible, Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h Hybrid, 21 Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid; and (3) the Backup Collision 22 Intervention system, used in products including but not limited to the Infiniti Q50, 23 QX60/JX, QX80/QX56, Q50 Hybrid, and QX60 Hybrid. 24 29. Defendants infringement of the 486 Patent has been and continues to 25 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 26 30. Unless enjoined by this Court, Defendant will continue to infringe the

27 486 Patent. 28 31. As a direct and proximate result of the Defendants conduct, Plaintiff 7
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

1 has suffered, and will continue to suffer, irreparable injury for which it has no 2 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 3 issues, will continue to be damaged in an amount yet to be determined. 4 5 6 32. 7 forth in full herein. 8 33. Signal IP is the owner of the entire right, title, and interest in and to 9 U.S. Patent No. 6,775,601 (the 601 Patent), entitled Method and Control System 10 for Controlling Propulsion in a Hybrid Vehicle. The 601 Patent was duly and 11 legally issued by the U.S. Patent and Trademark Office on August 10, 2004. A true 12 and correct copy of the 601 Patent is attached as Exhibit D. 13 34. Defendant has directly infringed and continues to infringe, literally 14 and/or under the doctrine of equivalents, the 601 Patent by making, using, offering 15 for sale, and/or selling in the United States certain methods or systems disclosed and 16 claimed in the 601 Patent, including but not limited to the Nissan Altima Hybrid 17 and Pathfinder Hybrid, and Infiniti M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and 18 Q70 Hybrid. 19 35. Defendant has contributorily infringed and is currently contributorily FOURTH CLAIM FOR RELIEF (Infringement of the 601 Patent) Plaintiff incorporates paragraphs 1 through 31 of this complaint as if set

20 infringing the 601 Patent by making, using, offering for sale, and/or selling in the 21 United States certain methods or systems disclosed and claimed in the 601 Patent, 22 including but not limited to the Nissan Altima Hybrid and Pathfinder Hybrid, and 23 Infiniti M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 24 36. Defendant has actively induced and is actively inducing the

25 infringement of the 601 Patent by making, using, offering for sale, and/or selling in 26 the United States certain methods or systems disclosed and claimed in the 601 27 Patent, including but not limited to the Nissan Altima Hybrid and Pathfinder Hybrid, 28 and Infiniti M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 8
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

37. 38.

Defendants infringement of the 601 Patent has been and continues to Unless enjoined by this Court, Defendant will continue to infringe on

2 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 3

4 the 601 Patent. 5 39. As a direct and proximate result of the Defendants conduct, Plaintiff 6 has suffered, and will continue to suffer, irreparable injury for which it has no 7 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 8 issues, will continue to be damaged in an amount yet to be determined. 9 10 11 40. 12 forth in full herein. 13 41. Signal IP is the owner of the entire right, title, and interest in and to 14 U.S. Patent No. 6,012,007 (the 007 Patent), entitled Occupant Detection Method 15 and Apparatus for Air Bag System. The 007 Patent was duly and legally issued by 16 the U.S. Patent and Trademark Office on January 4, 2000. A true and correct copy 17 of the 007 Patent is attached as Exhibit E. 18 42. Defendant has directly infringed and continues to infringe, literally 19 and/or under the doctrine of equivalents, the 007 Patent by making, using, offering 20 for sale, and/or selling in the United States certain methods or systems for vehicles 21 disclosed and claimed in the 007 Patent, including but not limited to the Nissan 22 Advanced Airbags with Occupant Classification Sensor, used in products including 23 but not limited to the Nissan 370Z, Altima, Armada, Cube, Frontier, GT-R, Juke, 24 Leaf, Maxima, Murano, Pathfinder, Quest, Rogue, Sentra, Titan, Versa, Xterra, NV, 25 NV 200, Altima Hybrid, and Pathfinder Hybrid, and the Occupant Classification 26 Sensor, used in products including but not limited to the Infiniti G Sedan, G/Q60, 27 Q50, Q60 and G37 Coupe and Convertible, Q70/M, QX50/EX, QX60/JX, 28 QX70/FX, QX80/QX56, M35h Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 9
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

FIFTH CLAIM FOR RELIEF (Infringement of the 007 Patent) Plaintiff incorporates paragraphs 1 through 39 of this complaint as if set

1 Hybrid. 2 43. Defendant has contributorily infringed and is currently contributorily

3 infringing the 007 Patent by making, using, offering for sale, and/or selling in the 4 United States certain methods or systems disclosed and claimed in the 007 Patent, 5 including but not limited to the Nissan Advanced Airbags with Occupant 6 Classification Sensor, used in products including but not limited to the Nissan 370Z, 7 Altima, Armada, Cube, Frontier, GT-R, Juke, Leaf, Maxima, Murano, Pathfinder, 8 Quest, Rogue, Sentra, Titan, Versa, Xterra, NV, NV 200, Altima Hybrid, and 9 Pathfinder Hybrid, and the Occupant Classification Sensor, used in products 10 including but not limited to the Infiniti G Sedan, G/Q60, Q50, Q60 and G37 Coupe 11 and Convertible, Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h 12 Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 13 44. Defendant has actively induced and is actively inducing the 14 infringement of the 007 Patent by making, using, offering for sale, and/or selling in 15 the United States certain methods or systems disclosed and claimed in the 007 16 Patent, including but not limited to the Nissan Advanced Airbags with Occupant 17 Classification Sensor, used in products including but not limited to the Nissan 370Z, 18 Altima, Armada, Cube, Frontier, GT-R, Juke, Leaf, Maxima, Murano, Pathfinder, 19 Quest, Rogue, Sentra, Titan, Versa, Xterra, NV, NV 200, Altima Hybrid, and 20 Pathfinder Hybrid, and the Occupant Classification Sensor, used in products 21 including but not limited to the Infiniti G Sedan, G/Q60, Q50, Q60 and G37 Coupe 22 and Convertible, Q70/M, QX50/EX, QX60/JX, QX70/FX, QX80/QX56, M35h 23 Hybrid, Q50 Hybrid, QX60 Hybrid, and Q70 Hybrid. 24 45. 46. Defendants infringement of the 007 Patent has been and continues to Unless enjoined by this Court, Defendant will continue to infringe on 25 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 26

27 the 007 Patent. 28 47. As a direct and proximate result of the Defendants conduct, Plaintiff 10
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

1 has suffered, and will continue to suffer, irreparable injury for which it has no 2 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 3 issues, will continue to be damaged in an amount yet to be determined. 4 5 6 48. 7 forth in full herein. 8 49. Signal IP is the owner of the entire right, title, and interest in and to 9 U.S. Patent No. 5,463,374 (the 374 Patent), entitled Method and Apparatus for 10 Tire Pressure Monitoring and for Shared Keyless Entry Control. The 374 Patent 11 was duly and legally issued by the U.S. Patent and Trademark Office on October 31, 12 1995. A true and correct copy of the 374 Patent is attached as Exhibit F. 13 50. Defendant has directly infringed, literally and/or under the doctrine of 14 equivalents, the 374 Patent by making, using, offering for sale, and/or selling in the 15 United States certain methods or systems for vehicles disclosed and claimed in the 16 374 Patent, including but not limited to the integrated Remote Keyless Entry (RKE) 17 and Tire Pressure Monitor Systems (TPMS), used in products including but not 18 limited to the Nissan Armada, Maxima, Pathfinder, Titan, and Versa, and the Infiniti 19 Q50, QX70/FX, QX80/QX56, and Q50 Hybrid. 20 51. Defendant has contributorily infringed the 374 Patent by making, 21 using, offering for sale, and/or selling in the United States certain methods or 22 systems disclosed and claimed in the 374 Patent, including but not limited to the 23 integrated Remote Keyless Entry (RKE) and Tire Pressure Monitor Systems 24 (TPMS), used in products including but not limited to the Nissan Armada, Maxima, 25 Pathfinder, Titan, and Versa, and the Infiniti Q50, QX70/FX, QX80/QX56, and Q50 26 Hybrid. 27 52. Defendant has actively induced infringement of the 374 Patent by 28 making, using, offering for sale, and/or selling in the United States certain methods 11
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

SIXTH CLAIM FOR RELIEF (Infringement of the 374 Patent) Plaintiff incorporates paragraphs 1 through 47 of this complaint as if set

1 or systems disclosed and claimed in the 374 Patent, including but not limited to the 2 integrated Remote Keyless Entry (RKE) and Tire Pressure Monitor Systems 3 (TPMS), used in products including but not limited to the Nissan Armada, Maxima, 4 Pathfinder, Titan, and Versa, and the Infiniti Q50, QX70/FX, QX80/QX56, and Q50 5 Hybrid. 6 53. As a direct and proximate result of the Defendant conduct, Plaintiff 7 has suffered irreparable injury for which it has no adequate remedy at law. Plaintiff 8 also has been damaged in an amount yet to be determined. 9 10 PRAYER FOR RELIEF Wherefore, Signal IP respectfully requests that the Court enter judgment

11 against Defendant as follows: 12 13 14 15 16 1. 2. 3. 4. 5. That Defendant has directly infringed the Patents-in-Suit; That Defendant has contributorily infringed the Patents-in-Suit; That Defendant has induced the infringement of the Patents-in-Suit; That Defendants infringement be adjudged willful and deliberate; That Defendant and its affiliates, subsidiaries, officers, directors,

17 employees, agents, representatives, successors, assigns, and all those acting in 18 concert, participation, or privity with them or on their behalf, including customers, 19 be enjoined from infringing, inducing others to infringe or contributing to the 20 infringement of the Patents-in-Suit; 21 6. For damages, according to proof, for Defendants infringement, 22 together with pre-judgment and post-judgment interest, as allowed by law and that 23 such damages be trebled as provided by 35 U.S.C. 284; 24 26 and 27 28 12
COMPLAINT FOR PATENT INFRINGEMENT Case No. 2:14-cv-02962

7.

That this Court determine that this is an exceptional case under 35

25 U.S.C. 285 and an award of attorneys fees and costs to Signal IP is warranted; For such other and further relief as the Court may deem just and proper.

1 Dated: April 17, 2014 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

LINER LLP

By:

/s/ Ryan E. Hatch Randall J. Sunshine Ryan E. Hatch Jason L. Haas Attorneys for Plaintiff SIGNAL IP, INC.

13
COMPLAINT FOR PATENT INFRINGEMENT

Case No. 2:14-cv-02962