IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SILVER SCREEN TELE

-REALITY, INC., Plaintiff VS. DEALER IMPACT SYSTEMS, L.L.C.; YPAUTOS.COM, LLC, D/B/A EVERYCARLISTED.COM; DIGITAL MOTORWORKS, INC.; LIQUIDUS MARKETING, INC.; and UNITY WORKS! LLC, Defendants. § § § § § § § § § § § § § §

CASE NO. ___________________

JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement in which Silver Screen Tele-Reality, Inc. makes the following allegations against Dealer Impact Systems, L.L.C.; YPAutos.com, LLC, d/b/a EveryCarListed.com; Digital Motorworks, Inc.; Liquidus Marketing, Inc., and Unity Works! LLC (collectively the “Defendants”). I. PARTIES 1. Plaintiff Silver Screen Tele-Reality, Inc. (“Silver Screen”) is a Texas corporation with

its principle place of business at 4144 North Central Expressway, Suite 710, Dallas, Texas 75204. 2. Defendant Dealer Impact Systems, L.L.C. (“Dealer Impact”) is an Iowa limited

liability company with its principle place of business at 7733 Douglas Avenue, Urbandale, Iowa 50322. Dealer Impact has appointed Iowa Registered Agents Inc., 604 Locust Street, Suite 222, Des Moines, Iowa 50309, as its agent for service of process. 3. Defendant YPAutos.com, LLC, d/b/a EveryCarListed.com (“YPAutos.com”) is a

Texas limited liability company with its principle place of business at 6855 Oak Hill Boulevard,

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Tyler, Texas 75703. YPAutos.com has appointed Robert A. Roseman, 615 S. Broadway Avenue, Tyler, Texas 75701 as its agent for service of process. 4. Defendant Digital Motorworks, Inc. (“DMI”) is a Texas corporation with its principle

place of business at One ADP Boulevard, Mail Stop 433, Roseland, New Jersey 07068. DMI has appointed National Registered Agents, Inc., 16055 Space Center, Suite 235, Houston, Texas 77062, as its agent for service of process. 5. Defendant Liquidus Marketing, Inc. (“Liquidus”) is a Delaware corporation with its

principle place of business at 372 West Ontario, Suite 400, Chicago, Illinois 60610. Liquidus has appointed Todd K. Holmes, 372 West Ontario, Suite 400, Chicago, Illinois 60610, as its agent for service of process. 6. Defendant Unity Works! LLC ("Unity") is a Minnesota limited liability company with

its principle place of business at 7900 Xerxes Avenue, Suite 600, Bloomington, Minnesota 55431. Unity has appointed Tim Kost, 7900 Xerxes Avenue South, Suite 600, Bloomington, Minnesota 55431, as its registered agent for service of process. II. JURISDICTION AND VENUE 7. This action arises under the patent laws of the United States, Title 35 of the United

States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 8. Venue is proper in this district under 28 U.S.C. §§ 1391(c) and 1400(b). On

information and belief, each Defendant has transacted business in this district and has committed and/or induced acts of patent infringement in this district. 9. On information and belief, Defendants are subject to this Court’s specific and general

personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least to their substantial business in this forum, including (i) at least a portion of the infringements alleged
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herein; and (ii) regularly doing or soliciting business, engaging in other persistent acts of conduct, and/or deriving substantial revenue from services provided to individuals in Texas and in this judicial district. III. COUNT ONE INFRINGEMENT OF U.S. PATENT NO. 7,882,258 10. Silver Screen is the owner by assignment of United States Patent No. 7,882,258 (“the ‘258 Patent”) entitled System, Method, and Computer Readable Medium for Creating a Video Clip”. The ‘258 Patent issued on February 1, 2011. A true and correct copy of the ‘258 Patent is attached as Exhibit A. 11. Upon information and belief, Defendant Dealer Impact has been and is now directly infringing, and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘258 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by, among other things, making, using, offering to sell, selling and/or importing methods, systems and/or a non-transitory computer readable medium covered by one or more claims of the ‘258 Patent within the United States, including in connection with various websites (including but not limited to www.dealerimpact.com and www.flickfusion.com). Methods,

systems and/or software made, used, offered for sale or sold by DealerImpact.com that infringe the ‘258 Patent include, but are not limited to, Dealer Impact System’s Video Generator and Syndication System and Flick Fusion. Defendant Dealer Impact is thus liable for infringement of the ‘258 Patent pursuant to 35 U.S.C. § 271. 12. Upon information and belief, Defendant YPAutos.com has been and is now directly infringing, and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘258 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by, among other things, making, using, offering to sell, selling and/or importing
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methods, systems and/or a non-transitory computer readable medium covered by one or more claims of the ‘258 Patent within the United States, including in connection with various websites (including but not limited to www.everycarlisted.com). Methods and/or systems made, used, offered for sale or sold by YPAutos.com that infringe the ‘258 Patent include, but are not limited to the EveryCarListed.com® videos. Defendant YPAutos.com is thus liable for infringement of the ‘258 Patent pursuant to 35 U.S.C. § 271. 13. Upon information and belief, Defendant DMI has been and is now directly infringing, and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘258 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by, among other things, making, using, offering to sell, selling and/or importing methods, systems and/or a non-transitory computer readable medium covered by one or more claims of the ‘258 Patent within the United States, including in connection with various websites (including but not limited to www.digitalmotorworks.com). Methods and/or systems made, used, offered for sale or sold by DMI that infringe the ‘258 Patent include, but are not limited to, InfoIQ® Videos. Defendant DMI is thus liable for infringement of the ‘258 Patent pursuant to 35 U.S.C. § 271. 14. Upon information and belief, Defendant Liquidus has been and is now directly infringing, and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘258 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by, among other things, making, using, offering to sell, selling and/or importing methods, systems and/or a non-transitory computer readable medium covered by one or more claims of the ‘258 Patent within the United States, including in connection with various websites (including but not limited to www.liquidus.net). Methods and/or systems made, used, offered for sale or sold by Liquidus that infringe the ‘258 Patent include, but are not limited to, Videolink™

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videos. Defendant Liquidus is thus liable for infringement of the ‘258 Patent pursuant to 35 U.S.C. § 271. 15. Upon information and belief, Defendant Unity has been and is now directly infringing, and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘258 Patent in the State of Texas, in this judicial district, and elsewhere in the United States by, among other things, making, using, offering to sell, selling and/or importing methods, systems and/or a non-transitory computer readable medium covered by one or more claims of the ‘258 Patent within the United States, including in connection with various websites (including but not limited to www.unityworksmedia.com). Methods and/or systems made, used, offered for sale or sold by Unity that infringe the ‘258 Patent include, but are not limited to, Unity's Video WalkArounds. Defendant Unity is thus liable for infringement of the ‘258 Patent pursuant to 35 U.S.C. § 271. 16. Silver Screen has at all times complied with 35 U.S.C. § 287.

17. To the extent that facts learned in discovery show that Defendants’ infringement of the ‘258 Patent is or has been willful, Silver Screen reserves the right to request such a finding at time of trial. 18. As a result of the Defendants’ infringement of the ‘258 Patent, Silver Screen has suffered monetary damages in an amount not yet determined. 19. Silver Screen has no adequate remedy at law against these acts of patent infringement. Unless Defendants are preliminarily and permanently enjoined from their infringement of the ‘258 Patent, Silver Screen will suffer irreparable harm.

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IV. PRAYER FOR RELIEF Plaintiff Silver Screen prays for the following relief: (a) A judgment that each Defendant has directly infringed the ‘258 Patent,

contributorily infringed the ‘258 Patent, and/or induced infringement of the ‘258 Patent; (b) Preliminary and permanent injunctive relief pursuant to 35 U.S.C. § 283 prohibiting

each Defendant and its officers, directors, agents, servants, employees, attorneys, licensees, successors, and assigns and those in active concert or participation with any of them from directly infringing, contributorily infringing, and inducing the infringement of the ’258 Patent; (c) A judgment and order requiring each Defendant to pay Silver Screen damages

under 35 U.S.C. § 284, together with pre-judgment and post-judgment interest; (d) infringement; (e) A judgment and order requiring each Defendant to pay Silver Screen the costs of Judgment that the damages so adjudged be trebled due to any of Defendants’ willful

this action (including all disbursements) and the attorneys’ fees as provided by U.S.C. § 285; and (f) Such other and further relief as the Court deems just and equitable. V. DEMAND FOR JURY TRIAL Plaintiff Silver Screen hereby demands that all issues be determined by jury.

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Dated: September 12, 2011. Respectfully submitted, /S/ Michael C. Wilson MICHAEL C. WILSON Texas State Bar No. 21704590 mwilson@munckcarter.com JOHN S. TORKELSON Texas State Bar No. 00795154 jtorkelson@munckcarter.com MUNCK CARTER, LLP 600 Banner Place Tower 12770 Coit Road Dallas, Texas 75251 Telephone: 972.628.3600 Telecopier: 972.628.3616 ATTORNEYS FOR PLAINTIFF, SILVER SCREEN TELE-REALITY, INC.

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