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INFRINGEMENT OF THE ’523 PATENT BY DEFENDANT
36. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
37. Defendant has knowledge of infringement of the ’523 patent since at
least the filing of this complaint.
38. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’523 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25
and 26 of the ’523 patent in violation of 35 U.S.C. § 271(a); (b) has induced and
continues to induce infringement of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25 and 26
of the ’523 patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and
continues to contribute to the infringement of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23,
25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(c).
39. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1 and 19 as well as dependent claims 3, 4, 6, 8, 9,
10, 21, 23, 25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(a).
40. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’523 patent and in a
manner Defendant knows infringes the patent.
41. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25 and 26 of the ’523 patent in violation of
35 U.S.C. § 271(b). In particular, Plaintiff alleges that the claims of the ‘523
patent are directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the
course of their normal use. Also, Defendant encourages others to directly infringe
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 10 of 20
COMPLAINT -11-
the claims of the ’523 patent by among other things, advertising and promoting the
sale and use of the accused products. Plaintiff also alleges that Defendant has
knowingly induced and continues to induce infringement of the ‘523 patent by
providing operating manuals, guides, instructional and /or informational videos and
other materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
42. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 6, 8,
9, 10, 19, 21, 23, 25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(c) by
importing into the United States, selling and/or offering to sell within the United
States accused products that it knows (a) infringe the aforementioned claims of the
‘523 patent by embodying a System and Method for Managing Mobile
Communications which includes but the Dropcam and Dropcam Pro wireless
camera systems, and without limitation, Defendant’s server and subscription
services for remote monitoring and communication as material components of the
accused products, (b) which were made and/or especially adapted for use in the
accused products, (c) which the Defendant knows to be especially adapted for use
in infringing the ’523 patent, and (d) are not staple articles of commerce suitable
for substantial non-infringing use with respect to the ’523 patent.
43. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’523 patent. On information and belief, these products are designed
to practice the infringing features.
44. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’523 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT FOUR
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 11 of 20
COMPLAINT -12-
INFRINGEMENT OF THE ’524 PATENT BY DEFENDANT
45. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
46. Defendant has knowledge of infringement of the ’524 patent since at
least the filing of this complaint.
47. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’524 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 5, 7 and 9 of the ’524 patent
in violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35
U.S.C. § 271(b); and (c) has contributed and continues to contribute to the
infringement of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35
U.S.C. § 271(c).
48. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1 as well as dependent claims 3, 4, 5, 7 and 9 of
the ’524 patent in violation of 35 U.S.C. § 271(a).
49. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’524 patent and in a
manner Defendant knows infringes the patent.
50. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35 U.S.C. § 271(b).
In particular, Plaintiff alleges that the claims of the ‘524 patent are directly
infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course of their
normal use. Also, Defendant encourages others to directly infringe the claims of
36. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
37. Defendant has knowledge of infringement of the ’523 patent since at
least the filing of this complaint.
38. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’523 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25
and 26 of the ’523 patent in violation of 35 U.S.C. § 271(a); (b) has induced and
continues to induce infringement of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25 and 26
of the ’523 patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and
continues to contribute to the infringement of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23,
25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(c).
39. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1 and 19 as well as dependent claims 3, 4, 6, 8, 9,
10, 21, 23, 25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(a).
40. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’523 patent and in a
manner Defendant knows infringes the patent.
41. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 6, 8, 9, 10, 19, 21, 23, 25 and 26 of the ’523 patent in violation of
35 U.S.C. § 271(b). In particular, Plaintiff alleges that the claims of the ‘523
patent are directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the
course of their normal use. Also, Defendant encourages others to directly infringe
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 10 of 20
COMPLAINT -11-
the claims of the ’523 patent by among other things, advertising and promoting the
sale and use of the accused products. Plaintiff also alleges that Defendant has
knowingly induced and continues to induce infringement of the ‘523 patent by
providing operating manuals, guides, instructional and /or informational videos and
other materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
42. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 6, 8,
9, 10, 19, 21, 23, 25 and 26 of the ’523 patent in violation of 35 U.S.C. § 271(c) by
importing into the United States, selling and/or offering to sell within the United
States accused products that it knows (a) infringe the aforementioned claims of the
‘523 patent by embodying a System and Method for Managing Mobile
Communications which includes but the Dropcam and Dropcam Pro wireless
camera systems, and without limitation, Defendant’s server and subscription
services for remote monitoring and communication as material components of the
accused products, (b) which were made and/or especially adapted for use in the
accused products, (c) which the Defendant knows to be especially adapted for use
in infringing the ’523 patent, and (d) are not staple articles of commerce suitable
for substantial non-infringing use with respect to the ’523 patent.
43. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’523 patent. On information and belief, these products are designed
to practice the infringing features.
44. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’523 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT FOUR
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 11 of 20
COMPLAINT -12-
INFRINGEMENT OF THE ’524 PATENT BY DEFENDANT
45. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
46. Defendant has knowledge of infringement of the ’524 patent since at
least the filing of this complaint.
47. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’524 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 5, 7 and 9 of the ’524 patent
in violation of 35 U.S.C. § 271(a); (b) has induced and continues to induce
infringement of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35
U.S.C. § 271(b); and (c) has contributed and continues to contribute to the
infringement of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35
U.S.C. § 271(c).
48. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1 as well as dependent claims 3, 4, 5, 7 and 9 of
the ’524 patent in violation of 35 U.S.C. § 271(a).
49. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’524 patent and in a
manner Defendant knows infringes the patent.
50. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 5, 7 and 9 of the ’524 patent in violation of 35 U.S.C. § 271(b).
In particular, Plaintiff alleges that the claims of the ‘524 patent are directly
infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course of their
normal use. Also, Defendant encourages others to directly infringe the claims of
the ’524 patent by among other things, advertising and promoting the sale and use
of the accused products. Plaintiff also alleges that Defendant has knowingly
induced and continues to induce infringement of the ‘524 patent by providing
operating manuals, guides, instructional and /or informational videos and other
materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
51. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 5, 7
and 9 of the ’524 patent in violation of 35 U.S.C. § 271(c) by importing into the
United States, selling and/or offering to sell within the United States accused
products that it knows (a) infringe the aforementioned claims of the ‘524 patent by
embodying a System and Method for Managing Mobile Communications which
includes but the Dropcam and Dropcam Pro wireless camera systems, and without
limitation, Defendant’s server and subscription services for remote monitoring and
communication as material components of the accused products, (b) which were
made and/or especially adapted for use in the accused products, (c) which the
Defendant knows to be especially adapted for use in infringing the ’524 patent, and
(d) are not staple articles of commerce suitable for substantial non-infringing use
with respect to the ’524 patent.
52. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’524 patent. On information and belief, these products are designed
to practice the infringing features.
53. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’524 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT FIVE
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 13 of 20
COMPLAINT -14-
INFRINGEMENT OF THE ’618 PATENT BY DEFENDANT
54. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
55. Defendant has knowledge of infringement of the ’618 patent since at
least the filing of this complaint.
56. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’618 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 15, 19, 20, 21, 22, 23, 24,
and 25 of the ’618 patent in violation of 35 U.S.C. § 271(a); (b) has induced and
continues to induce infringement of claims 1, 3, 4, 15, 19, 20 21, 22, 23, 24, and 25
of the ’618 patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and
continues to contribute to the infringement of claims 1, 3, 4, 15, 19, 20 21, 22, 23,
24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(c).
57. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1, 15, and 20 as well as dependent claims 3, 4,
19, 21, 23, 24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(a).
58. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’618 patent and in a
manner Defendant knows infringes the patent.
59. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 15, 19, 20 21, 23, 24, and 25 of the ’618 patent in violation of 35
U.S.C. § 271(b). In particular, Plaintiff alleges that the claims of the ‘618 patent
are directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course
of their normal use. Also, Defendant encourages others to directly infringe the
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 14 of 20
COMPLAINT -15-
claims of the ’618 patent by among other things, advertising and promoting the
sale and use of the accused products. Plaintiff also alleges that Defendant has
knowingly induced and continues to induce infringement of the ‘618 patent by
providing operating manuals, guides, instructional and /or informational videos and
other materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
60. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 15,
19, 20 21, 23, 24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(c) by
importing into the United States, selling and/or offering to sell within the United
States accused products that it knows (a) infringe the aforementioned claims of the
‘618 patent by embodying a System and Method for Managing Mobile
Communications which includes but the Dropcam and Dropcam Pro wireless
camera systems, and without limitation, Defendant’s server and subscription
services for remote monitoring and communication as material components of the
accused products, (b) which were made and/or especially adapted for use in the
accused products, (c) which the Defendant knows to be especially adapted for use
in infringing the ’618 patent, and (d) are not staple articles of commerce suitable
for substantial non-infringing use with respect to the ’618 patent.
61. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’618 patent. On information and belief, these products are designed
to practice the infringing features.
62. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’618 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT SIX
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 15 of 20
COMPLAINT -16-
INFRINGEMENT OF THE ’619 PATENT BY DEFENDANT
63. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
64. Defendant has knowledge of infringement of the ’619 patent since at
least the filing of this complaint.
65. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’619 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32
of the ’619 patent in violation of 35 U.S.C. § 271(a); (b) has induced and continues
to induce infringement of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the ’619
patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and continues to
contribute to the infringement of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the
’619 patent in violation of 35 U.S.C. § 271(c).
66. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1, and 19 as well as dependent claims 3, 4, 8, 21,
23, 29, 30, and 32 of the ’619 patent in violation of 35 U.S.C. § 271(a).
67. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’619 patent and in a
manner Defendant knows infringes the patent.
68. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the ’619 patent in violation of 35
U.S.C. § 271(b) In particular, Plaintiff alleges that the claims of the ‘619 patent are
directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course of
their normal use. Also, Defendant encourages others to directly infringe the claims
of the accused products. Plaintiff also alleges that Defendant has knowingly
induced and continues to induce infringement of the ‘524 patent by providing
operating manuals, guides, instructional and /or informational videos and other
materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
51. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 5, 7
and 9 of the ’524 patent in violation of 35 U.S.C. § 271(c) by importing into the
United States, selling and/or offering to sell within the United States accused
products that it knows (a) infringe the aforementioned claims of the ‘524 patent by
embodying a System and Method for Managing Mobile Communications which
includes but the Dropcam and Dropcam Pro wireless camera systems, and without
limitation, Defendant’s server and subscription services for remote monitoring and
communication as material components of the accused products, (b) which were
made and/or especially adapted for use in the accused products, (c) which the
Defendant knows to be especially adapted for use in infringing the ’524 patent, and
(d) are not staple articles of commerce suitable for substantial non-infringing use
with respect to the ’524 patent.
52. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’524 patent. On information and belief, these products are designed
to practice the infringing features.
53. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’524 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT FIVE
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 13 of 20
COMPLAINT -14-
INFRINGEMENT OF THE ’618 PATENT BY DEFENDANT
54. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
55. Defendant has knowledge of infringement of the ’618 patent since at
least the filing of this complaint.
56. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’618 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 15, 19, 20, 21, 22, 23, 24,
and 25 of the ’618 patent in violation of 35 U.S.C. § 271(a); (b) has induced and
continues to induce infringement of claims 1, 3, 4, 15, 19, 20 21, 22, 23, 24, and 25
of the ’618 patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and
continues to contribute to the infringement of claims 1, 3, 4, 15, 19, 20 21, 22, 23,
24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(c).
57. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1, 15, and 20 as well as dependent claims 3, 4,
19, 21, 23, 24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(a).
58. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’618 patent and in a
manner Defendant knows infringes the patent.
59. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 15, 19, 20 21, 23, 24, and 25 of the ’618 patent in violation of 35
U.S.C. § 271(b). In particular, Plaintiff alleges that the claims of the ‘618 patent
are directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course
of their normal use. Also, Defendant encourages others to directly infringe the
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 14 of 20
COMPLAINT -15-
claims of the ’618 patent by among other things, advertising and promoting the
sale and use of the accused products. Plaintiff also alleges that Defendant has
knowingly induced and continues to induce infringement of the ‘618 patent by
providing operating manuals, guides, instructional and /or informational videos and
other materials designed to instruct others how to use the products in an infringing
manner as more fully described herein.
60. Upon information and belief, Defendant, without authority, has
contributed and continues to contribute to the infringement of claims 1, 3, 4, 15,
19, 20 21, 23, 24, and 25 of the ’618 patent in violation of 35 U.S.C. § 271(c) by
importing into the United States, selling and/or offering to sell within the United
States accused products that it knows (a) infringe the aforementioned claims of the
‘618 patent by embodying a System and Method for Managing Mobile
Communications which includes but the Dropcam and Dropcam Pro wireless
camera systems, and without limitation, Defendant’s server and subscription
services for remote monitoring and communication as material components of the
accused products, (b) which were made and/or especially adapted for use in the
accused products, (c) which the Defendant knows to be especially adapted for use
in infringing the ’618 patent, and (d) are not staple articles of commerce suitable
for substantial non-infringing use with respect to the ’618 patent.
61. On information and belief, Defendant sells, ships or otherwise
delivers the accused products with all the features required to infringe the asserted
claims of the ’618 patent. On information and belief, these products are designed
to practice the infringing features.
62. Plaintiff has been irreparably harmed by these acts of infringement
and has no adequate remedy at law. Upon information and belief, infringement of
the ’618 patent is ongoing and will continue unless Defendant is enjoined from
further infringement by the court.
COUNT SIX
Case 3:14-cv-01579-BEN-DHB Document 1 Filed 07/01/14 Page 15 of 20
COMPLAINT -16-
INFRINGEMENT OF THE ’619 PATENT BY DEFENDANT
63. Plaintiff re-alleges and incorporates by reference each of the
allegations set forth in paragraphs 1 through 17 above.
64. Defendant has knowledge of infringement of the ’619 patent since at
least the filing of this complaint.
65. Upon information and belief, Defendant, without authority, (a) has
knowingly directly infringed and continues to directly infringe the ’619 patent by
making, using, offering to sell, selling within the United States, or importing into
the United States, products that practice claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32
of the ’619 patent in violation of 35 U.S.C. § 271(a); (b) has induced and continues
to induce infringement of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the ’619
patent in violation of 35 U.S.C. § 271(b); and (c) has contributed and continues to
contribute to the infringement of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the
’619 patent in violation of 35 U.S.C. § 271(c).
66. The accused products, alone or in combination with other products,
directly or alternatively under the doctrine of equivalents practice each of the
limitations of independent claims 1, and 19 as well as dependent claims 3, 4, 8, 21,
23, 29, 30, and 32 of the ’619 patent in violation of 35 U.S.C. § 271(a).
67. Defendant’s product literature, materials and instructional videos also
advertise and encourage customers to use the accused product(s) for remote
monitoring, which utilizes the devices described by the ’619 patent and in a
manner Defendant knows infringes the patent.
68. Upon information and belief, Defendant, in the United States, without
authority, has also actively induced and continues to actively induce infringement
of claims 1, 3, 4, 8, 19, 21, 23, 29, 30, and 32 of the ’619 patent in violation of 35
U.S.C. § 271(b) In particular, Plaintiff alleges that the claims of the ‘619 patent are
directly infringed by Defendant in violation of 35 U.S.C. § 271(a) in the course of
their normal use. Also, Defendant encourages others to directly infringe the claims
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sman998
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