Traxxas v. Hobbico - Amended Complaint

February 14, 2018 | Author: Anonymous RDX12QAu | Category: Patent Infringement, Title 35 Of The United States Code, Patent Claim, Patent, Lawsuit
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Traxxas v. Hobbico - Amended Complaint...

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Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 1 of 26 PageID #: 199

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION § § § § § § § § §

TRAXXAS, L.P., Plaintiff, v. HOBBICO, INC., et al., Defendants.

Civil Action No. 2:16-cv-768-JRG-RSP JURY TRIAL DEMANDED

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT

COMES NOW Plaintiff Traxxas, L.P. (“Traxxas”) and files this First Amended Complaint for Patent Infringement against Defendants Hobbico, Inc. (“Hobbico”) and Arrma Durango Ltd. (“Arrma”), alleging as follows: I. NATURE OF THE SUIT 1.

This is a claim for patent infringement arising under the patent laws of the United

States, Title 35 of the United States Code. II. THE PARTIES 2.

Plaintiff Traxxas, L.P. is a Texas limited partnership that maintains its principal

place of business in McKinney, Texas. 3.

Defendant Hobbico, Inc. is an Illinois corporation that does business in Texas,

directly or through intermediaries, and maintains its principal place of business in Champaign, Illinois. 4.

Defendant Arrma Durango Ltd. is a United Kingdom private limited company

and a subsidiary of Defendant Hobbico, Inc. that does business in Texas, directly or through

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intermediaries, and maintains its principal place of business in Moira, Derbyshire, United Kingdom. III. JURISDICTION AND VENUE 5.

This action arises under the patent laws of the United States, Title 35 of the

United States Code. Thus, this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 6.

This Court has specific personal jurisdiction over each Defendant pursuant to due

process and the Texas Long Arm Statute because each Defendant, directly or through intermediaries, has conducted and does conduct substantial business in this forum, such substantial business including but not limited to: (i) at least a portion of the infringements alleged herein; (ii) purposefully and voluntarily placing one or more infringing products or services into the stream of commerce with the expectation that they will be purchased by consumers in this forum; or (iii) regularly doing or soliciting business, engaging in other persistent courses of conduct, or deriving substantial revenue from goods and services provided to individuals in Texas and in this District. 7.

Venue is proper in this Court under 28 U.S.C. §§ 1391(b)-(d) and 1400(b) for the

reasons set forth above. Furthermore, venue is proper because each Defendant, directly or through intermediaries, sells and offers to sell infringing products to persons in this District, as discussed below. Each of Defendants’ infringing acts in this District gives rise to proper venue.

First Amended Complaint for Patent Infringement

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IV. BACKGROUND A.

The Asserted Patents 8.

This cause of action asserts infringement of United States Patent Nos.

7,793,951 B2; 8,982,541 B1; 7,883,099 B2; D567,886 S; 9,061,763 B1; and 9,221,539 B2 (collectively, the “Asserted Patents”). 9.

A true and correct copy of United States Patent No. 7,793,951 B2 (the “’951

Patent”), entitled “Integrated Center Point Steering Mechanism for a Model Vehicle,” is attached hereto as Exhibit A. 10.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’951 Patent, which duly and legally issued on September 14, 2010, with Brent Whitfield Byers and Seralaathan Hariharesan as the named inventors. Traxxas has standing to sue for infringement of the ’951 Patent. 11.

A true and correct copy of United States Patent No. 8,982,541 B1 (the “’541

Patent”), entitled “Protective Enclosure for Model Vehicle,” is attached hereto as Exhibit B. 12.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’541 Patent, which duly and legally issued on March 17, 2015, with Timothy E. Roberts, Jon Kenneth Lampert, and Otto Karl Allmendinger as the named inventors. Traxxas has standing to sue for infringement of the ’541 Patent. 13.

A true and correct copy of United States Patent No. 7,883,099 B2 (the “’099

Patent”), entitled “Vehicle Suspension for a Model Vehicle,” is attached hereto as Exhibit C. 14.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’099 Patent, which duly and legally issued on February 8, 2011, with Brent Whitfield

First Amended Complaint for Patent Infringement

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Byers and Jon Kenneth Lampert as the named inventors. Traxxas has standing to sue for infringement of the ’099 Patent. 15.

A true and correct copy of United States Patent No. D567,886 S (the “’886

Patent”), entitled “Vehicle Mounted Coil Spring and Shock Assembly,” is attached hereto as Exhibit D. 16.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’886 Patent, which duly and legally issued on April 28, 2008, with Jon Kenneth Lampert and Brent Whitfield Byers as the named inventors. Traxxas has standing to sue for infringement of the ’886 Patent. 17.

A true and correct copy of United States Patent No. 9,061,763 B1 (the “’763

Patent”), entitled “Rotorcraft With Integrated Light Pipe Support Members,” is attached hereto as Exhibit E. 18.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’763 Patent, which duly and legally issued on June 23, 2015, with Casey Christen Jens Christensen, Otto Karl Allmendinger, Richard Douglas Hohnholt, Kent Poteet, Scott Rollin Michael Schmitz, and Thomas Blackwell as the named inventors. Traxxas has standing to sue for infringement of the ’763 Patent. 19.

A true and correct copy of United States Patent No. 9,221,539 B2 (the “’539

Patent”), entitled “Rotorcraft With Integrated Light Pipe Support Members,” is attached hereto as Exhibit F. 20.

Traxxas is the current owner by assignment of all rights, title, and interest in and

under the ’539 Patent, which duly and legally issued on December 29, 2015, with Casey Christen Jens Christensen, Otto Karl Allmendinger, Richard Douglas Hohnholt, Kent Poteet, Scott Rollin

First Amended Complaint for Patent Infringement

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Michael Schmitz, and Thomas Blackwell as the named inventors. Traxxas has standing to sue for infringement of the ’539 Patent. B.

Arrma 21.

Arrma, directly or through intermediaries, makes, uses, sells, or offers to sell

within the United States, or imports into the United States, remotely controllable model vehicles (the “Arrma Accused Products”), including but not limited to the NERO 6S BLX Monster Truck. 22.

The Arrma Accused Products are sold or offered for sale in this District via

distributors such as HobbyTown. 23.

By selling and/or offering to sell the Arrma Accused Products, Arrma, directly or

through intermediaries, purposefully and voluntarily places the Arrma Accused Products into the stream of commerce with the expectation that they will be purchased by consumers in this District. C.

Hobbico 24.

Hobbico, directly or through intermediaries (including but not limited to its

subsidiary Arrma), makes, uses, sells, or offers to sell the Arrma Accused Products within the United States, or imports the Arrma Accused Products into the United States. 25.

Hobbico, directly or through intermediaries, makes, uses, sells, or offers to sell

within the United States, or imports into the United States, remotely controllable quadcopters (the “Dromida Accused Products”), including but not limited to the Dromida Vista UAV Drone and the Dromida OMINUS FPV Quad. 26.

The Arrma Accused Products and the Dromida Accused Products are sold or

offered for sale in this District via distributors such as HobbyTown.

First Amended Complaint for Patent Infringement

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27.

By selling and/or offering to sell the Arrma Accused Products and the Dromida

Accused Products in this District, Hobbico, directly or through intermediaries, purposefully and voluntarily places the Arrma Accused Products and the Dromida Accused Products into the stream of commerce with the expectation that they will be purchased by consumers in this District. V. CLAIMS—ARRMA 28.

Based on the above-described products, Traxxas asserts the following causes of

action against Arrma. A.

Infringement of the ’951 Patent 29.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 30.

The Arrma Accused Products are covered by at least claim 27 of the ’951 Patent.

31.

Arrma has directly infringed and continues to infringe at least claim 27 of the

’951 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 32.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively inducing infringement of at least claim 27 of the ’951 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe at least claim 27 of the ’951 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Arrma’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way

First Amended Complaint for Patent Infringement

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by, directly or through intermediaries, supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Arrma provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Arrma knows or should know infringes at least claim 27 of the ’951 Patent. 33.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively contributing to infringement of at least claim 27 of the ’951 Patent in violation of 35 U.S.C. § 271(c). Arrma installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to a steering servo protection system, that are especially made or especially adapted to practice the invention claimed in at least claim 27 of the ’951 Patent. The steering servo protection system within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 27 of the ’951 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 27 of the ’951 Patent. Arrma’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include a steering servo protection system, knowing the steering servo protection system to be especially made or especially adapted for use in an infringement of at least claim 27 of the ’951 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 34.

Arrma’s infringement of the ’951 Patent has been and continues to be willful and

deliberate.

First Amended Complaint for Patent Infringement

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B.

Infringement of the ’541 Patent 35.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 36.

The Arrma Accused Products are covered by at least claim 1 of the ’541 Patent.

37.

Arrma has directly infringed and continues to infringe at least claim 1 of the ’541

Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 38.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively inducing infringement of at least claim 1 of the ’541 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe at least claim 1 of the ’541 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Arrma’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries, supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Arrma provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Arrma knows or should know infringes at least claim 1 of the ’541 Patent. 39.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively contributing to infringement of at least claim 1 of the ’541 Patent in violation of 35 U.S.C. § 271(c). Arrma installs, configures, and sells the

First Amended Complaint for Patent Infringement

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Arrma Accused Products with distinct components, including but not limited to a Radio Box Set (Part No. AR320248), that are especially made or especially adapted to practice the invention claimed in at least claim 1 of the ’541 Patent. The Radio Box Set within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 1 of the ’541 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 1 of the ’541 Patent.

Arrma’s contributions include, without

limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the Radio Box Set, knowing the Radio Box Set to be especially made or especially adapted for use in an infringement of at least claim 1 of the ’541 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 40.

Arrma’s infringement of the ’541 Patent has been and continues to be willful and

deliberate. C.

Infringement of the ’099 Patent 41.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 42.

The Arrma Accused Products are covered by at least claim 1 of the ’099 Patent.

43.

Arrma has directly infringed and continues to infringe at least claim 1 of the ’099

Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 44.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively inducing infringement of at least claim 1 of the

First Amended Complaint for Patent Infringement

Page 9

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’099 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe at least claim 1 of the ’099 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Arrma’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries, supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Arrma provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Arrma knows or should know infringes at least claim 1 of the ’099 Patent. 45.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively contributing to infringement of at least claim 1 of the ’099 Patent in violation of 35 U.S.C. § 271(c). Arrma installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to suspension system components such as shocks, suspension arms, and rockers, that are especially made or especially adapted to practice the invention claimed in at least claim 1 of the ’099 Patent. Each suspension system component within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 1 of the ’099 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 1 of the ’099 Patent. Arrma’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the suspension system components, knowing each suspension system component to be especially made or especially adapted for use in an infringement of at least

First Amended Complaint for Patent Infringement

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claim 1 of the ’099 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 46.

Arrma’s infringement of the ’099 Patent has been and continues to be willful and

deliberate. D.

Infringement of the ’886 Patent 47.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 48.

The ’886 Patent claims an “ornamental design for a vehicle mounted coil spring

and shock assembly, as shown and described,” for example, in Figure 5, reproduced below:

49.

The Arrma Accused Products comprise a vehicle-mounted coil spring and shock

assembly, as shown in the examples below:

First Amended Complaint for Patent Infringement

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50.

The vehicle-mounted coil spring and shock assembly in the Arrma Accused

Products embodies the patented design claimed by the ’886 Patent or a colorable imitation thereof. 51.

In the eye of an ordinary observer, giving such attention as a purchaser usually

gives, the design of the vehicle-mounted coil spring and shock assembly in the Arrma Accused Products is substantially the same as the design claimed by the ’886 Patent. The resemblance is such as to deceive such an observer, inducing him to purchase one supposing it to be the other. 52.

The Arrma Accused Products are covered by the ’886 Patent.

53.

Arrma has directly infringed and continues to infringe the ’886 Patent in violation

of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 54.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively inducing infringement of the ’886 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe the ’886 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Arrma’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries, supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Arrma provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Arrma knows or should know infringes the ’886 Patent.

First Amended Complaint for Patent Infringement

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55.

Further and in the alternative, at least since the filing and service of this

Complaint, Arrma has been and now is actively contributing to infringement of the ’886 Patent in violation of 35 U.S.C. § 271(c). Arrma installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to the vehicle-mounted coil spring and shock assembly, that are especially made or especially adapted to practice the invention claimed in the ’886 Patent. The vehicle-mounted coil spring and shock assembly within the Arrma Accused Products constitutes a material part of the claimed invention recited in the ’886 Patent and not a staple article or commodity of commerce because it is specifically configured according to the ’886 Patent. Arrma’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the vehicle-mounted coil spring and shock assembly, knowing the vehicle-mounted coil spring and shock assembly to be especially made or especially adapted for use in an infringement of the ’886 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 56.

Arrma’s infringement of the ’886 Patent has been and continues to be willful and

deliberate. VI. CLAIMS—HOBBICO 57.

Based on the above-described products, Traxxas asserts the following causes of

action against Hobbico. A.

Infringement of the ’951 Patent 58.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein.

First Amended Complaint for Patent Infringement

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59.

Hobbico has directly infringed and continues to infringe at least claim 27 of the

’951 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries (including but not limited to its subsidiary Arrma) and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 60.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of at least claim 27 of the ’951 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe at least claim 27 of the ’951 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way.

Hobbico’s inducements include, without

limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries (including but not limited to its subsidiary Arrma), supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Hobbico knows or should know infringes at least claim 27 of the ’951 Patent. 61.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of at least claim 27 of the ’951 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to a steering servo protection system, that are especially made or especially adapted to practice the invention

First Amended Complaint for Patent Infringement

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claimed in at least claim 27 of the ’951 Patent. The steering servo protection system within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 27 of the ’951 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 27 of the ’951 Patent.

Hobbico’s

contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include a steering servo protection system, knowing the steering servo protection system to be especially made or especially adapted for use in an infringement of at least claim 27 of the ’951 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 62.

Hobbico’s infringement of the ’951 Patent has been and continues to be willful

and deliberate. B.

Infringement of the ’541 Patent 63.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 64.

Hobbico has directly infringed and continues to infringe at least claim 1 of the

’541 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries (including but not limited to its subsidiary Arrma) and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 65.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of at least claim 1 of the ’541 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly

First Amended Complaint for Patent Infringement

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infringe at least claim 1 of the ’541 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Hobbico’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries (including but not limited to its subsidiary Arrma), supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Hobbico knows or should know infringes at least claim 1 of the ’541 Patent. 66.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of at least claim 1 of the ’541 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to a Radio Box Set (Part No. AR320248), that are especially made or especially adapted to practice the invention claimed in at least claim 1 of the ’541 Patent. The Radio Box Set within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 1 of the ’541 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 1 of the ’541 Patent. Hobbico’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the Radio Box Set, knowing the Radio Box Set to be especially made or especially adapted for use in an infringement of at least

First Amended Complaint for Patent Infringement

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claim 1 of the ’541 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 67.

Hobbico’s infringement of the ’541 Patent has been and continues to be willful

and deliberate. C.

Infringement of the ’099 Patent 68.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 69.

Hobbico has directly infringed and continues to infringe at least claim 1 of the

’099 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries (including but not limited to its subsidiary Arrma) and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 70.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of at least claim 1 of the ’099 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe at least claim 1 of the ’099 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Hobbico’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries (including but not limited to its subsidiary Arrma), supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary,

First Amended Complaint for Patent Infringement

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and intended way, which Hobbico knows or should know infringes at least claim 1 of the ’099 Patent. 71.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of at least claim 1 of the ’099 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to suspension system components such as shocks, suspension arms, and rockers, that are especially made or especially adapted to practice the invention claimed in at least claim 1 of the ’099 Patent. Each suspension system component within the Arrma Accused Products constitutes a material part of the claimed invention recited in at least claim 1 of the ’099 Patent and not a staple article or commodity of commerce because it is specifically configured according to at least claim 1 of the ’099 Patent. Hobbico’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the suspension system components, knowing each suspension system component to be especially made or especially adapted for use in an infringement of at least claim 1 of the ’099 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 72.

Hobbico’s infringement of the ’099 Patent has been and continues to be willful

and deliberate. D.

Infringement of the ’886 Patent 73.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein.

First Amended Complaint for Patent Infringement

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74.

Hobbico has directly infringed and continues to infringe the ’886 Patent in

violation of 35 U.S.C. § 271(a) by, directly or through intermediaries (including but not limited to its subsidiary Arrma) and without Traxxas’ authority, making, using, selling, or offering to sell the Arrma Accused Products in the United States, or importing the Arrma Accused Products into the United States. 75.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of the ’886 Patent in violation of 35 U.S.C. § 271(b). Users of the Arrma Accused Products directly infringe the ’886 Patent when they use the Arrma Accused Products in the ordinary, customary, and intended way. Hobbico’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Arrma Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries (including but not limited to its subsidiary Arrma), supplying the Arrma Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Arrma Accused Products) how to use the Arrma Accused Products in the ordinary, customary, and intended way, which Hobbico knows or should know infringes the ’886 Patent. 76.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of the ’886 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Arrma Accused Products with distinct components, including but not limited to the vehicle-mounted coil spring and shock assembly, that are especially made or especially adapted to practice the invention claimed in the ’886 Patent. The vehicle-mounted coil spring and shock assembly within the

First Amended Complaint for Patent Infringement

Page 19

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 20 of 26 PageID #: 218

Arrma Accused Products constitutes a material part of the claimed invention recited in the ’886 Patent and not a staple article or commodity of commerce because it is specifically configured according to the ’886 Patent. Hobbico’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Arrma Accused Products, which include the vehicle-mounted coil spring and shock assembly, knowing the vehicle-mounted coil spring and shock assembly to be especially made or especially adapted for use in an infringement of the ’886 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 77.

Hobbico’s infringement of the ’886 Patent has been and continues to be willful

and deliberate. E.

Infringement of the ’763 Patent 78.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 79.

The Dromida Accused Products are covered by at least claim 1 of the ’763 Patent.

80.

Hobbico has directly infringed and continues to infringe at least claim 1 of the

’763 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Dromida Accused Products in the United States, or importing the Dromida Accused Products into the United States. 81.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of at least claim 1 of the ’763 Patent in violation of 35 U.S.C. § 271(b). Users of the Dromida Accused Products directly infringe at least claim 1 of the ’763 Patent when they use the Dromida Accused Products in the ordinary, customary, and intended way. Hobbico’s inducements include, without limitation and

First Amended Complaint for Patent Infringement

Page 20

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 21 of 26 PageID #: 219

with specific intent to encourage the infringement, knowingly inducing consumers to use the Dromida Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries, supplying the Dromida Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Dromida Accused Products) how to use the Dromida Accused Products in the ordinary, customary, and intended way, which Hobbico knows or should know infringes at least claim 1 of the ’763 Patent. 82.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of at least claim 1 of the ’763 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Dromida Accused Products with distinct components, including but not limited to LED Arm Covers (Part Nos. DIDE1183, DIDE1184, DIDE1185, and DIDE1186) and E-Boards (Part Nos. DIDM1110, DIDM1111, DIDM1112, DIDM1113, DIDM1214, and DIDM1215), that are especially made or especially adapted to practice the invention claimed in at least claim 1 of the ’763 Patent. The LED Arm Covers and E-Boards within the Dromida Accused Products each constitute a material part of the claimed invention recited in at least claim 1 of the ’763 Patent and not a staple article or commodity of commerce because they are specifically configured according to at least claim 1 of the ’763 Patent. Hobbico’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Dromida Accused Products, which include LED Arm Covers and EBoards, knowing the LED Arm Covers and E-Boards to be especially made or especially adapted for use in an infringement of at least claim 1 of the ’763 Patent, and not staple articles or commodities of commerce suitable for substantial noninfringing use.

First Amended Complaint for Patent Infringement

Page 21

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 22 of 26 PageID #: 220

83.

Hobbico’s infringement of the ’763 Patent has been and continues to be willful

and deliberate. F.

Infringement of the ’539 Patent 84.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 85.

The Dromida Accused Products are covered by at least claim 27 of the ’539

86.

Hobbico has directly infringed and continues to infringe at least claim 27 of the

Patent.

’539 Patent in violation of 35 U.S.C. § 271(a) by, directly or through intermediaries and without Traxxas’ authority, making, using, selling, or offering to sell the Dromida Accused Products in the United States, or importing the Dromida Accused Products into the United States. 87.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively inducing infringement of at least claim 27 of the ’539 Patent in violation of 35 U.S.C. § 271(b). Users of the Dromida Accused Products directly infringe at least claim 27 of the ’539 Patent when they use the Dromida Accused Products in the ordinary, customary, and intended way. Hobbico’s inducements include, without limitation and with specific intent to encourage the infringement, knowingly inducing consumers to use the Dromida Accused Products within the United States in the ordinary, customary, and intended way by, directly or through intermediaries, supplying the Dromida Accused Products to consumers within the United States and instructing such consumers (for example in instruction manuals that Hobbico provides online or with the Dromida Accused Products) how to use the Dromida Accused Products in the ordinary, customary, and intended way, which Hobbico knows or should know infringes at least claim 27 of the ’539 Patent.

First Amended Complaint for Patent Infringement

Page 22

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 23 of 26 PageID #: 221

88.

Further and in the alternative, at least since the filing and service of this

Complaint, Hobbico has been and now is actively contributing to infringement of at least claim 27 of the ’539 Patent in violation of 35 U.S.C. § 271(c). Hobbico installs, configures, and sells the Dromida Accused Products with distinct components, including but not limited to LED Arm Covers (Part Nos. DIDE1183, DIDE1184, DIDE1185, and DIDE1186) and E-Boards (Part Nos. DIDM1110, DIDM1111, DIDM1112, DIDM1113, DIDM1214, and DIDM1215), that are especially made or especially adapted to practice the invention claimed in at least claim 27 of the ’539 Patent. The LED Arm Covers and E-Boards within the Dromida Accused Products each constitute a material part of the claimed invention recited in at least claim 27 of the ’539 Patent and not a staple article or commodity of commerce because they are specifically configured according to at least claim 27 of the ’539 Patent. Hobbico’s contributions include, without limitation, making, offering to sell, and/or selling within the United States, and/or importing into the United States, the Dromida Accused Products, which include LED Arm Covers and EBoards, knowing the LED Arm Covers and E-Boards to be especially made or especially adapted for use in an infringement of at least claim 27 of the ’539 Patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 89.

Hobbico’s infringement of the ’539 Patent has been and continues to be willful

and deliberate. VII. VICARIOUS LIABILITY 90.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 91.

In addition to liability for its own independent conduct, each Defendant is also

liable for the conduct of its subsidiaries, affiliates, and related entities under the doctrines of alter

First Amended Complaint for Patent Infringement

Page 23

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 24 of 26 PageID #: 222

ego and single business enterprise, and under applicable state and federal statutes and regulations. VIII. NOTICE AND MARKING 92.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 93.

At all times, each and every patentee of the Asserted Patents, and each and every

person making, offering for sale, or selling within the United States, or importing into the United States, any patented article for or under any of them, has complied with the marking requirements set forth in 35 U.S.C. § 287. 94.

At least by filing and serving this First Amended Complaint for Patent

Infringement, Traxxas has given each Defendant written notice of its infringement. IX. DAMAGES 95.

The allegations of each foregoing paragraph are incorporated by reference as if

fully set forth herein. 96.

For the above-described infringement, Traxxas has been injured and seeks

damages to adequately compensate it for each Defendant’s infringement of the Asserted Patents. Such damages, to be proved at trial, should be no less than the amount of a reasonable royalty under 35 U.S.C. § 284, together with Traxxas’ costs and expenses, pre-judgment and postjudgment interest, and supplemental damages for any continuing post-verdict or post-judgment infringement, with an accounting as needed. 97.

Each Defendant’s infringement of the Asserted Patents has been and continues to

be willful, such that Traxxas seeks treble damages under 35 U.S.C. § 284.

First Amended Complaint for Patent Infringement

Page 24

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 25 of 26 PageID #: 223

98.

Each Defendant’s willful infringement of the Asserted Patents renders this case

exceptional under 35 U.S.C. § 285, such that Traxxas seeks all reasonable attorneys’ fees and costs incurred in this litigation pursuant to 35 U.S.C. § 284, together with pre-judgment and postjudgment interest thereon. X. PRAYER FOR RELIEF Traxxas respectfully requests the following relief: a.

A judgment in favor of Traxxas that each Defendant has infringed each of the

Asserted Patents, whether literally or under the doctrine of equivalents, as described herein; b.

A permanent injunction enjoining each Defendant, its officers, directors, agents,

subsidiaries, employees, successors, and assigns, and all persons acting in privity, concert, or participation with it, from making, using, selling, or offering for sale in the United States, or importing into the United States, any and all products and services embodying the inventions claimed in the Asserted Patents; c.

A judgment and order requiring each Defendant to pay Traxxas its damages,

costs, expenses, and pre-judgment and post-judgment interest for the Defendant’s infringement of the Asserted Patents as provided under 35 U.S.C. § 284, including supplemental damages for any continuing post-verdict or post-judgment infringement with an accounting as needed; d.

A judgment and order requiring each Defendant to pay Traxxas enhanced

damages for willful infringement as provided under 35 U.S.C. § 284; e.

A judgment and order finding this case exceptional and requiring each Defendant

to pay Traxxas its reasonable attorneys’ fees and costs incurred in this litigation pursuant to 35 U.S.C. § 284, together with pre-judgment and post-judgment interest thereon; and f.

Such other and further relief as the Court deems just and proper.

First Amended Complaint for Patent Infringement

Page 25

Case 2:16-cv-00768-JRG-RSP Document 8 Filed 08/02/16 Page 26 of 26 PageID #: 224

X. JURY DEMAND Pursuant to Federal Rule of Civil Procedure 38(b), Traxxas requests a jury trial of all issues triable of right by a jury.

Dated: August 2, 2016

Respectfully Submitted, By: /s/ William E. Davis, III William E. Davis, III Texas State Bar No. 24047416 [email protected] Debra Coleman (Of Counsel) Texas State Bar No. 24059595 [email protected] The Davis Firm, PC 213 N. Fredonia Street, Suite 230 Longview, Texas 75601 Telephone: (903) 230-9090 Facsimile: (903) 230-9661 Counsel for Plaintiff Traxxas, L.P. CERTIFICATE OF SERVICE

The undersigned certifies that the foregoing document and all attachments thereto are being filed electronically in compliance with Local Rule CV-5(a). As such, this document is being served this August 2, 2016, on all counsel of record, each of whom is deemed to have consented to electronic service. L.R. CV-5(a)(3)(A). /s/ William E. Davis, III William E. Davis, III

First Amended Complaint for Patent Infringement

Page 26

Case 2:16-cv-00768-JRG-RSP Document 8-1 Filed 08/02/16 Page 1 of 96 PageID #: 225

EXHIBIT A U.S. Patent No. 7,793,951 B2

Case 2:16-cv-00768-JRG-RSP Document 8-1 Filed 08/02/16 Page 2 of 96 PageID #: 226 111111 1111111111111111111111111111111111111111111111111111111111111 US007793951B2

c12)

United States Patent

(10)

Byers et al.

(45)

(54)

INTEGRATED CENTER POINT STEERING MECHANISM FOR A MODEL VEHICLE

(75)

Inventors: Brent Whitfield Byers, Plano, TX (US); Seralaathan Hariharesan, Flower Mound, TX (US)

(73)

Assignee: Traxxas LP, Plano, TX (US)

( *)

Notice:

(21)

Appl. No.: 11/348,769

(22)

Filed:

Feb.6,2006

Dec. 14,2006

Related U.S. Application Data

(60) (51) (52) (58)

Continuation-in-part of application No. 11/102,008, filed on Apr. 7, 2005, now abandoned, and a continuation-in-part of application No. 29/227,305, filed on Apr. 7, 2005, now Pat. No. Des. 567,886. Provisional application No. 60/669,664, filed on Apr. 7, 2005. Int. Cl. B62D 7116 (2006.01) U.S. Cl. .................................. 280/93.502; 280/774 Field of Classification Search ............ 280/93.502, 280/93.513, 93.514, 774 See application file for complete search history.

(56)

A A A A A A A A A A A A A A A A

* * * * * * * * * * * * * * * *

10/1922 12/1926 4/1955 3/1961 4/1966 8/1970 111971 6/1971 111973 9/1980 12/1984 5/1985 111990 10/1990 10/1993 8/1994

US 7, 793,951 B2 Sep.14,2010 Dutton ....................... 280/775 Nicholson .................... 60/572 Umstott ...................... 280/774 Merritt ....................... 180/409 Lahr .......................... 180/443 Knapp eta!. ................ 180/243 Mitchell eta!. ............. 180/411 Gamaunt .................... 180/431 Hickey ....................... 180/249 Andersson ........... 280/124.146 Ruggles ................... 280/5.521 Musgrove .............. 280/93.513 Gleasman et al ............... 475/7 Young ........................ 56/10.8 Watanabe eta!. ........... 180/404 Miles ......................... 446/456

(Continued)

Prior Publication Data

US 2006/0278464 AI

(63)

1,432,237 1,610,580 2,707,109 2,974,974 3,246,719 3,522,861 3,556,241 3,587,767 3,709,314 4,225,148 4,487,429 4,518,170 4,895,052 4,964,265 5,249,638 5,338,247

Subject to any disclaimer, the term of this patent is extended or adjusted under 35 U.S.C. 154(b) by 1025 days.

(65)

Patent No.: Date of Patent:

References Cited

OTHER PUBLICATIONS Horizon Hobby; "Team Losi LST Super Truck-Operations Guide"; pp. 1-23; Horizon Hobby, Inc., Champaigne, Illinois; (admitted prior art).

(Continued) Primary Examiner-Paul N Dickson Assistant Examiner-Timothy D Wilhelm (74) Attorney, Agent, or Firm-Carr LLP

(57)

ABSTRACT

A steering mechanism for a model vehicle is provided, having one or more steering actuators, a steering control arm pivotally mounted for rotation relative to a model vehicle chassis, the steering control arm being coupled directly to at least two tie rods, each tie rod controlling the steering of at least one wheel of a vehicle, and each of the one or more steering actuators coupled to the steering control arm to rotate the control arm relative to the vehicle chassis.

U.S. PATENT DOCUMENTS 634,597 A

*

10/1899 Warren ....................... 180/263

43 Claims, 75 Drawing Sheets

Case 2:16-cv-00768-JRG-RSP Document 8-1 Filed 08/02/16 Page 3 of 96 PageID #: 227 US 7, 793,951 B2 Page 2 U.S. PATENT DOCUMENTS 5,653,304 5,775,972 5,785,576 5,816,352 6,113,459 6,202,781 6,793,555 6,796,567 7,000,931 7,029,016 7,077,234 7,350,792 2006/0055139 2006/0232035

A * 8/1997 Renfroe ...................... 180/402 A * 7I 1998 Siu ............................ 446/468 A * 7/1998 Belton ........................ 446/456 A * 10/1998 Hacker ....................... 180/167 A * 9/2000 Nanunoto ................... 446/454 B1 * 3/2001 Ima ............................ 180/252 B1 * 9/2004 Tilbor eta!. ................ 446/456 B2 * 9/2004 Shimizu et al ......... 280/93.502 B1 * 2/2006 Chevalier . ... .. ... ... ... 280/93.502 B2 * 4/2006 Lin ... ... ... ... .. ... ... ... 280/93.502 B2 * 7/2006 Klais eta!. .................. 180/428 B1 * 4/2008 Garman ................... 280/93.51 A1 * 3/2006 Furumi et al ........... 280/93.513 A1 * 10/2006 Lambert .. ... .. ... ... ... 280/93.502

2008/0067768 A1 *

3/2008 Yang ..................... 280/93.502

OTHER PUBLICATIONS Kyosho, "V-ONER New Generation Touring Car-Instruction Manual"; 2000, Kyosho Corp. of America, Lake Forest, California. Kyosho, "Inferno MP7.5-Exploded View"; Kyosho Corp. of America, Lake Forest, California (admitted prior art). Pro-Line, "Servo Saver"; Pro-Line, Beaumont, California; 1 photograph (admitted prior art). Traxxas; "T-MAXX, Front Assembly" exploded view; Traxxas LP, Plano, Texas; (admitted prior art). Xray, "T1R Raycer-Instruction Manual"; XRay Model Racing Cars, Trencin, Slovak Republic, Europe (admitted prior art).

* cited by examiner

Case 2:16-cv-00768-JRG-RSP Document 8-1 Filed 08/02/16 Page 4 of 96 PageID #: 228

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Sep.14,2010

Sheet 1 of75

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