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

com 4 LINER LLP 1100 Glendon Avenue, 14th Floor 5 Los Angeles, California 90024.3503 Telephone: (310) 500-3500 6 Facsimile: (310) 500-3501 7 Attorneys for Plaintiff SIGNAL IP, INC. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 SIGNAL IP, INC., a California 12 corporation, 13 14 vs. JURY TRIAL DEMANDED Plaintiff, Case No. 14-cv-3107 COMPLAINT FOR PATENT INFRINGEMENT

15 VOLVO CARS OF NORTH AMERICA, LLC, a Delaware limited 16 liability company, 17 18 19 Defendant.

Plaintiff Signal IP, Inc. (Signal IP or Plaintiff) brings this Complaint

20 against Defendant Volvo Cars of North America, LLC (Volvo or Defendant), 21 alleging as follows: 22 23 1. PARTIES Plaintiff Signal IP is a California corporation with its principal place of

24 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. 25 2. On information and belief, Defendant Volvo Cars of North America, 26 LLC is a Delaware limited liability company with its principal place of business at 1 27 Volvo Drive, Rockleigh, New Jersey 07647. 28
Case No. 14-cv-3107 COMPLAINT FOR PATENT INFRINGEMENT

1 2 3.

JURISDICTION, VENUE AND JOINDER This action arises under the patent laws of the United States, Title 35 of

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

22 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. It is the 23 owner of the entire right, title and interest in and to U.S. Patent Nos. 5,714,927; 24 6,434,486; 6,775,601; 6,012,007; and 5,463,374 (the Patents-in-Suit). 25 7. On information and belief, Defendant is a direct or indirect subsidiary 26 of global car manufacturer and distributor Zhejiang Geely Holding Group Co., Ltd. 27 (Geely), which is headquartered in Hangzhou, China. Geely manufactures and 28 distributes cars in the United States under the Volvo brand name. 2
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

1 2 3 8. 4 forth in full herein. 5 9.

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

Signal IP is the owner of the entire right, title, and interest in and to

6 U.S. Patent No. 5,714,927 (the 927 Patent), entitled Method of Improving Zone of 7 Coverage Response of Automotive Radar. The 927 Patent was duly and legally 8 issued by the U.S. Patent and Trademark Office on February 3, 1998. A true and 9 correct copy of the 927 Patent is attached as Exhibit A. 10 10. Defendant has directly infringed and continues to infringe, literally 11 and/or under the doctrine of equivalents, the 927 Patent by making, using, offering 12 for sale, and/or selling in the United States certain methods or systems disclosed and 13 claimed in the 927 Patent, including but not limited to the Blind Spot Information 14 System (BLIS), used in products including but not limited to the Volvo C30, S40, 15 C70, S60, S80, V60, XC60, XC70, XC90, V50, and V70. 16 11. Defendant has contributorily infringed and is currently contributorily 17 infringing the 927 Patent by making, using, offering for sale, and/or selling in the 18 United States certain methods or systems disclosed and claimed in the 927 Patent, 19 including but not limited to the Blind Spot Information System (BLIS), used in 20 products including but not limited to the Volvo C30, S40, C70, S60, S80, V60, 21 XC60, XC70, XC90, V50, and V70. 22 12. Defendant has actively induced and is actively inducing the 23 infringement of the 927 Patent by making, using, offering for sale, and/or selling in 24 the United States certain methods or systems disclosed and claimed in the 927 25 Patent, including but not limited to the Blind Spot Information System (BLIS), used 26 in products including but not limited to the Volvo C30, S40, C70, S60, S80, V60, 27 XC60, XC70, XC90, V50, and V70. 28 13. Defendants infringement of the 927 Patent has been and continues to 3
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

1 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 2 14. Unless enjoined by this Court, Defendant will continue to infringe the 3 927 Patent. 4 15. As a direct and proximate result of the Defendants conduct, Plaintiff 5 has suffered, and will continue to suffer, irreparable injury for which it has no 6 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 7 issues, will continue to be damaged in an amount yet to be determined. 8 9 10 16. 11 forth in full herein. 12 17. Signal IP is the owner of the entire right, title, and interest in and to 13 U.S. Patent No. 6,434,486 (the 486 Patent), entitled Technique for Limiting the 14 Range of an Object Sensing System in a Vehicle. The 486 Patent duly and legally 15 issued by the U.S. Patent and Trademark Office on August 13, 2002. A true and 16 correct copy of the 486 Patent is attached as Exhibit B. 17 18. Defendant has directly infringed and continues to infringe, literally 18 and/or under the doctrine of equivalents, the 486 Patent by making, using, offering 19 for sale, and/or selling in the United States certain methods or systems disclosed and 20 claimed in the 486 Patent, including but not limited to collision prevention or 21 avoidance systems, including but not limited to the Adaptive Cruise Control system, 22 used in products including but not limited to the Volvo S60, S80, V60, XC60, and 23 XC70. 24 19. Defendant has contributorily infringed and is currently contributorily 25 infringing the 486 Patent by making, using, offering for sale, and/or selling in the 26 United States certain methods or systems disclosed and claimed in the 486 Patent, 27 including but not limited to collision prevention or avoidance systems, including but 28 not limited to the Adaptive Cruise Control system, used in products including but 4
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

SECOND CLAIM FOR RELIEF (Infringement of the 486 Patent) Plaintiff incorporates paragraphs 1 through 15 of this complaint as if set

1 not limited to the Volvo S60, S80, V60, XC60, and XC70. 2 20. Defendant has actively induced and is actively inducing the 3 infringement of the 486 Patent by making, using, offering for sale, and/or selling in 4 the United States certain methods or systems disclosed and claimed in the 486 5 Patent, including but not limited to collision prevention or avoidance systems, 6 including but not limited to the Adaptive Cruise Control system, used in products 7 including but not limited to the Volvo S60, S80, V60, XC60, and XC70. 8 21. Defendants infringement of the 486 Patent has been and continues to 9 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 10 22. Unless enjoined by this Court, Defendant will continue to infringe the

11 486 Patent. 12 23. As a direct and proximate result of the Defendants conduct, Plaintiff 13 has suffered, and will continue to suffer, irreparable injury for which it has no 14 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 15 issues, will continue to be damaged in an amount yet to be determined. 16 17 18 24. 19 forth in full herein. 20 25. Signal IP is the owner of the entire right, title, and interest in and to 21 U.S. Patent No. 6,775,601 (the 601 Patent), entitled Method and Control System 22 for Controlling Propulsion in a Hybrid Vehicle. The 601 Patent was duly and 23 legally issued by the U.S. Patent and Trademark Office on August 10, 2004. A true 24 and correct copy of the 601 Patent is attached as Exhibit C. 25 26. Defendant has directly infringed and continues to infringe, literally 26 and/or under the doctrine of equivalents, the 601 Patent by making, using, offering 27 for sale, and/or selling in the United States certain methods or systems for hybrid 28 vehicles disclosed and claimed in the 601 Patent, including but not limited to the 5
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

THIRD CLAIM FOR RELIEF (Infringement of the 601 Patent) Plaintiff incorporates paragraphs 1 through 23 of this complaint as if set

1 Volvo V60 Hybrid. 2 27. Defendant has contributorily infringed and is currently contributorily

3 infringing the 601 Patent by making, using, offering for sale, and/or selling in the 4 United States certain methods or systems disclosed and claimed in the 601 Patent, 5 including but not limited to the Volvo V60 Hybrid. 6 28. Defendant has actively induced and is actively inducing the

7 infringement of the 601 Patent by making, using, offering for sale, and/or selling in 8 the United States certain methods or systems disclosed and claimed in the 601 9 Patent, including but not limited to the Volvo V60 Hybrid. 10 29. 30. Defendants infringement of the 601 Patent has been and continues to Unless enjoined by this Court, Defendant will continue to infringe on 11 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 12

13 the 601 Patent. 14 31. As a direct and proximate result of the Defendants conduct, Plaintiff 15 has suffered, and will continue to suffer, irreparable injury for which it has no 16 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 17 issues, will continue to be damaged in an amount yet to be determined. 18 19 20 32. 21 forth in full herein. 22 33. Signal IP is the owner of the entire right, title, and interest in and to 23 U.S. Patent No. 6,012,007 (the 007 Patent), entitled Occupant Detection Method 24 and Apparatus for Air Bag System. The 007 Patent was duly and legally issued by 25 the U.S. Patent and Trademark Office on January 4, 2000. A true and correct copy 26 of the 007 Patent is attached as Exhibit D. 27 34. Defendant has directly infringed and continues to infringe, literally 28 and/or under the doctrine of equivalents, the 007 Patent by making, using, offering 6
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

FOURTH CLAIM FOR RELIEF (Infringement of the 007 Patent) Plaintiff incorporates paragraphs 1 through 31 of this complaint as if set

1 for sale, and/or selling in the United States certain methods or systems disclosed and 2 claimed in the 007 Patent, including but not limited to the Occupant Weight Sensor, 3 used in products including but not limited to the Volvo C30, S40, C70, S60, S80, 4 V60, XC60, XC70, XC90, V50, and V70. 5 35. Defendant has contributorily infringed and is currently contributorily

6 infringing the 007 Patent by making, using, offering for sale, and/or selling in the 7 United States certain methods or systems disclosed and claimed in the 007 Patent, 8 including but not limited to the Occupant Weight Sensor, used in products including 9 but not limited to the Volvo C30, S40, C70, S60, S80, V60, XC60, XC70, XC90, 10 V50, and V70. 11 36. Defendant has actively induced and is actively inducing the 12 infringement of the 007 Patent by making, using, offering for sale, and/or selling in 13 the United States certain methods or systems disclosed and claimed in the 007 14 Patent, including but not limited to the Occupant Weight Sensor, used in products 15 including but not limited to the Volvo C30, S40, C70, S60, S80, V60, XC60, XC70, 16 XC90, V50, and V70. 17 37. 38. Defendants infringement of the 007 Patent has been and continues to Unless enjoined by this Court, Defendant will continue to infringe on 18 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 19

20 the 007 Patent. 21 39. As a direct and proximate result of the Defendants conduct, Plaintiff 22 has suffered, and will continue to suffer, irreparable injury for which it has no 23 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 24 issues, will continue to be damaged in an amount yet to be determined. 25 26 27 40. 28 forth in full herein. 7
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

FIFTH CLAIM FOR RELIEF (Infringement of the 374 Patent) Plaintiff incorporates paragraphs 1 through 39 of this complaint as if set

41.

Signal IP is the owner of the entire right, title, and interest in and to

2 U.S. Patent No. 5,463,374 (the 374 Patent), entitled Method and Apparatus for 3 Tire Pressure Monitoring and for Shared Keyless Entry Control. The 374 Patent 4 was duly and legally issued by the U.S. Patent and Trademark Office on October 31, 5 1995. A true and correct copy of the 374 Patent is attached as Exhibit E. 6 42. Defendant has directly infringed, literally and/or under the doctrine of 7 equivalents, the 374 Patent by making, using, offering for sale, and/or selling in the 8 United States certain methods or systems for vehicles disclosed and claimed in the 9 374 Patent, including but not limited to the integrated Remote Keyless Entry (RKE) 10 and Tire Pressure Monitor Systems (TPMS), used in products including but not 11 limited to the Volvo C30, S60, S80, V60, XC60, XC70, XC90, and V50. 12 43. Defendant has contributorily infringed the 374 Patent by making, 13 using, offering for sale, and/or selling in the United States certain methods or 14 systems disclosed and claimed in the 374 Patent, including but not limited to the 15 integrated Remote Keyless Entry (RKE) and Tire Pressure Monitor Systems 16 (TPMS), used in products including but not limited to the Volvo C30, S60, S80, 17 V60, XC60, XC70, XC90, and V50. 18 44. Defendant has actively induced infringement of the 374 Patent by 19 making, using, offering for sale, and/or selling in the United States certain methods 20 or systems disclosed and claimed in the 374 Patent, including but not limited to the 21 integrated Remote Keyless Entry (RKE) and Tire Pressure Monitor Systems 22 (TPMS), used in products including but not limited to the Volvo C30, S60, S80, 23 V60, XC60, XC70, XC90, and V50. 24 45. As a direct and proximate result of Defendants conduct, Plaintiff has 25 suffered irreparable injury for which it has no adequate remedy at law. Plaintiff also 26 has been damaged in an amount yet to be determined. 27 28 PRAYER FOR RELIEF Wherefore, Signal IP respectfully requests that the Court enter judgment 8
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

1 against Defendant as follows: 2 3 4 5 6 1. 2. 3. 4. 5. That Defendant has directly infringed the Patents-in-Suit; That Defendant has contributorily infringed the Patents-in-Suit; That Defendant has induced the infringement of the Patents-in-Suit; That Defendants infringement be adjudged willful and deliberate; That Defendant and its affiliates, subsidiaries, officers, directors,

7 employees, agents, representatives, successors, assigns, and all those acting in 8 concert, participation, or privity with them or on their behalf, including customers, 9 be enjoined from infringing, inducing others to infringe or contributing to the 10 infringement of the Patents-in-Suit; 11 6. For damages, according to proof, for Defendants infringement, 12 together with pre-judgment and post-judgment interest, as allowed by law and that 13 such damages be trebled as provided by 35 U.S.C. 284; 14 16 and 17 18 19 Dated: April 23, 2014 20 21 22 23 24 25 26 27 28 9
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

7.

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

15 U.S.C. 285 and an award of attorneys fees and costs to Signal IP is warranted; 8. For such other and further relief as the Court may deem just and proper. LINER LLP

By:

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

1 2

JURY DEMAND Pursuant to Federal Rules of Civil Procedure Rule 38(b), Plaintiff Signal

3 IP, Inc. respectfully demands a jury trial on any and all issues triable as of right 4 by a jury in this action. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3107

Dated: April 23, 2014

LINER LLP

By:

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