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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION OGMA, LLC, CASE NO.: Plaintiff, v. 3M COMPANY; ASUSTEK COMPUTER, INC.; ASUS COMPUTER INTERNATIONAL; CANON INC.; CANON U.S.A., INC.; CASIO COMPUTER CO., LTD.; CASIO AMERICA, INC.; CHRISTIE DIGITAL SYSTEMS USA, INC.; COBY ELECTRONICS CORP.; DUKANE CORPORATION; EIKI INTERNATIONAL, INC.; SEIKO EPSON CORPORATION; EPSON AMERICA, INC.; HAIER GROUP COMPANY; HAIER AMERICA TRADING, L.L.C.; INFOCUS CORPORATION; LENOVO GROUP, LTD.; LENOVO HOLDING COMPANY, INC.; LENOVO (UNITED STATES), INC.; LG ELECTRONICS, INC.; LG ELECTRONICS U.S.A., INC.; MICROSTAR INTERNATIONAL CO., LTD.; MSI COMPUTER CORP.; MITSUBISHI ELECTRIC CORPORATION; MITSUBISHI ELECTRIC & ELECTRONICS USA, INC.; NEC CORPORATION; NEC CORPORATION OF AMERICA; OPTOMA CORPORATION; OPTOMA TECHNOLOGY, INC.; PANASONIC CORPORATION; PANASONIC CORPORATION OF NORTH AMERICA; PLANAR SYSTEMS, INC.; RUNCO INTERNATIONAL, L.L.C.; SANYO ELECTRIC CO., LTD.; SANYO NORTH AMERICA CORPORATION; SHARP CORPORATION; SHARP ELECTRONICS CORPORATION; SONY CORPORATION; SONY ELECTRONICS, INC.; SUPERSONIC, INC.; SYSTEMAX, INC.; TOSHIBA CORPORATION; TOSHIBA AMERICA INFORMATION SYSTEMS, INC.; VIEWSONIC CORPORATION; and VIVITEK CORPORATION, Defendants. COMPLAINT FOR PATENT INFRINGEMENT DEMAND FOR JURY TRIAL

Plaintiff Ogma, LLC (Ogma) hereby alleges for its Complaint against defendants 3M Company; ASUSTeK Computer, Inc.; ASUS Computer International; Canon, Inc.; Canon
COMPLAINT FOR PATENT INFRINGEMENT

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U.S.A., Inc.; Casio Computer Co., Ltd.; Casio America, Inc.; Christie Digital Systems USA, Inc.; Coby Electronics Corp.; Dukane Corporation; Eiki International, Inc.; Seiko Epson Corporation; Epson America, Inc.; Haier Group Company; Haier America Trading, L.L.C.; InFocus Corporation; Lenovo Group, Ltd.; Lenovo Holding Company, Inc.; Lenovo (United States), Inc.; LG Electronics, Inc.; LG Electronics U.S.A., Inc.; Micro-Star International Co., Ltd.; MSI Computer Corp.; Mitsubishi Electric Corporation; Mitsubishi Electric & Electronics USA, Inc.; NEC Corporation; NEC Corporation of America; Optoma Corporation; Optoma Technology, Inc.; Panasonic Corporation; Panasonic Corporation of North America; Planar Systems, Inc.; Runco International, L.L.C.; Sanyo Electric Co., Ltd.; Sanyo North America Corporation; Sharp Corporation; Sharp Electronics Corporation; Sony Corporation; Sony Electronics, Inc.; Supersonic, Inc.; Systemax, Inc.; Toshiba Corporation; Toshiba America Information Systems, Inc.; ViewSonic Corporation; and Vivitek Corporation (collectively the Defendants) on personal knowledge as to its own actions and on information and belief as to the actions of others, as follows: THE PARTIES 1. Plaintiff Ogma is a Texas limited liability company with a place of business at

3301 W. Marshall Ave., Suite 303, Longview, TX 75604. 2. On information and belief, Defendant 3M Company (3M) is a Delaware

corporation with a principal place of business at 3M Center, St. Paul, MN 55144. 3. On information and belief, Defendant ASUSTeK Computer Inc. (ASUS) is a

Taiwanese corporation with a principal place of business at 4F, 150, Li-Te Road, Beitou District, Taipei City, Taiwan. On further information and belief, Defendant ASUS Computer

International (ACI) is a California corporation with a principal place of business at 800 Corporate Way, Fremont, CA 94539. ASUS and ACI will be referred to herein individually and collectively as the ASUS Defendants. 4. On information and belief, Defendant Canon Inc. (Canon) is a Japanese

corporation with a principal place of business at 30-2 Shimomaruko 3-Chome, Ohta-Ku, Tokyo
COMPLAINT FOR PATENT INFRINGEMENT

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146-8501, Japan. On further information and belief, Defendant Canon U.S.A., Inc. (Canon USA) is a New York corporation with a principal place of business at One Canon Plaza, Lake Success, NY 11042. Canon and Canon USA will be referred to herein individually and

collectively as the Canon Defendants. 5. On information and belief, Defendant Casio Computer Co., Ltd. (Casio) is a

Japanese corporation with a principal place of business at 6-2, Hon-machi 1-chome, Shibuya-ku, Tokyo 151-8543, Japan. On further information and belief, Defendant Casio America, Inc. (Casio America) is a New York corporation with a principal place of business at 570 Mount Pleasant A venue, Dover, NJ 07801. Casio and Casio America will be referred to herein individually and collectively as the Casio Defendants. 6. On information and belief, Defendant Christie Digital Systems USA, Inc.

(Christie) is a California corporation with a principal place of business at 10550 Camden Dr, Cypress, CA 90630. 7. On information and belief, Defendant Coby Electronics Corp. (Coby) is a New

York corporation with a principal place of business at 1991 Marcus Ave., Lake Success, NY 11042. 8. On information and belief, Defendant Dukane Corporation (Dukane) is a

Delaware corporation with a principal place of business at 2900 Dukane Drive, Saint Charles, IL 60174. 9. On information and belief, Defendant Eiki International, Inc. (Eiki) is a

California corporation with a principal place of business at 30251 Esperanza, Rancho Santa Margarita, CA 92688. 10. On information and belief, Defendant Seiko Epson Corporation (Seiko Epson)

is a Japanese corporation with a principal place of business at 3-3-5 Owa, Suwa, Nagano 3928502, Japan. On further information and belief, Defendant Epson America, Inc. (Epson

America) is a California corporation with a principal place of business at 3840 Kilroy Airport

COMPLAINT FOR PATENT INFRINGEMENT

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Way, Long Beach, CA 90806. Seiko Epson and Epson America will be referred to herein individually and collectively as the Epson Defendants. 11. On information and belief, Defendant Haier Group Company (Haier) is a

Chinese corporation with a principal place of business at No.1 Haier Road Hi-tech Zone, Qingdao, China. On further information and belief, Defendant Haier America Trading, L.L.C. (Haier America) is a New York limited liability company with a principal place of business at 1356 Broadway, New York, NY 10018. Haier and Haier America will be referred to herein individually and collectively as the Haier Defendants. 12. On information and belief, Defendant InFocus Corporation (InFocus) is an

Oregon corporation with a principal place of business at 13190 SW 68th Parkway, Suite 200, Portland, OR 97223. 13. On information and belief, Defendant Lenovo Group, Ltd. (Lenovo) is a

Chinese corporation with a principal place of business at No. 6 Chuang Ye Road, Shangdi Information Industry Base, Haidan District, Beijing 100085, China. On further information and belief, Defendant Lenovo Holding Company, Inc. (Lenovo Holding) is a Delaware corporation with a principal place of business at 1009 Think Place, Morrisville, NC 27560. On further information and belief, Defendant Lenovo (United States), Inc. (Lenovo US) is a Delaware corporation with a principal place of business at 1009 Think Place, Morrisville, NC 27560. Lenovo, Lenovo Holding, and Lenovo US will be referred to herein individually and collectively as the Lenovo Defendants. 14. On information and belief, Defendant LG Electronics, Inc. (LG) is a South

Korean corporation with a principal place of business at LG Twin Towers, 20 Yeouido-dong, Yeongdeungpo-gu, Seoul 150-721, South Korea. On further information and belief, Defendant LG Electronics U.S.A., Inc. (LG USA) is a Delaware corporation with a principal place of business at 1000 Sylvan Avenue Englewood Cliffs, NJ 07632. LG and LG USA will be referred to herein individually and collectively as the LG Defendants.

COMPLAINT FOR PATENT INFRINGEMENT

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15.

On information and belief, Defendant Micro-Star International Co., Ltd. (MSI)

is a Taiwanese corporation with a principal place of business at No. 69, Li-De St., Jung-He City, Taipei Hsien, Taiwan. On further information and belief, Defendant MSI Computer Corp. (MSI Computer) is a California corporation with a principal place of business at 901 Canada Ct., City of Industry, CA 91748. MSI and MSI Computer will be referred to herein individually and collectively as the MSI Defendants. 16. On information and belief, Defendant Mitsubishi Electric Corporation

(Mitsubishi) is a Japanese corporation with a principal place of business at Tokyo Building, 27-3, Marunouchi, Chiyoda-ku, Tokyo 100-8310, Japan. On further information and belief, Defendant Mitsubishi Electric & Electronics USA, Inc. (Mitsubishi USA) is a Delaware corporation with a principal place of business at 5665 Plaza Drive, Cypress, CA 90630. Mitsubishi and Mitsubishi USA will be referred to herein individually and collectively as the Mitsubishi Defendants. 17. On information and belief, Defendant NEC Corporation (NEC) is a Japanese

corporation with a principal place of business at 7-1, Shiba 5-chome, Minato-ku, Tokyo 1088001, Japan. On further information and belief, Defendant NEC Corporation of America (NEC America) is a Nevada corporation with a principal place of business at 6535 N. State Highway 161, Irving, Texas 75039. NEC and NEC America will be referred to herein individually and collectively as the NEC Defendants. 18. On information and belief, Defendant Optoma Corporation (Optoma) is a

Taiwanese corporation with a principal place of business at 5F., No. 108, Minchiuan Rd., Shindian City, Taipei, Taiwan. On further information and belief, Defendant Optoma

Technology, Inc. (Optoma Technology) is a California corporation with a principal place of business at 715 Sycamore Dr, Milpitas, CA 95035. Optoma and Optoma Technology will be referred to herein individually and collectively as the Optoma Defendants. 19. On information and belief, Defendant Panasonic Corporation (Panasonic) is a

Japanese corporation with a principal place of business at 1006 Oaza Kadoma, Kadoma, Osaka
COMPLAINT FOR PATENT INFRINGEMENT

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571-8501, Japan. On further information and belief, Defendant Panasonic Corporation of North America (Panasonic North America) is a Delaware corporation with a principal place of business at One Panasonic Way, Secaucus, NJ 07094. Panasonic and Panasonic North America will be referred to herein individually and collectively as the Panasonic Defendants. 20. On information and belief, Defendant Planar Systems, Inc. (Planar) is a

Delaware corporation with a principal place of business at 1195 NW Compton Drive, Beaverton, OR 97006. 21. On information and belief, Defendant Runco International, L.L.C. (Runco) is an

Oregon limited liability company with a principal place of business at 1195 NW Compton Drive, Beaverton, OR 97006. 22. On information and belief, Defendant Sanyo Electric Co., Ltd. (Sanyo) is a

Japanese corporation with a principal place of business at 2-5-5 Keihan-Hondori, Moriguchi-ku, Osaka 570-8677, Japan. On further information and belief, Defendant Sanyo North America Corporation (Sanyo North America) is a Delaware corporation with a principal place of business at 2055 Sanyo Avenue, San Diego, CA 92154. Sanyo and Sanyo North America will be referred to herein individually and collectively as the Sanyo Defendants. 23. On information and belief, Defendant Sharp Corporation (Sharp) is a Japanese

corporation with a principal place of business at 22-22 Nagaike-cho, Abeno-ku, Osaka 545-8422, Japan. On further information and belief, Defendant Sharp Electronics Corporation (SEC) is a New York corporation with a principal place of business at 1 Sharp Plaza Mahwah, NJ 07495. Sharp and SEC will be referred to herein individually and collectively as the Sharp Defendants. 24. On information and belief, Defendant Sony Corporation (Sony) is a Japanese

corporation with a principal place of business at 1-7-1 Konan, Minato-ku, Tokyo 108-0075, Japan. On information and belief, Defendant Sony Electronics, Inc. (SEI) is a Delaware corporation with a principal place of business at 16530 Via Esprillo, San Diego, CA 92127. Sony and SEI will be referred to herein individually and collectively as the Sony Defendants.
COMPLAINT FOR PATENT INFRINGEMENT

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25.

On information and belief, Defendant Supersonic, Inc. (Supersonic) is a

California corporation with a principal place of business at 6555 Bandini Blvd., Commerce, CA 90040. 26. On information and belief, Defendant Systemax, Inc. (Systemax) is a Delaware

corporation with a principal place of business at 11 Harbor Park Drive, Port Washington, NY 11050. 27. On information and belief, Defendant Toshiba Corporation (Toshiba) is a

Japanese corporation with a principal place of business at 1-1, Shibaura 1-chome, Minato-ku, Tokyo 105-8001, Japan. On further information and belief, Defendant Toshiba America

Information Systems, Inc (Toshiba America) is a California corporation with a principal place of business at 9740 Irvine Boulevard, Irvine, CA 92618. Toshiba and Toshiba America will be referred to herein individually and collectively as the Toshiba Defendants. 28. On information and belief, Defendant ViewSonic Corporation (ViewSonic) is a

Delaware corporation with a principal place of business at 381 Brea Canyon Road, Walnut, CA 91789. 29. On information and belief, Defendant Vivitek Corporation (Vivitek) is a

California corporation with a principal place of business at 4425 Cushing Pky, San Jose, CA 94538. JURISDICTION AND VENUE 30. This action arises under the patent laws of the United States, Title 35 of the

United States Code, 271 and 281, et seq. because each of the Defendants has committed acts of patent infringement within the United States and this judicial district. Accordingly, this Court has subject matter jurisdiction of this action pursuant to 28 U.S.C. 1331 and 1338(a). 31. Personal jurisdiction and venue are proper in this Court pursuant to 28 U.S.C.

1391(b), 1391(c) and 1400(b), in that the defendants are subject to personal jurisdiction in this district. At a minimum, each of the defendants has delivered infringing products into the stream

COMPLAINT FOR PATENT INFRINGEMENT

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of commerce with the expectation that they will be purchased by consumers in Texas, including consumers in the Eastern District of Texas. THE 427 PATENT 32. On October 20, 1998, the United States Patent and Trademark Office duly and

legally issued U.S. Patent No. 5,825,427 (the 427 Patent), entitled Image Display System, to Kenneth J. Macleod. A copy of the 427 Patent is attached to the Complaint as Exhibit A. 33. By reason of an assignment dated January 25, 2011, Plaintiff Ogma owns all

rights, title and interest in the 427 Patent. FIRST CAUSE OF ACTION (Infringement of the 427 Patent) (35 U.S.C. 271) 34. Plaintiff repeats and incorporates by reference each of the allegations contained in

Paragraphs 1 through 33 above, and further alleges as follows: 35. On information and belief, without a license or permission from Plaintiff,

Defendant 3M has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant 3M did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant 3Ms infringing products include multi-touch displays C2254PW, C2234SW, M2256PW, the WX20 projector, and related families of products. Defendant 3Ms infringement of the 427 Patent has caused substantial damage to Plaintiff. 36. On information and belief, without a license or permission from Plaintiff, the

ASUS Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The ASUS Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the ASUS Defendants infringing products include laptop computers G50v, M50,

COMPLAINT FOR PATENT INFRINGEMENT

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N50, N80, EP121, and related families of products. The ASUS Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 37. On information and belief, without a license or permission from Plaintiff, the

Canon Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Canon Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the Canon Defendants infringing products include projectors W4000, W4000, WUX10 Mark II, WUX10 Mark II D, LV-8310, LV-8215, and related families of products. The Canon Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 38. On information and belief, without a license or permission from Plaintiff, the

Casio Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Casio Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the Casio Defendants infringing products include projectors XJ-A255V, XJ-A250, XJ-A245V, XJ-A240, XJ-A235U, XJ-A230, and related families of products. The Casio

Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 39. On information and belief, without a license or permission from Plaintiff,

Defendant Christie has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Christie did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant Christies infringing products include projectors LW400, LWU420, LWU505, LW555, LW650, DWU670-E, WX7K-M, WX10K-M, WU7K-M, WU12K-M, WU12K-M, WU3, WU7K-M, WU7, WU12K-M, WU12, WU18, and related families of products. Defendant Christies infringement of the 427 Patent has caused substantial damage to Plaintiff.
COMPLAINT FOR PATENT INFRINGEMENT

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40.

On information and belief, without a license or permission from Plaintiff,

Defendant Coby has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Coby did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant Cobys infringing products are the TFTV1325 LCD television, the DP1452 and DP1252 digital photo frames, and related families of products. Defendant Cobys infringement of the 427 Patent has caused substantial damage to Plaintiff. 41. On information and belief, without a license or permission from Plaintiff,

Defendant Dukane has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Dukane did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant Dukanes infringing products are projectors 8111H, 8407, 8791HW, 8924HW, 8104HW, 8957HW, 8949H, 9137WU, and related families of products. Defendant Dukanes infringement of the 427 Patent has caused substantial damage to Plaintiff. 42. On information and belief, without a license or permission from Plaintiff,

Defendant Eiki has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Eiki did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant Eikis infringing products are projectors EIP-WX5000, EIP-WX5000/L, LC-WXL200, LC-WGC500A, LC-WUL100, and related families of products. Defendant Eikis infringement of the 427 Patent has caused substantial damage to Plaintiff. 43. On information and belief, without a license or permission from Plaintiff, the

Epson Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Epson
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Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, a few examples of the Epson Defendants infringing products are the 450Wi and 450WiRM projectors, and related families of products. The Epson Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 44. On information and belief, without a license or permission from Plaintiff, the

Haier Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Haier Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one of the Haier Defendants infringing products is the HLT10 LCD television. The Haier Defendants

infringement of the 427 Patent has caused substantial damage to Plaintiff. 45. On information and belief, without a license or permission from Plaintiff,

Defendant InFocus has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant InFocus did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant InFocuss infringing products include projectors ASK Proxima C410, A3300, C250W, M22, and projectors InFocus IN3904, IN2116, IN1102, IN1503, IN3116, IN146, IN5104, IN5110, IN5304, IN5502, IN5532, IN5533, IN5535, IN5124, IN1102, and related families of products. Defendant InFocuss infringement of the 427 Patent has caused substantial damage to Plaintiff. 46. On information and belief, without a license or permission from Plaintiff, the

Lenovo Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Lenovo Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention.
COMPLAINT FOR PATENT INFRINGEMENT

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examples of the Lenovo Defendants infringing products include laptop computers G350, X30, T400, T500, T410S, and related families of products. The Lenovo Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 47. On information and belief, without a license or permission from Plaintiff, the LG

Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The LG Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of the LG

Defendants infringing products include LCD monitors C220WXE,W2286L, W3000H, and related families of products. The LG Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 48. On information and belief, without a license or permission from Plaintiff, the MSI

Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The MSI Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of the MSI Defendants infringing products include laptop computers GT640-287US, GX640-260US, GX740-235US, GX640-098US, GT640-287US, GX633-070US, GX630-037CA, VR601, and related families of products. The MSI Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 49. On information and belief, without a license or permission from Plaintiff, the

Mitsubishi Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Mitsubishi Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of the Mitsubishi Defendants infringing products include projectors EW270U, EW230U-ST, WD620U-G, WD620U, WD3300U, WD8200U, WL2650U, and related families
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of products. The Mitsubishi Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 50. On information and belief, without a license or permission from Plaintiff, the

NEC Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The NEC Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the NEC Defendants infringing products include projectors NP410W, NP-M260W, NP510WS, NP-M300W, NP-M300WS, NP-U310W, NP-P350W, NP-PA550W, NP3250W, NP4100W, and related families of products. The NEC Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 51. On information and belief, without a license or permission from Plaintiff, the

Optoma Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Optoma Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the Optoma Defendants infringing products include projectors EW330, EW536, Pro350W, EW1610, and related families of products. The Optoma Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 52. On information and belief, without a license or permission from Plaintiff, the

Panasonic Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Panasonic Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of the Panasonic Defendants infringing products include the PT-DW530U projector, the Toughbook CF-F9 laptop computer, and related families of products. The

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Panasonic Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 53. On information and belief, without a license or permission from Plaintiff,

Defendant Planar has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Planar did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one example of Defendant Planars

Defendant Planars infringing products is the PR5030 projector. infringement of the 427 Patent has caused substantial damage to Plaintiff. 54.

On information and belief, without a license or permission from Plaintiff,

Defendant Runco has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Runco did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one example of Defendant Runcos

Defendant Runcos infringing products is the VX-8D projector. infringement of the 427 Patent has caused substantial damage to Plaintiff. 55.

On information and belief, without a license or permission from Plaintiff, the

Sanyo Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Sanyo Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the Sanyo Defendants infringing products include projectors PLC-ZM5000L, PLCWTC500L, PLC-WM5500/L, PLC-WM4500/L, PLC-WTC500AL, PLC-WXU700A, PLCWXU30A, PLC-WXU300, PLC-WK2500, PDG-DWL100, PLC-WL2500, PLC-WR251, PLCWTC500AL, PLC-WL2503, PDG-DWL2500, and related families of products. The Sanyo Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff.

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56.

On information and belief, without a license or permission from Plaintiff, the

Sharp Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Sharp Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, a few examples of the Sharp Defendants infringing products include the PG-D2870W and PG-D3050W projectors, and related families of products. The Sharp Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 57. On information and belief, without a license or permission from Plaintiff, the

Sony Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Sony Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of the Sony Defendants infringing products include the DPX-XR100, DPF-D1020, DPF-VR100 digital photo frames, the VGN-FZ150E/BC laptop computer, the VPL-BW7 LCD television, and related families of products. The Sony Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 58. On information and belief, without a license or permission from Plaintiff,

Defendant Supersonic has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Supersonic did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one example of Defendant Supersonics infringing products is the SC-1331 LCD television. Defendant

Supersonics infringement of the 427 Patent has caused substantial damage to Plaintiff. 59. On information and belief, without a license or permission from Plaintiff,

Defendant Systemax has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant
COMPLAINT FOR PATENT INFRINGEMENT

15

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Filed 03/16/11 Page 16 of 18 07/18/11 27

Systemax did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one example of Defendant Systemaxs infringing products is the Pursuit 4170 laptop computer. Defendant Systemaxs infringement of the 427 Patent has caused substantial damage to Plaintiff. 60. On information and belief, without a license or permission from Plaintiff, the

Toshiba Defendants have infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. The Toshiba Defendants did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, one example of the Toshiba Defendants infringing products is the L305 laptop computer. The Toshiba

Defendants infringement of the 427 Patent has caused substantial damage to Plaintiff. 61. On information and belief, without a license or permission from Plaintiff,

Defendant ViewSonic has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant ViewSonic did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several

examples of Defendant ViewSonics infringing products include the PJD6531w, PJD7583w, Pro8450w projectors, and related families of products. Defendant ViewSonics infringement of the 427 Patent has caused substantial damage to Plaintiff. 62. On information and belief, without a license or permission from Plaintiff,

Defendant Vivitek has infringed, induced others to infringe, and/or contributorily infringed, literally or under the doctrine of equivalents, one or more claims of the 427 Patent. Defendant Vivitek did so by importing, making, using, offering to sell, and/or selling products and devices that embody and/or practice the patented invention. Without limitation, several examples of Defendant Viviteks infringing products include projectors D326WX, D330WX, D513W, D537W, and related families of products. Defendant Viviteks infringement of the 427 Patent has caused substantial damage to Plaintiff.
COMPLAINT FOR PATENT INFRINGEMENT

16

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Filed 03/16/11 Page 17 of 18 07/18/11 27

PRAYER FOR RELIEF WHEREFORE, Plaintiff Ogma, LLC prays for relief as follows: A. Declaring that the Patent-in-Suit is valid and enforceable, and that each Defendant

has infringed one or more claims of the Patent-in-Suit; B. Awarding Plaintiff damages in an amount adequate to compensate Plaintiff for

each defendants infringement, in accordance with 35 U.S.C. 284; C. Awarding Plaintiff its costs of suit, including reasonable attorney fees, because

this is an exceptional case under 35 U.S.C. 285; and D. appropriate. DEMAND FOR JURY TRIAL Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff Ogma, LLC demands a trial by jury of this action. Granting such other and further relief as this Court may deem just and

COMPLAINT FOR PATENT INFRINGEMENT

17

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Filed 03/16/11 Page 18 of 18 07/18/11 27

Dated: March 16, 2011

Respectfully submitted,

By: /s/ Andrew W. Spangler Andrew W. Spangler State Bar No. 24941960 spangler@spanglerlawpc.com Spangler Law PC 208 N. Green St., Suite 300 Longview, TX 75601 Bus: (903) 753-9300 Fax: (903) 553-0403 Co-Counsel: James C. Otteson CA Bar No. 157781 (Admitted E.D. Texas) jim@agilityiplaw.com David A. Caine CA Bar No. 218074 (Admitted E.D. Texas) dacaine@agilityiplaw.com Thomas T. Carmack CA Bar No. 229324 (Admitted E.D. Texas) tom@agilityiplaw.com Xiang Long CA Bar No. 246629 (Admitted E.D. Texas) longxiang@agilityiplaw.com Agility IP Law 1900 University Circle, Suite 201 East Palo Alto, CA 94303 Bus: 650-227-4800 Fax: 650-318-3483 Attorneys for Plaintiff OGMA, LLC

COMPLAINT FOR PATENT INFRINGEMENT

18

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Exhibit A

Case 2:11-cv-00322-TJW Document 2 Filed 07/18/11 Page 202of 27 Case 2:11-cv-00178-TJW Document 1-1 Filed 03/16/11 Page of 7 111111 1111111111111111111111111111111111111111111111111111111111111
US005825427A

United States Patent


MacLeod
[54] [76]

[19]

[11]
[45]

Patent Number: Date of Patent:

5,825,427
Oct. 20, 1998

IMAGE DISPLAY SYSTEM


Inventor:

Kenneth J. MacLeod, 111 Fleurance, Laguna Niguel, Calif. 92677

Primary Examiner-Richard A. Hjerpe Assistant Examiner-Ricardo Osorio Attorney, Agent, or Firm---Drummond & Duckworth [57]

ABSTRACT

[21] [22] [51] [52] [58]

Appl. No.: 518,583 Filed:

Aug. 22, 1995

Int. CI. 6 ....................................................... H04N 7/01 U.S. CI. ............................................. 348/445; 348/913 Field of Search ..................................... 348/448,445, 348/556, 913; 345/127, 128, 129, 130, 131 References Cited
U.S. PATENT DOCUMENTS
4,734,772 5,223,928 5,243,421 5,489,952 5,491,512 3/1988 6/1993 9/1993 2/1996 2/1996 Akiyama ................................. Hamada .................................. Nagata et al. .......................... Gave et al. ............................. Itakura et al. .......................... 348/445 348/445 348/445 348/448 348/445

[56]

The present invention addresses problems of dealing with video formats in both 4:3 and 16:9 aspect ratios by providing an image display system having an aspect ratio between the 4:3 aspect ratio of the standard National Television System Committee (NTSC) and the soon to be implemented 16:9 aspect ratio of High Definition TV (HDTV). In a first embodiment, the apparatus utilizes a video screen having a substantially rectangular configuration having an aspect ratio being between 1.4:1 and 1.7:1. In a more preferred embodiment, the image display system includes a video screen having an aspect ratio being between 1.5:1 and 1.6:1. In an even more preferred embodiment, the video screen of the image display system optimally has an aspect ratio of (square root of 64/27):1.0.

4 Claims, 2 Drawing Sheets

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u.s. Patent

Oct. 20, 1998

Sheet 1 of 2

5,825,427

17

FIG. 1
7"\
5 5

FIG. 2

FIG. 3

21 25 19 5 23 9 23

I'

21

-I
5

FIG. 4

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u.s. Patent

Oct. 20, 1998

Sheet 2 of 2

5,825,427

25

1+1----2-1---_-+-1_1

21

~~~~~~~~~~19
5 5

23

23

19

FIG. 7

21

21

~:~~~~~~~~~~19
5
5

23

FIG. 8

19

FIG. 9

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5,825,427 1
Il\1AGE DISPlAY SYSTEM
BACKGROUND The invention relates to the field of video broadcasting. More particularly, the invention relates to the soon to be implemented change from the present 4:3 aspect ratio of the National Television System Committee (NTSC) most prevalently used for television and the soon to be implemented 16:9 aspect ratio of future systems. The NTSC television system is presently used as the standard color television system in the USA and several other countries. The NTSC system includes 525 horizontal scan lines typically received in a frequency band of 4.2 MHz to produce a video format having an aspect ratio of 4:3. Hereinafter, the aspect ratio is defined as the ratio of the horizontal length of a displayed image as a ratio to the vertical length of a displayed image (horizontal:vertical). Additional present day systems include PAL and SECAM systems that also utilize a 4:3 aspect ratio. Unfortunately, the 4:3 aspect of television conflicts with the wide format display aspect ratio of 16:9 corresponding to the display aspect ratio of theatrical movies. This has continued to create problems for both the television and cinematic industries which must process the video images prior to their transition from theater to home television, often resulting in a loss of video information. Conventionally, if a video image having an aspect ratio of 16:9 is shown on a screen of 4:3, the ends of the scanning lines are removed in the horizontal direction, expansion of the video signal in the vertical direction, or the video signal is displayed without any processing. This results in the loss of video information, the distortion of the video signal by expansion of the vertical direction or the inclusion of blank portions appended to the top and bottom sides of the video image. Partly in order to resolve this problem both Japan and the United States have begun to study a new television system, a High Definition TV (HDTV). One of the characteristic features of the proposed HDTV systems is that the number of scan lines up to 1125 and the signal bandwidth is 20 MHz or wider, which has information capacity of about five times as large as the present system. Another characteristic feature of HDTV is that the aspect ratio of the proposed screen is 16: 9, identical to that of cinematic productions. Furthermore, other television systems are also under study, including Enhanced TV (EDTV) and a second generation (EDTV-II), which also employ a 16:9 aspect ratio. Widespread use of video image formats of 16:9 are expected to come into practical use in the near future, while continuing to use the presently used NTSC 4:3 aspect ratio. Accordingly, for the next several years, video material will be provided in one of two primary formats: the traditional 4:3 (1.333:1) aspect ratio, or the new HDTV or EDTV aspect ratio of 16:9 (1.778:1). In order to optimally display one of the types of video material using the full screen, it is anticipated most video display systems will be constructed with an aspect ratio of either 4:3 or 16:9. If broadcast signals of various systems are all to be received, several television receivers are required to be newly bought and installed, which is not practical from the aspects of expense and space. To overcome these obstacles, image display systems have been developed that will display both the NTSC system, including 525 horizontal scan lines and frequency band of 4.2 MHz, and the HDTV and EDTV systems having 1125 scan lines and a frequency band of 20 MHz. For example, U.S. Pat. No. 5,218,436 discloses a television signal processing circuit capable of receiving television signals of
5

2
different systems with a single television receiver by discriminating the input television signal and selecting a proper signal processing circuit. Unfortunately, the display of 4:3 video material on a 16:9 screen or the display of 16:9 video material on a 4:3 leaves a substantial amount of unused screen that is not only inefficient but is substantially annoying to a person viewing the video image. As shown in FIG. 4, the display of 16:9 video material on a 4:3 screen leaves the top and bottom 25% of the screen unused. Similarly, as shown in FIG. 5, the display of 4:3 video material on a 16:9 screen leaves 25% of the left and right portions of the screen unused. Not only does this result in the ineffective use of the video screen but the constant display of video in the middle portions of the screen while the sides, top and bottom are only temporally used, results in uneven degradation of the cathode ray tube. In order to overcome these problems, several additional image display systems have been devised. For example, as disclosed in U.S. Pat. No. 4,670,784, the blank portions are fixed in a mid-gray to decrease the unevenness of the degradation in those areas of the cathode ray tube. Similarly, U.S. Pat. No. 5,193,006 discloses displaying the unused portions at an average of the brightness of the entire video area. Unfortunately, each of these systems result in the display portion appearing rather small in comparison to the screen. In a somewhat compromising system, U.S. Pat. No. 5,386,236 discloses a combination of clipping and distorting the received image that results in a display that is substantially fatter than originally received. Additional systems that have been developed to adapt 4:3 and 16:9 aspect ratios include displaying the image on the left portion of the screen while providing character data on the right portion of the screen (U.S. Pat. No. 5,170,256), providing the viewer with a switch for the viewer to decide whether to crop, distort or provide shaded panels on the screen (U.S. Pat. No. 5,243, 421) and providing the viewer with a joystick for the viewer to pan back and forth along the display in order to view the portion of the image most desired (U.S. Pat. No. 4,953,025). Unfortunately, the wide variety of systems that have been developed to combine the 4:3 and 16:9 aspect ratios into a single system dramatically expose the struggle that the industry has encountered to resolve these incompatibility problems. Accordingly, it would be advantageous to have an improved image display system that displayed images presented in both the 4:3 and 16:9 aspect ratios. Further, it would be advantageous to have an image display system that displayed 4:3 and 16:9 images with a minimum of non-information border area being displayed on the screen. Moreover, it would be desirable to have an image display system that reduced or completely eliminated the need to clip or distort the image prior to display to completely fill the video screen. SUMMARY The present invention addresses the aforementioned disadvantages by providing an image display system having an aspect ratio between the 4:3 aspect ratio of the standard 60 National Television System Committee (NTSC) and the soon to be implemented 16:9 aspect ratio of High Definition TV (HDTV). In a first embodiment, the apparatus utilizes a video screen having a substantially rectangular configuration having an aspect ratio being between 1.4:1 and 1.7:1.In 65 a more preferred embodiment, the image display system includes a video screen having an aspect ratio being between 1.5:1 and 1.6:1. In an even more preferred embodiment, the

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video screen of the image display system optimally has an aspect ratio of the square root of 64/27 (1.54):1.0. By providing an image display system with an aspect ratio of 1.54:1.0, creates an adaptive video system optimally suitable for receiving video signals having aspect ratios of both 4:3 and 16:9. An additional advantage of the present invention is that the image display system does not require complicated and expensive processing units to adapt a 4:3 formatted video signal to a 16:9 video screen or to adapt a 16:9 formatted video signal to a 4:3 video screen. Moreover, the image display system reduces or completely eliminates the need to clip or distort the video image prior its to display to completely fill the video screen. Other features and advantages of the present invention will be appreciated by those skilled in the art upon reading the detailed description which follows with reference to the attached drawings. BRIEF DESCRIPTION OF THE DRAWINGS These and other features, aspects, and advantages of the present invention will become better understood with regard to the following description, appended claims, and a=ompanying drawings where: FIG. 1 is an isometric view of the image display system of the present invention; FIG. 2 is a frontal view of the video screen of a prior art image display system having a 4:3 aspect ratio; FIG. 3 is a frontal view of the video screen of the soon to be implemented image display systems having a 16:9 aspect ratio; FIG. 4 is a frontal view of the video screen of a prior art image display system having a 4:3 aspect ratio displaying a video image having a 16:9 aspect ratio; FIG. 5 is a frontal view of the video screen of the soon to be implemented image display systems having a 16:9 aspect ratio displaying a video image having a 4:3 aspect ratio; FIG. 6 is a frontal view of the video screen of the present invention having a 1.54:1 aspect ratio displaying a video image having a 16:9 aspect ratio; FIG. 7 is a frontal view of the video screen of the present invention having a 1.54:1 aspect ratio displaying a video image having a 4:3 aspect ratio; FIG. 8 is a frontal view of the video screen of the present invention having a 1.54: 1 aspect ratio displaying an overscanned video image having a 16:9 aspect ratio; and FIG. 9 is a frontal view of the video screen of the present invention having a 1.54:1 aspect ratio displaying an overscanned video image having a 4:3 aspect ratio. DETAILED DESCRIPTION While the present invention is susceptible of embodiment in various forms, there is shown in the drawings and will hereinafter be described a presently preferred embodiment of the invention, with the understanding that the present disclosure is to be considered as an exemplification of the invention, and is not intended to limit the invention to the specific embodiment illustrated. As shown in the exemplary drawings where like numerals represent like elements, the invention is embodied in an image display having an aspect ratio between the presently employed 4:3 ratio and the soon to be implemented in 16:9 ratio. As would be well understood by those in the art, the present invention is not limited to a typical television system
55

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as shown, but may include theatrical screens, rear projection systems, computer monitors and the like. Referring to FIG. 1, a typical prior art image display system 1 and exemplary of the image display system of the present invention is shown to include a cabinet housing 3, a video screen 5, a video image processor 11, a control panel 13 and an input lead 15. With reference to FIGS. 1, 2 and 3, typically the video screen 5 is positioned in the cabinet housing 3 to provide a substantial planar vertically extending surface having a horizontal dimension 7 and a vertical dimension 9 for displaying a video image. Connected to the video screen 5 is the video image processor 11 for processing input signals 17 received from the input lead 15 for producing an image on the video screen. Also, as would be readily understood by those in the art, the input lead 15 is depicted as a cable, typically used by television consumers; however, the input lead 15 is representative of any signal receiver for receiving a signal image such as an antenna or satellite dish. With continued reference to FIGS. 1 and 2, video material is presently displayed on a screen having an 4:3 aspect ratio of the horizontal dimension 7 to the vertical dimension 9. This corresponds the standard NTSC system which includes 525 horizontal scan lines received in a frequency band of 4.2 MHz. As shown in FIG. 3, in the next few years video material will be provided in an aspect ratio of 16:9 of the horizontal dimension 7 and vertical dimension 9 corresponding to the proposed HDTV system or the like having up to 1125 scan lines and a signal bandwidth is 20 MHz. As a result, video material will be provided in one of two primary formats, the traditional 4:3 aspect ratio or the 16:9 aspect ratio, and video displays will be constructed with an aspect ratio of either 4:3 or 16:9 in order to optimally display one of the types of video material using the entire screen. As shown in FIGS. 4 and 5, with the construction of a screen having either aspect ratio, the display of the other type of video material thereon ,vill only utilize 75% of the available area of the screen due to incompatible aspect ratios. For example, FIG. 4 shows the display of an image 25 having a 16:9 aspect ratio on a video screen having an aspect ratio of 4:3. The horizontal dimension 21 of the image extends the horizontal length 7 of the screen; however, the vertical dimension 23 of the image is substantially less than the vertical dimension of the screen 9 resulting in two unused screen portions 19 comprising 25% of the entire screen area. Similarly, as shown in FIG. 5, the display of an image 25 having a 4:3 aspect ratio on a video screen having an aspect ratio of 16:9 will result in two unused screen portions 19 at the sides of the screen also comprising 25% of the entire screen area. The invention proposes an intermediate aspect ratio for video display screens which will minimize the worst-case portion of unused screen area during the period that display formats transition from the 4:3 aspect ratio to the 16:9 aspect ratio. It has been determined that there is a mathematically defined range of aspect ratios for achieving this result. In a first embodiment, the video screen of the present invention has a substantially rectangular configuration having an aspect ratio being between 1.4:1 and 1.7:1 thereby eliminating a substantial portion of the unused screen area. In a more preferred embodiment, the image display system includes a video screen having an aspect ratio being between 1.5:1 and 1.6:1. It has been determined that the optimum aspect ratio for minimizing the unused display area when supporting either 4:3 or 16:9 formats of the video material is the geometric mean between the two ratios. In other words, the optimum aspect ratio is the square root of (4/3x16/19) which is equal to the square root of 64/27.

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5
Accordingly, in the preferred embodiment, the image display system includes a video screen having an aspect ratio of approximately 1.54:1. As shown in FIG. 6, the display of a video image 25 having a 16:9 aspect ratio on a video screen 5 of the present invention including a 1.54: 1 aspect ratio produces virtually insignificant unused screen portions 19 that would not destroy any of the information of the video image or detract from the viewer's enjoyment. The utilization of a video screen having a 1.54:1 aspect ratio to display an image having a 16:9 results in 86.6% of the screen being used and, accordingly, only an unused portion of 13.4%. Likewise, as shown in FIG. 7, the use a screen having an aspect ratio of 1.54:1 to display an image having a 4:3 format also results in insignificant unused screen portions 19 that also comprise only 13.4% of the screen or 86.6% of the screen being used. The percentage of utilization is identical for either format resulting in exceptionally high utilization. Moreover, the present invention is ideally suited for the use of "overscan." The control of the size of a video image changes with time in most image display systems due to the degradation of circuit components. Accordingly, the video image has a tendency to shrink over time creating an unused border around the video image similar to the unused border area discussed above. In order to eliminate this unsightliness, the processor of the image display system is adjusted prior to integration with the system to "overscan" the received input signal to oversize the video image by 5%-10%. This results in an oversized image, an unnoticeable loss of the edge portion of the image which diminishes as the video image shrinks over time, and the elimination of the border created due to image shrinkage. With reference to FIGS. 8 and 9, the use of a 5%-10% overscan, as is typically used in present systems, to an image display system having a screen with a 1.54:1 aspect ratio will result in the utilization of 91 %-95% of the video screen. For example, as shown in FIG. 8, the display of an image 25 having a 16:9 format on a screen 5 having a 1.54:1 aspect ratio, will result in insignificant unused border areas 19 at the top and bottom of the screen. Similarly, as shown in FIG. 9, the display of an image 25 having a 4:3 format on a screen 5 having a 1.54: 1 aspect ratio, will result in insignificant unused border areas 19 at the sides of the screen. In either instance, the formats will utilize 91 %-95% which would be very satisfactory to viewers. Furthermore, though not necessary, for the practice of this invention it is anticipated that the image display system of the present invention could be combined with prior art systems which clip and distort the image and the like to eliminate any border area seen by the viewer.

6
Although the present invention has been described with reference to the preferred embodiment, workers skilled in the art will recognize that changes may be made in form and detail without departing from the spirit and scope of the invention. Having identified the presently preferred best mode thereof. I claim: 1. An image display system for displaying a video image having an aspect ratio of either 4:3 or 16:9, the image display system comprising:

10

a video screen having a substantially rectangular configuration forming an aspect ratio of the horizontal dimension of said video screen to the vertical dimension of the said video screen, said aspect ratio being between 15 1.4:1 and 1.65:1; a first image producing means for producing an image originally formatted with an aspect ratio of 4:3 on said video screen having an aspect ratio between 1.4:1 and 20 1.65:1; and a second image producing means for producing an image originally formatted with an aspect ratio of 16:9 on said video screen having an aspect ratio between 1.4:1 and 1.65:1. 25 2. An image display system of claim 1 wherein: said aspect ratio is between 1.5: 1 and 1.6: 1. 3. An image display system for displaying a video image comprising: 30 a video screen having a substantially rectangular configuration forming an aspect ratio of the horizontal dimension of said video screen to the vertical dimension of said video screen, said aspect ratio being between 1.45:1 and 1.60:1. 35 4. An image display system for displaying a first video image having a first aspect ratio or a second video image having a second aspect ratio, the image display system comprising: a video screen having a rectangular configuration forming 40 a third aspect ratio, said third aspect ratio being substantially equal to the geometric mean of said first aspect ratio and said second aspect ratio; a first image producing means for producing an image originally formatted with said first aspect ratio; and 45 a second image producing means for producing an image originally formatted with said second aspect ratio.

* * * * *

OJS 44 (Rev. 12/07)

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CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINTIFFS Ogma, LLC (b) County of Residence of First Listed Plaintiff
(EXCEPT IN U.S. PLAINTIFF CASES)

DEFENDANTS

3M Company, et al
County of Residence of First Listed Defendant
(IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number)

Attorneys (If Known)

Andrew W. Spangler, Spangler Law P.C., 208 N. Green St., Ste. 300, Longview, Texas 75601, (903) 753-9300 II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an X in One Box for Plaintiff
1
U.S. Government Plaintiff

3 Federal Question (U.S. Government Not a Party) 4 Diversity


(Indicate Citizenship of Parties in Item III)

(For Diversity Cases Only) PTF Citizen of This State 1

DEF 1

and One Box for Defendant) PTF DEF Incorporated or Principal Place 4 4 of Business In This State Incorporated and Principal Place of Business In Another State Foreign Nation

U.S. Government Defendant

Citizen of Another State

2 3

5 6

5 6

Citizen or Subject of a Foreign Country

IV. NATURE OF SUIT


CONTRACT

(Place an X in One Box Only) TORTS PERSONAL INJURY 310 Airplane 315 Airplane Product Liability 320 Assault, Libel & Slander 330 Federal Employers Liability 340 Marine 345 Marine Product Liability 350 Motor Vehicle 355 Motor Vehicle Product Liability 360 Other Personal Injury CIVIL RIGHTS 441 Voting 442 Employment 443 Housing/ Accommodations 444 Welfare 445 Amer. w/Disabilities Employment 446 Amer. w/Disabilities Other 440 Other Civil Rights PERSONAL INJURY 362 Personal Injury Med. Malpractice 365 Personal Injury Product Liability 368 Asbestos Personal Injury Product Liability PERSONAL PROPERTY 370 Other Fraud 371 Truth in Lending 380 Other Personal Property Damage 385 Property Damage Product Liability PRISONER PETITIONS 510 Motions to Vacate Sentence Habeas Corpus: 530 General 535 Death Penalty 540 Mandamus & Other 550 Civil Rights 555 Prison Condition

FORFEITURE/PENALTY

BANKRUPTCY

OTHER STATUTES

110 Insurance 120 Marine 130 Miller Act 140 Negotiable Instrument 150 Recovery of Overpayment & Enforcement of Judgment 151 Medicare Act 152 Recovery of Defaulted Student Loans (Excl. Veterans) 153 Recovery of Overpayment of Veterans Benefits 160 Stockholders Suits 190 Other Contract 195 Contract Product Liability 196 Franchise REAL PROPERTY 210 Land Condemnation 220 Foreclosure 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability 290 All Other Real Property

610 Agriculture 620 Other Food & Drug 625 Drug Related Seizure of Property 21 USC 881 630 Liquor Laws 640 R.R. & Truck 650 Airline Regs. 660 Occupational Safety/Health 690 Other LABOR 710 Fair Labor Standards Act 720 Labor/Mgmt. Relations 730 Labor/Mgmt.Reporting & Disclosure Act 740 Railway Labor Act 790 Other Labor Litigation 791 Empl. Ret. Inc. Security Act
IMMIGRATION 462 Naturalization Application 463 Habeas Corpus Alien Detainee 465 Other Immigration Actions

422 Appeal 28 USC 158 423 Withdrawal 28 USC 157


PROPERTY RIGHTS 820 Copyrights 830 Patent 840 Trademark

SOCIAL SECURITY 861 HIA (1395ff) 862 Black Lung (923) 863 DIWC/DIWW (405(g)) 864 SSID Title XVI 865 RSI (405(g)) FEDERAL TAX SUITS 870 Taxes (U.S. Plaintiff or Defendant) 871 IRSThird Party 26 USC 7609

400 State Reapportionment 410 Antitrust 430 Banks and Banking 450 Commerce 460 Deportation 470 Racketeer Influenced and Corrupt Organizations 480 Consumer Credit 490 Cable/Sat TV 810 Selective Service 850 Securities/Commodities/ Exchange 875 Customer Challenge 12 USC 3410 890 Other Statutory Actions 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters 894 Energy Allocation Act 895 Freedom of Information Act 900Appeal of Fee Determination Under Equal Access to Justice 950 Constitutionality of State Statutes

V. ORIGIN
1 Original Proceeding

(Place an X in One Box Only)

Appeal to District Appellate Court

2 Removed from
State Court

3 Remanded from

4 Reinstated or 5 Transferred from 6 Multidistrict another district Reopened Litigation (specify)

7 Judge from Magistrate


Judgment

35 U.S.C. 271 and 281, et seq. VI. CAUSE OF ACTION Brief description of cause: Patent Infringement DEMAND $ CHECK IF THIS IS A CLASS ACTION VII. REQUESTED IN UNDER F.R.C.P. 23 COMPLAINT: VIII. RELATED CASE(S) (See instructions): JUDGE T. John Ward IF ANY
DATE

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

CHECK YES only if demanded in complaint: Yes No JURY DEMAND: DOCKET NUMBER

2:11-cv-168-TJW

SIGNATURE OF ATTORNEY OF RECORD

03/16/2011
FOR OFFICE USE ONLY RECEIPT # AMOUNT

/s/ Andrew W. Spangler

APPLYING IFP

JUDGE

MAG. JUDGE

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JS 44 Reverse (Rev. 12/07)

Case 2:11-cv-00322-TJW Document 2 Filed 07/18/11 Page 272of 27 Case 2:11-cv-00178-TJW Document 1-2 Filed 03/16/11 Page of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44


Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed. The attorney filing a case should complete the form as follows: I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving both name and title. (b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases, the county of residence of the defendant is the location of the tract of land involved.) (c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting in this section (see attachment). II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an X in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here. United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an X in this box. Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box 1 or 2 should be marked. Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.) III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this section for each principal party. IV. Nature of Suit. Place an X in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is sufficient to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select the most definitive. V. Origin. Place an X in one of the seven boxes. Original Proceedings. (1) Cases which originate in the United States district courts. Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition for removal is granted, check this box. Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date. Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date. Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict litigation transfers. Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this box is checked, do not check (5) above. Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judges decision. VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service VII. Requested in Complaint. Class Action. Place an X in this box if you are filing a class action under Rule 23, F.R.Cv.P. Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction. Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded. VIII. Related Cases. This section of the JS 44 is used to reference related pending cases if any. If there are related pending cases, insert the docket numbers and the corresponding judge names for such cases. Date and Attorney Signature. Date and sign the civil cover sheet.

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