DataQuill Limited v. Apple Inc.

Filing 1

COMPLAINT ( Filing fee $ 400 receipt number 0542-5774656), filed by DataQuill Limited. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5-1, # 6 Exhibit 5-2, # 7 Civil Cover Sheet)(Wilson, Douglas)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

DATAQUILL LIMITED

Plaintiff,

v.
APPLE INC.
Defendant.

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Civil Action No. 1:13-cv-706

JURY TRIAL REQUESTED

PLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff DataQuill Limited files this Original Complaint for patent infringement against
Defendant Apple Inc.
PARTIES
1.

Plaintiff DataQuill Limited (“DataQuill”) is a limited company organized under

the laws of the British Virgin Islands.
2.

On information and belief, Defendant Apple Inc. (“Apple”) is a corporation duly

organized and existing under the laws of the state of California, with places of business at 12545
Riata Vista Circle, Austin, TX 78727, and 1 Infinite Loop, Cupertino, CA 95014. Apple may be
served with process in Texas through its registered agent, C T Corporation System, at 350 North
St. Paul St., Suite 2900, Dallas, TX 75201.
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JURISDICTION AND VENUE
3.

This is an action for patent infringement under the Patent Laws of the United

States, 35 U.S.C. § 271.
4.

This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and

1338(a).
5.

This Court has personal jurisdiction over Apple. Apple regularly sells (either

directly or indirectly) products and services into this judicial district. Additionally, Apple has
substantial operations located in this judicial district including an existing campus that employs
more than 3,500 individuals. Apple is also currently building a new campus that it has publicly
stated will more than double the size of its workforce in this judicial district.
6.

Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and 1400(b)

because a substantial part of the events giving rise to the claims occurred in this district, Apple
has a regular and established practice of business in this district, and Apple has committed acts
of infringement in this district.
DATAQUILL & THE ASSERTED PATENTS
7.

Over the past twelve years, DataQuill has sought to protect its invention through a

licensing program (which has on several occasions required litigation). Many of the largest
high-tech companies, including HTC, Nokia, Motorola, LG, Samsung, Palm, and HewlettPackard, have purchased a license to DataQuill’s patent portfolio. To date, DataQuill has
obtained over $75 million in licensing revenue.
8.

The value of DataQuill’s asserted patents is further demonstrated by DataQuill’s

repeated success against validity challenges. Three of the asserted patents have been through
reexaminations at the United States Patent & Trademark Office where hundreds of references
2

have been considered. In prior litigations, several of the asserted patents withstood heavy
scrutiny, including motions for summary judgment of anticipation, obviousness, inequitable
conduct, lack of enablement, and lack of an adequate written description—all of which were
resolved in DataQuill’s favor. The following is a list of DataQuill’s previous litigation, all of
which concluded with the defendant taking a license to DataQuill’s portfolio:


DataQuill Ltd. v. Handspring Inc., No. 1:01-cv-04635 (N.D. Ill.) (June 19, 2001 –
October 4, 2005)



DataQuill Limited v. Kyocera Wireless, No. 3:01-cv-02302 (S.D. Cal.) (December
14, 2001 – April 25, 2006)



DataQuill Limited v. Novatel Wireless Inc., No. 3:03-cv-02066 (S.D. Cal. (October
16, 2003 – July 1, 2004)



Research In Motion Limited v. DataQuill BVI, Ltd., No. 3:06-cv-00973 (N.D. Tex.)
(March 31, 2006 – December 3, 2008)



DataQuill Limited v. Nokia Corp., No. 3:07-cv-01055 (S.D. Cal.) (June 8, 2007 –
April 9, 2008)



DataQuill Limited v. High Tech Computer Corp., No. 3:08-cv-00543 (S.D. Cal.)
(March 25, 2008 – September 21, 2012)

9.

Prior to filing this lawsuit, DataQuill diligently attempted to resolve its claims

against Apple without litigation. Beginning in April 2009, DataQuill had communications with
Apple. Over the course of these discussions, DataQuill has repeatedly informed Apple that it is
infringing DataQuill’s patents and provided claim charts that specifically describe the
infringement.

The following partial chronology details DataQuill’s attempts to resolve its

dispute with Apple:
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

On April 14, 2009, DataQuill sent Apple a claim chart detailing how the iPhone
infringes DataQuill’s U.S. Patent No. 6,058,304 and a copy of the district court’s
claim construction order issued in connection with DataQuill’s litigation against
Research in Motion.



On May 13, 2009, DataQuill sent Apple a claim chart detailing how the iPhone
infringes DataQuill’s U.S. Patent No. 7,505,785 as well as a copy of another pending
and published DataQuill patent application.



On November 30, 2009, DataQuill sent Apple a letter including a copy of the
Reexamination Certificate for U.S. Patent No. 7,139,591 along with a claim chart
detailing how the iPhone infringes that patent. In this letter, DataQuill requested that
Apple consider purchasing a license to DataQuill’s patents.



On April 21, 2010, DataQuill sent Apple a copy of the Reexamination Certificate
issued for DataQuill’s U.S. Patent No. 6,058,304. In this letter, DataQuill again
requested that Apple consider purchasing a license to DataQuill’s patents.



On April 13, 2011, DataQuill sent Apple another letter requesting that Apple consider
taking a license to DataQuill’s portfolio.

This letter also included a copy of

DataQuill’s then-recently issued U.S. Patent. No. 7,920,898.


On May 16, 2011, DataQuill sent Apple another letter in which it provided a copy of
the Reexamination Certificate for DataQuill’s U.S. Patent No. 7,505,785 and yet
again requested that Apple consider purchasing a license.

10.

Notwithstanding DataQuill’s concerted efforts to resolve its claims against Apple

without litigation—and despite DataQuill’s extensive and successful history of licensing its

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portfolio to major players in the smartphone industry—Apple has declined to enter into a license
agreement with DataQuill.
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,058,304
11.

DataQuill incorporates the foregoing paragraphs as if fully set forth here.

12.

On May 2, 2000, the United States Patent & Trademark Office (“USPTO”) duly

and legally issued United States Patent No. 6,058,304 (“the ‘304 Patent”), entitled “Data Entry
System” to DataQuill Limited.

On April 13, 2010, the USPTO issued an Ex Parte

Reexamination Certificate for the ‘304 Patent. DataQuill owns the ‘304 Patent and holds the
right to sue and recover damages for infringement thereof.
13.

Apple has been and now is directly infringing the ‘304 Patent in the state of

Texas, in this judicial district, and elsewhere within the United States by making, using, offering
for sale, selling, and/or importing devices that infringe one or more claims of the ‘304 Patent,
including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5. Apple is thus
liable for infringement of the ‘304 Patent under 35 U.S.C. § 271(a).
14.

Apple has had knowledge of the ’304 Patent and Apple’s infringement thereof

since no later than April 14, 2009. On that date, DataQuill provided Apple with a claim chart for
the Apple iPhone describing how it infringes the ‘304 Patent. DataQuill also provided Apple
with a copy of the claim construction order issued in the Research in Motion case. Thereafter,
and on an on-going basis, DataQuill provided Apple with infringement charts and updates about
the issuance of new patents and reexamination certificates. For example, on April 21, 2010,
DataQuill sent Apple a letter informing it of the issuance of the ‘304 Patent’s Ex Parte
Reexamination Certificate.

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15.

With knowledge of the ‘304 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged its retailers to directly infringe the
‘304 Patent by offering to sell and selling these devices to end user consumers. Apple knew of
and intended to cause its retailers’ direct infringement and is therefore liable for inducing their
infringement of the ‘304 Patent under 35 U.S.C. § 271(b).
16.

With knowledge of the ‘304 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged end users to directly infringe the
‘304 Patent by using these devices. Apple has marketed, promoted, and instructed users to use
these devices in an infringing manner.

This marketing, promotion, and instruction has

specifically included instructions to use the App Store, iTunes, and iBooks functionality to
download apps, music, podcasts, audiobooks, and books. Apple knew of and intended to cause
its end users’ direct infringement and is therefore liable for inducing their infringement of the
‘304 Patent under 35 U.S.C. § 271(b).
17.

As a result of its infringement of the ‘304 Patent, Apple has damaged DataQuill.

Apple is liable to DataQuill in an amount to be determined at trial that adequately compensates
DataQuill for the infringement, which by law can be no less than a reasonable royalty.
18.

Because Apple knew of the ‘304 Patent and its infringement thereof (as detailed

above), Apple’s infringement of the ‘304 Patent is therefore willful and deliberate, entitling
DataQuill to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred
in prosecuting this action under 35 U.S.C. § 285.

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COUNT II: INFRINGEMENT OF U.S. PATENT NO. 7,139,591
19.

DataQuill incorporates the foregoing paragraphs as if fully set forth here.

20.

On November 21, 2006 the USPTO duly and legally issued United States Patent

No. 7,139,591 (“the ‘591 Patent”), entitled “Hand Held Telecommunications And Data Entry
Device” to DataQuill Limited.

On October 29, 2009, the USPTO issued an Ex Parte

Reexamination Certificate for the ‘591 Patent. The ‘591 Patent claims priority to and is entitled
to the filing date of the ‘304 Patent. DataQuill owns the ‘591 Patent and holds the right to sue
and recover damages for infringement thereof.
21.

Apple has been and now is directly infringing the ‘591 Patent in the state of

Texas, in this judicial district, and elsewhere within the United States by making, using, offering
for sale, selling, and/or importing devices that infringe one or more claims of the ‘591 Patent,
including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5. Apple is thus
liable for infringement of the ‘591 Patent under 35 U.S.C. § 271(a).
22.

Apple has had knowledge of the ’591 Patent and Apple’s infringement thereof

since no later than April 14, 2009. On that date, DataQuill provided Apple with a claim chart for
the Apple iPhone describing how it infringes the related ‘304 Patent. DataQuill also provided
Apple with a copy of the claim construction order issued in the RIM case. This order also
addresses the ‘591 Patent. Thereafter, and on an on-going basis, DataQuill provided Apple with
infringement charts and updates about the issuance of new patents and reexamination
certificates.

For example, on May 26, 2009, DataQuill sent Apple a letter concerning its

infringement that specifically identified the ‘591 Patent in the subject line.

Additionally,

DataQuill informed Apple of the issuance of the Ex Parte Reexamination Certificate for the ‘591

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Patent and provided Apple with a claim chart detailing its infringement of the ’591 Patent no
later than November 30, 2009.
23.

With knowledge of the ‘591 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged its retailers to directly infringe the
‘591 Patent by offering to sell and selling these devices to end user consumers. Apple knew of
and intended to cause its retailers’ direct infringement and is therefore liable for inducing their
infringement of the ‘591 Patent under 35 U.S.C. § 271(b).
24.

With knowledge of the ‘591 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged end users to directly infringe the
‘591 Patent by using these devices. Apple has marketed, promoted, and instructed users to use
these devices in an infringing manner.

This marketing, promotion, and instruction has

specifically included instructions to use the App Store, iTunes, and iBooks functionality to
download apps, music, podcasts, audiobooks, and books. Apple knew of and intended to cause
its end users’ direct infringement and is therefore liable for inducing their infringement of the
‘591 Patent under 35 U.S.C. § 271(b).
25.

As a result of its infringement of the ‘591 Patent, Apple has damaged DataQuill.

Apple is liable to DataQuill in an amount to be determined at trial that adequately compensates
DataQuill for the infringement, which by law can be no less than a reasonable royalty.
26.

Because Apple knew of the ‘591 Patent and its infringement thereof (as detailed

above), Apple’s infringement of the ‘591 Patent is therefore willful and deliberate, entitling

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DataQuill to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred
in prosecuting this action under 35 U.S.C. § 285.
COUNT III: INFRINGEMENT OF U.S. PATENT NO. 7,505,785
27.

DataQuill incorporates the foregoing paragraphs as if fully set forth here.

28.

On March 17, 2009, the USPTO duly and legally issued United States Patent No.

7,505,785 (“the ‘785 Patent”), entitled “Data Entry Systems” to DataQuill Limited. On May 10,
2011, the USPTO issued an Ex Parte Reexamination Certificate for the ‘785 Patent. The ‘785
Patent claims priority to and is entitled to the filing date of the ‘304 Patent. DataQuill owns the
‘785 Patent and holds the right to sue and recover damages for infringement thereof.
29.

Apple has been and now is directly infringing the ‘785 Patent in the state of

Texas, in this judicial district, and elsewhere within the United States by making, using, offering
for sale, selling, and/or importing devices that infringe one or more claims of the ‘785 Patent,
including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5. Apple is thus
liable for infringement of the ‘785 Patent under 35 U.S.C. § 271(a).
30.

Apple has had knowledge of the ‘785 Patent and Apple’s infringement thereof

since no later than May 13, 2009. On that date, DataQuill provided Apple with a claim chart for
the Apple iPhone describing how it infringes the ‘785 Patent. Thereafter, and on an on-going
basis, DataQuill provided Apple with infringement charts and updates about the issuance of new
patents and reexamination certificates. For example, on May 16, 2011, DataQuill sent Apple a
letter informing it of the issuance of the ‘785 Patent’s Ex Parte Reexamination Certificate.
31.

With knowledge of the ‘785 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged its retailers to directly infringe the
9

‘785 Patent by offering to sell and selling these devices to end user consumers. Apple knew of
and intended to cause its retailers’ direct infringement and is therefore liable for inducing their
infringement of the ‘785 Patent under 35 U.S.C. § 271(b).
32.

With knowledge of the ‘785 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged end users to directly infringe the
‘785 Patent by using these devices. Apple has marketed, promoted, and instructed users to use
these devices in an infringing manner.

This marketing, promotion, and instruction has

specifically included instructions to use the App Store, iTunes, and iBooks functionality to
download apps, music, podcasts, audiobooks, and books. Apple knew of and intended to cause
its end users’ direct infringement and is therefore liable for inducing their infringement of the
‘785 Patent under 35 U.S.C. § 271(b).
33.

As a result of its infringement of the ‘785 Patent, Apple has damaged DataQuill.

Apple is liable to DataQuill in an amount to be determined at trial that adequately compensates
DataQuill for the infringement, which by law can be no less than a reasonable royalty.
34.

Because Apple knew of the ‘785 Patent and its infringement thereof (as detailed

above), Apple’s infringement of the ‘785 Patent is therefore willful and deliberate, entitling
DataQuill to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred
in prosecuting this action under 35 U.S.C. § 285.
COUNT IV: INFRINGEMENT OF U.S. PATENT NO. 7,920,898
35.

DataQuill incorporates the foregoing paragraphs as if fully set forth here.

36.

On April 5, 2011, the USPTO duly and legally issued United States Patent No.

7,920,898 (“the ‘898 Patent”), entitled “Data Entry Systems” to DataQuill Limited. The ‘898
10

Patent claims priority to and is entitled to the filing date of the ‘304 Patent. DataQuill owns the
‘898 Patent and holds the right to sue and recover damages for infringement thereof.
37.

Apple has been and now is directly infringing the ‘898 Patent in the state of

Texas, in this judicial district, and elsewhere within the United States by making, using, offering
for sale, selling, and/or importing devices that infringe one or more claims of the ‘898 Patent,
including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5. Apple is thus
liable for infringement of the ‘898 Patent pursuant to 35 U.S.C. § 271(a).
38.

On May 14, 2009, DataQuill provided Apple with a copy of the published patent

application that issued as the ‘898 Patent. On November 30, 2009, DataQuill provided Apple
with a re-published copy of the application that issued as the ‘898 Patent. DataQuill is thus also
entitled to a reasonable royalty for Apple’s making, using, offering for sale, selling, and
importing into the United States the invention claimed in the published patent applications and
substantially identical inventions claimed in the ‘898 Patent under 35 U.S.C. § 154(d).
39.

Apple has had knowledge of the ‘898 Patent and Apple’s infringement thereof

since no later than May 14, 2009. On that date, DataQuill provided Apple with a copy of the
published patent application that resulted in the ‘898 Patent. Thereafter, and on an on-going
basis, DataQuill provided Apple with infringement charts and updates about the issuance of new
patents and reexamination certificates. For example, DataQuill sent Apple a letter informing it
of the issuance of the ‘898 Patent on April 13, 2011.
40.

With knowledge of the ‘898 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged its retailers to directly infringe the
‘898 Patent by offering to sell and selling these devices to end user consumers. Apple knew of
11

and intended to cause its retailers’ direct infringement and is therefore liable for inducing their
infringement of the ‘898 Patent under 35 U.S.C. § 271(b).
41.

With knowledge of the ‘898 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged end users to directly infringe the
‘898 Patent by using these devices. Apple has marketed, promoted, and instructed users to use
these devices in an infringing manner.

This marketing, promotion, and instruction has

specifically included instructions to use the App Store, iTunes, and iBooks functionality to
download apps, music, podcasts, audiobooks, and books. Apple knew of and intended to cause
its end users’ direct infringement and is therefore liable for inducing their infringement of the
‘898 Patent under 35 U.S.C. § 271(b).
42.

As a result of its infringement of the ‘898 Patent, Apple has damaged DataQuill.

Apple is liable to DataQuill in an amount to be determined at trial that adequately compensates
DataQuill for the infringement, which by law can be no less than a reasonable royalty.
43.

Because Apple knew of the ‘898 Patent and its infringement thereof (as detailed

above), Apple’s infringement of the ‘898 Patent is therefore willful and deliberate, entitling
DataQuill to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred
in prosecuting this action under 35 U.S.C. § 285.
COUNT V: INFRINGEMENT OF U.S. PATENT NO. 8,290,538
44.

DataQuill incorporates the foregoing paragraphs as if fully set forth here.

45.

On October 16, 2012, the USPTO duly and legally issued United States Patent

No. 8,290,538 (“the ‘538 Patent”), entitled “Data Entry Systems” to DataQuill Limited. The

12

‘538 Patent claims priority to and is entitled to the filing date of the ‘304 Patent. DataQuill owns
the ‘538 Patent and holds the right to sue and recover damages for infringement thereof.
46.

Apple has been and now is directly infringing the ‘538 Patent in the state of

Texas, in this judicial district, and elsewhere within the United States by making, using, offering
for sale, selling, and/or importing devices that infringe one or more claims of the ‘538 Patent,
including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5. Apple is thus
liable for infringement of the ‘538 Patent pursuant to 35 U.S.C. § 271(a).
47.

On information and belief, Apple has had knowledge of the ‘538 Patent and

Apple’s infringement thereof since no later than its issuance on October 16, 2012. As described
in the preceding paragraphs, DataQuill and Apple have an extensive history of correspondence
that demonstrates that Apple was familiar with DataQuill’s patent portfolio. At a minimum,
Apple has had knowledge of the ‘538 Patent and its infringement thereof since no later than the
filing of this lawsuit.
48.

With knowledge of the ‘538 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged its retailers to directly infringe the
‘538 Patent by offering to sell and selling these devices to end user consumers. Apple knew of
and intended to cause its retailers’ direct infringement and is therefore liable for inducing their
infringement of the ‘538 Patent under 35 U.S.C. § 271(b).
49.

With knowledge of the ‘538 Patent and knowledge of the infringing nature of its

devices including the iPhone, iPhone 3G, iPhone 3GS, iPhone 4, iPhone 4S, and iPhone 5 (or, at
a minimum, willful blindness thereto), Apple has encouraged end users to directly infringe the
‘538 Patent by using these devices. Apple has marketed, promoted, and instructed users to use
13

these devices in an infringing manner.

This marketing, promotion, and instruction has

specifically included instructions to use the App Store, iTunes, and iBooks functionality to
download apps, music, podcasts, audiobooks, and books. Apple knew of and intended to cause
its end users’ direct infringement and is therefore liable for inducing their infringement of the
‘538 Patent under 35 U.S.C. § 271(b).
50.

As a result of its infringement of the ‘538 Patent, Apple has damaged DataQuill.

Apple is liable to DataQuill in an amount to be determined at trial that adequately compensates
DataQuill for the infringement, which by law can be no less than a reasonable royalty.
51.

On information and belief, Apple knew of the ‘538 Patent and its infringement

thereof (as detailed above), and Apple’s infringement of the ‘538 Patent is therefore willful and
deliberate, entitling DataQuill to increased damages under 35 U.S.C. § 284 and to attorneys’ fees
and costs incurred in prosecuting this action under 35 U.S.C. § 285.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff DataQuill prays for the following relief:
52.

A judgment in favor of DataQuill that Apple has infringed the ‘304, ‘591, ‘785,

‘898, and ‘538 Patents;
53.

A judgment in favor of DataQuill that Apple’s infringement of the ‘304, ‘591,

‘785, ‘898, and ‘538 Patents was willful and that DataQuill is therefore is entitled to treble
damages and attorney fees under 35 U.S.C. § 284 and 35 U.S.C. § 285;
54.

A judgment and order requiring Apple to pay DataQuill damage for its

infringement of the ’304, ‘591, ‘785, ‘898, and ‘538 Patents, together with interest (both preand post-judgment), costs and disbursements as fixed by this Court under 35 U.S.C. § 284 and 35
U.S.C. § 285;
14

55.

A judgment and order finding that this is an exceptional case within the meaning

of 35 U.S.C. § 285 and awarding to DataQuill its reasonable attorney’s fees; and
56.

Such other and further relief in law or in equity to which DataQuill may be justly

entitled.
DEMAND FOR JURY TRIAL
57. Plaintiff demands a trial by jury of any and all issues triable of right before a jury.

Dated: August 16, 2013

Respectfully submitted,
Parker C. Folse, III (by permission Douglas R. Wilson)

Parker C. Folse, III (LEAD COUNSEL)
Washington State Bar No. 24895
[e-mail]
SUSMAN GODFREY LLP
1201 Third Avenue, Suite 3800
Seattle, Washington 98101
Telephone:
[phone]
Facsimile:
[phone]
Joseph S. Grinstein
Texas Bar No. 24002188
[e-mail]
SUSMAN GODFREY LLP
1000 Louisiana Street, Suite 5100
Houston, Texas 77002-5096
Telephone:
[phone]
Facsimile:
[phone]
Leslie V. Payne
Texas Bar No. 00784736
[e-mail]
Michael F. Heim
Texas Bar No. 09380923
[e-mail]
Nathan J. Davis
Texas Bar No. 24065122
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[e-mail]
Robert Allan Bullwinkel
Texas Bar No. 24064327
[e-mail]
HEIM, PAYNE & CHORUSH, LLP
600 Travis Street, Suite 6710
Houston, Texas 77002-2912
Telephone: [phone]
Facsimile: [phone]
Douglas R. Wilson
Texas Bar No. 24037719
[e-mail]
HEIM, PAYNE & CHORUSH, LLP
9442 Capital of Texas Hwy North
Plaza 1, Suite 500-146
Austin, TX 78759
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR DATAQUILL LIMITED

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