Freedom Scientific v. Aumed - M.D. Fla.

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION

FREEDOM SCIENTIFIC, INC,
a Delaware Corporation,

Plaintiff,

vs. Case No. _____________________

AUMED, INC.,
a California Corporation,

and AUMED GROUP CORP.,
a Foreign corporation,

Defendants.
_____________________________________ /

COMPLAINT

Freedom Scientific, Inc., a Delaware corporation (Freedom Scientific), sues
Defendants Aumed, Inc. and Aumed Group Corp. (collectively Aumed) and alleges as follows:
PARTIES
1. Freedom Scientific is a Delaware corporation with a principal place of business at
11800 31st Court North, Saint Petersburg, Pinellas County, Florida 33716.
2. Defendant Aumed, Inc. is a California corporation with a principal place of
business at 131 Glenn Way, Unit 5, San Carlos, CA 94070.
3. Defendant Aumed Group Corp. is a foreign corporation with a principal place of
business in 3/F Building D No. 31, J iaoda Dong Road, Haidian District, Beijing 100044, China.

1
Case 8:13-cv-02495-MSS-MAP Document 1 Filed 09/27/13 Page 1 of 25 PageID 1
JURISDICTION
4. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
1331 & 1338(a). Further, this Court possesses subject matter jurisdiction over this action
insofar as the matter in controversy exceeds the sum or value of $75,000, exclusive of interest
and costs, and is between citizens of different States as provided in 28 U.S.C. 1332(a)(1).
7. This Court has personal jurisdiction over the Defendants pursuant to Fla. Stat.
48.193(1)(a), (b) and (f) & (2). Specifically, Defendants have committed a tortious act within
the State of Florida by, inter alia, selling or offering to sell a product which infringes upon
patents held by Freedom Scientific.
8. Venue is properly placed in this district and division pursuant to 28 U.S.C.
1391(b), and Local Rule 1.02(c), M.D. Fla. Local Rules.
BACKGROUND
9. United States Design Patent No. D624,107, entitled Hand Held Multi Position
Magnifier Camera, was duly filed on J une 5, 2009, and was issued by the U.S. Patent and
Trademark Office on September 21, 2010, naming as assignee Plaintiff, Freedom Scientific,
Inc. A true copy of the 107 Design Patent is attached as Exhibit A to this Complaint and
incorporated by reference.
10. The 107 Design Patent currently is, and at all relevant times in the past has
been, in full force and effect.
11. United States Utility Patent No. 8,264,598, entitled Multiposition Handheld
Electronic Magnifier, was duly filed on J une 5, 2009, and was issued by the U.S. Patent and
Trademark Office on September 11, 2012, naming as assignee Plaintiff, Freedom Scientific,
Inc. A true copy of the 598 Utility Patent is attached as Exhibit B to this Complaint and

2
incorporated by reference.
12. The 598 Utility Patent currently is, and at all relevant times in the past has
been, in full force and effect.
13. Based on the 107 Design Patent and the 598 Utility Patent, Freedom
Scientific developed and sells the RUBY
Handheld Video Magnifier (RUBY), a portable

handheld video magnifier.
14. To use the RUBY
, a user places it over an object, and adjusts magnification

with the zoom button. The RUBY
stays flat on the table or can be held over the reading

material with the fold-away handle. The magnified image or text appears in the display
window. Additionally, the RUBY
can be converted into a conventional magnifying glass by

flipping out the handle.
15. The design and use of the RUBY
is depicted in the below images:

3
16. Defendants currently sell the Image handheld video magnifier (Image),
which is virtually identical in design and function to the RUBY
. The design and use of the

RUBY
is depicted in the below images:

17. Defendants have advertised, promoted, marketed, offered to sell and, upon
information and belief, sold the Image, which infringes upon the 107 Design Patent and the
598 Utility Patent.
18. Freedom Scientific has been damaged by Defendants infringing activities and
will be irreparably injured unless such infringing actions are enjoined by this Court.
19. Freedom Scientific has no adequate remedy at law to prevent such injury.
20. Given Defendants clear infringement of Freedom Scientifics intellectual
property rights, Freedom Scientific will likely prevail upon the merits of this action.
21. The balance of the hardships and the public interest require that Defendants
immediately cease its infringing activities.
22. All conditions precedent to Freedom Scientifics maintenance of this action
have occurred, have been performed, or have been excused or waived.
23. Freedom Scientific has retained the law firm of Gray Robinson P.A. to
vindicate its rights against Defendants, and Freedom Scientific is obligated to pay its attorneys
a reasonable attorneys fee for their services.

4
COUNT I- INFRINGEMENT OF U.S. DESIGN PATENT D624,107
24. Freedom Scientific incorporates by reference and realleges the allegations of
paragraphs 1 through 23 as though fully set forth herein.
25. Defendants, without authority or consent from Freedom Scientific, are directly
infringing the claim of the 107 Design Patent by manufacturing, distributing, offering to sell,
importing and/or selling the Image, which misappropriates or colorably imitates the design
covered by the claim in the 107 Design Patent.
26. Defendants handheld video magnifier would cause an ordinary person to be
deceived and/or induced into purchasing the Image supposing it to be the RUBY
.
27. Defendants infringing conduct is willful, malicious and in conscious disregard
of Freedom Scientifics rights under the 107 Design Patent.
28. Defendants activities described above constitute infringement of Freedom
Scientifics federally protected patent rights in the 107 Design Patent and violate 35 U.S.C.
271.
29. As a result of the acts of Defendants infringement of the 107 Design Patent,
Freedom Scientific has suffered and continues to suffer damages, and Freedom Scientific is
entitled to all remedies provided by Chapter 29 of Title 35, United States Code.
30. Unless temporarily restrained, preliminary and permanently enjoined from
infringing the 107 Design Patent, Freedom Scientific will continue to suffer irreparable harm
from which it has no adequate remedy at law.

5
COUNT II- INFRINGEMENT OF U.S. UTILITY PATENT 8,264,598
31. Freedom Scientific incorporates by reference and realleges the allegations of
paragraphs 1 through 23 as though fully set forth herein.
32. Defendants, without the authority or consent from Freedom Scientific, are
directly infringing the 598 Utility Patent by manufacturing, distributing, offering to sell,
importing and/or selling the Image.
33. Defendants infringing conduct is willful, malicious and in conscious disregard
of Freedom Scientifics rights under the 598 Utility Patent.
34. As a result of the acts of Defendants infringement of the 598 Utility Patent,
Freedom Scientific has suffered and continues to suffer damages, and Freedom Scientific is
entitled to all remedies provided by Chapter 29 of Title 35, United States Code.
35. Unless temporarily restrained, preliminary and permanently enjoined from
infringing the 598 Utility Patent, Freedom Scientific will continue to suffer irreparable harm
from which it has no adequate remedy at law.
WHEREFORE, Plaintiff, Freedom Scientific, Inc. a Delaware corporation, prays for
relief as follows:
A. That the Court adjudge that Defendants have infringed on the 107 Design Patent
and 598 Utility Patent;
B. That the Court adjudge that Defendants infringement of the 107 Design Patent
and 598 Utility Patent has been willful and deliberate;
C. That the Court permanently enjoin Defendants from manufacturing, distributing,
offering to sell, importing and/or selling the Image;

6
D. That the Court award Plaintiff its damages in accordance with 35 U.S.C. 284,
and increase those damages up to three (3) times by reason of the willful and deliberate
infringement;
E. That the Court award Plaintiff the Defendants total profits realized from the
infringement of the 107 Design Patent in accordance with 35 U.S.C. 289
F. That the Court award Plaintiff its costs in connection with this action;
G. That the Court declare the patent infringement claims herein to be an
exceptional case within the meaning of 35 U.S.C. 285, and award Plaintiff its reasonable
attorney fees, expenses and costs in this action;
H. That the Court award Plaintiff such other and further relief as the Court may deem
to be just and proper.
DEMAND FOR JURY TRIAL
Freedom Scientific hereby demands a trial by jury on all issues so triable.
Respectfully submitted this 26
th
day of September of 2013.

/s/Kevin P. Crosby
KEVIN P. CROSBY, ESQ.
Florida Bar No. 654360
GrayRobinson, P.A.
401 E. Las Olas Blvd., Ste. 1000
Ft. Lauderdale, FL 33301
(954)-761-8111
(954)-761-8112

Attorneys for Plaintiff

#4298516 v1

7
EXHIBIT A
111111 1111111111111111111111111111111111111111111111111111111111111
c12) United States Design Patent
Goldenberg
(54) HAND HELD MULTI POSITION MAGNIFIER
CAMERA
(75) Inventor: Michael Goldenberg, Melbourne Beach,
FL (US)
(73) Assignee: Freedom Scientific, Inc., St. Pcterburg,
FL (US)
(**) Term: 14 Years
(21) Appl. No.: 29/338,154
(22) Filed: Jnn.5,2009
(51) LOC (9) Ct. . ................................................. 16-01
(52) U.S. CI ................ D161211; 014/138 G; D16/l35;
D16/200
(58) Field of Classification Search ............ 014/138 G;
(56)
D16/130, 200,201,208,211, 219; 348/63,
348/333.06,333.07, 373, 376; 359/802;
396/535-541
See application file for complete search history.
References Cited
U.S. PATENT DOCUMENTS
D374,227 s *
7,172,305 B2 *
7,194,290 B2 *
D543,569 S *
7,495,700 B2 *
7,605,862 B2 *
10/1996 Williams ............... DJ41138 G
2/2007 Rodriguez et al. .......... 359/802
3/2007 Ma1sunami ................. 348/373
5/2007 Clarketal ................. Dl6/211
212009 Watanabe ................... 348/376
10/2009 Hou ........................... 348/373
2007/0229989 AI* 10/2007 Scott et al. .................. 359/802
* cited by examiner
Primary Examiner-Adir Aronovich
(74) Attorney, Agent, or Firm Michael .1. Colitz, lll; Gray
Robinson, P.A.
USOOD624107S
(10) Patent No.: US D624,107 S
** Sep. 21, 2010 (45) Date of Patent:
(57) CLAIM
The ornamental design for a hand held multiple position
magnifier camera, as shown and described.
DESCRIPTION
FIG. 1 is a front elevational view of a hand held multiple
position magnifier camera of the present invention;
FIG. 2 is a rear elevational view of the hand held magnifier
camera of the present invention;
FIG. 3 is a side elevational view of the hand held magnifier
FIG. 4 is a side elevational view (opposite of that shown in
FIG. 3) of the hand held multiple position magnifier camera
of the present invention;
FIG. 5 is a top plan view of the hand held magnifier camera of
the present invention;
FIG. 6 is a bottom plan view of the hand held magnifier
FlO. 7 is a front prospective view of the hand held magnifier
FIG. 8 is a rear prospective view of the hand held magnifier
FIG. 9 is a top perspective view of the hand held magnifier
camera in its folded orientation;
FIG. 10 is a bottom perspective view of a hand held magnifier
cam em in its folded orientation;
FIG. 11 is a rear perspective view of the hand held magnifier
camera in its partially J(J]ded orientation; a n ~
FIG. 12 is a front perspective view of the hand held magnifier
camera in its partially folded orientation.
1 Claim, 5 Drawing Sheets
U.S. Patent Sep.21,2010 Sheet 1 of 5 US D624, 107 S
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Sep.21,2010
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Sheet 2 of 5 US D624,107 S
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FIG. 6
U.S. Patent Sep.21,2010 Sheet 3 of 5
US D624,107 S
U.S. Patent Sep. 21, 2010 Sheet 4 of 5 US D624,107 S
FIG. 9
FIG. 10
U.S. Patent Sep. 21, 2010 Sheet 5 of 5 US D624,107 S
EXHIBITB
c12) United States Patent
Rodriguez et al.
(54) MULTIPOSITION HANDHELD ELECTRONIC
MAGNIFIER
(75) Inventors: Carlos M. Rodriguez, Palm Harbor, FL
(US); Patrick Murphy, Riverview, FL
(US); Waldemar Tunkis, Palm Harbor,
FL (US); Todd Conard, Ruskin, FL
(US); Michael Goldenberg, Melbourne,
FL (US); .Jeffrey McDaniel, Largo, FL
(US)
(73) Assignee: Freedom Scientific, Inc., St. Petersburg,
FL (US)
( *) Notice: Subject to any disclaimer, the term of this
patent is extended or adjusted under 35
U.S.C. 154(b) by 235 days.
(21) Appl. No.: 12/478,993
(22) Filed: .J1m. 5, 2009
(65) Prior Publication Data
US 2010/0073545 Al Mar. 25, 2010
Related U.S. Application Data
(63) Continuation-in-part of application No. 12/235,182,
filed on Sep. 22, 2008.
(51) Int.CI.
H04N51225 (2006.01)
(52) U.S. CJ. ....... .. ........................... 348/373
(58) Field of Classification Search ................... 348/373
(56)
See application file for complete search history.
References Cited
U.S. PATENT DOCUMENTS
3,252,067 A
3,253,529 A
3,850,523 A
511966 Derenbechcr, Jr.
511966 Fah1enberg
111197 4 Skavnak
111111111111111111111111111111111111111111111111111111111111111111111111111
EP
US008264598B2
(JO) Patent No.: US 8,264,598 B2
Sep. 11,2012 (45) Date of Patent:
4,362,806 A
4,456,931 A
4,799,049 A
5,335,192 A
5,633,674 A
5,703,661 A
5,717,964 A
5,739,859 A
5,748,228 A
5,815,735 A
5,893,651 A
D454,146 S
6,636,359 B2
6,642,505 B 1
D488,440 S
6,767,107 B1
6,809,741 B1
D503,944 S
6,956,616 B2
6,971,600 B2
6,971,700 B2
6,977,676 B 1
7,106,357 B2 *
7,119,319 B2
7,170,557 132
12/1982 Whitmore
611984 Toyoda et al.
1/1989 Avila
8/1994 Oshiba
511997 Trulaske et al.
12/1997 Wu
2/1998 Dowe
411998 Hattori et al.
511998 Kobayashi et al.
9/1998 Baker
4/1999 Sakamoto
3/2002 Mori
10/2003 Travers et al.
11/2003 Nakano eta!.
4/2004 Senda
7/2004 Leifer et al.
I 0/2004 Bates et al.
4/2005 Adachi eta!.
I 0/2005 Jung et al.
12/2005 Cheung
12/2005 B1anger et al.
12/2005 Sato et a!,
912006 Fukuda el al. ............. 348/14.02
10/2006 No to et al.
112007 Manico et al.
(Continued)
FOREIGN PATENT DOCUMENTS
1921838 A2 5/2008
(Continued)
Primary James Hannett
(74) Attorney, Agent, or Gray Robinson, P.A.;
Michael J. Colitz, III
(57) ABSTRACT
Disclosed is a magnifier for use by blind or low vision users.
The magnifier includes a camera, such as a CMOS image
sensor, that displays enlarged images upon a screen for easy
viewing. The magnifier further includes a handle that is piv-
otally interconnected to a housing to allow for handheld use in
a variety of different configurations.
7 Claims, 5 Drawing Sheets
-32
lit +
US 8,264,598 B2
Page 2
U.S. PATENT DOCUMENTS 200610158427 A1 7/2006 Goldenberg et al.
2006/0268569 A1 11/2006 Rodriguez et al.
7,172,304 B2 2/2007 Rodriguez et al.
2007/0018919 A1 1/2007 Zavracky et al.
7,172,305 B2 2/2007 Rodriguez et al.
2007/0040907 AI 2/2007 Kern et al.
7,295,244 B2 I112007 Manica eta!.
2007/0223906 AI 9/2007 Hanney et al.
7,336,295 B2 2/2008 Sukenari et al.
2007/0263014 A1 1112007 Keto1aet al.
D614,220 S 4/2010 Goldenberg
2007/0273708 A1 1112007 Andreasson et al.
8,115,831 132 212012 RodJiguez et al.
2007/0296845 A1 12/2007 Watanabe et al.
200110002850 A1 612001 Slatter
2008/0165141 A1 7/2008 Christie
2002/0063791 A 1 512002 Waterman et al.
2009/0059038 A1 3/2009 Sealcins el al.
200210071047 A1 612002 Strong et al.
2009/0160996 A 1 6/2009 Yamaoka et al.
200310063214 A1 412003 Van Hees
201010026854 A1 2/2010 Rodriguez et al.
200310210340 A1 1112003 Frederick Romanowich
201010026855 A1 2/2010 Conard et al.
200410246340 A I 1212004 Sukenari et al.
200510141099 A1 6/2005 Bang et al.
FOREIGN PATENT DOCUMENTS
200510162512 A1 712005 Sealcins
GB 2403370 A 1212004
200610018508 A 1 112006 Monk eta!.
200610034601 A 1 212006 Andersson et al. * cited by examiner
U.S. Patent Sep. 11, 2012 Sheet 1 of 5 US 8,264,598 B2
(D\_52
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US 8,264,598 B2
1
MULTIPOSITION HANDHELD ELECTRONIC
MAGNIFIER
2
BRIEF DESCRIPTION OF TI-lE DRAWINGS
RELATED APPLICATION DATA
TI1is is a continuation-in-part of co-pending application
Ser. No. 12/235,182 filed on Sep. 22, 2008 and entitled "Por-
table Multi Position Magnifier Camera", the contents of
which are fully incorporated herein by reference.
For a fuller understanding of the nature and objects of the
invention, reference should be had to the following detailed
5 description taken in connection with the accompanying draw-
ings in which:
FIG. 1 is front plan view of the magnifier of the present
invention.
FIG. 2 is a back plan view of the magnifier of the present
10
invention.
BACKGROUND OF THE INVENTION
l. Field of the Invention
This invention relates to a magnification device for indi-
15
vi duals with low vision. More particularly, the present inven-
tion relates to a handheld magnification device that has a
variety of discrete configurations.
2. Description of the Background Art
The use of electronic magnifiers for low vision users is
20
known in the art. To date, however, these magnifiers have
been heavy, bulk')', and cumbersome to use. Additionally,
many of these magnifiers have only one mode of operation, a
mode that requires the user to hold the device at a fixed
distance above the object being viewed. Prior art magnifiers 25
also suffer from lack portability, which is problematic for
users who may need assistance viewing objects when they are
away from a traditional magnifier.
What is needed, then, is a magnifier with multiple configu-
rations and modes of operation, whereby a user can use the
30
magnifier by either holding the device relative to the object or
by placing the device upon the object itself. There is an
additional need for a magnifier that allows users to interact
with the object while it is being magnified. There is also a
35
need in the art for a magnifier that is handheld and easily
transportable.
The portable multi position magnifier camera of the
present invention is directed at fulfilling these needs.
SUMMARY OF TilE INVENTION
40
It is therefore one of the objectives of this invention to
allow a user to configure a magnifier camera into one of a
variety of viewing modes so as to optimize the viewing of
45
different sized objects at differing distances.
It is another objective of this invention to provide a mag-
nifier camera that can either be held in front of an object to be
viewed or positioned upon the object to be viewed.
It is yet another objective of tlus invention to provide a so
magnifier camera that has is hand-held, compact, and readily
transportable.
TI1e foregoing has outlined rather broadly the more perti-
nent and important features of the present invention in order
that the detailed description oft he invention that follows may 55
be better understood so that the present contribution to the art
can be more fully appreciated.
Additional features of the invention will be described here-
inafter which form the subject of the claims of the invention.
FIG. 3 is a perspective view of the front of the magnifying
apparatus.
FIG. 4 is a perspective view of the back of the magnifying
apparatus.
FIG. 5 is a side view illustrating the various orientations of
the magnifYing apparatl1s.
FIG. 6 is a view of the magnifYing apparatus in its first
orientation.
FIG. 7 is a view of the magnifYing apparatus in its third
orientation.
FIG. 8 is a view of the magtlif)'ing apparatus in its second
orientation.
FIG. 9 is a cross sectional view showing the internal light
chamber of the handle.
FIG. 10 is a side view of the magnifier illustrating the light
being directed to a focal point beneath the housing.
FIG. 11 is a perspective and partially exploded view of the
magnifier cam em with the battery cover removed.
Similar reference characters refer to similar parts through-
out the several views of the drawings.
PARTS LIST
20 Magnifier Device 52 LEDs
22 Housing 54 Focal Point
24 Handle 56 Object Being Viewed
26 Front Face (Housing) 58 Front Face (Handle)
28 Back Face (Housing) 62 Back Face (Handle)
.12 Peripheral Edge (Housing) 64 Peripheml Edge (Handle)
.14 Sensor 66 Aperture (Handle)
36 Aperture (Housing) 68 Light Guides (Handle)
38 Screen 72 Opening (Handle)
42 Power Button 74 Battery Door
44 Camera Button 76 Batteries
46 Zoom Button 78 Light Chamber
48 Mode Control Button 82 Angled Swfaces (Chamber)
R4 Battery Compartments
DETAILED DESCRIPTION OF THE PREFERRED
EMBODIMENT
The' present invention relates to a magnifier device for use
by blind or low vision users. The magnifier includes a ca111era
that can display enlarged images oftarget objects for viewing
by the user. The magnifier device further includes a handle
that is pivotally interconnected to a housing to thereby allow
the device to be configured in a number of different configu-
rations. T11e various features of the present invention, and the
60 manner in which they interrelate, will be described in greater
detail hereinafter.
It should be appreciated by those skilled in the art that the
conception and the specific embodiment disclosed may be
readily utilized as a basis for modifying or designing other
stmctures for carrying out the same purposes of the present
invention. It should also be realized by those skilled in the art
that such equivalent constructions do not depart from the 65
spirit and scope of the invention as set forth in the appended
claims.
With reference to FIGS. 1-4, the housing 22 and intercon-
nected handle 24 of the magnifier 20 are illustrated. These
components are preferably fanned from an impact resistant
plastic, such as an acrylonitrile butadiene styrene (ABS) plas-
tic, or an equivalent thereof. Handle 24 and housing 22 are
engaged with one another about an axis to thereby permit
US 8,264,598 B2
3
rotation of handle 24. As noted more fully hereinafter, mag-
nifier 20 takes on various configurations based upon the angle
of handle 24.
Housing 22 is defined by front and back faces (26 and 28,
respectively) and an associated peripheral edge 32. With ref- 5
erence to FIG. 2, the camera for use with the magnifier is
depicted. In the preferred embodiment, camera is a 3 mega-
pixel CMOS sensor 34. Such sensors are commercially avail-
able and those of ordinary skill in tht! art will appreciate
suitable equivalents thereto. With continuing reference to
10
FIG. 2, it is seen that the sensor 34 includes an aperture that is
aligned with an aperture 36 on the back face 28 ofhousing 22.
The output from sensor 34 is supplied to a field programmable
gate array (FPGA) and an image buffer. Additionally, images
15
captured by sensor 34 can be stored in non-volatile memory to
be recalled later by the user. The images can be processed by
the imaging method described in commonly owned and co-
pending application entitled "System and Method for Imag-
ing Objects" (app. No. 61/099,185) filed on Sep. 22, 2008. 20
The contents of this co-pending application are fully incor-
porated herein.
Stored images, or images currently viewed with sensor 34,
can be displayed on screen 38. In the depicted embodiment,
an LCD screen38 is employed. Screen 38 is ideally recessed 25
within front face 26 of housing 22. As such, a peripheral edge
32 is inwardly beveled. The LCD screen 38 is a full color
video graphics array (VGA) display. Low-voltage differential
signaling (LVDS) can be used to intercotmect the LCD screen
38 to the FPGA and/or image buffer as noted above. This 30
arrangement ensures a purely digital output on LCD screen
4
With reference again to FIGS. 1-4, handle 24 of the device
20 is described. Handle 24 is defined by a front face 58, a back
face 62, and a peripheral edge 64 therebetween. An aperture
66 and a pair of light guides 68 are formed within back face
62. Additionally, an opening 72 formed is within front face 58
and is positioned such that it is in alignment with aperture 66.
As noted in PIG. 11, handle 24 filrther includes a battery door
74. The edges of battery door 74 are designed to slide into
corresponding grooves within the peripheral edges 64 of
handle 24. Door 74 serves to enclose batteries 76 that are
positioned within handle 24 and which power device 20. In
the depicted embodiment, four "AA'' batteries 76 are used.
Handle 24 also includes an internal light chamber 78.
Chamber 78 is most easily seen in the cross sectional view of
FIG. 9. As described more fully hereinafter, light chamber 78
directs light from LEDs 52 to the object being viewed 56. One
suitable light chamber is described in commonly owned U.S.
Pat. No. 7,172,304 to Rodriguez et. al., the contents of which
are fully incorporated herein. Whatever type oflight chamber
is utilized, it should include angled surfaces that are lightly
colored to promote maximum light reflection and diffusion.
In the preferred embodiment, light chamber 78 is white and
includes angled surfaces 82 that are positioned immediately
below light guides 68. With continuing reference to FIG. 4, it
is seen that battery compartments 84 are positioned on either
side of light chamber 78.
By pivoting handle 24 with respect to housing 22, magni-
fier 20 can be brought into a number of different orientations.
The user can select the desired orientation for optimal view-
ing. The various magnifier orientations are described below in
connection with FIGS. 5-8.
First Orientation
The first orientation oftl1e magnifier 20 is depicted in FIG.
1. This orientation is defined by housing 22 and handle 24
38 and also permits magnifier 20 to be ust!d with an external
monitor (not shown). Thus, by way of the LCD screen 38,
objects within range of sensor 34 can be selectively displayed
and digitally enlarged for the blind or low-vision user. 35 being in alignment with one another. Namely, the angle
between housing 22 and handle 24 is 180, or approximately
180. This orientation is preferred when magnifier 20 is used
to view objects 56 at a distance or when the user otherwise
With reference to FIG. 1, the magnifier controls are illus-
tratt!d. Controls are included for: power 42, camera/sensor 44,
zoom 46, and mode 48. Power blJtton 42 is used to tum the
device 20 on and off. Camera button 44 is used to activate
sensor 34 and also to take "snap shots" of the object being 40
viewed. Depressing the control the first time activates sensor
34 such that the images within range are displayed on LCD
screen 38. Depressing the control again captures tht! images
and stores it in memory for later viewing. Zoom button 46 is
used to change the magnification employed by sensor 34. For 45
instance, by cycling zoom button 46, the user can select a
suitable magnification level. In the preferred embodiment,
magnification between 5x to 15x are possible. Finally, mode
control 48 can be used to change the colm combinations
displayed upon screen 38. For instance, the screen can display so
objects in various color combinations, such as blue/green,
red/yellow, or black/white. These color combinations can be
cycled through m1til the user finds the mode effective output.
Light sources are also mounted to back face 28 of housing
22. In the preferred embodiment, these light sources are light 55
emitting diodes (LEDs) 52. Other light sources, however,
such as cold cathode fluorescent lan1ps (CCFLs) can alterna-
tively be used. With particular reference to FIGS. 9 and 10, it
can be seen that LEDS 52 are preferably mounted at an angle
relative to the plane of housing 22. The depicted angle is 60
approximately 45. The back face 28 is raised about the LEDs
52 to thereby shield the LEDs 52 from damage. As illustrated,
LEOs 52 are angled such that the emitted light emitting con-
verges on a focal point 54. Preferably, focal point 54 is located
at or near the object being viewed 56. LEOs 52 can be selec- 65
tively illuminated depending upon ambient lighting condi-
tions.
does not need both hands free. In the orientation, the user
holds magnifier 20 by grasping handle 24 and pointing sensor
34 at an object 56. The user's free hand can then be used to
operate the controls to, for example, zoom in on the object
(but1Dn 46), or take a snap shot (buHon 44). In this orientation,
objects arc viewed through the bottom of housing 22, while
handle 24 is used to grasp the device 20.
Second Orientation
The second orientation of the magnifier 20 is depicted in
FIG. 8. Here, handle 24 and housing 22 are positioned at an
angleofless than 180. In the depicted embodiment, housing
22 is positioned at a 90 angle relative to handle 24. When so
configured, handle 24 can be positioned upon a surface, such
as a table, and objects 56 can be placed in front of camera 34.
Magnifier 20 can maintain tllis position because handle 24 is
substantially heavier than housing 22 insomuch as handle 24
houses batteries. By positioning the device 20 on a table, the
user is free to use both hands, as may be preferred if the object
56 needs to be ma!lipulated in front of camera sensor 34.
Thereafter, the user can utilize the controls to zoom in (button
46) and capture desired images (camera button 44).
'lbird Orientation
FIG. 7 illustrates the third orientation. Here, the back faces
(28, 62) of the housing and handle (22, 24) are brought
together, such that they are in facing relation to one another. In
other words, the angle between housing 22 and handle 24 is
0, or approximately 0. This orientation is preferred when
magnifier 20 is to be positioned directly over an object 56.
This includes resting magnifier 20 directly upon a flat object
US 8,264,598 B2
5
56 such as a document. In this configuration, sensor 34 is
viewing the object through the aperture 36 in housing 22, as
well as aperture and opening (66, 72) in handle 24, Further-
more, in the third orientation, the LEDs 52 are brought into
registry with light guides 68 in handle 24. Thus, LEDs 52
direct light through light guides 68, into light chamber 78, and
out through opening 72. In this manner, LEDs 52 can effec-
tively illuminate the object being viewed 56.
6
back faces of the housing and handle are brought
together, such that the handle can be positioned over top
of the object being viewed;
whereby the third orientation permits the camera to view
objects through the apertures and the opening, and
directs light from the LEDs, through the light guides,
into the light chamber, and out through the opening to
thereby ilhnninate the object being viewed.
2. A handheld magnifier to assist blind or low vision users
1 o in viewing objects, the magnifier comprising:
The present disclosure includes that contained in the
appended claims, as well as that of the foregoing description.
Although this invention has been described in its preferred
form with a certain degree of particularity, it is understood
that the present disclosure of the preferred form has been
made only by way of example and that numerous changes in
the details of construction and the combination and arrange- 15
ment of parts may be resorted to without departing from the
spirit and scope of the invention.
Now that the invention has been described,
What is claimed is:
1. A handheld electronic magnifier to assist blind or low 20
vision users in viewing objects, the magnifier comprising:
a housing having a front face, a back face, and a peripheral
edge therebetween, a camera positioned within the
housing, a camera aperture formed within the back face
and in alignment with the camera, an LCD screen 25
recessed within the front face, the LCD screen selec-
tively displaying objects viewed by the camera, a series
of controls adjacent to the LCD screen, a pair of LEDs
positioned upon the back face, the LEDs being angled
inwardly towards a focal point; 30
a handle pivotally cmmected to the housing, the handle
having a front face, a hack face, and a peripheral edge
therebetween, an aperh1re and a pair of light guides
fonned within the back face, an opening formed within
the front face, the aperhrre and opening being in align- 35
ment, a battery door within the back face;
a housing having a front face, a back face, and a peripheral
edge therebetween, a camera positioned within the
housing, a camera aperture formed within the back face
and in alignment with the camera, a light source posi-
tioned adjacent the camera aperture, a screen positioned
within the front face, the screen selectively displaying
objects viewed by the camera;
a handle pivotally cmmected to the housing, the handle
having a front face, a back face, and a peripheral edge
therebetween, an opening and a light guide formed in the
handle;
a light chamber fonned within the handle;
the magnifier having a first orientation wherein the housing
and handle are in alignment, such that the handle can be
held by the user to position the camera at a distance from
the object being viewed, the magnifier having a second
orientation wherein the handle and housing are angu-
larly related, such that the handle can be positioned upon
a surface and objects can be placed in front of the cam-
era, the magnifier having a third orientation wherein the
back faces of the housing and handle are brought
together, such that the handle can be positioned over top
of the object being viewed;
whereby the third orientation permits the camera to view
objects through the camera aperture and handle opening,
and whereby light from the light source is direct into the
light guide and into the light chamber to thereby illumi-
nate the object being viewed.
a light chamber fonned within the handle, the light cham-
ber having a color that promotes light reflection and
further including angled strrfaces positioned immedi-
ately below the light guides, a pair of battery compart-
ments positioned adjacent to the light chamber, whereby
the battery door can be removed to gain access to the
battery compartments;
3. T11e magnifier as described in claim 2 wherein the light
40 source is a pair ofLEDs.
the magnifier having a first orientation wherein the housing
and handle are in alignment, such that the handle can be 45
held by the user to position the camera at a distance from
the object being viewed, the magnifier having a second
orientation wherein the handle and housing are angu-
larly related, such that the handle can be positioned upon
a surface and objects can be placed in front of the cam- so
era, the magnifier having a third orientation wherein the
4. T11e magnifier as described in claim 2 wherein the light
source is angled,
5. The magnifier as described in claim 2 wherein the handle
houses a battery compartment.
6. The magnifier as described in claim 2 wherein the light
chamber is formed from a light reflective material.
7. The magnifier as described in claim 2 wherein the light
chamber includes an angled surface that is positioned imme-
diately below the light guide when in the third orientation.
* * * *
Case 8:13-cv-02495-MSS-MAP Document 1-1 Filed 09/27/13 Page 1 of 1 PageID 26
JS 44 (Rev. 0911 I)
CIVIL COVER SHEET
The JS 44 civil coversheet and the inforrrlltion contained herein neither replace nor supplerrcnt the filing and service of pl eadngs or other papers as required by law, except as povided
by local rules of court. This form, approved by the Judi cial Conference of the United States inSeptember 1974, is required for the use of the Clerk of Court for the purpose of mitiating
the civi l docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
DEFENDANTS
AUMED, INC, a California Corporation and AUMED GROUP CORP.,
I. (a) PLAINTIFFS
FREEDOM SCIENTIFIC, INC. a Delaware Corporation
a foreign corporation
(b) County of Residence of First Listed Plaintiff fl.lo._e.J.Las,_ ______ _ County of Residence of First Listed Defendant ,S"'a"- n'-'-'M-"a,t,., e"'o'--------
(EXCEPT IN U.S. PLAINTIFF CASES)
KJyJ,
-s111
401 East. Las Olas Blvd, Ste 1000, Fort Lauderdale, FL 33301
NOTE:
Attorneys (If Known)
(/N U.S. PLAINTIFF CASES ONLY)
IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND rNVOLVED.
II. BASIS OF JURISDICTION (Piacean "X" inOneBoxOnlyJ Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Boxfor Plaintiff)
0 I U.S. Government
Plaintiff
0 2 U.S. Government
Defendant
3 Federal Question
(U.S. Government Not o Party)
0 4 Diversity
(Indicate Citizenship qf Parties in Item Ill)
IV. NATURE OF SUIT (Place an "X" in One Box Onlv)
CONTRACT TORTS
0 I I 0 Insurance PERSONAL INJURY PERSONAL INJURY
0 120 Marine 0 3 10 Airplane 0 365 Personal Injury -
0 130 Miller Act 0 315 Airplane Product Product Liability
0 140 Negotiable Instrument Liability 0 367 Health Care/
0 150 Recovery of Overpayment 0 320 Assault, Libel & Pharmaceutical
& Enforcement of Judgment Slander Personal Injury
0 15 1 Medicare Act 0 330 Federal Employers' Product Liability
0 152 Recovery of Defaulted Liability 0 368 Asbestos Personal
Student Loans 0 340 Marine Injury Product
(Excl. Veterans) 0 345 Marine Product Liability
0 153 Recovery of Overpayment Liability PERSONAL PROPERTY
of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud
0 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lending
0 190 Other Contract Product Liability 0 380 Other Personal
0 195 Contract Product Liability 0 360 Other Personal Property Damage
0 196 Franchise Injury 0 385 Property Damage
0 362 Personal Injury- Product Liability
Med. Malpracti ce
REAL PROPERTY CIVIL RIGHTS PRISONER'PETITIONS
0 2 10 Land Condemnation 0 440 Other Civil Rights 0 510 Motions to Vacate
0 220 Foreclosure 0 441 Voting Sentence
0 230 Rent Lease & Ejectment 0 442 Employment Habeas Corpus:
0 240 Torts to Land 0 443 Housing/ 0 530 General
0 245 Tort Product Liability Accommodations 0 535 Death Penalty
0 290 All Other Real Property 0 445 Amer. w/Disabilities- 0 540 Mandamus & Other
Employment 0 550 Civil Rights
0 446 Amer. w/Disabilities- 0 555 Prison Condition
Other 0 560 Civil Detainee-
0 448 Education Conditions of
Confinement
(For Diversity Cases Only)
PTF
and One Boxfor
DEF PTF DEF
Citizen of This State 0 I 0 I Incorporated or Principal Place 0 4 0 4
of Business In This State
Citizen of Another State
FORFEITURE/PENALTY
0 625 Drug Related Seizure
of Property 2 1 USC 881
0 690 Other
LABOR
0 710 Fair Labor Standards
Act
0 720 Labor/Mgmt. Relations
0 740 Railway Labor Act
0 751 Family and Medical
Leave Act
0 790 Other Labor Litigation
0 79 1 Empl. Ret. Inc.
Security Act
IMMIGRATIONc
0 2 0 2 Incorporated and Principal Place
of Business In Another State
0 0 5
0 3 0 3 Foreign Nation 0 6 0 6
BANKRUPTCY OTHER STATUTES
0 422 Appeal 28 USC 158 0 375 False Claims Act
0 423 Wi thdrawal 0 400 State Reapportionment
28USC 157 0 410 Antitrust
0 430 Banks and Banking
PRDPERTYRI HTS 0 450 Commerce
0 820 Copyrights 0 460 Deportation
830 Patent 0 470 Racketeer lnfiuenced and
0 840 Trademark Corrupt Organizations
0 480 Consumer Credit
SOCIAL SECURITY 0 490 Cable/ Sat TV
0 861 HIA (!395ft) 0 850 Securities/Commodi ties/
0 862 Black Lung (923) Exchange
0 863 DIWC/DIWW (405(g)) 0 890 Other Statutory Actions
0 864 SSID Title XVI 0 891 Agricultural Acts
0 865 RSI (405(g)) 0 893 Environmental Matters
0 895 Freedom of Information
Act
0 896 Arbitration
FEDERAL TAX SUITS 0 899 Administrative Procedure
0 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
or Defendant) Agency Decision
0 871 IRS-Third Party 0 950 Constitutionality of
26 usc 7609 State Statutes
0 462 Naturalization Application
0 463 Habeas Corpus -
Alien Detainee
(Prisoner Petition)
0 465 Other Immi gration
Actions
V. ORIGIN
I2J: I Original
Proceeding
(Place an "X" in One Box Only)
0 2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 0 6 Multidistrict
State Court Appellate Court Reopened s eci Litigation
Cite the U.S. Civil Statute under which you arc filing (Do not citejurisdictional.<tatute,, unless diversity):
35 U.S.C. 271
VI. CAUSE OF ACTION 1-:B:-'r:,:ie=-:f..:.de..:..s::ccr:,:ip:,:t.,.:io::cn_o'-:f-ca-u-sc-:-------------------------------------
VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
DATE
09/26/2013
FOR OFFICE USE ONLY
Patent lnfrin ment
0 CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
(See instrucrions) :
JUDGE
RECEIPT # AMOUNT APPLYING IFP
DEMAND$ CHECK YES only if demanded in complaint:
JURY DEMAND: IX Yes 0 No
DOCKET NUMBER
JUDGE MAG. JUDGE

Freedom Scientific v. Aumed - M.D. Fla.

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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

Handheld Video Magnifier (RUBY), a portable

, a user places it over an object, and adjusts magnification

stays flat on the table or can be held over the reading

can be converted into a conventional magnifying glass by

is depicted in the below images:

. The design and use of the

is depicted in the below images:

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