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

com 4 LINER LLP 1100 Glendon Avenue, 14th Floor 5 Los Angeles, California 90024.3503 Telephone: (310) 500-3500 6 Facsimile: (310) 500-3501 7 Attorneys for Plaintiff SIGNAL IP, INC. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 SIGNAL IP, INC., a California 12 corporation, 13 14 vs. JURY TRIAL DEMANDED Plaintiff, Case No. 14-cv-3108 COMPLAINT FOR PATENT INFRINGEMENT

15 JAGUAR LAND ROVER NORTH AMERICA, LLC, a Delaware limited 16 liability company 17 18 19 Defendant.

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

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

24 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. 25 2. On information and belief, Defendant Jaguar Land Rover North 26 America, LLC is a Delaware limited liability company with its principal place of 27 business at 555 Macarthur Blvd., Mahwah, NJ 07430. 28
Case No. 14-cv-3108 COMPLAINT FOR PATENT INFRINGEMENT

1 2 3.

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

3 the United States Code. This Court has subject matter jurisdiction pursuant to 28 4 U.S.C. 1331 and 1338(a). 5 4. This Court has personal jurisdiction over Defendant. Defendant has 6 conducted extensive commercial activities and continues to conduct extensive 7 commercial activities within the State of California. Defendant is registered to do 8 business in California. Additionally, on information and belief, Defendant, directly 9 and/or through intermediaries (including Defendants entities, subsidiaries, 10 distributors, sales agents, partners and others), distributes, offers for sale, sells, 11 and/or advertises its products (including but not limited to the products and services 12 that are accused of infringement in this lawsuit) in the United States, in the State of 13 California, and in this judicial district, under the Jaguar, Land Rover and 14 Range Rover brand names. Defendant has purposefully and voluntarily placed 15 one or more of their infringing products and services into the stream of commerce 16 with the expectation that the products and services will be purchased or used by 17 customers in California and within this judicial district. Accordingly, Defendant has 18 infringed Signal IPs patents within the State of California and in this judicial 19 district as alleged in more detail below. 20 21 22 6. 5. Venue is proper in this district under 28 U.S.C. 1391 and 1400(b). BACKGROUND Signal IP, Inc. is a California corporation with a principal place of

23 business at 11100 Santa Monica Blvd., Suite 380, Los Angeles, CA 90025. It is the 24 owner of the entire right, title and interest in and to U.S. Patent Nos. 5,714,927; 25 6,434,486; and 6,012,007 (the Patents-in-Suit). 26 7. On information and belief, Defendant is a direct or indirect subsidiary 27 of global car manufacturer and distributor Tata Motors, Ltd. (Tata), which is 28 headquartered in India. Tata manufactures and distributes cars under the Jaguar, 2
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

1 Land Rover and Range Rover brand names. 2 3 4 8. 5 forth in full herein. 6 9. Signal IP is the owner of the entire right, title, and interest in and to 7 U.S. Patent No. 5,714,927 (the 927 Patent), entitled Method of Improving Zone of 8 Coverage Response of Automotive Radar. The 927 Patent was duly and legally 9 issued by the U.S. Patent and Trademark Office on February 3, 1998. A true and 10 correct copy of the 927 Patent is attached as Exhibit A. 11 10. Defendant has directly infringed and continues to infringe, literally 12 and/or under the doctrine of equivalents, the 927 Patent by making, using, offering 13 for sale, and/or selling in the United States certain methods or systems disclosed and 14 claimed in the 927 Patent, including but not limited to the Blind Spot Monitor 15 (BSM) system, used in products including but not limited to the Jaguar F-Type, XF, 16 and XJ, and the Land Rover LR2, LR4, Range Rover, Range Rover Evoque, and 17 Range Rover Sport. 18 11. Defendant has contributorily infringed and is currently contributorily 19 infringing the 927 Patent by making, using, offering for sale, and/or selling in the 20 United States certain methods or systems disclosed and claimed in the 927 Patent, 21 including but not limited to the Blind Spot Monitor (BSM) system, used in products 22 including but not limited to the Jaguar F-Type, XF, and XJ, and the Land Rover 23 LR2, LR4, Range Rover, Range Rover Evoque, and Range Rover Sport. 24 12. Defendant has actively induced and is actively inducing the 25 infringement of the 927 Patent by making, using, offering for sale, and/or selling in 26 the United States certain methods or systems disclosed and claimed in the 927 27 Patent, including but not limited to the Blind Spot Monitor (BSM) system, used in 28 products including but not limited to the Jaguar F-Type, XF, and XJ, and the Land 3
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

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

1 Rover LR2, LR4, Range Rover, Range Rover Evoque, and Range Rover Sport. 2 13. Defendants infringement of the 927 Patent has been and continues to 3 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 4 14. Unless enjoined by this Court, Defendant will continue to infringe the 5 927 Patent. 6 15. As a direct and proximate result of the Defendants conduct, Plaintiff 7 has suffered, and will continue to suffer, irreparable injury for which it has no 8 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 9 issues, will continue to be damaged in an amount yet to be determined. 10 11 12 16. 13 forth in full herein. 14 17. Signal IP is the owner of the entire right, title, and interest in and to 15 U.S. Patent No. 6,434,486 (the 486 Patent), entitled Technique for Limiting the 16 Range of an Object Sensing System in a Vehicle. The 486 Patent duly and legally 17 issued by the U.S. Patent and Trademark Office on August 13, 2002. A true and 18 correct copy of the 486 Patent is attached as Exhibit B. 19 18. Defendant has directly infringed and continues to infringe, literally 20 and/or under the doctrine of equivalents, the 486 Patent by making, using, offering 21 for sale, and/or selling in the United States certain methods or systems disclosed and 22 claimed in the 486 Patent, including but not limited to collision prevention or 23 avoidance systems, including but not limited to the Adaptive Cruise Control (ACC) 24 system, used in products including but not limited to the Jaguar F-Type, XF, XJ, and 25 XK, and the Land Rover Range Rover, Range Rover Evoque, and Range Rover 26 Sport. 27 19. Defendant has contributorily infringed and is currently contributorily 28 infringing the 486 Patent by making, using, offering for sale, and/or selling in the 4
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

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

1 United States certain methods or systems disclosed and claimed in the 486 Patent, 2 including but not limited to collision prevention or avoidance systems, including but 3 not limited to the Adaptive Cruise Control (ACC) system, used in products 4 including but not limited to the Jaguar F-Type, XF, XJ, and XK, and the Land Rover 5 Range Rover, Range Rover Evoque, and Range Rover Sport. 6 20. Defendant has actively induced and is actively inducing the 7 infringement of the 486 Patent by making, using, offering for sale, and/or selling in 8 the United States certain methods or systems disclosed and claimed in the 486 9 Patent, including but not limited to collision prevention or avoidance systems, 10 including but not limited to the Adaptive Cruise Control (ACC) system, used in 11 products including but not limited to the Jaguar F-Type, XF, XJ, and XK, and the 12 Land Rover Range Rover, Range Rover Evoque, and Range Rover Sport. 13 21. Defendants infringement of the 486 Patent has been and continues to 14 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 15 22. Unless enjoined by this Court, Defendant will continue to infringe the

16 486 Patent. 17 23. As a direct and proximate result of the Defendants conduct, Plaintiff 18 has suffered, and will continue to suffer, irreparable injury for which it has no 19 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 20 issues, will continue to be damaged in an amount yet to be determined. 21 22 23 24. 24 forth in full herein. 25 25. Signal IP is the owner of the entire right, title, and interest in and to 26 U.S. Patent No. 6,012,007 (the 007 Patent), entitled Occupant Detection Method 27 and Apparatus for Air Bag System. The 007 Patent was duly and legally issued by 28 the U.S. Patent and Trademark Office on January 4, 2000. A true and correct copy 5
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

THIRD CLAIM FOR RELIEF (Infringement of the 007 Patent) Plaintiff incorporates paragraphs 1 through 23 of this complaint as if set

1 of the 007 Patent is attached as Exhibit C. 2 26. Defendant has directly infringed and continues to infringe, literally 3 and/or under the doctrine of equivalents, the 007 Patent by making, using, offering 4 for sale, and/or selling in the United States certain methods or systems disclosed and 5 claimed in the 007 Patent, including but not limited to the Occupancy Sensing 6 System, used in products including but not limited to the Jaguar F-Type, XF, XJ, 7 XK, S-Type, and X-Type, and the Land Rover LR2, LR4, Range Rover, Range 8 Rover Evoque, and Range Rover Sport. 9 27. Defendant has contributorily infringed and is currently contributorily

10 infringing the 007 Patent by making, using, offering for sale, and/or selling in the 11 United States certain methods or systems disclosed and claimed in the 007 Patent, 12 including but not limited to the Occupancy Sensing System, used in products 13 including but not limited to the Jaguar F-Type, XF, XJ, XK, S-Type, and X-Type, 14 and the Land Rover LR2, LR4, Range Rover, Range Rover Evoque, and Range 15 Rover Sport. 16 28. Defendant has actively induced and is actively inducing the 17 infringement of the 007 Patent by making, using, offering for sale, and/or selling in 18 the United States certain methods or systems disclosed and claimed in the 007 19 Patent, including but not limited to the Occupancy Sensing System, used in products 20 including but not limited to the Jaguar F-Type, XF, XJ, XK, S-Type, and X-Type, 21 and the Land Rover LR2, LR4, Range Rover, Range Rover Evoque, and Range 22 Rover Sport. 23 29. 30. Defendants infringement of the 007 Patent has been and continues to Unless enjoined by this Court, Defendant will continue to infringe on 24 be willful, rendering this case exceptional within the meaning of 35 U.S.C. 285. 25

26 the 007 Patent. 27 31. As a direct and proximate result of the Defendants conduct, Plaintiff 28 has suffered, and will continue to suffer, irreparable injury for which it has no 6
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

1 adequate remedy at law. Plaintiff also has been damaged and, until an injunction 2 issues, will continue to be damaged in an amount yet to be determined. 3 4 PRAYER FOR RELIEF Wherefore, Signal IP respectfully requests that the Court enter judgment

5 against Defendant as follows: 6 7 8 9 10 1. 2. 3. 4. 5. That Defendant has directly infringed the Patents-in-Suit; That Defendant has contributorily infringed the Patents-in-Suit; That Defendant has induced the infringement of the Patents-in-Suit; That Defendants infringement be adjudged willful and deliberate; That Defendant and its affiliates, subsidiaries, officers, directors,

11 employees, agents, representatives, successors, assigns, and all those acting in 12 concert, participation, or privity with them or on their behalf, including customers, 13 be enjoined from infringing, inducing others to infringe or contributing to the 14 infringement of the Patents-in-Suit; 15 6. For damages, according to proof, for Defendants infringement, 16 together with pre-judgment and post-judgment interest, as allowed by law and that 17 such damages be trebled as provided by 35 U.S.C. 284; 18 20 and 21 22 23 24 25 26 27 28 7
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

7.

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

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

1 Dated: April 23, 2014 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

LINER LLP

By:

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

8
COMPLAINT FOR PATENT INFRINGEMENT

Case No. 14-cv-3108

1 2

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

3 IP, Inc. respectfully demands a jury trial on any and all issues triable as of right 4 by a jury in this action. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 9
COMPLAINT FOR PATENT INFRINGEMENT Case No. 14-cv-3108

Dated: April 23, 2014

LINER LLP

By:

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