Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 1 of 30 PageID #: 1

IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISION
Stratasys, Inc.,
Plaintiff,v.
Shenzhen Tuozhu Technology Co., Ltd.,
Shanghai Lunkuo Technology Co., Ltd.,
Bambulab Limited,
Beijing Tiertime Technology Co., Ltd.
Beijing Yinhua Laser Rapid Prototyping and
Mould Technology Co. Ltd., andTuozhu Technology Limited
Defendants.

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CIVIL ACTION NO. 2:24-cv-644
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Stratasys, Inc. (“Plaintiff” or “Stratasys”), by and through its undersigned counsel,
brings this complaint for patent infringement against Defendants Shenzhen Tuozhu Technology
Co., Ltd., Shanghai Lunkuo Technology Co., Ltd., Bambulab Limited, Beijing Tiertime
Technology Co., Ltd., Beijing Yinhua Laser Rapid Prototyping and Mould Technology Co. Ltd.,and Tuozhu Technology Limited (collectively, “Bambu Lab” or “Defendants”) and would
respectfully show the Court as follows:
I.
1.

PARTIES

Stratasys is one of the pioneers in the field of three-dimensional (3D) printing

technology, founded in 1988. Plaintiff Stratasys, Inc. is a Delaware corporation with its place ofbusiness located at 7665 Commerce Way, Eden Prairie, Minnesota.
2.

On information and belief, Defendant Shenzhen Tuozhu Technology Co., Ltd. (深圳拓竹科技有限公司, hereafter, “Shenzhen Tuozhu”) is a company organized and existing underCase 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 2 of 30 PageID #: 2

the laws of the People’s Republic of China. On information and belief, Shenzhen Tuozhu operates
under the brand name “Bambu Lab” and holds itself forth under the English name Shenzhen
Bambu Lab Co., Ltd. That name does not appear separately in China’s National Enterprise Credit
Information Publicity System.
3.

On information and belief, Defendant Shanghai Lunkuo Technology Co., Ltd. (上海轮廓科技有限公司, hereafter, “Shanghai Lunkuo”) is a company organized and existing under
the laws of the People’s Republic of China. On information and belief, Shanghai Lunkuo conducts
business, either directly or through its agents, on an ongoing basis in this judicial district andelsewhere in the United States. On information and belief, Shanghai Lunkuo holds itself forth
under the English name Shanghai Contour Technology Co., Ltd. That name does not appear
separately in China’s National Enterprise Credit Information Publicity System, as Lunkuo is aphonetic spelling of the Chinese word that translates to Contour.
4.

On information and belief, Defendant Bambulab Limited is a company organizedand existing under the laws of Hong Kong SAR, China, and is a wholly-owned subsidiary ofShenzhen Tuozhu Technology Co., Ltd.
5.

On information and belief, Defendant Beijing Tiertime Technology Co., Ltd. (北京太尔时代科技有限公司), is a company organized and existing under the laws of the People’s
Republic of China.
6.

On information and belief, Defendant Beijing Yinhua Laser Rapid Prototyping and

Mould Technology Co. Ltd. (北京殷华激光快速成形与模具技术有限公司), is a company
organized and existing under the laws of the People’s Republic of China.

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7.

On information and belief, Defendant Tuozhu Technology Limited, is a company

organized and existing under the laws of Hong Kong SAR, China, and is a wholly-owned
subsidiary of Shenzhen Tuozhu Technology Co., Ltd.
II.
8.

JURISDICTION AND VENUEThis is a civil action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. §§ 1 et seq. Accordingly, this Court has subject matter jurisdiction overthis action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
9.

This Court has personal jurisdiction over Defendants at least because they (1) havecommitted acts of patent infringement and contributed to and induced acts of patent infringementby others in this District; (2) regularly did business or solicited business in this District; (3) engaged
in other persistent courses of conduct and derived substantial revenue by its offering of infringing
products and services and providing infringing products and services in this District; and (4)purposefully established substantial, systematic, and continuous contacts with this District andshould have reasonably expected to be subject to suit here by its offering of infringing products
and services and providing infringing products and services in this District.
10.

Defendants conduct business, either directly or through its agents, on an ongoingbasis in this judicial district and elsewhere in the United States. On information and belief,
Defendants are responsible for the research, development, and manufacturing of Bambu-branded
products imported, sold, offered for sale, and/or used in the United States, including Bambu’s
three-dimensional (3D) printing products in this District.
11.

Defendants have sold their 3D printers and 3D-printer related products within thisjudicial district via their online store at https://store.bambulab.com/products.
12.

Defendants, directly and through subsidiaries or intermediaries (including

distributors, retailers, and others), have purposefully and voluntarily placed their infringing-2-

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products into this district and into the stream of commerce with the intention and expectation thatthe infringing products will be purchased for use in this district. Defendants have imported, offered
for sale and sold, and continue to import, offer for sale and sell, infringing products for delivery
and use in this district.
13.

Venue is proper in this district under at least 28 U.S.C. §§ 1391(b), (c) and/or

1400(b). Venue in this district is proper for Defendants at least because they are foreign entities
that have committed acts of infringement in this district as detailed throughout this complaint.
III.
14.

BACKGROUND OF THE DISPUTE

Stratasys was founded in 1988 and is a pioneer in the field of three-dimensional

printing. Stratasys was the original innovator in the field of fused deposition modeling (alsoknown as material extrusion 3D printing), which is an additive manufacturing process that prints
three-dimensional objects from computer models by building up layers of one or more extruded
materials onto a platform using a device that has come to be generally known as a 3D printer.
Stratasys has commercialized this technology (which it refers to as its “FDM” technology), andcontinues to do so today, selling Stratasys FDM® printers and filament, along with an ecosystemof software, accessories and services.
15.

Stratasys is an indirectly wholly-owned subsidiary of Stratasys Ltd. Stratasys Ltd.

is a publicly owned company organized under the laws of Israel, that is publicly traded in the
United States on the NASDAQ (ticker symbol: SSYS).
16.

Stratasys’s printers are backed by its proprietary technologies. Stratasys holdapproximately 2,600 patents and pending patents internationally, and its 3D printing systems
utilize its patented extrusion-based FDM®, inkjet-based PolyJet™, powder-bed-based SAF®,
photopolymer-based P3™, and stereolithography technologies to enable the production of-3-

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prototypes, tools used for production, and manufactured goods directly from 3D CAD files or other3D content.
17.

In 2012, Stratasys, Inc. merged with Objet Ltd. to form the corporate entity

Stratasys Ltd. Today, Stratasys Ltd. and its subsidiaries, including Stratasys, Inc., have more than
1,900 employees worldwide, hold approximately 2,600 granted or pending patents globally, andhave received numerous awards for technology and leadership.
18.

Over the years, other companies began to make and sell 3D printers that incorporate

features and capabilities involving the extrusion of materials in additive layers to form 3D objects.
For example, by 2022, Defendants began making and selling its “Bambu Lab” branded printers.
On information and belief, the Bambu Lab printers are sold in the United States through direct
sales over the Internet and through resellers.
19.

On information and belief, Defendants have sold their printers, including theirBambu Lab A1 3D printer, A1 mini 3D printer, P1P 3D printer, X1-Carbon 3D printer, P1S 3Dprinter and X1E 3D printer.

Defendants also make available and distribute marketing,

instructional, and support materials to customers through their website, and maintains a technicalsupport staff that provides support to customers, including through their website.
20.

On information and belief, Defendants’ printers (including their Bambu Lab A1 3D

printer, A1 mini 3D printer, P1P 3D printer, X1-Carbon (“X1C”) 3D printer, P1S 3D printer andX1E 3D printer) transmit data to Defendants’ servers or servers operated by third parties under
Defendants’ control. This includes, but is not limited to, Defendants’ servers that may be locatedin China.
21.

In fact, Defendants have acknowledged that their printers have security concerns.

In a November 2022 blog post, Defendants’ representative stated that: “We admit that the security-4-

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design of the whole Bambu Lab system was not the best from the very beginning. The honest
reason is simply that the initial team has a background in robotics, but very little experience innetwork security. We now understand, thanks to the community contributions, that we haveunderestimated this issue, and there is no excuse for this.” https://blog.bambulab.com/answeringnetwork-security-concerns/.
IV.

CAUSES OF ACTION

COUNT 1: U.S. Patent No. 9,421,713
22.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
23.

On August 23, 2016, the United States Patent Office (USPTO) duly and lawfully

issued United States Patent No. 9,421,713, entitled “Additive Manufacturing Method For Printing
Three-Dimensional Parts With Purge Towers.” By assignment, duly recorded with the USPTO,
Stratasys owns all substantial rights to the ’713 Patent, including the right to sue and recoverdamages for all infringement.
24.

The ’713 Patent generally relates to additive three-dimensional printing with purge

25.

Bambu Lab has directly infringed, and continues to directly infringe the ’713 Patent

towers.

in violation of 35 U.S.C. 271(a) by using in the United States, without authorization, the accused
products that practice various claims of the ’713 Patent literally or under the doctrine ofequivalents. Those products include, for example, Bambu’s X1C, X1E, and P1S, and P1P printers.
26.

As a non-limiting example, the Accused ’713 Products meet every element of atleast Claim 1 of the ’713 Patent literally or under the doctrine of equivalents. Claim 1 recites:
1. A method for printing a three-dimensional part with an additive
manufacturing system, the method comprising:-5-

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printing layers of the three-dimensional part and of a support
structure for the three-dimensional part from multiple print heads
or deposition lines using a layer-based, additive manufacturing
technique;switching the print heads or deposition line between stand-bymodes and operating modes in-between the printing of the layersof the three-dimensional part and the support structure;
performing a purge operation for each print head or deposition line
switched to the operating mode, the purge operation comprising
printing at least one purge tower in a layer-by-layer manner,
wherein the layers of the at least one purge tower are printed fromthe print head or deposition line switched to the operating mode.
27.

For example, Bambu Lab makes, uses, sells and offers to sell various additive

manufacturing systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, and A1 mini
which are used for printing three-dimensional parts. Bambu Lab’s 3D printers print layers of a 3Dpart using an Automatic Material System (AMS), which supports multiple filament spools eachhaving an independent deposition line operatively coupled to the print head of the 3D printer.
Furthermore, Bambu Labs distributes Bambu Studio for use in conjunction with its 3D printers.
Bambu Studio includes use of support material (as needed) in its slicer software, and it instructs
the 3D printer to switch deposition lines between printing of part material and printing of support
material. In addition, the Bambu Studio slicer software instructs the Bambu Labs 3D printers to
perform a purge operation to a prime tower when a deposition line is switched between the partmaterial and the support material. Bambu Lab thus directly infringed and continues to directly
infringe each limitation of at least Claim 1 of the ’713 Patent by using, in the United States, withoutauthorization the Accused ’713 Products.
28.

To the extent Defendants do not perform each and every limitation of the claims ofthe ’713 Patent, Defendants jointly infringe those claims. In particular, Defendants direct orcontrol its users of the Accused ’713 Products to perform one or more limitations of the claims-6-Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 8 of 30 PageID #: 8nationwide through its own websites, applications, and manuals, and expects and intends that the
Accused ’713 Products will be so used. For example, Defendants require customers and users to
use the accused products through the applications Defendants produce and distribute for use.
Defendants further require users of the accused products to agree to extensive terms andconditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’technology to print and manufacture tangible items.
29.

Defendants also indirectly infringe at least Claim 1 of the ’713 Patent in violationof 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
providers, in the United States with knowledge and specific intent that its efforts would result in
the direct infringement of the ’713 Patent. For example, Defendants actively induce infringementof the ’713 Patent by designing, manufacturing, selling, or distributing the Accused ’713 Products
and then training its customers and users on the use of those products and the accompanying
applications, including through the creation and dissemination of supporting materials,
maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
Handy),

instructions,productmanuals,

andtechnical

information.

See

https://wiki.bambulab.com/en/home. As another example, Defendants actively induces
infringement of the ’713 Patent by instructing, encouraging, or requiring their subsidiaries andaffiliates in the United States to use, sell, offer for sale in the United States, and importing into theUnited States, without authorization, the accused products that practice various claims of the ’713
Patent, such as any Bambu Lab printer that is used in combination with the corresponding
applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet anotherexample, Defendants actively induce infringement of the ’713 Patent through the creation and-7-Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 9 of 30 PageID #: 9dissemination of promotional and marketing materials and instructional videos. See
https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with theknowledge and the specific intent that its efforts would result in the direct infringement of the ’713
Patent.
30.

Defendants were put on notice of their direct and indirect infringement of the ’713

Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
have knowledge of the ’713 Patent and knowledge of how Defendants induce third parties toinfringe that patent at least as early as August 5, 2024.
31.

Defendants are also liable for contributory infringement of the ’713 Patent under

35 U.S.C. 271(c) by selling or offering for sale the Accused ’713 Products and/or other components(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
Accused ’713 Products and/or other components (e.g., filament, automatic material system, build
plates, etc.) in the United States with knowledge that they are especially designed or adapted tooperate in a manner that infringes the ’713 Patent and are not a staple article or commodity ofcommerce suitable for substantially non-infringing use. Defendants contribute to infringement of
the ’713 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’713 Products
and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
parties.
32.

Defendants also have had knowledge of how Defendants infringe the ’713 Patent

at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants haveknowledge of the ’713 Patent and knowledge of how Defendants contribute to third parties’
infringement of that patent at least as early as August 5, 2024.

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33.

Defendants’ infringement of the ’713 Patent has been and continues to be willful.

At least as early as August 5, 2024, Defendants were notified of their infringing acts anddeliberately continued to infringe the ’713 Patent despite knowing of the existence of the patentand how Defendants infringe. Further, Defendants have deliberately continued to encourageothers’ infringement of the ’713 Patent, including by continuing to disseminate its marketing andtechnical materials to customers.
34.

Defendants’ acts of infringement have injured and damaged Stratasys and willcontinue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amountto be proven at trial.
35.

Defendants’ infringement has damaged and will continue to damage Stratasys

irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the’713 Patent.
36.

Stratasys is entitled to all damages to which it otherwise is entitled because it hascomplied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the’713 Patent.
COUNT 2: U.S. Patent No. 9,592,660
37.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
38.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.

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39.

On March 14, 2017, the United States Patent Office (USPTO) duly and lawfully

issued United States Patent No. 9,592,660, entitled “Heated Build Platform And System For ThreeDimensional Printing Methods.” By assignment, duly recorded with the USPTO, Stratasys owns
all substantial rights to the ’660 Patent, including the right to sue and recover damages for all
infringement.
40.

The ’660 Patent generally relates to a base for printing 3D objects using hightemperature thermoplastics using additive manufacturing methods.
41.

Bambu Lab has directly infringed, and continues to directly infringe the ’660 Patentin violation of 35 U.S.C. 271(a) by using, selling, offering for sale in the United States, andimporting into the United States, without authorization, the accused products that practice various
claims of the ’660 Patent literally or under the doctrine of equivalents. Those products include,for example, Bambu’s X1C, X1E, and P1S, P1P, A1 and A1 mini printers.
42.

As a non-limiting example, the Accused ’660 Products meet every element of atleast Claim 1 of the ’660 Patent literally or under the doctrine of equivalents. Claim 1 recites:
1. A build apparatus for printing a 3D object of thermoplastics
employing additive manufacturing methods, the apparatus
comprising:a build platform with a temperature control unit configured tocontrol heating of the build platform;
a thermally conductive plate disposed adjacent to the build
platform; anda polymer coating attached to a surface of the thermally conductive
plate which is capable of (i) facilitating adhesion to the 3D object
during printing and (ii) permitting removal of the 3D object oncethe 3D object has been formed and cooled without chemically ormechanically removing the polymer coating from 3D object andwithout damaging the polymer coating, the thermally conductive
plate, or the 3D object, wherein the polymer coating is not apolymer tape.

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43.

For example, Bambu Lab makes, uses, sells and offers to sell various additive

manufacturing systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, and A1 mini,
which are used for printing three-dimensional parts using thermoplastic filaments. The Bambu
printers have a heated build platform (i.e., heatbed).

In addition, Bambu sells thermallyconductive build plates with their 3D printers, such as the Bambu Engineering Plate, Textured PEI
Plate, and High Temperature Plate, that are placed on the heatbed for fabrication of the 3D part.
These build plates are made by coating a polymer (e.g., polyetherimide) onto a steel sheet, whichfacilitates adhesion of the 3D part to the build plate. The 3D object is removable from the build
plate without chemically or mechanically removing the polymer coating and without damaging
the polymer coating, such as by flexing the build plate after the 3D object has cooled. Bambu Lab
thus directly infringed and continues to directly infringe each limitation of at least Claim 1 of the’660 Patent by using, selling, offering for sale in the United States, and importing into the UnitedStates, without authorization the Accused ’660 Products.
44.

To the extent Defendants do not perform each and every limitation of the claims ofthe ’660 Patent, Defendants jointly infringe those claims. In particular, Bambu Lab directs orcontrols its users of the Accused ’660 Products to perform one or more limitations of the claims
nationwide through its own websites, applications, and manuals, and expects and intends that the
Accused ’660 Products will be so used. For example, Defendants require customers and users to
use the accused products through the applications Defendants produce and distribute for use.
Defendants further require users of the accused products to agree to extensive terms andconditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’technology to print and manufacture tangible items.

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45.

Defendants also indirectly infringe at least Claim 1 of the ’660 Patent in violationof 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
providers, in the United States with knowledge and specific intent that its efforts would result in
the direct infringement of the ’660 Patent. For example, Defendants actively induce infringementof the ’660 Patent by designing, manufacturing, selling, or distributing the Accused ’660 Products
and then training its customers and users on the use of those products and the accompanying
applications, including through the creation and dissemination of supporting materials,
maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
Handy),

instructions,productmanuals,

andtechnical

information.

See

https://wiki.bambulab.com/en/home. As another example, Defendants actively induces
infringement of the ’660 Patent by instructing, encouraging, or requiring their subsidiaries andaffiliates in the United States to use, sell, offer for sale in the United States, and importing into theUnited States, without authorization, the accused products that practice various claims of the ’660
Patent, such as any Bambu Lab printer that is used in combination with the corresponding
applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet anotherexample, Defendants actively induce infringement of the ’660 Patent through the creation anddissemination of promotional and marketing materials and instructional videos. See
https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with theknowledge and the specific intent that its efforts would result in the direct infringement of the ’660
Patent.
46.

Defendants were put on notice of their direct and indirect infringement of the ’660

Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants- 12 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 14 of 30 PageID #: 14have knowledge of the ’660 Patent and knowledge of how Defendants induce third parties toinfringe that patent at least as early as August 5, 2024.
47.

Defendants are also liable for contributory infringement of the ’660 Patent under

35 U.S.C. 271(c) by selling or offering for sale the Accused ’660 Products and/or other components(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
Accused ’660 Products and/or other components (e.g., filament, automatic material system, build
plates, etc.) in the United States with knowledge that they are especially designed or adapted tooperate in a manner that infringes the ’660 Patent and are not a staple article or commodity ofcommerce suitable for substantially non-infringing use. Defendants contribute to infringement of
the ’660 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’660 Products
and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
parties.
48.

Defendants also have had knowledge of how Defendants infringe the ’660 Patent

at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants haveknowledge of the ’660 Patent and knowledge of how Defendants contribute to third parties’
infringement of that patent at least as early as August 5, 2024.
49.

Defendants’ infringement of the ’660 Patent has been and continues to be willful.

At least as early as August 5, 2024, Defendants were notified of their infringing acts anddeliberately continued to infringe the ’660 Patent despite knowing of the existence of the patentand how Defendants infringe. Further, Defendants have deliberately continued to encourageothers’ infringement of the ’660 Patent, including by continuing to disseminate its marketing andtechnical materials to customers.

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50.

Defendants’ acts of infringement have injured and damaged Stratasys and willcontinue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amountto be proven at trial.
51.

Defendants’ infringement has damaged and will continue to damage Stratasys

irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the’660 Patent.
52.

Stratasys is entitled to all damages to which it otherwise is entitled because it hascomplied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the’660 Patent.
COUNT 3: U.S. Patent No. 7,555,357
53.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
54.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
55.

On June 30, 2009, the United States Patent Office (USPTO) duly and lawfully

issued United States Patent No. 7,555,357, entitled “Method For Building Three-Dimensional
Objects With Extrusion-Based Layer Deposition Systems.” By assignment, duly recorded with the
USPTO, Stratasys owns all substantial rights to the ’357 Patent, including the right to sue andrecover damages for all infringement.

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56.

The ’357 Patent generally relates to methods of forming three-dimensional objects

using an extrusion-based layered deposition system that generates a build path for building a layerof the three-dimensional object where the build path defines a void region.
57.

Bambu Lab has directly infringed, and continues to directly infringe the ’357 Patentin violation of 35 U.S.C. 271(a) by using in the United States, without authorization, the accused
products that practice various claims of the ’357 Patent literally or under the doctrine ofequivalents. Those products include, for example, Bambu’s X1C, X1E, and P1S, P1P, A1 and A1
mini printers.
58.

As a non-limiting example, the Accused ’357 Products meet every element of atleast Claim 15 of the ’357 Patent literally or under the doctrine of equivalents. Claim 15 recites:
15. A method of forming a three-dimensional object using an
extrusion-based layered deposition system, the method comprising:
generating a build path for building a layer of the threedimensional object with a plurality of first deposition roads basedon a first road width resolution, wherein the build path defines avoid region having dimensions that are smaller than the first roadwidth resolution along at least one axis; andgenerating a remnant path in the void region for filling at least[part] of a cavity corresponding to the defined void region with asecond deposition road based on deposition rates that are
configured to vary based on the dimensions of the void region.
59.

For example, Bambu Lab makes, uses, sells and offers to sell various extrusion-

based layered deposition systems (i.e., 3D printers), including the X1C, X1E, P1S, P1P, A1, andA1 mini, which are used for printing three-dimensional parts. A 3D model of the 3D object to beprinted is loaded into Bambu Studio and sliced to generate a .3mf file, which is the file format used
for the printer to be able to print the model. The .3mf file contains instructions for executing build
paths (e.g., “roads,” “walls,” etc.) during the printing of the object. These instructions are provided
to a Bambu Lab 3D printer and executed by the printer to, for example, generate void regions- 15 -

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formed using walls of one width that that are filled in with remnant paths of another width. For
example, the Bambu Lab Wiki describes the concept of wall distribution count as a parameter foradjusting a number of and width of walls. For example, widths of a wall are modified to fill a void
formed between other walls. Bambu Lab thus directly infringed and continues to directly infringe
each limitation of at least Claim 15 of the ’357 Patent by using in the United States, withoutauthorization the Accused ’357 Products.
60.

To the extent Defendants do not perform each and every limitation of the claims ofthe ’357 Patent, Defendants jointly infringe those claims. In particular, Bambu Lab directs orcontrols its users of the Accused ’357 Products to perform one or more limitations of the claims
nationwide through its own websites, applications, and manuals, and expects and intends that the
Accused ’357 Products will be so used. For example, Defendants require customers and users to
use the accused products through the applications Defendants produce and distribute for use.
Defendants further require users of the accused products to agree to extensive terms andconditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’technology to print and manufacture tangible items.
61.

Defendants also indirectly infringe at least Claim 15 of the ’357 Patent in violationof 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
providers, in the United States with knowledge and specific intent that its efforts would result in
the direct infringement of the ’357 Patent. For example, Defendants actively induce infringementof the ’357 Patent by designing, manufacturing, selling, or distributing the Accused ’357 Products
and then training its customers and users on the use of those products and the accompanying
applications, including through the creation and dissemination of supporting materials,- 16 -

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maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
Handy),

instructions,productmanuals,

andtechnical

information.

See

https://wiki.bambulab.com/en/home. As another example, Defendants actively induces
infringement of the ’357 Patent by instructing, encouraging, or requiring their subsidiaries andaffiliates in the United States to use, sell, offer for sale in the United States, and importing into theUnited States, without authorization, the accused products that practice various claims of the ’357
Patent, such as any Bambu Lab printer that is used in combination with the corresponding
applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet anotherexample, Defendants actively induce infringement of the ’357 Patent through the creation anddissemination of promotional and marketing materials and instructional videos. See
https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with theknowledge and the specific intent that its efforts would result in the direct infringement of the ’357
Patent.
62.

Defendants were put on notice of their direct and indirect infringement of the ’357

Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
have knowledge of the ’357 Patent and knowledge of how Defendants induce third parties toinfringe that patent at least as early as August 5, 2024.
63.

Defendants are also liable for contributory infringement of the ’357 Patent under

35 U.S.C. 271(c) by selling or offering for sale the Accused ’357 Products and/or other components(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
Accused ’357 Products and/or other components (e.g., filament, automatic material system, build
plates, etc.) in the United States with knowledge that they are especially designed or adapted tooperate in a manner that infringes the ’357 Patent and are not a staple article or commodity of- 17 -

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commerce suitable for substantially non-infringing use. Defendants contribute to infringement of
the ’357 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’357 Products
and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
parties.
64.

Defendants also have had knowledge of how Defendants infringe the ’357 Patent

at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants haveknowledge of the ’357 Patent and knowledge of how Defendants contribute to third parties’
infringement of that patent at least as early as August 5, 2024.
65.

Defendants’ infringement of the ’357 Patent has been and continues to be willful.

At least as early as August 5, 2024, Defendants were notified of their infringing acts anddeliberately continued to infringe the ’357 Patent despite knowing of the existence of the patentand how Defendants infringe. Further, Defendants have deliberately continued to encourageothers’ infringement of the ’357 Patent, including by continuing to disseminate its marketing andtechnical materials to customers.
66.

Defendants’ acts of infringement have injured and damaged Stratasys and willcontinue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amountto be proven at trial.
67.

Defendants’ infringement has damaged and will continue to damage Stratasys

irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the’357 Patent.

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Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 20 of 30 PageID #: 20

68.

Stratasys is entitled to all damages to which it otherwise is entitled because it hascomplied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the’357 Patent.
COUNT 4: U.S. Patent No. 9,168,698
69.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
70.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
71.

On October 27, 2015, the United States Patent Office (USPTO) duly and lawfully

issued United States Patent No. 9,168,698, entitled “Three-Dimensional Printer With Force
Detection.” By assignment, duly recorded with the USPTO, Stratasys owns all substantial rights
to the ’698 Patent, including the right to sue and recover damages for all infringement.
72.

The ’698 Patent generally relates to methods for detecting contact force against an

extruder or other tool head of a three-dimensional printer.
73.

Bambu Lab has directly infringed, and continues to directly infringe the ’698 Patentin violation of 35 U.S.C. 271(a) by using in the United States, without authorization, the accused
products that practice various claims of the ’698 Patent literally or under the doctrine ofequivalents. Those products include, for example, Bambu’s A1 and A1 mini printers.
74.

As a non-limiting example, the Accused ’698 Products meet every element of atleast Claim 1 of the ’698 Patent literally or under the doctrine of equivalents. Claim 1 recites:
1. A method comprising:identifying build instructions for fabricating an object;initiating a build using a three-dimensional printer comprising a- 19 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 21 of 30 PageID #: 21

fabrication tool and one or more sensors mechanically coupled to
the fabrication tool, the one or more sensors configured to detect acurrent contact force between the fabrication tool and a separate
structure;detecting the current contact force based on a sensor signal fromthe one or more sensors; andcreating a control signal to control at least one component of thethree-dimensional printer in response to the current contact force
while depositing material during the build.
75.

For example, Bambu Lab makes, uses, sells and offers to sell various additive

manufacturing systems (i.e., 3D printers), including the A1 and A1 mini, which are used for
fabricating three-dimensional parts using build instructions. A request to fabricate an object frombuild instructions can be received at least via the user interface on the printer and via the Bambu
Studio or Handy apps. The Bambu Labs A1 and A1 mini 3D printers include an extrusion nozzle
with an extrusion force sensor (e.g., an eddy force sensor). The force sensor is used to detect aforce caused by nozzle clumping (e.g., the force of filament material clumped around the nozzle
being pushed against the heatbed) and to automatically stop a print job based on this detected force.
Bambu Lab thus directly infringed and continues to directly infringe each limitation of at least
Claim 1 of the ’698 Patent by using in the United States, without authorization the Accused ’698
Products.
76.

To the extent Defendants do not perform each and every limitation of the claims ofthe ’698 Patent, Defendants jointly infringe those claims. In particular, Bambu Lab directs orcontrols its users of the Accused ’698 Products to perform one or more limitations of the claims
nationwide through its own websites, applications, and manuals, and expects and intends that the
Accused ’698 Products will be so used. For example, Defendants require customers and users to
use the accused products through the applications Defendants produce and distribute for use.
Defendants further require users of the accused products to agree to extensive terms and- 20 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 22 of 30 PageID #: 22

conditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’technology to print and manufacture tangible items.
77.

Defendants also indirectly infringe at least Claim 1 of the ’698 Patent in violationof 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
providers, in the United States with knowledge and specific intent that its efforts would result in
the direct infringement of the ’698 Patent. For example, Defendants actively induce infringementof the ’698 Patent by designing, manufacturing, selling, or distributing the Accused ’698 Products
and then training its customers and users on the use of those products and the accompanying
applications, including through the creation and dissemination of supporting materials,
maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
Handy),

instructions,productmanuals,

andtechnical

information.

See

https://wiki.bambulab.com/en/home. As another example, Defendants actively induces
infringement of the ’698 Patent by instructing, encouraging, or requiring their subsidiaries andaffiliates in the United States to use, sell, offer for sale in the United States, and importing into theUnited States, without authorization, the accused products that practice various claims of the ’698
Patent, such as any Bambu Lab printer that is used in combination with the corresponding
applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet anotherexample, Defendants actively induce infringement of the ’698 Patent through the creation anddissemination of promotional and marketing materials and instructional videos. See
https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with theknowledge and the specific intent that its efforts would result in the direct infringement of the ’698
Patent.

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Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 23 of 30 PageID #: 23

78.

Defendants were put on notice of their direct and indirect infringement of the ’698

Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
have knowledge of the ’698 Patent and knowledge of how Defendants induce third parties toinfringe that patent at least as early as August 5, 2024.
79.

Defendants are also liable for contributory infringement of the ’698 Patent under

35 U.S.C. 271(c) by selling or offering for sale the Accused ’698 Products and/or other components(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
Accused ’698 Products and/or other components (e.g., filament, automatic material system, build
plates, etc.) in the United States with knowledge that they are especially designed or adapted tooperate in a manner that infringes the ’698 Patent and are not a staple article or commodity ofcommerce suitable for substantially non-infringing use. Defendants contribute to infringement of
the ’698 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’698 Products
and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
parties.
80.

Defendants also have had knowledge of how Defendants infringe the ’698 Patent

at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants haveknowledge of the ’698 Patent and knowledge of how Defendants contribute to third parties’
infringement of that patent at least as early as August 5, 2024.
81.

Defendants’ infringement of the ’698 Patent has been and continues to be willful.

At least as early as August 5, 2024, Defendants were notified of their infringing acts anddeliberately continued to infringe the ’698 Patent despite knowing of the existence of the patentand how Defendants infringe. Further, Defendants have deliberately continued to encourage- 22 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 24 of 30 PageID #: 24others’ infringement of the ’698 Patent, including by continuing to disseminate its marketing andtechnical materials to customers.
82.

Defendants’ acts of infringement have injured and damaged Stratasys and willcontinue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amountto be proven at trial.
83.

Defendants’ infringement has damaged and will continue to damage Stratasys

irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the’698 Patent.
84.

Stratasys is entitled to all damages to which it otherwise is entitled because it hascomplied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the’698 Patent.
COUNT 5: U.S. Patent No. 10,556,381
85.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
86.

Stratasys repeats and re-alleges each of the allegations in the foregoing paragraphs

as if fully set forth herein.
87.

On February 11, 2020, the United States Patent Office (USPTO) duly and lawfully

issued United States Patent No. 10,556,381, entitled “Three-Dimensional Printer With Force
Detection.” By assignment, duly recorded with the USPTO, Stratasys owns all substantial rights
to the ’381 Patent, including the right to sue and recover damages for all infringement.

- 23 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 25 of 30 PageID #: 25

88.

The ’381 Patent generally relates to a three-dimensional printer that includes an

extruder or another tool head to detect contact forces during fabrication.
89.

Bambu Lab has directly infringed, and continues to directly infringe the ’381 Patentin violation of 35 U.S.C. 271(a) by using, selling, offering for sale in the United States, andimporting into the United States, without authorization, the accused products that practice various
claims of the ’381 Patent literally or under the doctrine of equivalents. Those products include,for example, Bambu’s A1 and A1 mini printers.
90.

As a non-limiting example, the Accused ’381 Products meet every element of atleast Claim 1 of the ’381 Patent literally or under the doctrine of equivalents. Claim 1 recites:
1. A three-dimensional printer comprising:a fabrication tool including an extruder configured to extrude build
material to fabricate an object during a build process;one or more sensors mechanically coupled to the extruder, wherein
the one or more sensors are collectively operable to sense a contact
force between the extruder and a separate structure distinct fromthe fabrication tool; anda controller configured to receive a signal from the one or moresensors on the extruder and to calculate the contact force between
the extruder and the separate structure.
91.

For example, Bambu Lab makes, uses, sells and offers to sell various additive

manufacturing systems (i.e., 3D printers), including the A1 and A1 mini, which are used for
fabricating three-dimensional parts using build instructions. A request to fabricate an object frombuild instructions can be received at least via the user interface on the printer and via the Bambu
Studio or Handy apps. The Bambu Labs A1 and A1 mini 3D printers include an extrusion nozzle
with an extrusion force sensor (e.g., an eddy force sensor). The force sensor is used to detect aforce caused by nozzle clumping (e.g., the force of filament material clumped around the nozzle
being pushed against the heatbed) and to automatically stop a print job based on this detected force.
- 24 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 26 of 30 PageID #: 26

Bambu Lab thus directly infringed and continues to directly infringe each limitation of at least
Claim 1 of the ’381 Patent by using, selling, offering for sale in the United States, and importing
into the United States, without authorization the Accused ’381 Products.
92.

To the extent Defendants do not perform each and every limitation of the claims ofthe ’381 Patent, Defendants jointly infringe those claims. In particular, Bambu Lab directs orcontrols its users of the Accused ’381 Products to perform one or more limitations of the claims
nationwide through its own websites, applications, and manuals, and expects and intends that the
Accused ’381 Products will be so used. For example, Defendants require customers and users to
use the accused products through the applications Defendants produce and distribute for use.
Defendants further require users of the accused products to agree to extensive terms andconditions. Finally, Defendants’ customers realize a tangible benefit by using Defendants’technology to print and manufacture tangible items.
93.

Defendants also indirectly infringe at least Claim 1 of the ’381 Patent in violationof 35 U.S.C. 271(b) by taking active steps to encourage and facilitate direct infringement by third
parties, including users, partners, affiliates, subsidiaries, resellers, distributors and service
providers, in the United States with knowledge and specific intent that its efforts would result in
the direct infringement of the ’381 Patent. For example, Defendants actively induce infringementof the ’381 Patent by designing, manufacturing, selling, or distributing the Accused ’381 Products
and then training its customers and users on the use of those products and the accompanying
applications, including through the creation and dissemination of supporting materials,
maintenance guides, troubleshooting guides, software (including Bambu Studio and Bambu
Handy),

instructions,productmanuals,

andtechnical

information.

See

https://wiki.bambulab.com/en/home. As another example, Defendants actively induces- 25 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 27 of 30 PageID #: 27

infringement of the ’381 Patent by instructing, encouraging, or requiring their subsidiaries andaffiliates in the United States to use, sell, offer for sale in the United States, and importing into theUnited States, without authorization, the accused products that practice various claims of the ’381
Patent, such as any Bambu Lab printer that is used in combination with the corresponding
applications or controllers (e.g., the Bambu Studio and Bambu Handy, etc.). As yet anotherexample, Defendants actively induce infringement of the ’381 Patent through the creation anddissemination of promotional and marketing materials and instructional videos. See
https://www.youtube.com/c/BambuLab. Defendants’ active inducement is done with theknowledge and the specific intent that its efforts would result in the direct infringement of the ’381
Patent.
94.

Defendants were put on notice of their direct and indirect infringement of the ’381

Patent at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants
have knowledge of the ’381 Patent and knowledge of how Defendants induce third parties toinfringe that patent at least as early as August 5, 2024.
95.

Defendants are also liable for contributory infringement of the ’381 Patent under

35 U.S.C. 271(c) by selling or offering for sale the Accused ’381 Products and/or other components(e.g., filament, automatic material system, build plates, etc.) in the United States and importing the
Accused ’381 Products and/or other components (e.g., filament, automatic material system, build
plates, etc.) in the United States with knowledge that they are especially designed or adapted tooperate in a manner that infringes the ’381 Patent and are not a staple article or commodity ofcommerce suitable for substantially non-infringing use. Defendants contribute to infringement of
the ’381 Patent by, inter alia, promotion, and/or sales of the infringing Accused ’381 Products- 26 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 28 of 30 PageID #: 28

and/or other components (e.g., filament, automatic material system, build plates, etc.) to third
parties.
96.

Defendants also have had knowledge of how Defendants infringe the ’381 Patent

at least as early as August 5, 2024 through a notice letter sent to Defendants. Defendants haveknowledge of the ’381 Patent and knowledge of how Defendants contribute to third parties’
infringement of that patent at least as early as August 5, 2024.
97.

Defendants’ infringement of the ’381 Patent has been and continues to be willful.

At least as early as August 5, 2024, Defendants were notified of their infringing acts anddeliberately continued to infringe the ’381 Patent despite knowing of the existence of the patentand how Defendants infringe. Further, Defendants have deliberately continued to encourageothers’ infringement of the ’381 Patent, including by continuing to disseminate its marketing andtechnical materials to customers.
98.

Defendants’ acts of infringement have injured and damaged Stratasys and willcontinue to injure and damage Stratasys. Stratasys is therefore entitled to recover from Defendants
the damages it has sustained as a result of Defendants’ wrongful and continued acts in an amountto be proven at trial.
99.

Defendants’ infringement has damaged and will continue to damage Stratasys

irreparably, and Stratasys has no adequate remedy at law for its injuries. In addition to actual
damages, Stratasys is entitled to a permanent injunction enjoining Defendants from infringing the’381 Patent.
100.

Stratasys is entitled to all damages to which it otherwise is entitled because it hascomplied with 35 U.S.C. 287 by marking its patent-practicing products with the number of the’381 Patent.

- 27 -

Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 29 of 30 PageID #: 29

V.

JURY DEMAND

101.

Plaintiff hereby demands a trial by jury.

102.

The ’713 Patent, the ’660 Patent, the ’357 Patent, the ’698 Patent and the ’381

Patent are collectively referred to as “Asserted Patents.”
PRAYER
WHEREFORE, Plaintiff prays for judgment in their favor on all counts in the Complaint
and requests relief as follows:
A. Declaring that Defendants have infringed the Asserted Patents, directly and indirectly,
literally and/or under the doctrine of equivalents.
B. Awarding Stratasys damages arising out of this infringement of the Asserted Patents,
including enhanced damages pursuant to 35 U.S.C. 284.
C. Permanently enjoining Defendants and their respective officers, agents, servants,
employees, and those acting in privity with it, from further infringement, including
inducing infringement and contributory infringement, of the Asserted Patents.
D. Awarding attorneys’ fees to Stratasys pursuant to 35 U.S.C. 285 or as otherwise
permitted by law; andE. Awarding to Stratasys such other costs and further relief as the Court deems just andproper.

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Case 2:24-cv-00644-JRG Document 1 Filed 08/08/24 Page 30 of 30 PageID #: 30

Dated: August 8, 2024

Respectfully submitted,
By: /s/ Kevin J. Meek by permission Andrea
L. Fair
Kevin J. Meek
Texas Bar No. 13899600
Brian Oaks
Texas Bar No. 24007767
Syed K. Fareed
Texas Bar No. 24065216
Aashish Kapadia
Texas Bar No. 24097917
MCDERMOTT WILL & EMERY LLP
303 Colorado Street, Suite 2200
Austin, Texas 78701-4078
Telephone: (512) 726-2600
Facsimile: (512) 532-0002
kmeek@mwe.com
boaks@mwe.com
sfareed@mwe.com
akapadia@mwe.com
Deron R. Dacus
Texas Bar No. 00790553
THE DACUS FIRM, P.C.
821 ESE Loop 323, Suite 430
Tyler, Texas 75701
903-705-1117 (phone)903-581-2543 (fax)ddacus@dacusfirm.com
Andrea L. Fair
Texas Bar No. 24078488
Claire A. Henry
Texas Bar No. 24053063
WARD, SMITH & HILL, PLLC
1507 Bill Owens Parkway
Longview, Texas 75604
andrea@wsfirm.com
ATTORNEYS FOR PLAINTIFF
STRATASYS, INC.

- 29 -