IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

IRONWORKS PATENTS, LLC, 

Plaintiff,

v.

ONEPLUS TECHNOLOGY 

(SHENZHEN) CO., LTD.

Defendant. 

Case No. 6:20-cv-252

COMPLAINT FOR PATENT

INFRINGEMENT AND 

JURY TRIAL DEMANDED

COMPLAINT

Plaintiff Ironworks Patents LLC (“Ironworks” or “Plaintiff”) files this Complaint for patent 

infringement under the patent laws of the United States, Title 35 of the United States Code, against 

Defendant OnePlus Technology (Shenzhen) Co., Ltd. (“OnePlus” or “Defendant”) that relates to 

three U.S. patents owned by Ironworks: 6,850,150; 8,847,734; and 9,521,269 (collectively, the 

“Patents-in-Suit”). 

PARTIES

1. Plaintiff Ironworks is a limited liability company organized under the laws of the

State of Illinois, with an office at 125 S. Clark St., 17th Floor, Chicago, Illinois 60603. 

2. Defendant OnePlus is a corporation duly organized and existing under the laws of

China, with its principal place of business at 18F, Tairan Building, Block C, Tairan 8th Road, 

Chegongmiao, Futian District Shenzhen, Guangdong, 518040, China. On information and belief, 

OnePlus can be served with process at that address. 

3. OnePlus makes, uses, imports, sells and offers for sale wireless mobile devices,

including smartphones. 

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4. OnePlus is ranked by independent industry analysts as a top-five phone 

manufacturer in the United States. 

JURISDICTION AND VENUE

5. This is a civil action for patent infringement arising under the Patent Laws of the 

United States, 35 U.S.C. § 1, et seq., and more particularly 35 U.S.C. § 271.

6. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. 

§§ 1331 and 1338(a).

7. Defendant OnePlus is subject to this Court’s general personal jurisdiction due at 

least to its substantial business conducted in this District, including: its place of business (national 

repair center) at 3918 Range Rd Ste B, Temple, Texas 76504. In addition, OnePlus has solicited 

business in the State of Texas, transacted business within the State of Texas and attempted to 

derive financial benefit from residents of the State of Texas in this District, including benefits 

directly related to the instant patent infringement causes of action set forth herein; (ii) having 

placed its products and services into the stream of commerce throughout the United States and 

having been actively engaged in transacting business in Texas and in this District, and (iii) having 

committed the complained of tortious acts in Texas and in this District.

8. OnePlus, directly and/or through subsidiaries and agents (including distributors, 

retailers, and others), makes, imports, ships, distributes, offers for sale, sells, uses, and advertises 

(including offering products and services through its website, https://www.oneplus.com, as well 

as other retailers) its products and/or services in the United States, the State of Texas, and the 

Western District of Texas. 

9. OnePlus, directly and/or through its subsidiaries and agents (including distributors, 

retailers, and others), has purposefully and voluntarily placed one or more of its infringing products 

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and/or services, as described below, into the stream of commerce with the expectation that they 

will be purchased and used by consumers in the Western District of Texas. These infringing 

products and/or services have been and continue to be purchased and used by consumers in the 

Western District of Texas. OnePlus has committed acts of patent infringement within the State of 

Texas and, more particularly, within the Western District of Texas. 

10. Venue is proper in this District under 28 U.S.C. §§ 1391 (b) and (c) and 1400(b). 

Defendant is subject to personal jurisdiction in this District, has transacted business in this District, 

and has committed acts of patent infringement in this District.

11. Venue is proper as to OnePlus, which is organized under the laws of China, under 

28 U.S.C. § 1391(c)(3), which provides that “a defendant not resident in the United States may be 

sued in any judicial district, and the joinder of such a defendant shall be disregarded in determining 

where the action may be brought with respect to other defendants.”

BACKGROUND FACTS REGARDING THE IRONWORKS PATENTS

12. Ironworks is the owner of record and assignee of each of U.S. Patent Nos. 6,850,150

(“the ’150 Patent”); 8,847,734 (“the ’734 Patent”); and 9,521,269 (“the ’269 Patent”) (collectively 

the “Patents-in-Suit”).

13. The ’150 Patent was originally filed by, and assigned to, Nokia Mobile Devices

Ltd. (“Nokia”). The ’734 Patent is a continuation of the ’150 Patent and the ’269 Patent is a 

continuation the ’734 Patent. 

14. Nokia is a Finnish multinational communications and information technology 

company, and at one time was the world’s largest producer of mobile phones.

15. For example, the world’s first mobile phone satellite call was made on a Nokia 

phone.

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16. For more than 20 years, Nokia has defined many of the fundamental technologies 

used in virtually all mobile devices and taken a leadership role in standards setting. As a result, 

Nokia owns a leading share of essential patents for GSM, 3G radio and 4G LTE technologies. 

These, together with other Nokia patents for Wi-Fi and video standards, form the core of Nokia’s 

patent portfolio. 

17. Between 1984 and 2014, Nokia has invested more than 50 billion Euros to create a 

portfolio of 30,000 patents and patent applications. Nokia’s long history of innovation has resulted 

in the company being awarded more than 30,000 patents in more than 10,000 patent families.

THE PATENTS-IN-SUIT AND CLAIMS-IN-SUIT

18. Ironworks has the exclusive right to sue and the exclusive right to recover damages 

for infringement of the Patents-in-Suit during all relevant time periods.

19. On February 1, 2005, the ’150 Patent entitled “Portable Device” was duly and 

legally issued by the USPTO. 

20. On September 30, 2014, the ’734 Patent entitled “Method of giving the user 

information, portable device, and computer program product” was duly and legally issued by the 

USPTO. 

21. On December 13, 2016, the ’269 Patent entitled “Method of giving the user 

information and portable device” was duly and legally issued by the USPTO. 

ONEPLUS’S INFRINGING PRODUCTS

22. OnePlus has been, and now is, directly infringing claims of the Patents-in-Suit 

under 35 U.S.C. § 271(a) by making, using, offering for sale, selling, and/or importing the below 

accused smartphones and other mobile wireless devices in this District and elsewhere in the United 

States that include the systems claimed in the Patents-in-Suit.

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23. OnePlus has been and now is inducing the direct infringement of claims of the 

Patents-in-Suit pursuant to U.S.C. § 271(b) at least by one or more of making, using, offering for 

sale, selling and/or importing the below accused smartphones in this District and elsewhere in the 

United States that were designed and intended to be covered by the Patents-in-Suit. Further, 

OnePlus has induced infringement by, for example, providing user guides and other support 

materials and services to its users and by advertising features that are used, and benefits that are 

achieved through use of the Patents-in-Suit.

24. Despite OnePlus’s awareness of the Patents-in-Suit, OnePlus has continued these 

acts of inducement with specific intent to cause and encourage direct infringement of the Patentsin-Suit with willful blindness that such activities occurred, are still occurring, and constitute direct 

infringement of the Patents-in-Suit.

ONEPLUS’S KNOWLEDGE OF THE PATENTS-IN-SUIT

AND CONTINUED INFRINGEMENT DESPITE THAT KNOWLEDGE

25. The Patents-in-Suit were previously owned by MobileMedia Ideas, LLC (“MMI”).

MMI assigned the Patents-in-Suit to Ironworks in March 2017.

26. On May 23, 2019, counsel for Ironworks sent a letter to Mr. Bingo Hu, Legal 

Director of OnePlus Technology Co. Ltd

27. The letter provided background information on the Ironworks patent portfolio, 

including specific information about the Patents-in-Suit. 

28. Counsel for Ironworks also provided claim charts that detailed OnePlus’ 

infringement of the Patents-in-Suit. 

29. To Ironworks’ knowledge, OnePlus never raised any non-infringement defense 

related to any of the Patents-in-Suit and never raised any prior art issues related to any of the 

Patents-in-Suit.

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30. OnePlus has not agreed to enter into a licensing agreement with MMI or Ironworks.

31. This Complaint serves as additional notice to OnePlus of the Patents-in-Suit and 

the manner in which they are infringed.

32. Despite knowledge of the Patents-in-Suit and knowledge of the manner in which 

the Patents-in-Suit are infringed as demonstrated in the provided claim charts, OnePlus has 

continued to infringe, and/or induce the infringement of, the Patents-in-Suit.

COUNT I: INFRINGEMENT OF U.S. PAT. 6,850,150 CLAIM 1

33. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 32 of this Complaint as though set forth in full herein.

34. Claim 1 of the ’150 Patent provides:

Preamble to 

Claim 1

A portable device, comprising:

Element A control means for monitoring and controlling the operation of the device;

Element B and a user interface which comprises alarm means for performing a silent 

alarm producing a silent, invisible, tactile sensation in the user;

Element C wherein the control means are arranged to give the user abstract information 

on multiple internal operational events of the device by using various alarm 

patterns of silent, invisible sensations produced by the alarm means and 

sensed by the user, 

Element D the alarm patterns differing from one another such that at least one alarm 

pattern characteristic sensed by the user varies, said abstract information 

comprising a notification of a selected item on a menu of the user interface.

35. Defendant makes, uses, sells, offers for sale, and/or imports wireless mobile 

devices, including mobile smartphones that are mobile stations (“Accused ’150 OnePlus 

Devices”). Accused ’150 OnePlus Devices include, for example, at least OnePlus One, 2, X, 3, 

3T, 5, 5T, 6, 6T, 7, 7 Pro, 7T, and 7T Pro devices.

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36. Defendant has and continues to make, use, sell, import, and/or offer for sale the 

Accused ’150 OnePlus Devices that meet each and every element of claim 1 of the ’150 Patent.

37. Accused ’150 OnePlus Devices are portable devices as described in this claim.

38. Accused ’150 OnePlus Devices include a control means (e.g., a microprocessor 

with operating system software) for monitoring and controlling the operation of the device.

39. Accused ’150 OnePlus Devices include a user interface, which includes alarm 

means (e.g., a vibration motor) for performing a silent alarm producing a silent, invisible, tactile 

sensation (e.g., vibration) in the user.

40. Accused ’150 OnePlus Devices’ microprocessor and operating system are 

arranged to give the user abstract information on multiple internal operational events of the 

device by using various vibration patterns produced by the vibration motor and sensed by the 

user.

41. Accused ’150 OnePlus Devices’ vibration patterns differ from one another so that 

the vibration characteristics sensed by the user varies.

42. The various vibration patterns give OnePlus device users abstract information on 

internal operational events of the device, including a notification of a selected item on a menu of 

the user interface.

43. The technology claimed in claim 1 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

44. Defendant had knowledge of the ’150 Patent since at least May 2019.

45. Defendant directly infringes at least claim 1 of the ’150 Patent by manufacturing 

and selling Accused ’150 OnePlus Devices.

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46. Defendant makes, uses, and/or imports the Accused ’150 OnePlus Devices 

knowing that Defendant has infringed and continues to infringe at least claim 1 of the ’150 

Patent under 35 U.S.C. § 271(a) directly.

47. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT II: INFRINGEMENT OF U.S. PAT. 6,850,150 CLAIM 2

48. Ironworks reasserts and realleges paragraphs 1 through 47 of this Complaint as 

though set forth fully here.

49. Claim 2 of the ’150 Patent provides:

Element A A portable device as claimed in claim 1, wherein the alarm means are a 

vibrating alarm.

50. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’150 

OnePlus Devices that meet each and every element of claim 2 of the ’150 Patent.

51. Accused ’150 OnePlus Devices include alarm means that are a vibrating alarm.

52. The technology claimed in claim 2 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

53. Defendant had knowledge of the ’150 Patent since at least May 2019.

54. Defendant directly infringes at least claim 2 of the ’150 Patent by manufacturing 

and selling Accused ’150 OnePlus Devices.

55. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

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COUNT III: INFRINGEMENT OF U.S. PAT. 6,850,150 CLAIM 10

56. Ironworks reasserts and realleges paragraphs 1 through 55 of this Complaint as 

though set forth fully here.

57. Claim 10 of the ’150 Patent provides:

Element A A portable device as claimed in claim 1, wherein the portable device is a 

subscriber terminal in a telecommunication system.

58. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’150 

OnePlus Devices that meet each and every element of claim 10 of the ’150 Patent.

59. Accused ’150 OnePlus Devices are subscriber terminals in a telecommunication 

system.

60. The technology claimed in claim 10 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

61. Defendant had knowledge of the ’150 Patent since at least May 2019.

62. Defendant directly infringes at least claim 10 of the ’150 Patent by manufacturing 

and selling Accused ’150 OnePlus Devices.

63. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT IV: INFRINGEMENT OF PAT. 8,847,734 CLAIM 1

64. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 63 of this Complaint as though set forth in full herein.

65. Claim 1 of the ’734 Patent provides:

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Preamble 

to Claim 1

A mobile station comprising:

Element A a user interface configured to enable a user to control operation of the 

mobile station by manual input and to obtain information on the operation 

of the mobile station,

Element B a tactile alert device configured to generate a tactile vibration, and

Element C a control circuit configured to control the tactile alert device to generate a 

first tactile vibration with a first pattern in response to a first event and a 

second tactile vibration with a second pattern that is distinctly humanly 

perceptibly different from the first pattern in response to a second event 

different from the first event,

Element D wherein one of the events is user entry of an incorrect personal 

identification number code.

66. OnePlus makes, uses, sells, offers for sale, and/or imports wireless mobile devices, 

including mobile smartphones that are mobile stations (“Accused ’734 OnePlus Devices”). 

Accused ’734 OnePlus Devices include, for example, at least OnePlus One, 2, X, 3, 3T, 5, 5T, 6, 

6T, 7, 7 Pro, 7T, and 7T Pro devices that vibrate when an incorrect PIN or passcode is entered.

67. Accused ’734 OnePlus Devices are mobile stations as described in this claim.

68. Accused ’734 OnePlus Devices include a user interface that is configured to enable 

a user to control operation of the mobile station by manual input (e.g., touching the touchscreen) 

and to obtain information on the operation of the mobile station (e.g., when a phone call is 

incoming).

69. Accused ’734 OnePlus Devices include a tactile alert device (e.g., a vibration 

motor) configured to generate a tactile vibration.

70. Accused ’734 OnePlus Devices include a control circuit configured to control the 

tactile alert device. The tactile alert device can generate a first tactile vibration with a first pattern 

in response to a first event (e.g., an incoming call) and a second tactile vibration with a second 

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pattern that is distinctly humanly perceptibly different from the first pattern in response to a second 

event (e.g., entry of an incorrect PIN).

71. Accused ’734 OnePlus Devices vibrate when an incorrect personal identification 

number code (e.g., passcode) has been entered.

72. The technology claimed in claim 1 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

73. OnePlus had knowledge of the ’734 Patent since at least May 2019.

74. OnePlus directly infringes at least claim 1 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

75. OnePlus makes, uses, and/or imports the Accused ’734 OnePlus Devices knowing 

that OnePlus has infringed and continues to infringe at least claim 1 of the ’734 Patent under 35 

U.S.C. § 271(a) directly.

76. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT V: INFRINGEMENT OF PAT. 8,847,734 CLAIM 2

77. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 76 of this Complaint as though set forth in full herein.

78. Claim 2 of the ’734 Patent provides:

Element A The mobile station of claim 1 wherein the mobile station is a mobile 

telephone.

79. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 2 of the ’734 Patent.

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80. Accused ’734 OnePlus Devices are mobile telephones.

81. The technology claimed in claim 2 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

82. OnePlus had knowledge of the ’734 Patent since at least May 2019.

83. OnePlus directly infringes at least claim 2 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

84. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT VI: INFRINGEMENT OF PAT. 8,847,734 CLAIM 3

85. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 84 of this Complaint as though set forth in full herein.

86. Claim 3 of the ’734 Patent provides:

Preamble 

to Claim 3

The mobile station of claim 1 further comprising:

Element A a transceiver for generating a transmitted signal and handling a received 

signal, and

Element B an antenna coupled to the transceiver for receiving a wireless signal and for 

transmitting a wireless signal.

87. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 3 of the ’734 Patent.

88. Accused ’734 OnePlus Devices include a transceiver for generating a transmitted 

signal and handling a received signal, and an antenna coupled to the transceiver for receiving a 

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wireless signal and for transmitting a wireless signal.

89. The technology claimed in claim 3 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

90. OnePlus had knowledge of the ’734 Patent since at least May 2019.

91. OnePlus directly infringes at least claim 3 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

92. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT VII: INFRINGEMENT OF PAT. 8,847,734 CLAIM 4

93. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 92 of this Complaint as though set forth in full herein.

94. Claim 4 of the ’734 Patent provides:

Element A The mobile station of claim 1 further comprising a battery for supplying 

power to the mobile station.

95. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 4 of the ’734 Patent.

96. Accused ’734 OnePlus Devices include a battery for supplying power to the mobile 

station.

97. The technology claimed in claim 4 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

98. OnePlus had knowledge of the ’734 Patent since at least May 2019.

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99. OnePlus directly infringes at least claim 4 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

100. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT VIII: INFRINGEMENT OF PAT. 8,847,734 CLAIM 5

101. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 100 of this Complaint as though set forth in full herein.

102. Claim 5 of the ’734 Patent provides:

Preamble 

to Claim 5

The mobile station of claim 1 wherein the user interface further comprises:

Element A a flat panel display,

Element B a microphone configured to receive speech to be transmitted,

Element C a loudspeaker configured to generate sounds,

Element D a camera, and

Element E a circuit configured to receive manual input of a user for manually 

controlling the operation of the mobile station.

103. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 5 of the ’734 Patent.

104. Accused ’734 OnePlus Devices include a flat panel display, a microphone 

configured to receive speech to be transmitted, a loudspeaker configured to generate sounds, a 

camera, and a circuit configured to receive manual input of a user for manually controlling the 

operation of the mobile station.

105. The technology claimed in claim 5 was not well understood, routine, or 

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conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

106. OnePlus had knowledge of the ’734 Patent since at least May 2019.

107. OnePlus directly infringes at least claim 5 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

108. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT IX: INFRINGEMENT OF PAT. 8,847,734 CLAIM 6

109. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 108 of this Complaint as though set forth in full herein.

110. Claim 6 of the ’734 Patent provides:

Preamble 

to Claim 6

The mobile station of claim 1 wherein the control circuit further comprises:

Element A a microprocessor, and

Element B software executed by the microprocessor.

111. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 6 of the ’734 Patent.

112. Accused ’734 OnePlus Devices include a control circuit, which includes a 

microprocessor, and software executed by the microprocessor.

113. The technology claimed in claim 6 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

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114. OnePlus had knowledge of the ’734 Patent since at least May 2019.

115. OnePlus directly infringes at least claim 6 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

116. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT X: INFRINGEMENT OF PAT. 8,847,734 CLAIM 7

117. Ironworks Patents incorporates by reference the allegations set forth in paragraphs 

1 to 116 of this Complaint as though set forth in full herein.

118. Claim 7 of the ’734 Patent provides:

Element A The mobile station of claim 1 where the control circuit is configured to 

monitor and control operation of the mobile station, to monitor and control 

the operation of the user interface and to control the operation of the tactile 

alert device.

119. OnePlus makes, uses, sells, offers for sale, and/or imports the Accused ’734 

OnePlus Devices that meet each and every element of claim 7 of the ’734 Patent.

120. Accused ’734 OnePlus Devices include a control circuit configured to monitor and 

control operation of the mobile station, to monitor and control the operation of the user interface, 

and to control the operation of the tactile alert device.

121. The technology claimed in claim 7 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

122. OnePlus had knowledge of the ’734 Patent since at least May 2019.

123. OnePlus directly infringes at least claim 7 of the ’734 Patent by manufacturing and 

selling Accused ’734 OnePlus Devices. 

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124. As a direct and proximate result of OnePlus’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XI: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 1

125. Ironworks reasserts and realleges paragraphs 1 through 124 of this Complaint as 

though set forth fully here.

126. Claim 1 of the ’269 Patent provides:

Preamble to 

Claim 1

A mobile station comprising:

Element A a user interface configured to enable a user to control operation of the mobile 

station by manual input and to obtain information on the operation of the 

mobile station,

Element B a tactile alert device configured to generate a tactile vibration, and

Element C a control circuit configured to control the tactile alert device to generate a 

first tactile vibration with a first pattern in response to a first event and a 

second tactile vibration with a second pattern that is distinctly humanly 

perceptibly different from the first pattern in response to a second event 

different from the first event,

Element D wherein the first event is correct user manual input.

127. Defendant makes, uses, sells, offers for sale, and/or imports wireless mobile 

devices, including mobile smartphones that are mobile stations (“Accused ’269 OnePlus

Devices”). The Accused ’269 OnePlus Devices include, for example, at least OnePlus One, 2, X, 

3, 3T, 5, 5T, 6, 6T, 7, 7 Pro, 7T, and 7T Pro devices.

128. Defendant has and continues to make, use, sell, import, and/or offer for sale the 

Accused ’269 OnePlus Devices that meet each and every element of claim 1 of the ’269 Patent.

129. Accused ’269 OnePlus Devices are mobile stations.

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130. Accused ’269 OnePlus Devices include a user interface configured to enable a user 

to control operation of the mobile station by manual input and to obtain information on the 

operation of the mobile station.

131. Accused ’269 OnePlus Devices include a tactile alert device (e.g., a vibration 

motor) configured to generate a tactile vibration.

132. Accused ’269 OnePlus Devices include a control circuit configured to control the 

tactile alert device to generate a first tactile vibration with a first pattern in response to a first event 

(e.g., a fingerprint scan) and a second tactile vibration with a second pattern that is distinctly 

humanly perceptibly different from the first pattern in response to a second event (e.g., an incoming 

phone call) different from the first event.

133. The first event is correct user manual input.

134. The technology claimed in claim 1 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

135. OnePlus had knowledge of the ’269 Patent since at least May 2019.

136. Defendant directly infringes at least claim 1 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

137. Defendant makes, uses, and/or imports the Accused ’269 OnePlus Devices 

knowing that Defendant has infringed and continues to infringe at least claim 1 of the ’269 Patent 

under 35 U.S.C. § 271(a) directly.

138. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

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COUNT XII: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 5

139. Ironworks reasserts and realleges paragraphs 1 through 138 of this Complaint as 

though set forth fully here.

140. Claim 5 of the ’269 Patent provides:

Element A The mobile station of claim 1, wherein the second event is an incoming call.

141. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 5 of the ’269 Patent.

142. Accused ’269 OnePlus Devices generate a second tactile vibration with a second 

pattern in response to an incoming call.

143. The technology claimed in claim 5 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

144. OnePlus had knowledge of the ’269 Patent since at least May 2019.

145. Defendant directly infringes at least claim 5 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

146. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XIII: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 9

147. Ironworks reasserts and realleges paragraphs 1 through 146 of this Complaint as 

though set forth fully here.

148. Claim 9 of the ’269 Patent provides:

Element A The mobile station of claim 1, wherein the mobile station is a mobile 

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telephone.

149. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 9 of the ’269 Patent.

150. Accused ’269 OnePlus Devices are mobile telephones.

151. The technology claimed in claim 9 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

152. OnePlus had knowledge of the ’269 Patent since at least May 2019.

153. Defendant directly infringes at least claim 9 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

154. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XIV: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 10

155. Ironworks reasserts and realleges paragraphs 1 through 154 of this Complaint as 

though set forth fully here.

156. Claim 10 of the ’269 Patent provides:

Preamble to 

Claim 10

The mobile station of claim 1 further comprising:

Element A a transceiver configured to generate a transmitted signal and to handle a 

received signal, and

Element B an antenna coupled to the transceiver and configured to receive a first 

wireless signal as the received signal and to transmit the transmitted signal 

as a second wireless signal.

157. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

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OnePlus Devices that meet each and every element of claim 10 of the ’269 Patent.

158. Accused ’269 OnePlus Devices include a transceiver configured to generate a 

transmitted signal and to handle a received signal.

159. Accused ’269 OnePlus Devices include an antenna coupled to the transceiver and 

configured to receive a first wireless signal as the received signal and to transmit the transmitted 

signal as a second wireless signal.

160. The technology claimed in claim 10 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

161. OnePlus had knowledge of the ’269 Patent since at least May 2019.

162. Defendant directly infringes at least claim 10 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

163. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XV: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 11

164. Ironworks reasserts and realleges paragraphs 1 through 163 of this Complaint as 

though set forth fully here.

165. Claim 11 of the ’269 Patent provides:

Element A The mobile station of claim 1 further comprising a battery configured to 

supply power to the mobile station.

166. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 11 of the ’269 Patent.

167. Accused ’269 OnePlus Devices include a battery configured to supply power to the 

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mobile station.

168. The technology claimed in claim 11 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

169. OnePlus had knowledge of the ’269 Patent since at least May 2019.

170. Defendant directly infringes at least claim 11 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

171. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XVI: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 12

172. Ironworks reasserts and realleges paragraphs 1 through 171 of this Complaint as 

though set forth fully here.

173. Claim 12 of the ’269 Patent provides:

Preamble to 

Claim 12

The mobile station of claim 1, wherein the user interface comprises:

Element A a flat panel display,

Element B a microphone configured to receive speech to be transmitted,

Element C a loudspeaker configured to generate sounds,

Element D a camera, and

Element E a circuit configured to receive manual input of a user for manually 

controlling the operation of the mobile station.

174. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 12 of the ’269 Patent.

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175. The user interfaces of the Accused ’269 OnePlus Devices include a flat panel 

display, a microphone configured to receive speech to be transmitted, a loudspeaker configured to 

generate sounds, a camera, and a circuit configured to receive manual input of a user for manually 

controlling the operation of the mobile station.

176. The technology claimed in claim 12 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

177. OnePlus had knowledge of the ’269 Patent since at least May 2019.

178. Defendant directly infringes at least claim 12 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

179. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XVII: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 13

180. Ironworks reasserts and realleges paragraphs 1 through 179 of this Complaint as 

though set forth fully here.

181. Claim 13 of the ’269 Patent provides:

Preamble to 

Claim 13

The mobile station of claim 1, wherein the control circuit further comprises:

Element A a microprocessor, and

Element B software executed by the microprocessor.

182. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 13 of the ’269 Patent.

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183. The control circuits of the Accused ’269 OnePlus Devices include a microprocessor 

and software executed by the microprocessor.

184. The technology claimed in claim 13 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

185. OnePlus had knowledge of the ’269 Patent since at least May 2019.

186. Defendant directly infringes at least claim 13 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

187. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XVIII: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 17

188. Ironworks reasserts and realleges paragraphs 1 through 187 of this Complaint as 

though set forth fully here.

189. Claim 17 of the ’269 Patent provides:

Element A The mobile station of claim 1, wherein the first vibration provides user 

feedback at the time that the first event has occurred.

190. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 17 of the ’269 Patent.

191. Accused ’269 OnePlus Devices generate the first vibration, which provides user 

feedback at the time that the first event has occurred.

192. The technology claimed in claim 17 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

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193. OnePlus had knowledge of the ’269 Patent since at least May 2019.

194. Defendant directly infringes at least claim 17 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

195. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

sustain damages.

COUNT XIX: INFRINGEMENT OF U.S. PAT. 9,521,269 CLAIM 18

196. Ironworks reasserts and realleges paragraphs 1 through 195 of this Complaint as 

though set forth fully here.

197. Claim 18 of the ’269 Patent provides:

Element A The mobile station of claim 1, wherein the first event is correct user manual 

input at the user interface.

198. Defendant makes, uses, sells, offers for sale, and/or imports the Accused ’269 

OnePlus Devices that meet each and every element of claim 18 of the ’269 Patent.

199. Accused ’269 OnePlus Devices generate a tactile vibration in response to correct 

user manual input at the user interface.

200. The technology claimed in claim 18 was not well understood, routine, or 

conventional at the time that the application was filed and provided a technological solution to a 

technological problem rooted in computer technology.

201. OnePlus had knowledge of the ’269 Patent since at least May 2019.

202. Defendant directly infringes at least claim 18 of the ’269 Patent by manufacturing 

and selling Accused ’269 OnePlus Devices.

203. As a direct and proximate result of Defendant’s acts of patent infringement, 

Ironworks Patents has been and continues to be injured and has sustained and will continue to 

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sustain damages.

WILLFUL INFRINGEMENT

204. OnePlus has infringed and continues to infringe the above identified claims of each 

of the Patents-in-Suit despite its knowledge of the ’150, ’734, and ’269 Patents and how OnePlus 

devices infringe claims of those Patents since at least as early as May 2019 and despite the 

objectively high likelihood that its actions constitute patent infringement.

205. OnePlus’s infringement of the Patents-in-Suit is willful and deliberate and its 

actions constitute egregious misconduct, including refusing to take a license, refusing to negotiate 

in good faith, and having knowledge of the Patents-in-Suit and notice of the infringement but 

having no reasonable factual basis for non-infringement or invalidity. This willful misconduct by 

OnePlus entitles Ironworks to enhanced damages under 35 U.S.C. § 284 and to attorneys’ fees and 

costs incurred in prosecuting this action under 35 U.S.C. § 285.

JURY DEMAND

Ironworks demands a trial by jury on all issues that may be so tried. 

REQUEST FOR RELIEF

WHEREFORE, Plaintiff Ironworks requests that this Court enter judgment in its favor and 

against Defendant OnePlus as follows:

A. Adjudging, finding, and declaring that OnePlus has infringed the above-identified 

claims of each of the Patents-in-Suit under 35 U.S.C. § 271;

B. Awarding the past and future damages arising out of OnePlus’s infringement of the 

Patents-in-Suit to Ironworks in an amount no less than a reasonable royalty, together with 

prejudgment and post-judgment interest, in an amount according to proof;

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C. Adjudging, finding, and declaring that OnePlus’s infringement is willful and 

awarding enhanced damages and fees as a result of that willfulness under 35 U.S.C. § 284;

D. Adjudging, finding, and declaring that the Patents-in-Suit are valid and enforceable;

E. Awarding attorney’s fees, costs, or other damages pursuant to 35 U.S.C. §§ 284 or 

285 or as otherwise permitted by law; and

F. Granting Ironworks such other further relief as is just and proper, or as the Court 

deems appropriate. 

DATED: March 31, 2020

Respectfully submitted,

/s/ Alison Aubry Richards

Alison Aubry Richards

IL Bar # 6285669 (also admitted in WD Texas)

arichards@giplg.com

Global IP Law Group, LLC

55 West Monroe Street, Suite 3400

Chicago, IL 60603

(312) 241-1500

Attorney for Plaintiff Ironworks Patents, LLC

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