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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

Daedalus Blue LLC 

Plaintiff, 

v. 

SZ DJI Technology Co., Ltd., & 

DJI Europe B.V.

Defendants.

Civil Action No. 

The Honorable ________________________ 

COMPLAINT FOR PATENT 

INFRINGEMENT

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL 

TO THE HONORABLE JUDGE OF SAID COURT: 

 Plaintiff Daedalus Blue LLC (“Daedalus Blue”), files this Complaint for Patent 

Infringement and Damages against Defendants SZ DJI Technology Co., Ltd. and DJI Europe B.V. 

(collectively, “DJI” or “Defendants”), and would respectfully show the Court as follows: 

PARTIES 

1. Plaintiff Daedalus Blue is a Delaware limited liability company with its principal place of 

business located at 51 Pondfield Rd., Suite 3, Bronxville, NY 10708. 

2. On information and belief, Defendant SZ DJI Technology Co., Ltd. is a Chinese 

corporation with its principal place of business at 14th Floor, West Wing, Skyworth 

Semiconductor Design Building, No. 18 Gaoxin South 4th Ave, Nanshan District, 

Shenzhen, China. On information and belief, Defendant SZ DJI Technology Co., Ltd. is 

responsible for the development of DJI branded products sold in the United States. 

Although Defendant is engaged in business in the State of Texas, it has not designated an 

agent for service of process in the State. The Secretary of State, therefore, is an agent for 

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service of process for SZ DJI Technology Co., Ltd. pursuant to TEX. CIV. PRAC. & REM.

CODE § 17.044(b). 

3. On information and belief, Defendant DJI Europe B.V. is a European corporation with its 

principal place of business at Bijdorp-Oost 6, 2992 LA Barendrecht, Netherlands. On 

information and belief, DJI Europe B.V. sells DJI branded products in the United States. 

Although DJI Europe B.V. is engaged in business in the State of Texas, it has not designated 

an agent for service of process in the State. The Secretary of State, therefore, is an agent 

for service or process for DJI Europe B.V. pursuant to TEX. CIV. PRAC. & REM. CODE

§17.044(b). 

JURISDICTION AND VENUE 

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

States as set forth in 35 U.S.C. §§ 271, et seq. 

5. This Court has federal subject matter jurisdiction over this action pursuant to 28 U.S.C. 

§§ 1331 and 1338(a). 

6. This Court has personal jurisdiction over Defendants pursuant to TEX. CIV. PRAC. & REM.

CODE § 17.041 et seq. General personal jurisdiction exists over Defendants because 

Defendants have minimum contacts with this forum as a result of business regularly 

conducted within the State of Texas and within this district, and, on information and 

belief, specific personal jurisdiction exists because Defendants have, at least, committed 

the tort of patent infringement within Texas and this district. Personal jurisdiction also 

exists because, on information and belief, Defendants have: (1) operated the Internet 

website, https://www.dji.com/, which is available to and accessed by users, customers, 

and potential customers of the Defendants within this judicial district; (2) sold 

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Defendants’ drone and drone-related products within this judicial district; (3) transacted 

business within the State of Texas; (4) actively infringed and/or induced infringement in 

Texas; (5) established regular and systematic business contacts within the State of Texas; 

and (6) continue to conduct such business in Texas through the sale of Defendants’ drone 

and drone-related products. Accordingly, this Court’s jurisdiction over the Defendants 

comports with the constitutional standards of fair play and substantial justice and arises 

directly from the Defendants’ purposeful minimum contacts with the State of Texas. 

7. This Court also has personal jurisdiction over Defendants because, on information and 

belief, DJI and its authorized resellers (or those acting on their behalf) and DJI’s customers 

committed and continue to commit acts of patent infringement in this judicial district. 

Defendants transact business within the State of Texas and in this judicial district and have 

committed acts of patent infringement within the State of Texas and this judicial district as 

set forth hereinafter. Such business includes, without limitation, Defendants’ operation of 

the Internet website, https://www.dji.com/, which is available to and accessed by users, 

customers, and potential customers of the Defendants within this judicial district, and the 

sale of Defendants’ drone and drone-related products within this judicial district, both 

online at http://store.dji.com and through other official online stores, resellers/retail stores, 

and varied dealers within this jurisdiction, as provided at https://www.dji.com/where-tobuy/. 

8. In addition to Defendants’ own online store at http://store.djj.com, Defendants have also 

sold their drone and drone-related products within this judicial district via the following 

means: 

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a. Defendants have official online stores with Amazon, Newegg, AliExpress, and 

eBay, all of which are available to and accessed by users, customers, and potential 

customers of the Defendants within this judicial district. 

b. In addition to official online stores, Defendants have a wide variety of resellers 

selling Defendants’ drones and drone-related products within this judicial district. 

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Texas 

Austin, Texas San Antonio, Texas 

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Waco, Texas El Paso, Texas 

Such resellers/retail stores include companies such as Walmart, Best Buy, Sam’s 

Club, Target, and Apple Store. 

Example 1: Austin, Texas 

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Example 2: San Antonio, Texas 

Example 3: Waco, Texas 

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Example 4: El Paso, Texas 

c. Defendants have also authorized over 80 online retailers, as listed at 

https://www.dji.com/where-to-buy/online-retails, and have extended warranties to 

products purchased from the authorized DJI Dealers. Such authorized dealers 

include those companies listed above (e.g. Walmart and Sam’s Club) and many 

more (e.g. Microsoft, BJ’s, Gamestop, Home Depot, Verizon Wireless, etc.). Most, 

if not all, of these online retailers are available to and accessed by users, customers, 

and potential customers of the defendant within this judicial district. 

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d. Defendants also have 25 designated professional dealers operating in the United 

States, all of which have online stores through which to sell Defendants’ drones and 

drone-related products, which are available to and accessed by users, customers, 

and potential customers of the Defendants within this judicial district. A complete 

list of professional dealers can be found at: https://www.dji.com/where-tobuy/professional-dealers. 

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e. On information and belief, relying in part on evidence presented in ¶ 8(b), DJI 

maintains a regular and established place of business with a significant physical 

presence in this judicial district, with a substantial amount of authorized resellers 

located within the district, as represented by information presented on: Austin, 

Texas; San Antonio, Texas; Waco, Texas; and El Paso, Texas. This information 

presented is not wholly representative of all authorized resellers located within the 

Western District of Texas, but merely demonstrative. 

9. Venue is proper in this Court under 28 U.S.C. §§ 1391(b) and (c) and 28 U.S.C. 

§ 1400(b) based on the information and belief that the Defendants have committed or 

induced acts of infringement, and/or advertise, market, sell, and/or offer to sell products, 

including infringing products, in this judicial district, as discussed above. 

THE PATENTS-IN-SUIT 

10. On June 5, 2007, United States Patent No. 7,228,232 (“the ‘232 patent”), entitled 

“Navigating a UAV with Obstacle Avoidance Algorithms,” was duly and legally issued 

by the United States Patent and Trademark Office (“USPTO”) to William Kress Bodin, 

Jesse Redman, and Derral Charles Thorson, with the International Business Machines 

Corporation (“IBM”) as assignee. A copy of the ‘232 patent is attached hereto as Exhibit 

A. 

11. On June 12, 2007, United States Patent No. 7,231,294 (“the ‘294 patent”), entitled 

“Navigating a UAV,” was duly and legally issued by the USPTO to William Kress Bodin, 

Jesse J. W. Redman, and Derral C. Thorson, with IBM as assignee. A copy of the ‘294 

patent is attached hereto as Exhibit B. 

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12. On October 23, 2007, United States Patent No. 7,286,913 (“the ‘913 patent”), entitled 

“Navigating a UAV with Telemetry Through a Socket,” was duly and legally issued by 

the USPTO to William Kress Bodin, Jesse J. W. Redman, and Derral C. Thorson, with 

IBM as assignee. A copy of the ‘913 patent is attached hereto as Exhibit C. 

13. The ‘232, ‘294, and ‘913 patents are referred to hereinafter as “the Daedalus Blue 

Patents.” 

14. Plaintiff Daedalus Blue LLC is the owner of the entire right, title, and interest in and to 

the Daedalus Blue Patents, with the right to sue in its own name. The Daedalus Blue 

Patents were initially assigned by IBM to Daedalus Group LLC on or about September 

30, 2019. The respective assignments were recorded on November 14, 2019, at the U.S. 

Patent and Trademark Office. Daedalus Group LLC then assigned the patents to 

Daedalus Blue LLC, on or about January 24, 2020. The respective assignments were 

recorded on or about January 29, 2020, at the U.S. Patent and Trademark Office. 

15. Each of the Daedalus Blue Patents are presumed valid under 35 U.S.C. § 282. 

16. All patents-in-suit relate to innovative technology for piloting, controlling, navigating, 

and optimizing flight missions for unmanned aerial vehicles (“UAV” or “drone”). 

United States Patent No. 7,228,232 

17. The ‘232 patent claimed UAV obstacle avoidance technologies that anticipate the future 

position of the UAV through GPS sequencing, and avoid obstacles in dependence of that 

anticipated future position. Such obstacles may be physical three-dimensional objects 

such as buildings, mountains, and others that will occur to those of skill in the art; or two 

and three -dimensional geographic areas such as a no-fly zone. In the present complaint, 

Defendants’ suite of drones and drone-related products (infra ¶ 30) infringe on this 

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inventive aspect of the ‘232 patent. Representative of this infringement is Defendants’ 

Phantom Series drones, including, but not limited to, the Phantom 4 Pro V2.0. The 

Phantom 4 Pro V2.0 houses a GPS module on-board, which transmits UAV location and 

flight control instructions back and forth from the UAV user’s remote-control device, and 

vice versa. In so doing, the GPS module tracks the UAV location and ensures the UAV is 

not entering a restricted zone and/or no fly zones. The Phantom 4 Pro V2.0, and other 

infringing UAVs described in later paragraphs, is designed to avoid these zones, either 

notifying the UAV user that the UAV is entering a zone or even disallowing take-off 

within a zone. Such functionality is within Defendants’ “Fly Safe” technology, as 

described at: https://www.dji.com/flysafe. All intelligent flight features are affected when 

DJI aircraft fly nearby or into GEO Zones. Such interference includes, but is not limited 

to, decreased speed, takeoff failure, and flight termination. 

18. The ‘232 patent overcomes shortcomings in the prior art, which required conventional 

UAV operators to manually control the flight using the camera images from the UAV that 

were provided to the operator through downlink telemetry (col. 1, lines 18-23). Certain of 

the inventive aspects of the ‘232 patent addressed the need for improvements in the area 

of UAV navigation, by automating certain aspects of the UAV mission (col. 1, lines 26-

30). More specifically, the inventive aspects of automatically identifying and avoiding 

obstacles that would otherwise disrupt the flight of the UAV (col. 17, lines 66-67), were 

not well-understood, routine, or conventional at the time of the invention. 

United States Patent No. 7,231,294

19. The ‘294 patent claims UAV navigation technologies that maps a UAV’s position, from 

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control device. In the present complaint, Defendants’ suite of drones and drone-related 

products (infra ¶ 30) infringe on this inventive aspect of the ‘294 patent. Representative 

of this infringement is Defendants’ Matrice Series, including, but not limited to the 

Matrice 200. The Matrice 200 functions with DJI’s “FlightHub,” the “DJI GO 4” 

application, “DJI GS Pro” application, and the “DJI Ground Station” application to map 

the UAVs’ position from the start of a mission, through mission waypoints, and to the end 

of a mission. For example, the Matrice 200, and other infringing products described in 

later paragraphs, use the DJI GO 4 application, which provides an “Intelligent Flight 

Mode” that maps the waypoints and starting position of a UAV’s mission through a GUI 

map and remote-control device. 

20. The ‘294 patent overcomes shortcomings in the prior art, which required conventional 

UAV operators to manually control the flight using the camera images from the UAV that 

were provided to the operator through downlink telemetry (col. 1, lines 17-20). Certain of 

the inventive aspects of the ‘294 patent addressed the need for improvements in the area 

of UAV navigation, by automating certain aspects of the UAV mission (col. 1, lines 24-

28). More specifically, the inventive aspects of automatically selecting waypoints using a 

mouseclick or joystick button click, to control the flight path of the UAV (col. 1, lines 33-

36), were not well-understood, routine, or conventional at the time of the invention. 

Moreover, the ability to upload multiple waypoints enabled more complex missions to be 

performed with just a few keystrokes or mouseclicks on the remote control device (col. 1, 

lines 57-59 and col. 2, lines 2-4), which was also not well-understood, routine, or 

conventional at the time of the invention. 

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United States Patent No. 7,286,913 

21. The ‘913 patent claims UAV navigation technologies for downlink telemetry of the UAV 

to the user’s remote-control device, which then uplinks telemetry and flight control 

instructions to the UAV through a socket. Here, a socket is an end-point of a two-way 

communication link between two application programs running on a network. This 

communication link pairs the user’s remote-control device, or controller, with the drone 

or UAV to enable the user to operate the UAV. In some instances, a socket on a UAV 

would be considered a server-side socket, and a socket on a remote-control device may be 

considered a client socket. In the present complaint, Defendants’ suite of drones and 

drone-related products (infra ¶ 30) infringe on this inventive aspect of the ‘913 patent. 

Representative of this infringement is Defendants’ Mavic Series drones, including, but 

not limited to the Mavic 2 Pro. The Mavic 2 Pro houses a receiver/transmitter on-board, 

which serves as the server-side socket transmitting downlink telemetry to the UAV user’s 

remote-control device through one or more application programs, including, but not 

limited to the DJI GO 4 application or the DJI GS Pro application (depending on the 

user’s selection). Then using the selected remote-control device application, which may 

serve as the client socket, uplink telemetry and flight control instructions are transmitted 

back to the UAV. 

22. The ‘913 patent overcomes shortcomings in the prior art, which required conventional 

UAV operators to manually control the flight using the camera images from the UAV that 

were provided to the operator through downlink telemetry (col. 1, lines 18-21). Certain of 

the inventive aspects of the ‘913 patent addressed the need for improvements in the area 

of UAV navigation, by automating certain aspects of the UAV mission (col. 1, lines 25-

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28). More specifically, the inventive aspects of automatically selecting waypoints using a 

mouseclick or joystick button click, to control the flight path of the UAV (col. 1, lines 33-

35), were not well-understood, routine, or conventional at the time of the invention. 

Moreover, the ability to upload multiple waypoints enabled more complex missions to be 

performed with just a few keystrokes or mouseclicks on the remote control device (col. 1, 

lines 64-67 and col. 2, lines 1-2, 10-11), and the use of a socket to facilitate 

communications between the UAV and the remote control device (col. 2, lines 34-37), 

were also not well-understood, routine, or conventional at the time of the invention. 

COUNT I 

PATENT INFRINGEMENT OF THE ‘232 PATENT 

23. Plaintiff Daedalus Blue repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein. 

24. Plaintiff Daedalus Blue is the owner of all rights, title, and interest in the ‘232 patent. 

25. Plaintiff Daedalus Blue and predecessors in interest have never licensed any of the 

Defendants under the ‘232 patent, nor has Plaintiff Daedalus Blue otherwise authorized 

any of the Defendants to practice any part of the ‘232 patent. 

26. The ‘232 patent is presumed valid under 35 U.S.C. §282. 

27. The ‘232 patent relates to, among other things, navigation technology that enables 

obstacle avoidance by UAVs. 

28. On information and belief, Defendants manufacture and market DJI branded products. 

Exhibit D. 

29. On information and belief, Defendants distribute, sell, and market such DJI branded 

products, as well as remote controls, parts, and accessories for such DJI branded 

products. Exhibit E. 

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30. Direct Infringement: On information and belief, Defendants have directly infringed and 

continue to directly infringe, either literally or under the doctrine of equivalents, one or 

more claims of the ‘232, including for example (but not limited to) at least method claims 

1-6, system claims 7-12, and computer program product claims 13-18 of the ‘232 patent 

by making, using, selling, offering to sell, or importing without license or authority, 

Defendants’ suite of infringing drone and drone-related products, including, but not 

limited to, at least DJI products that correspond to DJI branded model lines including the 

Matrice 200 Series V2 (Matrice 200 V2, Matrice 210 V2); the Matrice 200 Series 

(Matrice 200, Matrice 210, Matrice 210RTK), Matrice 600 Pro, Matrice 600, Matrice 

100; the Inspire Series (Inspire 1, Inspire 1Pro/Raw, Inspire 2); the Mavic 2 Enterprise 

Series (Mavic 2 Enterprise, Mavic 2 Enterprise Dual); the Mavic Series (Mavic Mini, 

Mavic 2 Pro, Mavic 2 Zoom, Mavic Air, Mavic Pro Platinum); P4Multispectral; Phantom 

4 RTK; the Phantom 4 Series (Phantom 4 Pro V2.0, Phantom 4 Advanced, Phantom 4 

Pro, Phantom 4) (hereinafter “Defendants’ UAVs”); and the DJI GO application, DJI GO 

4 application, DJI GS Pro application, DJI Terra application and FlightHub application, 

together with their compatible controllers (hereinafter “Defendants’ “Flight Control 

Components”), without Plaintiff Daedalus Blue’s authorization, in violation of 35 U.S.C. 

§271(a). See Exhibit F (depicting specifications, instruction manuals, and downloads of 

products for all Defendants’ UAVs and Defendants’ Flight Control Components). A 

detailed infringement claim mapping is provided in paragraphs 42-50 below. 

31. On information and belief, Defendants have been aware of the ‘232 patent since at least 

June 19, 2014. The ‘232 patent is well known in the industry – having been cited in at 

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least 95 cited patents since its filing date, including in at least 17 of Defendants’ own 

patents: 

Patent Number Patent Title 

US9483950 Flight control for flight-restricted regions 

US10029789 Context-based flight mode selection 

US20160068267 Context-based flight mode selection 

US20160070264 Velocity control for an unmanned aerial vehicle 

WO2016033795 Velocity control for an unmanned aerial vehicle 

US9317036 Flight control for flight-restricted regions 

US9592911 Context-based flight mode selection 

US9604723 Context-based flight mode selection 

US9625907 Velocity control for an unmanned aerial vehicle 

US9625909 Velocity control for an unmanned aerial vehicle 

US9704408 Flight control for flight-restricted regions 

US9842505 Flight control for flight-restricted regions 

US10001778 Velocity control for an unmanned aerial vehicle 

US10240930 Sensor Fusion 

US20160070265 Multi-sensor environmental mapping 

US10429839 Multi-sensor environmental mapping 

US10421543 Context-based flight mode selection 

With this in mind, in accordance with 35 U.S.C. §287(a), Defendants had constructive 

and actual notice of the existence of the ‘232 patent and have been aware of the ‘232 

patent since at least June 19, 2014, when Defendants cited the ‘232 patent to the United 

States Patent and Trademark Office in an Information Disclosure Statement 

(PTO/SB/08b) as being material to the patentability of Defendants’ own patent, U.S. 

Patent No. 9,317,036 (italicized above). 

32. Induced Infringement: On information and belief, Defendants have and continue to 

promote, advertise, and instruct customers and potential customers about DJI products, 

such as Defendants’ UAVs and Defendants’ Flight Control Components (see ¶ 30), and 

how to use DJI branded products, including infringing uses. Defendants’ promotion, 

advertising, and instruction efforts include, at a minimum, maintenance of its own 

website http://www.dji.com, as well as support via third party resellers. See Exhibit G. 

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Defendants also provided mission planning and control applications for mobile 

computing devices, such as smartphones, laptops, and tablets, which allows consumers to 

use the infringing features of the products. Such applications include, but are not limited 

to Defendants’ Flight Control Components (see ¶ 30), which allow users to control the 

gimbal, camera, navigation, and other aircraft functions of the infringing UAV products. 

On information and belief, Defendants engaged in these acts with the actual intent to 

cause the acts which they knew or should have known would induce actual infringement. 

33. Contributory Infringement: On information and belief, Defendants knew or should 

have known that at least DJI branded model lines identified above in Paragraph 30 utilize 

flight planning and control programs implementing “Obstacle Avoidance Algorithms” 

that aid the user of the Defendants’ products, as the products autonomously avoid 

obstacles by GPS based avoidance of two- or three-dimensional geographic areas (e.g. no 

fly zones or restricted zones) or three-dimensional physical objects. Such obstacle 

avoidance algorithms, stored both on-board Defendants’ UAVs and within Defendants’ 

applications, such as the DJI GO 4 Application and the DJI GS Pro Application, are 

especially made or especially adapted for use in an infringement of at least claims 1-18 of 

the ‘232 patent and have no substantially non-infringing uses in these drone and dronerelated products. 

34. On information and belief, the portions of Defendants’ products that allow the user to 

pilot the Defendants’ products in accordance with a selected obstacle avoidance algorithm 

as described in Paragraph 30, including DJI branded products made, marketed, used, 

sold, offered to sell, or imported by Defendants, are not staple articles or commodities of 

commerce suitable for substantial non-infringing use. 

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35. Willful Infringement: As set forth in paragraph 31 above, in accordance with 35 U.S.C. 

§287(a), Defendants had constructive and actual notice of the existence of the ‘232 

patent, and have been aware of the ‘232 patent since at least June 19, 2014, when 

Defendants cited the ‘232 patent to the United States Patent and Trademark Office in an 

Information Disclosure Statement. 

36. On information and belief, the International Business Machines Corporation (“IBM”), a 

past predecessor in interest of the ‘232 patent, and Defendants engaged in discussions 

regarding the ‘232 patent, on or about October 16, 2017, if not earlier since the October 

16, 2017 remarks referenced prior written exchanges between IBM and DJI. Therefore, 

Defendants also had actual knowledge of the ‘232 patent at least as of October 16, 2017. 

And yet, even with full knowledge of Daedalus Blue’s patent rights (acquired through 

IBM), Defendants have continued to commit acts of infringement and have failed to 

cease their infringing activities. Because Defendants have been aware of the ‘232 patent, 

but acted despite an objectively high likelihood that their actions constituted infringement 

of a valid patent, Defendants’ infringement has been, and continues to be, egregious and 

willful. 

37. Detailed Mapping of Direct Infringement: On information and belief, with regard to 

the claim elements of the ‘232 patent, the DJI Mavic Series, Matrice Series, Phantom 

Series, Spark Series, Multispectral Series, and Inspire Series, as further laid out in 

Paragraph 30, function similarly to each other. Infringement of the ‘232 patent by these 

DJI drones and drone-related products is demonstrated below using the Mavic Series 

UAV (including the Mavic 2 Pro) as an example. Method claims 1-6 of the ‘232 patent 

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are representative of, and are of similar scope to system claims 7-12 and computer 

program product claims 13-18 of the ‘232 patent. 

38. Method claim 1 is representative of the alleged claims: 

 

1. A method for navigating a UAV, the method comprising: 

 piloting the UAV, under control of a navigation computer, in accordance with a 

navigation algorithm; 

 while piloting the UAV: 

 reading from a GPS receiver a sequence of GPS data; 

 anticipating a future position of the UAV in dependence upon the sequence of 

GPS data; 

 identifying an obstacle in dependence upon the future position; 

selecting an obstacle avoidance algorithm; and 

piloting the UAV in accordance with the selected obstacle avoidance algorithm. 

39. On information and belief, the Mavic Series UAV (“Mavic”) performs a method for 

navigating an unmanned aerial vehicle (“UAV”). 

40. On information and belief, the Mavic pilots the UAV under control of a navigation 

computer, in accordance with a navigation algorithm. 

User’s Manual, DJI GS Pro at p. 6 

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https://www.youtube.com/watch?v=nWCbdMqfrE4 

User’s Manual, DJI GS Pro at p. 5 and p. 18 

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User’s Manual, DJI GS Pro at p. 20 

41. On information and belief, the Mavic, while piloting the UAV, reads from a GPS receiver 

a sequence of GPS data. 

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User’s Manual, Mavic 2 Pro/Zoom at p. 62 

https://www.youtube.com/watch?v=nWCbdMqfrE4 

42. On information and belief, the Mavic anticipates a future position of the UAV in 

dependence upon the sequence of GPS data. 

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User’s Manual, Mavic 2 Pro/Zoom at p. 17 

43. On information and belief, the Mavic identifies an obstacle in dependence upon the future 

position. 

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User’s Manual, Mavic 2 Pro/Zoom at p. 17 

44. On information and belief, the Mavic selects an obstacle avoidance algorithm. 

User’s Manual, Mavic 2 Pro/Zoom at p. 17 

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45. On information and belief, the Mavic pilots the UAV in accordance with the selected 

obstacle avoidance algorithm. 

User’s Manual, Mavic 2 Pro/Zoom at p. 17 

46. On information and belief, Defendants’ actions have and continue to constitute active 

inducement and contributory infringement of at least claims 1-6, 7-12, and 13-18 of the 

‘232 patent in violation of 35 U.S.C. §271(b) and 271(c). 

47. As a result of Defendants’ infringement of at least claims 1-6, 7-12, and 13-18 of the ‘232 

patent, Plaintiff Daedalus Blue has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendants’ 

infringing activities are enjoined by this Court. 

48. Defendants’ wrongful acts have damaged and will continue to damage Plaintiff Daedalus 

Blue irreparably, and Plaintiff has no adequate remedy at law for those wrongs and 

injuries. In addition to its actual damages, Plaintiff Daedalus Blue is entitled to a 

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permanent injunction restraining and enjoining Defendants and their respective agents, 

servants, and employees, and all person acting thereunder, in concert with, or on its 

behalf, from infringing at least claims 1-6, 7-12, and 13-18 of the ‘232 patent. 

COUNT II 

PATENT INFRINGEMENT OF THE ‘294 PATENT 

49. Plaintiff Daedalus Blue repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein. 

50. Plaintiff Daedalus Blue is the owner of all rights, title, and interest in the ‘294 patent. 

51. Plaintiff Daedalus Blue and predecessors in interest have never licensed any of the 

Defendants under the ‘294 patent, nor has Plaintiff Daedalus Blue otherwise authorized 

any of the Defendants to practice any part of the ‘294 patent. 

52. The ‘294 patent is presumed valid under 35 U.S.C. § 282. 

53. The ‘294 patent relates to, among other things, navigation technology that enables a user 

to pilot a UAV through use of a remote-control device with a Graphical User Interface 

(GUI) map. 

54. On information and belief, Defendants manufacture and market DJI branded products. 

Exhibit D. 

55. On information and belief, Defendants distribute, sell, and market such DJI branded 

products, as well as remote controls, flight planning and control programs, parts, and 

accessories for such DJI branded products. Exhibit E. 

56. Direct Infringement: On information and belief, Defendants have directly infringed and 

continue to directly infringe, either literally and/or under the doctrine of equivalents, at 

least method claims 1-11, system claims 12-22, and computer program product claims 

23-33 of the ‘294 patent by making, using, selling, offering to sell, or importing without 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 27 of 61
28 

license or authority, Defendants’ suite of drone and drone-related products, including, but 

not limited to, at least DJI products that correspond to Defendants’ UAVs and 

Defendants’ Flight Control Components (see ¶ 30), without Plaintiff Daedalus Blue’s 

authorization, in violation of 35 U.S.C. §271(a). See Exhibit F. A detailed infringement 

claim mapping is provided in paragraphs 70-77 below. 

57. On information and belief, Defendants have been aware of the ‘294 patent since at least 

February 11, 2015. The ‘294 patent is well known in the industry – having been cited in 

at least 70 cited patents since its filing date, including in at least 16 of Defendants’ own 

patents: 

Patent Number Patent Title 

US9483950 Flight control for flight-restricted regions 

US10029789 Context-based flight mode selection 

US20150254988 Flight control for flight-restricted regions 

US20160068267 Context-based flight mode selection 

US20160070264 Velocity control for an unmanned aerial vehicle 

US9317036 Flight control for flight-restricted regions 

US9592911 Context-based flight mode selection 

US9604723 Context-based flight mode selection 

US9625907 Velocity control for an unmanned aerial vehicle 

US9625909 Velocity control for an unmanned aerial vehicle 

US9704408 Flight control for flight-restricted regions 

US9842505 Flight control for flight-restricted regions 

US10001778 Velocity control for an unmanned aerial vehicle 

US10240930 Sensor Fusion 

US10429839 Multi-sensor environmental mapping 

US10421543 Context-based flight mode selection 

With this in mind, in accordance with 35 U.S.C. §287(a), Defendants had constructive 

and actual notice of the existence of the ‘294 patent and have been aware of the ‘294 

patent since at least February 11, 2015, because on that date, the United States Patent and 

Trademark Office cited the ‘294 patent to reject the patentability of Defendants’ own 

patent, U.S. Patent No. 9,317,036 (italicized above). 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 28 of 61
29 

58. Induced Infringement: On information and belief, Defendants have and continue to 

promote, advertise, and instruct customers and potential customers about DJI products, 

such as Defendants’ UAVs and Defendants’ Flight Control Components (see ¶ 30), and 

how to use DJI branded products, including infringing uses. Defendants’ promotion, 

advertising, and instruction efforts include, at a minimum, maintenance of its own 

website http://www.dji.com, as well as support via third party resellers. See Exhibit G. 

Defendants also provided mission planning and control applications for mobile 

computing devices, such as smartphones, laptops and tablets, which allows consumers to 

use the infringing features of the products. Such applications include, but are not limited 

to, Defendants’ Flight Control Components (see ¶ 30), which allow users to control the 

gimbal, camera, navigation, and other aircraft functions of the infringing UAV products. 

On information and belief, Defendants engaged in these acts with the actual intent to 

cause the acts which they knew or should have known would induce actual infringement. 

59. Contributory Infringement: On information and belief, Defendants knew or should 

have known that at least DJI branded model lines identified above in Paragraph 30 utilize 

at least four mission planning and UAV control programs implementing “Navigation 

Algorithms” that allow the user to control the Defendants’ product by means of a remote 

control with GUI map pixels representing waypoints: (1) the DJI GO 4 application, (2) 

the DJI GS Pro application, (3) DJI Terra, or (4) DJI FlightHub. Such navigation 

algorithms are especially made or especially adapted for use in an infringement of at least 

method claims 1-11, system claims 12-22, and computer program product claims 23-33 

of the ‘294 patent and have no substantially non-infringing uses in these drone and dronerelated products. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 29 of 61
30 

60. On information and belief, the portions of Defendants’ products that allow the user to 

pilot the Defendants’ products in accordance with a navigation algorithm as described in 

Paragraph 59, including DJI branded products made, marketed, used, sold, offered to sell, 

or imported by Defendants, are not staple articles or commodities of commerce suitable 

for substantial non-infringing use. 

61. On information and belief, DJI drones and drone-related products listed above were sold 

with remote-control devices equipped with, or able to be equipped with, GUI mapping. 

Such remote-control devices could also be purchased separately from the DJI drone and 

drone-related products. Additionally, users of the DJI drone and drone-related products 

could download and install DJI brand applications and software (DJI GO 4, DJI Terra, 

DJI FlightHub, DJI GS Pro) onto mobile computing devices (smartphones, laptop, 

tablets) to effectively turn said devices into remote controls equipped with GUI mapping. 

62. On information and belief, the portions of Defendants’ products that allow the user to 

pilot the Defendants’ products in accordance with a navigation algorithm as described in 

Paragraph 61, including DJI branded products made, marketed, used, sold, offered to sell, 

or imported by Defendants, are not staple articles or commodities of commerce suitable 

for substantial non-infringing use. 

63. Willful Infringement: As set forth in paragraph 57 above, in accordance with 35 U.S.C. 

§ 287(a), Defendants had constructive and actual notice of the existence of the ‘294 

patent and have been aware of the ‘294 patent since at least February 11, 2015, when the 

United States Patent and Trademark Office cited the ‘294 patent to reject the patentability 

of Defendants’ own patent. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 30 of 61
31 

64. On information and belief, IBM, a past predecessor in interest of the ‘294 patent, and 

Defendants engaged in discussions regarding the ‘294 patent, on or about October 16, 

2017, if not earlier since the October 16, 2017 remarks referenced prior written 

exchanges between IBM and DJI. Therefore, Defendants also had actual knowledge of 

the ‘294 patent at least as of October 16, 2017. And yet, even with full knowledge of 

Daedalus Blue’s patent rights (acquired through IBM), Defendants have continued to 

commit acts of infringement and have failed to cease their infringing activities. Because 

Defendants have been aware of the ‘294 patent, but acted despite an objectively high 

likelihood that their actions constituted infringement of a valid patent, Defendants’ 

infringement has been, and continues to be, egregious and willful. 

65. Detailed Mapping of Direct Infringement: On information and belief, with regard to 

the claim elements of the ‘294 patent, the DJI Mavic Series, Matrice Series, Phantom 

Series, Spark Series, Multispectral Series, and Inspire Series, as further laid out in 

Paragraph 30, function similarly to each other. Infringement of the ‘294 patent by these 

DJI drones and drone-related products is demonstrated below using the Phantom 4 Pro 

Series UAV (including V2.0) as an example. Method claims 1-11 of the ‘294 patent are 

representative of, and of similar scope to system claims 12-22 and computer program 

product claims 23-33 of the ‘294 patent. 

66. Method claim 1 is representative of the alleged claims: 

 

1. A method for navigating an unmanned aerial vehicle (“UAV”), the method 

comprising: 

 receiving in a remote control device a user's selection of a GUI map pixel that 

 represents a waypoint for UAV navigation, the pixel having a location on the GUI; 

 mapping the pixel’s location on the GUI to Earth coordinates of the waypoint; 

 transmitting the coordinates of the waypoint to the UAV; 

 reading a starting position from a GPS receiver on the UAV; and 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 31 of 61
32 

 piloting the UAV, under control of a navigation computer on the UAV, from the 

 starting position to the waypoint in accordance with a navigation algorithm. 

67. On information and belief, the Phantom 4 Pro Series UAV (“Phantom 4”) performs a 

method for navigating an unmanned aerial vehicle (“UAV”). 

68. On information and belief, the Phantom 4 receives in a remote-control device a user’s 

selection of a GUI map pixel that represents a waypoint for UAV navigation, the pixel 

having a location on the GUI. On information and belief, the Phantom 4 can utilize both 

the DJI GO 4 application and the DJI GS Pro application. 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 36 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 2 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 32 of 61
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User’s Manual, DJI GS Pro at p. 5 and p. 18 

Phantom 4 Pro V2.0 remote-control device compatible with DJI GO 4 App, 

https://www.dji.com/phantom-4-pro-v2 

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34 

A remote-control device (iPad) compatible with Phantom 4 Pro V2.0 through the DJI GS 

Pro app, https://www.dji.com/ground-station-pro/info#downloads 

69. On information and belief, the Phantom 4 maps the pixel’s location the GUI to Earth 

coordinates of the waypoint. 

Remote-control device for use with DJI GO 4 App, https://store.dji.com/guides/dji-go-4-

manual/ 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 34 of 61
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DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

https://www.youtube.com/watch?v=qRrjvOi_dFA 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 35 of 61
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A remote-control device for use with DJI GS Pro App, https://www.dji.com/groundstation-pro/info#downloads 

User’s Manual, DJI GS Pro at p. 22-3 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 36 of 61
37 

70. On information and belief, the Phantom 4 transmits the coordinates of the waypoint to the 

UAV. 

User’s Manual, DJI GS Pro at p. 6 

https://www.youtube.com/watch?v=1nuPypFQ3nI 

71. On information and belief, the Phantom 4 reads a starting position from a GPS receiver 

on the UAV. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 37 of 61
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DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

User’s Manual, DJI GS Pro at p. 20 

72. On information and belief, the Phantom 4 is piloted under control of a navigation 

computer on-board, from the starting point to the waypoint in accordance with a 

navigation algorithm. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 38 of 61
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User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 13 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 39 of 61
40 

DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

73. On information and belief, Defendants’ actions have and continue to constitute active 

inducement and contributory infringement of at least claims 1-33 of the ‘294 patent in 

violation of 35 U.S.C. § 271(b) and 271(c). 

74. As a result of Defendants’ infringement of at least claims 1-33 of the ‘294 patent, 

Plaintiff Daedalus Blue has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendants’ 

infringing activities are enjoined by this Court. 

75. Defendants’ wrongful acts have damaged and will continue to damage Plaintiff Daedalus 

Blue irreparably, and Plaintiff has no adequate remedy at law for those wrongs and 

injuries. In addition to its actual damages, Plaintiff Daedalus Blue is entitled to a 

permanent injunction restraining and enjoining Defendants and their respective agents, 

servants, and employees, and all person acting thereunder, in concert with, or on its 

behalf, from infringing at least claims 1-33 of the ‘294 patent. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 40 of 61
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COUNT III 

PATENT INFRINGEMENT OF THE ‘913 PATENT 

76. Plaintiff Daedalus Blue repeats and realleges the above paragraphs, which are 

incorporated by reference as if fully restated herein. 

77. Plaintiff Daedalus Blue is the owner of all rights, title, and interest in the ‘913 patent. 

78. Plaintiff Daedalus Blue and predecessors in interest have never licensed any of the 

Defendants under the ‘913 patent, nor has Plaintiff Daedalus Blue otherwise authorized 

any of the Defendants to practice any part of the ‘913 patent. 

79. The ‘913 patent is presumed valid under 35 U.S.C. §282. 

80. The ‘913 patent relates to, among other things, navigation technology that enables a user 

to pilot a UAV using a socket to transmit downlink telemetry from the UAV to the user’s 

remote control device and then uplink telemetry from the remote control device back to 

the UAV. 

81. On information and belief, Defendants manufacture and market DJI branded products. 

Exhibit D. 

82. On information and belief, Defendants distribute, sell, and market such DJI branded 

products, as well as remote controls, flight planning and control applications, parts, and 

accessories for such DJI branded products. Exhibit E. 

83. Direct Infringement: On information and belief, Defendants have directly infringed and 

continue to directly infringe, either literally or under the doctrine of equivalents, one or 

more claims of the ‘913, including for example (but not limited to) at least method claims 

1-15, system claims 16-30, and computer program product claims 31-45 of the ‘913 

patent by making, using, selling, offering to sell, or importing without license or 

authority, Defendants’ suite of drone and drone-related products, including, but not 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 41 of 61
42 

limited to, at least DJI products that correspond to Defendants’ UAVs and Defendants’ 

Flight Control Components (see ¶ 30), without Plaintiff Daedalus Blue’s authorization, in 

violation of 35 U.S.C. §271(a). See Exhibit F. A detailed infringement claim mapping is 

provided in paragraphs 95-103 below. 

84. On information and belief, Defendants have been aware of the ‘913 patent since at least 

January 11, 2015. The ‘913 patent is well known in the industry – having been cited in at 

least 49 cited patents since its filing date, including in at least three of Defendants’ own 

patents: 

Patent Number Patent Title 

US9457915 Systems and methods for UAV docking 

US10059467 Systems and methods for UAV docking 

US9302783 Systems and methods for UAV docking 

With this in mind, in accordance with 35 U.S.C. §287(a), Defendants had constructive 

and actual notice of the existence of the ‘913 patent and have been aware of the ‘913 

patent since at least January 11, 2015, because on that date, the United States Patent and 

Trademark Office cited the ‘913 patent in a List of Referenced Cited by Examiner in 

connection with Defendants’ own patent, U.S. Patent No. 9,302,783 (italicized above). 

85. Induced Infringement: On information and belief, Defendants have and continue to 

promote, advertise, and instruct customers and potential customers about DJI products, 

such as Defendants’ UAVs and Defendants’ Flight Control Components (see ¶30), and 

how to use DJI branded products, including infringing uses. Defendants’ promotion, 

advertising, and instruction efforts include, at a minimum, maintenance of its own 

website http://www.dji.com, as well as support via third party resellers. See Exhibit G. 

Defendants also provided applications for mobile computing devices, such as 

smartphones, laptops, and tablets, which allows consumers to use the infringing features 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 42 of 61
43 

of the products. Such applications include, but is not limited to Defendants’ Flight 

Control Components (see ¶30), which allow users to control the gimbal, camera, 

navigation and other aircraft functions of the infringing UAV products. On information 

and belief, Defendants engaged in these acts with the actual intent to cause the acts which 

they knew or should have known would induce actual infringement. 

86. Contributory Infringement: On information and belief, Defendants knew or should 

have known that at least DJI branded model lines identified above in Paragraph 30 utilize 

at least three mission planning and UAV control applications implementing “Navigation 

Algorithms” that allow the user to control the Defendants’ product by means of a remote 

control with GUI map pixels representing waypoints: (1) the DJI GO 4, (2) the DJI GS 

Pro, (3) DJI Terra, and (4) DJI FlightHub. Such navigation algorithms are especially 

made or especially adapted for use in an infringement of at least method claims 1-15, 

system claims 16-30, and computer program product claims 31-45 of the ‘913 patent and 

have no substantially non-infringing uses in these drone and drone-related products. 

87. On information and belief, the portions of Defendants’ products that allow the user to 

pilot the Defendants’ products in accordance with a navigation algorithm as described in 

Paragraph 85, including DJI branded products made, marketed, used, sold, offered to sell, 

or imported by Defendants, are not staple articles or commodities of commerce suitable 

for substantial non-infringing use. 

88. Willful Infringement: As set forth in paragraph 84 above, in accordance with 35 U.S.C. 

§287(a), Defendants had constructive and actual notice of the existence of the ‘913 patent 

and have been aware of the ‘913 patent since at least January 11, 2015, when the United 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 43 of 61
44 

States Patent and Trademark Office cited the ‘913 patent to reject the patentability of 

Defendants’ own patent. 

89. On information and belief, IBM, a past predecessor in interest of the ‘913 patent, and 

Defendants engaged in discussions regarding the ‘913 patent, on or about October 16, 

2017, if not earlier since the October 16, 2017 remarks referenced prior written 

exchanges between IBM and DJI. Therefore, Defendants also had actual knowledge of 

the ‘913 patent at least as of October 16, 2017. And yet, even with full knowledge of 

Daedalus Blue’s patent rights (acquired through IBM), Defendants have continued to 

commit acts of infringement and have failed to cease their infringing activities. Because 

Defendants have been aware of the ‘913 patent, but acted despite an objectively high 

likelihood that their actions constituted infringement of a valid patent, Defendants’ 

infringement has been egregious, and continues to be, willful. 

90. Detailed Mapping of Direct Infringement: On information and belief, with regard to 

the claim elements of the ‘913 patent, the DJI Mavic Series, Matrice Series, Phantom 

Series, Spark Series, Multispectral Series and Inspire Series, as further laid out in 

Paragraph 30, function similarly to each other. Infringement of the ‘913 patent by these 

DJI drones and drone-related products is demonstrated below using the Phantom 4 Pro 

Series UAV (including V2.0) as an example. Method claims 1-15 of the ‘913 patent are 

representative of, and similar in scope to system claims 16-30 and computer program 

product claims 31-45 of the ‘913 patent. 

91. Method claim 1 is representative of the alleged claims: 

 

 1. A method for navigating an Unmanned Aerial Vehicle (UAV), the method 

comprising: 

 receiving in a remote control device a user’s selection of a GUI map pixel that 

 represents a waypoint for UAV navigation, the pixel having a location on the GUI; 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 44 of 61
45 

 mapping the pixel’s location on the GUI to Earth coordinates of the waypoint; 

 receiving downlink telemetry, including a starting position from a GPS receiver 

 on the UAV, from the UAV through a socket on the remote control device; 

 calculating a heading in dependence upon the starting position, the coordinates of 

 the waypoint, and a navigation algorithm; 

 identifying flight control instructions for flying the UAV on the heading; and 

 transmitting uplink telemetry, including the flight control instructions, through the 

 socket to the UAV. 

92. The Phantom 4 Pro Series UAV (“Phantom 4”) performs a method for navigating an 

unmanned aerial vehicle (“UAV”). 

93. On information and belief, the Phantom 4 receives in a remote-control device a user’s 

selection of a GUI map pixel that represents a waypoint for UAV navigation, the pixel 

having a location on the GUI. On information and belief, the Phantom 4 can utilize both 

the DJI GO 4 application and the DJI GS Pro application. 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 36 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 2 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 45 of 61
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User’s Manual, DJI GS Pro at p. 5 and p. 18 

Phantom 4 Pro V2.0 remote-control device compatible with DJI GO 4 App, 

https://www.dji.com/phantom-4-pro-v2 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 46 of 61
47 

A remote-control device (iPad) compatible with Phantom 4 Pro V2.0 through the DJI GS 

Pro app, https://www.dji.com/ground-station-pro/info#downloads 

94. On information and belief, the Phantom 4 maps the pixel’s location the GUI to Earth 

coordinates of the waypoint. 

Remote-control device for use with DJI GO 4 App, https://store.dji.com/guides/dji-go-4-

manual/ 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 47 of 61
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DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

https://www.youtube.com/watch?v=qRrjvOi_dFA 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 48 of 61
49 

A remote-control device for use with DJI GS Pro App, https://www.dji.com/groundstation-pro/info#downloads 

User’s Manual, DJI GS Pro at p. 22-3 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 49 of 61
50 

95. On information and belief, the Phantom 4 receives downlink telemetry, including a 

starting position from a GPS receiver on the UAV, from the UAV through a socket on a 

remote-control device. 

User’s Manual, DJI GS Pro at p. 23 

User’s Manual, DJI GS Pro at p. 6 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 50 of 61
51 

https://www.youtube.com/watch?v=1nuPypFQ3nI 

https://developer.dji.com/mobile-sdk/documentation/introduction/component-guideairlink.html 

96. On information and belief, the Phantom 4 calculates a heading in dependence upon the 

starting position, the coordinates of the waypoint, and a navigation algorithm. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 51 of 61
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User’s Manual, DJI GS Pro at p. 30 

DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

User’s Manual, DJI GS Pro at p. 20 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 52 of 61
53 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 13 

97. On information and belief, the Phantom 4 identifies flight control instructions for flying 

the UAV on the heading. 

User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 13 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 53 of 61
54 

DJI’s YouTube channel, https://www.youtube.com/watch?v=zvvbMxQ9Hj0 

98. On information and belief, the Phantom 4 transmits uplink telemetry, including the flight 

control instructions, through the socket to the UAV. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 54 of 61
55 

User’s Manual, DJI GS Pro at p. 23 and p. 18-9 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 55 of 61
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User’s Manual, DJI Phantom 4 Pro/Pro+ series at p. 49 

https://developer.dji.com/mobile-sdk/documentation/introduction/component-guideairlink.html 

99. On information and belief, at least Defendants’ Mobile SDK AirLink, which “describes 

the wireless link between aircraft, remote controllers, handheld cameras and mobile 

devices,” operates as an end-point of a two-way communication link between two 

application programs running on a network. In other words, Defendant’s Mobile SDK 

AirLink operates as a socket. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 56 of 61
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https://developer.dji.com/mobile-sdk/documentation/introduction/component-guideairlink.html 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 57 of 61
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https://developer.dji.com/mobile-sdk/documentation/introduction/component-guideairlink.html 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 58 of 61
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https://developer.dji.com/mobile-sdk/documentation/introduction/component-guideairlink.html 

100. On information and belief, Defendants’ actions have and continue to constitute 

active inducement and contributory infringement of at least claims 1-45 of the ‘913 

patent in violation of 35 U.S.C. §271(b) and 271(c). 

101. As a result of Defendants’ infringement of at least claims 1-45 of the ‘913 patent, 

Plaintiff Daedalus Blue has suffered monetary damages in an amount yet to be 

determined, and will continue to suffer damages in the future unless Defendants’ 

infringing activities are enjoined by this Court. 

102. Defendants’ wrongful acts have damaged and will continue to damage Plaintiff 

Daedalus Blue irreparably, and Plaintiff has no adequate remedy at law for those wrongs 

and injuries. In addition to its actual damages, Plaintiff Daedalus Blue is entitled to a 

permanent injunction restraining and enjoining Defendants and their respective agents, 

servants, and employees, and all person acting thereunder, in concert with, or on its 

behalf, from infringing at least claims 1-45 of the ‘913 patent. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff Daedalus Blue respectfully requests that this Court enter: 

A. A judgment in favor of Plaintiff Daedalus Blue that Defendants have been and are 

infringing at least claims 1-18 of the ‘232 patent, claims 1-33 of the ‘294 patent, and 

claims 1-45 of the ‘913 patent pursuant to 35 U.S.C. §§ 271(a), 271(b) and/or 271(c); 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 59 of 61
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B. A preliminary and permanent injunction enjoining Defendants and their respective 

officers, directors, agents, servants, affiliates, employees, divisions, branches, 

subsidiaries, parents, and all others acting in concert or privity with any of them from 

infringing, inducing the infringement of, or contributing to the infringement of, at least 

claims 1-18 of the ‘232 patent, claims 1-33 of the ‘294 patent, and claims 1-45 of the 

‘913 patent; 

C. A judgment awarding Plaintiff Daedalus Blue all damages adequate to compensate it for 

Defendants’ infringement of the Daedalus Blue Patents, and in no event less than a 

reasonable royalty for Defendants’ acts of infringement, including all pre-judgment and 

post-judgment interest at the maximum rate permitted by law, and including all past 

damages prior to filing this Complaint in accordance with 35 U.S.C. § 286, as a result of 

Defendants’ infringement of at least claims 1-18 of the ‘232 patent, claims 1-33 of the 

‘294 patent, and claims 1-45 of the ‘913 patent. 

D. An award of enhanced damages as a result of SZ DJI Technology Co., Ltd.’s and DJI 

Europe B.V.’s willful infringement of at least claims 1-18 of the ‘232 patent, claims 1-33 

of the ‘294 patent, and claims 1-45 of the ‘913 patent, after being apprised of these 

patents, as provided under 35 U.S.C. § 284; 

E. An assessment of costs, including reasonable attorney fees pursuant to 35 U.S.C. § 285, 

and prejudgment interest against Defendants; and 

F. Such other and further relief as this Court may deem just and proper. 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 60 of 61
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JURY TRIAL DEMANDED 

Pursuant to FED. R. CIV. P. 38, Plaintiff Daedalus Blue hereby demands a trial by jury on 

all issues so triable. 

Dated: January 31, 2020 Respectfully submitted, 

 

/s/ Thomas M. Dunlap 

Thomas M. Dunlap (Admitted W.D. 

Tex./VA Bar No. 44016) 

David Ludwig (Admitted W.D. Tex./VA 

Bar No. 73157) 

Dunlap Bennett & Ludwig PLLC 

8300 Boone Blvd., Suite 550 

Vienna, Virginia 22182 

(703) 442-3890 (t) 

(703) 777-3656 (f) 

tdunlap@dbllawyers.com 

dludwig@dbllawyers.com 

Erick Robinson 

Texas Bar No. 24039142 

Dunlap Bennett & Ludwig PLLC 

7215 Bosque Blvd. 

Waco, Texas 76710 

(254) 870-7302 (t) 

(713) 583-9737 (f) 

erobinson@dbllawyers.com 

Attorneys for Daedalus Blue LLC 

Case 6:20-cv-00073-ADA Document 1 Filed 01/31/20 Page 61 of 61