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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

ANADEX DATA COMMUNICATIONS 

LLC, 

Plaintiff, 

v. 

LOREX TECHNOLOGY, INC. 

Defendant.

Civil Action No. 6:20-cv-00246

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Anadex Data Communications LLC (“ADC” or “Plaintiff”), for its Complaint 

against Defendant LOREX Technology, Inc. (“LOREX” or “Defendant”), alleges the following: 

NATURE OF THE ACTION 

1. This is an action for patent infringement arising under the Patent Laws of the 

United States, 35 U.S.C. § 1 et seq. 

THE PARTIES 

2. Plaintiff is a limited liability company organized under the laws of the State of 

Texas with a place of business at 3107 Boardwalk, Atlantic City, NJ 08401. 

3. Upon information and belief, LOREX is a corporation organized and existing 

under the laws of Canada, with a place of business at 250 Royal Crest Ct., Markham, Ontario, 

Canada L3R 3S1. Upon information and belief, LOREX sells and offers to sells and offers to 

sell products and services throughout the United States, including in this judicial district, and 

introduces products and services into the stream of commerce that incorporate infringing 

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technology knowing that they would be sold in this judicial district and elsewhere in the United 

States. 

4. Plaintiff is the assignee and owner of the patent at issue in this action: US Patent 

No. 7,310,120 (“Asserted Patent” or “’120 Patent”). Plaintiff holds all substantial rights and 

interest in the Asserted Patent, as described below, including the exclusive right to sue Defendant 

for infringement and recover damages. 

5. Plaintiff seeks monetary damages and prejudgment interest for Defendant’s past 

and ongoing direct and indirect infringement of the Asserted Patent. 

JURISDICTION AND VENUE 

6. This is an action for patent infringement arising under the Patent Laws of the 

United States, Title 35 of the United States Code. 

7. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 

8. This Court has personal jurisdiction over Defendant LOREX because (i) 

Defendant has conducted and regularly conducts business in this District, directly or through its 

subsidiaries and intermediaries; (ii) at least a portion of the alleged infringement occurred in this 

District; and (iii) Defendant regularly solicits business, engages in other persistent courses of 

conduct, or derives revenue from products and services provided to consumers and businesses in 

this District. 

9. Furthermore, LOREX has purposefully availed itself of the privileges of 

conducting business in the United States, and more specifically in the State of Texas and this 

District. LOREX has sought protection and benefit from the laws of the State of Texas by 

placing infringing products and services into the stream of commerce through an established 

distribution channel with the awareness and/or intent that they will be purchased by consumers in 

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this District. Having purposefully availed itself of the privilege of conducting business within 

this District, LOREX should reasonably and fairly anticipate being brought into court here. 

10. Venue is proper in this judicial district under 28 U.S.C. § 1391(b)-(c). In 

particular, venue is proper as to a foreign defendant in any district. See 28 U.S.C. § 1391(c)(3). 

On information and belief, LOREX is a Canadian corporation. As a foreign defendant, LOREX 

may be sued in any judicial district it is subject to personal jurisdiction, including this District. 

See In re HTC Corp., 889 F.3d 1349, 1361 (Fed. Cir. 2018). 

11. Additionally, LOREX—directly or through intermediaries (including distributors, 

retailers, and others), subsidiaries, alter egos, and/or agents—ships, distributes, offers for sale, 

and/or sells its products and services in the United States and this District. LOREX has 

purposefully and voluntarily placed one or more of its infringing products and services into the 

stream of commerce with the awareness and/or intent that they will be purchased by consumers 

in this District. LOREX knowingly and purposefully ships products into, and within, this 

District through an established distribution channel that infringe the Asserted Patent. These 

products have been, and continue to be, purchased by consumers and businesses in this District. 

BACKGROUND OF THE INVENTION(S) 

12. Mr. Marcin Zalewski is the sole inventor of the ’120 Patent. 

13. The ’120 Patent resulted from the pioneering efforts of Mr. Zalewski (hereinafter 

“the Inventor”) in the area of analog video conversion receivers. These efforts resulted in 

development of a receiver which could receive and convert an analogue video signal and control 

the display of the video frames at the time of the invention in 2004. At the time of these 

pioneering efforts, the most widely implemented technologies used to address controlling display 

of video signal frames were systems comprising a single frame buffer or systems comprising two 

frame buffers. In single frame buffer systems, output could be affected by interferences unless 

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input and output timers were synchronized. This was problematic due to difficulties related to 

switching among input signals with different synchronization frequencies/phases. Systems with 

two frame buffers also suffered from similar performance-related drawbacks, as they required 

copying of large amounts of data, including data that must be fetched into the first buffer and 

copied to the second buffer in order to perform double buffering. The Inventor conceived of the 

inventions claimed in the ’120 Patent as a way to eliminate these drawbacks and allow a 

conversion of video frames in such a way that the output frequency could be either lower or 

higher than the input frequency. (See Ex. 1 at 1:16-66.) 

THE ASSERTED PATENT 

14. On December 18, 2007, the ’120 Patent, entitled “Receiver of Analogue Video 

Signal Having Means for Analogue Video Signal Conversion and Method for Control of Display 

of Video Frames” was duly and legally issued by the United States Patent and Trademark Office. 

A true and correct copy of the ’120 Patent is attached as Exhibit 1. 

15. Plaintiff owns all substantial right, title, and interest in the ’120 Patent, and holds 

the right to sue and recover damages for infringement thereof, including past infringement. 

 COUNT I – INFRINGEMENT OF U.S. PATENT NO. 7,210,120 

16. Plaintiff incorporates and realleges the preceding paragraphs as if fully set forth 

herein. 

17. Upon information and belief, Defendant has infringed and continues to directly 

infringe each and every element of at least claim 1 of the ’120 Patent pursuant to 35 U.S.C. § 

271(a), literally or under the doctrine of equivalents, by making, using, selling, offering to sell, 

and/or importing in the United States without authority video surveillance systems, and similar 

products, devices, systems, and/or components of systems that perform analog video signal 

conversion between two different formats (“Infringing Products”). The Infringing Products 

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include, without limitation and by way of example, MPX1612D2ZW, LW16122MW, 

4KMPX1616, LW16106W, LW1662MDW, 4KA166, LW1684W, 2KA166BD, 2KMPX1616, 

MPX1616W, LW1684UW, LX1080-166W, LW84W, MPX168AW, LW1642W, 4KAD168, 

4KMPX88, MPX851DZW, MPX1616DW, LX1081-166, MPX166DW, MPX1684DW, 

LX1080-166BW, 4KAD88, DF162-C2NAE-W, 4KA88, DF162-A2NAE-W, 

LHV51082T8KXW, MPX168W, LX1081-168, MPX84AW, LHV514K86, LW422W, 4KAD84, 

MPX2K88, 2KA88, 2KA88BD, MPX88W, 2KMPX88, LX1080-88W, LHV51082T6KXW, 

DP181-82NAE-W, MPX84MW, 4KMPX44, LX1081-88BD, MPX84W, MPX88DW, 

LHV514K84, MPX44W, MPX44MDW, MPX84DW, MPX86W, 4KA84, LX1081-88, 

4KMPX82, 2KMPX422D, MPX82W, 2KA84, 2KMPX44, LX1080-44W, LX1080-44BW, 

LX1081-44, and LX1081-44BD. See HD DVR Camera Systems, available at 

https://www.lorextechnology.com/site/hd-dvr-camera-system/N180xlif?Nrpp=999&Ns=sku.activePrice%7C1 (last visited on Mar. 18, 2020).

18. Discovery is expected to uncover the full extent of Defendant’s infringement of 

the ’120 Patent beyond the Infringing Products already identified through public information. 

19. A claim chart detailing how an Infringing Product, LOREX’s security camera 

DVR system, infringes claim 1 of the ’120 Patent is attached hereto as Exhibit 2 and 

incorporated herein by reference. 

20. The Infringing Products have infringed and continue to infringe at least claim 1 of 

the ’120 Patent. 

21. On information and belief, these Infringing Products are used, marketed, provided 

to, and/or used by or for each of Defendant’s partners, clients, customers and end users across 

the country and in this District. 

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22. Defendant was made aware of the ’120 Patent and its infringement thereof at least 

as early as the filing of this Complaint. 

23. Plaintiff has suffered, and continues to suffer, damages as a result of Defendant’s 

infringement of the ’120 Patent. 

24. Defendant has infringed and continues to infringe the ’120 Patent since at least 

the filing of this Complaint, despite being on notice of the ’120 Patent and its infringement. 

Defendant has therefore infringed the ’120 Patent knowingly, willfully, deliberately, and in 

disregard of Plaintiff’s patent rights by infringing with actual knowledge of its direct 

infringement or while remaining willfully blind to the fact of its direct infringement. As a result 

of at least this conduct, Plaintiff is entitled to enhanced damages under 35 U.S.C. § 284 and to 

attorneys’ fees and costs under 35 U.S.C. § 285. 

25. Plaintiff reserves the right to modify its infringement theories as discovery 

progresses in this case. Plaintiff shall not be estopped for purposes of its infringement 

contentions or its claim constructions by the claim charts that it provides with this Complaint. 

Plaintiff intends the claim chart (Ex. 2) for the ’120 Patent to satisfy the notice requirements of 

Rule 8(a)(2) of the Federal Rule of Civil Procedure. The claim chart is not Plaintiff’s 

preliminary or final infringement contentions or preliminary or final claim construction 

positions. 

JURY DEMAND 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands a trial by 

jury on all issues triable as such. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff demands judgment for itself and against Defendant as follows: 

A. A judgment that Defendant has directly infringed the ’120 Patent; 

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B. A judgment that Defendant has willfully infringed one or more claims of the ’120 

Patent; 

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

Defendant’s infringement, and in no event less than a reasonable royalty for 

Defendant’s acts of infringement, including all pre-judgment and post-judgment 

interest at the maximum rate allowed by law; 

D. A judgment awarding Plaintiff treble damages pursuant to 35 U.S.C. § 284 as a 

result of Defendant’s willful conduct; 

E. A judgment and order finding that this case is an exceptional case within the 

meaning of 35 U.S.C. § 285 and awarding Plaintiff its reasonable attorneys’ fees; 

and 

F. An award to Plaintiff of such further relief at law or in equity as the Court deems 

just and proper. 

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Dated: March 27, 2020 DEVLIN LAW FIRM LLC 

/s/ Alex Chan

Alex Chan 

achan@devlinlawfirm.com 

Timothy Devlin (pro hac vice to be filed) 

tdevlin@devlinlawfirm.com 

1526 Gilpin Ave. 

Wilmington, Delaware 19806 

Telephone: (302) 449-9010 

Facsimile: (302) 353-4251 

Attorneys for Plaintiff 

ANADEX DATA COMMUNICATIONS LLC 

 

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