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UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

ZEROCLICK, LLC,

Plaintiff,

v.

LG ELECTRONICS, INC., AND LG 

ELECTRONICS MOBILECOMM U.S.A., 

INC.,

Defendants.

Case No.

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT AGAINST LG ELECTRONICS, INC., 

AND LG ELECTRONICS MOBILECOMM U.S.A., INC.

This is an action for patent infringement arising under the Patent Laws of the United States 

of America, 35 U.S.C. § 1 et seq., in which Plaintiff Zeroclick, LLC (“Plaintiff” or “Zeroclick”) 

makes the following allegations against Defendants LG Electronics, Inc.. and LG Electronics 

Mobilecomm U.S.A., Inc. (collectively, “Defendants”):

INTRODUCTION

1. This complaint arises from Defendant’s unlawful infringement of the following 

United States patents owned by Zeroclick: United States Patent No. 7,818,691 (“’691 Patent”) and 

United States Patent No. 8,549,443 (“443 Patent”) together the “Asserted Patents.”

2. Plaintiff is the owner and assignee of a portfolio of patents containing the inventions 

of Dr. Nes Irvine, a medical doctor who possessed the prescient vision to develop touch-only user 

interface technologies that would enable significant benefits to his medical work and any field 

where users interacted with graphical user interfaces (“GUIs”). Dr. Irvine filed applications that 

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eventually became his “Zeroclick” U.S. Patents in the year 2000.

PARTIES

3. Plaintiff Zeroclick, LLC is a Texas limited liability company, having a business 

address at 3610-2 N Josey Lane #223, Carrollton, TX 75007.

4. Defendant LG Electronics, Inc. is a corporation organized and existing under the 

laws of Korea with its principal place of business at LG Twin Towers, 128 Yeoui-daero, 

Yeongdungpo-gu, Seoul 150-721, Republic of Korea. On information and belief, this Defendant 

may be served with process at its principal place of business. Defendant LG Electronics, Inc. 

designs, makes, and sells many different products throughout the world for consumer use, 

including wireless mobile communications devices. Defendant LG Electronics, Inc. is a parent 

corporation of Defendant LG Electronics Mobilecomm U.S.A., Inc. 

5. Defendant LG Electronics Mobilecomm U.S.A., Inc. is a wholly-owned subsidiary 

of Defendant LG Electronics, Inc. and is a Delaware corporation with regular and established 

places of business in Texas at 9420 Research Blvd, Austin, Texas 78759; 21251-2155 Eagle 

Parkway, Fort Worth, Texas 76177; and 14901 Beach St, Fort Worth, TX 76177. Defendant LG 

Electronics Mobilecomm U.S.A., Inc. is registered to do business in the State of Texas and has 

been since at least April 3, 1984. Defendant LG Electronics Mobilecomm U.S.A., Inc. may be 

served with process at its registered agent for service of process at United States Corporation 

Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701. Defendant LG Electronics U.S.A., 

Inc. distributes wireless mobile communication devices to customers throughout the United States. 

On information and belief, Defendant LG Electronics Mobilecomm U.S.A., Inc. imports such 

wireless communication devices from its parent corporation Defendant LG Electronics, Inc. in 

South Korea, where they are designed and made

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JURISDICTION AND VENUE

6. This action arises under the patent laws of the United States, Title 35 of the United 

States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 

1338(a).

7. This Court has personal jurisdiction over Defendants in this action because 

Defendants have committed acts within this District giving rise to this action, and has established 

minimum contacts with this forum such that the exercise of jurisdiction over Defendants would 

not offend traditional notions of fair play and substantial justice. Defendants, directly and through 

subsidiaries or intermediaries, have committed and continues to commit acts of infringement in 

this District by, among other things, importing, offering to sell, and selling products that infringe 

the asserted patents.

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

are registered to do business in Texas, and upon information and belief, Defendants have 

transacted business in this District and have committed acts of direct and indirect infringement in

this District by, among other things, making, using, offering to sell, selling, and importing products 

that infringe the asserted patents. Defendants have regular and established places of businesses in 

this District, including at 9420 Research Blvd, Austin, Texas 78759.

COUNT I

INFRINGEMENT OF U.S. PATENT NO. 7,818,691

9. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

10. Plaintiff is the owner and assignee of United States Patent No. 7,818,691 (“the ‘691 

patent”) titled “Zeroclick.” The ‘691 patent was duly and legally issued by the United States Patent 

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and Trademark Office on October 19, 2010. Plaintiff is the owner and assignee, possessing all 

substantial rights, to the ‘691 patent. A true and correct copy of the ’691 Patent is attached as 

Exhibit 1.

11. On information and belief, Defendants make, use, offer for sale, sell, and/or import 

certain touch screen cellular telephone and tablet products that utilize Google’s Android software

(“Accused Products”), such as the LG V30, that directly infringe, literally and/or under the doctrine 

of equivalents, one or more claims of the ’691 Patent. 

12. Defendants also knowingly and intentionally induce infringement of one or more 

claims of the ’691 Patent in violation of 35 U.S.C. § 271(b). Through the filing and service of this 

Complaint, Defendants have had knowledge of the ’691 Patent and the infringing nature of the 

Accused Products. Despite this knowledge of the ’691 Patent, Defendants continue to actively 

encourage and instruct its customers and end users (for example, through its user manuals and 

online instruction materials on its website) to use the Accused Products in ways that directly 

infringe the ‘691 Patent. Defendants do so knowing and intending that their customers and end 

users will commit these infringing acts. Defendants also continue to make, use, offer for sale, sell, 

and/or import the Accused Products, despite their knowledge of the ’691 Patent, thereby 

specifically intending for and inducing their customers to infringe the ’691 Patent through the 

customers’ normal and customary use of the Accused Products.

13. The Accused Products satisfy all claim limitations of one or more claims of the 

’691 Patent. A claim chart comparing independent claim 2 of the ’691 Patent to representative 

Accused Product, the LG V30 is attached as Exhibit 2.

14. By making, using, offering for sale, selling and/or importing into the United States 

the Accused Products, Defendants have injured Plaintiff and is liable for infringement of the ’691

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Patent pursuant to 35 U.S.C. § 271.

15. As a result of Defendants’ infringement of the ’691 Patent, Plaintiff is entitled to 

monetary damages in an amount adequate to compensate for Defendants’ infringement, but in no 

event less than a reasonable royalty for the use made of the invention by Defendants, together with 

interest and costs as fixed by the Court.

16. Defendants’ infringing activities have injured and will continue to injure Plaintiff, 

unless and until this Court enters an injunction prohibiting further infringement of the ’691 Patent, 

and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that 

come within the scope of the patent claims.

COUNT II

INFRINGEMENT OF U.S. PATENT NO. 8,549,443

17. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

18. Plaintiff is the owner and assignee of United States Patent No. 8,549,443 titled 

“Zeroclick.” The ‘443 patent was duly and legally issued by the United States Patent and 

Trademark Office on October 1, 2013. Plaintiff is the owner and assignee, possessing all 

substantial rights, to the ‘’443 patent. A true and correct copy of the ‘443 Patent is attached as 

Exhibit 3.

19. On information and belief, Defendants make, use, offer for sale, sell, and/or import 

certain touch screen cellular telephone and tablet products that utilize Google’s Android software 

(“Accused Products”), such as the LG V30, that directly infringe, literally and/or under the doctrine 

of equivalents, one or more claims of the ’443 Patent.

20. Defendants also knowingly and intentionally induce infringement of one or more 

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claims of the ’443 Patent in violation of 35 U.S.C. § 271(b). Through the filing and service of this 

Complaint, Defendants have had knowledge of the ’443 Patent and the infringing nature of the 

Accused Products. Despite this knowledge of the ’443 Patent, Defendants continue to actively 

encourage and instruct its customers and end users (for example, through its user manuals and 

online instruction materials on its website) to use the Accused Products in ways that directly 

infringe the ‘443 Patent. Defendants do so knowing and intending that their customers and end 

users will commit these infringing acts. Defendants also continue to make, use, offer for sale, sell, 

and/or import the Accused Products, despite their knowledge of the ’443 Patent, thereby 

specifically intending for and inducing their customers to infringe the ’443 Patent through the 

customers’ normal and customary use of the Accused Products.

21. The Accused Products satisfy all claim limitations of one or more claims of the 

’443 Patent. A claim charts comparing independent claim 19 of the ’443 Patent to representative 

Accused Product, the LG V30, is attached as Exhibit 4.

22. By making, using, offering for sale, selling and/or importing into the United States 

the Accused Products, Defendants have injured Plaintiff and is liable for infringement of the ’443 

Patent pursuant to 35 U.S.C. § 271.

23. As a result of Defendants’ infringement of the ’443 Patent, Plaintiff is entitled to 

monetary damages in an amount adequate to compensate for Defendants’ infringement, but in no 

event less than a reasonable royalty for the use made of the invention by Defendants, together with 

interest and costs as fixed by the Court.

24. Defendants’ infringing activities have injured and will continue to injure Plaintiff, 

unless and until this Court enters an injunction prohibiting further infringement of the ’443 Patent, 

and, specifically, enjoining further manufacture, use, sale, importation, and/or offers for sale that 

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come within the scope of the patent claims

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter:

a. A judgment in favor of Plaintiff that Defendants have infringed, either literally 

and/or under the doctrine of equivalents, the ‘691 Patent and ‘443 Patent;

b. A permanent injunction prohibiting Defendants from further acts of infringement 

of the ’691 Patent and ‘443 Patent;

c. A judgment and order requiring Defendants, jointly and severally, to pay Plaintiff 

its damages, costs, expenses, and pre-judgment and post-judgment interest for Defendant’s

infringement of the ’691 Patent and ‘443 Patent; and

d. A judgment and order requiring Defendants to provide an accounting and to pay 

supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment 

interest; 

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

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

f. Any and all other relief as the Court may deem appropriate and just under the 

circumstances.

DEMAND FOR JURY TRIAL

Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of 

any issues so triable by right.

Dated: May 26, 2020 Respectfully submitted,

/s/ Brian D. Ledahl

Marc A. Fenster, CA SBN 181067

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mfenster@raklaw.com

Brian D. Ledahl, CA SBN 186579

bledahl@raklaw.com

RUSS AUGUST & KABAT

12424 Wilshire Blvd. 12th Floor

Los Angeles, CA 90025

Phone: (310) 826-7474

Attorneys for Plaintiff Zeroclick, LLC

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