UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

KAMINO LLC, 

 Plaintiff 

 v. 

DYNABOOK, INC. AND INNOLUX 

CORP. 

 Defendants 

Case No. 6:20-cv-00519 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Kamino LLC (“Plaintiff” or “Kamino”) hereby asserts the following 

claims for patent infringement against Defendants Dynabook, Inc. and Innolux Corp. 

(collectively “Defendants”), and alleges, on information and belief, as follows: 

THE PARTIES 

1. Kamino is a limited liability company organized and existing under the laws of 

the Texas with its principal place of business at 17330 Preston Road, Suite 200D, Dallas, 

Texas 75252. 

2. On information and belief, Defendant Dynabook, Inc. is a corporation organized 

and existing under the laws of Japan, with its principal place of business at NBF Toyosu 

Garden Front Bldg., Toyosu 5-6-15, Koto-ku, Tokyo, Japan. 

3. On information and belief, Defendant Innolux is a Chinese company having a 

principal place of business at No.160, Kesyue Rd., Jhunan Science Park, Miaoli County 

35053, Taiwan. 

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JURISDICTION AND VENUE 

4. This action arises under the patent laws of the United States, 35 U.S.C. § 1, et seq. 

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

5. Defendants have committed acts of infringement in this judicial district. 

6. On information and belief, the Court has personal jurisdiction over Defendants 

because Defendants have committed, and continue to commit, acts of infringement in the 

state of Texas, have conducted business in the state of Texas, and/or have engaged in 

continuous and systematic activities in the state of Texas. 

7. On information and belief, Defendants’ instrumentalities that are alleged herein 

to infringe were and continue to be used, imported, offered for sale, and/or sold in the 

Western District of Texas. 

8. Venue is proper as to Defendants in this District under 28 U.S.C. § 1391(c) 

because, inter alia, Defendants are a foreign corporation. 

THE PATENT-IN_SUIT 

9. On August 20, 2002, United States Patent No. 6,435,686 (the “’686 patent”), 

entitled "Light Conducting Plate for a Back Lighting Device and Back Lighting Device," 

was duly and lawfully issued by the U.S. Patent and Trademark Office. A true and correct 

copy of the ’686 patent is attached hereto as Exhibit A. 

10. Kamino is the assignee and owner of the right, title and interest in and to the ’686 

patent, including the right to assert all causes of action arising under said patents and 

the right to any remedies for infringement of them. 

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COUNT I – INFRINGEMENT OF U.S. PATENT NO. 6,435,686 

11. Kamino repeats and realleges the allegations of paragraphs 1 through 10 as if 

fully set forth herein. 

12. Claim 1 of the ’686 Patent recites: 

1. A light conducting plate for a back lighting device, comprising: 

a light-inlet end face for introducing light emitted from a light source to be 

disposed facing said light conducting plate; 

a reflecting face for reflecting the light introduced through said light-inlet 

end face; and 

a light-outlet face disposed opposite to said reflecting face for allowing the 

light reflected from the reflecting face to emit therethrough, 

wherein said reflecting face includes a light-scattering region and a 

remainder region, and the remainder region is located on a side near to said 

light-inlet end face. 

13. Without license or authorization and in violation of 35 U.S.C. § 271(a), Defendant 

has infringed and continues to infringe the ’686 patent by making, using, importing, 

offering for sale, and/or selling products, such as the Tecra C40 D1414 products (the 

“Accused Products”). 

14. As exemplified below, the Accused Products includes a light conducting plate as 

claimed by the ’686 Patent. 

1. A light conducting plate for a back lighting device, comprising: 

The Accused Instrumentality includes a light conducting plate for a back lighting 

device. 

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https://www.amazon.com/dp/B082QXTQX6/ref=pe_2640190_232748420_TE_item

The light conducting plate of the Accused Instrumentality is part of display apparatus. 

The light conducting plate includes a light-inlet end face, a reflecting face, and a light 

outlet face. The reflecting face includes a light-scattering region and a remainder region. 

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a light-inlet end face for introducing light emitted from a light source to be 

disposed facing said light conducting plate; 

The Accused Instrumentality includes a light-inlet end face for introducing light emitted 

from a light source. 

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a reflecting face for reflecting the light introduced through said light-inlet 

end face; and 

The Accused Instrumentality includes a reflecting face for reflecting the light introduced 

through the light-inlet end face. 

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a light-outlet face disposed opposite to said reflecting face for allowing the 

light reflected from the reflecting face to emit therethrough, 

The Accused Instrumentality includes a light-outlet face disposed opposite to the 

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reflecting face for allowing the light reflected from the reflecting face to emit 

therethrough. 

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wherein said reflecting face includes a light-scattering region and a 

remainder region, and the remainder region is located on a side near to said 

light-inlet end face. 

15. The reflecting face includes a light-scattering region and a remainder region. The 

remainder region is located on a side near to the light-inlet face Kamino is entitled to 

recover from Defendants the damages sustained by Kamino as a result of Defendants’ 

infringement of the ’686 patent in an amount subject to proof at trial, which, by law, 

cannot be less than a reasonable royalty, together with interest and costs as fixed by this 

Court under 35 U.S.C. § 284. 

PRAYER FOR RELIEF 

WHEREFORE, Kamino requests that this Court enter judgment against 

Defendants as follows: 

A. An adjudication that Defendants have infringed the ’686 patent; 

B. An award of damages to be paid by Defendants adequate to compensate 

Kamino for Defendants’ past infringement of the ’686 patent and any continuing or future 

infringement through the date such judgment is entered, including interest, costs, 

expenses and an accounting of all infringing acts including, but not limited to, those acts 

not presented at trial; 

C. A declaration that this case is exceptional under 35 U.S.C. § 285, and an 

award of Kamino's reasonable attorneys' fees; and 

D. An award to Kamino of such further relief at law or in equity as the Court 

deems just and proper. 

JURY DEMAND 

Plaintiff demands trial by jury, Under Fed. R. Civ. P. 38. 

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Dated: June 11, 2020 Respectfully Submitted 

/s/ Raymond W. Mort, III 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

THE MORT LAW FIRM, PLLC 

100 Congress Ave, Suite 2200 

Austin, Texas 78701 

Tel/Fax: (512) 865-7950 

ATTORNEYS FOR PLAINTIFF 

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