IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

GUEST TEK INTERACTIVE 

ENTERTAINMENT LTD., 

 Plaintiff, 

 v. 

EXCEPTIONAL INNOVATION, INC., 

 Defendant. 

CASE NO. 2:17-CV-00963-ALM-CMV 

JUDGE ALGENON L. MARBLEY 

MAGISTRATE JUDGE CHELSEY M. 

VASCURA 

JURY TRIAL DEMANDED 

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff, Guest Tek Interactive Entertainment Ltd. (“Guest Tek” or “Plaintiff”), for its 

First Amended Complaint against Defendant Exceptional Innovation, Inc. (“Defendant”), alleges 

as follows: 

Nature of the Action 

1. This is an action for infringement of United States Patent Nos. 9,137,281 (“the 281 

Patent”) and 9,781,172 (“the 172 Patent”) (collectively, “the Patents-in-Suit”) under the 

patent laws of the United States, 35 U.S.C. §§ 1 et seq. 

The Parties 

2. Guest Tek is a corporation organized and existing under the laws of the province of 

Alberta, Canada with a place of business at Suite 600, 777 8 Ave., SW, Calgary, Alberta, 

T2P 3R5, Canada. 

3. Upon information and belief, Defendant is a corporation organized and existing under the 

laws of the State of Ohio, with its principal place of business at 480 Olde Worthington 

Road, Suite 350, Westerville, Ohio, 43082. 

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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 over the action under 28 U.S.C. §§ 1331 and 

1338(a). 

5. This Court has jurisdiction over Defendant as it is incorporated under the laws of the 

State of Ohio. 

6. Venue is proper in this judicial district under 28 U.S.C. §1400(b). 

Background 

7. On September 15, 2015, the 281 Patent, titled “Dynamically Enabling Guest Device 

Supporting Network-Based Media Sharing Protocol To Share Media Content Over Local 

Area Computer Network Of Lodging Establishment With Subset Of In-Room Media 

Devices Connected Thereto,” was duly and legally issued by the United States Patent and 

Trademark Office (“USPTO”) to inventors Peter S. Warrick, Brendan G. Cassidy, 

Lindsey M. Carriere and Michael D. McCarthy. A true and correct copy of the 281 

Patent is attached to this Complaint as Exhibit A. 

8. On October 3, 2017, the 172 Patent, titled “Media Proxy That Transparently Proxies 

Network-Based Media Sharing Protocol Between Guest Device And An Associated One 

Of A Plurality Of Media Devices,” was duly and legally issued by the USPTO to 

inventors Peter S. Warrick, Brendan G. Cassidy, Lindsey M. Carriere and Michael D. 

McCarthy. A true and correct copy of the 172 Patent is attached to this Complaint as 

Exhibit B. 

9. Guest Tek is the owner, by assignment registered in the USPTO, of the entire right, title, 

and interest in the Patents-in-Suit. 

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10. Guest Tek is a global leader in broadband technology and interactive solutions for the 

hospitality industry. Among Guest Tek’s products are its OneView Internet and 

OneView Media solutions that allow hotels to offer internet and media services to their 

guests (“OneView Products”). 

11. The OneView Products are covered by at least one claim of each of the Patents-in-Suit. 

Guest Tek has complied with the marking requirements of 35 U.S.C. § 287. 

12. Guest Tek has incurred significant costs in connection with the research, development, 

and marketing done in connection with OneView Products. Guest Tek’s OneView 

Products have achieved substantial commercial success and won praise from the industry. 

13. Upon information and belief, Defendant currently makes, uses, sells and/or offers to sell 

in, and/or imports into, the United States, and/or has made, used, sold and/or offered to 

sell in, and/or imported into, the United States, either directly and/or through or in 

cooperation with others, products and/or solutions known as the Exceptional Innovation 

iQx Platform (“iQx Platform”) including the Model STB-4000 Set-Top Box (“STB4000”). In at least some instances, the STB-4000 is made, used, sold, offered for sale 

and/or imported by, on or on behalf of, Defendant with a Chromecast device installed 

therein. For clarity, the term “STB-4000,” when used alone, refers to a STB-4000 

without a Chromecast device installed therein, and the term “STB-4000 with 

Chromecast” refers to a STB-4000 with a Chromecast device installed therein. 

14. Upon information and belief, Defendant instructs and/or has instructed others to install a 

Chromecast device inside of a STB-4000 that does not already have a Chromecast device 

installed therein, and provides and/or has provided instructions on how to do so, and such 

others have followed the instructions and installed a Chromecast device, and/or during 

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the term of the Patents-in-Suit, will follow the instructions to install a Chromecast device, 

inside of a STB-4000 that did not previously have a Chromecast device installed therein. 

15. Upon information and belief, Defendant currently makes, uses, sells and/or offers to sell 

in, and/or imports into, the United States, and/or has made, used, sold and/or offered to 

sell in, and/or imported into, the United States, and/or, during the term of the Patents-inSuit, will sell, either directly and/or through or in cooperation with others, products 

and/or solutions known as iQ cast entertainment solution (“iQ cast”). 

16. Upon information and belief, Defendant has prepared instructions to, instructs, has 

instructed, and/or, during the term of the Patents-in-Suit, will instruct, others to install, in 

a hotel already having a local area network (“LAN”), such equipment as is necessary to 

provide iQ cast within a hotel that did not previously have iQ cast, including instructions 

to install a computer, called an “iQ cast server,” on the hotel’s existing high speed 

internet access (“HSIA”) network, and to install Chromecast devices in a HDMI port of 

TV’s within guest rooms of the hotel, and such hotels have followed the instructions to 

install such equipment, and/or during the term of the Patents-in-Suit, will follow the 

instructions to install such equipment. 

17. Upon information and belief, Defendant imports into, and/or offers for sale and/or sells 

in, the Unites States, has imported into, and/or offered for sale and/or sold in, and/or 

during the term of the Patents-in-Suit, will import into, and/or sell in, the United States, 

the iQ cast server. 

18. Upon information and belief, the iQ cast server is a material part of iQ cast, and is 

especially adapted to provide iQ cast to an establishment such as a hotel. 

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19. Upon information and belief, the iQ cast server is not a staple article or commodity of 

commerce suitable for substantial use other than in iQ cast. 

20. Defendant has had actual knowledge of the Patents-in-Suit, and of Guest-Tek’s 

allegations that Defendant infringes the Patents-in-Suit, since at least October 31, 2017. 

21. The iQx Platform, including a STB-4000 with Chromecast, are together referred to as an 

“Infringing Product,” and iQ cast and the iQcast server are also each referred to as an 

“Infringing Product,” and all are collectively referred to as “Infringing Products.” 

The Infringing Products 

22. Guest Tek and Defendant are direct competitors in the market for interactive solutions for 

the hospitality industry. Guest Tek’s OneView Products compete against Defendant’s 

STB-4000 and the Infringing Products. 

23. Upon information and belief, Defendant sells and/or offers for sale the STB-4000 and the 

Infringing Products to hotels directly, and/or through a family of related companies 

including interTouch and Quadriga (“Sister Companies”) as demonstrated by the 

Defendant and the Sister Companies’ websites:1

 

1 www.exceptionalinnovation.com; www.intertouch.com; www.quadriga.com (last visited October 1, 2018). 

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24. The iQx Platform comprises the STB-4000. The STB-4000 is illustrated and described in 

the STB-4000 User Manual, attached hereto as Exhibit C (the “STB-4000 User 

Manual”): 

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25. As described in the STB-4000 User Manual, a STB-4000 with Chromecast connects to a 

hotel network and provides a virtual LAN by which a hotel guest can stream audio and 

video from a personal device to an in-room TV connected to the STB-4000: 

26. As described in the STB-4000 User Manual, a STB-4000 with Chromecast provides a 

proxy to an internal Chromecast media device: 

27. As described on the interTouch website, which shares a common home page with the 

Defendant, interTouch also offers the iQx platform and notes that it is powered by the 

Defendant:2

 

2 http://www.intertouch.com/solutions/iqx-platform/ (last visited October 1, 2018). 

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28. As described on the Quadriga website, which shares a common home page with the 

Defendant, Quadriga also offers the iQx platform and notes that it is powered by the 

Defendant:3

 

3 http://www.intertouch.com/solutions/iqx-platform/ (last visited October 1, 2018). 

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29. As described by a press release issued by Defendant, iQ cast allows a hotel to use its 

HSIA network, such as a wireless LAN, to provide audio and video streaming capability 

to a TV in a hotel guest room without requiring the hotel to purchase a set-top box, such 

as the STB-4000.4

 

30. As described on the interTouch website, which shares a common home page with the 

Defendant, interTouch also offers iQ cast, and the copyright notice at the bottom thereof, 

and the contact information under the “About” link thereon, refers to the Defendant.5

31. As described on the Quadriga website, which shares a common home page with the 

Defendant, Quadriga also offers Q cast, and the copyright notice at the bottom thereof, 

and the contact information under the “About” link thereon, refers to the Defendant.6

32. InterTouch and Quadriga share the same executive team as evidenced by the company 

websites.7

33. Seale Moorer, the Chief Executive Officer for all three companies, indicates on his 

biography that he cofounded “Exceptional Innovation and in 2013, he added The 

SmarTV Company, LLC to the Defendant portfolio followed by additional acquisitions 

of Quadriga and interTouch in 2015.”8

Count I: Direct Infringement of the 281 Patent by the iQx Platform/STB-4000 with 

Chromecast, and by iQ cast 

34. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

 

4 http://www.exceptionalinnovation.com/2018/04/09/iq-cast-debut/ (last visited October 1, 2018) 5 http://www.intertouch.com/solutions/iq-cast/ (last visited October 1, 2018) 

6 http://www.quadriga.com/solutions/iq-cast/ (last visited October 1, 2018) 7 http://www.intertouch.com/company/regional-team/; http://www.quadriga.com/company/regional-team/ (last 

visited on October 1, 2018). 

8 Id.

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35. Hotel guests frequently carry a personal device, such as a smart phone, tablet, or 

computer (hereinafter “personal device” or “guest device”). A hotel guest may desire to 

render media content stored on or available via her personal device on the media device 

in her guest room. For example, a hotel guest may have photos or music stored on her 

personal device that she desires to render on the guest room’s media device. Or, she may 

wish to stream subscription programming available via her personal device, e.g., Netflix, 

to the media device in her guest room. This may be done, for example, via a Chromecast 

device installed in the STB-4000, or, in the case of iQ cast, via a Chromecast device 

plugged into a media port, such as an HDMI port, of an in-room TV. 

36. The 281 Patent is directed to a media system and method for operating a media system 

that selectively allows hotel guests to stream media content stored on, or available 

through, their personal devices to the media device in their guest room via the hotel’s 

computer network. 

37. The system and method described and claimed in the 281 Patent prevents the media 

content on a hotel guest’s personal device from being streamed to a media device in 

another guest room. 

38. Claim 1 of the 281 Patent is reproduced below and each paragraph has been annotated 

with an identifying letter: 

A media system comprising: 

a) a local area computer network installed at a hospitality establishment, the 

hospitality establishment being a lodging establishment; 

b) a plurality of media devices coupled to the computer network and located in a 

plurality of guest rooms of the hospitality establishment, the media devices being 

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audio-visual (“AV”) entertainment devices providing media functions within the 

guest rooms to guests of the hospitality establishment; and 

c) a system controller coupled to the computer network; 

d) wherein the computer network allows a guest device supporting a network-based 

media sharing protocol to be coupled thereto, the guest device operated by a guest 

of the hospitality establishment; 

e) the computer network by default prevents the guest device from utilizing the 

network-based media sharing protocol to share media content with the media 

devices; 

f) the system controller selects a subset of the media devices for which media 

sharing is to be enabled for the guest device, the subset including at least one of 

the media devices but not all of the media devices, the subset of the media devices 

for which media sharing is to be enabled for the guest device being located in a 

specific guest room of the hospitality establishment; 

g) the system controller dynamically reconfigures one or more components of the 

computer network in response to an event occurrence to enable the guest device to 

utilize the network-based media sharing protocol to share media over the 

computer network with only the subset of the media devices; 

h) at least one of the components is a media proxy that supports the network-based 

media sharing protocol; 

i) the computer network blocks multicast announcements from the media devices 

from reaching the [g]uest device; 

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j) the media proxy periodically multicasts an announcement according to the 

network-based media sharing protocol that indicates the media proxy is available 

on the computer network; 

k) the computer network allows the guest device to receive the announcement from 

the media proxy; 

l) the computer network allows the guest device to discover and share media with 

the media proxy utilizing the network-based media sharing protocol; 

m) the media proxy by default does not reroute media shared by the guest device to 

any of the media devices; 

n) the system controller dynamically reconfigures the media proxy in response to the 

event occurrence to cause the media proxy to reroute media shared by the guest 

device to one or more of the subset of the media devices; 

o) at least one of the subset of the media devices supports the network-based media 

sharing protocol; and 

p) when rerouting media shared by the guest device to the one or more of the subset 

of the media devices, the media proxy redirects a media stream received from the 

guest device to the at least one of the subset of the media devices that supports the 

network-based media sharing protocol. 

39. Upon information and belief, and without authorization from the Guest Tek, Defendant 

makes, uses, sells and/or offers to sell in, and/or imports into, the United States, and/or 

has made, used, sold and/or offered to sell in, and/or imported into, the United States, 

and/or, during the term of the 281 Patent, will sell in the United States, either directly 

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and/or through or in cooperation with others, the iQx Platform/STB-4000 with 

Chromecast, and iQ cast, both of which are covered by at least claim 1 of the 281 Patent. 

40. The factual allegations of paragraph nos.41 through 71 are upon information and belief. 

The iQx Platform/STB-4000 with Chromecast 

41. The iQx Platform comprises the STB-4000. Particularly, the STB-4000 is an AV 

entertainment device having media functions that allow a hotel guest to, for example, 

access the internet, play music, play games, and watch video programming on a device, 

such as a TV, connected to the STB-4000. 

42. The iQx Platform comprises a plurality of STB-4000’s located in a plurality of guest 

rooms. For at least this reason, the iQx Platform comprises a “plurality of media 

devices” as recited by paragraph b) of claim 1 of the 281 Patent. 

43. Each STB-4000 includes a central processing unit (“CPU”) connected to a computer 

network, as set forth below. For at least this reason, the iQx Platform comprises a 

“system controller” as recited by paragraph c) of claim 1 of the 281 Patent. 

44. Within a hotel, the plurality of STB-4000’s, including their CPU’s, are connected to a 

hotel’s LAN, as recited by paragraph a) of claim 1 of the 281 Patent. The hotel LAN 

includes a WiFi network. 

45. Within a hotel using STB-4000’s with Chromecast, a hotel guest can connect a personal 

device to the LAN, for example, via the WiFi network. This is typically done via the 

Chromecast device. By default, the LAN prevents the personal device from sharing 

content with a STB-4000. 

46. By way of example, some of the service set identifiers (“SSIDs”) (the names associated 

with the WiFi network) presented by the LAN connect a guest device to an STB-4000 

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with Chromecast, but no connection can be established with them until the guest takes 

further action. In addition, the LAN prevents the personal device from utilizing the 

Chromecast device on SSID’s to which the guest is not connected. For at least this 

reason, the iQx Platform/STB-4000 with Chromecast comprises the structure and 

functionality recited by paragraphs d) and e) of claim 1 of the 281 Patent. 

47. Within a hotel using STB-4000’s with Chromecast, the Chromecast device can be 

configured by a guest to allow her personal device to share content with the STB-4000 in 

her guest room via a secure SSID created on the WiFi network. When this has been 

done, the STB-4000 prompts the guest to begin a session by which content available via 

the personal device can be shared with the STB-4000 in her guest room. By way of 

example, a guest can select a Chromecast menu option via the STB-4000 such that a new 

SSID with an identifier associated with the guest room is presented, and the guest can 

connect her personal device to the LAN via the new SSID. Once a connection to the new 

SSID has been made, the guest is prompted to begin a Chromecast session. Once the 

guest has responded to the prompt so as to begin a Chromecast session, a prompt is 

presented to the guest stating “Simply tap the Cast button in an app and choose a video to 

play on your TV.” In response to the guest selecting “Okay” via the STB-4000’s remote 

control, the guest is able to share media, using the Chromecast device within the STB4000 via her personal device. Thus, at least one component of the LAN is dynamically 

reconfigured in response to the guest responding to the prompt. For at least this reason, 

the iQx Platform/STB-4000 with Chromecast comprises the structure and functionality 

recited by paragraphs f) and g) of claim 1 of the 281 Patent. 

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48. Within a hotel using STB-4000’s with Chromecast that have been configured as recited 

above, the STB-4000 serves as a proxy between the guest’s personal device and the 

Chromecast device within the STB-4000 because it proxies data (content) between the 

guest’s personal device and the Chromecast device. For at least this reason, at least one of 

the components is a “media proxy” as recited by paragraph h) of claim 1 of the 281 

Patent. 

49. Within a hotel using STB-4000’s with Chromecast, the LAN broadcasts multicast 

announcements that contain information about traffic on the LAN to personal devices 

connected to the LAN. When a personal device is connected to the LAN via an SSID 

associated with a Chromecast session, the multicast announcement includes information 

about the Chromecast session. When the personal device is connected to the LAN via a 

different SSID, there is no information about the Chromecast session in the multicast 

announcement. For at least this reason, the iQx Platform/STB-4000 with Chromecast 

comprises the structure and functionality recited by paragraphs i), j) and k) of claim 1 of 

the 281 Patent. 

50. Within a hotel using STB-4000’s with Chromecast, and as set forth above, once a 

Chromecast session has been initiated, the LAN discovers the guest’s personal device and 

allows content to be shared with the STB-4000 via the personal device. For at least this 

reason, the iQx Platform/STB-4000 with Chromecast comprises the structure and 

functionality recited by paragraph l) of claim 1 of the 281 Patent. 

51. Within a hotel using STB-4000’s with Chromecast, the STB-4000 will not route content 

that it has received from the guest’s personal device to any of the Chromecast devices, 

and hence the content will not be rendered on a TV or other AV device connected 

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thereto. For at least this reason, the iQx Platform/STB-4000 with Chromecast comprises 

the structure and functionality recited by paragraph m) of claim 1 of the 281 Patent. 

52. Within a hotel using STB-4000’s with Chromecast, and as set forth above, once the guest 

has responded to the prompt and a Chromecast session has been initiated, the CPU allows 

the STB-4000 to route the content that it receives from the guest’s personal device to a 

Chromecast device and media playback begins. For at least this reason, the iQx 

Platform/STB-4000 with Chromecast comprises comprise the structure and functionality 

recited by paragraph n) of claim 1 of the 281 Patent. 

53. Within a hotel using STB-4000’s with Chromecast, the STB-4000 in the guest room has 

been configured to allow a Chromecast session. For at least this reason, the iQx 

Platform/STB-4000 with Chromecast comprises the structure and functionality recited by 

paragraph o) of claim 1 of the 281 Patent. 

54. Within a hotel using STB-4000’s with Chromecast, and as set forth above, once a 

Chromecast session has been initiated, the CPU redirects the media stream from the 

guest’s personal device to the internally installed Chromecast media device within the 

STB-4000. The output of the Chromecast device is sent via the STB-4000’s Chromecast 

HDMI port, to the TV or other AV equipment connected thereto. For at least this reason, 

the iQx Platform/STB-4000 with Chromecast comprises the structure and functionality 

recited by paragraph p) of claim 1 of the 281 Patent. 

iQ cast 

55. Within a hotel using iQ cast, a hotel guest can stream content via her personal device to 

her in-room TV, and therefore iQ cast is a media system, as recited by the preamble of 

claim 1 of the 281 Patent. 

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56. Within a hotel using iQ cast, the hotel’s existing LAN is used to stream content. For at 

least this reason, iQ cast comprises and/or employs the structure and function recited by 

paragraph a) of claim 1 of the 281 Patent. 

57. Within a hotel using iQ cast, Chromecast devices are installed on guest room TV’s and 

communicate via a network, and the TV settings are configured to implement 

Chromecast as a TV channel via an HDMI port selection. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph b) of claim 1 of 

the 281 Patent. 

58. Within a hotel using iQ cast, there is an iQ cast server coupled to the hotel’s LAN. For at 

least this reason, iQ cast comprises and/or employs the structure and function recited by 

paragraph c) of claim 1 of the 281 Patent. 

59. Within a hotel using iQ cast, the hotel’s LAN allows a guest device that supports 

Chromecast functionality to be coupled to the LAN. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph d) of claim 1 of 

the 281 Patent. 

60. Within a hotel using iQ cast, a guest can login to the hotel’s HSIA network and register 

her device. After registration, the guest’s device is associated with the room by the iQ 

cast server. Before registration, the guest device is unable to share media with the in 

room media device, i.e., the in-room Chromecast device. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph e) of claim 1 of 

the 281 Patent. 

61. Within a hotel using iQ cast, there is a Guest virtual local area network (“VLAN”) by 

which a guest can use the hotel’s HSIA network. The iQ cast server has access to the 

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Guest VLAN. There is also a Chromecast VLAN by which the Chromecast devices 

communicate with the iQ cast server. The iQ cast server associates with the guest rooms 

those Chromecast devices for which media sharing is enabled. The guest can only view 

content via the Chromecast device in that room. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph f) of claim 1 of 

the 281 Patent. 

62. Within a hotel using iQ cast, the iQ cast server is configured to associate a guest device to 

a guest room once the guest has logged into the hotel’s HSIA and provided a name and 

room number. The guest can then use the Chromecast device associated with that guest 

room. The guest can only view content via the Chromecast device in that room. For at 

least this reason, iQ cast comprises and/or employs the structure and function recited by 

paragraph g) of claim 1 of the 281 Patent. 

63. Within a hotel using iQ cast, the iQ cast server acts as a media proxy that supports a 

network-based media sharing protocol. For at least this reason, iQ cast comprises and/or 

employs the structure and function recited by paragraph h) of claim 1 of the 281 Patent. 

64. Within a hotel using iQ cast, Chromecast devices are on the Chromecast VLAN and 

guest devices are on the Guest VLAN, and multicast announcements on the Chromecast 

VLAN are blocked from reaching the guest devices. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph i) of claim 1 of 

the 281 Patent. 

65. Within a hotel using iQ cast, the iQ cast server sends multicast announcements on the 

Guest VLAN in accordance with the Chromecast device standard in order for the guest 

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devices to connect to the iQ cast server. For at least this reason, iQ cast comprises and/or 

employs the structure and function recited by paragraph j) of claim 1 of the 281 Patent. 

66. Within a hotel using iQ cast, the iQ cast server sends multicast announcements on the 

Guest VLAN in order for the guest devices to receive the announcements. For at least this 

reason, iQ cast comprises and/or employs the structure and function recited by paragraph 

k) of claim 1 of the 281 Patent. 

67. Within a hotel using iQ cast, the hotel’s HSIA allows the guest to use the Chromecast 

device in her room via the iQ cast server, and iQ cast server serves as the media proxy. 

For at least this reason, iQ cast comprises and/or employs the structure and function 

recited by paragraph l) of claim 1 of the 281 Patent. 

68. Within a hotel using iQ cast, if a guest connects to the hotel’s HSIA without having first 

associated her guest device with her room, the iQ cast server will not route media shared 

by the guest device to any of the Chromecast devices. For at least this reason, iQ cast 

comprises and/or employs the structure and function recited by paragraph m) of claim 1 

of the 281 Patent. 

69. Within a hotel using iQ cast, the iQ cast server is responsible for associating and 

disassociating guest devices with guest rooms, and clears all Chromecast data at guest 

check-in and check-out. When a new guest checks into a room and logs into the hotel’s 

HSIA with her name and guest room number with her guest device, that guest’s device is 

associated with the iQ cast server, and media can be shared between her device and the 

Chromecast device in her room. For at least this reason, iQ cast comprises and/or 

employs the structure and function recited by paragraph n) of claim 1 of the 281 Patent. 

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70. Within a hotel using iQ cast, the Chromecast devices connected to the in room TV’s 

support the Chromecast protocol. For at least this reason, iQ cast comprises and/or 

employs the structure and function recited by paragraph o) of claim 1 of the 281 Patent. 

71. Within a hotel using iQ cast, the media that is shared by the guest device is shared with 

the iQ cast server, and the iQ cast server directs the media shared by the guest device to 

the Chromecast device in her room. For at least this reason, iQ cast comprises and/or 

employs the structure and function recited by paragraph p) of claim 1 of the 281 Patent. 

72. Defendant has directly infringed, and continues to directly infringe, and/or, during the 

term of the 281 Patent, will directly infringe, at least claim 1 of the 281 Patent by making, 

using, selling, offering for sale in, and/or importing into, the United States, Infringing 

Products, as described above. 

73. Defendant has been on actual notice that it infringes the 281 Patent. Guest Tek has 

marked its products. Additionally, Defendant has had actual knowledge of its 

infringement of the 281 Patent at least since about October 31, 2017, when Guest Tek 

filed this action. Defendant has deliberately, intentionally and willfully infringed the 281 

Patent, and continues to do so. 

74. As a direct result of Defendant’s infringing acts, Guest Tek has suffered and will 

continue to suffer damage and irreparable harm. 

75. Unless Defendant and those acting in active concert with Defendant are enjoined from 

infringing the 281 Patent, Guest Tek will suffer irreparable injury for which damages are 

an inadequate remedy. 

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Count II: Direct Infringement of the 172 Patent by the iQx Platform/STB-4000 with 

Chromecast, and by iQ cast. 

76. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

77. The 172 Patent is directed to a media proxy that selectively allows hotel guests to stream 

media content stored on, or available through, their personal devices to a media device in 

their guest room via the hotel’s LAN. 

78. The media proxy described and claimed in the 172 Patent facilitates sharing of media 

content from the hotel guest’s personal device with the media device in her guest room 

and prevents media content from also being streamed to the media device in another 

guest room. 

79. Claim 1 of the 172 Patent is reproduced below and each paragraph thereof has been 

annotated with an identifying letter: 

80. A media proxy comprising: 

a) a storage device storing a plurality of software instructions and a set of proxy 

rules; 

b) a network interface coupled to a computer network; and 

c) one or more processors coupled to the storage device and the network interface; 

wherein, by the one or more processors executing the software instructions loaded 

from the storage device, the one or more processors are operable to cause the 

media proxy at least to: 

d) update the set of proxy rules to associate an identifier of a guest device with a 

subset of a plurality of media devices in response to a first event occurrence; 

e) wherein the guest device is operable by a guest of a hospitality establishment; 

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f) the media devices are AV entertainment devices located within guest rooms of the 

hospitality establishment, are streaming destinations capable of playing media 

content initiated by the guest device utilizing a network based media sharing 

protocol, and are isolated from the guest device such that the media devices are 

not directly accessible over the computer network by the guest device; 

g) the subset of the media devices represents one or more of the media devices for 

which media sharing is to be enabled for the guest device; and 

h) the subset of the media devices includes at least one of the media devices but not 

all of the media devices; 

i) receive from the guest device via the computer network a query for available 

media devices supporting the network based media sharing protocol; 

j) send via the computer network a reply announcing availability of the media proxy 

as a streaming destination supporting the network-based media sharing protocol at 

a network address of the media proxy on the computer network; 

k) receive from the guest device at the network address of the media proxy an 

incoming request to initiate media streaming playback utilizing the network-based 

media sharing protocol; 

l) perform at least one transparent proxy operation between the guest device and a 

selected one of the subset of the media devices determined to be associated with 

the identifier of the guest device according to the set of proxy rules thereby 

enabling the guest device to initiate media streaming playback on the selected one 

of the subset of the media devices according to the network-based media sharing 

protocol; and 

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m) send an input port selection command to a display device located in a guest room 

of the hospitality establishment, the input port selection command causing the 

display device to switch to a first input port and begin playing media initiated for 

playback on the selected one of the subset of the media devices, the media 

initiated for playback on the selected one of the subset of the media devices being 

received by the display device on the first input port. 

81. Upon information and belief, and without authorization from Guest Tek, Defendant 

makes, uses, sells and/or offers to sell in, and/or imports into, the United States, and/or 

has made, used, sold and/or offered to sell in, and/or imported into, the United States, 

and/or, during the term of the 172 Patent, will sell in the United States, either directly 

and/or through or in cooperation with others, the iQx Platform/STB-4000 with 

Chromecast, and iQ cast, both of which are covered by at least claim 1 of the 172 Patent. 

82. The factual allegations of paragraphs 83 through 105 are upon information and belief. 

The iQx Platform/STB-4000 with Chromecast 

83. The STB-4000 with Chromecast is an AV entertainment device having media functions 

that allow a hotel guest to, for example, use a personal device to access the internet, play 

music, play games, and watch video programming on a device, such as a TV, connected 

to the STB-4000. At least one of the components is a media proxy. 

84. Each STB-4000 includes a CPU and a memory and an interface for connecting to a 

computer network as recited by paragraphs a), b), and c) of claim 1 of the 172 Patent. 

Thus, the STB-4000 comprises a one or more processors coupled to a storage device and 

the network interface. The CPU executes software instruction from the storage device as 

recited by paragraph c) of claim 1 of the 172 Patent. 

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85. When a guest device connects by way of the network to a STB-4000 with Chromecast, 

the STB-4000 stores information about the guest device. When desired by the hotel 

guest, the STB-4000 further associates the guest device with the Chromecast device 

installed within the STB-4000 to enable casting operations. For at least this reason, the 

iQx Platform/STB-4000 with Chromecast comprises the structure and functionality 

recited by paragraph d) of claim 1. 

86. A STB-4000 with Chromecast is designed to operate with a personal device of a hotel 

guest. For at least this reason, the iQx Platform/STB-4000 with Chromecast comprises 

the structure and functionality recited by paragraph e) of claim 1of the 172 Patent . 

87. STB-4000’s are designed to connect to a hotel network to extend the LAN within a guest 

room and to connect to a TV. The network connection allows a personal device that 

supports a network-based media sharing protocol (e.g., Chromecast) to connect to a STB4000 with Chromecast by way of the LAN in order to initiate media content playback on 

the Chromecast device installed within the STB-4000 for playback on the TV. A 

separate STB-4000 with Chromecast is installed in each of plurality of guest rooms, and 

the Chromecast device within each STB-4000 is not directly accessible to the guest 

personal device. For at least this reason, the iQx Platform/STB-4000 with Chromecast 

comprises the structure and functionality recited by paragraph f) of claim 1 of the 172 

Patent . 

88. Within a STB-4000 with Chromecast, media sharing functions on the Chromecast device 

as initiated by the guest device, are selectively enabled by the STB-4000. The STB-4000 

controls whether the guest device is able to initiate media content playback on that 

Chromecast device. For at least this reason, the iQx Platform/STB-4000 with 

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Chromecast comprises the structure and functionality recited by paragraph g) of claim 1 

of the 172 Patent. 

89. Within a hotel having STB-4000’s with Chromecast, a guest can configure the 

STB-4000 so as to allow her personal device to share content with the STB-4000 in her 

guest room via a secure SSID created on the WiFi network. The STB-4000 prompts the 

guest to begin a session by which content initiated via the personal device can be shared 

with the STB-4000 in her guest room. By way of example, a guest can select a 

Chromecast menu option via the STB-4000 such that a new SSID with a Chromecast 

identifier associated with the guest room is presented, and the guest can connect her 

personal device to the LAN via the new SSID. Once a connection to the new SSID has 

been made, the guest is prompted to begin a Chromecast session. Once the guest has 

responded to the prompt so as to begin a Chromecast session, a prompt is presented to the 

guest stating “Simply tap the Cast button in an app and choose a video to play on your 

TV.” In response to the guest selecting “Okay” via the STB-4000’s remote control, the 

guest is able to share media, using Chromecast, with the STB-4000 via her personal 

device. For at least this reason, the iQx Platform/STB-4000 with Chromecast comprises 

the structure and functionality recited by paragraphs g), h), i), j), and k) of claim 1 of the 

172 Patent. 

90. Each STB-4000 with Chromecast that has been configured as recited above serves as a 

proxy between the guest’s personal device and the Chromecast device within the STB4000 because it proxies data between the guest’s personal device and the Chromecast 

device. Once a Chromecast session has been initiated, the guest device can initiate media 

content playback and the LAN allows content to be shared with the STB-4000 for 

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playback through the Chromecast device. For at least this reason, the iQx Platform/STB4000 with Chromecast comprises the structure and functionality recited by paragraph l) 

of claim 1 of the 172 Patent. 

91. As set forth above, with a STB-4000 with Chromecast, once a Chromecast session has 

been initiated, media content playing on the Chromecast device is sent via a particular 

HDMI port on the STB-4000 to the in-room TV connected thereto. The CPU of the STB4000 sends an input port selection command to the in-room TV causing the TV to switch 

its active HDMI port to the particular HDMI port that is coupled to the Chromecast 

device. After the input port selection command is sent to the TV, the hotel guest sees on 

the in-room TV the media content playing on the Chromecast device. For at least this 

reason, the iQx Platform/STB-4000 with Chromecast comprises the structure and 

functionality recited by paragraph m) of claim 1 of the 172 Patent. 

iQ cast 

92. Within a hotel having iQ cast, the iQ cast server serves as a media proxy, as recited by 

the preamble of claim 1 of the 172 Patent. 

93. Within a hotel having iQ cast, the iQ cast server comprises a storage device that stores 

software instructions. The Chromecast devices in each room are associated with the iQ 

cast server. The iQ cast server is also given access to the Guest VLAN. The iQ cast 

server stores information about the in-room Chromecast devices and the personal devices 

on the Guest VLAN in the form of proxy rules. For at least this reason, iQ cast comprises 

the structure and functionality recited by paragraph a) of claim 1 of the 172 Patent. 

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94. Within a hotel having iQ cast, the iQ cast server has an network interface that is used to 

couple the iQ cast server to a hotel network. For at least this reason, iQ cast comprises the 

structure and functionality recited by paragraph b) of claim 1 of the 172 Patent. 

95. Within a hotel having iQ cast, the iQ cast server has at least one processor and memory 

storage. The processor communicates with the network interface that is also part of the 

iQ cast server, and executes software instructions that are stored on a storage device. The 

processor executing the software instructions causes the media proxy to carry out the 

operations and perform the functions recited below. For at least this reason, iQ cast 

comprises the structure and functionality recited by paragraph c) of claim 1 of the 172 

Patent. 

96. Within a hotel having iQ cast, the iQ cast server is configured to associate a guest device 

to a guest room when the guest has logged into the hotel’s HSIA login portal, and 

provided a name and room number. The guest is associated with the Chromecast device 

associated with the guest’s room when the guest logs into the hotel’s HSIA. For at least 

this reason, iQ cast comprises the structure and functionality recited by paragraph d) of 

claim 1 of the 172 Patent. 

97. Within a hotel having iQ cast, the iQ cast solution allows guests to use their own devices 

to stream content. For at least this reason, iQ cast comprises the structure and 

functionality recited by paragraph e) of claim 1 of the 172 Patent. 

98. Within a hotel having iQ cast, Chromecast devices are located in guest rooms and are 

capable of playing media content initiated by the guest devices using the Chromecast 

protocol. The Chromecast devices and guest devices are on separate VLANs. For at least 

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this reason, iQ cast comprises the structure and functionality recited by paragraph f) of 

claim 1 of the 172 Patent. 

99. Within a hotel having iQ cast, media sharing is enabled only for a Chromecast device 

associated to the guest’s room. For at least this reason, iQ cast comprises the structure 

and functionality recited by paragraph g) of claim 1 of the 172 Patent. 

100. Within a hotel having iQ cast, a guest can only share media with the Chromecast device 

in the guest’s room, but not in the adjoining or surrounding rooms. For at least this 

reason, iQ cast comprises the structure and functionality recited by paragraph h) of 

claim 1 of the 172 Patent. 

101. Within a hotel having iQ cast, in order to find available Chromecast devices, the guest 

device searches for devices on the network. The iQ cast server will only allow a guest 

device to share media with a Chromecast device associated with a guest’s room. For at 

least this reason, iQ cast comprises the structure and functionality recited by paragraph i) 

of claim 1 of the 172 Patent. 

102. Within a hotel having iQ cast, the IQ cast server sends an announcement over the Guest 

VLAN using a mDNS message in the same format as a Chromecast device that provides 

a network address of the iQ cast server. For at least this reason, iQ cast comprises the 

structure and functionality recited by paragraph j) of claim 1 of the 172 Patent. 

103. Within a hotel having iQ cast, the Chromecast devices are on the Chromecast VLAN. 

The iQ cast server receives, over the Guest VLAN, the request from the guest device to 

initiate media streaming. For at least this reason, iQ cast comprises the structure and 

functionality recited by paragraph k) of claim 1 of the 172 Patent. 

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104. Within a hotel having iQ cast, the iQ cast server has access to the Chromecast and Guest 

VLAN’s. The iQ cast server enables the guest to initiate media streaming via the 

Chromecast device associated with the guest’s room. For at least this reason, iQ cast 

comprises the structure and functionality recited by paragraph l) of claim 1 of the 172 

Patent. 

105. Within a hotel having iQ cast, the iQ cast server causes the input port on the TV to switch 

to the Chromecast HDMI port. It is received by the TV via FTG channel mapping. 

Thereafter, the Chromecast device can display media on the TV by way of the HDMI 

port. For at least this reason, iQ cast comprises the structure and functionality recited by 

paragraph m) of claim 1 of the 172 Patent. 

106. Defendant has directly infringed, and continues to directly infringe, and/or, during the 

term of the 172 Patent, will directly infringe, at least claim 1 of the 172 Patent by making, 

using, selling, offering for sale in, and/or importing into, the United States, Infringing 

Products as described above. 

107. Defendant has been on actual notice that it infringes the 172 Patent. Guest Tek has 

marked its products. Additionally, Defendant has had actual knowledge of its 

infringement of the 172 Patent at least since about October 31, 2017, when Guest Tek 

filed this action. Defendant has deliberately, intentionally and willfully infringed the 172 

Patent, and continues to do so. 

108. As a direct result of Defendant’s infringing acts, Guest Tek has suffered and will 

continue to suffer damage and irreparable harm. 

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109. Unless Defendant and those acting in active concert with Defendant are enjoined from 

infringing the 172 Patent, Guest Tek will suffer irreparable injury for which damages are 

an inadequate remedy. 

Count III: Indirect Infringement of the 281 Patent – Inducement 

110. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

111. The factual allegations of paragraphs 112 through 120 are upon information and belief.

STB-4000/Chromecast 

112. Defendant currently makes, uses, sells and/or offers to sell in, and/or imports into, the 

United States, and/or has made, used, sold and/or offered to sell in, and/or imported into, 

the United States, either directly and/or through or in cooperation with others, STB4000’s. 

113. As manufactured and sold by Defendant, STB-4000’s are each equipped with an internal 

HDMI port which is specifically designated to receive a Chromecast device. 

114. Installation of a Chromecast device into a STB-4000, by plugging the Chromecast device 

into the specifically designated HDMI port, completes the invention defined by at least 

claim 1 of the 281 Patent, for the reasons set forth above. 

115. Defendant anticipates that purchasers and/or owners of STB-4000’s may wish to install, 

and/or have installed, Chromecast devices into their STB-4000’s following their purchase 

thereof and/or at some time during their ownership or use thereof. 

116. Defendant has been aware of, and had knowledge of, the 281 Patent since at least 

October 31, 2017. 

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117. Defendant has been aware, since at least October 31, 2017, of Guest Tek’s allegations 

that the iQx Platform, including STB-4000’s with Chromecast, when installed in hotels, 

satisfy at least claim 1 of the 281 Patent. 

118. Defendant has been aware, since at least October 31, 2017, of Guest Tek’s allegations 

that Defendant’s activities in making, using, selling, offering for sale in the United States, 

and/or importing into the United States, iQx Platforms that include STB-4000’s with 

Chromecast constitute direct infringement of the 281 Patent. 

119. Defendant has encouraged and encourages purchasers and owners of STB-4000’s to 

install for use Chromecast devices therein so as to complete the invention of claim 1 of 

the 281 Patent and thus to infringe the 281 Patent. 

120. Defendant’s encouraging activity includes, but is not limited to, providing detailed 

written instructions as to how to remove a secure door from the STB-4000 using a 

“security” key, installing a Chromecast device into the compartment concealed by the 

door, inserting it into the specifically designated HDMI port, and reinstalling the secure 

door. 

121. Through its acts of instructing others how to install a Chromecast device into the 

specifically designated HDMI port in a STB-4000, and with knowledge of the 281 Patent 

and Guest Tek’s infringement allegations relating thereto, Defendant has intended, and 

intends, that others directly infringe the 281 Patent. 

122. Defendant’s acts of encouraging and instructing others to install a Chromecast device in a 

STB-4000, as alleged herein, have resulted in direct infringement of, and/or, during the 

term of the 281 Patent, will result in direct infringement of, the 281 Patent by others, 

including, but not limited to, Quadriga and Intertouch. 

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123. Defendant’s acts, as alleged herein, constitute indirect infringement of the 281 Patent 

under 35 U.S.C. § 271(b). 

124. As a direct result of Defendant’s acts of indirect infringement of the 281 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm. 

125. Unless Defendant and those acting in active concert with Defendant are enjoined from 

indirectly infringing the 281 Patent, Guest Tek will suffer irreparable injury for which 

damages are an inadequate remedy. 

iQ cast

126. The factual allegations of paragraphs 127 through 132 are upon information and belief. 

127. Defendant currently makes, uses, sells and/or offers to sell in, and/or imports into, the 

United States, and/or has made, used, sold and/or offered to sell in, and/or imported into, 

the United States, and/or, during the term of the 281 Patent, will sell in the United States, 

either directly and/or through or in cooperation with others, iQ cast servers. 

128. iQ cast servers are specifically designed and programmed to implement and support the 

iQ cast solution. 

129. Installation of an iQ cast server on a hotel’s existing HSIA, and of Chromecast devices on 

TV’s in guest rooms of the hotel, and configuring the TV settings to implement 

Chromecast as a TV channel via an HDMI port selection, completes and/or will complete 

the invention of at least claim 1 of the 281 Patent, for the reasons set forth above. 

130. Defendant anticipates that hotels may wish to install, and/or have installed, iQ cast 

servers on their LAN’s, and Chromecast devices in the TV’s in their guest rooms, as set 

forth above, so as to provide hotel guests with the ability to stream content from their 

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personal devices to their TV’s, using Chromecast, without the need to purchase and/or 

install a STB-4000 with Chromecast. 

131. Defendant instructs, has instructed, and/or, during the term of the 281 Patent, will provide 

instructions to, others to install, in a hotel already having a LAN, such equipment as is 

necessary to provide iQ cast within a hotel that did not previously have iQ cast, including 

instructions to install an iQ cast server on the hotel’s existing HSIA, to install 

Chromecast devices to an HDMI port of TV’s within guest rooms of the hotel, and to 

configure the TV’s settings to implement Chromecast as a TV channel with an HDMI 

port selection. 

132. Defendant encourages purchasers and owners of iQ cast servers to install an iQ cast 

server on the hotel’s existing HSIA, to install Chromecast devices to an HDMI port of 

TV’s within guest rooms of the hotel, and to configure the TV’s settings to implement 

Chromecast as a TV channel with an HDMI port selection so as to complete the invention 

of at least claim 1 of the 281 Patent and thus to infringe the 281 Patent. 

133. Defendant has been aware of, and had knowledge of, the 281 Patent since at least 

October 31, 2017. 

134. Through its acts of instructing others how to install an iQ cast server on a hotel’s existing 

HSIA, how to install Chromecast devices on an HDMI port of TV’s within guest rooms 

of the hotel, and how to configure the TV’s settings to implement Chromecast as a TV 

channel with an HDMI port selection, and with knowledge of the 281 Patent and Guest 

Tek’s previous infringement allegations as they relate to the STB-4000 with Chromecast, 

Defendant has intended, and intends, that others directly infringe the 281 Patent. 

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135. Defendant’s has known, and knows, that its acts, as alleged herein, would result in others 

infringing the 281 Patent. 

136. Defendant’s acts, as alleged herein, have resulted in direct infringement of, and/or, during 

the term of the 281 Patent, will result in direct infringement of, the 281 Patent by others, 

including, but not limited to, direct infringement by Quadriga and Intertouch. 

137. Defendant’s acts, as alleged herein, constitute indirect infringement of the 281 Patent 

under 35 U.S.C. § 271 (b). 

138. As a direct result of Defendant’s acts of indirect infringement of the 281 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm. 

139. Unless Defendant and those acting in active concert with Defendant are enjoined from 

indirectly infringing the 281 Patent, Guest Tek will suffer irreparable injury for which 

damages are an inadequate remedy. 

Count IV: Indirect Infringement of the 172 Patent - Inducement 

140. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

STB-4000/Chromecast 

141. Installation of a Chromecast device into a STB-4000, by plugging the Chromecast device 

into the specifically designated HDMI port, completes the invention defined by claim 1 

of the 172 Patent, for the reasons set forth above. 

142. Upon information and belief, Defendant encourages purchasers and owners of STB4000’s to install Chromecast devices therein so as to complete the invention of at least 

claim 1 of the 172 Patent and thus to infringe the 172 patent. 

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143. Defendant has been aware, since at least October 31, 2017, of Guest Tek’s allegations 

that the iQx Platform, including STB-4000’s with Chromecast, when installed in hotels, 

satisfy at least claim 1 of the 172 Patent. 

144. Defendant’s has been aware, since at least October 31, 2017, of Guest Tek’s allegations 

that Defendant’s activities in making, using, selling, offering for sale in the United States, 

and/or importing into the United States, iQx Platforms that include STB-4000’s with 

Chromecast constitute direct infringement of the 172 Patent. 

145. Through its acts of instructing others how to install a Chromecast device into the 

specifically designated HDMI port in a STB-4000, and with knowledge of the 172 Patent 

and Guest Tek’s infringement allegations relating thereto, Defendant has intended, and 

intends, that others directly infringe the 172 Patent. 

146. Defendant’s acts of encouraging and instructing others to install a Chromecast device in a 

STB-4000, as alleged herein, have resulted in direct infringement of, and/or, during the 

term of the 172 Patent, will result in direct infringement of, the 172 Patent by others, 

including Quadriga and Intertouch. 

147. Defendant’s acts, as alleged herein, constitute indirect infringement of the 172 Patent 

under 35 U.S.C. § 271 (b). 

148. As a direct result of Defendant’s acts of indirect infringement of the 172 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm. 

149. Unless Defendant and those acting in active concert with Defendant are enjoined from 

indirectly infringing the 172 Patent, Guest Tek will suffer irreparable injury for which 

damages are an inadequate remedy. 

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iQ cast 

150. Upon information and belief, installation of an iQ cast server on a hotel’s existing HSIA, 

and of Chromecast devices on TV’s in guest rooms of the hotel, and configuring the TV 

settings to implement Chromecast as a TV channel via an HDMI port selection, 

completes the invention of at least claim 1 of the 172 Patent, for the reasons set forth 

above. 

151. Through its acts of instructing others how to install an iQ cast server on a hotel’s existing 

HSIA, how to install Chromecast devices on an HDMI port of TV’s within guest rooms 

of the hotel, and how to configure the TV’s settings to implement Chromecast as a TV 

channel with an HDMI port selection, and with knowledge of the 172 Patent and Guest 

Tek’s previous infringement allegations as they relate to the STB-4000 with Chromecast, 

Defendant encourages, and has encouraged, others to complete the invention of claim 1 

of the 172 Patent. 

152. Through its acts of instructing others how to install an iQ cast server on a hotel’s existing 

HSIA, how to install Chromecast devices on an HDMI port of TVs within guest rooms of 

the hotel, and how to configure the TVs’ settings to implement Chromecast as a TV 

channel with an HDMI port selection, and with knowledge of the 172 Patent and Guest 

Tek’s infringement allegations as they relate to the STB-4000 with Chromecast, 

Defendant has intended, and intends, that others directly infringe the 172 Patent. 

153. Defendant’s has known, and knows that, its acts, as alleged herein, would result in others 

infringing the 172 Patent. 

154. Defendant has been aware of, and had knowledge of, the 172 patent since at least October 

31, 2017. 

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155. Defendant’s acts, as alleged herein, have resulted in direct infringement of, and/or, during 

the term of the 172 Patent, will result in direct infringement of the 172 Patent by others, 

including but not limited to, direct infringement, by Quadriga and Intertouch. 

156. Defendant’s acts, as alleged herein, constitute indirect infringement of the 172 Patent 

under 35 U.S.C. § 271 (b). 

157. As a direct result of Defendant’s acts of indirect infringement of the 172 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm. 

158. Unless Defendant and those acting in active concert with Defendant are enjoined from 

indirectly infringing the 172 Patent, Guest Tek will suffer irreparable injury for which 

damages are an inadequate remedy. 

Count V: Contributory Infringement of the 281 Patent by iQ cast Servers 

159. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

160. The factual allegations of paragraphs 161 through 165 are upon information and belief. 

161. Defendant has offered to sell in, and/or sold in, the United States, and/or imported into 

the United States, and/or, during the term of the 281 Patent, will sell in the United States, 

iQ cast servers. 

162. For the reasons set forth above, iQ cast servers are and/or will be a component and 

material part, of Defendant’s infringing iQ cast solution. 

163. iQ cast servers are and/or will be programmed so as be to specially made for use in 

connection with the iQ cast solution, and are not a staple article or commodity or 

commodity of commerce. 

164. iQ cast servers have no substantial use other than other than in connection with the 

infringing iQ cast solution. 

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165. Accordingly, iQ cast servers constitute a material component of the system defined by 

claim 1 of the 281 Patent, and are not a staple article or commodity of commerce suitable 

for substantial non-infringing use in respect to at least claim 1 of the 281 Patent. 

166. Defendant has been aware of, and had knowledge of, the 281 Patent since at least 

October 31, 2017. 

167. Defendant has been aware, since at least October 31, 2017, that, once an iQ cast server 

has been installed in a hotel, together with the installation of Chromecast devices in the 

guest room TV sets, and configured as described above, such installation would satisfy at 

least claim 1 of the 281 Patent. 

168. Defendant has been aware, since at least October 31, 2017, that, once an iQ cast server 

has been installed in a hotel, together with the installation of Chromecast devices in the 

guest room TV sets, and configured as described above, such installation would result in 

direct infringement of at least claim 1 of the 281 Patent. 

169. Accordingly, Defendant has contributed to infringement of the 281 Patent through its 

selling, offering for sale and/or importing of iQ cast servers.

170. Defendant’s acts, as alleged herein, have resulted in direct infringement of, and/or, during 

the term of the 281 Patent, will result in direct infringement of, the 281 Patent by others, 

including, but not limited to, direct infringement, by Quadriga and Intertouch. 

171. Defendant’s acts, as alleged herein, constitute indirect infringement of the 281 Patent 

under 35 U.S.C. § 271 (c). 

172. As a direct result of Defendant’s acts of indirect infringement of the 281 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm. 

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173. Unless Defendant and those acting in active concert with Defendant are enjoined from 

indirectly infringing the 281 Patent, Guest Tek will suffer irreparable injury for which 

damages are an inadequate remedy. 

Count VI: Contributory Infringement of the 172 Patent by iQ cast Servers 

174. Guest Tek incorporates each of the preceding paragraphs as if fully set forth herein. 

175. Upon information and belief, iQ cast servers constitute a material component of the 

system defined by claim 1 of the 172 Patent, and are not a staple article or commodity of 

commerce suitable for substantial non-infringing use in respect to at least claim 1 of the 

172 Patent. 

176. Defendant has been aware of, and had knowledge of, the 172 Patent since at least 

October 31, 2017. 

177. Defendant has been aware, since at least October 31, 2017, that, once an iQ cast server 

has been installed in a hotel, together with the installation of Chromecast devices in the 

guest room TV sets, and configured as described above, such installation would satisfy at 

least claim 1 of the 172 Patent. 

178. Defendant has been aware, since at least October 31, 2017, that, once an iQ cast server 

has been installed in a hotel, together with the installation of Chromecast devices in the 

guest room TV sets, and configured as described above, such installation would result in 

direct infringement of at least claim 1 of the 172 Patent. 

179. Accordingly, Defendant has contributed to infringement of the 172 Patent through its 

selling, offering for sale and/or importing of iQ cast servers.

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180. Defendant’s acts, as alleged herein, have resulted in direct infringement of, and/or, during 

the term of the 172 Patent, will result in direct infringement of, the 172 Patent by others, 

including, but not limited to, direct infringement, by Quadriga and Intertouch. 

181. Defendant’s acts, as alleged herein, constitute indirect infringement of the 172 Patent 

under 35 U.S.C. § 271 (c). 

182. As a direct result of Defendant’s acts of indirect infringement of the 172 Patent, Guest 

Tek has suffered and will continue to suffer damage and irreparable harm 

PRAYER FOR RELIEF 

Guest Tek respectfully requests the following relief from this Court: 

(a) Judgment that Defendant has directly and indirectly infringed one or more claims 

of each of the Patents-in-Suit; 

(b) Entry of a preliminary and permanent injunction against Defendant and those in 

privity with it and acting in concert with it from further acts of direct and indirect infringement 

of the Patents-in-Suit, such as through the making, selling, offering for sale and/or importing the 

Infringing Products and/or inducing others to use the Infringing Products and contributing to 

infringement of the Patents-in-Suit; 

(c) An award to Guest Tek of damages adequate to compensate it for all infringement 

occurring through the date of judgment, with prejudgment interest, and for any supplemental 

damages as appropriate and post-judgment interest after that date; 

(d) Judgment that Defendant’s infringement has been willful; and an award of triple 

damages as a result of Defendant’s willful infringement. 

(e) Judgment that this case is exceptional under 35 U.S.C. § 285. 

(f) An award of reasonable attorneys’ fees and costs; and 

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(g) An award of such other and further relief as the Court may deem just and proper. 

DEMAND FOR TRIAL BY JURY 

Pursuant to Federal Rule of Civil Procedure 38(b), Guest Tek hereby demands a trial by 

jury of all issues so triable. 

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Dated: December 17, 2018 Respectfully submitted, 

/s/ Lauren M. Hilsheimer 

 Lauren M. Hilsheimer (0085389) 

Email: lhilsheimer@bakerlaw.com 

Andrew E. Samuels (0090189) 

Email: asamuels@bakerlaw.com 

BAKER & HOSTETLER LLP 

200 Civic Center Drive, Suite 1200 

Columbus, OH 43215-4138 

Telephone: 614-228-1541 

Facsimile: 614-462-2616 

Steven J. Rocci (pro hac vice) 

Email: srocci@bakerlaw.com 

Daniel J. Goettle (pro hac vice)

Email: dgoettle@bakerlaw.com 

Jeffrey W. Lesovitz (pro hac vice) 

Email: jlesovitz@bakerlaw.com 

BAKER & HOSTETLER LLP 

2929 Arch Street 

Cira Centre, 12th Floor 

Philadelphia, PA 19104-2891 

Telephone: 215-568-3100 

Facsimile: 215-568-3439 

Michael J. Swope (pro hac vice) 

Email: mswope@bakerlaw.com 

BAKER & HOSTETLER LLP 

999 Third Avenue, Suite 3600 

Seattle, WA 98104-4040 

Telephone: 206-332-1380 

Facsimile: 206-624-7317 

Attorneys for Plaintiff 

GUEST TEK INTERACTIVE 

ENTERTAINMENT LTD. 

 

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CERTIFICATE OF SERVICE 

 I certify that on December 17, 2018, I served the foregoing on all parties by electronically 

filing it through the Court’s ECF system. 

/s/ Lauren M. Hilsheimer 

Lauren M. Hilsheimer 

Attorney for Plaintiff-Counterdefendant 

Guest-Tek Interactive Entertainment Ltd. 

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