IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

FACET TECHNOLOGY CORP., 

Plaintiff, 

v. 

MOBILEYE GLOBAL, INC., 

Defendant. 

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Civil Action No. 2:24-cv-00058 

JURY TRIAL DEMAND 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Facet Technology Corp. (“Facet” or “Plaintiff”) files this Complaint for Patent 

Infringement and Demand for Jury Trial against Mobileye Global, Inc. (“Mobileye” or 

“Defendant”) for infringement of United States Patent Nos. 9,335,255 (“the ’255 Patent”) and 

9,671,328 (“the ’328 Patent”) (collectively the “Patents-in-Suit”). 

THE PARTIES 

1. Facet is a corporation organized and existing under the laws of Minnesota and 

located at 1044 Rosemary Circle, Chaska, MN 55318. 

2. Upon information and belief, Defendant Mobileye is a corporation organized and 

existing under the laws of Delaware with its headquarters and principal place of business located 

at 13 Hartom Street, Har Hotzvim, Jerusalem, Israel. 

 

JURISDICTION AND VENUE 

3. This is an action for patent infringement arising under the patent laws of the United 

States, Title 35, United States Code, including 35 U.S.C. §§ 154, 271, 281, and 283-285. 

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4. This Court has exclusive subject matter jurisdiction over this case for patent 

infringement under 28 U.S.C. §§ 1331 and 1338. 

5. Mobileye is subject to the general and specific personal jurisdiction of this Court, 

based upon its regularly conducted business in the State of Texas and in the Eastern District of 

Texas (“District”), including conduct giving rise to this action. 

6. Mobileye has conducted and does conduct business within the State of Texas. 

7. Mobileye has committed, and continues to commit, acts of infringement in this 

District, has conducted business in this District and has engaged in continuous and systematic 

activities in this District and throughout the state of Texas through the activities and relationships 

described below. 

8. This Court has personal jurisdiction over Mobileye at least because Mobileye has 

made, used, offered to sell, sold, or put into service the accused products, systems, or services 

within the District, thus committing acts of infringement within the District, and placed infringing 

products, systems, or services into the stream of commerce knowing or understanding that such 

products, systems, or services would be used in the United States, including in the Eastern District 

of Texas. Mobileye thus has committed and continues to commit acts of infringement in this 

District by, among other things, offering to sell, selling products and/or services, and/or using 

services that infringe the Asserted Patents. 

9. This Court likewise has personal jurisdiction over Mobileye at least because 

Mobileye has 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 Mobileye would not 

offend traditional notions of fair play and substantial justice. 

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10. This Court has specific personal jurisdiction over Mobileye in this action pursuant 

to due process and the Texas Long Arm Statute because the claims asserted herein arise out of or 

are related to Mobileye’s voluntary contacts with this forum, such voluntary contacts including 

but not limited to: (i) at least a portion of the actions complained of herein; (ii) purposefully and 

voluntarily placing one or more Accused Products into this District and into the stream of 

commerce with the intention and expectation that it will be purchased and used by customers in 

this District; or (iii) regularly doing or soliciting business, engaging in other persistent courses of 

conduct, or deriving substantial revenue from goods and services, including the Accused Products. 

11. Venue is proper in this Court pursuant to 28 U.S.C. § 1400(b) for the following 

reasons: 

12. Mobileye is registered to do business in Texas, and upon information and belief, 

Mobileye has transacted business in this District and has committed acts of direct and indirect 

infringement in this District. 

13. Since first engaging with General Motors, LLC (“GM”) in 2016, Mobileye has 

done and does extensive business with GM. GM is the subject of a related suit filed in this District 

for infringement of the Patents at issue here. Indeed, at least a portion of GM’s infringing conduct, 

including conduct in this District, arises from its purchase, use, sale and offers for sale of GM 

products containing Mobileye EyeQ3 and EyeQ4 Systems-on-Chip (SOCs) (the “Accused 

Products”). 

14. Mobileye has an ongoing relationship with Envue Telematics, Inc., located at 119 

West Tyler Street, Suite 100, Longview, Texas, through which, on information and belief, 

Mobileye provides data gathered using its infringing technology as well as the infringing 

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technology itself to enable collision avoidance and lane departure warning functionalities in 

Envue’s telematics technology. 

15. On information and belief, Mobileye is engaged in a collaboration with 

Volkswagen, Inc., to equip autonomous vehicles with Mobileye’s infringing technology and test 

them on the streets of Austin, Texas. 

16. Until October 2022, Mobileye was a wholly owned subsidiary of Intel Corporation, 

and, on information and belief, Intel still owns over 88% of Mobileye stock. Intel has a regular 

and established places of business and more than 2,000 employees in its Texas facility, located at 

1300 S MoPac Expy, Austin, Texas. 

17. Mobileye is participating in a research collaboration with Texas A&M University, 

located in College Station, Texas, to test Mobileye collision avoidance technology in vehicles on 

the Texas A&M campus. The project is being funded by the Texas Department of Transportation. 

18. Mobileye offers and tests its products and/or services, including those accused 

herein of infringement, to customers and potential customers located in Texas and in this District. 

THE ’255 PATENT 

19. Facet is the owner by assignment from the inventors, James E. Retterath and Robert 

A. Laumeyer, of all right, title, and interest in and to United States Patent No. 9,335,255 (the “’255 

Patent”) titled “System and Assessment of Reflective Objects Along a Roadway,” including the 

right to sue for all past, present, and future infringement. A true and correct copy of the ’255 Patent 

is attached to this Complaint at Exhibit A. 

20. The ’255 Patent issued from U.S. Patent Application No. 14/512,735, filed on 

October 13, 2014. 

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21. The ’255 Patent is a continuation of application No. 14/025,614, filed on September 

12, 2013. 

22. The Patent Office issued the ’255 Patent on May 10, 2016, after a full and fair 

examination. 

23. The ’255 Patent is valid and enforceable. 

24. The ’255 Patent relates to a system for classifying different types of sheeting 

materials of road signs depicted in a videostream. 

25. The inventors of the ’255 Patent identified a critical problem in identifying and 

creating an accurate inventory of road and traffic signs along a given street or highway. The patent 

addresses the challenge of providing an automated, more accurate, and more efficient system for 

cataloguing the more than 58 million road and traffic signs in the United States. 

26. The ’255 Patent provides several advantages over the prior art, such as determining 

the retroreflectivity and sheeting classification of traffic signs without the need to target individual 

signs. 

27. The ’255 Patent describes and claims a system using an automated method of 

assessing reflective surfaces along a roadway. The patent details activating a light source to 

illuminate an area that includes the reflective surface of a road marker. The patent then describes 

an intensity sensor directed to cover a field of view that includes the area illuminated by the light 

source. The patent further describes the system as including a computer processing system that is 

configured to identify a portion of the light intensity value associated with one of the reflective 

surface of the road marker and to analyze the light intensity value to determine the reflective 

characteristic of the road marker. 

28. Claim 12 of the ’255 Patent reads: 

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12. An automated method of assessing reflective surfaces disposed along a 

highway comprising: 

(a) activating a light source as the light source is traversed along a roadway to 

illuminate an area that includes at least one reflective surface on a road 

marker, the road marker having a reflective characteristic; 

(b) determining a plurality of light intensity values with at least one intensity 

sensor directed to cover a field of view which includes at least a portion of the 

area illuminated by the light source; and 

(c) using a computer processing system configured to: 

 (i) identify a portion of at least one light intensity value of the plurality of 

light intensity values associated with one of the at least one reflective 

surface of the road marker; and 

(ii) analyze the portion of the at least one light intensity value of the 

plurality of light intensity values to determine an assessment of the 

reflective characteristic of the road marker. 

THE ’328 PATENT 

29. Facet is the owner by assignment from the inventors, James E. Retterath and Robert 

A. Laumeyer, of all right, title, and interest in and to United States Patent No. 9,671,328 (“the ’328 

Patent”) titled “System and Assessment of Reflective Objects Along a Roadway,” including the 

right to sue for all past, present, and future infringement. A true and correct copy of the ’328 Patent 

is attached to this Complaint at Exhibit B. 

30. The ’328 Patent issued from U.S. Patent Application Serial No. 15/148,722, filed 

on May 6, 2016. 

31. The ’328 Patent claims the benefit of U.S. Patent Application Serial No. 

14/512,735, filed on October 13, 2014. 

32. The Patent Office issued the ’328 Patent on June 6, 2017, after a full and fair 

examination. 

33. The ’328 Patent is valid and enforceable. 

34. The ’328 Patent relates to a system for classifying different types of sheeting 

materials of road signs depicted in a videostream. 

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35. The inventors of the ’328 Patent identified a critical problem in identifying and 

creating an accurate inventory of road and traffic signs along a given street or highway. The patent 

addresses the challenge of providing an automated system for cataloguing the more than 58 million 

such road and traffic signs in the United States that is more accurate and efficient than prior 

methods of doing so. 

36. The ’328 Patent provides several advantages over the prior art, such as determining 

the retroreflectivity of a traffic sign without the need to target individual signs and automatically 

determining sheeting classification. 

37. The ’328 Patent describes and claims a specific system that involves using an 

automated system to detect and determine the reflective surfaces along a roadway. The patent 

details capturing images along the roadway, using a light sensor to illuminate the roadway and 

measure light intensity, and a computer processing system connected to the image capture system 

and light sensor that can detect objects of interest within the field of view of the light source. The 

patent further describes that the computer processing system can determine the location, whether 

the object includes a reflective surface, the retroreflectivity of the surface, and whether the 

reflective surface is a road marker. 

38. Claim 9 of the ’328 Patent reads: 

9. An automated system for assessing reflective surfaces disposed along a 

roadway comprising: 

(a) an active light sensor that is traversed along a roadway that includes at least 

one reflective surface on a road marker, the road marker having a reflective 

characteristic, the active light sensor including: 

 (i) a light source to illuminate an area that includes the at least one 

reflective surface; and 

(ii) a light sensor that measures a plurality of light intensity values within 

a field of view which includes at least a portion of the area illuminated 

by the light source and 

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 (b) a computer processing system operably connected to the active light sensor 

and configured to detect objects of interest within the field of view for each 

object of interest: 

 (i) determine whether the object of interest includes at least one light 

intensity value associated with a reflective surface of a road marker in 

the field of view; and 

(ii) analyze the at least one light intensity value to determine an 

assessment of a discrete location of the road marker within the field of 

view. 

MOBILEYE 

39. Mobileye develops, manufactures and sells advanced driver assistance (ADA) 

technologies and autonomous driving technologies. 

40. Mobileye manufactures, sells, offers to sell, uses and imports its EyeQ3 and EyeQ4 

Systems-on-Chip (SOCs), which are used in infringing systems, including in GM products that 

use Mobileye SOCs with cameras that support safety technologies such as forward collision alert 

and lane departure warning systems. Beyond GM, Mobileye sells the Accused Products to many 

of the largest vehicle manufacturers in the world. 

41. Upon information and belief, Mobileye was founded in 1999 by Prof. Amnon 

Shashua in Israel. 

42. Upon information and belief, Mobileye developed the EyeQ series of SOCs, which 

are used in various categories of driver assistance systems. 

43. Upon information and belief, Mobileye is a Tier 1 component supplier to GM, 

including the EyeQ3 and EyeQ4 SOCs, which GM uses to implement its LDW and LKA 

technologies in the infringing GM products. 

44. On information and belief, Mobileye first began engaging with GM at least as early 

as 2016. In that same year, Facet began a test project with GeoDigital (formerly Ushr and now 

DMP) for automating HD mapping per a statement of work directing that Facet would use its 

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existing tools to convert LIDAR data to pavement markings. Facet converted the GeoDigital 

LIDAR data collected from Michigan roads that GeoDigital had already used to manually create 

pavement markings in the HD maps. GM compared the HD maps derived from manually created 

pavement locations by GeoDigital with automated pavement marking locations created by Facet 

for some roads. During the course of this test project, the licensing of the Facet patents, including 

the Patents-in-Suit, was discussed on November 28, 2016 with Mary L. Mayer, PHD MBA who 

was the director of Technology Commercialization for GM. Given that Mobileye was 

collaborating with GM on related technology during that same time period, it may reasonably be 

inferred that Mobileye also had notice of the Facet patents around that same time. 

45. On February 20, 2020, counsel for Facet sent notice to GM that it was infringing 

the ’328 Patent. On March 2, 2020, David S. Willoughby, IP Counsel for GM, responded that GM 

was in receipt of Facet’s notice and that it would respond in due course. Again, because this notice 

letter implicated Mobileye’s infringing technology, it is reasonable to assume that Mobileye 

received notice of the Facet letter at or around the same time GM received it. 

46. GM sells vehicles that incorporate the EyeQ3 and EyeQ4 SOCs to implement Lane 

Keep Assist (“LKA”) and Lane Departure Warning (“LDW”) technology (the “Accused 

Products”). 

47. Automated safety technologies, such as those enabled by Mobileye SOCs in GM 

automobiles and automobiles from other manufacturers, are essential for competiveness in today’s 

vehicle marketplace. 

48. The financial gains accrued by Mobileye through the use of Facet’s patented 

technology have been substantial, providing Mobileye with competitive advantages in the market 

for ADAs. 

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49. The benefits reaped by Mobileye through the exploitation of Facet’s intellectual 

property have resulted in corresponding harm to Facet. This harm includes but is not limited to 

lost business opportunities, revenue, and diminution of the value of its patented technology. 

50. This case is filed to address and seek redress for the unauthorized use of Facet’s 

patented technology by Mobileye. 

COUNT I 

(DIRECT PATENT INFRINGEMENT OF THE ’255 PATENT) 

51. Facet repeats, realleges, and incorporates by reference, as if fully set forth herein, 

the allegations of the preceding paragraphs, as set forth above. 

52. Mobileye has made, used, offered for sale, and sold in the United States, products 

and systems that directly infringe at least Claim 12 of the ’255 Patent, including the EyeQ3 and 

EyeQ4 SOCs. 

53. The Accused Products provide a method of assessing reflective surfaces disposed 

along a highway, including, but not limited to, GM’s use of LKA and LDW systems which 

incorporate Mobileye’s EyeQ3 and EyeQ4 SOCs. 

54. The Accused Products activate a light source as the light source travels along a 

roadway to illuminate an area that includes at least one reflective surface on a road marker that has 

a reflective characteristic. The Mobileye system relies on headlights to function properly at night. 

55. The Accused Products determine a plurality of light intensity values with at least 

one intensity sensor directed to cover a field of view which includes at least a portion of the area 

illuminated by the light source. The Mobileye SOCs used in vehicles for LKA and LDW rely on 

a forward looking camera module that acts as the intensity sensor. 

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56. The Accused Products use a computer processing system. For example, as 

implemented in GM’s vehicles the Mobileye SOCs make use of electronic control units (ECUs) 

that are computer processing systems configured to perform various functions including for LKA 

and LDW. 

57. The computer processing systems of the Accused Products identify a portion of at 

least one light intensity value of the plurality of light intensity values associated with one of the at 

least one reflective surface of the road marker. For example, GM’s LKA and LDW systems use 

the Mobileye SOCs to enable GM vehicles to detect road markers at night based on reflected light 

intensity. 

58. The computer processing systems of the Accused Products analyze the portion of 

the at least one light intensity value of the plurality of light intensity values to determine an 

assessment for the reflective characteristic of the road marker. 

59. Mobileye’s infringing activities are and have been without authority or license 

under the ’255 Patent. 

60. As a direct and proximate result of Mobileye’s infringement of the ’255 Patent, 

Facet has suffered and will continue to suffer damage.. 

61. Facet is informed and believes that, through its relationship with GM (which has 

been on notice of the patents-in-suit since at least as early as 2016 and which received notice of its 

infringement by means of a letter sent in 2022), Mobileye knew or was willfully blind to the 

patented technology of the ’255 Patent. Despite this knowledge or willful blindness, Mobileye has 

acted with blatant disregard for Facet’s patent rights with an objectively high likelihood of 

infringement. 

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62. Facet is informed and believes that Mobileye has made no efforts to avoid 

infringement of the ’255 Patent, despite its knowledge and understanding that its products and 

systems infringe the ’255 Patent. 

63. Therefore, Mobileye’s infringement of the ’255 Patent is willful and egregious, 

warranting an enhancement of damages. 

64. As such, Mobileye has acted and continues to act recklessly, willfully, wantonly, 

deliberately, and egregiously in infringement of the ’255 Patent, justifying an award to Facet of 

increased damages under 35 U.S.C. § 284, and attorneys’ fees and costs incurred under 35 U.S.C. 

§ 285. 

COUNT II 

(INDUCED PATENT INFRINGEMENT OF THE ’255 PATENT) 

65. Facet repeats, realleges, and incorporates by reference, as if fully set forth herein, 

the allegations of the preceding paragraphs, as set forth above. 

66. Mobileye is liable for indirect infringement under 35 U.S.C. § 271(b) of at least one 

claim of the ’255 Patent, at least as early as the filing of this Complaint, because it knowingly 

induced, aided, and directed others to use the Accused Products in a manner that infringes the ’255 

Patent. 

67. As detailed above, Mobileye has had knowledge of Facet and its patents at least 

since receiving notice of infringement in 2020, but likely since the joint test project in 2016 

described above. 

68. Mobileye’s use of the Accused Products demonstrates specific intent to induce 

infringement of the ’255 Patent. Mobileye encouraged, directed, aided, and abetted the use and 

operation of the Accused Products in a manner that infringes the ’255 Patent. 

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69. Mobileye’s knowledge of the ’255 Patent, combined with its ongoing use of the 

Accused Products, demonstrates Mobileye’s knowledge and intent that the Accused Products be 

used in a manner that infringes the ’255 Patent. 

70. Mobileye’s actions and the manner in which the Accused Products are used in GM 

vehicles, consistent with Mobileye’s promotions and instructions, demonstrate Mobileye’s 

specific intent to induce infringement of the ’255 Patent. 

71. Facet is informed and believes that, through its relationship with GM (which has 

been on notice of the patents-in-suit since 2016 and which received notice of its infringement by 

means of a letter sent in 2020), Mobileye knew or was willfully blind to the fact that it was inducing 

others, including its customers, including but not limited to GM and its customers, other large 

vehicle manufacturers and their customers, and Mobileye’s staff, to infringe by practicing, either 

themselves or in conjunction with GM and other vehicle manufacturers, one or more claims of the 

’255 Patent. 

72. As a direct and proximate result of Mobileye’s induced infringement of the ’255 

Patent, Facet has suffered and will continue to suffer damage. 

73. Facet is entitled to recover from Mobileye compensation in the form of monetary 

damages suffered as a result of Mobileye’s infringement in an amount that cannot be less than a 

reasonable royalty, together with interest and costs as fixed by this Court. 

COUNT III 

(DIRECT PATENT INFRINGEMENT OF THE ’328 PATENT) 

74. Facet repeats, realleges, and incorporates by reference, as if fully set forth herein, 

the allegations of the preceding paragraphs, as set forth above. 

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75. Mobileye has made, used, offered for sale, and sold in the United States, products 

and systems that directly infringe at least Claim 9 of the ’328 Patent, including the EyeQ3 and 

EyeQ4 SOCs. 

76. The Accused Products provide an automated system for assessing reflective 

surfaces disposed along a roadway, including, but not limited to, in GM’s LKA and LDW systems 

which incorporate Mobileye’s EyeQ3 and EyeQ4 SOCs. 

77. For example, GM infringing products employing the Accused Products have an 

active light sensor, through use of a forward looking camera, that travels along a roadway 

containing at least one reflective surface on a road marker, the road marker having a reflective 

characteristic. 

78. The Accused Products make use of an active light sensor that includes a light source 

to illuminate an area that includes at least one reflective surface. For example, in GM’s vehicles 

implementing the Mobileye Accused Products headlights serve as a light source to illuminate an 

area that includes, for example, lane markers. 

79. In, for example, GM vehicles implementing the Mobileye Accused Products, the 

active light sensor includes a light sensor that measures a plurality of light intensity values within 

a field of view which includes at least a portion of the area illuminated by the light source. The 

active light sensor provides the measurements obtained to the Accused Products. 

80. In, for example, GM vehicles implementing the Mobileye Accused Products, the 

Accused Products comprise a computer processing system operably connected to the active light 

sensor and configured to detect objects of interest within the field of view. GM’s LKA and LDW 

systems detect objects of interest such as lane markers. 

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81. For each detected object of interest, the Accused Products determine whether the 

object of interest includes at least one light intensity value associated with a reflective surface of 

a road marker in the field of view, such as when detecting a lane marking. 

82. For each detected object of interest, the Accused Products analyze the at least one 

light intensity value to determine an assessment of a discrete location of the road marker within 

the field of view such as when determining the location of a lane marking. 

83. Mobileye has directly infringed the ’328 Patent in violation of 35 U.S.C. § 271(a) 

by making, using, offering for sale, selling, and/or operating the Accused Products that embody 

the patented inventions of at least Claim 9 of the ’328 Patent. 

84. As implemented in, for example, GM vehicles, the Accused Products satisfy each 

and every element of the asserted claim of the ’328 Patent either literally or under the doctrine of 

equivalents. 

85. Mobileye’s infringing activities are and have been without authority or license 

under the ’328 Patent. 

86. As a direct and proximate result of Mobileye’s infringement of the ’328 Patent, 

Facet has suffered and will continue to suffer damage. 

87. Facet is informed and believes that, at least through its relationship with GM (which 

has been on notice of the Asserted Patents since 2016 and received notice of its infringement by 

letter in 2020), Mobileye knew or was willfully blind to the patented technology of the ’328 Patent. 

Despite this knowledge or willful blindness, Mobileye has acted with blatant disregard for Facet’s 

patent rights with an objectively high likelihood of infringement. 

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88. Facet is informed and believes that Mobileye has made no efforts to avoid 

infringement of the ’328 Patent, despite its knowledge and understanding that its products and 

systems infringe the ’328 Patent. 

89. Therefore, Mobileye’s infringement of the ’328 Patent is willful and egregious, 

warranting an enhancement of damages. 

90. As such, Mobileye has acted and continues to act recklessly, willfully, wantonly, 

deliberately, and egregiously in infringement of the ’328 Patent, justifying an award to Facet of 

increased damages under 35 U.S.C. § 284, and attorneys’ fees and costs incurred under 35 U.S.C. 

§ 285. 

COUNT IV 

(INDUCED PATENT INFRINGEMENT OF THE ’328 PATENT) 

91. Facet repeats, realleges, and incorporates by reference, as if fully set forth herein, 

the allegations of the preceding paragraphs, as set forth above. 

92. Mobileye is liable for indirect infringement under 35 U.S.C. § 271(b) of at least one 

claim of the ’328 Patent , at least as early as the filing of this Complaint, because it knowingly 

induced, aided, and directed others to use the Accused Products in a manner that infringes the ’328 

Patent. 

93. As detailed above, on information and belief, at least through its relationship with 

GM, which has had notice of the patents since 2016 and has been on notice of its infringement 

since receiving a letter from Facet in 2020, Mobileye has had knowledge of Facet and its patents. 

At a minimum, Mobileye has had notice of Facet and its patents since the date of the filing of this 

Complaint. 

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94. Mobileye’s use of the Accused Products demonstrates specific intent to induce 

infringement of the ’328 Patent. Mobileye encouraged, directed, aided, and abetted the use and 

operation of the Accused Products, including by GM, in a manner that infringes the ’328 Patent. 

95. Mobileye’s knowledge of the ’328 Patent, combined with its ongoing use of the 

Accused Products, demonstrates Mobileye’s knowledge and intent that the Accused Products be 

used in a manner that infringes the ’328 Patent. 

96. Mobileye’s actions and the manner in which the Accused Products are used, 

consistent with Mobileye’s promotions and instructions, demonstrate Mobileye’s specific intent to 

induce infringement of the ’328 Patent. 

97. Facet is informed and believes, and on that basis alleges, that Mobileye knew or 

was willfully blind to the fact that it was inducing others, including its customers, such as GM and 

other vehicle manufacturers, and staff, to infringe by practicing, either themselves or in 

conjunction with Mobileye, one or more claims of the ’328 Patent. 

98. As a direct and proximate result of Mobileye’s induced infringement of the ’328 

Patent, Facet has suffered and will continue to suffer damage. 

99. Facet is entitled to recover from Mobileye compensation in the form of monetary 

damages suffered as a result of Mobileye’s infringement in an amount that cannot be less than a 

reasonable royalty, together with interest and costs as fixed by this Court. 

JURY DEMAND 

Facet hereby demands a trial by jury of all issues so triable pursuant to Rule 38 of the 

Federal Rules of Civil Procedure. 

PRAYER FOR RELIEF 

WHEREFORE, Facet prays for relief against Mobileye as follows: 

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(A) An entry of judgment that Mobileye has infringed and is directly infringing one or 

more claims of each of the Patents-in-Suit; 

(B) An entry of judgment that Mobileye has infringed and is indirectly infringing one 

or more claims of each of the Patents-in-Suit; 

(C) An order pursuant to 35 U.S.C. § 283 permanently enjoining Mobileye, its officers, 

agents, servants, employees, attorneys, and those persons in active concert or 

participation with it, from further acts of infringement of the Patents-in-Suit; 

(D) An entry of judgment that the Patents-in-Suit are valid and enforceable; 

(E) An order awarding damages sufficient to compensate Facet for Mobileye’s 

infringement of the Patents-in-Suit, but in no event less than a reasonable royalty, 

together with interest and costs; 

(F) A determination that Mobileye’s infringement has been willful, wanton, deliberate, 

and egregious; 

(G) A determination that the damages against Mobileye be trebled or for any other basis 

within the Court’s discretion pursuant to 35 U.S.C. § 284; 

(H) A finding that this case against Mobileye is “exceptional” and an award to Facet of 

its costs and reasonable attorneys’ fees, as provided by 35 U.S.C. § 285; 

(I) An accounting of all infringing sales and revenues of Mobileye, together with postjudgment interest and prejudgment interest from the first date of infringement of 

the ’255 Patent, and the ’328 Patent; and 

(J) Such further and other relief as the Court may deem proper and just. 

 

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Dated: January 26, 2024 Respectfully submitted, 

 /s/ Christopher E. Hanba 

Christopher E. Hanba 

Texas Bar No. 24121391 

chanba@dickinson-wright.com 

Steven R. Daniels 

Texas Bar No. 24025318 

sdaniels@dickinson-wright.com 

Joshua G. Jones 

Texas Bar No. 24065517 

jjones@dickinson-wright.com 

DICKINSON WRIGHT PLLC 

607 W. 3rd Street, Suite 2500 

Austin, Texas 78701 

Telephone: (512) 582-6889 

Facsimile: (844) 670-6009 

Ariana D. Pellegrino 

Michigan Bar No. P79104 

apellegrino@dickinson-wright.com 

DICKINSON WRIGHT PLLC 

500 Woodward Avenue, Suite 4000 

Detroit, MI 48226 

Telephone: 313-223-3500 

Attorneys for Plaintiff 

Facet Technology, Corp. 

Case 2:24-cv-00058-RWS-RSP Document 1 Filed 01/26/24 Page 19 of 19 PageID #: 19