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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
BEAUMONT DIVISION
PERSONAL AUDIO, LLC,

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Plaintiff,
v.
GOOGLE, INC.
Defendant.

Civil Action No. 1:15-cv-350
Jury Trial Demanded

ORIGINAL COMPLAINT
Plaintiff Personal Audio, LLC (“Personal Audio”), by and through its attorneys, for its
Complaint against Google, Inc., (herein, “Defendant” and/or “Google”) hereby alleges as follows:
I.
1.

NATURE OF THE ACTION

This is a patent infringement action to end Defendant’s contributory and/or induced

infringement of Plaintiff Personal Audio’s patented inventions.
2.

Personal Audio holds all substantial rights and interest in and to United States

Patent No. 6,199,076 (the “’076 patent”), issued on March 6, 2001, for “Audio Program Player
Including A Dynamic Program Selection Controller.”
3.

Personal Audio holds all substantial rights and interest in and to United States

Patent No. 7,509,178 entitled “Audio Program Distribution and Playback System” (“the ‘178
patent”)(together the “Asserted Patents”).
4.

Plaintiff Personal Audio seeks to prevent Defendant from continuing infringement

of Plaintiff’s patent rights.

Plaintiff Personal Audio further seeks monetary damages and

prejudgment interest for Defendant’s past infringement of the ’076 patent and the ‘178 patent.

LITIOC/2124258v1/103069-0000

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II.
5.

THE PARTIES

Plaintiff Personal Audio is a limited liability company organized and existing under

the laws of the State of Texas, with its corporate office located at 550 Fannin St., Ste. 1313,
Beaumont, TX 77701.
6.

Upon information and belief, Defendant Google, Inc. is a Delaware corporation

with its principal place of business located at 1600 Amphitheatre Parkway, Mountain View, CA
94043. Google’s registered agent for service of process is Corporation Service Company, 2710
Gateway Oaks Dr., Ste. 150N, Sacramento, CA 95833.
III.
7.

JURISDICTION AND VENUE

This is an action for patent infringement which arises under the Patent Laws of the

United States, in particular, 35 U.S.C. §§271, 281, 283, 284, and 285. This Court has jurisdiction
over the subject matter of this action under 28 U.S.C. §§1331 and 1338(a).
8.

This Court has personal jurisdiction over Defendant because it has committed acts

giving rise to this action within Texas and within this judicial district. The Court’s exercise of
jurisdiction over Defendant would not offend traditional notions of fair play and substantial justice
because Defendant has established minimum contacts with the forum. Upon information and
belief, Defendant transacts substantial business in the State of Texas and this Judicial District.
Further, Defendant has committed acts of infringement in this District, by among other things,
knowingly contributing to and/or inducing the infringement of Personal Audio’s Asserted Patents
knowing that the directly infringing devices are sold in the State of Texas and this Judicial District
as well as providing service and support to Defendant’s customers in this District.
9.

Venue in the Eastern District of Texas is proper pursuant to 28 U.S.C. §§ 139l (b),

(c) and l400(b) because Defendant has committed acts within this judicial district giving rise to
ORIGINAL COMPLAINT

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this action, and Defendant has and continue to conduct business in this judicial district, including
one or more acts of knowingly contributing to and/or inducing the infringement of Personal
Audio’s Asserted Patents knowing that the directly infringing devices are sold in the State of Texas
and this Judicial District as well as providing service and support to Defendant’s customers in this
District.
10.

Venue in the Eastern District of Texas is proper because this district is centrally

located to resolve common issues of fact among Personal Audio and Defendant.
11.

Venue in the Eastern District of Texas is proper because of judicial economy. This

Court has presided over five previous lawsuits involving the same patents at issue. Initially, the
Honorable Chief Judge Ron Clark presided over Personal Audio, LLC v. Apple Inc. et al., Civil
Action No. 9:09-CV-111 (“Apple Suit”). As part of that action, the Court has construed the claims
of the asserted ‘076 patent and the ‘178 patent in Memorandum Opinions and Orders dated
December 21, 2010 (Apple Suit, Dkt. No. 258), January 31 , 2011 (Id., Dkt. No. 292), and May
18, 2011 (Id., Dkt. No. 358).
12.

On September 9, 2011, Personal Audio filed suit against Samsung, Motorola, HTC,

and LG, which was duly assigned to the Honorable Ron Clark. Personal Audio, LLC, v. Samsung
Electronics Co., Ltd. et al, Civil Action No. 1:11-CV-00432-RC. The matter against each
defendant has since resolved.
13.

On November 22, 2011, Personal Audio filed suit against Amazon, which was duly

assigned to the Honorable Ron Clark. Personal Audio, LLC, v. Amazon Digital Services, Inc. et al,
Civil Action No. 1:11-cv-00655-RC. The matter against has since resolved.

ORIGINAL COMPLAINT

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14.

On August 13, 2013, Personal Audio filed suit against FUHU, Inc., which was also

assigned to the Honorable Ron Clark. Personal Audio, LLC, v. FUHU, Inc., Civil Action No.
1:13-cv-00513-RC. The matter has since resolved.
15.

On January 10, 2014, Personal Audio filed suit against Acer, Apollo Brands,

ASUSTek, Azpen Innovation, Barnes & Noble, Fujitsu, Huawei, Lenovo, Toshiba and ZTE, which
was also assigned to Honorable Ron Clark. Personal Audio, LLC, v. Acer, Inc., et al., Civil Action
No. 1:14-cv-00008-RC. The matter against each defendant has since resolved.
IV.

BACKGROUND
Personal Audio

16.
entrepreneur.

James Logan, the founder of Personal Audio, is a successful businessman and
In 1982, Logan founded MicroTouch Systems. Under Logan's stewardship,

MicroTouch became a leading developer of touch screen technologies used in a variety of
consumer and commercial products. When Logan founded MicroTouch, the majority of touch
screens used plastic surfaces for their contact interface.

MicroTouch was one of the first

companies to successfully manufacture and market touch screens with glass surfaces. By the mid1990s, MicroTouch was the world's leading supplier of touch screen technology. MicroTouch’s
technology became the industry standard and was widely used in retail outlets and purchased by
large companies.
17.

For fourteen years, from 1982 until 1996, Logan served as MicroTouch’s chief

executive officer (“CEO”). MicroTouch had a single employee (Logan) when Logan started the
company. By 1996, under Logan's leadership, MicroTouch employed over 600 individuals and
realized about $95 million in sales. In 2000, 3M purchased MicroTouch for approximately $160
million.
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18.

Logan is a prolific inventor. Logan is listed as an inventor or co-inventor on no

fewer than 32 United States patents.
19.

During his time at MicroTouch, Logan had to commute to work every day. Logan

became frustrated with the lack of radio listening options available during his commute. This
frustration gave Logan a new idea for presenting audio programs – an audio player for delivering
personalized audio content based on the past listening habits or selections of an individual user.
20.

In 1996, Logan resigned as CEO of MicroTouch. Thereafter he started a new

company, Personal Audio, Inc., to develop, manufacture, and sell his new idea for an audio player.
21.

From 1996 until 1998, Logan served as the president of Personal Audio, Inc. One

of the first employees he hired was Daniel Goessling. Goessling is a software developer who had
previously worked with Logan on developing a patented invention for pausing live television.
Goessling is listed as an inventor or co-inventor on no fewer than 12 United States patents.
22.

In the spring of 1996, Logan also contacted Charles Call for the purpose of

obtaining patent protection. Call is a patent attorney. Call has worked as a patent attorney for over
fifty years. As a patent attorney, Call has extensive experience with computers and computerrelated patents. Call has drafted over 500 United States patents. Call is also listed as an inventor
or co-inventor on no fewer than 12 United States patents.
‘076 Patent and ‘178 Patent
23.

By May of 1996, Call began drafting the application that became United States

Patent Application No. 08/724,813 (“the ‘813 application”), for the purpose of obtaining patent
protection for the personal audio player invention. The ‘813 application claimed, among other
things, an audio player capable of receiving navigable playlists.

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24.

On October 2, 1996, the ‘813 application was filed with the United States Patent &

Trademark Office ("PTO"). Logan, Goessling, and Call were listed as co-inventors of the ‘813
application.
25.

On March 6, 2001, the PTO issued United States Patent No. 6,199,076 (the ‘076

patent) entitled “Audio Program Player Including A Dynamic Program Selection Controller.”
26.

On February 13, 200l, Call filed United States Patent Application No. 091782,546.

(“the ‘546 application”). The ‘546 application was a division of the previously-filed ‘813
application. The ‘546 application claimed, among other inventions, an audio player capable of
downloading navigable playlists.
27.

On March 24, 2009, the PTO issued United States Patent No. 7,509,178 (the ‘178

patent) entitled “Audio Program Distribution and Playback System.”
28.

The ‘076 and ‘178 patents (collectively “the Asserted Patents”) share a common

specification.
29.

The ‘076 patent claims, among other inventions, a player that can reproduce a

selection of audio program files, and is further capable of receiving a navigable playlist. The
claimed player has the capability of using the received navigable playlist to allow a user to navigate
among the audio files identified in the playlist during playback. See ‘076 patent, 46:13-51 &
47:38-48:29.
30.

The ‘076 patent specification describes an audio program player in a variety of

hardware configurations. These hardware configurations include “an Internet server and PC client
player architecture,” “PDAs,” a “portable computer,” and a “simplified player for mobile use.” See
‘076 patent, 7:41-66.

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31.

The ‘178 patent claims, among other inventions, an audio program player capable

of downloading audio program segments and a sequencing file that specifies the playlist sequence.
The claimed player is capable of delivering a succession of audio program segments in a specified
sequence and further allows a user to navigate among the audio program segments in the playlist
sequence. See ‘178 patent, 45:60-46:33 & 48:1-49:5.
32.

The Asserted Patents’ specification describes several ways the player may store

data, including data received from outside the player and audio files. These ways include “high
speed RAM storage and a persistent mass storage device” or “replaceable media, such as an optical
disk cartridge.” See ‘076 patent, 4:33-41 & 7:63-66; ‘178 patent, 4:43-51 & 8:4-8.
33.

The Asserted Patents’ specification describes several ways that the player may

reproduce audio signals in an audible form. These ways include a “sound card,” “speakers,” and
a “headphone-out port.” See ‘076 patent, 5:22-25; ‘178 patent, 5:31-34.
34.

The Asserted Patents’ specification describes several types of controls with which

the player may accept control commands from a user. These ways include a “keyboard,” a
“'touchpad,” or “a small number of buttons.” See ‘076 patent, 5:26-29, 13:49-52 & 36:40-47; Ex.
‘178 patent, 5:35-38, 13:55-57 & 36:28-36.
35.

The Asserted Patents’ specification describes that the player may be

“advantageously implemented by… a processor.” See ‘076 patent, 4:33-41; ‘178 patent, 4:43-51.
36.

In addition to hardware components, the Asserted Patents disclose the use of

software algorithms. These software algorithms include continuously playing audio files (‘076
patent, 12:16-13:11 & 34:28-35:44; ‘178 patent, 12:27-13:16 & 34:19-35:34), detecting input
commands (‘076 patent, Fig. 3, steps 261, 262, 275, and 278; ‘178 patent, Fig 3, steps 261, 262,
275, and 278), skipping forward to the next audio file in a playlist sequence (‘076 patent, 15:21ORIGINAL COMPLAINT

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25 & 34:28-35:48; ‘076 patent, 15:25-29 & 34:19-35:37), restarting playback of the currently
playing audio file (‘076 patent, 15:49-59; ‘178 patent, 15:53-63), and skipping backward to the
previous audio file in a sequence (‘076 patent, 15:49-59 & 34:28-35:53; ‘178 patent, 5:53-63 &
34:19-35:42).
37.

Personal Audio holds all substantial rights in and to the Asserted Patents, including

all rights to recover for all past and future infringements thereof.
38.

Upon information and belief, the ‘076 patent has been cited approximately more

than 500 times by other patents and patent applications. Upon information and belief, many of
leading technology companies have cited the ‘076 patent more than once during prosecution of
their own patents, including Microsoft (approximately 40 citations), Google (approximately 2
citations), IBM (approximately 15 citations), and Sony (approximately 25 citations). Upon
information and belief, the ‘178 patent has also been cited as prior art by U.S. Patent Examiners
approximately more than 25 times during the prosecution of other patents.
Personal Audio’s Lawsuit Against Apple Inc.
39.

On June 25, 2009, Personal Audio sued Apple Inc. (“Apple”) in the Eastern District

of Texas for infringement of the ‘076 patent. Personal Audio alleged that Apple infringed the ‘076
patent by selling the iPod classic generations 1 through 6, the iPod mini generations 1 and 2, iPod
nano generations l through 5, iPod touch generations 1 through 3, iPhone, iPhone 3G, iPhone 3GS,
and iPad.
40.

The Court, the Honorable Ron Clark presiding, held a jury trial from June 23 until

July 8, 2011.
41.

During the trial, Apple asserted that claims 1, 3, and 15 of the ‘076 patent and

claims 1, 6, 13 and 14 of the ‘178 patent were invalid as anticipated or obvious. For each asserted
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claim, Apple argued that it was anticipated by the DAD486x Digital Audio Delivery System
Operation Manual (“DAD Manual”) and DAD486x Digital Audio Delivery System (“DAD
System”). Apple also argued that each of the asserted claims was rendered obvious by various
combinations of the DAD Manual, DAD System, Sound Blaster 16 User’s Guide for Windows 95,
Microsoft Windows 95 Resource Kit manual, “Architecting Personalized Delivery of Multimedia
Information” by S. Loeb, Music Shop Reference Manual, Sony Discman player and instructions,
and Sony Minidisc player and instructions.
42.

On July 8, 2011, the jury, by unanimous verdict, found that Apple infringed claims

1, 3, and 15 of the ‘076 patent by selling the iPod classic generations 3 through 6, iPod mini
generations 1 and 2, and iPod nano generations 1 through 5 in the United States. The jury awarded
damages to Personal Audio in the amount of $8,000,000.00.
43.

The jury rejected all of Apple’s invalidity arguments and found that claims 1, 3,

and 15 of the '076 patent and claims 1, 6, 13 and 14 of the ‘178 patent are not anticipated or
obvious.
44.

On August 30, 2011, the Court ordered final judgment in favor of Personal Audio

in the amount of $8,000,000.00 in damages, $4,182,331.00 in pre-judgment interest, postjudgment interest calculated at the rate of 0.11 %, and costs of courts.
45.

On January 14, 2010, Apple submitted a request for inter partes reexamination of

the ‘178 patent which the PTO granted (Control No. 95/001,295). During reexamination, the
Personal Audio v. Apple lawsuit concluded and the District Court found that Apple had failed to
carry its burden of establishing invalidity of the ‘178 patent claims. The District Court’s decision
became final and, as a result, the PTO terminated the reexamination proceedings pursuant to 35
U.S.C. §317(b). All of the ‘178 patent’s claims remain valid and enforceable.
ORIGINAL COMPLAINT

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46.

On March 17, 2011, Apple submitted a request for ex parte reexamination of

Claims 1-3 and 14-15 the ‘076 patent which the PTO granted (Control No. 90/011,579). The PTO
confirmed the patentability of Claims 1-3 and 14-15 and rejected Apple’s position that prior art
rendered the ‘076 patent claims invalid or obvious. The PTO issued a Certificate of Reexamination
for the ‘076 patent on November 30, 2012.
Google’s Acts of Infringement
47.

Personal Audio restates and realleges each of the allegations set forth above and

incorporates them herein.
48.

Upon information and belief, Google manufactures, uses, offers and/or sells

products and services including, but not limited to its Google Play Music available as a mobile and
tablet application, which constitutes a material part of the inventions in the Asserted Patents and
which, in combination with a hardware device, such as a smartphone or tablet, infringe the
Asserted Patents. Further, upon information and belief, Google knows its Google Play Music is
especially made or especially adapted for use in an infringement of the Asserted Patents and not a
staple article or commodity of commerce suitable for substantial non-infringing use.
49.

Upon information and belief, Google’s Play Music is offered in conjunction with

its Android operating system, and has been incorporated across a multitude of tablets and
smartphones that infringe the Asserted Patents.
50.

Upon information and belief, Google has been and continues to indirectly infringe

the Asserted Patents in the State of Texas within the judicial district, and elsewhere in the United
States, by, among other things, at least, without Plaintiff’s authority, inducing and/or contributing
to third parties, including without limitation customers, device manufacturers, resellers and/or end
users of Google Play Music, infringement of the claims of Plaintiff’s patents.
ORIGINAL COMPLAINT

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51.

Upon information and belief, direct infringement of the Asserted Patents is the

result of third parties incorporating Google Play Music into their hardware devices. By way of
example and based upon information and belief, infringing audio player devices are capable of
playing a sequence of selected audio program segments or files (i.e. playlists), and accepting
commands from the user to skip forward and backward in the sequence. Upon information and
belief, said audio player devices utilize “Google’s Play Music,” on the device to play and control
the sequence of selected audio program segments. Upon information and belief, by using Google
Play Music, the devices at least have the capability to continuously play a playlist of selected audio
files without input of a user command; detect a user command to skip forward or backward in the
playing playlist sequence; and respond to a command to skip forward by discontinuing playback
of the playing audio file and begin playback of the next audio file in the playlist sequence. Further,
upon information and belief, by way of a wireless communications port, such exemplar devices
are capable of establishing a data communications link for downloading and receiving a plurality
of selected audio program files and a sequencing file that specifics the playlist sequence using
Google Play Music.
52.

Upon information and belief, Google provides, makes, sells, and offers Google Play

Music with the specific intention that the third party direct infringers use the product in their
branded devices. Upon information and belief, Google provides and instructs third parties to use
the aforementioned product in the manner claimed in the Asserted Patents. Upon information and
belief, Google Play Music has no substantial non-infringing uses and is especially made and/or
adapted so as to be used in audio player devices, so as to infringe the Asserted Patents.
53.

On approximately September 19, 2012, Plaintiff gave notice to Google of Plaintiff’s

rights in the Asserted Patents via written correspondence. Upon information and belief, Google
ORIGINAL COMPLAINT

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has had notice and actual knowledge of Plaintiff’s rights in the Asserted Patents sent at least
September 19, 2012. Notwithstanding, Google continues to willfully infringe upon and cause
others to infringe upon one or more claims of the Asserted Patents.
COUNT ONE
PATENT INFRINGEMENT—U.S. PATENT NO. 6,199,076
54.

Personal Audio restates and realleges each of the allegations set forth above and

incorporates them herein.
55.

Defendant indirectly infringes the ‘076 patent by inducing or contributing to the

infringement of the ‘076 patent in violation of 35 U.S.C. § 271(b)-(c)&(f), including by its
customers/consumers.
56.

Defendant does not have a license or permission to use the claimed subject matter

in the ‘076 patent.
57.

As a direct and proximate result of Defendant’s induced and/or contributory

infringement of the ‘076 patent, Personal Audio has been injured and has been caused significant
financial damage.
58.

Defendant’s aforementioned acts have caused damage to Personal Audio and will

continue to do so unless and until enjoined.
59.

Personal Audio alleges upon information and belief that Defendant has, knowingly

or with willful blindness, willfully infringed one or more claims of the ‘076 patent. Defendant had
knowledge of the Accused Patents as alleged above, having been advised of the existence and
substance of the Accused Patents by the United States Patent & Trademark Office and Personal
Audio. Defendant acted with knowledge of the Accused Patents and, despite its knowledge or

ORIGINAL COMPLAINT

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despite that it should have known of an objectively high likelihood that its actions constituted
infringement of Personal Audio’s valid patent rights, continue to infringe.
60.

This objectively-defined risk was either known or so obvious that it should have

been known to Defendant. Personal Audio seeks enhanced damages pursuant to 35 U.S.C. § 284
from Defendant.
COUNT TWO
PATENT INFRINGEMENT—U.S. PATENT NO. 7,509,178
61.

Personal Audio restates and realleges each of the allegations set forth above and

incorporates them herein.
62.

Defendant indirectly infringes the ‘178 patent by inducing or contributing to the

infringement of the ‘178 patent in violation of 35 U.S.C. § 271(b)-(c)&(f), including by its
customers/consumers.
63.

Defendant does not have a license or permission to use the claimed subject matter

in the ‘178 patent.
64.

As a direct and proximate result of Defendant’s induced and/or contributory

infringement of the ‘178 patent, Personal Audio has been injured and has been caused significant
financial damage.
65.

Defendant’s aforementioned acts have caused damage to Personal Audio and will

continue to do so unless and until enjoined.
66.

Personal Audio alleges upon information and belief that Defendant has, knowingly

or with willful blindness, willfully infringed one or more claims of the ‘178 patent. Defendant had
knowledge of the Accused Patents as alleged above, having been advised of the existence and
substance of the Accused Patents by Personal Audio. Defendant acted with knowledge of the
ORIGINAL COMPLAINT

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Accused Patents and, despite its knowledge or despite that it should have known of an objectively
high likelihood that its actions constituted infringement of Personal Audio’s valid patent rights,
continue to infringe.
67.

This objectively-defined risk was either known or so obvious that it should have

been known to Defendant. Personal Audio seeks enhanced damages pursuant to 35 U.S.C. § 284
from Defendant.
VII.
68.

JURY DEMAND

Plaintiff hereby demands a jury on all issues so triable.
VIII. REQUEST FOR RELIEF

WHEREFORE, Plaintiff Personal Audio respectfully requests that the Court:
A.

Enter judgment that Defendant contributes to or induces others to
infringe one or more claims of the Accused Patents literally and/or
under the doctrine of equivalents;

B.

Permanently enjoin Defendant, their agents, servants, and
employees, and all those in privity with Defendant or in active
concert and participation with Defendant, from engaging in acts of
infringement of the Accused Patents;

C.

Award Plaintiff past and future damages together with prejudgment
and post-judgment interest to compensate for the infringement by
Defendant of the Accused Patents in accordance with 35 U.S.C.
§284, and increase such award by up to three times the amount found
or assessed in accordance with 35 U.S.C. §284;

D.

Award Plaintiff its costs, disbursements, attorneys’ fees;

E.

Award Plaintiff prejudgment and post-judgment interest to the
maximum extent provided under the law; and

F.

Award Plaintiff such further and additional relief as is deemed
appropriate by this Court.

ORIGINAL COMPLAINT

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Respectfully submitted,
Dated: September 15, 2015

By: /s/ William M. Parrish
William M. Parrish
Lead Attorney
Texas State Bar No. 15540325
bparrish@dpelaw.com
Nicole E. Glauser
Texas State Bar No. 24050694
nglauser@dpelaw.com
John D. Saba Jr.
Texas State Bar No. 24037415
jsaba@dpelaw.com
DiNovo Price Ellwanger & Hardy LLP
7000 N. MoPac Expressway, Suite 350
Austin, Texas 78731
Telephone: (512) 539-2626
Telecopier: (512) 539-2627
Charles W. Goehringer, Jr.
Texas State Bar No. 00793817
Germer PLLC
P.O. Box 4915
Beaumont, Texas 77704
Telephone: (409) 654-6700
Telecopier: (409) 835-2115
ATTORNEYS FOR PLAINTIFF
PERSONAL AUDIO, LLC

ORIGINAL COMPLAINT

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