Eyetalk back in court with skybell 10/3/2016
4. Eyetalk’s patent portfolio is seminal intellectual property in the field of entryway
management including inventions related to video doorbell technology. Some of the largest
Case 3:16-cv-00702 Document 1 Filed 10/03/16 Page 1 of 10
COMPLAINT FOR PATENT INFRINGEMENT Page 2 of 10
companies in the entryway management industry have taken licenses to Eyetalk’s patent
portfolio without litigation. Eyetalk’s notable licensees include The Chamberlain Group, Inc.,
HeathCo, LLC, and Bot Home Automation, Inc.—makers of the “Ring” video doorbell. These
companies and Eyetalk worked together to license Eyetalk’s portfolio without the need for
wasteful litigation. These companies should be commended for appreciating the patent rights of
others and licensing the Eyetalk patent portfolio in order to ensure a freedom to operate in the
space. Thus, there is no doubt that Eyetalk’s patent portfolio includes pioneering inventions
related to the entryway management industry. Upon information and belief, the Defendant in this
matter has adopted an approach known as “efficient infringement” whereby—despite its own
patents citing to Eyetalk’s patent portfolio over 40 times and its undisputed knowledge of the
patent-in-suit—Defendant would rather keep infringing the seminal intellectual property owned
by Eyetalk without taking a license and force Eyetalk to bring this case to the Court. Thus,
despite the largest companies in the industry taking a license to Eyetalk’s portfolio and
Defendant’s precise knowledge of Eyetalk’s patent portfolio, Defendant has decided to adopt an
approach that completely ignores Eyetalk’s intellectual property rights. These These companies should be commended for appreciating the patent rights of
others and licensing the Eyetalk patent portfolio in order to ensure a freedom to operate in the
space. Thus, there is no doubt that Eyetalk’s patent portfolio includes pioneering inventions
related to the entryway management industry. Upon information and belief, the Defendant in this
matter has adopted an approach known as “efficient infringement” whereby—despite its own
patents citing to Eyetalk’s patent portfolio over 40 times and its undisputed knowledge of the
patent-in-suit—Defendant would rather keep infringing the seminal intellectual property owned
by Eyetalk without taking a license and force Eyetalk to bring this case to the Court. Thus,
despite the largest companies in the industry taking a license to Eyetalk’s portfolio and
Defendant’s precise knowledge of Eyetalk’s patent portfolio, Defendant has decided to adopt an
approach that completely ignores Eyetalk’s intellectual property rights. These actions will no
These companies should be commended for appreciating the patent rights of
others and licensing the Eyetalk patent portfolio in order to ensure a freedom to operate in the
space. Thus, there is no doubt that Eyetalk’s patent portfolio includes pioneering inventions
related to the entryway management industry. Upon information and belief, the Defendant in this
matter has adopted an approach known as “efficient infringement” whereby—despite its own
patents citing to Eyetalk’s patent portfolio over 40 times and its undisputed knowledge of the
patent-in-suit—Defendant would rather keep infringing the seminal intellectual property owned
by Eyetalk without taking a license and force Eyetalk to bring this case to the Court. Thus,
despite the largest companies in the industry taking a license to Eyetalk’s portfolio and
Defendant’s precise knowledge of Eyetalk’s patent portfolio, Defendant has decided to adopt an
approach that completely ignores Eyetalk’s intellectual property rights. These actions will no These companies should be commended for appreciating the patent rights of
others and licensing the Eyetalk patent portfolio in order to ensure a freedom to operate in the
space. Thus, there is no doubt that Eyetalk’s patent portfolio includes pioneering inventions
related to the entryway management industry. Upon information and belief, the Defendant in this
matter has adopted an approach known as “efficient infringement” whereby—despite its own
patents citing to Eyetalk’s patent portfolio over 40 times and its undisputed knowledge of the
patent-in-suit—Defendant would rather keep infringing the seminal intellectual property owned
by Eyetalk without taking a license and force Eyetalk to bring this case to the Court. Thus,
despite the largest companies in the industry taking a license to Eyetalk’s portfolio and
Defendant’s precise knowledge of Eyetalk’s patent portfolio, Defendant has decided to adopt an
approach that completely ignores Eyetalk’s intellectual property rights. These actions will no
