InterDigital Inc (IDCC)

[Gamco]

SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT - filed 2/16/24
PRAYER FOR RELIEF

126. WHEREFORE, InterDigital respectfully requests that this Court enter judgment
in favor of InterDigital as follows:
(a) That Lenovo is liable for infringement, contributing to the infringement, and/or
inducing the infringement of one or more claims of the Patents-in-Suit;
(b) An award of damages adequate to compensate InterDigital for the infringement that
has occurred, pursuant to 35 U.S.C. § 284, including prejudgment and post-judgment interest;
(c) An award of enhanced damages including, without limitation, treble damages for
willful infringement pursuant to 35 U.S.C. § 284;
(d) An accounting and/or supplemental damages for all damages occurring after any
discovery cutoff and through the Court’s decision regarding the imposition of a permanent
injunction;
(e) An award of attorneys’ fees based on this being an exceptional case pursuant to 35
U.S.C. § 285, including prejudgment interest on such fees;
(f) Enter a permanent injunction against all Lenovo products found to infringe the
Patents-in-Suit;
(g) Award, in lieu of an injunction, a compulsory forward royalty;
(h) Costs and expenses in this action; and
(i) An award of any further relief that this Court deems just and proper.
Dated: February 16, 2024