12. Defendant has had knowledge of the ’644 Patent since at least December 6, 2013 when it submitted an Information Disclosure Statement (IDS) referencing the ’644 Patent as well as other Eyetalk patents to the United States Patent and Trademark Office during prosecution of its own patent application, which is now U.S. Patent No. 8,780,201. SkyBell similarly submitted an IDS on December 6, 2013, in another of its patent applications which referenced the ’644 Patent and is now U.S. Patent No. 8,823,795. On February 28, 2014, SkyBell submitted another IDS during prosecution of its own patent application that referenced the ’644 Patent and SkyBell’s patent application is now U.S. Patent No. 8,842,180. In another SkyBell patent application, SkyBell once again cited the ’644 Patent in an IDS filed on August 2, 2014, for a SkyBell patent application, which is now U.S. Patent No. 8,872,915. SkyBell cited the ’644 Patent in an IDS filed on November 7, 2014, for a SkyBell patent application that is now U.S. Patent No. 8,937,659. SkyBell also cited the ’644 Patent in an IDS for another of its patent applications on November 7, 2014, which became U.S. Patent No. 8,941,736. SkyBell’s co- founder, Joseph Scalisi, filed a patent application which matured into U.S. Patent No. 8,947,530 and in this application Mr. Scalisi filed an IDS listing the ’644 Patent on November 17, 2014. SkyBell, in another patent application which issued as U.S. Patent No. 8,953,040, cited the ’644 Patent in another IDS on November 7, 2014. On April 9, 2015, SkyBell cited the ‘644 patent in an IDS for its patent application, which became U.S. Patent No. 9,055,202. On April 9, 2015, SkyBell cited the ‘644 in another of its patent applications, which became U.S. Patent No. 9,058,738. On April 21, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,060,103. On April 21, 2015, SkyBell cited the ‘644ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT Page 4 of 8?Case 3:15-cv-00492 Document 1 Filed 10/14/15 Page 4 of 8
patent in an IDS for its own patent application, which became U.S. Patent No. 9,060,104. On April 21, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,065,987. On April 13, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,094,584. On January 31, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,109,378. On May 20, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,113,051. On June 3, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,113,052. On June 3, 2015, SkyBell cited the ‘644 patent in an IDS for its own patent application, which became U.S. Patent No. 9,118,819. In fact, the ’644 Patent has been repeatedly cited by either SkyBell or its co-founder Joseph Scalisi during prosecution of SkyBell’s own patents and rather than seek a license to the Eyetalk portfolio, SkyBell has chosen to willfully infringe the ’644 Patent despite having intimate knowledge of the patent during prosecution of its own patents.
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