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1 SIDLEY AUSTIN LLP JEFFREY M. OLSON (SBN 104074) 2 [email protected] THEODORE W. CHANDLER (SBN 219456) 3 [email protected] CLARENCE A. ROWLAND (SBN 285409) 4 [email protected] 555 West Fifth Street, Suite 4000 5 Los Angeles, California 90013 Telephone: (213) 896-6000 6 Facsimile: (213) 896-6600

7 Attorneys for Plaintiffs CORPORATION, 8 ELECTRIC CO., LTD., WARNER BROS. HOME ENTERTAINMENT INC. and 9 CORPORATION

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11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 PANASONIC CORPORATION, ) Case No. SANYO ELECTRIC CO., LTD., ) 14 WARNER BROS. HOME ) ENTERTAINMENT INC. and ) COMPLAINT FOR PATENT 15 MITSUBISHI ELECTRIC ) INFRINGEMENT AND JURY CORPORATION, ) DEMAND 16 ) Plaintiffs, ) 17 ) v. ) 18 ) ENCORE MEDIA SERVICES, INC.; ) 19 DVD FACTORY, INC.; DAVENPORT ) INTERNATIONAL CORP.; M. ) 20 MORRIS, INC., individually and doing ) business as BARRACUDA ) 21 ENTERTAINMENT, CABALLERO ) INTERNATIONAL, CABALLERO ) 22 VIDEO, and CABALLERO ) INTERNATIONAL VIDEO, INC.; ) 23 RODAX DISTRIBUTORS, INC.; 6480 ) CORPORATION; MAX MORRIS ) 24 ENTERPRISES, LLC; DANIEL ) MAMANE; GEROLD POOL and ) 25 TOMER YOFFE, ) ) 26 Defendants. ) ) 27

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1 Plaintiffs Panasonic Corporation (formerly known as Matsushita Electric 2 Industrial Co., Ltd.) (“Panasonic”), SANYO Electric Co., Ltd. (“SANYO”), Warner 3 Bros. Home Entertainment Inc. (“Warner Bros.”) and Mitsubishi Electric 4 Corporation (alternatively named Mitsubishi Denki Kabushiki Kaisha) 5 (“Mitsubishi”), by their undersigned attorneys, for their complaint against 6 Defendants Encore Media Services, Inc. (“Encore”); DVD Factory, Inc. (“DVD 7 Factory”); Davenport International Corp. (“Davenport”); M. Morris, Inc., 8 individually and doing business as Barracuda Entertainment, Caballero International, 9 Caballero Video, and Caballero International Video, Inc. (“MMI”); Rodax 10 Distributors, Inc. (“Rodax”); 6480 Corporation (“6480 Corp.”); Max Morris 11 Enterprises, LLC (“MME”); Daniel Mamane (“Mamane”); Gerold Pool (“Pool”) and 12 Tomer Yoffe (“Yoffe”) (collectively hereinafter “Defendants”) allege as follows: 13 PARTIES 14 1. Plaintiff Panasonic is a Japanese corporation, having its principal place 15 of business in Osaka, Japan. Panasonic owns patents that are the subject of this 16 complaint. 17 2. Plaintiff SANYO is a Japanese corporation, having its principal place of 18 business in Osaka, Japan. SANYO owns patents that are the subject of this 19 complaint. 20 3. Plaintiff Warner Bros. is a Delaware corporation, having its principal 21 place of business in Burbank, California. Warner Bros. owns patents that are the 22 subject of this complaint. 23 4. Plaintiff Mitsubishi is a Japanese corporation, having its principal place 24 of business in Tokyo, Japan. Mitsubishi owns patents that are the subject of this 25 complaint. 26 5. Defendant Encore, upon information and belief, is a California 27 corporation, incorporated on January 23, 2012, with a principal place of business at 28 24853 Avenue Rockefeller, Valencia, California 91355.

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1 6. Defendant DVD Factory, upon information and belief, is a California 2 corporation, incorporated on January 4, 2011, with a principal place of business at 3 7230 Coldwater Canyon Avenue, North Hollywood, California 91605. 4 7. Defendant Davenport, upon information and belief, is a New York 5 corporation, incorporated on May 20, 1993, with a principal place of business at 6 7230 Coldwater Canyon Avenue, North Hollywood, California 91605. 7 8. Defendant MMI, upon information and belief, is a California 8 corporation, incorporated on December 24, 2002, with a principal place of business 9 at 7230 Coldwater Canyon Avenue, North Hollywood, California 91605. 10 9. On information and belief, Defendant MMI filed in Los Angeles 11 County a Fictitious Business Name Statement for Caballero Video on March 22, 12 2012, and filed in Los Angeles County a Fictitious Business Name Statement for 13 Barracuda Entertainment and for Caballero International on June 11, 2014, and also 14 has used and/or is using the fictitious business name Caballero International Video, 15 Inc. 16 10. Defendant Rodax, upon information and belief, is a California 17 corporation, incorporated on October 17, 1991, with a principal place of business at 18 7230 Coldwater Canyon Avenue, North Hollywood, California 91605. 19 11. Defendant 6480 Corp., upon information and belief, is a California 20 corporation, incorporated on September 4, 1992, with a principal place of business at 21 7230 Coldwater Canyon Avenue, North Hollywood, California 91605. 22 12. Defendant MME, upon information and belief, is a California domestic 23 LLC, formed on December 9, 2002, with a principal place of business at 7230 24 Coldwater Canyon Avenue, North Hollywood, California 91605. 25 13. Upon information and belief, Defendant Mamane, also variously known 26 as Danny Mann and Max Morris, is the President of Defendants DVD Factory and 27 6480 Corp., and controls the day-to-day operations of each. 28

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1 14. Upon information and belief, Defendant Pool is the President of 2 Defendant Encore, and controls its day-to-day operations. In addition, upon 3 information and belief, Defendant Poole has held himself out as a “Records 4 Custodian” for some or all of the that are the subject of this complaint, 5 including identifying the address of 7230 Coldwater Canyon Avenue, North 6 Hollywood, California 91605 as the location of the records. 7 15. Upon information and belief, Defendant Yoffe is the President of 8 Defendants Davenport, MMI and Rodax, and controls the day-to-day operations of 9 each. 10 16. Defendants Encore, DVD Factory, Davenport, MMI, Rodax, 6480 11 Corp. and MME are the agents, subsidiaries and/or alter egos, and are under the 12 control of Mamane, Pool and/or Yoffe and of each other. 13 17. On information and belief, individually and/or collectively, Defendants 14 Encore, DVD Factory, Davenport, MMI, Rodax, 6480 Corp., MME, Mamane, Pool 15 and/or Yoffe direct and control all steps in the production, manufacture, marketing, 16 distribution and first sale of some or all of the DVDs that are subject of this 17 complaint, presenting common factual and legal questions as to each and every 18 Defendant that are best resolved in the same legal proceeding, and as further 19 described hereinafter. 20 JURISDICTION AND VENUE 21 18. This is an action for patent infringement arising under the Patent 22 Laws of the United States, United States Code, Title 35, § 1, et seq. 23 19. The Court has jurisdiction over the subject matter of this action 24 pursuant to 28 U.S.C. §§ 1331 and 1338(a). 25 20. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b), (c), 26 and (d), and 1400(b) because Defendants reside in this district, have committed acts 27 of direct and indirect infringement in this District, have a regular and established 28 place of business in this District, and have transacted business in this District,

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1 including making, using, offering to sell, selling and/or having sold DVDs, which 2 infringe the patents-in-suit. 3 21. Personal jurisdiction exists generally over each of the Defendants 4 because each Defendant has sufficient minimum contacts with the forum as a result 5 of their residences and because of business conducted within this State and District. 6 Personal jurisdiction also exists specifically over each of the Defendants because 7 each, directly or through affiliates, subsidiaries or intermediaries, transacts business 8 in this District including making, using, offering to sell, selling and/or having sold 9 DVDs within this State and District, which infringe the patents-in-suit. 10 PATENTS-IN-SUIT 11 22. United States Patent No. 5,463,565, entitled “Data Block Format For 12 Software Carrier And Player Therefor” (hereinafter, “the ‘ 565 patent”) was duly 13 and legally issued on October 31, 1995. A copy of the ‘565 patent is attached hereto 14 as Exhibit 1. 15 23. United States Patent No. 5,790,487, entitled “Optical Information 16 Recording Medium, Optical Information Recording Method, And Optical 17 Information Reproducing Apparatus Utilizing The Same” (hereinafter, “the ‘ 487 18 patent”) was duly and legally issued on August 4, 1998. A copy of the ‘487 patent 19 is attached hereto as Exhibit 2. 20 24. United States Patent No. 5,838,657, entitled “High Density Optical 21 Disc And Optical Disc Player” (hereinafter, “the ‘ 657 patent”) was duly and 22 legally issued on November 17, 1998. A copy of the ‘657 patent is attached hereto 23 as Exhibit 3. 24 25. United States Patent No. 5,881,032, entitled “Optical Disk, And Optical 25 Disk Reproduction Method And Apparatus Implementing A Mathematical 26 Complementary Relationship For Plural Layers” (hereinafter, “the ’032 patent”) 27 was duly and legally issued on March 9, 1999. A copy of the ‘032 patent is 28 attached hereto as Exhibit 4.

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1 26. United States Patent No. 5,896,367, entitled “High Density Optical 2 Disc And Optical Disc Player” (hereinafter, “the ‘ 367 patent”) was duly and 3 legally issued on April 20, 1999. A copy of the ‘367 patent is attached hereto as 4 Exhibit 5. 5 27. United States Patent No. 6,526,221, entitled “Data Structure 6 Representing Both Program And Command Data” (hereinafter, “the ‘ 221 patent”) 7 was duly and legally issued on February 25, 2003. A copy of the ‘221 patent is 8 attached hereto as Exhibit 6. 9 28. United States Patent No. 6,539,164, entitled “Disk Media, And Method 10 Of And Device For Playing Back Information On Or From A Disk Media” 11 (hereinafter, “the ‘ 164 patent”) was duly and legally issued on March 25, 2003. A 12 copy of the ‘ 164 patent is attached hereto as Exhibit 7. 13 29. United States Patent No. 6,549,717, entitled “Digital Video Signal 14 Record And Playback Device And Method For Giving Priority To A Center Of An I 15 Frame” (hereinafter, “the ‘717 patent”) was duly and legally issued on April 15, 16 2003. A copy of the ‘ 717 patent is attached hereto as Exhibit 8. 17 THE DVD-VIDEO FORMAT AND THE DVD FORUM 18 30. A DVD is a video, audio and data storage medium, which can be used 19 for viewing a complete movie on a single disc and for viewing and listening to other 20 visual and audio information and entertainment. 21 31. The DVD Forum is an international association of hardware 22 manufacturers, software firms, content providers and other users of DVDs. The 23 DVD Forum was founded in August 1997, to assume and extend the work of the 24 DVD Consortium, the ten-company organization that initially developed the DVD 25 specifications. The functions of the DVD Forum include defining and improving 26 DVD specifications, publishing reference materials, creating DVD Standard Format 27 books, approving DVD verification programs, and holding worldwide DVD 28 conferences and promoting information about DVDs, including on the DVD Forum

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1 web site. DVD Forum membership is open to any corporation or organization which 2 is engaged in activities related to DVD research, development and/or manufacturing. 3 The DVD Forum membership includes more than 100 companies worldwide. The 4 work of the DVD Forum always has been and continues to be well-publicized in the 5 DVD community. 6 32. DVD-Video is a DVD Standard Format used to store digital video on 7 DVD discs that is supported by the DVD Forum. It was conceived and designed to 8 overcome the technological limitations of pre-existing formats. The participating 9 entities in the DVD Forum established the DVD-Video format by preparing and 10 agreeing to the DVD Specifications for Read-Only Disc (“DVD Specifications”). 11 The DVD Specifications have been compiled and published in multiple volumes, 12 updated over time, and include: Part 1 – Physical Specifications, Part 2 – File 13 System Specifications and Part 3 – Video Specifications. 14 33. By implementing the DVD Specifications, DVDs provide the consumer 15 with a multitude of benefits. These include (i) video of superior quality to previous 16 home video formats, (ii) storing, on a single side, up to 13 times the amount of data 17 contained on a compact disc (“CD”), (iii) not deteriorating from multiple plays or 18 over time, (iv) remaining unaffected by magnetic fields, and (v) not requiring 19 rewinding after viewing. At an average bit rate of 4.5 Mbit/s, a single sided, single 20 layered DVD disc has the playback capability of 133 minutes of high quality video 21 images. 22 34. The universal acceptance of the DVD Specifications allows all DVDs 23 that comply with the Specifications to play on all similarly compliant DVD players. 24 Moreover, the DVD Specifications, including those portions of the DVD 25 Specifications that relate to the Plaintiffs’ inventions, enabled an entire industry of 26 DVD disc production. Without the work of the DVD Forum over many years and 27 the Plaintiffs’ valuable and important patented inventions that contributed to the 28

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1 existence and development of the DVD Specifications, Defendants’ DVD businesses 2 would not exist. 3 DVD6C LICENSING GROUP 4 35. DVD6C Licensing Group (“DVD6C”) is the name given to an 5 undertaking by nine leading developers of DVD technologies and formats. The nine 6 members of DVD6C – Consumer Electronics Co., Ltd., JVC KENWOOD 7 Corporation, Samsung Electronics Co., Ltd., and 8 Corporation, in addition to plaintiffs Panasonic, SANYO, Warner Bros. and 9 Mitsubishi – collectively own hundreds of essential patents, as further described 10 hereinafter, pertaining to various categories of DVD related products (“essential 11 DVD Patents”). DVD6C offers one-stop shopping for licensing the essential DVD 12 Patents within various categories of DVD related products, including the categories 13 identified as “DVD-ROM Disc” and “DVD-Video Disc.” On information and 14 belief, DVD discs within the categories of DVD-ROM Discs and DVD-Video Discs 15 are made and sold by Defendants. 16 36. The United States Department of Justice Antitrust Division (“DOJ”) has 17 stated that a patent pool “may provide competitive benefits by integrating 18 complementary technologies, reducing transaction costs, clearing blocking positions, 19 and avoiding costly infringement litigation.” Prior to DVD6C commencing its 20 licensing program, the DOJ stated in a Business Review Letter issued to members of 21 DVD6C that “the proposed [pooling] arrangement [of DVD6C] is likely to combine 22 complementary patent rights, thereby lowering the costs of manufactures that need 23 access to them in order to produce discs, players and decoders in conformity with 24 the DVD-Video and DVD-ROM formats.” 25 37. In accordance with the pooling arrangement of DVD6C, an impartial 26 and independent patent expert has determined which DVD related patents are 27 essential (either technically or as a practical matter) to the manufacture and use of 28 products in accordance with the DVD Specifications. These patents identified by

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1 the expert – essential DVD Patents – include patents within the categories of DVD- 2 ROM Discs and DVD-Video Discs (“the essential DVD-ROM and DVD-Video Disc 3 Patents”). Those who replicate and sell DVDs, such as the Defendants, cannot as a 4 practical matter produce or sell a DVD disc that complies with the relevant portion 5 of the DVD Specifications without directly and/or indirectly infringing the essential 6 DVD-ROM and DVD-Video Disc Patents. This complaint is limited to eight such 7 essential DVD-ROM and DVD-Video Disc Patents for purposes of management and 8 convenience. 9 38. Toshiba acts as licensing agent under the authority of the members of 10 DVD6C, and is the contracting party with licensees of the DVD6C patents. Under 11 such licenses, licensees received a non-exclusive, non-transferable license to make, 12 have made, use, import, offer for sale, sell, and otherwise dispose of licensed 13 products including DVD-ROM Discs and DVD-Video Discs. There are numerous 14 participants in the DVD industry, including those who compete with Defendants, 15 who have recognized both the value of Plaintiffs’ inventions and the need to respect 16 intellectual property rights. As a result, Toshiba has entered into hundreds of 17 licenses with such competitors on a non-discriminatory basis and Toshiba has 18 enforced these licenses from time to time by filing litigation to pursue claims for 19 breach of these licenses. These non-party licensees comply with their licensing 20 obligations and compete fairly by paying the royalties owed under their licenses for 21 their use of the DVD6C patents. Contrary to these non-party licensees, Defendants, 22 without any license, have used and continue to use Plaintiffs’ intellectual property, 23 for which they have paid no royalties, and thus have an unfair competitive advantage 24 over compliant non-party licensees. 25 39. The pooling of the essential DVD Patents combined with DVD6C’s 26 licensing program offers a fair, efficient and cost-effective means to be licensed and, 27 therefore, to avoid infringement of the essential DVD Patents. In particular, Toshiba 28 offers, as the contracting party, a pool license to the essential DVD Patents presently

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1 owned, or that may in the future be owned, by the nine members of DVD6C on fair, 2 reasonable and nondiscriminatory terms. But for the DVD6C licensing program, 3 licensees would have to negotiate and enter into multiple bilateral licenses resulting 4 in substantial transactional costs and royalty rates, which would potentially be far 5 greater than the DVD6C pool license. These multiple benefits to licensors and 6 licensees of the DVD6C pool license are not present when litigation is required to 7 address infringement by those who refuse to honor their intellectual property 8 obligations. 9 40. In addition to licensing its patents in the DVD6C licensing program, 10 Panasonic has committed to individually license its essential DVD Patents, SANYO 11 has committed to individually license its essential DVD Patents, Warner Bros. has 12 committed to individually license its essential DVD Patents and Mitsubishi has 13 committed to individually license its essential DVD Patents; each on fair, reasonable 14 and nondiscriminatory terms. 15 THE WILLFUL INFRINGEMENT BY DEFENDANTS 16 41. Under the authorization of the members of DVD6C, Panasonic is the 17 regional contact in the United States to communicate with actual and potential 18 infringers and inform them regarding the need for and benefit of a license to the 19 essential DVD Patents. 20 42. In good faith and demonstrating considerable patience, Panasonic has 21 communicated either directly with each of the Defendants, or indirectly through 22 common directors, officers and/or employees, and thereby given Defendants written 23 notice of its infringement, provided information relating to the infringement, and has 24 presented terms for licensing the essential DVD Patents on several occasions during 25 the last several years. These overtures have been made to directly to Mamane, Pool 26 and Yoffe, including immediately before this complaint was filed and previously, 27 and directly or indirectly to the companies they own and/or control. As part of these 28 communications, Panasonic has offered to meet with Defendants to answer any of

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1 their questions and discuss Defendants’ license obligations. Panasonic has 2 specifically identified to Defendants the website http://www.dvd6cla.com/, where 3 more information might be found regarding the essential DVD Patents, including the 4 patents-in-suit, and licensing obligations. 5 43. The DVD6C website provides several categories of useful information 6 regarding the essential DVD Patents to actual and potential licensees, including 7 News, License Agreements, Royalty Rates, Offer Letters, Patent List, Essentiality 8 Report, Patent Catalogue, Licensors, Licensee List, Frequently Asked Questions and 9 Contact Information. The News section provides various press releases by DVD6C. 10 The License Agreements section provides access to the DVD Patent License 11 Agreement. The Royalty Rates section provides the current royalty rates applicable 12 to new licensees, separated into various categories of products. The Offer Letters 13 section provides the letter sent to potential licensees. The Patent List section sets 14 forth the essential DVD Patents, including the patents-in-suit, separated into various 15 categories of products. The Essentiality Report section, which is further described 16 below, provides Summary Reports of the essential DVD Patents, including the 17 patents-in-suit, which have been evaluated by the impartial and independent patent 18 expert and determined to be essential in implementing the DVD Specifications. The 19 Patent Catalogue section identifies exemplary patents for various categories of 20 products. The Licensors section provides the names of the DVD6C members, which 21 then can be contacted if a prospective licensee elects to pursue individual license 22 negotiations. The Licensee List section provides the names of each of the licensees 23 and the licensed products for each licensee. The Frequently Asked Questions 24 section provides responses to various common questions. The Contact Information 25 section identifies representatives and contact information for each of the DVD6C 26 members, and also includes a template that can be filled out for making inquiries to 27 DVD6C. By the clicks of a computer mouse, all of this information was available to 28 Defendants.

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1 44. The Essentiality Report section assists potential licensees that are 2 making, using, offering to sell, selling and/or importing DVDs within the United 3 States in determining the relevancy of the essential DVD Patents, by providing 4 twenty-six Summary Reports of essential DVD Patents, which are separated by 5 product category. Two of these Summary Reports are for the essential DVD-ROM 6 and DVD-Video Disc Patents. Each of these Summary Reports provides the names 7 of the entities that own one or more essential patent within the category, an 8 identification of the patent number for each essential DVD Patent owned by that 9 entity, an identification of some or all of the foreign counterparts for each patent, an 10 identification of one or more representative claims for each patent, and a specific 11 identification of the relevant pages, sections, figures and tables of the DVD 12 Specifications for each representative claim. A Summary Report for each of the 13 patents-in-suit was provided in the Essentiality Report section of the DVD6C 14 website. 15 45. As a result of all of the foregoing, actual notice has been provided to 16 Defendants regarding their infringement of the essential DVD Patents including each 17 of the patents-in-suit. 18 46. Notwithstanding the efforts undertaken by DVD6C, no Defendant has 19 taken a license, or even negotiated to take a license, to any of the essential DVD 20 Patents. Nevertheless, Defendants have advertised and sold and continue to 21 advertise for sale and sell DVD discs that infringe the essential DVD Patents, 22 including the patents-in-suit. 23 47. Defendants have directly infringed some or all of the essential DVD 24 Patents, including the patents-in-suit, identified hereinafter, by making, using, 25 offering to sell, selling, having sold and/or importing DVDs within the United States 26 and/or have indirectly infringed these patents because DVDs made in accordance 27 with the DVD Specifications, have no substantial non-infringing use, and are known 28 by Defendants to be especially made and/or especially adapted for use in the

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1 infringement of the essential DVD Patents. Defendants specifically intended that the 2 DVDs they sell be used by their direct and/or indirect customers, which use would 3 infringe some or all of the essential DVD Patents, including the patents-in-suit, and 4 Defendants knew that such customers’ actions would constitute infringement. 5 48. Upon information and belief, Individual Defendants Mamane, Pool and 6 Yoffe, through their ownership and control of Defendants Encore, DVD Factory, 7 Davenport, MMI, Rodax, 6480 Corp. and MME have been personally involved with 8 the infringing manufacture, use, offers to sell and sales of DVDs and have actively 9 and knowingly induced the infringing sales made by Defendants Encore, DVD 10 Factory, Davenport, MMI, Rodax, 6480 Corp. and MME, including after each of 11 these individuals was informed of the infringement. 12 49. Defendants’ infringing actions were and are without authority, consent 13 or license. 14 50. Defendants have had the means and opportunity to access and consider 15 all of the information provided by Panasonic and found on the DVD6C website, and 16 they have willfully infringed the patents-in-suit either by reading and considering 17 this information, or by purposefully ignoring the information, and continuing the 18 infringing conduct. 19 51. Plaintiffs have each suffered damages as a result of the direct and 20 indirect infringing actions of Defendants, and will continue to suffer such damages 21 as long as those infringing actions continue. 22 COUNT I – INFRINGEMENT OF U.S. PATENT NO. 5,463,565 23 52. The allegations contained in paragraphs 1-51 above are repeated and 24 realleged as if fully set forth herein. 25 53. Warner Bros. is the assignee and owner of the right, title, and interest in 26 and to the ‘565 patent, now and for the entire period of and relevant to the 27 infringement, including the right to assert all causes of action arising under said 28 patent and the right to any remedies for infringement of it.

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1 54. Defendants are, and have been, on notice of the ‘565 patent since before 2 this lawsuit was filed. Among the ways that actual notice has been provided to 3 Defendants is the identification of the ‘565 patent on the Patent Lists and in one or 4 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 5 on the DVD6C website to which Defendants were directed by Panasonic. 6 55. Defendants have directly infringed and/or indirectly infringed, literally 7 and/or under the doctrine of equivalents, the ‘565 patent under 35 U.S.C. § 271. 8 56. Upon information and belief, the infringement of the ‘565 patent by 9 Defendants has been willful. 10 57. Warner Bros. has been damaged by the infringement of the ‘565 patent 11 by Defendants. 12 COUNT II – INFRINGEMENT OF U.S. PATENT NO. 5,790,487 13 58. The allegations contained in paragraphs 1-51 above are repeated and 14 realleged as if fully set forth herein. 15 59. Panasonic is the assignee and owner of the right, title, and interest in 16 and to the ‘487 patent, now and for the entire period of and relevant to the 17 infringement, including the right to assert all causes of action arising under said 18 patent and the right to any remedies for infringement of it. 19 60. Defendants are, and have been, on notice of the ‘487 patent since before 20 this lawsuit was filed. Among the ways that actual notice has been provided to 21 Defendants is the identification of the ‘487 patent on the Patent Lists and in one or 22 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 23 on the DVD6C website to which Defendants were directed by Panasonic. 24 61. Defendants have and continue to directly infringe and/or indirectly 25 infringe literally and/or under the doctrine of equivalents, the ‘487 patent under 35 26 U.S.C. § 271. 27 62. Upon information and belief, the infringement of the ‘487 patent by 28 Defendants has been willful.

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1 63. Panasonic has been damaged and continues to be damaged by the 2 infringement of the ‘487 patent by Defendants. 3 COUNT III – INFRINGEMENT OF U.S. PATENT NO. 5,838,657 4 64. The allegations contained in paragraphs 1-51 above are repeated and 5 realleged as if fully set forth herein. 6 65. SANYO is the assignee and owner of the right, title, and interest in and 7 to the ‘657 patent, now and for the entire period of and relevant to the infringement, 8 including the right to assert all causes of action arising under said patent and the 9 right to any remedies for infringement of it. 10 66. Defendants are, and have been, on notice of the ‘657 patent since before 11 this lawsuit was filed. Among the ways that actual notice has been provided to 12 Defendants is the identification of the ‘657 patent on the Patent Lists and in one or 13 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 14 on the DVD6C website to which Defendants were directed by Panasonic. 15 67. Defendants have directly infringed and/or indirectly infringed, literally 16 and/or under the doctrine of equivalents, the ‘657 patent under 35 U.S.C. § 271. 17 68. Upon information and belief, the infringement of the ‘657 patent by 18 Defendants has been willful. 19 69. SANYO has been damaged by the infringement of the ‘657 patent by 20 Defendants. 21 COUNT IV – INFRINGEMENT OF U.S. PATENT NO. 5,881,032 22 70. The allegations contained in paragraphs 1-51 above are repeated and 23 realleged as if fully set forth herein. 24 71. Panasonic is the assignee and owner of the right, title, and interest in 25 and to the ‘032 patent, now and for the entire period of and relevant to the 26 infringement, including the right to assert all causes of action arising under said 27 patent and the right to any remedies for infringement of it. 28

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1 72. Defendants are, and have been, on notice of the ‘032 patent since before 2 this lawsuit was filed. Among the ways that actual notice has been provided to 3 Defendants is the identification of the ‘032 patent on the Patent Lists and in one or 4 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 5 on the DVD6C website to which Defendants were directed by Panasonic. 6 73. Defendants have and continue to directly infringe and/or indirectly 7 infringe, literally and/or under the doctrine of equivalents, the ‘032 patent under 35 8 U.S.C. § 271. 9 74. Upon information and belief, the infringement of the ‘032 patent by 10 Defendants has been willful. 11 75. Panasonic has been damaged and continues to be damaged by the 12 infringement of the ‘032 patent by Defendants. 13 COUNT V – INFRINGEMENT OF U.S. PATENT NO. 5,896,367 14 76. The allegations contained in paragraphs 1-51 above are repeated and 15 realleged as if fully set forth herein. 16 77. SANYO is the assignee and owner of the right, title, and interest in and 17 to the ‘367 patent, now and for the entire period of and relevant to the infringement, 18 including the right to assert all causes of action arising under said patent and the 19 right to any remedies for infringement of it. 20 78. Defendants are, and have been, on notice of the ‘367 patent since before 21 this lawsuit was filed. Among the ways that actual notice has been provided to 22 Defendants is the identification of the ‘367 patent on the Patent Lists and in one or 23 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 24 on the DVD6C website to which Defendants were directed by Panasonic. 25 79. Defendants have directly infringed and/or indirectly infringed, literally 26 and/or under the doctrine of equivalents, the ‘367 patent under 35 U.S.C. § 271. 27 80. Upon information and belief, the infringement of the ‘367 patent by 28 Defendants has been willful.

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1 81. SANYO has been damaged by the infringement of the ‘367 patent by 2 Defendants. 3 COUNT VI – INFRINGEMENT OF U.S. PATENT NO. 6,526,221 4 82. The allegations contained in paragraphs 1-51 above are repeated and 5 realleged as if fully set forth herein. 6 83. Warner Bros. is the assignee and owner of the right, title, and interest in 7 and to the ‘221 patent, now and for the entire period of and relevant to the 8 infringement, including the right to assert all causes of action arising under said 9 patent and the right to any remedies for infringement of it. 10 84. Defendants are, and have been, on notice of the ‘221 patent since before 11 this lawsuit was filed. Among the ways that actual notice has been provided to 12 Defendants is the identification of the ‘221 patent on the Patent Lists and in one or 13 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 14 on the DVD6C website to which Defendants were directed by Panasonic. 15 85. Defendants have directly infringed and/or indirectly infringed, literally 16 and/or under the doctrine of equivalents, the ‘221 patent under 35 U.S.C. § 271. 17 86. Upon information and belief, the infringement of the ‘221 patent by 18 Defendants has been willful. 19 87. Warner Bros. has been damaged by the infringement of the ‘221 patent 20 by Defendants. 21 COUNT VII – INFRINGEMENT OF U.S. PATENT NO. 6,539,164 22 88. The allegations contained in paragraphs 1-51 above are repeated and 23 realleged as if fully set forth herein. 24 89. Mitsubishi is the assignee and owner of the right, title, and interest in 25 and to the ‘164 patent, now and for the entire period of and relevant to the 26 infringement, including the right to assert all causes of action arising under said 27 patent and the right to any remedies for infringement of it. 28

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1 90. Defendants are, and have been, on notice of the ‘164 patent since before 2 this lawsuit was filed. Among the ways that actual notice has been provided to 3 Defendants is the identification of the ‘164 patent on the Patent Lists and in one or 4 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 5 on the DVD6C website to which Defendants were directed by Panasonic. 6 91. Defendants have and continue to directly infringe and/or indirectly 7 infringe, literally and/or under the doctrine of equivalents, the ‘164 patent under 35 8 U.S.C. § 271. 9 92. Upon information and belief, the infringement of the ‘164 patent by 10 Defendants has been willful. 11 93. Mitsubishi has been damaged and continues to be damaged by the 12 infringement of the ‘164 patent by Defendants. 13 COUNT VIII – INFRINGEMENT OF U.S. PATENT NO. 6,549,717 14 94. The allegations contained in paragraphs 1-51 above are repeated and 15 realleged as if fully set forth herein. 16 95. Mitsubishi is the assignee and owner of the right, title, and interest in 17 and to the ‘717 patent, now and for the entire period of and relevant to the 18 infringement, including the right to assert all causes of action arising under said 19 patent and the right to any remedies for infringement of it. 20 96. Defendants are, and have been, on notice of the ‘717 patent since before 21 this lawsuit was filed. Among the ways that actual notice has been provided to 22 Defendants is the identification of the ‘717 patent on the Patent Lists and in one or 23 both of the Summary Reports of essential DVD-ROM and DVD-Video Disc Patents 24 on the DVD6C website to which Defendants were directed by Panasonic. 25 97. Defendants have and continue to directly infringe and/or indirectly 26 infringe, literally and/or under the doctrine of equivalents, the ‘717 patent under 35 27 U.S.C. § 271. 28

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1 98. Upon information and belief, the infringement of the ‘717 patent by 2 Defendants has been willful. 3 99. Mitsubishi has been damaged and continues to be damaged by the 4 infringement of the ‘717 patent by Defendants. 5

6 REQUEST FOR RELIEF 7 8 WHEREFORE, Plaintiffs respectfully request that the Court enter a judgment: 9 A. Declaring that Defendants have infringed U.S. Patent Nos. 5,463,565, 10 5,790,487, 5,838,657, 5,881,032, 5,896,367, 6,526,221, 6,539,164, and 6,549,717; 11 B. Awarding Plaintiffs damages adequate to compensate for Defendants’ 12 infringing activities, including supplemental damages for any post-verdict 13 infringement up until entry of the final judgment with an accounting as needed, 14 together with prejudgment and post-judgment interest on the damages awarded; all 15 of these damages to be enhanced in an amount up to treble the amount of 16 compensatory damages as justified under 35 U.S.C. § 284; 17 C. Declaring that this case is exceptional under 35 U.S.C. § 285 and 18 awarding Plaintiffs their reasonable costs and expenses of litigation, including 19 attorneys’ and experts’ fees; and 20 D. Awarding Plaintiffs such other and further relief as the Court may deem 21 just and proper. 22 23 24 25 26 27 28

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1 JURY DEMAND 2 Plaintiffs demand a trial by jury as to all claims and all issues properly triable 3 thereby. 4 Respectfully submitted, 5 SIDLEY AUSTIN LLP 6 7 Dated: March 19, 2015 By: /s/ Jeffrey M. Olson Jeffrey M. Olson 8 Attorneys for Plaintiffs 9 PANASONIC CORPORATION, SANYO ELECTRIC CO., LTD., WARNER BROS. 10 HOME ENTERTAINMENT INC. and MITSUBISHI ELECTRIC CORPORATION 11

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