IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION


JOHN B. ADRAIN,

Plaintiff, Case No. 2:14-cv-625

vs.
JURY TRIAL DEMANDED
DAHUA TECHNOLOGY CO., LTD.

Defendant.


COMPLAINT FOR PATENT INFRINGEMENT


Plaintiff John B. Adrain (Adrain) brings this action against defendant Dahua Technology
Co., Ltd. (Dahua or Defendant) and alleges:
THE PARTIES
1. Adrain is the inventor of and owns the entire right, title, and interest in the patent at
issue in this case.
2. On information and belief, Dahua Technology Co., Ltd. is a corporation organized and
existing under the laws of China, with its principal place of business located at No. 1199, Binan
Road, Binjiang District, Hangzhou 310053, China. Service of process can be made on Dauha
Technology Co., Ltd. by way of The Hague Service Convention.
JURISDICTION AND VENUE
3. This is an action for patent infringement arising under the provisions of the Patent
Laws of the United States of America, Title 35, United States Code.


COMPLAINT FOR PATENT INFRINGEMENT Page -2-
4. Subject-matter jurisdiction over Adrains claim is conferred upon this Court by 28
U.S.C. 1331 and 1338(a).
5. On information and belief, Defendants products placed in the streamof commerce in
this District are being offered for sale, sold, and purchased in this District.
6. Venue is proper in this judicial district under 28 U.S.C. 1391(b), (c) and (d), and/or
1400(b).
GENERAL ALLEGATIONS REGARDING PATENT INFRINGEMENT
7. On November 3, 1998, U.S. Patent No. 5,831,669, entitled Facility Monitoring
Systemwith Image Memory and Correlation was duly and legally issued to the inventor, John B.
Adrain. A Reexamination Certificate for U.S. Patent 5,831,669 issued on August 21, 2012. (U.S.
Patent 5,831,669 and the Reexamination Certificate are collectively referred to as the 669 patent.)
Adrain owns all right, title and interest in the 669 patent, including the right to sue for and recover
all past, present and future damages for infringement of the 669 patent.
8. The 669 patent is presumed valid.
COUNT I
PATENT INFRINGEMENT

9. Adrain repeats and realleges the allegations of paragraphs 1-8 above, as though fully
set forth herein.
10. Upon information and belief, Dahua, either alone or in conjunction with others, has in
the past and continues to infringe and/or induce infringement of the 669 patent by making, using,
selling, offering to sell, and/or importing, and/or causing others to make, use, sell, or offer to sell,
and/or import, in this judicial district and/or elsewhere in the United States, security monitoring
systems that alone or in use are covered by one or more of the claims of the 669 patent.


COMPLAINT FOR PATENT INFRINGEMENT Page -3-
11. For example, Dahua makes, uses, sells, offers to sell and/or imports video surveillance
cameras, software and network video recorders. By way of further example, one such camera is the
SD6582A-HN that can be used with the NVR3204-P Network Video Recorder.
12. Consumers purchase and use Dahuas systems and devices and are instructed by
Dahua to use such systems and devices in manners that infringe one or more claims of the 669
patent.
13. Dahua provides instructions, such as user manuals, that instruct consumers on how to
set up and use such devices and systems, specifically intending such consumers will operate these
devices and systems in a manner that constitutes infringement of one or more claims of the 669
patent, and knowing of such actions, which constitutes infringement of one or more claims of the
669 patent.
14. Dahua has been and/or is now indirectly infringing one or more claims of the 669
patent in violation of 35 U.S.C. 271(b) by inducing users of Dahuas security monitoring systems to
directly infringe one or more claims of the 669 patent through their use of such systems.
15. For example, Dahua induces direct infringement of the 669 patent by providing user
manuals and instructions with the NVR3204-P software that show users how to setup and operate the
motion detection features of Dahuas security monitoring system. Dahua engages in such inducement
knowingly and, at least from the time of receipt of the present Complaint, has done so with
knowledge that such activity encourages consumers of its security monitoring systems to directly
infringe the 669 patent.
16. Dahua is liable for infringement of the 669 patent pursuant to 35 U.S.C. 271.


COMPLAINT FOR PATENT INFRINGEMENT Page -4-
17. Dahuas acts of infringement have caused damage to Adrain, and Adrain is entitled to
recover from Dahua the damages sustained by Adrain as a result of Dahuas wrongful acts in an
amount subject to proof at trial.
18. As a consequence of the infringement complained of herein, Adrain has been
irreparably damaged to an extent not yet determined and will continue to be irreparably damaged by
such acts in the future unless Dahua is enjoined by this Court from committing further acts of
infringement.
PRAYER FOR RELIEF
WHEREFORE, Adrain prays for entry of judgment that:
A. Defendant has directly infringed and/or induced infringement of the 669 patent;
B. Defendant account for and pay to Adrain all damages caused by its infringement of the
669 patent;
C. Adrain be granted permanent injunctive relief pursuant to 35 U.S.C. 283 enjoining
Defendant and its officers, agents, servants, employees and those persons in active concert or
participation with it from further acts of patent infringement;
D. Adrain be granted pre-judgment and post-judgment interest on the damages caused to
him by reason of Defendants patent infringement;
E. Adrain be granted his reasonable attorneys fees in accordance with 35 U.S.C. 285;
F. Costs be awarded to Adrain; and,
G. Adrain be granted such other and further relief as the Court may deemjust and proper
under the circumstances.
DEMAND FOR JURY TRIAL
Adrain demands trial by jury on all claims and issues so triable.



COMPLAINT FOR PATENT INFRINGEMENT Page -5-


Respectfully submitted,

Dated: May 14, 2014 By: /s/Otis Carroll
John T. Polasek
Texas Bar No. 16088590
[email protected]
C. Dale Quisenberry
Texas Bar No. 24005040
[email protected]
Jeffrey S. David
Texas Bar No. 24053171
[email protected]
POLASEK, QUISENBERRY & ERRINGTON, L.L.P.
6750 West Loop South, Suite 920
Bellaire, Texas 77401
Telephone: (832) 778-6000
Facsimile: (832) 778-6010

Otis W. Carroll
State Bar No. 03895700
[email protected]
Deborah Race
State Bar No. 16448700
[email protected]
IRELAND, CARROLL & KELLEY, P.C
6101 S. Broadway, Suite 500
P.O. Box 7879
Tyler, Texas 75711
Telephone: (903) 561-1600
Facsimile: (903) 581-1071

S. Calvin Capshaw
State Bar No. 03783900
[email protected]
Elizabeth L. DeRieux
State Bar No. 05770585
[email protected]
D. Jeffrey Rambin
State Bar No. 00791478
[email protected]
CAPSHAW DERIEUX, LLP
114 East Commerce Avenue
Gladewater, Texas 75647
Telephone: (903) 236-9800
Facsimile: (903) 236-8787


COMPLAINT FOR PATENT INFRINGEMENT Page -6-

Russell R. Smith
State Bar No. 18682310
[email protected]
Fairchild, Price, Haley, & Smith, L.L.P.
1801 North Street
Nacogdoches, Texas 75963-1668
Telephone: (936) 569-2327
Facsimile: (936) 569-7932

Attorneys for Plaintiff