Digital Dream Labs v. Living Tech. - Complaint

Case 2:20-cv-01500-DSC Document 1 Filed 10/05/20 Page 1 of 31
MUS3688312.1
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA
DIGITAL DREAM LABS, LLC., )

)
Plaintiff, ) Civil Action No. 2:20-cv-1500
)
v. )
)
LIVING TECHNOLOGY (SHENZHEN) CO., ) JURY TRIAL DEMANDED
LTD. d/b/a LIVING.AI and EMO PET, )
)
Defendant. )
COMPLAINT
Plaintiff, Digital Dream Labs, LLC , by its undersigned counsel, respectfully sets forth
this Complaint against Defendant, Living Technology (Shenzhen) Co., Ltd. d/b/a Living.Ai and
Emo Pet, stating as follows:
INTRODUCTION
1. This dispute arises from the wrongful and intentional acts of the Defendant Living
Technology (Shenzhen) Co., Ltd. d/b/a Living.Ai and Emo Pet (collectively, “Living.Ai” or
“Defendant”) to infringe and profit from the intellectual property rights, including copyright,
patent, trademark and trade dress rights, and commercial reputation belonging to, and otherwise
interfere with the contractual relations of Plaintiff Digital Dream Labs, LLC (“DDL”). At a
minimum1, Defendant has intentionally and willfully copied, duplicated, and reproduced the
following proprietary items owned by Plaintiff for Defendant’s own commercial use and profit:
1
Plaintiff is continuing to investigate the full scope of Defendant’s infringing conduct and other
wrongful acts, and Plaintiff reserves its right to amend this Complaint.
1) the patented head, face, and eye designs for a toy robot; 2) the copyrighted audio “voice” and
sounds used for a toy robot; 3) the registered trademark – VECTOR® – for use with, inter alia,
“Toy robots and smart robot toys”; and 4) the unauthorized and intentional display of Plaintiff’s
toy robot designs and trade dress for VECTOR® and COZMO® robots in Defendant’s own
marketing advertisements for Defendant’s infringing EMO toy robot, whereby Defendant at least
has created a false association between the parties’ products and a false endorsement of EMO by
Plaintiff.
2. VECTOR® and COZMO® are robotic companions made to socialize and assist
the user. Powered by artificial intelligence (“ai”) and advanced robotics, they are full of
personality and engaged by sight, sound, and touch. Both are voice-activated and will, among
other things, answer questions, take photos for you, time dinner, show you the weather, and
more. For example, if you choose to set up Alexa on your VECTOR®, you'll be able to: set
reminders, control smart home devices like lights, speakers, and thermostats, and so much more.
VECTOR® can independently navigate and self-charge. He recognizes people and avoids
obstacles. Both robots have an updating platform and are Cloud connected via Wi-Fi so they are
always learning and updating with new skills and features.
3. VECTOR® and COZMO® are both currently owned, advertised, and marketed
by DDL. VECTOR® now includes a subscription service that provides constant software
updates, in-app games and features, and other exclusive content provided by DDL.
4. DDL is not opposed to competition in the marketplace for toy robots
incorporating ai and competition does exist in this market, including without limitation, the
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WowWee Tribot, Dash and Dot, Lego Mindstorms EV 3, and Sphero BB-8 Droid. However,
DDL significantly opposes competition based on the theft of DDL’s intellectual property.
PARTIES
5. Plaintiff DDL is a Pennsylvania limited liability company with its principle place
of business at 100 South Commons, Pittsburgh, PA 15212. DDL is a technology education
company that sells and markets several high-functioning and interactive robots, including
VECTOR® and COZMO®, pictured below in that order.
6. Upon information and belief, Defendant Living.Ai is a Chinese corporation with
its principle place of business at 7H, Centre Avenue Mansion, Block D, Yuehe Road, Baoan
District, Shenzhen, Guangdong, 518000 China, and it is currently marketing a robotic desk
companion named EMO a/k/a EMO pet for sale in the United States. EMO is pictured below at
two different angles.
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JURISDICTION AND VENUE
7. This Court has federal question jurisdiction for DDL’s copyright, patent, and
trademark infringement claims under 28 U.S.C. §§ 1331 and 1338(a).
8. In addition, this Court also has federal question jurisdiction over DDL’s trade
dress claim under Section 43(a) of the Lanham Act pursuant to 15 U.S.C. § 1121.
9. Furthermore, this Court has supplemental jurisdiction over DDL’s state law claim
under 28 U.S.C. § 1367, as DDL’s state law claim forms part of the same case and controversy
as its federal statutory claims.
10. More specifically, and as set forth more fully below, (a) Living.Ai has committed
intentional acts and torts against DDL, (b) DDL has felt the brunt of the harm in this judicial
district such that this judicial district is the focal point of the harm suffered by DDL as a result of
the intentional acts and torts committed by Living.Ai, and (c) Living.Ai expressly aimed its
intentional acts and torts at this judicial district such that this district is the focal point of such
acts and torts.
11. Personal jurisdiction is also proper in this Court and this judicial district as the
collective actions of Living.Ai intentionally created an affiliation with DDL, which is located in
this judicial district in Pittsburgh, PA, and willfully and intentionally created confusion and
uncertainty regarding the association between the parties and the endorsement of EMO by DDL.
Further, as set forth more fully below, Living.Ai has intentionally sought to introduce EMO into
the United States, despite receiving a notice of infringement from DDL, has continued to market
EMO in this judicial district and intentionally directed its acts of infringement and
misappropriation against DDL in this judicial district.
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12. Alternatively, personal jurisdiction is also proper in this Court and this judicial
district under Fed. R. Civ. P. 4(k)(1)(A) because DDL’s claims arise under federal law and upon
information and belief, Living.Ai is not subject to the jurisdiction of any state’s courts of general
jurisdiction.
13. Venue in this judicial district is proper under 28 U.S.C. §§ 1391 and1400(a)-(b).
FACTUAL ALLEGATIONS
I. Background
14. DDL is a Pittsburgh-based education technology start-up that was formed in July
of 2012. DDL’s mission is to bring objects to life through robotics and artificial intelligence,
allowing people to build relationships with technology.
15. In December of 2019, DDL acquired all the assets of another robotics company,
Anki, Inc. (“Anki”), in a public sale and offering. Anki was the original developer of, among
other products, two (2) high-functioning and interactive robots called VECTOR® and
COZMO®. By assignment, all of Anki’s intellectual property assets were transferred to DDL.
16. One of the main reasons DDL acquired the entirety of Anki’s assets was the
former company’s market presence. Acquiring all of Anki’s intellectual property assets,
including registered patents and trademarks for VECTOR® and COZMO®, provided DDL with
access to a built-in customer base of millions together with an established relationship to the
VECTOR® and COZMO® products, along with other technology and intellectual property
rights.
17. COZMO® was introduced into the United States market by Anki in 2016.
VECTOR® made its debut to the United States market in 2018. VECTOR® was introduced to
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consumers through a Kickstarter campaign that launched on August 8, 2018. The original
VECTOR® Kickstarter page is accessible here:
https://www.kickstarter.com/projects/anki/vector-by-anki-a-giant-roll-forward-for-robot-
kind?ref=discovery&term=ANKI. This date is relevant because the design of EMO began to
change after VECTOR®’s introduction to mimic many aspects of VECTOR® as well as the
earlier design of COZMO®
18. The assets acquired by DDL from Anki included various patents and trademarks
relating to the design and function of both the VECTOR® and COZMO® robots. These patents
included three (3) U.S. Patents that cover the design of the head and eyes of both the VECTOR®
and COZMO® robots. DDL is continuing to investigate the application of other utility patents to
EMO.
19. United States Design Patent Nos. D812,153 and D812,154; dated March 6, 2018
titled “Toy Robot Head” and “Toy Robot Eyes”, are attached hereto as Exhibits A and B,
respectively. United States Design Patent No. D811,496 dated February 27, 2018 and titled
“Toy Robot Eye” is attached hereto as Exhibit C. These three (3) Patents shall collectively be
referred to as the “DDL Patents.”
20. The DDL Patents cover the unique shape and design of the VECTOR® and
COZMO® head and eyes. Figure 1 from each DDL Patent is displayed below:
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21. The design covered by the DDL Patents is intended to replicate the head of a
baby, with rounded surfaces, "ears" at the side panels and large eyes.
22. Similarly, as a result of the sale by Anki, DDL acquired rights to all trademarks
associated with Anki, including, but not limited to the marks VECTOR® and COZMO®, which
are respectively protected at U.S. Registered Trademark No. 5,711,131 dated March 26, 2019,
and attached hereto as Exhibit D (hereinafter “VECTOR® Trademark”) and U.S. Registered
Trademark No. 5842149, dated August 27, 2019, and attached hereto as Exhibit E (hereinafter
“COZMO® Trademark”).
23. Thereafter, in September of 2020, in order to further protect its interests in the
COZMO® robot, DDL applied for and was granted two (2) valid U.S. Copyright Registrations
covering the history and design of the sound recordings used to create the voice and
exclamations of COZMO®. See U.S. Copyright Registration Nos. SR 879-604 and SRu 1-424-
806, attached hereto as Exhibits F and G, respectively (hereinafter “the DDL Copyrights”).
II. Living.Ai’s Infringement of DDL’s Patents, Copyrights, and Trademarks
24. On September 1, 2020, DDL became aware that Living.Ai was marketing its
EMO robot for release in the United States. Specifically, Living.Ai utilized a series of posts on
the social media platforms Instagram® and Facebook®, including a Facebook® page with
multiple posts indicating that “VECTOR® and EMO are friends,” while also uploading a pre-
launch marketing video to YouTube®.
25. The pre-launch marketing video released by Living.Ai on its own website,
YouTube® page, and Facebook® page included a segment where VECTOR®, which is
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exclusively owned by DDL, is placed next to EMO and EMO reacts. A screenshot of Living.Ai’s
original pre-launch marketing video can be seen below:
26. Living.Ai specifically enhanced and expanded the false association and/or
endorsement of EMO by DDL when questions arose about the affiliation between VECTOR®
and EMO within the Living.Ai Facebook® group. On multiple occaisions where potential
consumers questioned the association between EMO and VECTOR®, the Living.Ai Facebook®
moderator replied by identifying VECTOR® and EMO as friends, including as follows:
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27. The use of VECTOR® in its pre-launch marketing video, without the consent of
DDL, the multiple references to “VECTOR® and EMO are friends” throughout Living.Ai’s
social media accounts, and the YouTube® video directly infringed on the VECTOR®
Trademark. More specifically, these various references to VECTOR® created, at a minimum, a
false association between VECTOR® and EMO and a false endorsement of EMO and Living.Ai
by DDL.
28. Additionally, the pre-launch video utilized by Living.Ai further created a false
asssociation with DDL through Living.Ai’s intentional and knowing inclusion of segments of
various marketing videos substantially similar to those prepared by Anki for the promotion of
COZMO®. The Living.Ai video segments were prepared and distributed by Living.Ai to target
current DDL customers and misrepresent a direct affiliation with VECTOR® and COZMO®.
One, but not the only, example of the video segrements directly copied from a COZMO®
promotional video (first photograph) and compared to the EMO pre-launch video (second
photograph) can be seen below:
29. As demonstrated above, all of the early marketing produced and distributed by
Living.Ai was directly targeted to current customers of DDL to make a false association between
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EMO, on the one hand, and VECTOR® and COZMO®, on the other hand. Indeed, when the
original pre-launch marketing video was released in the United States, individuals commenting
on online forums and chat boards, as well as technology reviewers, immediately assumed that
EMO had been developed by DDL as an updated version of VECTOR® and/or COZMO®. See
Upcoming Tech, Ep. 1, “EMO – Desktop AI Robot Pet: Vector Clone?”, dated September 18,
2020, https://www.youtube.com/watch?v=AnzUvRBc094&feature=youtu.be, last visited
October 1, 2020; see also, LJP Tech, “Emo The Desktop Robot Pet – My Thoughts”, dated
September 5, 2020, https://www.youtube.com/watch?v=ebEc8NpnyVE, last visited October 2,
2020 (“How could Living.Ai copy all those files[?] If they have done so without the permission
of Digital Dream Labs, this is a serious crime.”).
30. The similarities between VECTOR® and COZMO®, on the one hand, and EMO,
on the other hand, are readily apparent. Living.Ai has willfully and intentionally copied,
reproduced, and infringed on DDL’s patents, trademarks, and copyrights regarding the
VECTOR® and COZMO® robots. For example, the design and animations of the EMO robot’s
eyes and head was directly copied from the DDL Patents used to design and develop the
VECTOR® and COZMO® eyes and head.
31. Placing VECTOR® and EMO in a side-by-side comparison, as was done in
Living.Ai’s pre-launch marketing video, reveals other noticable similarities; the software, the
motions, the sound effects, and the behavior of both robots is nearly identical.
32. The false association and direct attempt by Living.Ai to target DDL’s consumer
base with a false endorsement of EMO, while simultaneously irreparably damaging DDL’s
goodwill and reputation in the robotics community, is further demonstrated by the following
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exchange on Reddit, a website that creates a network of communities for individuals with similar
interests, dated September 1, 2020:
33. Below are the animations and eye shape of EMO when prompted by the user
about the weather (on the right), as noted in the Reddit thread, and they are virtually identical to
those currently installed, patented, and used in VECTOR® (on the left):
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34. As demonstrated above, it is nearly impossible to distinguish between the head,
eyes, and animation of VECTOR® and EMO. In effect, Living.Ai has created a “knock-off”
version of VECTOR® that Living.Ai intends to sell at a discounted price.
35. The characteristics and visual appearance of EMO was intentionally and willfullly
designed by Living.Ai to signify to consumers, particularly those consumers familiar with
VECTOR® and COZMO®, that EMO was an updated or “second generation” version of
VECTOR® and/or other DDL products.
36. In addition, as noted above, the sound effects and “voice” of EMO directly
infringe on the valid DDL Copyrights owned and exclusively controlled by DDL. Specifically,
EMO utilizes a substantially similar set of sound effects and “exclamations” as those designed
and recorded solely for the COZMO® robot.
37. The tables below (collectively referred to as the “Copyright Tables”)
demonstrate the location of each copyrighted voice design owned by DDL and where it is
reproduced, copied, and infringed upon in the EMO pre-launch marketing video, that can be
found on the Living.Ai website:
EMO by Living.Ai COZMO® by DDL

https://www.living.ai/ Copyright Registration No. SR 879-604
(last visited October 1, 2020) Audio File
“Wake up” 0:04 seconds 0:01, 0:31 – 0:33 seconds
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https://www.living.ai/ Copyright Registration No. SR 879-604
“Excited” 0:12 seconds 0:12 seconds
“Wow” 0:18 seconds 0:13 seconds
“Curious” 0:21 seconds 0:04, 0:11 – 0:13 seconds

https://www.living.ai/ Copyright Registration No. SRu 1-424-806
“Excited” 0:12 seconds 1:31
“Giggle” 0:14 seconds 1:38 -1:40
“Wow” 0:18 seconds 1:34 – 1:36
“Thought” 0:51 seconds 0:11 seconds
38. An online comparison of the sound effects and exclamations of COZMO® and
EMO can be found here: Just Baselmans, “Emo The Desktop Robot and Anki Cozmo Sound
Comparison”, dated September 15, 2020, https://www.youtube.com/watch?v=ES52kcuW0dk
(last visited October 2, 2020).
39. In effect, the infringing EMO robot currently being marketed by Living.Ai in the
United States is a combination of VECTOR®’s head, eyes, and animation and COZMO®’s
sound effects and exclamations. These elements are protected by copyright and patent, as well as
trade dress.
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40. Upon information and belief, after the launch of the VECTOR® Kickstarter in
August of 2018, Living.Ai substantially changed the design, development, and functions of EMO
to directly copy the VECTOR® robot and COZMO® audio sounds.
41. At no time did Living.Ai seek the consent or approval of DDL to utilize any of
the trademarks, trade dress, copyrights, or patents associated with VECTOR® and COZMO®,
and DDL specifically asserts that no such consent was ever given.
42. Living.Ai’s egregious infringement of DDL’s trademarks, trade dress copyrights,
patents, and commerical advertising has resulted in a false association between EMO and DDL
and has misrepresented that DDL actively promotes, sponsors, and/or approves of the EMO
robot.
III. Pre-Suit Notice of Infringing Behavior and DDL’s Removal of Online

Content
43. As soon as DDL became aware of the infringing material posted on Living.Ai’s
Facebook®, YouTube®, and Instagram® accounts, DDL filed several notices and complaints of
infringement with those social media companies, with DDL asserting its trademark, copyright,
and patent rights and requesting that the content be removed. An example of the infringing
material posted in one Living.Ai social media site is below:
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44. As a result of its notices/complaints, the infringing content produced and
distributed by Living.Ai on Facebook®, YouTube®, and Instagram®, and the following links
have been disabled due to the patent, copyright, and trademark infringements of Living.Ai:
Facebook®:
https://www.facebook.com/LivingAi
https://www.facebook.com/LivingAi/photos/rpp.106974277624325/173559874299098/?t
ype=3&theater
ype=3&theater
ype=3&theater
https://www.facebook.com/groups/658594978254260/permalink/763796024400821
https://www.facebook.com/groups/658594978254260/permalink/764763674304056
https://www.facebook.com/groups/658594978254260/permalink/740382063408884/
https://www.facebook.com/106974277624325/videos/359042655254779
https://www.facebook.com/101458965055821/videos/782728375887429/
https://www.facebook.com/pg/EMO-AI-Desktop-Pet-
101458965055821/photos/?tab=album&album_id=101459635055754&ref=page_internal
https://www.facebook.com/101458965055821/photos/a.101459635055754/10145941838
9109/?type=3&theater
Instagram®:
https://www.instagram.com/p/CFbiSgmDy-M/
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https://www.instagram.com/p/CFbiSgmDy-M/
https://www.instagram.com/p/CEjUApQAcC8/
https://www.instagram.com/p/CEjUApQAcC8
https://www.instagram.com/p/CFSA0SVDxyP/
https://www.instagram.com/p/CFSA0SVDxyP
https://www.instagram.com/p/CFM1uNVjqRV/
https://www.instagram.com/p/CFM1uNVjqRV
https://www.instagram.com/p/CFDcfJ6j0f-/
https://www.instagram.com/p/CFDcfJ6j0f-
https://www.instagram.com/p/CFB7rkBjGVn/
https://www.instagram.com/p/CFB7rkBjGVn
YouTube®:
http://www.youtube.com/watch?v=ytv3HuxtwH0
45. On September 18, 2020, counsel for DDL sent a Notice of Infringement of
Intellectual Property Rights of Digital Dream Labs, LLC to Living.Ai asserting that the design
and functions of EMO violated the following intellectual property rights of DDL: 1) Violation
and infringement of U.S. design patents, including without limitation, U.S. Patents Nos.
D811,496, D812154, and D812,153; 2) Violation and infringement of U.S. and foreign utility
patents, including, without limitation, U.S. Patent Nos. 9,155,961, 9,919,232, 9,177,239, and
9,996,369, together with other pending applications in at least the United States and China; 3)
Violation and infringement of copyrights relating to the design of the VECTOR® robot and also
video and audio files created by DDL for promotion of COZMO®; 4) Violation and
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infringement of the VECTOR® trademark; and 5) Violation and infringement of trade dress
relating to the VECTOR® and COZMO® robots. See Notice of Infringement of Intellectual
Property Rights of Digital Dream Labs, LLC dated September 18, 2020, attached hereto as
Exhibit H.
46. Thereafter, DDL became aware that Living.Ai planned to launch EMO in North
America through the website Indiegogo® in order to sell directly to consumers in the United
States. Indiegogo, Inc. is a California company that specifically markets itself to Chinese
companies looking to break into the United States market. See Indiegogo for Entrepreneurs,
“Indiegogo China: Your Fast Track to the Global Market”,
https://entrepreneur.indiegogo.com/how-it-works/indiegogo-china/ (last visited October 1, 2020).
47. On September 21, 2020, DDL filed a Notice of Copyright Violation with
Indiegogo® and requested the removal of Living.Ai’s EMO launch website due to the alleged
infringements detailed above.
48. Thereafter, on September 23, 2020, Indiegogo® disabled the website link to
Living.Ai’s global launch of EMO, including the United States .2
49. Despite its knowing infringements of DDL’s intellectual property and the removal
of multiple website links for Living.Ai’s copycat product EMO (first photograph below),
Living.Ai continues to actively challenge the disablement of its infringing posts and seek other
avenues to begin selling EMO in the United States and has admitted its intent to do so on the
Living.Ai website (second photograph below):
2
https://www.indiegogo.com/projects/emo-coolest-desktop-pet-with-personality-and-
style/coming_soon?fbclid=IwAR330hwzeZKG1ywmAK0MNMk4M4AD559d0L2XWgPDUgE
cmV8lO50WUHmB7xQ
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50. Following the removal of Living.Ai’s Indiegogo launch page DDL quickly
discovered that the EMO robot was being advertised on other third-party websites for $19.99.
These third-party websites include: https://comingsoon.higizmos.com/emo and
https://loveumoreyy.com/products/%F0%9F%92%A5the-strongest-intelligent-robot-in-
history%F0%9F%92%A5?fbclid=IwAR2uWSW8xMWmzmTrb2EzU-
J7AuegzRWRWZPF5E9_nRYle29fhMiqF-o8v-8
51. Upon information and belief Living.Ai continues to attempt to promote, offer for
sale, and/or import into the United States, including this judicial district, the robot EMO, which
directly and willfully infringes on the intellectual property rights of DDL, even after receiving
DDL’s September 18, 2020 cease and desist letter and corresponding with DDL about the
violations.
COUNT I
Copyright Infringement
Digital Dream Labs, LLC vs. Living.Ai
52. The preceding paragraphs of the Complaint are hereby incorporated by reference
as though the same were fully set forth herein.
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53. The DDL Copyrights were and are, at all relevant times were, owned exclusively
by DDL.
54. The DDL Copyrights cover the sound/audio recordings of certain sounds and
exclamations of COZMO®. See U.S. Copyright Registration Nos. SR 879-604 and SRu 1-424-
806, at Exhibits F and G, respectively.
55. Upon information and belief, Living.Ai had access to and knowledge of the
sounds that are protected by the DDL Copyrights.
56. Living.Ai has directly, willfully, and intentionally infringed the sound/audio
recordings protected by the DDL Copyrights and set forth in the Copyright Tables listed above
by creating substantially similar sounds for use with the voice and exclamations of the EMO
robot.
57. More specifically, Living.Ai infringed DDL’s copyrights by integrating
substantially similar sounds and exclamations, as identified in the Copyright Tables above, into
the design of the EMO robot without DDL’s authorization or consent.
58. Furthermore, Living.Ai continues to infringe on DDL’s copyrights by continuing
to market, display, and offering to sell the EMO robot with substantially similar sounds and
exclamations subsequent to receiving notice of DDL’s rights in the subject copyrights.
59. Living.Ai has committed copyright infringement with actual or constructive
notice and knowledge of DDL’s rights, and/or in blatant disregard for DDL’s rights, such that
said acts of copyright infringement were, and continue to be, willful, intentional and malicious.
60. Living.Ai infringed DDL’s copyrights by utilizing substantially similar sounds
and exclamations in its pre-launch video for the EMO robot on many platforms, including,
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without limitation, its personal website, Facebook® page, Instagram® account, and YouTube®
channel without DDL’s authorization - both before and subsequent to receiving notice of DDL’s
rights in and to the audio recordings detailed in the DDL Copyrights.
61. Living.Ai’s acts of infringement, as alleged herein and in violation of the
Copyright Act, have caused and, unless enjoined by this Court, will continue to cause irreparable
harm to DDL. Further, the threatened and/or actual injuries that DDL has suffered and/or will
suffer are immediate and irreparable. Because of the difficulty in quantifying injury and harm to
DDL’s ability to compete and to maintain a competitive advantage through its intellectual
property, including the infringement of its valid Copyrights, damage to DDL’s business,
reputation, valuable rights in and to the DDL Copyrights, and goodwill associated therewith,
monetary damages alone will not fully compensate DDL for such wrongful conduct. DDL
therefore lacks an adequate and complete remedy at law and is entitled to injunctive relief.
62. Due to Living.Ai’s acts of infringement, DDL has suffered financial damages,
including but not limited to lost profits, in a presently undetermined amount.
63. Due to Living.Ai’s acts of copyright infringement, as alleged herein, Living.Ai
has obtained direct and indirect commercial and financial benefits and profit they would not
otherwise have realized but for their infringement of the DDL Copyrights. As such, DDL is
entitled to disgorgement of Living.Ai’s profits and/or financial benefits directly and indirectly
attributable to Living.Ai’s infringement of the DDL Copyrights in an amount to be established at
trial.
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COUNT II
Patent Infringement
65. As noted above, DDL is the owner, by assignment, of the entire right, title, and
interest in and to the DDL Patents and has all rights to sue for infringement of the DDL Patents.
66. DDL is the sole owner of United States Design Patent Nos. D812,153 and
D812,154; dated March 6, 2018 titled “Toy Robot Head” and “Toy Robot Eyes”, see Exhibits A
and B, respectively, and United States Design Patent No. D811,496 dated February 27, 2018 and
titled “Toy Robot Eye”, see Exhibit C.
67. The DDL Patents covering the unique shape and design of the VECTOR® and
COZMO® head and eyes have been directly, willfully, intentionally, and maliciously infringed
by Living.Ai.
68. Upon information and belief, Living.Ai has been importing, advertising,
marketing, selling, and/or offering for sale its EMO robot in and/or into the United States and
thereby directly infringing upon the DDL Patents.
69. Living.Ai’s importing, advertising, marketing, selling, and/or offering for sale its
EMO robot in and/or into the United States is a violation of DDL’s statutory rights under the
United States Patent Statute. See 35 U.S.C. §§ 1 et seq.
70. Living.Ai has been and continues to infringe on DDL’s patent rights by
importing, advertising, marketing, selling, and/or offering for sale its EMO robot, directly or
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through the use of intermediaries, within this judicial district and elsewhere within the United
States, its territories and possessions.
71. Living.Ai has been and continues to infringe on DDL’s patent rights by inducing
others to advertise, market, sell, offer for sale and/or use its EMO robot, directly or through the
use of other intermediaries, within this judicial district and elsewhere within the United States, its
territories and possessions. For example, Living.Ai partnered with Indiegogo to sell and/or offer
to sell the EMO robot.
72. Living.Ai’s acts of infringement, as alleged herein and in violation of U.S. Patent
law, have caused and, unless enjoined by this Court, will continue to cause irreparable harm to
DDL. Further, the threatened and/or actual injuries that DDL has suffered and/or will suffer are
immediate and irreparable. Because of the difficulty in quantifying injury and harm to DDL’s
ability to compete and to maintain a competitive advantage through its intellectual property,
including the infringement of its valid Patents, damage to DDL’s business, reputation, valuable
rights in and to the DDL Patents, and goodwill associated therewith, monetary damages alone
will not fully compensate DDL for such wrongful conduct. DDL therefore lacks an adequate and
complete remedy at law and is entitled to injunctive relief.
73. Due to Living.Ai’s acts of infringement, DDL has suffered financial damages,
including but not limited to lost profits, in a presently undetermined amount.
74. Due to Living.Ai’s acts of patent infringement, as alleged herein, Living Ai has
obtained direct and indirect commercial and financial benefits and profit they would not
otherwise have realized but for their infringement of the DDL Patents. As such, DDL is entitled
to disgorgement of Living.Ai’s profits and/or financial benefits directly and indirectly
- 22 -
attributable to Living.Ai’s infringement of the DDL Patents in an amount to be established at
trial.
75. Due to Living.Ai’s acts of infringement, DDL is entitled to compensatory
damages for infringement of its design patents under 35 U.S.C. § 289.
76. Due to Living.Ai’s acts of infringement, DDL is entitled to treble the amount of
compensatory damages for infringement of its design patents under 35 U.S.C. § 284.
77. Due to Living.Ai’s acts of infringement, DDL is entitled to reasonable attorneys’
fees and the costs of this action. An award to DDL of its attorneys’ fees and costs is available
pursuant to 35 U.S.C. § 285.
78. Due to Living.Ai’s acts of infringement, DDL seeks pre-judgment and post-
judgment interest on the above monetary awards and such other and further relief as this Court
deems just and proper.
COUNT III
Trademark Infringement
Digital Dream Labs, LLC vs. Living Ai
80. DDL has acquired the rights to all trademarks associated with Anki, including but
not limited to VECTOR®, and COZMO®, as set forth in U.S. Registered Trademark No.
5,711,131 dated March 26, 2019, see Exhibit D, and U.S. Registered Trademark No. 5842149,
dated August 27, 2019, see Exhibit E.
- 23 -
81. DDL is the owner, by assignment, of the entire right, title, and interest in and to
the VECTOR® trademark and has all rights to sue for infringement of the VECTOR®
trademark.
82. Living.Ai has used and/or is continuing to use VECTOR® in connection with the
advertisement, promotion, and/or sale of the EMO robot, which directly infringes on the
trademark rights exclusively owned and controlled by DDL, without authorization, consent, or
license to do so from DDL.
83. Without DDL’s authorization, consent, or license, but with actual or constructive
knowledge of the well-known, identifiable, and popular desktop robot VECTOR®, and with
knowledge that Living.Ai’s EMO robot was not affiliated, endorsed, or associated with
VECTOR®, Living.Ai utilized the goodwill and consumer recognition of VECTOR® to (i)
advertise, marking, import, promote, distribute, display, and/or offer for sale and/or sell the EMO
robot, (ii) create a false association between DDL and the EMO robot, (iii) create a false
endorsement of the EMO robot by DDL, and (iv) disparage the reputation and goodwill of DDL.
84. Living.Ai’s actions constitute willful infringement of DDL’s trademarks in
violation of 15 U.S.C. § 1114(1)(a) – (b), § 1117(a) – (b), and § 1125.
85. The use of DDL’s product, VECTOR®, in Living Ai’s Facebook® posts and pre-
launch marketing video has caused, and is likely to continue to cause, confusion, mistake, and
deception among the general public as to the origin of the EMO robot, and is likely to deceive
consumers, the public, and the robotics trade into believing that the EMO robot originates from,
is associated with, or is otherwise authorized by DDL, in violation of 15 U.S.C. § 1114(a).
- 24 -
86. Living.Ai’s acts of infringement, as alleged herein and in violation of U.S.
Trademark law, have caused and, unless enjoined by this Court, will continue to cause
irreparable harm to DDL. Further, the threatened and/or actual injuries that DDL has suffered
and/or will suffer are immediate and irreparable. Because of the difficulty in quantifying injury
and harm to DDL’s ability to compete and to maintain a competitive advantage through its
intellectual property, including the infringement of its valid VECTOR® Trademark, damage to
DDL’s business, reputation, valuable rights in and to the VECTOR® product, name and
goodwill associated therewith, monetary damages alone will not fully compensate DDL for such
wrongful conduct. DDL therefore lacks an adequate and complete remedy at law and is entitled
to injunctive relief.
87. Living.Ai’s acts of infringement, as alleged herein and in violation of U.S.
Trademark law, have caused and, unless enjoined by this Court, will continue to cause
irreparable harm to DDL, for which DDL has no adequate remedy at law.
88. Due to Living.Ai’s acts of trademark infringement, as alleged herein, Living.Ai
has obtained direct and indirect commercial and financial benefits and profit they would not
otherwise have realized but for their infringement of the VECTOR® trademark. As such, DDL is
entitled to disgorgement of Living.Ai’s profits and/or financial benefits directly and indirectly
attributable to Living.Ai’s infringement of the VECTOR® trademark in an amount to be
established at trial.
89. Due to Living.Ai’s acts of infringement, DDL is entitled to reasonable attorneys’
fees and the costs of this action.
- 25 -
COUNT IV
Trade Dress
Digital Dream Labs, LLC vs. Living Ai
91. Both the VECTOR® and COZMO® robots are instantly recognizable and have
engendered an excellent reputation and goodwill within the robotics community and consumer
market in the United States. This consumer recognition and goodwill extends to DDL as the
owner and current developer of VECTOR® and COZMO®.
92. Living.Ai’s use of a knockoff duplicate or confusingly similar imitation of both
VECTOR® and COZMO®’s trade dress has caused and is likely to cause confusion, deception,
and mistake by creating the false and misleading impression that Living.Ai’s EMO robot is
manufactured, developed, designed, or distributed by DDL, or is affiliated, connected, or
associated with DDL, or has the sponsorship, endorsement, or approval of DDL.
93. Living.Ai has made false representations, false descriptions, and false
designations of the origin of the EMO robot in violation of 15 U.S.C. § 1125(a), and Living.Ai’s
activities have caused and, unless enjoined by this Court, will continue to cause a likelihood of
confusion and deception of members of the robotics trade and public and, additionally, injury to
DDL’s goodwill and reputation as symbolized by the VECTOR® and COZMO® trade dress.
94. Living.Ai’s acts, as alleged herein and in violation of the Lanham Act, have
caused and, unless enjoined by this Court, will continue to cause irreparable harm to DDL.
Further, the threatened and/or actual injuries that DDL has suffered and/or will suffer are
immediate and irreparable. Because of the difficulty in quantifying injury and harm to DDL,
- 26 -
including damage to DDL’s business, reputation, valuable rights in and to the VECTOR® and
COZMO® products and trade dress, name and goodwill associated therewith, monetary
damages alone will not fully compensate DDL for such wrongful conduct. DDL therefore lacks
an adequate and complete remedy at law and is entitled to injunctive relief.
95. Due to Living.Ai’s conduct, as alleged herein, Living.Ai has obtained direct and
indirect commercial and financial benefits and profit they would not otherwise have realized but
for their infringement of the VECTOR® and COZMO® trade dress. As such, DDL is entitled to
disgorgement of Living.Ai’s profits and/or financial benefits directly and indirectly attributable
to Living Ai’s infringement of the VECTOR® and COZMO® trade dress in an amount to be
established at trial.
96. Living.Ai’s actions demonstrate an intentional, willful, and malicious intent to
trade on the goodwill and trade dress associated with DDL’s VECTOR® and COZMO® robots
to the great and irreparable injury of DDL.
97. Living.Ai’s conduct has caused, and is likely to continue causing, substantial
injury to the public and to DDL, and DDL is entitled to injunctive relief and to recover actual
damages, enhanced profits and damages, costs, and reasonable attorneys’ fees pursuant to 15
U.S.C. § 1116, § 1117, and § 1125(a).
- 27 -
COUNT V
Intentional Interference with Existing and Prospective Business Relationships
99. Living.Ai has acted and continues to act with the intent and for the purpose of
harming and destroying DDL’s business by attempting to interfere, interfering with, and
disrupting DDL’s contractual relationships with its existing and prospective customers.
100. Living.Ai has no right or privilege to interfere with DDL’s present or prospective
contractual and/or business relationships.
101. Living.Ai has intentionally manufactured, marketed, advertised, and offered for
sale an inferior product while materially misrepresenting its association to DDL in a manner that
has harmed, interfered with, and disrupted DDL’s business and business relationship with current
and prospective customers.
102. As a direct result of the intentional and tortious interference by Living.Ai with
DDL’s existing contractual relationships and its attempts to disrupt and interfere with DDL’s
prospective contractual and business relationships, DDL has suffered and will continue to suffer
substantial damages, including but not limited to the impairment or destruction of DDL’s brand,
loss of goodwill and customer relationships, and lost profits.
103. Further, the threatened and/or actual injuries that DDL has suffered and/or will
suffer are immediate and irreparable. Because of the difficulty in quantifying injury and harm to
DDL’s ability to compete and to maintain a competitive advantage through its intellectual
property and valuable existing and prospective customer relationships, as well as the harm
- 28 -
resulting from Living.Ai’s intentional interference with DDL’s contractual relations, monetary
damages alone will not fully compensate DDL for such wrongful conduct. DDL therefore lacks
an adequate and complete remedy at law and is entitled to injunctive relief.
104. As a direct and proximate result of the wrongful and tortious conduct alleged
herein, DDL is in imminent danger of suffering irreparable harm in the form of lost valuable
relationships with its customers and prospective customers; the loss of valuable contracts, sales
opportunities, orders, and profits; the loss of DDL’s goodwill, reputation, and standing in the
business and robotics community; the loss of DDL’s competitive advantage afforded by its
intellectual property rights; and the loss of DDL’s investment of time, money, and other
resources in developing, marketing, advertising, and improving the current products in its
collection.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment as follows:
a. That Defendant, its agents, officers, servants and employees be enjoined
preliminarily and permanently from (i) infringing DDL’s copyrights, patents, trademarks and
trade dress in any manner, specifically those utilized in the design, development, advertisement,
and marketing of EMO, and (ii) interfering with DDL’s existing and prospective customer
relationships;
b. That Defendant, its agents, officers, servants and employees, and those in active
concert or participation with them who receive actual notice of the order by personal service or
otherwise, be enjoined from manufacturing, advertising, marketing, selling, offering for sale
- 29 -
and/or using any products in the United States that infringe on DDL’s copyrights, patents, and/or
trademarks in any manner, including but not limited to the EMO robot;
c. That Plaintiff be awarded all profits of Defendant plus all losses of Plaintiff, plus
any other monetary advantage gained by the Defendant through its infringement, the exact sum
to be proven at trial;
d. That Plaintiff be awarded its attorneys’ fees as available under the Copyright Act,
17 U.S.C. §§ 101, et seq., the Lanham Act, 15 U.S.C. § 1116, § 1117, and § 1125(a), and 35
U.S.C. § 285;
e. That Plaintiff be awarded treble the amount of compensatory damages for
infringement of its design patents under 35 U.S.C. § 284;
f. That Plaintiff be awarded any other enhanced statutory damages permitted by
law;
g. That Defendant accounts to Plaintiff for its profits and any damages sustained by
Plaintiff arising from the foregoing acts of infringement;
h. That Plaintiff be awarded pre-judgment and post-judgment interest on the above
monetary awards;
i. That Plaintiff be awarded punitive damages against Defendant;
j. That Plaintiff be awarded the costs of this action;
k. That Plaintiff be awarded such further legal and equitable relief as the Court
deems proper;
- 30 -
A JURY TRIAL IS DEMANDED
Date: October 5, 2020 Respectfully submitted,
MEYER, UNKOVIC & SCOTT LLP
By: /s/ David G. Oberdick
David G. Oberdick, Esquire

Pa. I.D. No. 47648
Email: dgo@muslaw.com
Tony J. Thomson, Esquire
Pa I.D. No. 204609
Email: tjt@muslaw.com
Katelin J. Montgomery, Esquire

Pa. I.D. No. 3226988
Email: kjm@muslaw.com
535 Smithfield Street, Suite 1300

Pittsburgh, PA 15222
Phone – 412 456 2800
Fax – 412 446 2864
ATTORNEYS FOR PLAINTIFFS
- 31 -
Case 2:20-cv-01500-DSC Document 1-1 Filed 10/05/20 Page 1 of 3
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

DIGITAL DREAM LABS, LLC., LIVING TECHNOLOGY (SHENZHEN) CO., LTD. d/b/a LIVING.AI and
EMO PET
(b) County of Residence of First Listed Plaintiff Allegheny County of Residence of First Listed Defendant Guangdong Province, ROC
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
David G. Oberdick, Esquire, Meyer, Unkovic & Scott LLP Aron Chunrong LI, Benny Kong & Tsai Solicitors, 19B, OTB Building,
535 Smithfield Street, Suite 1300, Pittsburgh, PA 15222 160 Gloucester Road, Hong Kong
412.456.2851
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
17 U.S.C. Section 101, et seq.; 35 U.S.C. Section 1, et seq.; 15 U.S.C. Section 1125
VI. CAUSE OF ACTION Brief description of cause:
Copyright, patent, and trademark infringement for toy robot product.
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 500,000.00 plus JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
10/05/2020 David G. Oberdick, Tony J. Thompson & Katelin J. Montgomery
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
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JS 44A REVISED June, 2009

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
THIS CASE DESIGNATION SHEET MUST BE COMPLETED
PART A
This case belongs on the ( Erie Johnstown Pittsburgh) calendar.
1. ERIE CALENDAR - If
cause of action arose in the counties of Crawford, Elk, Erie,
Forest, McKean. Venang or Warren, OR any plaintiff or defendant resides in one of said
counties.
2. JOHNSTOWN CALENDAR - If cause of action arose in the counties of Bedford, Blair,
Cambria, Clearfield or Somerset OR any plaintiff or defendant resides in one of
said counties.
3. Complete if on ERIE CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
4. Complete if on JOHNSTOWN CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
PART B (You are to check ONE of the following)

1. This case is related to Number . Short Caption .
2. This case is not related to a pending or terminated case.
DEFINlTIONS OF RELATED CASES:

CIVIL: Civil cases are deemed related when a case filed relates to property included in
another suit or involves the same issues of fact or it grows out of the same transactions
as another suit or involves the validity or infringement of a patent involved in another
suit EMINENT DOMAIN: Cases in contiguous closely located groups and in common ownership
groups which will lend themselves to consolidation for trial shall be deemed related.
HABEAS CORPUS & CIVIL RIGHTS: All habeas corpus petitions filed by the same individual
shall be deemed related. All pro se Civil Rights actions by the same individual shall be
deemed related.
PARTC
I. CIVIL CATEGORY (Select the applicable category).
1. Antitrust and Securities Act Cases
2. Labor-Management Relations
3. Habeas corpus
4. Civil Rights
5. Patent, Copyright, and Trademark
6. Eminent Domain
7. All other federal question cases
8. All personal and property damage tort cases, including maritime, FELA,
Jones Act, Motor vehicle, products liability, assault, defamation, malicious
prosecution, and false arrest
9. Insurance indemnity, contract and other diversity cases.
10. Government Collection Cases (shall include HEW Student Loans (Education),
V A 0verpayment, Overpayment of Social Security, Enlistment
Overpayment (Army, Navy, etc.), HUD Loans, GAO Loans (Misc. Types),
Mortgage Foreclosures, SBA Loans, Civil Penalties and Coal Mine
Penalty and Reclamation Fees.)
I certify that to the best of my knowledge the entries on this Case Designation
Sheet are true and correct
David G. Oberdick
Date: 10/5/2020
ATTORNEY AT LAW
NOTE: ALL SECTIONS OF BOTH )2506 MUST BE COMPLETED BEFORE CASE CAN BE PROCESSED.
JS 44 Reverse (Rev. 06/17) Case 2:20-cv-01500-DSC Document 1-1 Filed 10/05/20 Page 3 of 3
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.
V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Generated on: This page was generated by TSDR on 2020-10-05 09:46:09 EDT
Mark: VECTOR
US Serial Number: 87768021 Application Filing Jan. 24, 2018

Date:
US Registration 5711131 Registration Date: Mar. 26, 2019
Number:
Filed as TEAS RF: Yes Currently TEAS RF: Yes
Register: Principal
Mark Type: Trademark
TM5 Common Status LIVE/REGISTRATION/Issued and Active
Descriptor:
The trademark application has been registered with the Office.
Status: Registered. The registration date is used to determine when post-registration maintenance documents are due.
Status Date: Mar. 26, 2019
Publication Date: Oct. 30, 2018 Notice of Dec. 25, 2018
Allowance Date:
Mark Information
Mark Literal VECTOR
Elements:
Standard Character Yes. The mark consists of standard characters without claim to any particular font style, size, or color.
Claim:
Mark Drawing 4 - STANDARD CHARACTER MARK
Type:
Goods and Services

Note:
The following symbols indicate that the registrant/owner has amended the goods/services:
Brackets [..] indicate deleted goods/services;
Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and
Asterisks *..* identify additional (new) wording in the goods/services.
For: Humanoid robots with artificial intelligence for entertainment purposes; downloadable mobile applications for controlling and interacting
with humanoid robots for entertainment purposes, and not for industrial purposes, by allowing the user to set up and view status of the
humanoid robot
International 009 - Primary Class U.S Class(es): 021, 023, 026, 036, 038
Class(es):
Class Status: ACTIVE
Basis: 1(a)
First Use: Oct. 18, 2018 Use in Commerce: Oct. 18, 2018
For: Toy robots and smart robot toys

International 028 - Primary Class U.S Class(es): 022, 023, 038, 050
Class(es):
Class Status: ACTIVE
Basis: 1(a)
First Use: Oct. 18, 2018 Use in Commerce: Oct. 18, 2018
Basis Information (Case Level)

Filed Use: No Currently Use: Yes
Filed ITU: Yes Currently ITU: No

Filed 44D: No Currently 44E: No
Filed 44E: No Currently 66A: No
Filed 66A: No Currently No Basis: No
Filed No Basis: No
Current Owner(s) Information

Owner Name: ANKI, INC.
Owner Address: 100 SOUTH COMMONS
PITTSBURGH, PENNSYLVANIA UNITED STATES 15212
Legal Entity Type: CORPORATION State or Country DELAWARE
Where Organized:
Attorney/Correspondence Information
Attorney of Record
Attorney Name: David G. Oberdick Docket Number: 280986.352
Attorney Primary dgo@muslaw.com Attorney Email Yes
Email Address: Authorized:
Correspondent
Correspondent David G. Oberdick
Name/Address: Meyer, Unkovic & Scott LLP
535 Smithfield Street
Suite 1300
Pittsburgh, PENNSYLVANIA UNITED STATES 15222
Phone: 412-456-2881 Fax: 412-456-2864
Correspondent e- dgo@muslaw.com tma@muslaw.com Correspondent e- Yes
mail: mail Authorized:
Domestic Representative - Not Found
Prosecution History
Proceeding
Date Description
Number
Sep. 15, 2020 APPLICANT/CORRESPONDENCE CHANGES (NON-RESPONSIVE) ENTERED 88888
Sep. 15, 2020 TEAS CHANGE OF CORRESPONDENCE RECEIVED
Sep. 15, 2020 TEAS WITHDRAWAL OF ATTORNEY RECEIVED-FIRM RETAINS
Sep. 15, 2020 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
Sep. 15, 2020 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
Sep. 15, 2020 TEAS CHANGE OF OWNER ADDRESS RECEIVED
Mar. 26, 2019 REGISTERED-PRINCIPAL REGISTER
Feb. 22, 2019 NOTICE OF ACCEPTANCE OF STATEMENT OF USE E-MAILED
Feb. 21, 2019 ALLOWED PRINCIPAL REGISTER - SOU ACCEPTED
Feb. 02, 2019 STATEMENT OF USE PROCESSING COMPLETE 74055
Jan. 08, 2019 USE AMENDMENT FILED 74055
Feb. 02, 2019 CASE ASSIGNED TO INTENT TO USE PARALEGAL 74055
Jan. 08, 2019 TEAS STATEMENT OF USE RECEIVED
Dec. 25, 2018 NOA E-MAILED - SOU REQUIRED FROM APPLICANT
Oct. 30, 2018 OFFICIAL GAZETTE PUBLICATION CONFIRMATION E-MAILED
Oct. 30, 2018 PUBLISHED FOR OPPOSITION
Oct. 10, 2018 NOTIFICATION OF NOTICE OF PUBLICATION E-MAILED
Sep. 21, 2018 ASSIGNED TO LIE 70633
Sep. 06, 2018 APPROVED FOR PUB - PRINCIPAL REGISTER
Aug. 23, 2018 TEAS/EMAIL CORRESPONDENCE ENTERED 88889
Aug. 22, 2018 CORRESPONDENCE RECEIVED IN LAW OFFICE 88889
Aug. 22, 2018 TEAS RESPONSE TO OFFICE ACTION RECEIVED
Jul. 12, 2018 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
Jul. 12, 2018 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED

Mar. 14, 2018 NOTIFICATION OF NON-FINAL ACTION E-MAILED 6325
Mar. 14, 2018 NON-FINAL ACTION E-MAILED 6325
Mar. 14, 2018 NON-FINAL ACTION WRITTEN 76581
Mar. 12, 2018 ASSIGNED TO EXAMINER 76581
Feb. 03, 2018 NEW APPLICATION OFFICE SUPPLIED DATA ENTERED IN TRAM
Jan. 27, 2018 NEW APPLICATION ENTERED IN TRAM
TM Staff and Location Information

TM Staff Information - None
File Location
Current Location: PUBLICATION AND ISSUE SECTION Date in Location: Feb. 21, 2019
Assignment Abstract Of Title Information

Summary
Total Assignments: 2 Registrant: ANKI, INC.
Assignment 1 of 2
Conveyance: SECURITY INTEREST

Reel/Frame: 6307/0004 Pages: 19
Date Recorded: Apr. 04, 2018
Supporting assignment-tm-6307-0004.pdf
Documents:
Assignor
Name: ANKI, INC. Execution Date: Mar. 30, 2018
Where Organized:
Assignee
Name: SILICON VALLEY BANK
Legal Entity Type: CORPORATION State or Country CALIFORNIA
Where Organized:
Address: 275 GROVE STREET
SUITE 2-200
NEWTON, MASSACHUSETTS 02466
Correspondent
Correspondent JOANNA MCCALL
Name:
Correspondent 1025 VERMONT AVE NW, SUITE 1130
Address: COGENCY GLOBAL INC.
WASHINGTON, DC 20005
Assignment 2 of 2
Conveyance: RELEASE BY SECURED PARTY

Reel/Frame: 6831/0225 Pages: 11
Date Recorded: Jan. 06, 2020
Supporting assignment-tm-6831-0225.pdf
Documents:
Assignor
Name: SILICON VALLEY BANK Execution Date: Dec. 30, 2019
Legal Entity Type: CORPORATION State or Country CALIFORNIA
Where Organized:
Assignee
Name: ANKI, INC.
Where Organized:
Address: 55 2ND STREET
FLOOR 15
SAN FRANCISCO, CALIFORNIA 94105
Correspondent
Correspondent DAVID G. OBERDICK
Name:
Correspondent 535 SMITHFIELD STREET
Address: SUITE 1300
PITTSBURGH, PA 15222
Reg. No. 5,711,131 ANKI, INC. (DELAWARE CORPORATION)

55 Second Street, 15th Floor
Registered Mar. 26, 2019 San Francisco, CALIFORNIA 94105
CLASS 9: Humanoid robots with artificial intelligence for entertainment purposes;

Int. Cl.: 9, 28 downloadable mobile applications for controlling and interacting with humanoid robots for
entertainment purposes, and not for industrial purposes, by allowing the user to set up and
Trademark view status of the humanoid robot
Principal Register FIRST USE 10-18-2018; IN COMMERCE 10-18-2018
CLASS 28: Toy robots and smart robot toys
FIRST USE 10-18-2018; IN COMMERCE 10-18-2018
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY

PARTICULAR FONT STYLE, SIZE OR COLOR
SER. NO. 87-768,021, FILED 01-24-2018

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION
WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
Requirements in the First Ten Years*

What and When to File:
First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.
Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.
Requirements in Successive Ten-Year Periods*

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*
Grace Period Filings*
The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.
*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an

extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.
NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.
NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.
Page: 2 of 2 / RN # 5711131
Reg. No. 5,842,149 ANKI, INC. (DELAWARE CORPORATION)

55 Second Street, 15th Floor
Registered Aug. 27, 2019 San Francisco, CALIFORNIA 94105
CLASS 28: Toy robots and smart robot toys

Int. Cl.: 28
FIRST USE 10-14-2016; IN COMMERCE 10-14-2016
Trademark
The color(s) Light yellow and dark yellow is/are claimed as a feature of the mark.
Principal Register
The mark consists of the stylized wording "COZMO" with a color gradient from light yellow
to dark yellow from top to bottom of each letter.
SER. NO. 87-796,062, FILED 02-13-2018

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION
WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
Requirements in the First Ten Years*

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.
Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.
Requirements in Successive Ten-Year Periods*

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*
Grace Period Filings*
The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.
*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an

extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.
NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.
NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.
Page: 2 of 2 / RN # 5842149
Writer’s direct dial phone number and e-mail address:

412-456-2881 ~ dgo@muslaw.com
September 18, 2020
Via Federal Express and electronic mail:
Living AI 7H
Centre Avenue Mansion Block D
Yuehe Rd. Baoan District,
Shenzhen, Guangdong 518000
CHINA
Email: emopet@living.ai
RE: Notice of Infringement of Intellectual Property Rights of Digital Dream

Labs, LLC (“DDL”)
Dear Sir or Madam:
We serve as intellectual property and litigation counsel to DDL. DDL has acquired the
intellectual property of Anki, Inc., including without limitation, patents and trademarks, relating
to the design and function of VECTOR and COZMO robots. In this capacity, we have been made
aware of your efforts to promote an EMO robot by use of social media including Facebook and
Instagram. We further understand that you plan a Kickstarter campaign for EMO.
Please be advised that the design and functions of EMO violate the intellectual property
rights of DDL in various respect, including, without limitation:
1. Violation and infringement of U.S. design patents, including without limitation,

U.S. Patents Nos. D811,496, D812154, and D812,153.
2. Violation and infringement of U.S. and foreign utility patents, including, without
limitation, U.S. Patent Nos. 9,155,961, 9,919,232, 9,177,239, and 9,996,369, together with other
pending applications in at least the United States and China.
3. Violation and infringement of copyrights relating to the design of the VECTOR

robot and also video and audio files created by DDL for promotion of COZMO.
Living AI 7H
Page 2
September 18, 2020
4. Violation and infringement of the VECTOR trademark. Among other infringing

behavior, you and your company are using this mark without permission and are falsely asserting
an association with and/or endorsement by DDL and its VECTOR robot.
5. Violation and infringement of trade dress relating to the VECTOR and COZMO
robots.
Accordingly, demand is made that you immediately cease and desist from any sale, offer
to sell, making, importing, and promotion of the EMO robot. I understand that you are already
aware that DDL has taken action with Facebook Absent compliance, DDL reserves all rights to
pursue injunctive relief and claims for money damages based on knowing and willful infringement
of DDL’s intellectual property rights, and continued infringement will trigger all consequences
associated with willful and intentional infringement.
Very truly yours,
David G. Oberdick
David G. Oberdick
DGO/lam
cc: Mr. Jacob Hanchar

MUS3678183.1

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Case 2:20-cv-01500-DSC Document 1 Filed 10/05/20 Page 1 of 31

IN THE UNITED STATES DISTRICT COURT

DIGITAL DREAM LABS, LLC., )

Emo Pet, stating as follows:

always learning and updating with new skills and features.

4. DDL is not opposed to competition in the marketplace for toy robots

of business at 100 South Commons, Pittsburgh, PA 15212. DDL is a technology education

VECTOR® and COZMO®, pictured below in that order.

6. Upon information and belief, Defendant Living.Ai is a Chinese corporation with

two different angles.

JURISDICTION AND VENUE

trademark infringement claims under 28 U.S.C. §§ 1331 and 1338(a).

as its federal statutory claims.

acts and torts.

misappropriation against DDL in this judicial district.

allowing people to build relationships with technology.

VECTOR® Kickstarter page is accessible here:

kind?ref=discovery&term=ANKI. This date is relevant because the design of EMO began to

earlier design of COZMO®

referred to as the “DDL Patents.”

II. Living.Ai’s Infringement of DDL’s Patents, Copyrights, and Trademarks

launch marketing video to YouTube®.

original pre-launch marketing video can be seen below:

moderator replied by identifying VECTOR® and EMO as friends, including as follows:

Trademark. More specifically, these various references to VECTOR® created, at a minimum, a

photograph) can be seen below:

2020, https://www.youtube.com/watch?v=AnzUvRBc094&feature=youtu.be, last visited

September 5, 2020, https://www.youtube.com/watch?v=ebEc8NpnyVE, last visited October 2,

of Digital Dream Labs, this is a serious crime.”).

VECTOR® and COZMO® eyes and head.

31. Placing VECTOR® and EMO in a side-by-side comparison, as was done in

interests, dated September 1, 2020:

34. As demonstrated above, it is nearly impossible to distinguish between the head,

version of VECTOR® that Living.Ai intends to sell at a discounted price.

designed by Living.Ai to signify to consumers, particularly those consumers familiar with

VECTOR® and/or other DDL products.

and recorded solely for the COZMO® robot.

37. The tables below (collectively referred to as the “Copyright Tables”)

found on the Living.Ai website:

EMO by Living.Ai COZMO® by DDL

EMO by Living.Ai COZMO® by DDL

“Wow” 0:18 seconds 0:13 seconds

“Curious” 0:21 seconds 0:04, 0:11 – 0:13 seconds

EMO by Living.Ai COZMO® by DDL

“Giggle” 0:14 seconds 1:38 -1:40

“Wow” 0:18 seconds 1:34 – 1:36

“Thought” 0:51 seconds 0:11 seconds

Comparison”, dated September 15, 2020, https://www.youtube.com/watch?v=ES52kcuW0dk

(last visited October 2, 2020).

to directly copy the VECTOR® robot and COZMO® audio sounds.

42. Living.Ai’s egregious infringement of DDL’s trademarks, trade dress copyrights,

III. Pre-Suit Notice of Infringing Behavior and DDL’s Removal of Online

material posted in one Living.Ai social media site is below:

44. As a result of its notices/complaints, the infringing content produced and

“Indiegogo China: Your Fast Track to the Global Market”,

https://entrepreneur.indiegogo.com/how-it-works/indiegogo-china/ (last visited October 1, 2020).

infringements detailed above.

Living.Ai’s global launch of EMO, including the United States .2

Living.Ai website (second photograph below):

These third-party websites include: https://comingsoon.higizmos.com/emo and

as though the same were fully set forth herein.

806, at Exhibits F and G, respectively.

sounds that are protected by the DDL Copyrights.

57. More specifically, Living.Ai infringed DDL’s copyrights by integrating