FILED IN CLERK'S OFFICE

U.S.D.C. Atlanta
Jury Trial Demanded
1
5 IL ACTION NO.
3- C-V- 3224
Plaintiffs,
Defendants.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
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PLAYRAPID EURL
vs.
a French Corporation
a French Corporation,
and
BURN CONTROLLERS
a U.K. Corporation,
SCUFGAMING
INTERNATIONAL, LLC,
a Georgia Corporation
and
IRONBURG INVENTIONS LTD.
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs, Scuf Gaming International, LLC and Ironburg Inventions Ltd. by
and through their undersigned attorney, and pursuant to Federal Rule of Civil
Procedure 8(a), on information and belief, allege the following in support of their
Complaint for patent infringement against Defendants:
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PARTIES
1. Plaintiff Ironburg Inventions Ltd. ("Ironburg") is a company
organized and existing under the laws of England having its principal place of
business at 10 Market Place, Wincanton, Somerset, Great Britain.
2. Within the United States, Ironburg conducts business by and through
Scuf Gaming International, LLC ("Scuf Gaming").
3. Plaintiff, Scuf Gaming is a corporation organized and existing under
the laws of the State of Georgia, having its principal place of business at 141 W.
Wieuca Road NE 202B, Atlanta, Georgia 30342.
4. Defendant, Playrapid EURL ("Playrapid") is a corporation organized
and existing under the laws of France, having a principal place of business at 4
Street Press, 13150 Tarascon, France.
5. Defendant, BURN Controllers ("BURN") is a corporation organized
and existing under the laws of France having principal places of business at 210
Route des Cayades, 13150 Tarascon, France and/or 25 Avenue Des Artisans,
13150 Tarascon, France.
6. Defendant Playrapid is the parent company of BURN Controllers.
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JURISDICTION AND VENUE
7. This is a Complaint for patent infringement arising under the patent
laws of the United States, Title 35 of the United States Code.
8. This Court has original jurisdiction under 28 U.S.C. 1338 over this
patent infringement action.
9. Each of the Defendants has committed acts and continues to commit
acts within this judicial district giving rise to this action. Venue is proper under 28
U.S.C. 1391(b) and 1400(b).
FACTUAL BACKGROUND
10. Plaintiff Scuf Gaming is a Georgia corporation established on July 20,
2011.
11. Plaintiff Scuf Gaming is the manufacturer, wholesaler, retailer, and
restorer of custom video game equipment and accessories, including video game
controllers ("gaming controllers").
12. Plaintiff Scuf Gaming has made significant investments in human
capital in this endeavor, employing more than 45 people within this District.
13. Plaintiff Scuf Gaming has invested more than two million dollars in
marketing and other operational expenses in connection with its gaming controller
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business.
14. As a result, Plaintiff Scuf Gaming has earned total revenues exceeding
ten million dollars since its establishment.
15. Plaintiff Scuf Gaming has an inventory of more than five hundred and
fifty thousand dollars ($550,000) worth of gaming controller inventory ordered to
meet forecasted customer demand until the introduction of new gaming controller
consoles scheduled to be released for the popular Xbox and PlayStation platforms
at the end of2013.
16. Defendants are presently making, using, importing, marketing and/or
selling gaming controllers in the United States, which gaming controllers
incorporate Plaintiffs' patented technology.
17. In fact, Defendants have sold gaming controllers in this District,
which gaming controllers incorporate Plaintiffs' patented technology.
THE PATENTS IN SUIT
18. On July 9, 2013, United States Patent No. 8,480,491, entitled "GAME
CONTROLLER" was duly and legally issued to Plaintiff Ironburg, a copy of
which is annexed hereto as Exhibit A.
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19. On September 25, 2012, United States Patent No. D677,892, entitled
"GAME CONTROLLER" was duly and legally issued to Plaintiff Ironburg, a copy
of which is annexed hereto as Exhibit B.
20. Plaintiff Ironburg is the owner of rights in and to United States Patent
Nos. 8,480,491 and D677,892 (collectively, the patents-in-suit) sufficient to bring
this action.
21. Plaintiff Scuf Gaming is the exclusive licensee of the patents-in-suit,
in the U.S.
COUNT I. INFRINGEMENT OF U.S. PATENT NO. 8,480,491
22. Plaintiff repeats and realleges Paragraphs 1 through 21 of this
Complaint as if fully set forth herein.
23. Defendants manufacture and retail custom video game equipment,
including gaming controllers.
24. Defendants' website and Twitter social media account promote the
sale of the gaming controllers with delivery to intemationallocations, including the
United States. EXHIBIT C.
25. Components of gaming controllers manufactured, sold and/or offered
by Defendants in the United States ("the Accused Products") are substantially
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similar to the invention disclosed and claimed III United States Patent No.
8,480,491. EXHIBIT D.
26. The gaming controllers manufactured, sold and/or offered by
Defendants ("the Accused Products") include each and every element recited in
some or all of the claims of United States Patent No. 8.480,491.
27. Defendant BURN has offered for sale and sold gaming controllers
within this District and elsewhere, gaming controllers which infringe United States
Patent No. 8.480,491. For example, Exhibit E.
28. Plaintiff Ironburg and Defendant BURN are currently engaged in
litigation disputes in France over substantially identical gaming controller features
patented by United States Patent No. 8,480,491.
29. Accordingly, Defendants are aware that Plaintiffs consider the
patented technology to be proprietary to Plaintiffs.
30. Defendants have constructive and actual knowledge of the existence
of United States Patent No. 8,480,491.
31. Despite Defendants' full knowledge of Plaintiff Ironburg's claim to
and ownership of proprietary rights to the patented features, the Defendants
knowingly and willfully sold or offered to sell the Accused Products within the
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United States.
32. As a result of Defendants' foreknowledge of the Plaintiffs' patent
rights and willful disregard, Plaintiffs have suffered and will continue to suffer
grievous damage.
33. Defendants' infringement of United States Patent No. 8,480,491 will
continue unless and until enjoined by this Court.
34. Pursuant to 35 U.S.C. 281, Plaintiffs are entitled to recover damages
from Defendants to compensate them for Defendants' infringement of the '491
Patent.
COUNT II. INFRINGEMENT OF U.S. DESIGN PATENT NO. D677,892
35. Plaintiff repeats and realleges Paragraphs 1 through 34 of this
Complaint as if fully set forth herein.
36. Defendants manufacture and retail custom video game equipment,
including gaming controllers.
37. Defendants' website and Twitter social media account promote the
sale of the gaming controllers with delivery to intemationallocations, including the
United States.
38. Gaming controllers manufactured, sold and/or offered by Defendants
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include features ("the Accused Designs") that are substantially similar to the
design claimed in United States Patent No. D677,892.
39. The substantial similarity between the Accused Designs and the
Plaintiffs' patented design is such that that a purchaser familiar with the prior art
would be deceived. See, for example, Exhibit F.
40. The substantial similarity between the Accused Designs and the
Plaintiffs' patented design is such that that a purchaser familiar with the prior art
would be induced to purchase Defendants' gaming controllers supposing them to
be the product of Plaintiffs.
41. Defendants have offered for sale and sold gaming controllers within
this District and elsewhere, gaming controllers that include the Accused Designs,
which infringe United States Patent No. D677,892.
42. Plaintiff Ironburg and Defendant BURN are currently engaged in
litigation disputes in France over substantially identical gaming controller designs
patented by United States Patent No. D677,892.
43. Despite Defendants' full knowledge of Plaintiff Ironburg's claim to
and ownership of proprietary rights to the patented designs, the Defendants
knowingly and willfully sold or offered to sell products incorporating the Accused
Designs within the United States.
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44. As a result of Defendants' foreknowledge of the Plaintiffs' patent
rights and willful disregard, Plaintiffs have suffered and will continue to suffer
grievous damage.
45. Defendants' infringement of United States Patent No. D677,892 will
continue unless and until enjoined by this Court.
46. Pursuant to 35 U.S.C. 281, Plaintiffs are entitled to recover damages
from Defendants to compensate them for Defendants' infringement of United
States Patent No. D677,892.
DEMAND FOR JURy TRIAL
47. Pursuant to Rule 38 of the Federal Rule of Civil Procedure, Plaintiffs
demand trial by jury on all claims asserted herein.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for:
A. A finding by this Court that Defendants have infringed United States
Patent Nos. 8,480,491 and D677,892 and that said infringement has been willful;
B. An order permanently enjoining Defendants and their officers, agents,
servants, employees and attorneys and all other persons acting in concert or in
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participation with Defendants from infringing Plaintiffs United States Patent Nos.
8,480,491 and D677,892;
C. An award against Defendants for the damages suffered by Plaintiffs as a
result of Defendants' acts of infringement with prejudgment interest thereon;
D. An assessment of up to three (3) times the damages so determined,
pursuant to 35 U.S.C. 284;
E. An award to Plaintiffs of attorney's fees, costs and expenses in this
action; and
F. That this Court grant such other and further relief as this Court may deem
just.
Respectfully submitted,
a Parks
Geo ia Bar No. 563,929
cparks@parksiplaw.com
Parks IP Law LLC
730 Peachtree Street NE, Suite 600
Atlanta, Georgia 30308
Direct Line: (678) 365- 4455
Main Line: (678) 365-4444
Facsimile: (678) 365-4450
Attorney for Plaintiffs Ironburg Inventions
LTD, and Scuf Gaming International, LLC
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(Rev. 1/13 NDGA) CIVIL COVER SHEET1 1 - f'Jl- "Z "")2Jt
Tbe JS44 civil cover sbeet and tbe information contained berein neitber replace nor supplement tbe filing and service of plea mttfr otber I-Ie s requir"..ty_
provided by local rules of court. This form is required for tbe use of the Clerk of Court for tbe purpose of initiating tbe civil docket record. (SEE INSTRUCTIONS ATIAC D)
I. (a) PLAINTIFF(S)
Scuf Gaming International, LLC and
lronburg Inventions Ltd.
DEFENDANT(S)
Playrapid EURL and
Burn Controllers
(b) COUNTY OF RESIDENCE OF FIRST LISTED
PLAINTIFF_F_Wton _
(EXCEPT IN us, PLAINTIFF CASES)
COUNTY OF RESIDENCE OF FIRST LISTED
DEFENDANT _
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LANDCONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF
LANDINVOLVED
(c) ATTORNEYS (FIRM NAME, ADDRESS, TELEPHONE NUMBER, AND
E-MAIL ADDRESS)
ATTORNEYS (IFKNOWN)
Cynthia Parks, Parks IP Law LLC
730 Peachtree St. NE, Suite 600, Atlanta, GA
30308
(678) 365-4455 - direct
cparks@parksiplaw.com

.lit ..
II. BASIS OF JURISDICTION
(pLACE ANX" IN ONE BOX ONLY)
III. CITIZENSmp OF PRINCIPAL PARTIES
(pLACE ANX" IN ONE BOX FOR PLAINTIFF ANDONE BOX FOR DEFENDANT)
(FOR DIVERSITY CASES ONLY)
CITIZEN OF THIS STATE D4 D 4
CITIZEN OF ANOTHER STATEDs OS
CITIZEN OR SUBJECT OF ADD
FOREIGN COUNTRY 6 6 FOREIGN NATION
INCORPORATED OR PRINCIPAL
PLACE OF BUSINESS INTillS STATE
INCORPORATED ANDPRINCIPAL
PLACE OF BUSINESS IN ANOTIIER
STATE
DEF PLF PLF DEF

3 FEDERAL QUESTION
(U.S. GOVERNMENT NOT A PARTY)
D 4 DIVERSITY
(INDICATE CITIZENSHIP OF PARTIES
IN ITEM III)
o1 U.S. GOVERNMENT
PLAINTIFF
D 1 U.S. GOVERNMENT
DEFENDANT
IV. ORIGIN (PLACEAN"X"INONEBOXONLy)
TRANSFERRED FROM
.1ORIGINAL 01 REMOVED FROM 03REMANDED FROM n 4 REINSTATED OR OSANOTHER DISTRICT 06MULTIDISTRICT
PROCEEDING STATE COURT APPELLATECOURt-J REOPENED (SpeclfyDlIlrtct) LITIGATION
O
APPEAL TO DISTRICT JUDGE
7 FROM MAGISTRATE JUDGE
JUDGMENT
V. CAUSE OF ACTION (CITE TIlE u.s.CIVIL STATUTE UNDERWHICH YOU ARE FILING ANDWRITE A BRIEF STATEMENT OF CAUSE - DO NOT CITE
JURISDICTIONAL STATUTES UNLESSDIVERSITY)
The cause of action is patent infringement of U.S. Patent No. 8,480,491 and U.S. Patent No.
0667,892. The cause of action is governed by 35 U.S.C. sec. 271, 35 U.S.C sect 1391, and 35
U.S.C. sec.1400.
(IF COMPLEX, CHECK REASON BELOW)
D 1. Unusually large number ofparties.
D 2. Unusually large number of claims or defenses.
D 3. Factual issues are exceptionally complex
D 4. Greater than normal volume of evidence.
D 5. Extended discovery period is needed.
D 6. Problems locating or preserving evidence
D 7. Pending parallel investigations or actions by government.
D 8. Multiple use of experts.
9. Need for discovery outside United States boundaries.
D 10. Existence ofhighly technical issues and proof.
CONTINUED ON REVERSE
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VI. NATURE OF SUIT (pLACE AN"X" IN ONE BOX ONLY)
CONTRACT - "0" MONTHS DISCOVERY TRACK
0150 RECOVERYOF OVERPAYMENT&
ENFORCEMENTOF JUDGMENT
0152 RECOVERYOF DEFAULTED STUDENT
LOANS(Excl, Veterans)
0153 RECOVERYOF OVERPAYMENTOF
VETERAN'SBENEFITS
CONTRACT - "4" MONTHS DISCOVERY TRACK
B
I 10INSURANCE
120MARINE
0130 MILLERACT
0140 NEGOTIABLEINSTRUMENT
[JlSI MEDICAREACT
[J160 STOCKHOLDERS'SUITS
[J190OTHERCONTRACT
0195 CONTRACTPRODUCTLIABILITY
0196 FRANCHISE
REAL PROPERTY - "4" MONTHS DISCOVERY
TRACK
--0210LANDCONDEMNATION
[J220 FORECLOSURE
0230 RENT LEASE& EJECTMENT
0240 TORTS TO LAND
0245 TORT PRODUCTLIABILITY
[J290 ALL OTHERREAL PROPERTY
TORTS - PERSONAL INmRY - "4" MONTHS
DISCOVERY TRACK
0310 AIRPLANE
0315 AIRPLANEPRODUCTLIABILITY
0320 ASSAULT, LIBEL& SLANDER
[J330 FEDERALEMPLOYERS'LIABILITY
0340 MARINE
0345 MARINEPRODUCTLIABILITY
0350 MOTORVEHICLE
0355 MOTORVEHICLEPRODUCTLIABILITY
0360 OTHERPERSONALINJURY
0362 PERSONALINJURY- MEDICAL
MALPRACTICE
[J365 PERSONALINJURY- PRODUCT LIABILITY
0367 PERSONALINJURY- HEALTHCAREl
PHARMACEUTICAL PRODUCTLIABILITY
[J368ASBESTOSPERSONALINJURYPRODUCT
LIABILITY
TORTS - PERSONAL PROPERTY - "4" MONTHS
DISCOVERY TRACK
370 OTHERFRAUD
371 TRUTHIN LENDING
380 OTHERPERSONALPROPERTYDAMAGE
[J385 PROPERTYDAMAGEPRODUCT LIABILITY
BANKRUPTCY - "0" MONTHS DISCOVERY TRACK
0422 APPEAL28 USC 158
0423 WITHDRAWAL28 USC157
CIVIL RIGHTS - "4" MONTHS DISCOVERY TRACK
0441 VOTING
0442 EMPLOYMENT
0443 HOUSING!ACCOMMODATIONS
0444 WELFARE
[J440 OTHER CIVIL RIGHTS
0445 AMERICANSwithDISABILITIES Employment
0446 AMERICANSwithDISABILITIES Other
0448 EDUCATION
IMMIGRAnON - "0" MONTHS DISCOVERY TRACK
462 NATURALIZATIONAPPLICATION
465 OTHERIMMIGRATIONACTIONS
PRISONER PETITIONS - "0" MONTHS DISCOVERY
TRACK
HABEASCORPUS AlienDetainee
8
510MOTIONSTOVACATESENTENCE
530HABEASCORPUS
0535 HABEASCORPUSDEATHPENALTY
0540 MANDAMUS& OTHER
0550 CIVIL RIGHTS- FiledPro se
0555 PRISONCONDITION(S) - FiledPro se
0560 CIVILDETAINEE: CONDITIONSOF
CONFINEMENT
PRISONER PETITIONS - "4" MONTHS DISCOVERY
TRACK
CIVIL RIGHTS FiledbyCounsel
0555 PRISONCONDITION(S)- FiledbyCounsel
FORFEITUREIPENALTY - "4" MONTHS DISCOVERY
TRACK
--0625DRUGRELATEDSEIZUREOF PROPERTY
21 USC881
0690 OTHER
LABOR - "4" MONTHS DISCOVERY TRACK
0710 FAIRLABORSTANDARDSACT
0720 LABOR/MGMT.RELATIONS
0740 RAILWAYLABORACT
0751 FAMILYand MEDICALLEAVEACT
B
790 OTHERLABORLITIGATION
791 EMPL. RET. INC. SECURITYACT
PROPERTY RIGHTS - "4" MONTHS DISCOVERY TRACK
8820 COPYRIGHTS
840 TRADEMARK
PROPERTY RIGHTS - "8" MONTHS DISCOVERY TRACK
1Zl830 PATENT
SOCIAL SECURITY - "0" MONTHS DISCOVERY
TRACK
--0861 HIA(1395/1)
0862 BLACKLUNG(923)
0863 DIWC(405(8
0863 DIWW(405(8
0864 ssmTITLEXVI
0865 RSI (405(g
FEDERAL TAX SUITS - "4" MONTHS DISCOVERY
TRACK
---c:J870 TAXES (U.S. P1aintifforDefendant)
0871 IRS - THIRDPARTY26 USC7609
OTHER STATUTES - "4" MONTHS DISCOVERY
TRACK
--0375 FALSECLAIMSACT
1:]400 STATE REAPPORTIONMENT
[J430 BANKSANDBANKING
0450 COMMERCEIICCRATESIETC.
[J460 DEPORTATION
0470 RACKETEERINFLUENCEDAND CORRUPT
ORGANIZATIONS
0480 CONSUMERCREDIT
0490 CABLE/SATELLITETV
0891 AGRICULTURALACTS
0893 ENVIRONMENTALMATTERS
0895 FREEDOMOF INFORMATIONACT
[J950 CONSTITUTIONALITYOF STATE STATUTES
0890 OTHERSTATUTORYACTIONS
0899 ADMINISTRATIVEPROCEDURESACTI
REVIEWOR APPEALOF AGENCY DECISION
OTHER STATUTES - "8" MONTHS DISCOVERY
TRACK
--0410ANTITRUST
0850 SECURITIESI COMMODITIESI EXCHANGE
OTHER STATUTES - "0" MONTHS DISCOVERY
TRACK
-----r::J896 ARBITRATION
(ConfirmI VocateI Order I ModifY)
* PLEASE NOTE DISCOVERY
TRACK FOR EACH CASE TYPE.
SEE LOCAL RULE 26.3
VII. REQUESTED IN COMPLAINT:
oCHECK IF CLASS ACTION UNDER F.R-Clv.P. 23 DEMANDs _
JURY DEMAND.YES DNO (CHECK YES ONLY IF DEMANDED IN COMPLAINT)
VIII. RELATEDIREFILED CASE(S) IF ANY
JUDGE _ DOCKET NO. _
CIVIL CASES ARE DEEMED RELATED IF THE PENDING CASE INVOLVES: (CHECK APPROPRIATE BOX)
OJ. PROPERTY INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
OZ. SAME ISSUE OF FACT OR ARISES OUT OF THE SAME EVENT OR TRANSACTION INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
03. VALIDITY OR INFRINGEMENT OF THE SAME PATENT, COPYRIGHT OR TRADEMARK INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
04. APPEALS ARISING OUT OF THE SAME BANKRUPTCY CASE AND ANY CASE RELATED THERETO WHICH HAVE BEEN DECIDED BY THE SAME
BANKRUPTCY JUDGE.

ISMISSED. This case 0 IS 0 IS NOT (cbeckone box) SUBSTANTIALLY THE SAME CASE.
DATE
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