Patent Suit

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT FOR THE MIDDLE DISTRICT 01.i OC'T 13 f;i 12: 52
OF FLORIDA· ORLANDO DIVISION

ROBERT KEYES,

v.

Plaintiff,

CLERK, ll.s. O:li1i.lGT courn
HIODLE DJSlF:C1 lir FLORID,\
) a;;t,\trn::. n!lf:IDA
)
)
}
)
)

DISNEY ENTERPRISES, INC. and )
THE WALT DISNEY COMPANY, )
)
Defendant, )

COMPLAINT

Plaintiff, Robert Keyes ("Keyes"), for his Complaint against the defendants, Disney Enterprises, Inc. and The Walt Disney Company (hereinafter collectively referenced as "Disney"), states as follows:
NATURE OF ACTION

This is an action underthe patent laws of the United States, 35 U.S.C. § 256, seeking correction of inventorship of a United States patent by adding plaintiff as a joint inventor and possibly deleting incorrectly named inventors. Plaintiff also has asserted a claim for unjust enrichment based upon Disney's obtaining a patent on an invention in which Keyes should have been included as an inventor.

PARTIES

Keyes is a citizen of the State of Tennessee: he resides at 2245 Sunningdate Road, Kingsport, Tennessee.
Disney Enterprises, Inc. is a Delaware corporation with its principal place of business inBurbank, California. Disney Enterprises, Inc. manages the intellectual property of The Walt Disney Company, Disney Enterprises, Inc. was known as "The Walt Disney Company" until February 9, 1996, when it became a wholly owned subsidiary of The Walt Disney Company as a consequence of an acquisition.
The Walt Disney Company is a Delaware corporation with Its principal place of business inBurbank, California. The Walt Disney Company was known as DC Holdco, Inc, untll February 9, 1996, and is now the parent corporation of Disney Enterprises, Inc. The Walt Disney Company owns and operates, through its subsidiaries, theme parks in Orlando, Florida, andelsewhere. Ithas successfully directed and maintained the exclusive use of the below described patent at such theme parks.

JURISDICTION AND VENUE

This action arises under the patent laws of the United States, more particularly 35 U.S,C. § 256, and therefore, jurisdiction of this Court arises under 28 U.S.C. § 1331. The Court also has jurisdiction over non-federal questions under 28 U.S.C. §§1332(a)(1) and 1367(a).
This is also the judicial district in which a substantial part of the events and omissions giving rise to the claims occurred. Venue is proper in this judicial district by virtue of 28 U.S.C. §§ 1391(a), (b} and (c).

!3ACKGROUND

In January of 1991, Keyes sent two letters to Richard Nunis and Robert Matheison, Disney executives located in Orlando, Florida, disclosing his invention for a system which would reduce the waiting time for people seeking entrance to attractions at MGM Studios and the Disney theme parks.
In essence, the invention which Keyes disclosed to Disney comprised a systematic method for managing guest density atvarious attractions byallowing guests two separate ways to access such attractions. One means of access was regulated by a document available to each guest at no additional charge. That document·· -which Keyes called a "pass" - - entitled guests to subsequently obtain a printed time for future access to a particular attraction. A guest could then leave the vicinity of the attraction and later return to access that attraction through a separate line at the future time printed on the pass. A second means of access allowed guests the opportunity to access the attraction through a normal line called the"Stand By line."
Keyes' invention allowed guests to avoid waiting in long lines for popular attractions. The Invention, in effect, guaranteed access to attractions at a future time and allowed guests to shop, dine or carry out other activities in the lime that would normally be spent waiting in line without the system.
The system Keyes invented had the potential to significantly Improve park and attraction efficiency by more effectively distributing guests' waiting time. The increased efficiency would not only increase satisfaction of guests, butwould also increase park revenue for Disney by allowing guests significantly greater opportunities for shopping and dining.
Nunis and Mathelson charged Greg Emmer, the Director of EPCOT for Walt Disney World, with the task of responding to Keyes' letters. On or about February 4, 1991, Emmer, on behalf of Disney, sent Keyes a letter stating that his invention would not work, but would instead result in "more guest inconvenience."
Subsequently, on February 25,1991, Disney's corporate law department sent Keyes a second letter. Although Disney had already accepted, reviewed, evaluated and answered Keyes' letters, the February 25, 1991 letter recited Disney's purported policy on unsolicited ideas and represented that the policy did not allow Disney to accept or review Keyes' "idea." In that letter, Disney also claimed that it was returning to Keyes all originals and copies of his letters. Disney, however, did not return the original of Keyes' first letter, but returned a fax copy of that letter instead.
Moreover, Disney made several copies or faxes of Keyes' letters, all of which itretained and internally distributed, In addition to sending Keyes' letters to Emmer, Nunis and Mathelson distributed them to others in the Disney organization, likely including Bruce Laval, who then held a position roughly equivalent to that of Emmer on the MGM side of theDisney business. Laval also succeeded toRobert Matheison's position; Matheison was one of the named addressees on the Keyes letters. Eventually, Emmer reported directly to Laval.
On information and belief, Nunis also had a practice of retaining promising ideas in written submissions in a box in his office for subsequent review and possible implementation. On information and belief, this was yet another way the Keyes' invention was reviewed and evaluated within Disney, 15, On January 9, 2001, Disney obtained the issuance of U.S. Patent No. 6,173,209 (the '209 patent) on the very invention which Keyes earlier disclosed to Disney. The abstract of the '209 patent describes the invention as follows:

The invention is a method and system for managing admission to an attraction. In one or more embodiments, the system comprises a first queue by which customers may access the attraction by waiting in line and a second queue by which customers may access the attraction in a manner which avoids the first queue. The system includes a first validator for validating an entitlement of a customer to receive an assigned time in the future for accessing the attraction via the second queue, a media distributor for distributing a media to an entitled customer, the media including the
assigned time at which the entitled customer is entitled to access the
attraction in the future, and a second validator for validating the entitled customer access to the attraction at the time provided on the media. In accordance with a method of the invention, a customer may access an attraction in a manner which avoids standing in a first waiting line by verifying entitlement to utilize a second queue, obtaining a pass entitling the customer to access the attraction at a future time, and returning to the attraction at the future time and gaining access with the pass. In this method, the customer may leave the vicinity of the attraction between when the pass is issued and the future time at which the customer is entitled to access to the attraction.

(Exhibit A).

1. Keyes' invention as disclosed to Disney likewise comprised:

1. 1. a first line or "queue" by which customers may access the attraction by waiting in line;

1. 1. a second queue by which customers may access the attraction in a manner which avoids the first queue;

1. 1. a first "Validator" - -a pass without any assigned times - -for validating an entitlement of a customer to receiVe assigned times in the future for accessing the attraction via the second queue;

1. 1. a "media distributor" for distributing media, the media Including the assigned time for future access to the attraction - • an assigned time for future access to the attraction is placed on the pass at the site of the attraction;

1. 1. a"second validator" for validating the entitled customers access tothe attraction at the time provided on the media - - a customer gains access to the second queue only with a pass containing the appropriate time;

1. 1. the ability of a customer to access an attraction in a manner which avoids standing in a first waiting line by verifying entitlement to utilize asecond queue, obtaining a pass entitling the customer to access the attraction at a future time, and returning to the attraction at the future time and gaining access with the pass: and

1. 1. the ability of acustomer to leave the vicinity of the attraction between when the pass is issued and the future time at which the customer is entitled to access to the attraction.

Disney was assigned the '209 patent by Bruce Laval and Gregory Hale, who were identified as the purported inventors. Laval is the same Disney executive who had access to - and likely studied - the Keyes letters. The '209 patent was the first and only time that Laval was a named inventor on any patent.
Disney has not licensed the '209 patent to any competitor, and the '209 patent has enabled Disney the exclusive right to practice the patent at Its theme parks. This has allowed Disney to obtain a significant competitive advantage over competitors such as Universal, Anheuser Busch and Six Flags, which have had to resort to charging extra for patrons seeking faster access to attractions. The '209 patent is so important to Disney that it has flied additional patent applications continuing from the '209 patent, seeking additional patent coverage on multiple variations of the Keyes' invention.

COUNT!
CORRECTION OF INVENTORSHIP

Plaintiff realleges and reincorporates paragraphs 1 through 17 above as if specifically set forth herein.

Plaintiff contributed ina significant manner to theconception of the inventions claimed in the Disney '209 patent; he also communicated to Disney a definite and permanent idea of a complete and operative invention.
As a consequence, plaintiff should have been named at least co-inventor of the '209 patent, as he conceived of every element of at least many, if not all of, the independent claims in that patent. Plaintiff may also be the true inventor of related patent applications filed by Disney.
Pursuant to 35 U.S.C. § 256, an order should issue correcting inventorship of the '209 patent by either naming plaintiff at least as a co-inventor of the '209 patent

COUNT II
UNJUST ENRICHMENT

Plaintiff realleges and reincorporates paragraphs 1 through 21 above as if specifically set forth herein.
Disney has been unjustly enriched at the expense of Keyes. Specifically, by

obtaining the '209 patent without naming Keyes as a co-inventor, Disney has enjoyed exclusivity on Keyes' invention, which has been a significant benefit to Disney, without having paid Keyes for either an assignment of his ownership interest in the '209 patent or for an exclusive license thereunder for the value of the invention to Disney.

The circumstances are such that it would be unjust for Disney to retain the benefit conferred by exclusive ownership of the patent without paying fair value to Keyes for such exclusivity.

WHEREFORE, plaintiff respectfully requests:

1. An order correcting inventorshlp of the '209 patent (and related pending appllcations), and
2. An award of damages from Disney Enterprises, Inc. and The Walt Disney Company in an amount to be determined at trial, plus interest and costs of suit.
3. Such further relief as a jury or the Court may find appropriate.

J!,IRYDEMAND
Plaintiff demands a trial by jury.
Plaintiff, ROBERT KEYES
·2
By: Raymond P. Niro Paul K Vickrey Christopher J. Lee
Niro. Scavone, Haller & Niro
181 West Madison, Suite 4600
Chicago, Illinois 60602

N inder Hull, P.A.
746-A North Magnolia Avenue
P.O. Box 533068 Orlando, FL 32853 407-422-1235 Fax: 407-423-2842
email: nlhull@bc.netcom.com
Unmd Slalllll Patml: 6,171,209 bHp://pall!.usplo.gov .Pimer'/5cell=l"IOl&Seca•mt'OF..

tJSPTO PADfN'!'Puu.-!JxTAHE> IMA.Cd OATABA,fll
( l:ismm l[ Slllhil5 ]!6dyan l[ Pot Nvrn ]I HJlb1 ]
[ Bottom j
!v1,w Oart] ddtn Cg
[ •mopes]

United Scatea Puent La\1111, etal.

Method and syst.em for managing attraction admission
Abstract

6,113,209
January !>, 2001

TheiiM::o1ion is a m=thod mid systelll ibr managing adJnission toan attraction. In one or more embodimen!S, tbe system comprises a first queueby whichcusrmnezs may accew1he attracticm by waiting inline and a. s«;oa.d by whk:b CUSlmJJcm may access the atll:1ttion inall'Wllllll' which a.voids 1he first queue. The system includes a fiJSt validator ibr validating an entitlement ofa.llll51tlmer to r vean assigned time inthe: future fur acc,...sing thc atttactlan \Ii& the second queue, a media clistnbUlor fut disttibuti.ffg e. media ro an enli1led customer, the media includin& theIISSigned time at which the cmlitled customer is enfitled to access 1he auraction in the fiJtnre, md a second validator fur wlideri"i the entitled cus10mer access to tlie attraction at1be lime provided on the media.1n with a method afthe inve:m:ion, a.customer may access an. attniction in11. manner which avoids standina inafirst waiting line by verifying entitlement to utiliz.e e.second
queue, o'btainin& apass Wlitlini1he ,ustomer 1D acccas tbc a1II1lCtion st a future time, and Mlll'llmg to the
attrac1ian at'lhoiillure time mdgaining access withihe(ll!S$, In 1his method, 1he may leave the vicioit)"af1be attraction betweetl when the pa is issued and thc future time at which the customer is emitled to access to the atlraction.

Jnvemors: Laval; Bmce G. (W'mdennmc, FL); Hale; Greiory B. (Orlando, FL)
Assignee: Disney Encerprfsev, Inc. Qilllbanlc, CA) Appl No.: 372405
Filed: Aupst 10, 1999

Carrcut U.S. Cius,

700/91; 235/382; 10S/S

lntnm'l Clan:
FJeld or Bean:b:

GOGF 155/00: G06F 013/00; 006F 017/60; G06K 005/00
700/91 705/5,1345/326 235/382

1 of3S EXHIBI

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT FOR THE MIDDLE DISTRICT 01.i OC'T 13 f;i 12: 52
OF FLORIDA· ORLANDO DIVISION

ROBERT KEYES,

v.

Plaintiff,

CLERK, ll.s. O:li1i.lGT courn
HIODLE DJSlF:C1 lir FLORID,\
) a;;t,\trn::. n!lf:IDA
)
)
}
)
)

DISNEY ENTERPRISES, INC. and )
THE WALT DISNEY COMPANY, )
)
Defendant, )

COMPLAINT

Plaintiff, Robert Keyes ("Keyes"), for his Complaint against the defendants, Disney Enterprises, Inc. and The Walt Disney Company (hereinafter collectively referenced as "Disney"), states as follows:
NATURE OF ACTION
This is an action underthe patent laws of the United States, 35 U.S.C. § 256, seeking correction of inventorship of a United States patent by adding plaintiff as a joint inventor and possibly deleting incorrectly named inventors. Plaintiff also has asserted a claim for unjust enrichment based upon Disney's obtaining a patent on an invention in which Keyes should have been included as an inventor.
PARTIES
Keyes is a citizen of the State of Tennessee: he resides at 2245 Sunningdate Road, Kingsport, Tennessee.
Disney Enterprises, Inc. is a Delaware corporation with its principal place of business inBurbank, California. Disney Enterprises, Inc. manages the intellectual property

of The Walt Disney Company, Disney Enterprises, Inc. was known as "The Walt Disney Company" until February 9, 1996, when it became a wholly owned subsidiary of The Walt Disney Company as a consequence of an acquisition.
The Walt Disney Company is a Delaware corporation with Its principal place of business inBurbank, California. The Walt Disney Company was known as DC Holdco, Inc, untll February 9, 1996, and is now the parent corporation of Disney Enterprises, Inc. The Walt Disney Company owns and operates, through its subsidiaries, theme parks in Orlando, Florida, andelsewhere. Ithas successfully directed and maintained the exclusive use of the below described patent at such theme parks.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, more particularly 35 U.S,C. § 256, and therefore, jurisdiction of this Court arises under 28 U.S.C.
§ 1331. The Court also has jurisdiction over non-federal questions under 28 U.S.C.
§§1332(a)(1) and 1367(a).

This is also the judicial district in which a substantial part of the events and omissions giving rise to the claims occurred. Venue is proper in this judicial district by virtue of 28 U.S.C. §§ 1391(a), (b} and (c).
!3ACKGROUND
In January of 1991, Keyes sent two letters to Richard Nunis and Robert Matheison, Disney executives located in Orlando, Florida, disclosing his invention for a system which would reduce the waiting time for people seeking entrance to attractions at MGM Studios and the Disney theme parks.

In essence, the invention which Keyes disclosed to Disney comprised a systematic method for managing guest density atvarious attractions byallowing guests two separate ways to access such attractions. One means of access was regulated by a document available to each guest at no additional charge. That document·· -which Keyes called a "pass" - - entitled guests to subsequently obtain a printed time for future access to a particular attraction. A guest could then leave the vicinity of the attraction and later return to access that attraction through a separate line at the future time printed on the pass. A second means of access allowed guests the opportunity to access the attraction through a normal line called the"Stand By line."
Keyes' invention allowed guests to avoid waiting in long lines for popular attractions. The Invention, in effect, guaranteed access to attractions at a future time and allowed guests to shop, dine or carry out other activities in the lime that would normally be spent waiting in line without the system.
The system Keyes invented had the potential to significantly Improve park and attraction efficiency by more effectively distributing guests' waiting time. The increased efficiency would not only increase satisfaction of guests, butwould also increase park revenue for Disney by allowing guests significantly greater opportunities for shopping and dining.
Nunis and Mathelson charged Greg Emmer, the Director of EPCOT for Walt Disney World, with the task of responding to Keyes' letters. On or about February 4, 1991, Emmer, on behalf of Disney, sent Keyes a letter stating that his invention would not work, but would instead result in "more guest inconvenience."

Subsequently, on February 25,1991, Disney's corporate law department sent Keyes a second letter. Although Disney had already accepted, reviewed, evaluated and answered Keyes' letters, the February 25, 1991 letter recited Disney's purported policy on unsolicited ideas and represented that the policy did not allow Disney to accept or review Keyes' "idea." In that letter, Disney also claimed that it was returning to Keyes all originals and copies of his letters. Disney, however, did not return the original of Keyes' first letter, but returned a fax copy of that letter instead.
Moreover, Disney made several copies or faxes of Keyes' letters, all of which
itretained and internally distributed, In addition to sending Keyes' letters to Emmer, Nunis and Mathelson distributed them to others in the Disney organization, likely including Bruce Laval, who then held a position roughly equivalent to that of Emmer on the MGM side of theDisney business. Laval also succeeded toRobert Matheison's position; Matheison was one of the named addressees on the Keyes letters. Eventually, Emmer reported directly to Laval.
On information and belief, Nunis also had a practice of retaining promising ideas in written submissions in a box in his office for subsequent review and possible implementation. On information and belief, this was yet another way the Keyes' invention was reviewed and evaluated within Disney,
15, On January 9, 2001, Disney obtained the issuance of U.S. Patent No. 6,173,209 (the '209 patent) on the very invention which Keyes earlier disclosed to Disney. The abstract of the '209 patent describes the invention as follows:
The invention is a method and system for managing admission to an attraction. In one or more embodiments, the system comprises a first queue

by which customers may access the attraction by waiting in line and a second queue by which customers may access the attraction in a manner which avoids the first queue. The system includes a first validator for validating an entitlement of a customer to receive an assigned time in the future for accessing the attraction via the second queue, a media distributor for distributing a media to an entitled customer, the media including the
assigned time at which the entitled customer is entitled to access the
attraction in the future, and a second validator for validating the entitled customer access to the attraction at the time provided on the media. In
accordance with a method of the invention, a customer may access an attraction in a manner which avoids standing in a first waiting line by verifying entitlement to utilize a second queue, obtaining a pass entitling the customer to access the attraction at a future time, and returning to the attraction at the future time and gaining access with the pass. In this method, the customer may leave the vicinity of the attraction between when the pass is issued and the future time at which the customer is entitled to access to the attraction.

(Exhibit A).

Keyes' invention as disclosed to Disney likewise comprised:

a first line or "queue" by which customers may access the attraction by waiting in line;

a second queue by which customers may access the attraction in a manner which avoids the first queue;

a first "Validator" - -a pass without any assigned times - -for validating an entitlement of a customer to receiVe assigned times in the future for accessing the attraction via the second queue;

a "media distributor" for distributing media, the media Including the assigned time for future access to the attraction - • an assigned time for future access to the attraction is placed on the pass at the site of the attraction;

a"second validator" for validating the entitled customers access tothe attraction at the time provided on the media - - a customer gains access to the second queue only with a pass containing the appropriate time;

the ability of a customer to access an attraction in a manner which avoids standing in a first waiting line by verifying entitlement to utilize asecond queue, obtaining a pass entitling the customer to access the attraction at a future time, and returning to the attraction at the future time and gaining access with the pass: and the ability of acustomer to leave the vicinity of the attraction between when the pass is issued and the future time at which the customer is entitled to access to the attraction.

Disney was assigned the '209 patent by Bruce Laval and Gregory Hale, who were identified as the purported inventors. Laval is the same Disney executive who had access to - and likely studied - the Keyes letters. The '209 patent was the first and only time that Laval was a named inventor on any patent.
Disney has not licensed the '209 patent to any competitor, and the '209 patent has enabled Disney the exclusive right to practice the patent at Its theme parks. This has allowed Disney to obtain a significant competitive advantage over competitors such as Universal, Anheuser Busch and Six Flags, which have had to resort to charging extra for patrons seeking faster access to attractions. The '209 patent is so important to Disney that it has flied additional patent applications continuing from the '209 patent, seeking additional patent coverage on multiple variations of the Keyes' invention.
COUNT!
CORRECTION OF INVENTORSHIP
Plaintiff realleges and reincorporates paragraphs 1 through 17 above as if
specifically set forth herein.

Plaintiff contributed ina significant manner to theconception of the inventions claimed in the Disney '209 patent; he also communicated to Disney a definite and permanent idea of a complete and operative invention.
As a consequence, plaintiff should have been named at least co-inventor of the '209 patent, as he conceived of every element of at least many, if not all of, the independent claims in that patent. Plaintiff may also be the true inventor of related patent applications filed by Disney.
Pursuant to 35 U.S.C. § 256, an order should issue correcting inventorship
of the '209 patent by either naming plaintiff at least as a co-inventor of the '209 patent
COUNT II
UNJUST ENRICHMENT
Plaintiff realleges and reincorporates paragraphs 1 through 21 above as if specifically set forth herein.
Disney has been unjustly enriched at the expense of Keyes. Specifically, by
obtaining the '209 patent without naming Keyes as a co-inventor, Disney has enjoyed exclusivity on Keyes' invention, which has been a significant benefit to Disney, without having paid Keyes for either an assignment of his ownership interest in the '209 patent or for an exclusive license thereunder for the value of the invention to Disney.
The circumstances are such that it would be unjust for Disney to retain the benefit conferred by exclusive ownership of the patent without paying fair value to Keyes for such exclusivity.
WHEREFORE, plaintiff respectfully requests:
An order correcting inventorshlp of the '209 patent (and related pending appllcations), and
An award of damages from Disney Enterprises, Inc. and The Walt Disney Company in an amount to be determined at trial, plus interest and costs of suit.
Such further relief as a jury or the Court may find appropriate.

J!,IRYDEMAND
Plaintiff demands a trial by jury.
.Pdv ....Plaintiff, ROBERT KEYES
·2
By: Raymond P. Niro Paul K Vickrey Christopher J. Lee
Niro. Scavone, Haller & Niro
181 West Madison, Suite 4600
Chicago, Illinois 60602

N inder Hull, P.A.
746-A North Magnolia Avenue
P.O. Box 533068 Orlando, FL 32853 407-422-1235 Fax: 407-423-2842
email: nlhull@bc.netcom.com
Unmd Slalllll Patml: 6,171,209 bHp://pall!.usplo.gov .Pimer'/5cell=l"IOl&Seca•mt'OF..

tJSPTO PADfN'!'Puu.-!JxTAHE> IMA.Cd OATABA,fll
( l:ismm l[ Slllhil5 ]!6dyan l[ Pot Nvrn ]I HJlb1 ]
[ Bottom j
!v1,w Oart] ddtn Cg
[ •mopes]

United Scatea Puent La\1111, etal.

Method and syst.em for managing attraction admission
Abstract

6,113,209
January !>, 2001

TheiiM::o1ion is a m=thod mid systelll ibr managing adJnission toan attraction. In one or more embodimen!S, tbe system comprises a first queueby whichcusrmnezs may accew1he attracticm by waiting inline and a. s«;oa.d by whk:b CUSlmJJcm may access the atll:1ttion inall'Wllllll' which a.voids 1he first queue. The system includes a fiJSt validator ibr validating an entitlement ofa.llll51tlmer to r vean assigned time inthe: future fur acc,...sing thc atttactlan \Ii& the second queue, a media clistnbUlor fut disttibuti.ffg e. media ro an enli1led customer, the media includin& theIISSigned time at which the cmlitled customer is enfitled to access 1he auraction in the fiJtnre, md a second validator fur wlideri"i the entitled cus10mer access to tlie attraction at1be lime provided on the media.1n with a method afthe inve:m:ion, a.customer may access an. attniction in11. manner which avoids standina inafirst waiting line by verifying entitlement to utiliz.e e.second
queue, o'btainin& apass Wlitlini1he ,ustomer 1D acccas tbc a1II1lCtion st a future time, and Mlll'llmg to the
attrac1ian at'lhoiillure time mdgaining access withihe(ll!S$, In 1his method, 1he may leave the vicioit)"af1be attraction betweetl when the pa is issued and thc future time at which the customer is emitled to access to the atlraction.
Jnvemors: Laval; Bmce G. (W'mdennmc, FL); Hale; Greiory B. (Orlando, FL)
Assignee: Disney Encerprfsev, Inc. Qilllbanlc, CA) Appl No.: 372405
Filed: Aupst 10, 1999

Carrcut U.S. Cius,

700/91; 235/382; 10S/S

lntnm'l Clan:
FJeld or Bean:b:

GOGF 155/00: G06F 013/00; 006F 017/60; G06K 005/00
700/91 705/5,1345/326 235/382

1 of3S EXHIBIT A

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT FOR THE MIDDLE DISTRICT 01.i OC'T 13 f;i 12: 52
OF FLORIDA· ORLANDO DIVISION

ROBERT KEYES,

v.

Plaintiff,

CLERK, ll.s. O:li1i.lGT courn
HIODLE DJSlF:C1 lir FLORID,\
) a;;t,\trn::. n!lf:IDA
)
)
}
)
)

DISNEY ENTERPRISES, INC. and )
THE WALT DISNEY COMPANY, )
)
Defendant, )

COMPLAINT

Plaintiff, Robert Keyes ("Keyes"), for his Complaint against the defendants, Disney Enterprises, Inc. and The Walt Disney Company (hereinafter collectively referenced as "Disney"), states as follows:
NATURE OF ACTION

This is an action underthe patent laws of the United States, 35 U.S.C. § 256, seeking correction of inventorship of a United States patent by adding plaintiff as a joint inventor and possibly deleting incorrectly named inventors. Plaintiff also has asserted a claim for unjust enrichment based upon Disney's obtaining a patent on an invention in which Keyes should have been included as an inventor.