Upon information and belief, Defendant ShenZhen Gospell

Smarthome Electronic Co., Ltd. (dba Oco Camera) is a business entity organized

and existing under the laws of the People's Republic of China ("China"), with an

office and principal place of business located at F12, F518 Idea Land, Baoyuan

Road, Baoan Central Area, Shenzhen City, People’s Republic of China. Upon

information and belief, ShenZhen Gospell Smarthome Electronic Co., Ltd. does

business as Oco in the United States.

8. Upon information and belief, Defendant Ivideon LLC is a corporation

registered and lawfully existing under the laws of the State of Nevada, with an

office and principal place of business located at 5348 Vegas Dr., Las Vegas,

Nevada, 89108. Upon information and belief, Ivideon LLC does business as Oco in

the United States. Upon information and belief, Ivideon LLC Corp. handles in total

or in part customer service related to the accused products, providing, among other

things, instructions to customers on how to use the Oco Camera and, thereby

infringe upon the patents at issue. Upon information and belief, the customer

service phone number listed in Oco user manuals/instructional guides, and/or on its

website www.getoco.com is 1-888-683-8950 which is the phone number of Ivideon LLC.

9. Upon information and belief, Defendant Global Innovations Inc. is a

corporation registered and lawfully existing under the laws of the State of

Washington, with an office and principal place of business located at 2519 15th Ave S. Seattle, WA 98144. Upon information and belief, Global Innovations Inc.is a U.S. importer and distributor of the accused products.

10. Upon information and belief, Defendant New Sight Devices Corp. is a

corporation registered and lawfully existing under the laws of the State of

Delaware, with an office and principal place of business located at 3524 Silverside Road Suite 35b, Wilmington, DE 19810-4929. Upon information and belief, New Sight Devices Corp. does business as Oco in the United States. Upon information and belief, New Sight Devices Corp. handles in total or in part customer service related to the accused products, providing, among other things, instructions to customers on how to use the Oco Camera and, thereby infringe upon the patents at issue. For example, upon information and belief, New Sight Devices Corp. has and continues to answer customer queries about the Oco Camera posted on Amazon.com.

11. Upon information and belief, Defendants do business under different

names including but not limited to the brand name of Oco.

12. Upon information and belief, Defendants does business under

different names including but not limited to the brand name of Ivideon.

THE ACCUSED PRODUCTS

13. The Defendant’s accused products for purposes of the asserted patents include but are not limited to the Defendant’s Oco wireless camera systems, which include, without limitation, Defendant’s subscription Ivideon Recording Services and server for remote monitoring and communication.

14. By way of example, information about and demonstration videos

showing how to infringe the asserted patents are posted by Defendant on its

website(s) at www.getoco.com, www.ivideon.com, and/or public websites.