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Advanced Optical Tracking v. Verbatim Americas et. al.

Advanced Optical Tracking v. Verbatim Americas et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-01696-UNA: Advanced Optical Tracking LLC v. Verbatim Americas LLC et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7gM for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-01696-UNA: Advanced Optical Tracking LLC v. Verbatim Americas LLC et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7gM for more info.

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Published by: PriorSmart on Dec 12, 2012
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02/01/2013

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1IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWAREADVANCED OPTICAL TRACKING, LLC, § Civil Case No. ____________§Plaintiff, §§v. §
JURY TRIAL DEMANDED
 §
 
VERBATIM AMERICAS, LLC, §VERBATIM CORPORATION, §MITSUBISHI KAGAKU MEDIA CO., LTD., §MITSUBISHI CHEMICAL CORPORATION, §and MITSUBISHI CHEMICAL HOLDINGS §CORPORATION, §§Defendants. §
COMPLAINT FOR PATENT INFRINGEMENT
 Plaintiff Advanced Optical Tracking, LLC, by way of its Complaint for PatentInfringement (“Complaint”) against Defendants Verbatim Americas, LLC (“VerbatimAmericas”), Verbatim Corporation (“Verbatim Corp.”), Mitsubishi Kagaku Media Co., LTD.(“Mitsubishi Kagaku”), Mitsubishi Chemical Corporation (“Mitsubishi Chemical”) andMitsubishi Chemical Holdings Corporation (“Mitsubishi Holdings”), alleges as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. § 1
et seq
.
THE PARTIES
2.
 
Plaintiff Advanced Optical Tracking, LLC (“AOT”) is a Delaware limitedliability company with a place of business at 1220 N. Market Street, Suite 806, Wilmington,Delaware 19801.
 
23.
 
Upon information and belief, Defendant Verbatim Americas, LLC (“VerbatimAmericas”) is a corporation organized under the laws of Delaware with a principal place of business at 1200 West W.T. Harris Blvd., Charlotte, North Carolina 28262. On information andbelief, Verbatim Americas is a wholly owned subsidiary of Verbatim Corporation.4.
 
Upon information and belief, Defendant Verbatim Corporation (“VerbatimCorp.”) is a corporation organized under the laws of California with a principal place of businessat 1200 West W.T. Harris Blvd., Charlotte, North Carolina 28262. On information and belief,Verbatim Corp. is a wholly owned subsidiary of Mitsubishi Kagaku Media Co., LTD.5.
 
Upon information and belief, Defendant Mitsubishi Kagaku Media Co., LTD.(“Mitsubishi Kagaku”) is a corporation organized under the laws of Japan with a principal placeof business at 1-23 Shiba 4-chome, Minato-ku, Tokyo 108-8415 Japan. On information andbelief, Mitsubishi Kagaku is a subsidiary of Mitsubishi Chemical Corporation.6.
 
Upon information and belief, Defendant Mitsubishi Chemical Corporation(“Mitsubishi Chemical”) is a corporation organized under the laws of Japan with a principalplace of business at 14-1 Shiba 4-chome, Minato-ku, Tokyo 108-0014 Japan. On informationand belief, Mitsubishi Chemical is a subsidiary of Mitsubishi Holdings Corporation.7.
 
Upon information and belief, Defendant Mitsubishi Chemical HoldingsCorporation (“Mitsubishi Holdings”) is a corporation organized under the laws of Japan with aprincipal place of business at 14-1 Shiba 4-chome, Minato-ku, Tokyo 108-0014 Japan.
JURISDICTION AND VENUE
8.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338(a).9.
 
Venue is proper in this Judicial District under 28 U.S.C. §§ 1391(c) and 1400(b).
 
310.
 
On information and belief, Defendants Verbatim Americas, Verbatim Corp.,Mitsubishi Kagaku, Mitsubishi Chemical and Mitsubishi Holdings are subject to the jurisdictionof this Court by reason of their acts of patent infringement which have been committed in thisJudicial District, and by virtue of their regularly conducted and systematic business contacts inthis State. As such, Defendants Verbatim Americas, Verbatim Corp., Mitsubishi Kagaku,Mitsubishi Chemical and Mitsubishi Holdings have purposefully availed themselves of theprivilege of conducting business within this Judicial District; have established sufficientminimum contacts with this Judicial District such that they should reasonably and fairlyanticipate being haled into court in this Judicial District; have purposefully directed activities atresidents of this State; and at least a portion of the patent infringement claims alleged herein ariseout of or are related to one or more of the foregoing activities.
THE PATENT-IN-SUIT
11.
 
On January 24, 2006, U.S. Patent No. 6,990,058 (the “‘058 Patent”), entitled“Structure and Method for Storing Data on Optical Disks,” was duly and legally issued by theUnited States Patent and Trademark Office. A true and correct copy of the ‘058 Patent isattached as Exhibit A to this Complaint.12.
 
AOT is the assignee and owner of the right, title and interest in and to the ‘058Patent, including the right to assert all causes of action arising under said patent and the right toany remedies for infringement of it.
COUNT I – INFRINGEMENT OF U.S. PATENT NO. 6,990,058
13.
 
The allegations set forth in the foregoing paragraphs 1 through 12 are herebyrealleged and incorporated herein by reference.

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