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Steelhead Licensing LLC

Steelhead Licensing LLC

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00035-UNA: Steelhead Licensing LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7ps for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00035-UNA: Steelhead Licensing LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7ps for more info.

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Published by: PriorSmart on Jan 04, 2013
Copyright:Public Domain

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02/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARESTEELHEAD LICENSING LLC,
Plaintiff,v.
HTC CORPORATION, HTC AMERICAHOLDING, INC., HTC AMERICA, INC.,HTC (B.V.I.) CORPORATION,
and
 EXEDEA, INC.,
Defendants.C.A. No.________________ 
TRIAL BY JURY DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Steelhead Licensing LLC (“Steelhead”), by and through its undersigned counsel,for its Complaint against HTC Corporation (“HTC Corp.”), HTC America Holding, Inc. (“HTCHolding”), HTC America, Inc. (“HTC America”), HTC (B.V.I.) Corporation (“HTC BVI”), andExedea, Inc. (“Exedea”) (collectively, “Defendants”), alleges as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the patent laws of theUnited States, Title 35 of the United States Code (“U.S.C.”) to prevent and enjoin Defendantsfrom infringing and profiting, in an illegal and unauthorized manner and without authorizationand/or consent from Steelhead, from U.S. Patent No. 5,491,834 (the “‘834 Patent”), attachedhereto as Exhibit A) pursuant to 35 U.S.C. §271, and to recover damages, attorneys’ fees, andcosts.
THE PARTIES
2.
 
Plaintiff Steelhead is a Delaware limited liability company with its principal placeof business at 222 Delaware Avenue, P.O. Box 25130, Wilmington, DE 19899
.
 
 
 
23.
 
Defendant HTC Corp. is a corporation organized and existing under the laws of Taiwan with its principal place of business at 23 Xinghau Road, Taoyuan 330, Taiwan, Republicof China. HTC Corp. is engaged in the design, manufacture, importation into the United States,and sale after importation into the United States of mobile devices and related software.4.
 
Defendant HTC Holding is a wholly-owned subsidiary of HTC Corp. and isincorporated under the laws of the state of Washington with its principal place of business at13920 SE Eastgate Way, Suite 400, Bellevue, Washington 98005. HTC Holding can be servedwith process through its agent National Registered Agents, Inc., 17809 Barnes Blvd., SWTumwater, Washington 98512-0410. HTC Holding is engaged in the activities on behalf of its parent, HTC Corp., and is the parent company HTC America.5.
 
Defendant HTC America is a wholly-owned subsidiary of HTC Holding and isincorporated under the laws of the state of Washington, with its principal place of business at13920 SE Eastgate Way, Suite 400, Bellevue, Washington 98005. HTC America can be servedwith process through its agent National Registered Agents, Inc., 17809 Barnes Blvd., SWTumwater, Washington 98512-0410. HTC America performs several services to support theimportation and sale of mobile devices and related software made by or on behalf of HTC Corp.into and within the United States, including marketing, repair, and after-sale services of mobiledevices.6.
 
Defendant HTC BVI is a wholly-owned subsidiary of HTC Corp. and isincorporated under the laws of the British Virgin Islands with its principal place of business at3F, Omar Hodge Building, Wickhams Cay I, P.O. Box 362, Road Town, Tortola, British VirginIslands. HTC BVI is engaged in activities on behalf of its parent, HTC Corp., and is the parentcompany of Exedea.
 
 
37.
 
Defendant Exedea is a wholly-owned subsidiary of HTC BVI and is incorporatedunder the laws of the state of Texas with its principal place of business at 5950 Corporate Drive,Houston, Texas 77036. Exedea imports mobile devices made by or on behalf of HTC Corp. intothe United States and distributes and sells such mobile devices after their importation.8.
 
Defendants are in the business of making, using, selling, offering for sale and/or importing mobile devices.
JURISDICTION AND VENUE
9.
 
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§1331 and 1338(a) because the action arises under the patent laws of the United States, 35U.S.C. §§1 et seq.10.
 
This Court has personal jurisdiction over Defendants by virtue of their systematicand continuous contacts with this jurisdiction, as well as because of the injury to Steelhead andthe cause of action Steelhead has raised, as alleged herein.11.
 
Defendants are subject to this Court’s specific and general personal jurisdiction pursuant to due process and/or the Delaware Long-Arm Statute,
 Del Code. Ann. Tit. 3, §3104
,due to at least their substantial business in this forum, including: (i) at least a portion of theinfringement alleged herein; and (ii) regularly doing or soliciting business, engaging in other  persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals in Delaware.12.
 
Defendants have conducted and do conduct business within the state of Delaware,directly or through intermediaries, resellers, agents, or offer for sale, sell, advertise products inDelaware that infringe the ‘834 Patent.

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