IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARESTEELHEAD LICENSING LLC,
HTC CORPORATION, HTC AMERICAHOLDING, INC., HTC AMERICA, INC.,HTC (B.V.I.) CORPORATION,
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
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.
Plaintiff Steelhead is a Delaware limited liability company with its principal placeof business at 222 Delaware Avenue, P.O. Box 25130, Wilmington, DE 19899