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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-00036-UNA: Steelhead Licensing LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7pr for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00036-UNA: Steelhead Licensing LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7pr for more info.

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

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07/11/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARESTEELHEAD LICENSING, LLC,
Plaintiff,v.
LG ELECTRONICS, INC.,LG ELECTRONICS U.S.A., INC.,
and
 LG ELECTRONICS MOBILECOMMU.S.A., INC.
Defendants.C.A. No.________________ 
TRIAL BY JURY DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Steelhead Licensing, LLC (“Steelhead”), by and through its undersignedcounsel, for its Complaint against LG Electronics, Inc. (hereinafter, “LGE”), LG ElectronicsU.S.A., Inc. (hereinafter, “LG USA”), and LG Electronics MobileComm U.S.A., Inc.(hereinafter, “LG Mobile”) (collectively, the “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 (hereinafter, the “‘834 Patent”)and U.S. Patent No. 5,678,185 (hereinafter, the “’185 Patent”), attached hereto as Exhibits A andB, respectively, pursuant to 35 U.S.C. §271, and to recover damages, attorneys’ fees, and costs.
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 LGE is a foreign corporation organized under the laws of the Republicof Korea. Its principal place of business is located at LG Twin Towers, 20 Yeouido-dong,Yeongdeungpo-gu, Seoul 150-721, South Korea.4.
 
Defendant LGE is the parent corporation of Defendants LG USA and LG Mobile.5.
 
Defendant LG USA is a Delaware corporation with its principal place of businessat 920 Sylvan Ave., Englewood Cliffs, New Jersey 07632. Defendant LG USA is a wholly-owned subsidiary of Defendant LGE. LG USA’s registered agent for service of process inCalifornia is Alan K. Tse, 10101 Old Grove Road, San Diego, California 92131. Defendant LGUSA’s registered agent for service of process is United States Corporation Company, 2711Centerville Road, Suite 400, Wilmington, Delaware 19808.6.
 
Defendant LG Mobile is a corporation organized and existing under the laws of the state of California, with its principal place of business located at 920 Sylvan Avenue,Englewood Cliffs, New Jersey 07632. LG Mobile’s registered agent for service of process inCalifornia is Alan K. Tse, 10101 Old Grove Road, San Diego, California 92131. Its registeredagent for service of process is national Registered Agents, Inc. of New Jersey, 100 Canal PointeBlvd. Suite 212, Princeton, New Jersey 08540. Defendant LG Mobile is a wholly ownedsubsidiary of Defendant LGE.7.
 
Defendants are in the business of making, using, selling, offering for sale and/or importing mobile communication devices including, but not limited to, mobile phones.
 
 
3
JURISDICTION AND VENUE
8.
 
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.9.
 
This Court has personal jurisdiction over Defendants by virtue of its 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.10.
 
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.11.
 
Defendants have conducted and does conduct business within the state of Delaware, directly or through intermediaries, resellers, agents, or offer for sale, sell, advertise products in Delaware that infringe the ‘834 and ‘185 Patents.12.
 
In addition to Defendants’ continuously and systematically conducting business inDelaware, the causes of action against Defendants are connected (but not limited) to Defendants’ purposeful acts committed in the state of Delaware, including Defendants’ making, using,importing, offering for sale, or selling products which include features that fall within the scopeof at least one claim of the ‘834 and ‘185 Patents.13.
 
Venue lies in this District under 28 U.S.C. §§1391 and 1400(b) because, amongother reasons, Defendants are subject to personal jurisdiction in this District, and have committed

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