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Parallel Networks v. KOG Games

Parallel Networks v. KOG Games

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00178-UNA: Parallel Networks, LLC v. KOG Games Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7zV for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00178-UNA: Parallel Networks, LLC v. KOG Games Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7zV for more info.

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Published by: PriorSmart on Feb 04, 2013
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02/04/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
 
PARALLEL NETWORKS, LLC,Plaintiff 
 ,
v.KOG GAMES, INC.,Defendant
.
))))))))))) C.A. No. __________
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Parallel Networks, LLC (“Parallel”) files this Complaint for patent infringementagainst Defendant KOG Games, Inc. (“KOG” or “Defendant”) and alleges as follows:
PARTIES
1.
 
Plaintiff Parallel Networks, LLC is a Delaware limited liability company havingits principal place of business at 1105 N. Market St., Suite 300, Wilmington, Delaware 19801.
2.
 
On information and belief, KOG Games, Inc. is a corporation organized underthe laws of the State of Delaware, and has a principal place of business at 1230 MontanaAvenue, Suite 210, Santa Monica, California, and/or is conducting business through an affiliatelocated at this address.
JURISDICTION AND VENUE
3.
 
This civil action for patent infringement arises under the Patent Laws of theUnited States, 35 U.S.C. §§ 1
et 
seq. This Court has jurisdiction over the claims presented hereinpursuant to 28 U.S.C. §§ 1331 and 1338(a).
 
2
4.
 
On information and belief, KOG makes, imports, sells, and/or offers for sale theAccused Products (as defined below) within the United States, including this District, thatinfringe one or more claims of United States Patent No. 7,188,145 entitled “METHOD ANDSYSTEM FOR DYNAMIC DISTRIBUTED DATA CACHING” (the “'145 Patent”). The '145Patent was duly and legally issued by the United States Patent and Trademark Office on March6, 2007. A true and correct copy of the '145 Patent is attached hereto as Exhibit 1.
5.
 
On information and belief, KOG makes, imports, sells, and/or offers for sale theAccused Products (as defined below) within the United States, including this District, thatinfringe one or more claims of United States Patent No. 7,730,262 entitled “METHOD ANDSYSTEM FOR DYNAMIC DISTRIBUTED DATA CACHING” (the “'262 Patent”). The '262Patent was duly and legally issued by the United States Patent and Trademark Office on June 1,2010. A true and correct copy of the '262 Patent is attached hereto as Exhibit 2.
6.
 
The '145 Patent and '262 Patent are collectively referred to herein as the“Asserted Patents.”
7.
 
On information and belief, Defendant KOG is engaged in the business of developing and distributing videogames, including but not limited to
 Elsword 
. KOG appears toderive revenue from the sale of “K-Ching,” a virtual currency that KOG’s customers use topurchase in-game enhancements. On information and belief, KOG markets and sells its games inthe United States, including within this District. On information and belief, KOG markets andsells K-Ching in-game currency in the United States, including within this District. Oninformation and belief, KOG customers, including customers within this District, downloadKOG games through KOG’s interactive websitehttp://www.elswordonline.com/ . KOG
 
3customers, including customers in this District, purchase K-Ching using a KOG website athttps://myaccount.elswordonline.com/Elsword/howtoloadup.
8.
 
On information and belief, KOG directly and/or indirectly imports,manufactures, uses, offers for sale, and/or sells the Accused Products (as defined below) withinthe United States, including this District, that infringe one or more claims of the AssertedPatents.
9.
 
Venue is proper in this District pursuant to 28 U.S.C. §§ 1400(b) and 1391(c).
GENERAL ALLEGATIONS
 
10.
 
Parallel is the owner by assignment of all rights, title, and interests in theAsserted Patents, and is entitled to sue for past and future infringement thereof.
11.
 
On information and belief, KOG is engaged in the business of developing anddistributing videogames, including but not limited to
 Elsword 
. On information and belief, KOGsells and/or distributes an installer, such as but not limited to the“ElswordDownloader_v3.0116.6.1.exe” installer (the “ElswordDownloader_v3.0116.6.1.exe”installer and all similar installers, downloaders and/or launchers referred to herein as the“Accused Products”) that is downloaded by an end-user using a KOG website, such as athttp://myaccount.elswordonline.com/Elsword/Download, through or by which KOG distributesits game or games.
FIRST CLAIM FOR RELIEF
(Infringement of the '145 Patent)
12.
 
Parallel incorporates paragraphs 1 through 11 as though fully set forth herein.
13.
 
Upon information and belief, Defendant KOG has been and now is directlyand/or indirectly infringing one or more claims of the '145 Patent by (1) making, importing,using, offering for sale, and/or selling the patented inventions, (2) by actively inducing others to

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