Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Canatelo v. LG Electronics et. al.

Canatelo v. LG Electronics et. al.

Ratings: (0)|Views: 65|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01149: Canatelo, LLC v. LG Electronics, Inc. et. al. Filed in U.S. District Court for the District of Puerto Rico, no judge yet assigned. See http://news.priorsmart.com/-l7Gp for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01149: Canatelo, LLC v. LG Electronics, Inc. et. al. Filed in U.S. District Court for the District of Puerto Rico, no judge yet assigned. See http://news.priorsmart.com/-l7Gp for more info.

More info:

Published by: PriorSmart on Feb 22, 2013
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

02/22/2013

pdf

text

original

 
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF PUERTO RICO
C
ANATELO
,
 
LLC
Plaintiff,
v.
LG
 
ELECTRONICS,
 
INC.
AND
LG
 
ELECTRONICS
 
U.S.A.,
 
INC.
 
Defendants.
C
IVIL
N
UM
:P
LAINTIFF REQUESTS
T
RIAL BY
J
URY
 P
ATENT
I
NFRINGEMENT
 
COMPLAINT FOR PATENT INFRINGEMENT
TO THE HONORABLE COURT:
COMES NOW, Canatelo, LLC (“Canatelo”), by and through its undersigned counsel, for 
its Complaint against
LG Electronics, Inc. (hereinafter, “LGE”) and LG Electronics U.S.A., Inc.(hereinafter, “LG USA”) (collectively, “Defendants”), respectfully alleges, states, and prays as
follows:
N
ATURE OF THE
A
CTION
 
1.
 
This is an action for patent infringement arising under the patent laws of the
United 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 Canatelo, from U.S. P
atent No. 7,310,111 (the “’111 Patent”) and U.S.Patent No. 6,476,858 (the “‘858 Patent”)
(attached hereto as Exhibits A and B respectively)
(collectively, the “Asserted Patents”), pursuant to 35 U.S.C. §271, and to recover damages,attorneys’ fees, and co
sts.
 
2
T
HE
P
ARTIES
 
2.
 
Plaintiff Canatelo is a Puerto Rico limited liability company with its principal place of business at Martinal Plaza, Aldea St. 1414, Suite 402, San Juan, Puerto Rico 00907.3.
 
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.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 LG
USA’s registered agent for service of process is United States Corporation Company, 2711
Centerville Road, Suite 400, Wilmington, Delaware 19808.
J
URISDICTION AND
V
ENUE
 
6.
 
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.7.
 
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 Canatelo andthe cause of action Canatelo has raised, as alleged herein.8.
 
Defendants are subject to this Court’s specific and
general personal jurisdiction pursuant to due process and/or the Puerto Rico long-arm statute, P.R. Laws Ann. Tit 32 App. V,
 
3
R. 3.1(a)(2), due to at least their substantial business in this forum, including: (i) at least a portion of the infringement alleged herein; and (ii) regularly doing or soliciting business,engaging in other persistent courses of conduct, and/or deriving substantial revenue from goodsand services provided to individuals in Puerto Rico.9.
 
Defendants have conducted and do conduct business within Puerto Rico, directlyor through intermediaries, resellers, agents, or offers for sale, sells, and/or advertises (includingthe use of interactive web pages with promotional material) products in Puerto Rico that infringethe Asserted Patents.10.
 
I
n addition to Defendants’ continuously and systematically conducting business in
Puerto Rico, the causes of action against Defendants are connected (but not limited) to
Defendants’ purposeful acts committed in Puerto Rico, including Defendants’ making, usi
ng,importing, offering for sale, or selling products which include features that fall within the scopeof at least one claim of each of the Asserted Patents.11.
 
At the time of the invention, all three inventors of the Asserted Patents wereresiding in Puerto Rico. Thus, the Asserted Patents grew out of invention and innovation thattook place in Puerto Rico.12.
 
Moreover, Canatelo is owned by a local Puerto Rico entrepreneur, who acquiredthe Asserted Patents as a way to further incentivize local innovation. Thus, the current owner of the Asserted Patents has availed itself of legal rights, duties and obligations within the district.13.
 
Venue lies in this District under 28 U.S.C. §§1391 and 1400(a) because, amongother reasons, Defendants are subject to personal jurisdiction in this District, and have committedand continue to commit acts of patent infringement in this District. For example, Defendantshave used, sold, offered for sale, and/or imported infringing products in this District.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->