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Cirrex Systems v. Illumina

Cirrex Systems v. Illumina

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00336-UNA: Cirrex Systems LLC v. Illumina Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7KP for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00336-UNA: Cirrex Systems LLC v. Illumina Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7KP for more info.

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Published by: PriorSmart on Feb 28, 2013
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08/09/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
CIRREX SYSTEMS, LLC,Plaintiff v.ILLUMINA, INC.,Defendant.C.A. No.
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Cirrex Systems, LLC (“Cirrex”) alleges as follows:
PARTIES
1.
 
Cirrex is a Delaware limited liability company with a principal place of businesslocated at 4425 Mariners Ridge, Alpharetta, GA 30005.2.
 
Defendant Illumina, Inc. (“Illumina”) is a Delaware corporation with a principal place of business at 5200 Research Way, San Diego, California, 92122. Illumina has appointedThe Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington,Delaware 19801, as its agent for service of process.
JURISDICTION AND VENUE
3.
 
This action arises under the patent laws of the United States, Title 35 of theUnited States Code. Accordingly, this Court has subject matter jurisdiction under 28 U.S.C.§§ 1331 and 1338(a).4.
 
Illumina is a corporation organized and existing under the laws of the State of Delaware. Thus, Illumina has purposefully availed itself of the benefits of the state of Delaware
 
 2
and the exercise of jurisdiction over Illumina would not offend traditional notions of fair playand substantial justice.5.
 
Venue is proper in this District under 28 U.S.C. §§ 1391 (b)-(d) and 1400(b) because Illumina is subject to personal jurisdiction in this District.
FACTUAL BACKGROUND
6.
 
Optical technologies empower telecommunications, photonic instrumentation, and biomedical devices. For the past two decades, Cirrex has pioneered the development of optics,optical systems, and optical fabrication related to process control and the chemistry of fiber optics. The main objective has been to find solutions that photonic technologies can provide thatwill benefit instrumentation, communications, and healthcare. To date, Cirrex’s innovation process has provided various novel technologies that combine the effects of multipleconventional optical elements such as filters, mirrors, prisms, and lenses; these are fashioned intohighly complex designs on a microscopic scale, enabling fiber optics and lasers to attain newuses at a fraction of the size and cost previously thought possible.7.
 
For many years, it was thought to be impossible to uniquely mark or otherwiseidentify optical fibers because of their tiny size and challenging composition (
e.g.
, glass).Moreover, different types of fibers that may appear identical to the human eye can have verydifferent qualities in practice. Additionally, the size of the markings on the fiber limits thenumber of unique identifiers for fiber segments that can be cataloged and tracked at one time.8.
 
Cirrex’s solution to this problem was born out of a need to identify myriad fiber optic segments, each different from one another, to place them in a desired configuration. Eachfiber segment was different from one another in shape or composition, and the minute scale of the fiber made traditional marking technology impossible to use. It was simply not achievable to
 
 3
uniquely identify each fiber segment by writing on it due to the miniature size, nor was it possible to identify the number of fiber segments needed to create a life sciences measuringsystem. Also, markings on the fiber can negatively impact the use of that fiber, as the markingscan be deleterious to light passing through the fiber as desired.9.
 
Cirrex’s ingenious solution is to use precisely the light that the fibers are intendedto interact with as the signal of a given fiber’s identification and any special qualities it mayhave. Machine-readable identifiers can be encoded by slightly modifying the outer cladding,inner core, or both to create a signature that can positively identify an almost limitless number of fiber segments. Using light waves to encode the identifier in the fiber segment allows for theidentification tag to be made extremely small; even the smallest fiber segment can be uniquelyidentified to a machine for any application. This has allowed companies like Illumina to providesolutions in the life sciences to rapidly and efficiently detect and analyze data at low costs whiledelivering consistent performance in application areas that require the testing and analysis of large volumes of samples.
THE ASSERTED PATENTS
 10.
 
Cirrex is the owner by assignment of U.S. Patent No. 6,542,673 (the “’673 patent”). The ’673 patent is entitled “Identifier System and Components for OpticalAssemblies.” The ’673 patent issued on April 1, 2003. A true and correct copy of the ’673 patent is attached hereto as Exhibit A.11.
 
Cirrex is the owner by assignment of U.S. Patent No. 8,135,250 (the “’250 patent”). The ’250 patent is entitled “Facile Production of Optical Communication Assembliesand Components.” The ’250 patent issued on March 13, 2012. A true and correct copy of the’250 patent is attached hereto as Exhibit B.

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