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Beacon Navigation v. Daimler et. al.

Beacon Navigation v. Daimler et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-11455-PJD-MAR: Beacon Navigation GmbH v. Daimler AG et. al. Filed in U.S. District Court for the Eastern District of Michigan, the Hon. Patrick J. Duggan presiding. See http://news.priorsmart.com/-l7U7 for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-11455-PJD-MAR: Beacon Navigation GmbH v. Daimler AG et. al. Filed in U.S. District Court for the Eastern District of Michigan, the Hon. Patrick J. Duggan presiding. See http://news.priorsmart.com/-l7U7 for more info.

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Published by: PriorSmart on Mar 29, 2013
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03/29/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWAREBEACON NAVIGATION GMBH,
Plaintiff,
v
.
DAIMLER AG; DAIMLER NORTHAMERICA CORPORATION; MERCEDES-BENZ USA, LLC; AND MERCEDES-BENZU.S. INTERNATIONAL, INC.,
Defendants.
Civil Action No.
 JURY TRIAL DEMANDEDCOMPLAINT
Plaintiff Beacon Navigation GmbH (“Beacon” or “Plaintiff”), for its Complaint againstDefendants Daimler AG (“Daimler”), Daimler North America Corporation (“Daimler NorthAmerica”), Mercedes-Benz USA, LLC (“Mercedes-Benz USA”), and Mercedes-Benz U.S.International, Inc. (“Mercedes-Benz U.S. International”) states and alleges as follows:
 THE PARTIES
1.
 
Plaintiff Beacon is a Swiss company with limited liability with a principal placeof business in Switzerland.2.
 
Upon information and belief, Defendant Daimler AG is a German corporationwith a principal place of business at Mercedesstrasse 137, 70327 Stuttgart, Germany.3.
 
Upon information and belief, Defendant Daimler North America Corporation is aDelaware corporation with its principal place of business at 36455 Corporate Dr., FarmingtonHills, MI 48331.4.
 
Upon information and belief, Defendant Mercedes-Benz USA, LLC is a Delaware
 
2corporation with its principal place of business at One Mercedes Drive, Montvale, NJ 07645.5.
 
Upon information and belief, Defendant Mercedes-Benz U.S. International, Inc. isan Alabama corporation with its principal place of business at One Mercedes Drive, Vance, AL35490.
 JURISDICTION AND VENUE
6.
 
 This action arises under the patent laws of the United States, 35 U.S.C. § 1
et seq
.,including 35 U.S.C. § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1338(a).7.
 
Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b), 1391(c),1391(d) and/or 1400(b) because (1) a substantial part of the events giving rise to Beacon’s claimsoccurred in the District of Delaware, (2) because each of the Defendants is either resident in orotherwise subject to personal jurisdiction in the District of Delaware, or is an alien, or (3) each of the Defendants has committed acts of infringement in and has a regular and established place of business in the District of Delaware.
BACKGROUND
8.
 
Beacon owns all right, title and interest in U.S. Patent No. 6,374,180 (the “’180patent”); U.S. Patent No. 6,178,380 (the “’380 patent”); U.S. Patent No. 6,029,111 (the “’111patent”) and U.S. Patent No. 5,862,511 (the “’511 patent”) (collectively, the “patents-in-suit”).9.
 
 The ’180 patent, entitled Points of Interest for a Navigation System,was dulyand legally issued by the United States Patent and Trademark Office on April 16, 2002, after fulland fair examination. A copy of the 180 patent is attached hereto as Exhibit A.10.
 
 The ’380 patent, entitled Street Identification for a Map Zoom of a NavigationSystem,” was duly and legally issued by the United States Patent and Trademark Office on
 
3 January 23, 2001, after full and fair examination. A copy of the ’380 patent is attached hereto asExhibit B.11.
 
 The ’111 patent, entitled Vehicle Navigation System and Method Using GPSVelocities,” was duly and legally issued by the United States Patent and Trademark Office onFebruary 22, 2000, after full and fair examination. A copy of the 111 patent is attached heretoas Exhibit C.12.
 
 The ’511 patent, entitled Vehicle Navigation System and Method,was duly andlegally issued by the United States Patent and Trademark Office on January 19, 1999, after fulland fair examination. A copy of the 511 patent is attached hereto as Exhibit D.13.
 
Daimler, Daimler North America, Mercedes-Benz USA, and Mercedes-Benz U.S.International manufacture, sell and distribute vehicles with navigation systems, including but notlimited to the Mercedes E350.
COUNT IINFRINGEMENT OF THE ’180 PATENT
14.
 
Beacon incorporates each of the preceding paragraphs 1-13 as if fully set forthherein.15.
 
Daimler, Daimler North America, Mercedes-Benz USA, and Mercedes-Benz U.S.International have been and are infringing literally and/or under the doctrine of equivalents,directly, contributorily, or by inducement, at least claim 1 of the ’180 patent.16.
 
Daimler, Daimler North America, Mercedes-Benz USA, and Mercedes-Benz U.S.International directly infringe, in violation of 35 U.S.C. § 271(a), by making, using, selling,offering for sale, and/or importing in or into the United States, without authority, products thatpractice the ’180 patent, including but not limited to the Mercedes E350.

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