Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
Wireless Mobile Devices v. Huawei Technologies Et. Al.

Wireless Mobile Devices v. Huawei Technologies Et. Al.

Ratings: (0)|Views: 66|Likes:
Published by PatentBlast
Wireless Mobile Devices v. Huawei Technologies et. al.
Wireless Mobile Devices v. Huawei Technologies et. al.

More info:

Published by: PatentBlast on May 23, 2013
Copyright:Attribution Non-commercial

Availability:

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

05/23/2013

pdf

text

original

 
1
IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXASDALLAS DIVISION
 
WIRELESS MOBILE DEVICES LLC,Plaintiff,v.HUAWEI TECHNOLOGIES CO. LTD.;HUAWEI DEVICE USA INC.; and T-MOBILEUS, INC.,Defendants.
Case No. ____________ JURY TRIAL REQUESTED
PLAINTIFF’S
ORIGINAL COMPLAINTFOR PATENT INFRINGEMENT
Plaintiff Wireless Mobile Devices LLC files this Original Complaint against HuaweiTechnologies Co. Ltd.; Huawei Device USA Inc.; and T-Mobile US, Inc. (collectively,
“Defendants”)
for infringement of U.S. Patent No. 6,560,604 (
“the ’604 patent”); U.S. Patent No. 7,082,365 (“the ’365 patent”); U.S. Patent No. 7,856,315 (“the ’315 patent”);
and/or U.S.Patent No. 7,321,826
(“the ’
826
 patent”)
.
THE PARTIES
1.
 
Wireless Mobile Devices LLC is a Texas limited liability company with its principal place of business in Plano, Texas.2.
 
Huawei Technologies Co. Ltd. is a
People’s
Republic of China corporation withits principal place of business in Shenzhen, P.R.C. On information and belief, this Defendantmay be served with process at its principal place of business at Huawei Industrial Base, BantianLonggang, Shenzhen, P.R.C.3.
 
Huawei Device USA Inc.
(with Huawei Technologies Co. Ltd., “Huawei”)
is aTexas corporation with its principal place of business in Plano, Texas. This Defendant may be
 
2served with process in Texas through its registered agent, C T Corporation System, 350 North St.Paul Street, Suite 2900, Dallas, Texas 75201-4234.4.
 
T-
Mobile US, Inc. (“T
-
Mobile”) is a Delaware corporation with its principal place
of business in Bellevue, Washington. This Defendant may be served with process in Delawarethrough its registered agent, Corporation Service Company, 2711 Centerville Road, Suite 400,Wilmington, Delaware 19808.
JURISDICTION AND VENUE
5.
 
Wireless Mobile Devices LLC brings this action for patent infringement under the patent laws of the United States, namely 35 U.S.C. §§ 271, 281, and 284
 – 
285, among others.This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a), and 1367.6.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(c) and1400(b). Each Defendant is deemed to reside in this judicial district, has committed acts of infringement in this judicial district, has purposely transacted business involving its accused products in this judicial district, and/or has regular and established places of business in this judicial district.7.
 
Each Defendant is subject to this Court’
s specific and general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least to itssubstantial business in this State and judicial district, including: (A) at least part of its infringingactivities alleged herein; and (B) regularly doing or soliciting business, engaging in other  persistent conduct, and/or deriving substantial revenue from goods sold and services provided toTexas residents.
COUNT I
(INFRINGEMENT OF U.S. PATENT NO. 6,560,604)
 
38.
 
Wireless Mobile Devices LLC incorporates paragraphs 1 through 7 herein byreference.9.
 
This cause of action arises under the patent laws of the United States, and in particular, 35 U.S.C. §§ 271,
et seq.
 10.
 
Wireless Mobile Devices LLC is the exclusive licensee of the
’604
 patent, entitled
“System
, method, and apparatus for automatically and dynamically updating options, features,and/or services available to a client device,
with ownership of all substantial rights in the
’604
 patent. Wireless Mobile Devices LLC has the exclusive right to exclude others and the exclusiveright to enforce, sue and recover damages for the past and future infringement, including theexclusive right to exclude Defendants and exclusive right to sue Defendants. A true and correctcopy of the
’604
 patent is attached as Exhibit A.11.
 
The
’604
 patent is valid, enforceable and was duly issued in full compliance withTitle 35 of the United States Code.12.
 
Huawei has directly infringed and continues to directly infringe one or more
claims of the ’604 patent in this judicial district and elsewhere in Texas and the United States,
including at least claim 14, by, among other things, making, using, offering for sale, sellingand/or importing computerized communication devices including, without limitation, the HuaweiPremia 4G
. Huawei and persons who acquire and use such devices, including Huawei’scustomers, have, at a minimum, directly infringed the ’604
patent, and Huawei is thereby liable
for direct infringement of the ’604 patent pursuant to 35 U.S.C. § 271.
 13.
 
T-Mobile has directly infringed and continues to directly infringe one or more
claims of the ’604 patent in this judicial district and elsewhere in Texas and the United States,
including at least claim 14, by, among other things, making, using, offering for sale, selling

You're Reading a Free Preview

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