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EON Corp, IP Holdings v. AT&T Mobility

EON Corp, IP Holdings v. AT&T Mobility

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00910-UNA: EON Corp, IP Holdings, LLC v. AT&T Mobility LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8tD for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00910-UNA: EON Corp, IP Holdings, LLC v. AT&T Mobility LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8tD for more info.

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Published by: PriorSmart on May 23, 2013
Copyright:Public Domain

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08/05/2014

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Page 1 of 15
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF PUERTO RICOEON CORP. IP HOLDINGS, LLC,
Plaintiff,v.
 AT&T MOBILITY, LLC; AT&T MOBILITY PUERTO RICO, INC.;PUERTO RICO TELEPHONE COMPANY,INC; CLARO INC.;TELECOMUNICACIONES DE PUERTORICO, INC. AND TELEFONICA DEPUERTO RICO, INC.,
Defendants
CIVIL NUM.:REQUEST FOR TRIAL BY JURYPATENT INFRINGEMENTP
LAINTIFF
EON
 
C
ORP
.
 
IP
 
H
OLDINGS
,
 
LLC’
S
O
RIGINAL
C
OMPLAINT
 
TO
 
THE
 
HONORABLE
 
COURT:COMES
 
NOW,
 
Plaintiff EON Corp. IP Holdings, LLC (“EON”),
through the undersigned attorneys, and respectfully alleges,states, and pray as follows:
I.
 
 NATURE OF THE ACTION
1.
 
This is an action for patent infringement under thePatent Laws of the United States, Title 35 of the United States
Code (“U.S.C.”) to prevent and enjoin co
-defendants AT&T
Mobility, LLC (“AT&T LLC”), AT&T Mobility Puerto Rico, Inc.(“AT&T Puerto Rico”)(
collectively,
“AT&T”)
, and Puerto RicoTelephone Company, Inc.
(“PRTC”), Telecomunicaciones de Puer
to
Rico, Inc. (“TPRI”), Telefonica de Puerto Rico, Inc.(“TPR”) and
Claro, Inc.
(“CI”)
, all d/b/a Claro Puerto Rico, (collectively,
“Claro”) (collectively, “Defendants”) from infringing and
 
Page 2 of 15
profiting from, in an illegal and unauthorized manner andwithout authorization and/or consent from Plaintiff, U.S. Patent
No. 5,663,757 (the “’757 Patent”)
, U.S. Patent No. 5,388,101
(the “’101 Patent”), U.S. Patent No. 5,481,546 (the “’546Patent”), and U.S. Patent No. 5,592,491 (the “’491 Patent”)
 pursuant to 35 U.S.C. §271, and to recover damages, attorneys
 fees, and costs.
 II.
 
JURISDICTION AND VENUE
2.
 
The Court has subject matter jurisdiction over thisaction pursuant to 28 U.S.C. §§1331 and 1338(a).3.
 
Venue lies in this judicial district pursuant to 28U.S.C. §§1391 and 1400(b).4.
 
This Court has personal jurisdiction over eachDefendant. Upon information and belief, each Defendant hasconducted and does conduct business within Puerto Rico, directlyor through intermediaries or agents, or offers for sale, sells,or advertises (including through the provision of interactiveweb pages) products or services, or uses or induces others touse services or products in Puerto Rico that infringe the
’757
Patent, the
’101 Patent,
the
’546 Patent
 
and the ’491 Pa
tent orknowingly contributes to infringement of the asserted patents.5.
 
In addition to the specific and general jurisdictionalleged above, this Court has personal jurisdiction over AT&T
 
Page 3 of 15
because it is, upon information and belief, a wireless operatorwithin Puerto Rico, and derives substantial revenue therefrom.6.
 
In addition to AT&T continuously and systematicallyconducting business in Puerto Rico, the causes of action against
AT&T arose from or are connected with AT&T’s purposeful acts
committed in Puerto R
ico, including AT&T’s making, using,
importing, offering for sale, or selling two-way communicationnetworks, two-way communication network components, subscriberunits, associated services, or data systems that fall within thescope of at least one claim
of the ’757 Patent
,
the ’491 Patent
,
the ’101 Patent, and
 
the ’546 Patent
.7.
 
In addition to the specific and general jurisdictionalleged above, this Court has personal jurisdiction over Clarobecause it is, upon information and belief, a wireless operatorwithin Puerto Rico and derives substantial revenue therefrom.8.
 
In addition to Claro continuously and systematicallyconducting business in Puerto Rico, the causes of action against
Claro arose from or are connected with Claro’s purposeful acts
committed in P
uerto Rico, including Claro’s making, using,
importing, offering for sale, or selling two-way communicationnetworks, two-way communication network components, subscriberunits, associated services, or data systems that fall within thescope of at least on
e claim of the ’757 Patent, the ’101 Patent,the ’546 Patent, and the ’491 Patent
.

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