COMPLAINT FOR PATENT INFRINGEMENT
Texas and in the Eastern District of Texas; Nokia regularly conduct and solicit business withinthe State of Texas and within the Eastern District of Texas; and causes of action arise directlyfrom Nokia
’s business contacts and other activities in the State of Texas and
in the EasternDistrict of Texas.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,418,131
NCKU is the owner of all rights, title and interest to United States Patent No.7,418,131 B2
Patent”) entitled “
Image-Capturing Device and Method For RemovingStrangers From An Image
.” The ‘131
Patent was issued on August 26, 2008 after a full and fair examination by the United States Patent and Trademark Office. The application leading to the
Patent was filed on July 6, 2005. Attached as Exhibi
t “A” is a copy of the ‘131
Patent is generally an image capturing device and method for removingstrangers from an image and more particularly, to an image-capturing device and method for comparing the captured image with an image database, removing an unwanted object from animage and filing the region left after removing the unwanted object.9.
On information and belief, Nokia have been and now are infringing the
Patent in the State of Texas, in this judicial district, and elsewhere in the United States bymaking, using, importing, selling or offering to sell devices used to remove unwanted objectsfrom an image that incorporate methods, and system units according to the
Patent. Oninformation and belief, examples of
s products that infringe the
Patent include, butare not limited to, all Nokia products using image-capturing methods for removing an unwantedobject from an image, including the Nokia Lumina 925. Nokia is thus liable for infringement of
the ‘131 Pat
ent pursuant to 35 U.S.C. § 271.