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Bluebonnet Telecommunications v. Nokia et. al.

Bluebonnet Telecommunications v. Nokia et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00509: Bluebonnet Telecommunications L.L.C. v. Nokia Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8Cc for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00509: Bluebonnet Telecommunications L.L.C. v. Nokia Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8Cc for more info.

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Published by: PriorSmart on Jun 19, 2013
Copyright:Public Domain

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06/19/2013

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1
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISION
BLUEBONNETTELECOMMUNICATIONS L.L.C.,Plaintiff,v. NOKIA INC. AND NOKIA CORPORATION,Defendants.CIVIL ACTION NO.
JURY TRIAL DEMANDEDORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Bluebonnet Telecommunications, L.L.C. (“Bluebonnet”) files this originalcomplaint against Nokia, Inc. and Nokia Corporation alleging, based on its own knowledgeas to itself and its own actions and based on information and belief as to all other matters,as follows:
PARTIES
1.
 
Bluebonnet is a corporation formed under the laws of the State of Texas,with a principal place of business in Longview, Texas.2.
 
Defendant Nokia, Inc. (“Nokia Inc.”) is a corporation organized under thelaws of the state of Delaware, with a principal place of business in White Plains, NewYork. Nokia Inc. can be served with process by serving its registered agent: 1021 MainStreet, Suite 1150, Houston, TX 77002.3.
 
Defendant Nokia Corporation (“Nokia Corp.”) is a corporation organized under the laws of Finland, with a principal place of business in Espoo, Finland. Nokia
 
2Corp. may be served at its principal place of business at Keilahadentie 2-4, FI-02150Espoo, Finland.
JURISDICTION AND VENUE
4.
 
This is an action for infringement of a United States patent arising under 35U.S.C. §§ 271, 281, and 284–85, among others. This Court has subject matter jurisdictionof the action under 28 U.S.C. §1331 and §1338(a).5.
 
Venue is proper in this district pursuant to 28 U.S.C. §§ 1391 and 1400(b).Upon information and belief, the defendants have transacted business in this district and have committed, by itself or in concert with others, acts of patent infringement in thisdistrict.6.
 
The defendants are subject to this Court’s specific and general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least toDefendants’ substantial business in this forum, including: (i) at least a portion of theinfringements alleged herein; and/or (ii) regularly doing or soliciting business, engaging inother persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals in Texas and in this district.
JOINDER
7.
 
Defendants are properly joined under 35 U.S.C. § 299(a)(1) because a rightto relief is asserted against the parties jointly, severally, and in the alternative with respectto the same transaction, occurrence, or series of transactions or occurrences relating to themaking, using, importing into the United States, offering for sale, and/or selling the sameaccused products. Specifically, as alleged in detail below, defendants are alleged to
 
3infringe the patent in suit with respect to a large number of overlapping smartphone products.8.
 
Defendants are properly joined under 35 U.S.C. § 299(a)(2). Questions of fact will arise that are common to all defendants, including for example, whether theoverlapping smartphone products alleged to infringe have features that meet the limitationsof one or more claims of the patent-in-suit, and what reasonable royalty will be adequate tocompensate the owner of the patent-in-suit for its infringement.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 5,485,511
9.
 
On June 16, 1996, United States Patent No. 5,485,511 (“the 511 patent”)was duly and legally issued by the United States Patent and Trademark Office for aninvention entitled “Method and Apparatus for Determining the Telephony FeaturesAssigned to a Telephone.”10.
 
Bluebonnet is the owner of the 511 patent with all substantive rights in and to that patent, including the sole and exclusive right to prosecute this action and enforcethe 511 patent against infringers, and to collect damages for all relevant times.11.
 
 Nokia Inc. and Nokia Corp. (collectively “Nokia”) directly or throughintermediaries, made, had made, used, imported, provided, supplied, distributed, sold and/or offered for sale products and/or systems (including at least the N97) that infringed one or more claims of the 511 patent.
 
12.
 
 Nokia has and is directly infringing the 511 patent.

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