IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF TEXASGALVESTON DIVISIONTechRadium, Inc.
§§v.§§§§Civil Action No. 3:13-cv-227Jury Trial DemandedCity of Friendswood Texas
§§TECHRADIUM’S COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff TechRadium, Inc. brings this complaint for patent infringement against the Cityof Friendswood Texas and alleges as follows:
1. Plaintiff TechRadium, Inc. is a Texas Corporation with its principal place of business in Sugar Land, Texas.2. Defendant City of Friendswood Texas (“Friendswood”) is a political subdivisionof the State of Texas. It may be served with process by serving Kevin M. Holland, its Mayor, at910 South Friendswood Drive, Friendswood, Texas 77546, or wherever he may be found.
Jurisdiction And Venue
3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §1331 and §1338(a), because Plaintiff’s claims arise under federal laws relating to patents and unfair competition.4. This Court has personal jurisdiction over the Defendant because Defendant hastransacted business in this judicial district and has committed acts of patent infringement in this judicial district. Under 35 U.S.C. §296, Defendant is not immune from suit for infringement of a patent and Defendant is subject to all remedies, at law and in equity, as are available for such a