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Innovative Display Technologies v. ZTE et. al.

Innovative Display Technologies v. ZTE et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00527: Innovative Display Technologies LLC v. ZTE Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8EL for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00527: Innovative Display Technologies LLC v. ZTE Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8EL for more info.

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Published by: PriorSmart on Jun 28, 2013
Copyright:Public Domain

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06/29/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONINNOVATIVE DISPLAYTECHNOLOGIES LLC,Plaintiff,v.ZTE CORPORATION andZTE (USA) INC.,Defendants.§§§§§§§§§§§§§C.A. No. ______JURY TRIAL DEMANDEDPLAINTIFF’S COMPLAINT
Plaintiff Innovative Display Technologies LLC, by and through its undersigned counsel,files this Complaint against Defendants ZTE Corporation and ZTE (USA) Inc. (collectively,“ZTE”).
THE PARTIES
1.
 
Innovative Display Technologies LLC is a Texas limited liability company with its principal place of business located at 2400 Dallas Parkway, Suite 200, Plano, TX 75093.2.
 
Upon information and belief, ZTE Corporation (“ZTE Corp.”) is limited companyincorporated in China located at ZTE Plaza, Keji Road South, Hi-Tech Industrial Park, NanshanDistrict, Shenzhen, Guangdong Province, P.R. China 518057. Upon information and belief, ZTECorp. may be served with process in P.R. China pursuant to the Hague Convention on the ServiceAbroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters.3.
 
Upon information and belief, ZTE (USA) Inc. (“ZTE USA”) is a New JerseyCorporation located at 33 Wood Avenue South, 7
th
Floor, Iselin, NJ 08830 and with headquarters
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at 2425 North Central Expressway, Suite 323, Richardson, TX 75080. Upon information and  belief, ZTE USA may be served with process by serving its registered agent, Li Mo, 4585 Spencer Dr., Plano, TX 75024.4.
 
Upon information and belief, ZTE Corp. is the parent of ZTE USA.5.
 
Upon information and belief, ZTE has conducted and regularly conducts businesswithin this District, has purposefully availed itself of the privileges of conducting business in thisDistrict, and has sought protection and benefit from the laws of the State of Texas.
JURISDICTION AND VENUE
6.
 
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1,
et seq.
,including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has subject matter jurisdictionover this case for patent infringement under 28 U.S.C. §§ 1331 and 1338(a).7.
 
As further detailed herein, this Court has personal jurisdiction over ZTE USA. ZTEUSA is amenable to service of summons for this action. Furthermore, personal jurisdiction over ZTE USA in this action comports with due process. ZTE USA maintains headquarters at 2425 North Central Expressway, Suite 323, Richardson, TX 75080. ZTE USA has conducted and regularly conducts business within the United States and this District. ZTE USA has purposefullyavailed itself of the privileges of conducting business in the United States, and more specificallyin Texas and this District. ZTE USA has sought protection and benefit from the laws of the Stateof Texas by maintaining headquarters in Richardson, TX, and/or by placing infringing productsinto the stream of commerce through an established distribution channel with the awareness and/or intent that they will be purchased by consumers in this District.8.
 
ZTE USA – directly or through intermediaries (including distributors, retailers, and others), subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sells its
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 products in the United States and this District. ZTE USA has purposefully and voluntarily placed one or more of its infringing products, as described below, into the stream of commerce with theawareness and/or intent that they will be purchased by consumers in this District. ZTE USAknowingly and purposefully ships infringing products into and within this District through anestablished distribution channel. These infringing products have been and continue to be purchased  by consumers in this District. Upon information and belief, through those activities, ZTE USA hascommitted the tort of patent infringement in this District and/or has induced others to commit patent infringement in this District. Plaintiff’s cause of action for patent infringement arisesdirectly from ZTE USA’s activities in this District.9.
 
As further detailed herein, this Court has personal jurisdiction over ZTE Corp. ZTECorp. is amenable to service of summons for this action. Furthermore, personal jurisdiction over ZTE Corp. in this action comports with due process. ZTE Corp. has conducted and regularlyconducts business within the United States and this District. ZTE Corp. has purposefully availed itself of the privileges of conducting business in the United States, and more specifically in Texasand this District. ZTE Corp. has sought protection and benefit from the laws of the State of Texas by maintaining offices of its United States subsidiaries in Texas and/or by placing infringing products into the stream of commerce through an established distribution channel with theawareness and/or intent that they will be purchased by consumers in this District.10.
 
ZTE Corp. – directly or through intermediaries (including distributors, retailers,and others), subsidiaries, alter egos, and/or agents – ships, distributes, offers for sale, and/or sellsits products in the United States and this District. ZTE Corp. has purposefully and voluntarily placed one or more of its infringing products, as described below, into the stream of commercewith the awareness and/or intent that they will be purchased by consumers in this District. ZTE
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