COMPLAINT FOR PATENT INFRINGEMENT(Case No. 13cv1244) ............................................... 2
123456789101112131415161718192021222324252627THE PARTIES2. Plaintiff Wei-Jen Tseng (“Plaintiff” or “Mr. Tseng”) is a Taiwanese citizenresiding in Taiwan.3. Upon information and belief, Defendant Wal-Mart Stores, Inc. (“Wal-Mart”) isa Delaware Corporation with a principle place of business in Bentonville, Arkansas.4. Upon information and belief, Defendant So Yang Enterprise Co., Ltd. (“SoYang”) is a Taiwanese Corporation with an address at 123 Lane 99 Bunding RD, Hsinchu,Taiwan.JURISDICTION AND VENUE5. This action arises under the Patent Act, 35 U.S.C. § 271
The Court hasoriginal jurisdiction of such claims pursuant to 28 U.S.C. §§ 1331, 1332 and 1338(a).6. Venue in this judicial district is proper under 28 U.S.C. §§ 1391(b), (c), (d),and/or 1400(b). Defendants have entered, and are currently in, this judicial district. Oninformation and belief, Defendants have and continue to distribute and sell into this districtinfringing products and a substantial part of the events giving rise to the claims occurred in thisdistrict.PLAINTIFF AND HIS RIGHTS7. Plaintiff Wei-Jen Tseng is the owner by assignment of the patent-in-suit, whichis used under an agreement with Mr. Tseng by an industry leader in the design, manufacture,marketing and sale of a variety of lighting and other electrical products, including holidaylights and components of holiday light strings.8. On May 7, 2002, the United States Patent and Trademark Office issued toPlaintiff’s father Jeou-Nan Tseng United States Patent No. 6,382,810 (hereinafter “the ’810Patent”), entitled “Ornamental Lamp.” The ’810 patent is valid, enforceable, and subsisting.