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Compound Photonics v. Sony et. al.

Compound Photonics v. Sony et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01684-WQH-JMA: Compound Photonics, Ltd. v. Sony Corporation et. al. Filed in U.S. District Court for the Southern District of California, the Hon. William Q. Hayes presiding. See http://news.priorsmart.com/-l8Ls for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01684-WQH-JMA: Compound Photonics, Ltd. v. Sony Corporation et. al. Filed in U.S. District Court for the Southern District of California, the Hon. William Q. Hayes presiding. See http://news.priorsmart.com/-l8Ls for more info.

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Published by: PriorSmart on Jul 18, 2013
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07/18/2013

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UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASTYLER DIVISION
COMPOUND PHOTONICS, LTD.,Plaintiff,v.SONY CORPORATION ANDSONY ELECTRONICS, INC.,Defendants.Civil Action No. 6:11-cv-552DEMAND FOR TRIAL BY JURY
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Compound Photonics Ltd.
(“Compound Photonics”)
hereby pleads the followingclaim for patent infringement against Defendants
Sony Corporation (“Sony Corporation”) andSony Electronics, Inc. (“Sony Electronics”)
(coll
ectively the “Defendants”)
, and alleges asfollows:
JURISDICTION AND VENUE
1.
 
This is an action for patent infringement based upon and arising under the patentlaws of the United States, 35 U.S.C. § 101
et seq
., including §§ 271, 281, 283, 284 and 285.2.
 
This Court has jurisdiction over the subject matter of this action pursuant to28 U.S.C. §§ 1331 and 1338(a).3.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 (b)-(d), and28 U.S.C. § 1400(b) because Sony Corporation is subject to personal jurisdiction in this judicialdistrict, has committed acts of infringement in this judicial district, and is an alien subject to suit
 
- 2 -in this judicial district; and because Sony Electronics is subject to personal jurisdiction in this judicial district and has committed acts of infringement in this judicial district.4.
 
Specifically, Defendants have transacted and continue to transact business in theUnited States and in this judicial district by: using or causing to be used; making or causing to bemade; importing or causing to be imported; offering to sell or causing to be offered for sale;and/or selling or causing to be sold directly, through intermediaries and/or as an intermediary,infringing products to customers in the United States, including customers in this judicial district,and Defendants will continue to do so unless enjoined by this Court.5.
 
Sony Corporation, for example, is committing and is causing acts of patentinfringement within the United States and within this judicial district, including the infringingacts alleged herein, both directly, through one or more intermediaries, and as an intermediary.Sony Corporation is involved in the distribution of infringing products and has been aware and isaware that its products are being sold throughout the United States, including in Texas. SonyCorporation has caused and causes injury and damages in this judicial district by acts or omissions outside of this judicial district, including but not limited to utilization of their owndistribution channels established in the United States and
Sony Electronics‟
distribution channelsin the United States, as set forth below, to ship a variety of infringing products into the UnitedStates and into this judicial district while deriving substantial revenue from services or thingsused or consumed within this judicial district, and will continue to do so unless enjoined by thisCourt.6.
 
Sony Electronics, for example, is committing acts of patent infringement withinthe United States and within this judicial district, including the infringing acts alleged herein, both directly, through one or more intermediaries, and as an intermediary. Sony Electronics
 
- 3 -regularly imports Sony products into the United States for distribution throughout the UnitedStates, including in this judicial district. Sony Electronics is involved in the distribution of infringing products and has been aware and is aware that its products are being sold throughoutthe United States, including in Texas.
Sony Electronics‟
established distribution networksconsist of national distributors and resellers, and these Defendants sell to customers in Texas anddistribute to national retailers that have stores located in Texas. By shipping into, offering to sellin, using, or selling products that infringe the Patent-in-Suit in this judicial district, SonyElectronics has transacted and transacts business and performs works and services in this judicialdistrict, has contracted and contracts to supply services and things in this judicial district, havecaused and causes injury and damages in this judicial district by acts and omissions in this judicial district, and has caused and causes injury and damages in this judicial district by acts or omissions outside of this judicial district while deriving substantial revenue from services or things used or consumed within this judicial district, and will continue to do so unless enjoined by this Court.
THE PARTIES
7.
 
Plaintiff Compound Photonics is a United Kingdom corporation, having its principal place of business at Gunpowder House, 66-68 Great Suffolk Street, Southwark,London, SE1-0BL United Kingdom.8.
 
On information and belief, Defendant Sony Corporation is a Japanese corporationwith its principal place of business at 1-7-1, Konan, Minato-ku, Tokyo, 108-0075 Japan.9.
 
According to Sony Corporation, it
is one of the world‟s largest manufacturers of 
electronics and information technology products for the consumer and business markets. Oninformation and belief, Sony Corporation manufactures LCD projection products in Japan and

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