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Cloud Satchel v. Sony Electronics et. al.

Cloud Satchel v. Sony Electronics et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01381-UNA: Cloud Satchel LLC v. Sony Electronics Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8Rg for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01381-UNA: Cloud Satchel LLC v. Sony Electronics Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8Rg for more info.

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Published by: PriorSmart on Aug 02, 2013
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08/02/2013

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  _____________________________________________________________________________ 
PLAINTIFF CLOUD SATCHEL LLC
sCOMPLAINT FOR PATENT INFRINGEMENT AND REQUEST FOR JURY TRIAL Page 1 of 9
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARECLOUD SATCHEL LLCPlaintiff,v.SONY ELECTRONICS, INC., andSONY CORPORATIONDefendant.Civil Action No.JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Cloud Satchel LLC, by way of Complaint against Defendants Sony Electronics,Inc. and Sony Corporation (collectively
Sony
”)
, alleges the following:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the Patent Laws of theUnited States, 35 U.S.C. § 1
et seq
.
THE PARTIES
2.
 
Plaintiff Cloud Satchel is a limited liability company organized under the laws of the State of Delaware with its place of business at 1220 North Market Street, Suite 806,Wilmington, Delaware 19801.3.
 
Defendant Sony Electronics, Inc. is a corporation organized under the laws of theState of Delaware with its principal place of business at 16530 Via Esprillo, San Diego,California 92127.4.
 
Defendant Sony Corporation is company organized under the laws of Japan with a place of business at 7-1, Konan, 1-Chrome, Minato-ku, Tokyo, Japan 108-0075.
 
  _____________________________________________________________________________ 
PLAINTIFF CLOUD SATCHEL LLC
sCOMPLAINT FOR PATENT INFRINGEMENT AND REQUEST FOR JURY TRIAL Page 2 of 9
JURISDICTION AND VENUE
5.
 
This is an action for patent infringement arising under the Patent Laws of theUnited States, Title 35 of the United States Code.6.
 
This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338.7.
 
Sony Electronics, Inc. is subject to the jurisdiction of this Court by virtue of beingincorporated in Delaware. On information and belief, all Defendants are subject to the jurisdiction of this Court by reason of their acts of patent infringement which have beencommitted in this Judicial District, and by virtue of their regularly conducted and systematic business contacts in this State. As such, Defendants have purposefully availed themselves of the privilege of conducting business within this Judicial District; have established sufficientminimum contacts with this Judicial District such that they should reasonably and fairlyanticipate being haled into court in this Judicial District; have purposefully directed activities atresidents of this State; and at least a portion of the patent infringement claims alleged herein ariseout of or are related to one or more of the foregoing activities.8.
 
Venue is proper in this judicial district under 28 U.S.C. §§ 1391(c) and 1400(b).
COUNT I
 – 
INFRINGEMENT OF U.S. PATENT No. 5,862,321
9.
 
The allegations set forth in the foregoing paragraphs 1 through 8 are hereby re-alleged and incorporated herein by reference.10.
 
On January 19, 1999, United States Patent No. 5,862,321
, entitled “
System andMethod For Accessing And Distributing Electronic Documents
,” was duly and legally issued by
the United States Patent and Trademark Office. A t
rue and correct copy of the ’321
Patent isattached as Exhibit A to this Complaint.
 
  _____________________________________________________________________________ 
PLAINTIFF CLOUD SATCHEL LLC
sCOMPLAINT FOR PATENT INFRINGEMENT AND REQUEST FOR JURY TRIAL Page 3 of 9
11.
 
Cloud Satchel is the assignee and owner of the entire right, title, and interest inand to the
321 Patent, including the right to assert all causes of action arising under said patentand the right to any remedies for infringement.12.
 
In violation of 35 U.S.C. § 271(a), Sony has directly infringed, and continues todirectly infringe, the
321 Patent both literally and under the doctrine of equivalents. Sony
sinfringement includes its making, testing, using, importing, selling, and offering to sell certain portable products that control the transport of electronic documents; its making, testing, andusing the web-
 based storage system (hereinafter “Accused Storage and Delivery System”)
whichfunctions with such portable products to store and deliver electronic documents; and, its performing methods which involve such portable products and Accused Storage and Delivery
System, that practice the subject matter recited in one or more claims of the ’321 Patent,
including but not limited to claims 1, 15, and 19. Sony
s infringing acts are performed in theUnited States, including within this Judicial District, without the authorization of Cloud Satchel.The accused portable products include Sony
s line of eReaders and tablets (collectively
eReaders
”) as they connect and operate with
Sony
s web-based networked system, includingthe Sony Reader Store, and the means Sony employs to store and produce documents from itsReader Store. The accused eReaders include the Sony PRS series of eReaders, the Sony Xperiatablets, and any variations of these models. Sony infringes by making, testing, and using theAccused Storage and Delivery System, and infringes by making, using, testing, importing, providing, selling, and offering to sell its eReaders. The infringing methods include the methodof operating the eReaders, including how electronic document references are received anddistributed in response to the functioning of the eReaders with respect to the Accused Storage

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