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Cellular Communications Equipment v. Dell

Cellular Communications Equipment v. Dell

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00569: Cellular Communications Equipment LLC v. Dell Inc. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8RA for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00569: Cellular Communications Equipment LLC v. Dell Inc. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8RA 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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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASTYLER DIVISION
CELLULAR COMMUNICATIONSEQUIPMENT LLC,Plaintiff,v.DELL INC.Defendant.§§§§§§§§§§§§§§CIVIL ACTION NO. 6:13cv569
JURY TRIAL DEMANDEDPLAINTIFF’S ORIGINAL COMPLAINTFOR PATENT INFRINGEMENT
Plaintiff Cellular Communications Equipment LLC files this Original Complaint againstDell Inc. for infringement of U.S. Patent No. 6,819,923 (“the ’9923 patent”), U.S. Patent No.7,215,962 (“the ’962 patent”), U.S. Patent No. 7,941,174 (“the ’174 patent”), and U.S. Patent No. 8,055,820 (“the ’820 patent”).
THE PARTIES
1.
 
Cellular Communications Equipment LLC (“CCE”) is a Texas limited liabilitycompany with its principal place of business in Plano, Texas.2.
 
Dell Inc. (“Dell” or “Defendant”) is a Delaware corporation with its principal place of business in Round Rock, Texas. Defendant may be served with process through itsagent, Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware19808. Defendant does business in the State of Texas and in the Eastern District of Texas.
 
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JURISDICTION AND VENUE
3.
 
This action arises under the patent laws of the United States, namely 35 U.S.C. §§271, 281, and 284-285, among others.4.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a), and 1367.5.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and (c),and 1400(b). On information and belief, Defendant is deemed to reside in this judicial district,has committed acts of infringement in this judicial district, has purposely transacted business inthis judicial district, and/or has regular and established places of business in this judicial district.6.
 
On information and belief, Defendant is subject to this Court’s specific and general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due atleast to their substantial business in this State and judicial district, including: (A) at least part of their infringing activities alleged herein; and (B) regularly doing or soliciting business, engagingin other persistent conduct, and/or deriving substantial revenue from goods sold and services provided to Texas residents.
COUNT I
(INFRINGEMENT OF U.S. PATENT NO. 6,819,923)7.
 
CCE incorporates paragraphs 1 through 6 herein by reference.8.
 
CCE is the assignee of the ’9923 patent, entitled “Method for Communication of  Neighbor Cell Information,” with ownership of all substantial rights in the ’9923 patent,including the right to exclude others and to enforce, sue and recover damages for past and futureinfringements. A true and correct copy of the ’9923 patent is attached as Exhibit A.9.
 
The ’9923 patent is valid, enforceable and was duly issued in full compliance withTitle 35 of the United States Code.
 
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10.
 
Defendant has and continues to directly infringe one or more claims of the ’9923 patent in this judicial district and elsewhere in Texas and the United States, including at leastclaim 11, by, among other things, making, using, offering for sale, selling and/or importing Delldevices, including, for example: the XPS 10 Tablet, the DW5630 Mini Card (alone and included in Dell computer systems), the DW5560 Mini Card (alone and included in Dell computer systems), the DW5804 Mini Card (alone and included in Dell computer systems), and theDW5540 Mini Card (alone and included in Dell computer systems). These devices arecollectively referred to as the “’9923 Dell Devices.”11.
 
Defendant directly infringes the apparatus claims of the ’9923 patent by making,offering to sell, selling, and/or importing the ’9923 Dell Devices. Defendant is thereby liable for direct infringement.12.
 
CCE has been damaged as a result of Defendant’s infringing conduct described inthis Count. Defendant is, thus, liable to CCE in an amount that adequately compensates it for their infringements, which, by law, cannot be less than a reasonable royalty, together withinterest and costs as fixed by this Court under 35 U.S.C. § 284.
COUNT II
(INFRINGEMENT OF U.S. PATENT NO. 7,215,962)13.
 
CCE incorporates paragraphs 1 through 6 herein by reference.14.
 
CCE is the assignee of the ’962 patent, entitled “Method for an IntersystemConnection Handover,” with ownership of all substantial rights in the ’962 patent, including theright to exclude others and to enforce, sue and recover damages for past and futureinfringements. A true and correct copy of the ’962 patent is attached as Exhibit B.15.
 
The ’962 patent is valid, enforceable and was duly issued in full compliance withTitle 35 of the United States Code.

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