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Adaptix v. NEC CASIO Mobile Communications et. al.

Adaptix v. NEC CASIO Mobile Communications et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Adaptix, Inc. v. NEC CASIO Mobile Communications, Ltd. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8SU for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Adaptix, Inc. v. NEC CASIO Mobile Communications, Ltd. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8SU for more info.

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Published by: PriorSmart on Aug 07, 2013
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10/01/2013

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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXASTYLER DIVISION
)
ADAPTIX, INC.,
))Plaintiff, ))v. ) Civil Action No. 6:13-cv-00585) NEC CASIO MOBILE ) JURY TRIAL DEMANDEDCOMMUNICATIONS, LTD., ) NEC CORPORATION OF AMERICA, )
AT&T, INC.,
AT&T MOBILITY LLC, )and CELLCO PARTNERSHIP
d/b/a 
)VERIZON WIRELESS, ))Defendants. ))
ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
This is an action for patent infringement in which plaintiff, ADAPTIX, Inc.(“ADAPTIX”), complains against Defendants NEC Casio Mobile Communications, Ltd. (“NECCasio”), NEC Corporation of America (“NEC America”), AT&T, Inc. and AT&T Mobility LLC(collectively “AT&T”), and Cellco Partnership
d/b/a
Verizon Wireless (“Verizon”) (NEC Casio, NEC America, AT&T, and Verizon may be referred to collectively as “Defendants”), as follows:1.
 
ADAPTIX is a Delaware corporation with a principal place of business in theEastern District of Texas at 2400 Dallas Parkway, Suite 200, Plano, Texas 75093.
THE PARTIES
 2.
 
On information and belief, NEC Casio Mobile Communications, Ltd. (“NECCasio”) is a corporation registered and lawfully existing under the Laws of Japan, with a principal place of business at 1753, Shimonumabe, Nakahara-Ku, Kawasaki, Kanagawa, 211-
 
28666, JAPAN, where it can be served with process, and regularly does business throughout this judicial district and by, among things, committing jointly, directly, and/or indirectly the tort of  patent infringement giving rise to this complaint.3.
 
On information and belief, NEC Corporation of America (“NEC America”) is a Nevada corporation with a principal place of business at 6535 N. State Highway 161, Irving, TX75039 and regularly does business throughout this judicial district and by, among things,committing jointly, directly, and/or indirectly the tort of patent infringement giving rise to thiscomplaint. NEC America has designated National Registered Agents Inc., located at 1021 MainStreet, Suite 1150, Houston, TX 77002, and/or National Registered Agents, Inc. of Nevada, 311South Division Street, Carson City, Nevada 89703, as its agent for service of process.4.
 
On information and belief, NEC America is a subsidiary of non-party NECCorporation, a Japanese corporation having a principal place of business at 7-1, Shiba 5-chome,Minato-ku, Tokyo 108-8001, JAPAN, and regularly does business throughout this judicialdistrict.5.
 
On information and belief, NEC Casio is a joint venture between three Japaneseelectronics manufacturers: NEC Corporation, Casio Computer Co., Ltd., and Hitachi, Ltd.,where NEC Corporation owns 70.14%, Casio Computer Co., Ltd. owns 20.00%, and Hitachi,Ltd. owns 9.26%.6.
 
On information and belief, NEC America has an internet site(http://www.necam.com/Smartphones/det.cfm?t=NECTerrain&c=5)which provides information concerning (a)
support 
of certain computerized communications devices, including the
NECTerrain™ 4G LTE
device,
infra
.; (b)
a link to
download a 12.5 MB “NEC Terrain™ User Manual” that states, at page 95, that “[a]ll applicable rights of the Intellectual Property
 
3[concerning the NEC Terrain™ 4G LTE device] shall remain with NEC CASIO MobileCommunications, Ltd. and its suppliers,” and, at page 97, that “NEC TERRAIN and NEC areregistered trademarks of NEC Corporation [and t]he TERRAIN logo is a registered trademark of  NEC CASIO Mobile Communications;” (c)
contact information
by phone (1-800-637-5917), byemail(customercare@necam.com), and by regular mail (to NEC, 1801 N. Robison Road, Texarkana, TX 75501 (in this judicial district)) regarding the NEC Terrain™ 4G LTE device;and (d)
a link to
14 Frequently Asked Questions about the NEC Terrain™ 4G LTE device;7.
 
On information and belief, AT&T, Inc. is a Delaware corporation with a principal place of business at 208 Akard Street, Dallas, Texas 75202, and regularly does businessthroughout this judicial district and by, among things, committing jointly, directly, and/or indirectly the tort of patent infringement giving rise to this complaint. AT&T, Inc.’s registered agent for service of process in Texas is CT Corporation System, 350 North St. Paul Street, Suite2900, Dallas, Texas 75201, and its registered agent for service of process in Delaware is TheCorporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE19801.8.
 
On information and belief, AT&T Mobility LLC is a Delaware corporation with a principal place of business at Glenridge Highlands Two, 5565 Glenridge Connector, Atlanta,Georgia 30342 and/or 1025 Lenox Park Blvd., NE, Atlanta, Georgia 30319, and regularly does business in this judicial district at 5976 West Parker Road, Plano, Texas 75093 and by, amongthings, committing jointly, directly, and/or indirectly the tort of patent infringement giving rise tothis complaint. AT&T Mobility LLC’s registered agent for service of process in Texas is CTCorporation System, 350 North St. Paul Street, Dallas, Suite 2900, Texas 75201, and itsregistered agent for service of process in Delaware is The Corporation Trust Company,

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