Upon information and belief, Huawei Device USA, Inc. (
) is acorporation organized and existing under the laws of the State of Texas, with its principal placeof business at 5700 Tennyson Parkway, Plano, Texas 75024. Huawei is registered to do businessin Texas and can be served with process through its registered agent, C T Corporation System,350 North Saint Paul Street, Suite 2900, Dallas, Texas 75201.7.
Upon information and belief, ZTE (United States) Inc. (
) is a corporationorganized and existing under the laws of the State of New Jersey, with its principal place of business at 2425 North Central Expressway, Richardson, Texas 75080. ZTE is registered to do business in Texas and can be served with process through its registered agent, Jing Li, 2425 North Central Expressway, Suite 323, Richardson, Texas 75080.
JURISDICTION AND VENUE
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction over this case for patent infringement under 28 U.S.C. §§ 1331 and 1338(a).9.
The Court has personal jurisdiction over Defendants because: Defendants haveminimum contacts within the State of Texas and the Eastern District of Texas; Defendants have purposefully availed itself of the privileges of conducting business in the State of Texas and inthe Eastern District of Texas; Defendants have sought protection and benefit from the laws of theState of Texas; Defendants regularly conduct business within the State of Texas and within the
Eastern District of Texas; and Plaintiff’s cause of action arises directly from Defendants’
business contacts and other activities in the State of Texas and in the Eastern District of Texas.10.
More specifically, Defendants, directly and/or through intermediaries, ships,distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web