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Hopewell Culture & Design v. Microsoft Et. Al.

Hopewell Culture & Design v. Microsoft Et. Al.

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Published by PatentBlast
Hopewell Culture & Design v. Microsoft et. al.
Hopewell Culture & Design v. Microsoft et. al.

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Published by: PatentBlast on Aug 17, 2013
Copyright:Attribution Non-commercial

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01/20/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONHOPEWELL CULTURE & DESIGN LLC,Plaintiff,V.MICROSOFT CORPORATION,ACER AMERICA CORPORATION,FUJITSU AMERICA, INC.,HUAWEI DEVICE USA, INC.,ZTE (UNITED STATES) INC.,Defendant.CASE NO. 2:13-CV-622JURY TRIAL DEMANDED
 
PLAINTIFF’S
ORIGINAL COMPLAINT
Plaintiff Hopewell Culture & Design
LLC (“Plaintiff”), by and through its undersigned
counsel, files this Original Complaint against Microsoft Corporation, Acer America Corporation,Fujitsu America, Inc., Huawei Device, USA, Inc., and ZTE (United States) Inc.
(“Defendant
s
”)
as follows:
NATURE OF THE ACTION
1.
 
This is a patent infringement action to stop
Defendants’
infringement of UnitedStates Patent No. 7,171,625 (
“the ’625 patent”) entitled “Double
-Clicking a Point-and-Click Interface Apparatus to Enable a New Interaction with Content Represented by an Active Visual
Display Element”. A true and correct copy of the ’625 Patent is attached hereto as
Exhibit A.Plai
ntiff is the exclusive licensee of the ’625 patent. Plaintiff seeks injunctive relief and
monetary damages.
 
2
PARTIES
 2.
 
Plaintiff is a limited liability company organized and existing under the laws of the State of Texas. Plaintiff maintains its principal place of business at 104 East Houston Street,Suite 170, Marshall, Texas 75670. Plaintiff is authorized to do business in Texas. Plaintiff is the
exclusive licensee of the ’625 patent
, and possesses the right to sue for infringement and recover  past damages.3.
 
Upon information and belief, Microsoft Corporation (
Microsoft
) is acorporation organized and existing under the laws of the State of Washington, with its principal place of business at 1 Microsoft Way, Redmond, WA 98052. Microsoft is registered to do business in Texas and can be served with process through its registered agent, CorporationService Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808.4.
 
Upon information and belief, Acer America Corporation (
“Acer”
) is a corporationorganized and existing under the laws of the State of California, with its principal place of  business at 333 West San Carlos Street, Suite 1500, San Jose, CA 95110. Acer can be servedwith process through its registered agent, C T Corporation System, 818 West Seventh Street, LosAngeles, CA 90017.5.
 
Upon information and belief, Fujitsu America, Inc. (
“Fujitsu”
) is a corporationorganized and existing under the laws of the State of California, with its principal place of  business at 1250 East Arques Avenue, M/S 124. Sunnyvale, CA 94085. Fujitsu is registered todo business in Texas and can be served with process through its registered agent, TheCorporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE19801.
 
36.
 
Upon information and belief, Huawei Device USA, Inc. (
“Huawei”
) 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. (
“ZTE”
) 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
8.
 
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
et  seq.
, 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

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