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COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Summers Patent Holdings, LLC, by and through its attorneys,hereby alleges for its complaint against defendant Clarion Corporation of Americaas follows:
This complaint is based upon d
efendant Clarion Corporation of America’s(“Defendant” or “Clarion”) unauthorized making, importing, using, selling a
nd offering to sell in the United States and abroad products that infringe United States
Patent No. 5,971,799 (“the ‘799 patent”)
, and inducing others to do so.
Plaintiff Summers Patent Holdings, LLC
(“SPH” or “Plaintiff”)
is alimited liability corporation organized and existing under the laws of the State of California.2.
SPH is informed and believes, and on that basis alleges, that defendantClarion Corporation of America is now, and at all times herein mentioned was, acorporation organized and existing under the laws of the State of California with its principal place of business at 6200 Gateway Drive, Cypress, California 90630.3.
The true names and capacities, whether individual, corporate, associateor otherwise, of the defendants named herein as DOES 1 through 10, inclusive, areunknown to Plaintiff and Plaintiff therefore sues said defendants by such fictitiousnames. Plaintiff will amend this Complaint to show their true names and capacitieswhen ascertained. Plaintiff is informed and believes, and on that basis alleges, thateach of such fictitiously named defendants is responsible in some manner for thematters herein alleged. (All defendants are collectively referred to herein as
Plaintiff is informed and believes, and on that basis alleges, that at alltimes mentioned herein Defendants were the partners, joint venturers, affiliates,agents, servants, employees, landlords, lessees, or alter ego of their co-Defendantsand, in doing the things hereinafter mentioned, were acting within the scope of their
Case 2:13-cv-05891-DDP-SH Document 1 Filed 08/13/13 Page 2 of 26 Page ID #:38