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Summers Patent Holdings v. Clarion Corporation of America et. al.

Summers Patent Holdings v. Clarion Corporation of America et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-05891-DDP-SH: Summers Patent Holdings LLC v. Clarion Corporation of America et. al. Filed in U.S. District Court for the Central District of California, the Hon. Dean D. Pregerson presiding. See http://news.priorsmart.com/-l8Uu for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-05891-DDP-SH: Summers Patent Holdings LLC v. Clarion Corporation of America et. al. Filed in U.S. District Court for the Central District of California, the Hon. Dean D. Pregerson presiding. See http://news.priorsmart.com/-l8Uu for more info.

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Published by: PriorSmart on Aug 19, 2013
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10/23/2013

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Case 2:13-cv-05891-DDP-SH Document 1 Filed 08/13/13 Page 1 of 26 Page ID #:37
 
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- 1 -
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:
INTRODUCTION
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.
THE PARTIES
1.
 
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
“Defendants”).
4.
 
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
 
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- 2 -
COMPLAINT FOR PATENT INFRINGEMENT
authority as such with the permission and consent of their co-Defendants and are jointly responsible for the wrongful conduct alleged herein.
JURISDICTION
5.
 
This is an action for patent infringement that arises under, among other things, the United States patent laws, 35 U.S.C. § 101
etseq.
, including,
inter alia
,§ 271. Subject matter jurisdiction is therefore based upon 28 U.S.C. §§ 1331 and 1338(a), providing for federal question jurisdiction of patent infringement actionsand exclusive jurisdiction of patent infringement actions in the U.S. district courts.6.
 
This Court has both general and specific personal jurisdiction over defendant Clarion because Clarion has systematic and continuous contacts with theState of Califor 
nia and because the claims alleges herein also stem from Clarion’s
contacts with the State of California. On information and belief, Clarion isregistered with the California Secretary of State to do business in California, isorganized and existing under the laws of the State of California, and the acts of infringement alleged herein occurred at least in part within California and this judicial district. Clarion has purposefully availed itself of the laws of the State of California by making, importing, using, selling, offering to sell, throughoutCalifornia and in this judicial district product
s that infringe the ‘799 patent, and
inducing others to do so.
VENUE
7.
 
SPH is informed and believes, and thereon alleges, that this Court isthe appropriate venue for this matter pursuant to 28 U.S.C. §§ 1391(b)-(d) and 1400(b) because the acts of patent infringement alleged herein were engaged inwithin this judicial district and because Clarion resides within this judicial district.
FACTS
8.
 
Plaintiff SPH is a private technology company engaged in the businessof, among other things, monetizing technology and its federally protected intellectual property, which SPH and/or its principals have developed and/or 
Case 2:13-cv-05891-DDP-SH Document 1 Filed 08/13/13 Page 3 of 26 Page ID #:39

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