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Industrial Technology Research Institute v. LG Electronics et. al.

Industrial Technology Research Institute v. LG Electronics et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-02016-GPC-NLS: Industrial Technology Research Institute v. LG Electronics Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. Gonzalo P. Curiel presiding. See http://news.priorsmart.com/-l92w for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-02016-GPC-NLS: Industrial Technology Research Institute v. LG Electronics Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. Gonzalo P. Curiel presiding. See http://news.priorsmart.com/-l92w for more info.

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Published by: PriorSmart on Sep 04, 2013
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GCA Law Partners LLP2570 W. El Camino Real, Suite 500Mountain View, CA 94040(650)428-3900
Jill F. Kopeikin (State Bar No. 160792) jkopeikin@gcalaw.comValerie M. Wagner (State Bar No. 173146) vwagner@gcalaw.comGCA LAW PARTNERS LLP2570 W. El Camino Real, Suite 500Mountain View, CA 94040Telephone: (650) 428-3900Fax: (650) 428-3901Attorneys for Plaintiff INDUSTRIAL TECHNOLOGYRESEARCH INSTITUTE
IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF CALIFORNIA
INDUSTRIAL TECHNOLOGYRESEARCH INSTITUTE,
Plaintiff,
LG ELECTRONICS INC.,LG ELECTRONICS U.S.A., INC.,AND LG ELECTRONICSMOBILECOMM U.S.A., INC.,CASE NO.ORIGINAL COMPLAINT FOR PATENT INFRINGEMENTDEMAND FOR JURY TRIALPlaintiff Industrial Technology Research Institute (“ITRI” or “Plaintiff”) byand through its undersigned counsel, files this Original Complaint againstDefendants LG Electronics Inc., LG Electronics U.S.A., Inc., and LG ElectronicsMobileComm U.S.A., Inc. (collectively, “LG” or “Defendants”) as follows:
THE PARTIES
1.
 
Industrial Technology Research Institute is Taiwan's largest applied technology research and development institution, having a principal address of 195,Sec. 4, Chung Hsing Rd., Chutung, Hsinchu, Taiwan 31040, R.O.C.
'13
CV2016
NLS
GPC
 
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GCA Law Partners LLP2570 W. El Camino Real, Suite 500Mountain View, CA 94040(650)428-3900
2.
 
Upon information and belief, LG Electronics Inc. is a Koreancorporation with its principal place of business at LG Twin Towers, 20 Yeouido-dong, Yeongdeungpo-gu, Seoul 150-721, Korea. Upon information and belief, LGElectronics may be served at LG Twin Towers, 20 Yeouido-dong, Yeongdeungpo-gu, Seoul 150-721, Korea via an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service of process.3.
 
Upon information and belief, LG Electronics U.S.A., Inc. is a Delawarecorporation with its principal place of business at 1000 Sylvan Avenue, Englewood Cliffs, NJ, 07632. Upon information and belief, LG Electronics U.S.A., Inc. may beserved with process by serving its registered agent, Lawyers Incorporating Service,2710 Gateway Oaks Dr., Suite 150N, Sacramento, CA 95833. Upon information and  belief, LG Electronics U.S.A., Inc. is a wholly owned subsidiary of LG ElectronicsInc.4.
 
Upon information and belief, LG Electronics MobileComm U.S.A., Inc.is a California corporation with its principal place of business at 10101 Old GroveRoad, San Diego, California 92131. Upon information and belief, LG ElectronicsMobileComm U.S.A., Inc. also conducts business as “LG Mobile Phones.” Uponinformation and belief, LG Electronics MobileComm U.S.A., Inc. may be served with process by serving its registered agent, National Registered Agents, Inc., 818W. Seventh St., Los Angeles, CA 90017. Upon information and belief, LGElectronics MobileComm U.S.A., Inc. is a wholly owned subsidiary of LGElectronics U.S.A., Inc.
JURISDICTION AND VENUE
5.
 
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 hassubject matter jurisdiction over this case for patent infringement under 28 U.S.C. §§1331 and 1338(a).
 
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GCA Law Partners LLP2570 W. El Camino Real, Suite 500Mountain View, CA 94040(650)428-3900
6.
 
This Court has personal jurisdiction over each Defendant. EachDefendant has conducted and does conduct business within the state of California.Each Defendant, directly or through intermediaries (including distributors, retailers,and others), ships, distributes, offers for sale, and/or sells its devices in the United States, the State of California, and the Southern District of California. EachDefendant has purposefully and voluntarily placed one or more of its infringingdevices into the stream of commerce with the expectation that they will be purchased  by consumers in the Southern District of California. Upon information and belief,each Defendant has committed acts of patent infringement within the State of California and, more particularly, within the Southern District of California.7.
 
Venue is proper in this Court under 28 U.S.C. §§ 1391(b), (c), and (d),as well as 28 U.S.C. § 1400(b), in that, upon information and belief, each Defendanthas committed acts within this judicial District giving rise to this action and does business in this District, including using, selling, offering for sale, providing serviceand support for their respective customers, and/or importing infringing devices inand/or into this District. Further, LG intentionally availed itself of this judicialDistrict by filing a motion to transfer claims from the Eastern District of Texas to theSouthern District of California. As in the instant case, the transferred case involved cellular telephones.
 Industrial Technology Research Institute v. LG Corporation, LG Electronics, Inc., and LG Electronics, U.S.A., Inc.
, No. 6:10-cv-631-LED(transferred from Eastern District of Texas to Southern District of California onFebruary 13, 2012).
PATENT INFRINGEMENT OF U.S. PATENT NO. 6,163,355
8.
 
Plaintiff repeats and re-alleges each and every allegation of paragraphs1-7 as though fully set forth herein.

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