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Cronos Technologies v. RadioShack

Cronos Technologies v. RadioShack

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Published by PatentBlast
Cronos Technologies v. RadioShack
Cronos Technologies v. RadioShack

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Published by: PatentBlast on Sep 09, 2013
Copyright:Attribution Non-commercial

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09/09/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
CRONOS TECHNOLOGIES, LLC,Plaintiff,v.RADIOSHACK CORP.,Defendant.)))))))))))C.A. No. ______________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Cronos Technologies, LLC (“Plaintiff” or “Cronos”), by and through itsundersigned counsel, files this Complaint for patent infringement against Defendant RadioShack Corp. (“Defendant”) as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the Patent Laws of theUnited States of America, 35 U.S.C. § 1,
et seq.
to stop Defendant’s infringement of Plaintiff’sUnited States Patent No. 5,664,110 entitled “
 Remote Ordering System
” (hereinafter, the “’110 patent” or the “Patent-in-Suit”). A copy of the ’110 patent, is attached hereto as Exhibit A.Plaintiff is the owner of the Patent-in-Suit with respect to the Defendant. Plaintiff seeksinjunctive relief and monetary damages.
PARTIES
2.
 
Cronos is a limited liability company organized under the laws of the State of Delaware, and maintains its principal place of business at 717 N. Union St. #65, Wilmington,Delaware 19805.
 
 
23.
 
Plaintiff is the owner the Patent-in-Suit with respect to the Defendant, and possesses all right to enforce the Patent-in-Suit, including the right to sue the Defendant for infringement and recover past damages.4.
 
Upon information and belief, Defendant is a corporation duly organized andexisting under the laws of the State of Delaware, having a place of business located at 300RadioShack Circle, Fort Worth, Texas 76102-1964. Upon information and belief, Defendantdoes business through its website, www.radioshack.com, which is accused of infringing thePatent-in-Suit. Defendant can be served via its registered agent, Corporation Service Company,2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
JURISDICTION AND VENUE
5.
 
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
et  seq
. This Court has subject matter jurisdiction over this case for patent infringement under 28U.S.C. §§ 1331 and 1338(a).6.
 
On information and belief, Defendant is subject to this Court’s specific andgeneral personal jurisdiction pursuant to due process and/or the Delaware Long Arm Statute, dueto having availed itself of the rights and benefits of the state of Delaware by engaging inactivities including (i) incorporating under Delaware law; (ii) conducting substantial business inthis forum; and (iii) engaging in other persistent courses of conduct, and/or deriving substantialrevenue from services provided to individuals in Delaware, and this Judicial District.7.
 
More specifically, Defendant, directly and/or through its intermediaries,distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web page) its services in the United States, the State of Delaware, and this Judicial District. Uponinformation and belief, Defendant and/or its customers have committed patent infringement in
 
 
3the State of Delaware and in this District, and/or has intentionally induced others to commit patent infringement in the State of Delaware and in this District. Defendant solicits customers inthe State of Delaware and in this District. On information and belief, Defendant has many paying customers who are residents of the State of Delaware and this District and who useDefendant’s products and services in the State of Delaware and in this District.8.
 
Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 and 1400(b). Oninformation and belief, Defendant resides in this Judicial District pursuant to 28 U.S.C. § 1391,and engages in activities including transacting business in this district and engaging in acts of infringement in this district.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 5,664,110
9.
 
The ’110 patent was duly and legally issued by the United States Patent andTrademark Office on September 2, 1997, after full and fair examination. Plaintiff is the owner under the ’110 patent with respect to Defendant, and possesses all right, title and interest in thePatent-in-Suit including the right to enforce the Patent-in-Suit, and the right to sue Defendant for infringement and recover past damages.10.
 
Plaintiff is informed and believes that Defendant owns, operates, advertises, andcontrols its website, www.radioshack.com, the operation of which infringes the ’110 patenteither literally or under the doctrine of equivalents. Upon information and belief, Defendant hasinfringed and continues to infringe one or more claims of the ’110 patent by making, using, and providing a remote ordering terminal, associated with Defendant and its order processing systemwith attendant item codes, comprised of a user identifier means, a data entry device, a user-specific database, a storage memory, a communication means between the devices and terminal,

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