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Acqis v. Alcatel-Lucent Et. Al.

Acqis v. Alcatel-Lucent Et. Al.

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Published by PatentBlast
Acqis v. Alcatel-Lucent et. al.
Acqis v. Alcatel-Lucent et. al.

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Published by: PatentBlast on Sep 11, 2013
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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXASTYLER DIVISION
ACQIS LLC,Plaintiff,v.Alcatel-Lucent USA, Inc., and Alcatel-LucentS.A.,Defendant.
COMPLAINT
 
FOR 
 
PATENT
 
INFRINGEMENT
 
Case No.
Jury Trial Demanded
Plaintiff ACQIS LLC complains against Alcatel-Lucent USA, Inc. and Alcatel-LucentS.A. as follows:
THE PARTIES
1.
 
Plaintiff ACQIS LLC is a limited liability corporation organized under the laws of Texas, with offices at 411 Interchange Street, McKinney, Texas 75071. A related entity, ACQISTechnology, Inc. is a corporation organized under the laws of California, having its principal place of business at 1621 West El Camino Real, Mountain View, California 94040. ACQISLLC
 — 
the Texas entity
 — 
is operated from California where its President William Chu resides.Mr. Chu is also the Chief Executive Officer of ACQIS Technology, Inc. The plaintiff in thiscase, ACQIS LLC, will be referred to herein as ACQIS.2.
 
Defendant Alcatel-Lucent S.A. is a corporation organized under the laws of France, having its principal place of business at 3 avenue Octave Greard, FR-75007 Paris,France. Alcatel-Lucent does business in the United States through its subsidiary, Alcatel-LucentUSA, Inc., a corporation organized under the laws of Delaware, having its principal place of 
 
2 business in New Jersey. Alcatel-
Lucent‟s agent for service of process in Texas is
Prentice HallCorporation System, 211 E. 7th Street, Suite 620, Austin, Texas 78701. Alcatel-Lucent USA,Inc. and Alcatel-Lucent are collectively referred to
as “Alcatel
-
Lucent.”
 
JURISDICTION AND VENUE
3.
 
This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. § 1
et seq.
 4.
 
The Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§1331 and 1338(a).5.
 
Alcatel-
Lucent is subject to this Court‟s personal jurisdiction because it does and
has done substantial business in Texas, including: (i) making, using, and/or selling infringinggoods; and (ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from goods used or consumed by, and services provided to, persons in the state of Texas and in this judicial district. For example, Alcatel-Lucent does business in Texas and this judicial district through its offices at 1227 West MarshallAvenue, Longview, Texas 75604 and 3400 West Plano Parkway Plano, Texas 75075.Accordingly, Alcatel-Lucent has established minimum contacts with the forum such that theexercise of jurisdiction over it would not offend traditional notions of fair play and substantial justice.6.
 
Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b) and (c), and1400(b).
THE PATENTS-IN-SUIT
 7.
 
On April 22, 2008, United States Patent No. 7,363,416 (“the „416 Patent”)entitled “Computer System Utilizing Multiple Computer Modules with Password Protection”issued to William W.Y. Chu. (A copy of the „416 Patent is attached hereto as Exhibit
A.) The
 
3
entire right, title and interest to the „416 Patent has been assigned to ACQIS. ACQIS is theowner and possessor of all rights pertaining to the „416 Patent
.8.
 
On March 9, 2010, United States Patent No. 7,676,624 (“the „624 Patent”)entitled “Multiple Module Computer System and Method Including Differential Signal ChannelComprising Unidirectional Serial Bit Channels” issued to William W.Y. Chu. (A copy of the
 
„624 Paten
t is attached hereto as Exhibit B
.) The entire right, title and interest to the „624 Patent
has been assigned to ACQIS. ACQIS is the owner and possessor of all rights pertaining to the
„624 Patent.
 9.
 
On October 19, 2010, United States Patent No.
7,818,487 (“the „487 Patent”)entitled “Multiple Module Computer System and Method Using Differential Signal ChannelIncluding Unidirectional, Serial Bit Channels” issued to William W.Y. Chu. (A copy of the „487
Patent is attached hereto as Exhibit C.)
The entire right, title and interest to the „487 Patent has been assigned to ACQIS. ACQIS is the owner and possessor of all rights pertaining to the „487
Patent.10.
 
On October 18, 2011, United States Patent No. 8,041,873 (“the „873 Patent”)entitled “Multipl
e Module Computer System and Method Including Differential Signal ChannelComprising Unidirectional Serial Bit Channels to Transmit Encoded Peripheral Component
Interconnect Bus Transaction Data” issued to William W.Y. Chu. (A copy of the „873 Paten
t isattached hereto as Exhibit D
.) The entire right, title and interest to the „873 Patent has beenassigned to ACQIS, including the right to enforce the „873 patent and obtain legal and equitable
relief for infringement.11.
 
On April 27, 2010, United States Paten
t No. RE41,294 (“the „294 Patent”)entitled “Password Protected Modular Computer Method and Device” issued to William W.Y.

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