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Denmel Holdings et. al. v. IXT Systems International et. al.

Denmel Holdings et. al. v. IXT Systems International et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00888-DBP: Denmel Holdings et. al. v. IXT Systems International et. al. Filed in U.S. District Court for the District of Utah, the Hon. Dustin B. Pead presiding. See http://news.priorsmart.com/-l9dW for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00888-DBP: Denmel Holdings et. al. v. IXT Systems International et. al. Filed in U.S. District Court for the District of Utah, the Hon. Dustin B. Pead presiding. See http://news.priorsmart.com/-l9dW for more info.

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Published by: PriorSmart on Oct 01, 2013
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11/13/2013

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Randall B. Bateman (USB 6482)Sarah W. Matthews (USB 13295)BATEMAN IP LAW GROUP, P.C.
 
257 East 200 South, Suite 750P.O. Box 1319Salt Lake City, Utah 84110Tel: (801) 533-0320/Fax: (801) 533-0323Email: mail@batemanip.com, rbb@batemanip.com, sm@batemanip.comAttorneys for Plaintiffs,Denmel Holdings, LLC and Melanie ReahUNITED STATES DISTRICT COURTFOR THE DISTRICT OF UTAH, CENTRAL DIVISIONDENMEL HOLDINGS, LLC, a Utah limited liabilitycompany, and MELANIE REAH, an individualPlaintiffs,vs.IXT SYSTEMS INTERNATIONAL LIMITED, aHong Kong entity; JS KARAOKE, LLC, a FloridaLimited Liability Company, DOK SOLUTION, LLC, aFlorida Limited Liability Company; WAL-MART.COM USA, LLC, a California limited liability;TARGET CORPORATION, a Minnesota corporation;KOHL’S DEPARTMENT STORES, INC., aWisconsin corporation; SEARS HOLDINGSMANAGEMENT CORPORATION, dba KMART, aDelaware corporation; SEARS ROEBUCK AND CO.,an Illinois corporation; RADIO SHACKCORPORATION, a Delaware corporation;SKYMALL, INC., a Delaware corporation; TOYS “R”US, INC., a New Jersey corporation; AMAZON.COM,INC., a Delaware corporation; WAYFAIR, LLC, aMassachusetts limited liability company; and DOES 1-5,Defendants.
COMPLAINT AND JURYDEMAND
Case No. 2:13-cv-888-DBP
Judge Dustin B. Pead
 
 
2Plaintiffs, Denmel Holdings, LLC and Melanie Reah (“Plaintiffs” or “Denmel”), herebycomplain against Defendants, and allege as follows:
PARTIES
1.
 
Plaintiff, Melanie Reah, is an individual that resides in Amanzimtoti, South Africa.2.
 
Plaintiff, Denmel Holdings, LLC, is a limited liability company organized underthe laws of the State of Utah.3.
 
On information and belief, Defendant, IXT Systems Limited is a Hong Kongentity having a place of business at 1185 Gooden Crossing, Largo, FL 33778.4.
 
Defendant JS Karaoke, LLC is a Florida Limited Liability Company having abusiness address at 1185 Gooden Crossing, Largo, Florida 33778.5.
 
On information and belief, Defendant Dok Solution, LLC is a Florida LimitedLiability Company have a business address at
7778 Bent Grass Court, Largo, Florida 33777.
 6.
 
Defendant Wal-Mart.com USA, LLC is a limited liability company organized andexisting under the laws of the State of California, having a business address in Bentonville,Arizona.7.
 
Defendant Target Corporation is a corporation organized and existing under thelaws of the State of Minnesota, having a business address in Salt Lake City, Utah.8.
 
Defendant Kohl’s Department Stores, Inc., is a corporation organized and existingunder the laws of the State of Wisconsin, having a business address in Salt Lake City, Utah.
 
 
39.
 
Defendant Sears Holding Management Corporation, dba Kmart, is a corporationorganized and existing under the laws of the State of Delaware, having a business address in SaltLake City, Utah.10.
 
Defendant Sears Roebuck and Co. is a corporation organized and existing underthe laws of the State of Illinois, having a business address in Salt Lake City, Utah.11.
 
Defendant Radio Shack Corporation is a corporation organized and existing underthe laws of the state of Delaware, having a business address in Salt Lake City, Utah.12.
 
Defendant Skymall, Inc. is a corporation organized and existing under the laws of the State of Delaware, having a business address at 1520 E Pima St, Phoenix, AZ 85034.13.
 
Defendant Toys “R” Us, Inc., is a corporation organized and existing under thelaws of the State of New Jersey, having a business address in Salt Lake City, Utah.14.
 
Defendant Amazon.com, Inc. is a corporation organized and existing under thelaws of the State of Delaware, having a business address of 1200 12th Ave. South, Ste. 1200,Seattle, WA 98144-2734.15.
 
Defendant Wayfair, LLC is a corporation organized and existing under the lawsof the state of Massachusetts, having a business address of 177 Huntington Avenue, Suite 6000,Boston, Massachusetts 02115.16.
 
On information and belief, DOES 1-5 are business entities and individuals whohave participated in the acts alleged herein and have infringed Plaintiffs’ patent by making, using,selling, offering for sale, or importing infringing products in the United States, and/or inducingor contributing to infringement of United States Patent No. 6,982,542 (“the ’542 Patent”).

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