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Monolithic Power Systems v. Silergy et. al.

Monolithic Power Systems v. Silergy et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-08122: Monolithic Power Systems, Inc. v. Silergy Corporation et. al. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-l9qV for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-08122: Monolithic Power Systems, Inc. v. Silergy Corporation et. al. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-l9qV for more info.

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Published by: PriorSmart on Nov 02, 2013
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11/15/2013

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Case No. 2:13-cv-08122 COMPLAINT
 
John P. Schnurer, Bar No. 185725JSchnurer@perkinscoie.com Jack Ko, Bar No. 244630 JKo@perkinscoie.com Kevin Patariu, Bar No. 256755 KPatariu@perkinscoie.com PERKINS COIE LLP 11988 El Camino Real, Suite 200 San Diego, CA 92130 Telephone: 858.720.5700 Facsimile: 858.720.5799 Michael J. Engle, Bar No. 259476 MEngle@perkinscoie.com PERKINS COIE LLP 1888 Century Park E., Suite 1700 Los Angeles, CA 90067-1721 Telephone: 310.788.9900 Facsimile: 310.788.3399 Attorneys for Plaintiff Monolithic Power Sstems, Inc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION MONOLITHIC POWER SYSTEMS, INC., Plaintiff, v. SILERGY CORPORATION, SILERGY TECHNOLOGY, COMPAL ELECTRONICS, INC., and BIZCOM ELECTRONICS, INC., Defendants. Case No. 2:13-cv-08122
COMPLAINT FOR PATENT INFRINGEMENT DEMAND FOR JURY TRIAL
 Plaintiff Monolithic Power Systems, Inc. ("MPS") hereby pleads the following claims for patent infringement against Defendants Silergy Corporation and Silergy Technology (collectively "Silergy") and Defendants Compal
 
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Case No. 2:13-cv-08122 COMPLAINT
 
Electronics, Inc. and Bizcom Electronics, Inc. (collectively "Compal"), and alleges as follows:
PARTIES
Plaintiff MPS is a California corporation with its principal place of
1.
 business located at 79 Great Oaks Blvd., San Jose, CA 95119. MPS is the owner of the patent rights at issue in this action. On information and belief, Defendant Silergy Corporation is a
2.
corporation organized and existing under the laws of the Cayman Islands with a mailing address at Cayman Management Ltd., Ground Floor, Harbour Centre, P.O. Box 1596, George Town, Grand Cayman, Cayman Islands, British West Indies and a principal place of business at 14F., No. 663, Bannan Road, Zhonghe District, Xinbei City, Taipei County, 231, Taiwan (R.O.C.). On information and belief, Defendant Silergy Corporation was a registered entity with the State of California (Entity No. C3181618) at least as of December 5, 2008, but has since surrendered its status. On information and belief, Defendant Silergy Technology is a
3.
corporation organized and existing under the laws of the State of California with a  principal place of business at 1309 S. Mary Ave., #215, Sunnyvale, CA 94087. On information and belief, Silergy Technology is a subsidiary of Silergy Corporation. On information and belief, Defendant Compal Electronics, Inc. is a
4.
corporation organized and existing under the laws of Taiwan with a principal place of business at No. 581, Ruiguang Rd., Neihu District, Taipei City 11492, Taiwan (R.O.C.). On information and belief, Defendant Bizcom Electronics, Inc. is a
5.
corporation organized and existing under the laws of the State of California with a  principal place of business at 1171 Montague Expressway, Milpitas, CA 95035. On information and belief, Bizcom Electronics, Inc. is a wholly-owned subsidiary of Compal Electronics, Inc.
 
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Case No. 2:13-cv-08122 COMPLAINT
 
JURISDICTION AND VENUE
This is an action for patent infringement arising under the patent laws
6.
of the United States, 35 U.S.C. § 1
et seq.
, including but not limited to 35 U.S.C. § 271. The Court has subject matter jurisdiction over this action under 28
7.
U.S.C. §§ 1331 and 1338(a). This Court has personal jurisdiction over Defendants because, among
8.
other things, they have committed, aided, abetted, contributed to, induced, or  participated in the commission of patent infringement in this judicial district and elsewhere that led to foreseeable harm and injury to MPS. On information and  belief, Defendants, directly or through third parties, manufacture or assemble  products that are and have been offered for sale, sold, purchased, and/or used within this forum, including without limitation by Silergy's direct or indirect customers, such as Compal and other contract manufacturers, and by the direct or indirect customers of Compal and other contract manufacturers, such as consumer electronic brands like Lenovo and Acer. Defendants, directly or through its distribution networks, regularly place their products within the stream of commerce with the knowledge, understanding, and desire that such products, by themselves or incorporated within its direct or indirect customers’ products, including without limitation notebook products from consumer electronics brands, such as Lenovo or Acer manufactured by Compal or other contract manufacturers, that use Silergy components, will be shipped to, sold, or used in this forum and throughout the United States. Thus, Defendants have established minimum contacts within the forum and purposefully availed themselves of the benefits of this forum, and the exercise of personal jurisdiction over Defendants would not offend traditional notions of fair play and substantial justice. Defendants transact business in this forum because, among other
9.
things, they manufacture, import, and distribute products that are shipped to,

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