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Innovative Wireless Solutions v. D-Link Systems

Innovative Wireless Solutions v. D-Link Systems

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 8:13-cv-01814: Innovative Wireless Solutions, LLC v. D-Link Systems, Inc. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-l9vZ for more info.
Official Complaint for Patent Infringement in Civil Action No. 8:13-cv-01814: Innovative Wireless Solutions, LLC v. D-Link Systems, Inc. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-l9vZ for more info.

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Published by: PriorSmart on Nov 20, 2013
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H. H. (Shashi) Kewalramani (Bar No. 262290) shashi@ljpklaw.com
LEE, JORGENSEN, PYLE & KEWALRAMANI, PC
440 W 1
st
 Street, Suite 205 Tustin, CA 92780 Telephone: (714) 252-6611 Facsimile: (714) 602-4690 Attorneys for Plaintiff INNOVATIVE WIRELESS SOLUTIONS, LLC IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION INNOVATIVE WIRELESS SOLUTIONS, LLC, Plaintiff, v. D-LINK SYSTEMS, INC., Defendant. Civil Case No. SA CV 13-1814
COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
 Plaintiff Innovative Wireless Solutions, LLC (“IWS” or “Plaintiff”), by way of its Complaint for Patent Infringement (“Complaint”) against Defendant D-Link Systems, Inc. (“D-Link” or “Defendant”), alleges as follows:
JURISDICTION AND VENUE
1.
 
This is a civil action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 1
et seq
. This Court has subject matter  jurisdiction over such Federal Question claims pursuant to 28 U.S.C. §§ 1331 and 1338(a). 2.
 
Venue is proper in this Judicial District under 28 U.S.C. §§ 1391 and 1400(b).
COMPLAINT FOR PATENT INFRINGEMENT 1 CASE NO. SA CV 13-1814
 
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3.
 
On information and belief, Defendant is subject to the jurisdiction of this Court by virtue of the fact that it is organized under the laws of the State of California. On information and belief, Defendant is also subject to the jurisdiction of this Court by reason of its acts of patent infringement which have been committed in this Judicial District, and by virtue of its regularly conducted and systematic business contacts in this State. As such, Defendant has purposefully availed itself of the privilege of conducting business within this Judicial District, has established sufficient minimum contacts with this Judicial District such that it should reasonably and fairly anticipate being haled into court in this Judicial District, has purposefully directed activities at residents of this State, and at least a  portion of the patent infringement claims alleged herein arise out of or are related to one or more of the foregoing activities.
THE PARTIES
4.
 
Plaintiff Innovative Wireless Solutions, LLC (“IWS”) is a Texas limited liability company with a place of business at 555 Republic Drive, Suite 200, Plano, Texas 75074. 5.
 
On information and belief, Defendant D-Link is a corporation organized under the laws of the State of California. On information and belief Defendant has a place of business at 17595 Mt. Herrmann, Fountain Valley, California 92708.
THE PATENT-IN-SUIT
6.
 
The allegations set forth in the foregoing paragraphs 1 through 5 are hereby realleged and incorporated herein by reference. 7.
 
On June 15, 1999, U.S. Patent Number 5,912,895 (the “’895 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and legally issued by the United States Patent and Trademark
COMPLAINT FOR PATENT INFRINGEMENT 2 CASE NO. SA CV 1314
 
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Office. A true and correct copy of the ’895 Patent is attached as Exhibit A to this Complaint. 8.
 
On December 4, 2001, U.S. Patent Number 6,327,264 (the “’264 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and legally issued by the United States Patent and Trademark Office. A true and correct copy of the ’264 Patent is attached as Exhibit B to this Complaint. 9.
 
On July 1, 2003, U.S. Patent Number 6,587,473 (the “’473 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and legally issued by the United States Patent and Trademark Office. A true and correct copy of the ’473 Patent is attached as Exhibit C to this Complaint. 10.
 
IWS is the assignee and owner of the right, title and interest in and to the ’895, ’264 and ’473 Patents (collectively, the “patents-in-suit”), including the right to assert all causes of action arising under said patents and the right to any remedies for infringement.
COUNT I (INFRINGEMENT OF U.S. PATENT NO. 5,912,895)
11.
 
The allegations set forth in the foregoing paragraphs 1 through 10 are hereby realleged and incorporated herein by reference. 12.
 
IWS provided actual notice to Defendant of its infringement of the ’895 Patent in a letter dated October 18, 2013 from IWS to Defendant. In this letter, IWS informed Defendant that it was infringing the ’895 Patent by making, using, offering for sale, selling, and/or importing wireless access points and/or routers capable of connecting to an Ethernet network and an IEEE 802.11 wireless network (the “’895 Patent Accused Products”) to provide wireless Internet access.
COMPLAINT FOR PATENT INFRINGEMENT 3 CASE NO. SA CV 1314

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