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Delaware Radio Technologies LLC et. al.

Delaware Radio Technologies LLC et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01949-UNA: Delaware Radio Technologies LLC et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9x2 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01949-UNA: Delaware Radio Technologies LLC et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9x2 for more info.

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Published by: PriorSmart on Nov 21, 2013
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11/21/2013

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
DELAWARE RADIO TECHNOLOGIES, LLC and WYNCOMM, LLC, Plaintiffs, v. HONDA MOTOR CO., LTD., HONDA  NORTH AMERICA, INC., AMERICAN HONDA MOTOR CO., INC., HONDA MANUFACTURING OF ALABAMA, LLC, HONDA MANUFACTURING OF INDIANA, LLC, and HONDA OF AMERICA MFG., INC., Defendants. Civil Action No. ___________________
JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
 Delaware Radio Technologies, LLC and Wyncomm, LLC (“Plaintiffs”), by way of this Complaint for Patent Infringement (“Complaint”) against Defendant Honda Motor Co., Ltd. (“Honda”), Defendant Honda North America, Inc. (“Honda NA”), Defendant American Honda Motor Company, Inc. (“American Honda”), Defendant Honda Manufacturing of Alabama, LLC (“Honda Alabama”), Defendant Honda Manufacturing of Indiana, LLC (“Honda Indiana”) and Defendant Honda of America MFG., Inc. (“Honda of America” or collectively as “Defendants”), allege as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 1
et seq
.
 
 THE PARTIES
2.
 
Plaintiff Delaware Radio Technologies, LLC (“Delaware Radio”) is a limited liability company organized under the laws of the State of Delaware with a place of business at 1209 Orange Street, Wilmington, Delaware 19801. 3.
 
Plaintiff Wyncomm, LLC (“Wyncomm”) is a limited liability company organized under the laws of Delaware with a place of business at 113 Barksdale Professional Center,  Newark, Delaware 19711. 4.
 
Upon information and belief, Defendant Honda is a corporation organized under the laws of Japan with its principal place of business at 1-1, 2-chome, Minami-Aoyama, Minato-ku, Tokyo 107-8556 Japan. 5.
 
Upon information and belief, Defendant Honda NA is a corporation organized under the laws of California with its principal place of business at 700 Van Ness Ave., Torrance, California, 90501 and a registered agent at CT Corporation System, 818 W. Seventh St., Los Angeles, California 90017. 6.
 
Upon information and belief, Defendant American Honda is a corporation organized under the laws of California, with its principal place of business at 1919 Torrance Blvd., Torrance, California 90501, and a registered agent at The Corporation Trust Company, 1209 Orange Street, Wilmington, Delaware, 19801. 7.
 
Upon information and belief, Defendant Honda Alabama is an Alabama corporation with its principal place of business at 1800 Honda Drive, Lincoln, Alabama 35096 and a registered agent, Clark B. Carpenter, at 212 North St. W, Talladega, Alabama 35160. 8.
 
Upon information and belief, Defendant Honda Indiana is a corporation organized under the laws of Indiana with its principal place of business at 2755 North Michigan Ave.,
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Greensburg, Indiana 47240 and a registered agent, Joseph M. Scimia, 600 E 96
th
 St., Suite 600, Indianapolis, Indiana 46240. 9.
 
Upon information and belief, Defendant Honda of America is a corporation organized under the laws of Ohio with its principal place of business at 24000 Honda Pkwy., Marysville, Ohio 43040 and a registered agent at Statutory Agent Corp, 52 East Gray Street, Columbus, Ohio 43215. 10.
 
Upon information and belief, Acura is a division of Defendants.
JURISDICTION AND VENUE
11.
 
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 271,
et seq
. 12.
 
This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331 and 1338(a). 13.
 
This Court has personal jurisdiction over Defendants at least because Defendants have ongoing and systematic contacts with this District and the United States. Defendants sell and/or offer to sell products and/or services throughout the United States, including in this Judicial District through at least the following dealerships: Union Park Honda in Wilmington, Delaware and Hertrich Acura in New Castle, Delaware. Further, Defendants introduce infringing products and/or services into the stream of commerce knowing that they would be sold in this Judicial District and elsewhere in the United States. 14.
 
Venue is proper in this District under 28 U.S.C. §§ 1400 (b) and 1391.
JOINDER
15.
 
Joinder is proper under 35 U.S.C. § 299. The allegations of infringement contained herein are asserted against the Defendants jointly, severally, or in the alternative and arise, at least in part, out of the same series of transactions or occurrences relating to Defendants’
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