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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-01954-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/-l9x7 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01954-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/-l9x7 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. DAIMLER AG, DAIMLER NORTH AMERICA CORPORATION, MERCEDES-BENZ USA, LLC, and MERCEDES-BENZ U.S. INTERNATIONAL, 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 Daimler AG (“Daimler”), Defendant Daimler North America Corporation (“Daimler North America”), Defendant Mercedes-Benz USA, LLC (“Mercedes-Benz USA”), and Defendant Mercedes-Benz U.S. International, Inc. (“Mercedes-Benz U.S. International” 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 the State of Delaware with a place of business at 113 Barksdale Professional Center, Newark, Delaware 19711. 4.
 
Upon information and belief, Defendant Daimler is a corporation organized under the laws of Germany with a principal place of business at Mercedesstrasse 137, 70327 Stuttgart, Germany. 5.
 
Upon information and belief, Defendant Daimler North America is a corporation organized under the laws of Delaware, with its principal place of business at 36455 Corporate Dr., Farmington Hills, Michigan 48331, and a registered agent at The Corporation Trust Company, 1209 Orange Street, Wilmington, Delaware, 19801. 6.
 
Upon information and belief, Defendant Mercedes-Benz USA, is a corporation organized under the laws of Delaware, with its principal place of business at One Mercedes Drive, Montvale, New Jersey, 07645, and a registered agent at The Corporation Trust Company, 1209 Orange Street, Wilmington, Delaware, 19801. 7.
 
Upon information and belief, Defendant Mercedes-Benz U.S. International is corporation organized under the laws of Alabama with its principal place of business at One Mercedes Drive, Vance, Alabama 35490, and a registered agent Edward R. Christian at P.O. Box 100, Tuscaloosa, Alabama 35403.
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JURISDICTION AND VENUE
8.
 
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 271,
et seq
. 9.
 
This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331 and 1338(a). 10.
 
This Court has personal jurisdiction over Defendants at least because Defendants have ongoing and systematic contacts with this District and the United States. Specifically, Defendants Daimler North America and Mercedes-Benz USA are corporations organized under the laws of Delaware, have a registered agent for service of process in Delaware, and have thereby availed itself of the privileges and the protections of the laws of the State of Delaware. Defendants sell and/or offer to sell products and/or services throughout the United States, including in this Judicial District, at least at the following dealership: Mercedes-Benz of Wilmington in Wilmington, 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. 11.
 
Venue is proper in this District under 28 U.S.C. §§ 1400 (b) and 1391.
JOINDER
12.
 
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’ manufacture, use, sale, offer for sale, and importation of the same accused products. On information and belief, the Defendants are part of the same corporate family of companies, and the infringement allegations arise at least in part from the Defendants’ collective activities with respect to the Defendants’ accused products. Questions of fact common to the Defendants will
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