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Affinity Labs of Texas v. Samsung Electronics et. al.

Affinity Labs of Texas v. Samsung Electronics et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00364: Affinity Labs of Texas, LLC v. Samsung Electronics Co., LTD et. al. Filed in U.S. District Court for the Western District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9xV for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00364: Affinity Labs of Texas, LLC v. Samsung Electronics Co., LTD et. al. Filed in U.S. District Court for the Western District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9xV for more info.

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Published by: PriorSmart on Nov 22, 2013
Copyright:Public Domain

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11/22/2013

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1823831.1
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION
AFFINITY LABS OF TEXAS, LLC, Plaintiff, v. SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., AND SAMSUNG TELECOMMUNICATIONS AMERICA, LLC F/K/A SAMSUNG TELECOMMUNICATIONS AMERICA, L.P., Defendants. ) )))))))))) ))) Case No. 6:13-cv-364
JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Affinity Labs of Texas, LLC (“Affinity Labs”) for its causes of action against Defendants, Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung Telecommunications America, LLC f/k/a Samsung Telecommunications America, LP (collectively, “Samsung” and/or “Defendants”), states and alleges on knowledge and information and belief as follows:
PARTIES
1.
 
Plaintiff Affinity Labs is a Texas limited liability company having offices at 31884 RR 12, Dripping Springs, TX 78620. 2.
 
On information and belief, Defendant Samsung Electronics Co., Ltd. is a Korean company having its principal place of business at 250 2-ga Taepyung-ro, Jung-gu, Seoul 100-742, Korea.
 
 
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1823831.1
3.
 
On information and belief, Defendant Samsung Electronics America, Inc. is a  New York corporation having its principal place of business at 85 Challenger Road, Ridgefield Park, NJ 07660. Samsung Electronics America, Inc. has been authorized to do business in the State of Texas by the Texas Secretary of State. Furthermore, Samsung Electronics America, Inc. has designated CT Corporation System, 350 N. Saint Paul Street, Suite 2900, Dallas, TX 75201, as its representative to accept service of process within the State of Texas. 4.
 
On information and belief, Defendant Samsung Telecommunications America, LLC f/k/a Samsung Telecommunications America, L.P., is a Delaware limited liability company having its principal place of business at 1301 E. Lookout Drive, Richardson, TX 75082.
JURISDICTION
5.
 
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1338(a), in that this action arises under the federal patent statutes, 35 U.S.C. §§ 271 and 281-285. 6.
 
This Court has personal jurisdiction over Samsung. Upon information and  belief, Samsung has committed and continues to commit acts giving rise to this action within Texas and within this judicial district and Samsung has established minimum contacts within the forum such that the exercise of jurisdiction over Samsung would not offend traditional notions of fair play and substantial justice. For example, Samsung has committed and continues to commit acts of infringement in this District, by among other things, offering to sell and selling products that infringe the Asserted Patent, including smartphones, tablets, and/or portable music players. In conducting its business in Texas and this judicial district, Samsung derives substantial revenue from infringing products being sold, used, imported, and/or offered for sale or providing service
 
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1823831.1
and support to Samsung’s customers in Texas and this District, and will continue to do so unless enjoined by this Court.
VENUE
7.
 
Venue in the Western District of Texas is proper pursuant to 28 U.S.C. §§ 1391(b) and (c) and 1400(b) because Samsung has committed acts within this judicial district giving rise to this action, and Samsung has and continues to conduct business in this judicial district, including one or more acts of selling, using, importing, and/or offering for sale infringing products or providing service and support to Samsung’s customers in this District. 8.
 
Venue in the Western District of Texas is further proper because Defendant Samsung Telecommunications America, LLC f/k/a Samsung Telecommunications America, L.P., has its principal place of business in Texas. 9.
 
Venue in the Western District of Texas is further proper because Affinity Labs is headquartered in this District in Dripping Springs, Texas. 10.
 
Venue in the Western District of Texas is further proper because the majority of Affinity Labs’ documents and relevant evidence is located at Affinity Labs’ headquarters within this District and numerous witnesses are also located within this District. 11.
 
Venue in the Western District of Texas is also proper because Affinity Labs is organized and governed by the limited liability company laws of Texas and is subject to taxes in Texas. Affinity Labs maintains a registered agent for service of process in Texas. 12.
 
Venue in the Western District of Texas is also proper because this District is centrally located to resolve common issues of fact among Affinity Labs and the Defendants.

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