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Adaptix v. NEC CASIO Mobile Communications et. al.

Adaptix v. NEC CASIO Mobile Communications et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00922: Adaptix, Inc. v. NEC CASIO Mobile Communications, Ltd. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9AA for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00922: Adaptix, Inc. v. NEC CASIO Mobile Communications, Ltd. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9AA for more info.

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Published by: PriorSmart on Dec 02, 2013
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07/23/2014

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION ) ADAPTIX, INC., ) ) Plaintiff, ) ) v. ) Civil Action No. 6:13-cv-922 ) NEC CASIO MOBILE COMMUNICATIONS ) LTD., NEC CORPORATION OF ) AMERICA, and ) CELLCO PARTNERSHIP (d/b/a) ) VERIZON WIRELESS ) ) JURY TRIAL DEMANDED Defendants. ) COMPLAINT FOR PATENT INFRINGEMENT
This is an action for patent infringement in which plaintiff, ADAPTIX, Inc. (“ADAPTIX”), complains against defendants, NEC Casio Mobile Communications, Ltd. (“NEC Casio”), NEC Corporation of America (“NEC America” collectively “NEC”), and Cellco Partnership d/b/a Verizon Wireless (“Verizon”)(NEC Casio, NEC America, and Verizon may be referred to collectively as “Defendants”), as follows:
THE PARTIES
 1.
 
ADAPTIX is a Delaware corporation with its principal place of business in the Eastern District of Texas at 2400 Dallas Parkway, Suite 200, Plano, Texas 75093. 2.
 
On information and belief, NEC Casio Mobile Communications, Ltd. is a corporation registered and lawfully existing under the Laws of Japan, with a principal place of  business at 1753, Shiminumabe, Nakahara-Ku, Kawasaki, Kanagawa, 211-8666, Japan, where it can be served with process, and regularly does business throughout this judicial district and
06057045
 1
 
  by, among other things, committing jointly, directly, and/or indirectly the tort of patent infringement giving rise to this complaint. 3.
 
On information and belief, NEC Corporation of America is a Nevada corporation with a principal place of business at 6535 N. State Highway 161, Irving, TX 75039 and regularly does business throughout this judicial district and by, among other things, committing jointly, directly, and/or indirectly the tort of patent infringement giving rise to this complaint. NEC America has designated National Registered Agents Inc., located at 1021 Main Street, Suite 1150, Houston, TX 77002, and/or National Registered Agents Inc. of  Nevada, 311 South Division Street, Carson City, Nevada 89703, as its agent for service of  process. 4.
 
On information and belief, NEC Casio is a joint venture between three Japanese manufacturers: NEC Corporation, Casio Computer Co., Ltd., and Hitachi, Ltd., where NEC Corporation owns 70.14%, Casio Computer Co., Ltd. owns 20.00%, and Hitachi, Ltd. owns 9.26%. 5.
 
On information and belief, Casio Computer Co., Ltd. has an internet site (www.casiogzone.com/us/) which provides information concerning (a)
support
of certain computerized communications devices, including the G’zOne Commando 4G LTE
 
device, infra.; (b)
a link to
download a “G’zOne Commando 4G LTE User Guide” that states, at page 274, that “G’zGEAR is trademark of NEC Casio Mobile Communications, Ltd.” and, that “G’zOne is trademark of Casio Computer Co., Ltd.;” (c)
contact information
 by phone (1-800-637-5917); by email (customercare@necam.com), and by regular mail (to NEC Corporation of America, 6535 HWY 161 Irving, TX 75039) regarding the G’zOne Commando 4G LTE device. 2
 
 6.
 
On information and belief, Cellco Partnership
d/b/a
 Verizon Wireless is a Delaware corporation with a principal place of business at 1 Verizon Way, Basking Ridge,  New Jersey 07920 and regularly does business throughout this judicial district and by, among other things, committing jointly, directly, and/or indirectly the tort of patent infringement giving rise to this complaint. Verizon has designated Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 as its agent for service of process. Alternatively, Verizon may be served with process by serving the Secretary of State of the State of Texas pursuant to the Texas Long Arm Statute, Texas Civil Practice & Remedies Code § 17.044 and asking the Secretary of State to serve Verizon at its principal place of  business at 1 Verizon Way, Basking Ridge, New Jersey 07920- Return Receipt Requested.
JURISDICTION AND VENUE
7.
 
This action arises under the patent laws of the United States, Title 35 of the United States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 8.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b, c) and 1400(b) because, among other reasons, defendants are subject to personal jurisdiction in this District, and have committed and continue to commit acts of patent infringement in this Districts. For example, defendants have used, sold, offered for sale, and/or imported infringing products in this District. 9.
 
On information and belief, each defendant is subject to this Court’s specific and general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least to its substantial business in this forum, including: (A) at least part of its infringing activities alleged herein, and (B) regularly doing or soliciting business, engaging in 3

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