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American Vehicular Sciences v. TomTom et. al.

American Vehicular Sciences v. TomTom et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:14-cv-00141: American Vehicular Sciences LLC v. TomTom, Inc., et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9Yz for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:14-cv-00141: American Vehicular Sciences LLC v. TomTom, Inc., et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9Yz for more info.

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Published by: PriorSmart on Feb 28, 2014
Copyright:Public Domain

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02/28/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION AMERICAN VEHICULAR SCIENCES LLC, Plaintiff, v. TOMTOM, INC., TOMTOM INTERNATIONAL B.V., TOMTOM N.V., AND MAZDA MOTOR OF AMERICA, INC. D/B/A MAZDA NORTH AMERICAN OPERATIONS, Defendants. § § § § § § § § § § § § § § § Civil Action No. _____________ JURY TRIAL
 
PLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff American Vehicular Sciences LLC (“AVS”) files this Original Complaint for  patent infringement against Defendants TomTom, Inc. (“TTI”), TomTom International B.V. (“TTIBV”), and TomTom N.V. (“TTNV”) (collectively, “TomTom Defendants” or “TomTom”) and Mazda Motor Of America, Inc. d/b/a Mazda North American Operations (“Mazda”).
PARTIES
1.
 
Plaintiff AVS is a limited liability company existing under the laws of Texas with its principal place of business at 6136 Frisco Square Blvd., Suite 385, Frisco, Texas 75034. 2.
 
On information and belief, Defendant TomTom, Inc. is a Massachusetts corporation with its principal place of business at 150 Baker Ave., Concord, Massachusetts, 01742.
 
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3.
 
On information and belief, Defendant TomTom International B.V. is a Dutch corporation with its principal place of business at Oosterdoksstraat 114, 1011 DK Amsterdam, The Netherlands. 4.
 
On information and belief, Defendant TomTom N.V. is a Dutch corporation with its principal place of business at Oosterdoksstraat 114, 1011 DK Amsterdam, The Netherlands. 5.
 
On information and belief, TomTom, Inc. is a wholly-owned subsidiary of TomTom International B.V. 6.
 
On information and belief, TomTom International B.V. is a wholly-owned subsidiary of TomTom N.V. 7.
 
On information and belief, TomTom N.V. is a publicly held corporation. 8.
 
On information and belief, Defendant Mazda Motor Of America, Inc. d/b/a Mazda North American Operations is a California corporation with its principal place of  business at 7755 Irvine Center Dr., Irvine, CA 92618.
JURISDICTION AND VENUE
9.
 
This is an action for patent infringement under the Patent Laws of the United States, 35 U.S.C. § 271. 10.
 
This court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 11.
 
This Court has personal jurisdiction over TomTom and Mazda. On information and belief, TomTom and Mazda, either directly or through intermediaries, regularly sell products and services into this judicial district and manufacture products intended to be sold and in fact sold into and within this judicial district. Additionally, on information and belief, this Court has
 
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 personal jurisdiction over TomTom and Mazda because TomTom and Mazda have committed and/or participated in the commission of acts within this judicial district giving rise to this action. 12.
 
Venue is proper as to all defendants in this judicial district under 28 U.S.C. §§ 1391(b) and 1400 (b).
SUMMARY
13.
 
Dr. David Breed is one of the leading inventors in the field of automotive technology in the world today. 14.
 
Dr. Breed is an inventor on more than 300 United States patents relating to automotive technologies, including airbags, navigation systems, vehicle diagnostics, crash sensors, vehicle communications, systems monitoring, theft protection, and collision avoidance. 15.
 
Dr. Breed has a Ph.D. in Mechanical Engineering from Columbia University as well as Bachelors’ and Masters’ degrees from the Massachusetts Institute of Technology. 16.
 
Dr. Breed has received the National Highway Traffic Safety Administration's Award for Safety Engineering and the prestigious H.H. Bliss award for his contributions to the development of the airbag. 17.
 
Dr. Breed is a member of the Tau Beta Pi and Pi Tau Sigma engineering honors societies and has published numerous peer-reviewed articles.
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,630,795
 18.
 
AVS incorporates the foregoing paragraphs as if fully set forth here. 19.
 
On January 14, 2014, the USPTO duly and legally issued United States Patent No. 8,630,795 B2 (“the ‘795 Patent”), entitled “Vehicle Speed Control Method and Arrangement.”

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