Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
LaserDynamics v. Alco Electronics Et. Al.

LaserDynamics v. Alco Electronics Et. Al.

Ratings: (0)|Views: 10|Likes:
Published by PatentBlast
LaserDynamics v. Alco Electronics et. al.
LaserDynamics v. Alco Electronics et. al.

More info:

Published by: PatentBlast on Mar 17, 2014
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

03/17/2014

pdf

text

original

 
:'i
'+::1S'*-;
;
' 1' '. .':t' imir'i"
IN
THE UNITED
STATES
DISTRICT
COURTFOR
THE
SOUTHERN
DISTRICT
OF NEW
YORK
LASERDYNAMICS, LLC,
a
Limited
Liability
Company,
Plaintiff,ALCO
ELECTRONICS
LTD.,ALCO
ELECTRONICS
INC.
and
AI,CO HOLDINGS
LIMITED
tJ ;{ur"so.l
H il
C
otvrpr.,lrnr
X'on
Plrnxr
IxrnrxcnMENT
Drlvr^lxn
Fon
Junv
Tnrar.
Defendants.
PLAINTIFF
LASERDYNAMICS'
COMPLAINT
FOR
PATENT
INFRINGEMENT
AND DEMAND
FOR
JURY
TRIAL
Plaintiff
LaserDynamics,
LLC
("LaserDynamics"
or
"Plaintiff')
by
and
for
its Complaint
against defendants
Alco
Electronics
Ltd.,
Alco
Electronics
Inc.
and
Alco
Holdings
Limited
("Alco"
or
"Defendants")
hereby
alleges
as
follows:
NATURE
OF
THE
CASE
1.
This
is
an action
for
patent
infringement arising
under
the
patent
laws
of
the
United States.
LaserDynamics holds the
rights
in
U.S.
Patent
No.
5,587,981
("the
'981
patent").
The
United
States
patent laws grant the holder
of
a patent
the
right
to
exclude
infringers from
making,
using,
selling or importing
the
invention
claimed
in
a
patent,
and
to
recover
damages
for
the infringer's
violations
of
these
rights,
and
to
recover
treble
damages
where
the
infringer
willingly
infringed the
patent.
Under
35
U.S.C.
$
282(a),
the
'981 Patent
is
entitled
to
a
presumption
of
validity.
LaserDynamics
is
suing Defendants
for infringing
its
patent, and doing
CoMPLAINT
tr.oR PATENT INFRINGEMENT
Case 1:14-cv-01704-JGK Document 2 Filed 03/12/14 Page 1 of 16
 
so
willfully.
LaserDynamics
seeks
to
recover
damages
from
Defendants,
including
treble
damages
for
willful
infringement.
2.
The ,981
patent generally relates
to
methods
for
discriminating
between
different
types
of
optical
discs (e.g.,
a
compact disc
("CD")
versus a
digital
video disc
("DVD"))
inserted
into
an
optical
disc
drive.
The '981
patent has been licensed
extensively
to
many
well-known
electronics
and
optical
disc
drive
manufacturers'
THE
PARTIES
3.
LaserDynamics
is
a limited
liability
company,
organized and
existing under
the
laws
of
the
State
of
Delaware,
having
a
place
of
business
at 75
Montebello
Road, Suffern,
New
York
10901-3740.
4.
Upon information and
belief,
Alco
Electronics
Ltd. ("AEL") is
a
corporation
existing under
the
laws
of
Hong
Kong.
Upon
information and
belief,
AEL's
corporateheadquarters are located
at
1lth
Floor, Zung Fu Industrial
Building,
1067
King's
Road, QuarryBay, Hong
Kong.
5.
Upon
information and
belief,
Alco
Electronics
Inc.
("AEI")
is a
corporationexisting
under the
laws of
North
Carolina
with
a
principal
place
of
business located
at
8392
Six
Forks Rd., Suite
104,
Raleigh,
NC
27615,
USA.
6.
Upon information
and
belief,
Alco
Holdings
Limited
("AHL")
is
a
corporationexisting
under the
laws
of
Hong
Kong.
Upon information
and
belief,
AEL
and
AEI
are
indirect
wholly
owned
subsidiaries
of
AHL,
which
is
publicly
traded company
listed
on
the Hong Kong
Stock
Exchange.
Upon
information
and
belief,
AHL's
corporate
headquarters are
located
at
11th
Floor,
Zung Fu
Industrial
Building,
1067
King's
Road, Quarry Bay,
Hong
Kong.
CoMPLAINT
FOR PATENT INFRINGEMENT
Case 1:14-cv-01704-JGK Document 2 Filed 03/12/14 Page 2 of 16
 
JURISDICTION
7.
This
is
an action
for
patent
infringement arising
under
the
patent
laws
of
the
United
States
of
America, more specifically under
35
U.S.C.
$ 100,
et
seq.
Subject
matter
jurisdiction
is proper
in this
Court pursuant
to
28
U.S.C.
$$
1331
and
1338.
8.
Personal
jurisdiction is
also proper
in
this
Court
and
this
judicial
district
under
N.Y.
Civ.
Pract.
L.
R.
$ 302
because,
upon
information
and
belief,
Defendants
have sufficient
contacts
within
the
State
of
New York
and
within
this
judicial
district
to
subject
itself
to
the
jurisdiction of this
Court.
Defendants have
purposefully
availed themselves
of
the
privileges
of
conducting
business
in the
State
of
New York
and
this
judicial district.
Defendants have
sought
protection
and
benefit
from the
laws
of
the
State
of
New
York.
Defendants
regularly
conduct
business
within
the
State
of New
York
and
within
this
judicial district.
Plaintifls
cause
of
actionarises
directly from
Defendants' business contacts and
other activities
in
the
State
of New
York
and
in
this
District.
9.
More
specifically,
personal
jurisdiction
is proper
in
this
judicial
district
because,
upon information
and
belief,
Defendants,
directly
andlor
through
its
intermediaries,
transacts
business
in
this
judicial
district, including
using,
distributing, importing, making,
offering
for
sale,
selling,
andlor
marketing,
supporting
and
advertising
of its
infringing
products
in
the
United
States,
the
State
of
New York
and
the
Southern
District
of
New
York.
In
particular,
Defendants
import
into the
United
States,
solicit
and
sell
DVD/Blu-Ray
players
in
the United
States,
including
within
the
Southern
District
of
New York
DVD/Blu-Ray
players under
the
RCA@,
Venturer@, Durabrand@,
Audiovox@
and
Trutech@
brand
names
("Brand
Names").
VENUE
CoMPLAINT
FoR
PATENT INFRINGEMENT
Case 1:14-cv-01704-JGK Document 2 Filed 03/12/14 Page 3 of 16

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->