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Peel Technologies v. Universal Electronics

Peel Technologies v. Universal Electronics

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 8:14-cv-00439: Peel Technologies, Inc. v. Universal Electronics Inc. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-la8J for more info.
Official Complaint for Patent Infringement in Civil Action No. 8:14-cv-00439: Peel Technologies, Inc. v. Universal Electronics Inc. Filed in U.S. District Court for the Central District of California, no judge yet assigned. See http://news.priorsmart.com/-la8J for more info.

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Published by: PriorSmart on Mar 21, 2014
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Case No. 8:14-cv-00439COMPLAINT FOR PATENT INFRINGEMENT
QUINN EMANUEL URQUHART & SULLIVAN, LLP CLAUDE M. STERN (Bar No. 96737) claudestern@quinnemanuel.com 555 Twin Dolphin Drive, 5
th
 Floor Redwood Shores, California 94065-2139 Telephone: (650) 801-5000 Facsimile: (650) 801-5100 JOSEPH M. PAUNOVICH (Bar No. 228222)  joepaunovich@quinnemanuel.com RICHARD H. DOSS (Bar No. 204078) richarddoss@quinnemanuel.com 865 S. Figueroa St., 10th Floor Los Angeles, California, 90017 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 Attorneys for Plaintiff Peel Technologies, Inc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION PEEL TECHNOLOGIES, INC., Plaintiff , vs. UNIVERSAL ELECTRONICS INC., Defendant. CASE NO. 8:14-cv-00439
COMPLAINT FOR PATENT INFRINGEMENT DEMAND FOR JURY TRIAL
 
 
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Case No. 8:14-cv-00439COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Peel Technologies, Inc. ("Peel") complains and alleges as follows against Universal Electronics Inc. ("UEI"):
NATURE OF CASE
1.
 
This is an action for patent infringement that arises under the patent laws of the United States, Title 35 of the United States Code.
2.
 
UEI has infringed and continues to infringe, contribute to the infringement of, and/or actively induce others to infringe U.S. Patent No. 6,879,351 ("the '351 Patent").
PARTIES
3.
 
Plaintiff Peel is a corporation organized and existing under the laws of the State of Delaware, having a principal place of business at 321 Castro St., Ste 201, Mountain View, California 94041.
4.
 
Defendant UEI is a corporation organized and existing under the laws of the State of Delaware, having a principal place of business at 201 E. Sandpointe Avenue, Santa Ana, California 92707.
JURISDICTION AND VENUE
5.
 
This lawsuit is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. §§ 1
et seq
. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1338.
6.
 
This Court has personal jurisdiction over UEI for at least the following reasons: (i) UEI maintains its principal place of business in this District; (ii) UEI has designated an agent for service of process in the State of California; (iii) UEI has committed acts of patent infringement and/or contributed to or induced acts of patent infringement by others in this District and elsewhere in California and the United States; (iv) UEI regularly does business or solicits business, engages in other persistent courses of conduct, and/or derives substantial revenue from products and/or services provided to individuals in this District and in this State; and (v) UEI has initiated litigation in this judicial District.
 
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Case No. 8:14-cv-00439COMPLAINT FOR PATENT INFRINGEMENT
7.
 
Venue is proper in this judicial District pursuant to 28 U.S.C. §§ 1391(b)-(d) and 1400(b) because UEI does business in the State of California, has committed acts of infringement in this State and in this District, has a regular and established place of business in this District, and is subject to personal  jurisdiction in this District.
COUNT I INFRINGEMENT OF THE '351 PATENT
8.
 
Peel realleges and incorporates by reference the allegations of Paragraphs 1-7 of this Complaint as though fully set forth herein.
9.
 
Peel is the owner of all rights, title, and interest, including the right to sue for past infringement, in and to the '351 Patent, entitled "Method and apparatus for remote control," which was duly and properly issued by the USPTO on April 12, 2005. Peel therefore has standing to sue for infringement of the '351 Patent. Attached hereto as Exhibit A is a true and correct copy of the '351 Patent.
10.
 
Upon information and belief, in violation of 35 U.S.C. § 271, UEI is and has been directly infringing, literally and/or under the doctrine of equivalents, contributing to the infringement of, and/or inducing others to infringe the '351 Patent by making, having made, using, selling, and/or offering to sell in the United States, or importing into the United States, products or processes that practice the inventions claimed in the '351 Patent, including without limitation, the UEI Atlas URC 1056, UEI Titan URC 1056, UEI Comcast DVR Silver URC 1056, UEI Comcast DVR Platinum URC 1167, UEI Comcast XMP 1067, UEI 1060 Charter C4000, UEI Pioneer Generic OCAP URC C4000 and S4000, UEI Cox DVR Silver URC 7820, UEI Nova, UEI Essence, UEI Contour, UEI Polaris, and UEI URC 1090 Remote Controls (collectively, the "Accused UEI Instrumentalities").
11.
 
Upon information and belief, UEI has had actual knowledge of the '351 Patent and its inducement and contributory infringement at least since the filing of this lawsuit if not earlier. With full knowledge of its inducement and

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