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Segan v. Zynga

Segan v. Zynga

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Published by PatentBlast
Segan v. Zynga
Segan v. Zynga

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Published by: PatentBlast on Mar 28, 2014
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03/28/2014

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IN THE UNITED STATES DISTRICT COURT
OR
THE DISTRICT OF DELAWARE
SEGANLLC§ § Plaintiff,§§ v. §CivilActionNo.§
ZY1~GA
INC.§§Defendant.§
Jury
TrialDemanded
PLAINTIFF S COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff,SeganLLC,filesthisComplaintagainstDefendant,Zynga,Inc.,and,insuportthereof,furtherstatesandallegesasfollows:
TH
PARTIES
1.
Plaintiff,SdganLLC,isaNewYorklimitedliabilitycompany,havinga
pl ~e
of
businesslocatedat33-00NorthernBoulevard,LongIslandCity,NewYork,
11101
2.
Uponinformationandbelief,DefendantZynga,Inc.isaDelawarecorporlon,havingaplace
of
businesslocatedat444DeHaroStreet,Sui132,SanFrancisco,Cali£rnia94107.
JURISDICTION AND VENU
3.
Thisisachrilactionforinfringementunderthe1ws
of
theUnitedStates,Title35
I
UnitedStatesCode
§§
1
e
seq
4.
ThisCourthasoriginalsubjectmatterjurisditionunder28U.S.C.
§§
(federalquestion)and1338(a)(patent-exclusivejurisdiction).
 
331
 
5. Upon
inforJ11ation
and belief, this Court has personal jurisdiction over Defe dant because Defendant is a corporation organized and existing under the laws
of
the Sta
of
Delaware and because
ef~ndant
has conducted and does conduct business within the Distnbt
of
Delaware.
6.
Venue is proper under 28 U.S.C.
§§
1391(b) and (c) and 1400(b), as Defend
tis
subject to personal jurisdiction in this district.
F CTU LB CKGROI~D
A.
nventors
7.
Joint-inventor Marc Segan is the Founder and President
of
Plaintiff, Segan L product invention and development company. Mr. Segan is a prolific inventor and entrepre eur, having designed and develfped numerous electronic and other products over the past
thirtY-I
ee years that have been
li en~ed
to or which have been used by major corporations.
n
additi?n to
I
founding Segan LLC, Mr. iSegan founded or co-founded SwartztrauberlSegan Inc., M. H. sbgan
I
&
Company Inc., Quadlogic Controls Corp., Long Hall Technologies, L.L.C., and The Animated Animations Company LLC, each
of
which has developed and produced num ous innovative products that
~ve
been widely distributed and highly profitable.
S.
JOint inv4r
Gene Lewin
has
served
in
management positions
for various technology companies for nearly 20 years. For
13
years, beginning in 1993,
Mr.
Lewin servrd as the Director
of
Information Technology for Plaintiff
or Plaintiffs
predecessor, where Mr.
WIll
maintained the informatibn technology infrastructure and provided numerous custo
I
applications, including
~tom
prototyping tools to aid in consumer electronic product de$ign. During his tenure at
seg~
LLC, Mr. Lewin worked closely with Mr. Segan to
evelo~
the
I :
concept behind a system for viewing content over a network, which is the subject
of
the
pr
sent 2
 
patent-in-suit, and developed all
of
the back-end communications components for the
i
prototype
of
that system.
B.
U.S. Patent
No.
7 O~4 928
9. On May 30, 2006, the U.S. Patent and Trademark Office duly and legally ed U.S. Patent No. 7,054,928
1
( the '928 patent ), entitled System for Viewing Content
0
r a
I '
i
Network and Method Thenrfor. Mr. Segan and Mr. Lewin are named as joint inventors. Aitrue and correct copy
of
the '928 patent is attached hereto as Exhibit A. 10. Plaintiff, Segan LLC, is the owner by assignment
of
the '928 patent. 11.
On
June 30,12011, Plaintiff sent to Defendant, vi United Parcel Service
ov
ght delivery, a copy
of
the '928 patent and a letter informing Defend nt
of
the '928 patent.
COUNT
I
Infrin ement
of
the '928 Paten
12. Plaintiff
inclJ
rporates the allegations
of
paragrap s 1 through
11
 
as
though
rllY
set forth herein. . 13. Upon infOlfation and belief, Defendant's busin ss is fundamentally predi4ated on
t
making, using,
semnJ.:.
offering for sale, and/or importing into the United States a
arier
of
computer applications cov:ered by the '928 patent, including but not limited to, Cafe Wrrld, CityVille, Empires
Allieis
FarmVille, FishVille, FrontierVille, Mafia Wars, PetVille, Treasure Isle, Yo Ville, and Zynga
ptker
14. Upon inforrpation and belief, Defendant has directly and/or indirectly
infri~ed
and continues to infringe, the '928 patent, by,
inter alia
making, using, selling, offering for
~ale
and/or importing these
pro~ucts
in the District
of
Delaware and elsewhere in the United
Statb
3
I

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