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Finisar v. InnoLight Technology Et. Al.

Finisar v. InnoLight Technology Et. Al.

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Published by PatentBlast
Finisar v. InnoLight Technology et. al.
Finisar v. InnoLight Technology et. al.

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Published by: PatentBlast on Apr 03, 2014
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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
M
ORGAN
,
 
L
EWIS
&
 
B
OCKIUS
LLP
A
TTORNEYS AT
L
AW
 P
ALO
A
LTO
 
MORGAN, LEWIS & BOCKIUS LLPDANIEL JOHNSON, JR. (SBN 57409) MICHAEL J. LYONS (SBN 202284) DION M. BREGMAN (SBN 208393) AHREN C. HSU-HOFFMAN (SBN 250469) MICHAEL F. CARR (SBN 259911) 2 Palo Alto Square 3000 El Camino Real, Suite 700 Palo Alto, CA 94306-2122 Tel: 650.843.4000 Fax: 650.843.4001 Email: djjohnson@morganlewis.com Email: mlyons@morganlewis.com Email: dbregman@morganlewis.com Email: ahsu-hoffman@morganlewis.com Email: mcarr@morganlewis.com Attorneys for Plaintiff FINISAR CORPORATION UNITED STATES DISTRICT COURT  NORTHERN DISTRICT OF CALIFORNIA FINISAR CORPORATION, a Delaware corporation, Plaintiff, v. INNOLIGHT TECHNOLOGY USA, INC., a California corporation, and INNOLIGHT TECHNOLOGY CORPORATION, a Chinese corporation, Defendants. Case No.
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF DEMAND FOR JURY TRIAL
 
 1
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
M
ORGAN
,
 
L
EWIS
&
 
B
OCKIUS
LLP
A
TTORNEYS AT
L
AW
 P
ALO
A
LTO
 
Plaintiff FINISAR CORPORATION (“Finisar”) alleges as follows:
PARTIES
1.
 
Plaintiff Finisar is a Delaware corporation with its principal place of business at 1389 Moffett Park Drive, Sunnyvale, California 94089. Finisar is qualified and duly authorized to conduct business in the State of California. 2.
 
Defendant InnoLight Technology USA, Inc. is, on information and belief, a California corporation doing business in this judicial district and having a principal place of  business at 3235 Kifer Road, Suite 150, Santa Clara, California 95051. 3.
 
Defendant InnoLight Technology Corporation is, on information and belief, a Chinese corporation doing business in the United States, the State of California, and this judicial district, including without limitation by and through its subsidiary, affiliate companies, sales offices, and/or research and development centers.
JURISDICTION AND VENUE
 4.
 
This is a civil action arising under the patent laws of the United States, 35 U.S.C. §§ 1
et seq
. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. § 1331 and 1338(a). 5.
 
Personal jurisdiction as to each of the Defendants is proper in the State of California and in this judicial district. Defendants have a regular and established place of  business and/or ongoing business activity in this State and in this judicial district, and therefore have sufficient contacts with the State of California to satisfy the requirements of due process and Rule 4(k)(2) of the Federal Rules of Civil Procedure. 6.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b)-(d) and 1400(b).
INTRADISTRICT ASSIGNMENT
 7.
 
Under Civil L. R. 3-2(c), this action for patent infringement shall be assigned on a district-wide basis.
PATENTS-IN-SUIT
 8.
 
Finisar is the sole owner of U.S. Patent No. 7,079,775, issued on July 18, 2006,
 
 2
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
M
ORGAN
,
 
L
EWIS
&
 
B
OCKIUS
LLP
A
TTORNEYS AT
L
AW
 P
ALO
A
LTO
 
titled “Integrated Memory Mapped Controller Circuit for Fiber Optics Transceiver.” A true and correct copy of the 775 patent is attached to this Complaint as Exhibit A. 9.
 
Finisar is the sole owner of U.S. Patent No. 6,957,021, issued on October 18, 2005, titled “Optical Transceiver with Memory Mapped Locations.” A true and correct copy of the 021 patent is attached to this Complaint as Exhibit B. 10.
 
Finisar is the sole owner of U.S. Patent No. 7,058,310, issued on June 6, 2006, titled “System and Method for Protecting Eye Safety During Operation of a Fiber Optic Transceiver.” A true and correct copy of the 310 patent is attached to this Complaint as Exhibit C. 11.
 
Finisar is the sole owner of U.S. Patent No. 6,952,531, issued on October 4, 2005, titled “System and Method for Protecting Eye Safety During Operation of a Fiber Optic Transceiver.” A true and correct copy of the 531 patent is attached to this Complaint as Exhibit D. 12.
 
Finisar is the sole owner of U.S. Patent No. 7,162,160, issued on January 9, 2007, titled “System and Method for Protecting Eye Safety During Operation of a Fiber Optic Transceiver.” A true and correct copy of the 160 patent is attached to this Complaint as Exhibit E. 13.
 
Finisar is the sole owner of U.S. Patent No. 7,184,668, issued on February 27, 2007, titled “System and Method for Protecting Eye Safety During Operation of a Fiber Optic Transceiver.” A true and correct copy of the 668 patent is attached to this Complaint as Exhibit F. 14.
 
Finisar is the sole owner of U.S. Patent No. 7,050,720, issued on May 23, 2006, titled “Integrated Memory Mapped Controller Circuit for Fiber Optics Transceiver.” A true and correct copy of the 720 patent is attached to this Complaint as Exhibit G. 15.
 
Finisar is the sole owner of U.S. Patent No. RE 36,886, filed on January 12, 1995, issued on January 21, 1997, and reissued on October 3, 2000, titled “Fiber Optic Module.” A true and correct copy of the 886 patent is attached to this Complaint as Exhibit H. 16.
 
Finisar is the sole owner of U.S. Patent No. RE 40,150, filed on January 12, 1995,

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