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Mitsubishi Electric et. al. v. World Media Group et. al.

Mitsubishi Electric et. al. v. World Media Group et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:14-cv-01257-P: Mitsubishi Electric Corporation et. al. v. World Media Group, Inc. et. al. Filed in U.S. District Court for the Northern District of Texas, the Hon. Jorge A Solis presiding. See http://news.priorsmart.com/-lacU for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:14-cv-01257-P: Mitsubishi Electric Corporation et. al. v. World Media Group, Inc. et. al. Filed in U.S. District Court for the Northern District of Texas, the Hon. Jorge A Solis presiding. See http://news.priorsmart.com/-lacU for more info.

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Published by: PriorSmart on Apr 08, 2014
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04/25/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION MITSUBISHI ELECTRIC CORPORATION, PANASONIC CORPORATION, SANYO ELECTRIC CO., LTD. and WARNER BROS. HOME ENTERTAINMENT INC., Plaintiffs, v. WORLD MEDIA GROUP, INC. and CRYSTAL CLEAR MEDIA GROUP, LLC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.
COMPLAINT FOR PATENT INFRINGEMENT; JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs Mitsubishi Electric Corporation (alternatively named Mitsubishi Denki Kabushiki Kaisha) (“Mitsubishi”), Panasonic Corporation (formerly known as Matsushita Electric Industrial Co., Ltd.) (“Panasonic”), SANYO Electric Co., Ltd. (“SANYO”) and Warner Bros. Home Entertainment Inc. (“Warner Bros.”), by their undersigned attorneys, for their complaint against Defendants World Media Group, Inc. (“WMG”) and Crystal Clear Media Group, LLC. (“CCMG”) (collectively hereinafter “Defendants”) allege as follows:
 
 
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PARTIES
 1. Plaintiff Mitsubishi is a Japanese corporation, having its principal place of  business in Tokyo, Japan. Mitsubishi owns patents that are the subject of this complaint. 2. Plaintiff Panasonic is a Japanese corporation, having its principal place of  business in Osaka, Japan. Panasonic owns patents that are the subject of this complaint. 3. Plaintiff SANYO is a Japanese corporation, having its principal place of  business in Osaka, Japan. SANYO owns patents that are the subject of this complaint. 4. Plaintiff Warner Bros. is a Delaware corporation, having its principal place of business in Burbank, California. Warner Bros. owns patents that are the subject of this complaint. 5. Defendant WMG, upon information and belief, is an Indiana corporation, with a principal place of business at 6737 E. 30
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 Street, in Indianapolis, Indiana. In addition to the Indianapolis location, WMG advertises its presence in Dallas, Texas by  prominently stating on its website (www.worldmediagroup.com) that it has a “sales and services center[] in Dallas, TX (Crystal Clear Media Group)” among other locations. The WMG website further identifies and advertises its presence in Dallas by listing CCMG for “Texas & Southwest Sales” and provides an address at 10451 Markison Road, Dallas, Texas. On information and belief, WMG and CCMG no longer transact business at the Markison Road address, but now transacts business at 10935 Estate Lane, Suite 238, Dallas, Texas. WMG, according to a Texas Business Personal Property Account, is identified as the current taxable owner of personal property located at the Estate Lane address. WMG’s website further identifies Dallas, Texas as a business location for its
 
 
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employees, including by identifying Jim Cocke as WMG’s Sales Manager – Dallas. WMG has infringed, and continues to infringe the patents identified herein by making, using, offering to sell, selling and/or importing DVDs. 6. Defendant CCMG, upon information and belief, is an Indiana corporation, with a principal place of business at 10935 Estate Lane, Suite 238, Dallas, Texas, and also having an address at 6737 E. 30
th
 Street, in Indianapolis, Indiana. On information and belief, CCMG is wholly owned and solely controlled by WMG. The CCMG website (www.crystalclearcds.com) identifies CCMG as “A World Media Group Company.” In addition, on information and belief, WMG and CCMG have common and shared directors, officers and/or employees. One such individual is Jim Cocke, who is identified on the CCMG website as its “head of sales”; the website provides contact information for Mr. Cocke at the “Dallas Sales Office.” CCMG has infringed, and continues to infringe the patents identified herein by making, using, offering to sell, selling and/or importing DVDs.
JURISDICTION AND VENUE
 
7. This is an action for patent infringement arising under the Patent Laws of the United States, United States Code, Title 35, § 1, et seq. 8. The Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338(a). 9. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b), (c), and (d), and 1400(b) because the Defendants have committed acts of direct and indirect infringement in this District, have a regular and established place of business in this

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