2 Mobility, LLC is a wholly-owned subsidiary of Google, Inc. Upon information and belief, Google may be served with process by serving its registered agent, CT Corporation System, 1999 Bryan St., Suite 900, Dallas, Texas 75201. 4.
Upon information and belief, Defendants have conducted and regularly conduct business within this District, have purposefully availed themselves of the privileges of conducting business in this District, and have sought protection and benefit from the laws of the State of Texas.
JURISDICTION AND VENUE
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1,
, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction over this case for patent infringement under 28 U.S.C. §§ 1331 and 1338(a). 6.
As further detailed herein, this Court has personal jurisdiction over Defendants. Defendants are amenable to service of summons for this action. Furthermore, personal jurisdiction over Defendants in this action comports with due process. Defendants have conducted and regularly conduct business within the United States and this District. Defendants have purposefully availed themselves of the privileges of conducting business in the United States and, more specifically, in this District. Defendants have sought protection and benefit from the laws of the State of Texas by maintaining offices in Texas, by making one or more infringing products in Fort Worth, Texas, and/or by placing infringing products into the stream of commerce through an established distribution channel with the expectation and/or knowledge that they will be purchased by consumers in this District. IDT
s causes of action arise directly from
business contacts and other activities in this District. 7.
directly or through intermediaries (including distributors, retailers, and others), subsidiaries, alter egos, and/or agents
ships, distributes, offers for sale, and/or sells their products in the United States and this District. Defendants have purposefully and voluntarily
Case 2:14-cv-00302-JRG-RSP Document 1 Filed 04/08/14 Page 2 of 29 PageID #: 2