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Published by sabatino123

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Published by: sabatino123 on Apr 08, 2014
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04/09/2014

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1
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS
INNOVATIVE DISPLAY TECHNOLOGIES LLC
Plaintiff, v. GOOGLE INC. and MOTOROLA MOBILITY, LLC, Defendants. § § § § § § § § § § § C.A. No. ____ JURY TRIAL DEMANDED PLAINTIFF
S COMPLAINT
Innovative Display Technologies LL
C (“Plaintiff”) by and through its
undersigned counsel, files this Complaint against Google, Inc. and Motorola Mobility, LLC (collectively,
“Defendants”).
 
THE PARTIES
1.
 
Innovative Display Technologies LLC
(“IDT”)
 is a Texas limited liability company with its principal place of business located at 2400 Dallas Parkway, Suite 200, Plano, Texas 75093. 2.
 
Upon information and belief, Google, Inc.,
(“Google”)
is a Delaware corporation with offices at 1600 Amphitheatre Parkway, Mountain View, California 94043. Upon information and belief, Google may be served with process by serving its registered agent, Corporation Service Company d/b/a CSC-Lawyers Incorporating Service Company, 211 E. 7
th
 Street, Suite 620, Austin, Texas 78701. 3.
 
Upon information and belief, Motorola Mobility, LLC (“Motorola”) is a
corporation organized under the laws of the State of Delaware with its principle place of business at 600 North U.S. Highway 45, Libertyville, Illinois 60048. Upon information and belief, Motorola
Case 2:14-cv-00302-JRG-RSP Document 1 Filed 04/08/14 Page 1 of 29 PageID #: 1
 
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
5.
 
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1,
et seq.
, 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
Defendants’
 business contacts and other activities in this District. 7.
 
Defendants
 – 
 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
 
3  placed one or more infringing products, as described below, into the stream of commerce with the expectation and/or knowledge that they will be purchased by consumers in this District. Defendants knowingly and purposefully ship infringing products into and within this District through an established distribution channel. These infringing products have been and continue to  be purchased by consumers in this District. Upon information and belief, Defendants have committed the tort of patent infringement in this District and/or has induced others to commit  patent infringement in this District. 8.
 
Venue is proper in this Court under 28 U.S.C. §§ 1391(b), (c), and (d), as well as 28 U.S.C. § 1400(b)
. One or more of IDT’s witnesses reside in this District.
 Defendants are subject to personal jurisdiction in this District, and therefore is deemed to reside in this District for  purposes of venue, and, upon information and belief, Defendants have committed acts within this  judicial District giving rise to this action and does business in this District, including but not limited to making sales in this District, providing service and support to their respective customers in this District, and/or operating interactive websites that are available to persons in this District, which websites advertise, market, and/or offer for sale infringing products. Defendants also make one or more infringing products in Fort Worth, Texas.
JOINDER
9.
 
Joinder is proper under 35 U.S.C. § 299. The allegations of infringement contained herein are asserted against the Defendants jointly, severally, or in the alternative and arise, at least in
 part, out of the same series of transactions or occurrences relating to Defendants’ manufacture,
use, sale, offer for sale, and importation of one or more of the same accused products. On information and belief, Defendants are part of the same corporate family of companies, and the
infringement allegations arise at least in part from Defendants’ collective activities with respect to
Case 2:14-cv-00302-JRG-RSP Document 1 Filed 04/08/14 Page 3 of 29 PageID #: 3

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