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InMotion Imagery Technologies v. Grass Valley et. al.

InMotion Imagery Technologies v. Grass Valley et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:14-cv-00365: InMotion Imagery Technologies, LLC v. Grass Valley USA, LLC et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-lafD for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:14-cv-00365: InMotion Imagery Technologies, LLC v. Grass Valley USA, LLC et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-lafD for more info.

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Published by: PriorSmart on Apr 16, 2014
Copyright:Public Domain

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04/16/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
INMOTION IMAGERY TECHNOLOGIES, LLC, Plaintiff, v. GRASS VALLEY USA, LLC, AND BELDEN, INC. Defendant. § § § § § § § § § § § § CIVIL ACTION NO. 2:14-cv-365
JURY TRIAL DEMANDED
PLAINTIFF’S ORIGINAL COMPLAINT
 
Plaintiff InMotion Imagery Technologies, LLC (hereinafter, “InMotion” or “Plaintiff”)
 by and through its undersigned counsel, files this Complaint against Defendants Grass Valley USA, LLC and Belden, Inc. (collectively, with Grass Valley USA, LLC,
Grass Valley
” or
Defendant
”),
as follows:
NATURE OF THE ACTION
1.
 
This is a patent infringement action to stop Defendant
s infringement of
Plaintiff’s United States Patent No. 6,526,219 (hereinafter, the “‘219 Patent”), entitled “Picture
-
Based Video Indexing System”, and United States Patent No. 8,150,239, also entitled “Picture
-Based Video Indexing S
ystem” (hereinafter, the “‘239 Patent”) (collectively, referred to as the “Patents
-in-
Suit”). A copy
 
of the ‘219
P
atent and the ‘239
 Patent is attached hereto as Exhibit A and Exhibit B, respectively. Plaintiff is the exclusive assignee of both the Patents-in-Suit. Plaintiff seeks injunctive relief and monetary damages.
 
2 COMPLAINT FOR PATENT INFRINGEMENT
PARTIES
2.
 
Plaintiff InMotion is a limited liability company organized and existing under the laws of Texas with its principal place of business at 104 East Houston Street, Suite #175, Marshall, Texas 75670. 3.
 
Plaintiff is the exclusive assignee under the Patents-in-Suit, including the exclusive right to sue the Defendant for infringement and recover past damages. 4.
 
Upon information and belief, Grass Valley USA, LLC is a limited liability company organized and existing under the laws of the State of Delaware. Upon information and  belief, in early 2014, it was announced that Belden, Inc. planned to acquire Grass Valley USA, LLC and combine Grass Valley USA, LLC with one of its other subsidiaries, Miranda Technologies, Inc. A
ccording to the California Secretary of State’s website, Grass Valley
 USA, LLC still maintains its principal place of business at 475 Brannan Street, Suite 400, San Francisco, CA 94107. 5.
 
Belden, Inc. is a corporation organized under the laws of the State of Delaware, with its principal place of business at 7733 Forsyth Boulevard, St. Louis, Missouri 63105. Upon information and belief, Belden, Inc. acquired Grass Valley, but still does business through Grass Valley USA, LLC under the Grass Valley Brand Name for its nonlinear video editing software. Belden, Inc. may be served with process through its registered agent, The Prentice-Hall Corporation System, Inc., located at 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
JURISDICTION AND VENUE
6.
 
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).
 
3 COMPLAINT FOR PATENT INFRINGEMENT 7.
 
The Court has personal jurisdiction over Defendant because Defendant has minimum contacts within the State of Texas, and the Eastern District of Texas; Defendant has  purposefully availed itself of the privileges of conducting business in the State of Texas and in the Eastern District of Texas; Defendant has sought protection and benefit from the laws of the State of Texas; Defendant regularly conducts business within the State of Texas and within the Eastern District of Texas;
and, Plaintiff’s cause of action arise
s directly from
Defendant’s
  business contacts and other activities in the State of Texas and in the Eastern District of Texas. 8.
 
More specifically, Defendant, directly and/or through intermediaries, ships, distributes, offers for sale, sells, and/or advertises its products and services in the United States, the State of Texas, and the Eastern District of Texas. Upon information and belief, Defendant has committed patent infringement in the State of Texas and in the Eastern District of Texas, has contributed to patent infringement in the State of Texas and in the Eastern District of Texas and/or has induced others to commit patent infringement in the State of Texas and in the Eastern District of Texas. Defendant solicits customers in the State of Texas and in the Eastern District of Texas. Defendant has many paying customers who are residents of the State of Texas and the Eastern District of Texas and who each use respectively
Defendant’s products and services in the
State of Texas and in the Eastern District of Texas. 9.
 
Venue is proper in the Eastern District of Texas pursuant to 28 U.S.C. §§ 1391 and 1400(b).
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,526,219 BY GRASS VALLEY
10.
 
United States Patent No. 6,526,219, entitled “Picture
-Based Video Indexing
System,” was duly and legally issued by the United States Patent and Trademark Office on

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