2 COMPLAINT FOR PATENT INFRINGEMENT
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
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).