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Parthenon Unified Memory Architecture v. LG Electronics Et. Al.

Parthenon Unified Memory Architecture v. LG Electronics Et. Al.

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Published by PatentBlast
Parthenon Unified Memory Architecture v. LG Electronics et. al.
Parthenon Unified Memory Architecture v. LG Electronics et. al.

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Published by: PatentBlast on Jun 14, 2014
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06/14/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PARTHENON UNIFIED MEMORY ARCHITECTURE LLC, PLAINTIFF, V. LG ELECTRONICS, INC. AND LG ELECTRONICS USA, INC., DEFENDANTS. § § § § § § § § § § § § § Case No. 2:14-cv-00691 JURY TRIAL REQUESTED PARTHENON UNIFIED MEMORY ARCHITECTURE LLC’S COMPLAINT FOR PATENT INFRINGEMENT
 
1 Plaintiff Parthenon Unified Memory Architecture LLC (“PUMA” or “Plaintiff”) hereby submits this Complaint against Defendants LG Electronics, Inc. and LG Electronics USA, Inc. (collectively “LG Electronics” or “Defendants”) and states as follows:
THE PARTIES
1.
 
PUMA is a Texas limited liability company, having a principal place of business at 2400 Dallas Parkway, Suite 200, Plano, Texas 75093. 2.
 
On information and belief, Defendant LG Electronics, Inc. is a corporation organized and existing under the laws of Korea, having a principal place of business at LG Twin Towers 20 Yeouido-dong, Yeongdeunspo-gu, Seoul 150-721, Republic of Korea. 3.
 
On information and belief, Defendant LG Electronics USA, Inc. is a corporation organized and existing under the laws of the state of Delaware, having a principal place of  business at 1000 Sylvan Avenue, Englewood Cliffs, New Jersey 07632.
JURISDICTION AND VENUE
4.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a) because this action arises under the patent laws of the United States, 35 U.S.C. §§ 101
et seq.
 5.
 
Venue is proper in this federal district pursuant to 28 U.S.C. §§1391(b)–(c) and 1400(b) in that Defendants have done business in this District, have committed acts of infringement in this District, and continue to commit acts of infringement in this District, entitling PUMA to relief.
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 5,812,789
6.
 
On September 22, 1998, the United States Patent and Trademark Office (“USPTO”) duly and legally issued United States Patent No. 5,812,789 (“the ’789 Patent”),
 
2 entitled “Video And/Or Audio Decompression And/Or Compression Device That Shares a Memory Interface.” PUMA holds all rights, title, and interest in and to the ’789 Patent. LG Electronics is not licensed to the ’789 Patent, yet LG Electronics knowingly, actively, and lucratively practices the patents. 7.
 
Upon information and belief, LG Electronics has infringed directly and continues to infringe directly the ’789 Patent. The infringing acts include, but are not limited to, the manufacture, use, sale, importation, and/or offer for sale of products and/or methods encompassed by the claims of the ’789 Patent. LG Electronics’ infringing products include, but are not limited to, at least the LG Elite, LG Enact, LG Enlighten, LG Escape, LG Expo, LG Exceed, LG Fathom, LG Fluid, LG G Flex, LG G2, LG Google Nexus 5, LG Ignite, LG Incite, LG Intuition, LG L40, LG L70, LG L90, LG Lucid, LG Mach, LG Marquee, LG Nexus 4, LG Optimus, LG Spectrum, and LG Splendor. 8.
 
The acts of infringement by LG Electronics have caused damage to PUMA, and PUMA is entitled to recover from LG Electronics the damages sustained by PUMA as a result of LG Electronics’ wrongful acts in an amount subject to proof at trial. The infringement of PUMA’s exclusive rights under the ’789 Patent by LG Electronics has damaged and will continue to damage PUMA, causing irreparable harm, for which there is no adequate remedy at law, unless enjoined by this Court. 9.
 
At least as early as its receipt of this Complaint, LG Electronics has had knowledge of the ’789 Patent and written notice of the infringement. PUMA intends to seek discovery on the issue of willfulness and reserves the right to seek a willfulness finding and increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred in  prosecuting this action under 35 U.S.C. § 285.

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