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Rothschild Location Technologies v. Nissan North America

Rothschild Location Technologies v. Nissan North America

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00879-UNA: Rothschild Location Technologies LLC v. Nissan North America Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-laF6 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00879-UNA: Rothschild Location Technologies LLC v. Nissan North America Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-laF6 for more info.

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Published by: PriorSmart on Jul 07, 2014
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09/10/2014

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1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
ROTHSCHILD LOCATIONTECHNOLOGIES, LLC,Plaintiff,v. NISSAN NORTH AMERICA, INC.,Defendant.C.A. No. ________________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Rothschild Location Technologies, LLC (“Rothschild” or “Plaintiff”) files thisComplaint for patent infringement against Nissan North America, Inc. (“Nissanor “Defendant”) alleging as follows:
PARTIES
1. Plaintiff Rothschild is limited liability corporation organized under the state of Delaware having a principal place of business of 1108 Kane Concourse, Suite 310, Bay Harbor Islands, FL 33154.2. On information and belief, Defendant Nissan is a corporation organized andexisting under the laws of the State of California, with its principal place of business located atOne Nissan Way, M.S. A-5-C, Franklin, TN 37067. On information and belief, Nissan may beserved via its registered agent, Corporation Service Company, 2710 Gateway Oaks Dr., Ste.150N, Sacramento, CA 95833.
 
2
JURISDICTION AND VENUE
3. This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338(a).4. Venue is proper in this district under 28 U.S.C. §§ 1391(c) and 1400(b). Oninformation and belief, Defendant has transacted business in this district, and has committed actsof patent infringement in this district.5. The Court has personal jurisdiction over Nissan, as has availed itself, under theDelaware Long Arm Statute, of the rights and benefits of this District by conducting business inthis jurisdiction, including by promoting products for sale via the internet, which are accessibleto and accessed by residents of this District.
U.S. PATENT NO. 7,917,285
6. Plaintiff is the owner by assignment of United States Patent No. 7,917,285 (the“’285 Patent”) entitled “Device, system and method for remotely entering, storing and sharingaddresses for a positional information device.The ’285 Patent issued on April 28, 2006. A trueand correct copy of the ’285 Patent is attached as Exhibit A.7. Mr. Leigh M. Rothschild is listed as the inventor on the ’285 Patent.8. On information and belief, to the extent any marking was required by 35 U.S.C.§ 287, predecessors in interest to the ’285 Patent complied with such requirements.
COUNT I(INFRINGEMENT OF U.S. PATENT NO. 7,917,285)
9. Nissan has, pursuant to 35 U.S.C. § 271, infringed and continues to infringe, the’285 Patent in the State of Delaware, in this judicial district, and/or elsewhere in the UnitedStates by, among other things, making, using, selling, offering to sell, and/or importing, without
 
3license, systems for remotely entering and sharing location information, such as Nissan’s InfinityConnect.10. Nissan’s Infinity Connect falls within the scope of at least claim 1 of the ’285Patent, as evidenced by Nissan’s product descriptions. For example, Nissan’s Infinity Connect provides a system for remotely entering location information into a positional informationdevice.
 See
 http://www.infinitiusa.com/intouch/faq.html. The Infinity Connect server isconfigured to receive a request of at least one location, determines the address of the at least onelocation and transmits the determined address to the positional information device, andtransmitting the one address to the first positional devices. For example, Infinity Connect allowsusers to “search for destinations from a point of interest . . . then send the information to your vehicle’s navigation system.”
 Id.
11. As a result of Nissan’s infringement of the ’285 Patent, Plaintiff has sufferedmonetary damages in an amount not yet determined, and will continue to suffer damages in thefuture unless Nissan’s infringing activities are enjoined by this Court..12. Unless a permanent injunction is issued enjoining Nissan and its agents, servants,employees, attorneys, representatives, affiliates, and all others acting on their behalf frominfringing the ’285 Patent, Plaintiff will be irreparably harmed.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter:1. A judgment in favor of Plaintiff that Nissan has infringed the ’285 Patent;2. A permanent injunction enjoining Nissan and its officers, directors, agentsservants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in

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