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COMPLAINT FOR PATENT INFRINGEMENT
SUSMAN
GODFREY
L.L.P.12345678910111213141516171819202122232425262728
UNITED STATES DISTRICT COURTWESTERN DISTRICT OF WASHINGTONAT SEATTLEINTERVAL LICENSING LLC,Plaintiff,v.AOL, INC.; APPLE, INC.; eBAY, INC.;FACEBOOK, INC.; GOOGLE INC.;NETFLIX, INC.; OFFICE DEPOT, INC.;OFFICEMAX INC.; STAPLES, INC.;YAHOO! INC.; AND YOUTUBE, LLC,Defendants.Case No.
COMPLAINT FOR PATENTINFRINGEMENT
JURY DEMAND
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Interval Licensing LLC, files this complaint for patent infringement againstDefendants AOL, Inc., Apple, Inc., eBay, Inc., Facebook, Inc., Google Inc., Netflix, Inc.,Office Depot, Inc., OfficeMax Inc., Staples, Inc., Yahoo! Inc., and YouTube, LLC. Plaintiff Interval Licensing LLC alleges:
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1201 Third Avenue, Suite 3800Seattle, WA 98101-3000Tel: (206) 516-3880; Fax: (206) 516-3883
1150437v1/011873
Case 2:10-cv-01385 Document 1 Filed 08/27/10 Page 1 of 15
COMPLAINT FOR PATENT INFRINGEMENT
SUSMAN
GODFREY
L.L.P.12569101114161921242627347812131517182022232528
THE PARTIES
1.
Interval Licensing LLC (“Interval”) is a limited liability company dulyorganized under the laws of the state of Washington, with its principal place of business at505 Fifth Avenue South, Suite 900, Seattle, WA 98104.2.
Interval is informed and believes, and on that basis alleges, that DefendantAOL, Inc. (“AOL”) is a corporation duly organized and existing under the laws of the stateof Delaware, with its principal place of business at 770 Broadway, New York, NY 10003.3.
Interval is informed and believes, and on that basis alleges, that DefendantApple, Inc. (“Apple”) is a corporation duly organized and existing under the laws of thestate of California, with its principal place of business at 1 Infinite Loop, Cupertino, CA95014.4.
Interval is informed and believes, and on that basis alleges, that DefendanteBay, Inc. (“eBay”) is a corporation duly organized and existing under the laws of the stateof Delaware, with its principal place of business at 2145 Hamilton Avenue, San Jose, CA95125.5.
Interval is informed and believes, and on that basis alleges, that DefendantFacebook, Inc. (“Facebook”) is a corporation duly organized and existing under the laws of the state of Delaware, with its principal place of business at 1601 S. California Avenue, PaloAlto, CA 94304.6.
Interval is informed and believes, and on that basis alleges, that DefendantGoogle Inc. (“Google”) is a corporation duly organized and existing under the laws of thestate of Delaware, with its principal place of business at 1600 Amphitheatre Parkway,Mountain View, CA 94043.
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1201 Third Avenue, Suite 3800Seattle, WA 98101-3000Tel: (206) 516-3880; Fax: (206) 516-3883
1150437v1/011873
Case 2:10-cv-01385 Document 1 Filed 08/27/10 Page 2 of 15
COMPLAINT FOR PATENT INFRINGEMENT
SUSMAN
GODFREY
L.L.P.15610111516202125262728
234789121314171819222324
7.
Interval is informed and believes, and on that basis alleges, that DefendantNetflix, Inc. (“Netflix”) is a corporation duly organized and existing under the laws of thestate of Delaware, with its principal place of business at 100 Winchester Circle, Los Gatos,CA 95032.8.
Interval is informed and believes, and on that basis alleges, that DefendantOffice Depot, Inc. (“Office Depot”) is a corporation duly organized and existing under thelaws of the state of Delaware, with its principal place of business at 6600 North MilitaryTrail, Boca Raton, FL 33496.9.
Interval is informed and believes, and on that basis alleges, that DefendantOfficeMax Inc. (“OfficeMax”) is a corporation duly organized and existing under the lawsof the state of Delaware, with its principal place of business at 263 Shuman Boulevard,Naperville, IL 60563.10.
Interval is informed and believes, and on that basis alleges, that DefendantStaples, Inc. (“Staples”) is a corporation duly organized and existing under the laws of thestate of Delaware, with its principal place of business at 500 Staples Drive, Framingham,MA 01702.11.
Interval is informed and believes, and on that basis alleges, that DefendantYahoo! Inc. (“Yahoo”) is a corporation duly organized and existing under the laws of thestate of Delaware, with its principal place of business at 701 First Avenue, Sunnyvale, CA94089.12.
Interval is informed and believes, and on that basis alleges, that DefendantYouTube, LLC (“YouTube”) is a limited liability company duly organized and existing
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1201 Third Avenue, Suite 3800Seattle, WA 98101-3000Tel: (206) 516-3880; Fax: (206) 516-3883
1150437v1/011873
Case 2:10-cv-01385 Document 1 Filed 08/27/10 Page 3 of 15
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