- 2 -damage and attempt to destroy its position in the marketplace for location positioningtechnology. In complete disregard of its common-law and statutory obligations, and in directopposition to its public messaging encouraging open innovation, Google wielded its control overthe Android operating system, as well as other Google mobile applications such as Google Maps,to force device manufacturers to use its technology rather than that of Skyhook, to terminatecontractual obligations with Skyhook, and to otherwise force device manufacturers to sacrificesuperior end user experience with Skyhook by threatening directly or indirectly to deny timelyand equal access to evolving versions of the Android operating system and other Google mobileapplications.
Plaintiff Skyhook Wireless, Inc. ("Skyhook") is a corporation organized andexisting under the laws of Delaware with a principal place of business in Boston, Massachusetts.5.
Skyhook is informed and believes, and on that basis alleges, that DefendantGoogle Inc. ("Google") is a Delaware corporation with a principal place of business in MountainView, California. Google conducts business within the Commonwealth of Massachusetts, andhas claimed that over the past year alone it generated $2.2 billion worth of economic activity inMassachusetts.
JURISDICTION AND VENUE
Jurisdiction is proper in the Commonwealth of Massachusetts pursuant to Mass.Gen. L. c. 223A, § 3 because Google “transacts business” in the Commonwealth.7.
Venue is proper in Suffolk County pursuant to Mass. Gen. L. c. 223, § 8(4) and c.93, § 42A because Skyhook’s principal place of business is in Boston, Suffolk County..
FACTUAL ALLEGATIONSSkyhook's Wi-Fi Positioning and XPS Technology Outperform All Competitors
Despite its size, Skyhook is an industry leader in location positioning, context,and intelligence. Founded in 2003, Skyhook pioneered the Wi-Fi Positioning System and today