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Digitude Innovations LLC

Digitude Innovations LLC

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:11-cv-01196-UNA: Digitude Innovations LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l4MR for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:11-cv-01196-UNA: Digitude Innovations LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l4MR for more info.

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Published by: PriorSmart on Dec 05, 2011
Copyright:Public Domain

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02/01/2013

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#15215657 v1
 
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
DIGITUDE INNOVATIONS LLC, ))) CIVIL ACTION NO.Plaintiff, ))v. ))RESEARCH IN MOTION LTD., andRESEARCH IN MOTION CORP.))JURY TRIAL DEMANDED)Defendants. )
COMPLAINT FOR PATENT INFRINGEMENT
1.
 
Plaintiff Digitude Innovations LLC. (“Digitude” or “Plaintiff”), by andthrough its attorneys, hereby demands a jury trial and complains of Defendants Research inMotion Ltd. and Research in Motion Corp. (“Defendants”) as follows:
NATURE OF THE ACTION
2.
 
This is an action for patent infringement arising under the patent lawsof the United States, 35 U.S.C. §§ 271,
et seq.,
to enjoin infringement and obtain damagesresulting from Defendants’ unauthorized manufacture, use, sale, offer to sell and/orimportation into the United States for subsequent use or sale of products, methods, processes,services and/or systems that infringe one or more claims of United States Patent No.5,926,636 (the “’636 Patent”) (attached as Exhibit A) entitled “Remote Procedure CallComponent Management Method for a Heterogeneous Computer Network,” United StatesPatent No. 5,929,655 (the “’655 Patent”) (attached as Exhibit B) entitled “Dual-Purpose I/OCircuit in a Combined LINK/PHY Integrated Circuit,” United States Patent No. 6,208,879(the “’879 Patent”) (attached as Exhibit C) entitled “Mobile Information Terminal Equipment
 
 
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#15215657 v1
and Portable Electronic Apparatus,” and United States Patent No. 6,456,841 (the “’841Patent”) (attached as Exhibit D) entitled “Mobile Communication Apparatus Notifying Userof Reproduction Waiting Information Effectively.” Plaintiff seeks injunctive relief to preventDefendants from continuing to infringe Plaintiff’s patents. In addition, Plaintiff seeks arecovery of monetary damages resulting from Defendants’ past infringement of these patents.3.
 
This action for patent infringement involves Defendants’ manufacture,use, sale, offer for sale, and/or importation into the United States of infringing products,methods, processes, services and systems that are primarily used or primarily adapted for usein portable communication devices, including but not limited to Defendants’ mobile phones,telecommunication devices, and other portable communication devices.
THE PARTIES
 4.
 
Plaintiff Digitude is a company with its principal place of business at601 King St., Suite #404, Alexandria, Virginia, 22314-3169.5.
 
Plaintiff Digitude is the lawful assignee of all right, title and interest inand to the ‘636, ‘655, ‘879, and ‘841 Patents (collectively, the “Asserted Patents”).6.
 
Plaintiff Digitude is a privately held company. Digitude focuses itsbusiness on licensing patented technology in the consumer electronics and communicationsindustry, including the ‘636 Patent, the ‘655 Patent, the ‘879 Patent, and the ‘841 Patent.7.
 
Upon information and belief, Defendant Research in Motion Ltd. is aforeign company organized and existing under the laws of Canada, with its principal place of business at 295 Phillip Street, Waterloo, Ontario, Canada, N2L 3WB.8.
 
Upon information and belief, Research in Motion Ltd. makes, sells,and/or offers for sale within the United States portable communication devices. Such devices
 
 
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include, but are not limited to, cell phones and computer tablets.9.
 
Upon information and belief, Research in Motion Ltd. is the parentcorporation of Defendant Research in Motion Corp., which operates the domestic operationsof Research in Motion Ltd.10.
 
Upon information and belief, Defendant Research in Motion Corp. is adomestic corporation organized and existing under the laws of the state of Delaware with itsprincipal place of business located at 122 W. John Carpenter Parkway, Suite 430, Irving,Texas 75039.11.
 
Upon information and belief, Research in Motion Corp. is a whollyowned subsidiary of Research in Motion Ltd., and is the managing entity of the United Statesoperations of Research in Motion Ltd.12.
 
Plaintiff has been irreparably harmed by the Defendants’infringements of its valuable patent rights. Moreover, Defendants’ unauthorized andinfringing uses of Plaintiff’s patented systems and methods have threatened the value of thisintellectual property because Defendants’ conduct results in Plaintiff’s loss of its lawfulpatent rights to exclude others from making, using, selling, offering to sell and/or importingthe patented inventions.13.
 
Defendants’ disregard for Plaintiff’s property rights threatensPlaintiff’s relationships with existing licensees and potential licensees of Plaintiff’s portablecommunication device patents. The Defendants will derive a competitive advantage overany of Plaintiff’s existing licensees and future licensees from using Plaintiff’s patentedtechnology without paying compensation for such use. Accordingly, unless and until theDefendants’ continued acts of infringement are enjoined, Plaintiff will suffer further

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