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Graphics Properties Holdings v. Motorola Mobility Holdings et. al.

Graphics Properties Holdings v. Motorola Mobility Holdings et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-00108-UNA: Graphics Properties Holdings Inc. v. Motorola Mobility Holdings Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l5m8 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-00108-UNA: Graphics Properties Holdings Inc. v. Motorola Mobility Holdings Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l5m8 for more info.

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Published by: PriorSmart on Jan 31, 2012
Copyright:Public Domain

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02/01/2013

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#15207086 v1
 
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
GRAPHICS PROPERTIES HOLDINGS,INC.,))) CIVIL ACTION NO.Plaintiff, ))v. ))MOTOROLA MOBILITY HOLDINGS,INC., AND MOTOROLA MOBILITY,INC.,)))JURY TRIAL DEMANDED)Defendants. )
COMPLAINT FOR PATENT INFRINGEMENT
1.
 
Plaintiff Graphics Properties Holdings, Inc. (“GPH” or “Plaintiff”), byand through its attorneys, hereby demands a jury trial and complains of Defendants MotorolaMobility Holdings, Inc., and Motorola Mobility, Inc. (collectively “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/or importation 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.6,650,327 (the “’327 Patent”) (attached as Exhibit A) entitled “Display System HavingFloating Point Rasterization and Floating Point Framebuffereing,” United States Patent No.6,816,145 (the “’145 Patent”) (attached as Exhibit B) entitled “Large Area Wide AspectRatio Flat Panel Display Having High Resolution For High Information Content Display,”and United States Patent No. 5,717,881 (the “’881 Patent”) (attached as Exhibit C) entitled
 
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#15207086 v1
“Data Processing System for Processing One and Two Parcel Instructions.” Plaintiff seeksinjunctive relief to prevent Defendants from continuing to infringe Plaintiff’s patents. Inaddition, Plaintiff seeks a recovery of monetary damages resulting from Defendants’ pastinfringement 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 consumer electronics and display devices, including but not limited to Defendants’ mobile phones, telecommunication devices, and other consumer electronics and display devices.
THE PARTIES
 4.
 
Plaintiff GPH is a Delaware corporation with its principal place of  business at 56 Harrison Street, Suite 505, New Rochelle, New York 10801.5.
 
Plaintiff GPH is the lawful assignee of all right, title and interest in andto the ’327, ’145 and ’881 Patents (collectively, the “Asserted Patents”).6.
 
GPH was formerly named Silicon Graphics, Inc. As Silicon Graphics,GPH developed technology and intellectual property used in the graphics, computer  processing, and display segments. GPH is owned by private investment funds and other institutional investors, following the bankruptcy of Silicon Graphics.7.
 
GPH continues to manage and license its intellectual property,including the ’327 Patent, the ’145 Patent, and the ’881 Patent.8.
 
Defendant Motorola Mobility, Inc. is a communications corporationorganized and existing under the laws of the state of Delaware, with its principal place of  business located at 600 N. U.S. Highway 45, Libertyville, Illinois 60048. Motorola Mobility,
 
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Inc. is in the business of developing, manufacturing, and selling portable communicationdevices. Such devices include, but are not limited to, cellphones and computer tablets.9.
 
Defendant Motorola Mobility Holdings, Inc., formerly the MobileDevices division of Motorola Inc. until January 2011, is a communications corporationorganized and existing under the laws of the state of Delaware, with its principal place of  business located at 600 N. U.S. Highway 45, Libertyville, Illinois 60048. Motorola MobilityHoldings, Inc. is the parent company of Motorola Mobility, Inc., and is in the business of developing, manufacturing, and selling portable communication devices. Such devicesinclude, but are not limited to, cellphones and computer tablets. Motorola MobilityHoldings, Inc. and Motorola Mobility, Inc. are referred to herein collectively as “Motorola”or “Defendants.”10.
 
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 lawful patent rights to exclude others from making, using, selling, offering to sell and/or importingthe patented inventions.11.
 
Defendants’ disregard for Plaintiff’s property rights threatensPlaintiff’s relationships with existing licensees and potential licensees of Plaintiff’s consumer electronics and display device patents. The Defendants will derive a competitive advantageover any 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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