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Gametek v. Nhn et. al.

Gametek v. Nhn et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:12-cv-00503-WQH-BGS: Gametek LLC v. Nhn USA, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. William Q. Hayes presiding. See http://news.priorsmart.com/-l5uC for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:12-cv-00503-WQH-BGS: Gametek LLC v. Nhn USA, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. William Q. Hayes presiding. See http://news.priorsmart.com/-l5uC for more info.

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Published by: PriorSmart on Feb 29, 2012
Copyright:Public Domain

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02/01/2013

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John J. Edmonds (State Bar No. 274200) jedmonds@cepiplaw.comCOLLINS EDMONDS POGORZELSKISCHLATHER & TOWER, PLLC1851 East First Street, Suite 900Santa Ana, California 92705Telephone: (951) 708-1237Facsimile: (951) 824-7901Attorney for Plaintiff,
GAMETEK LLC
 UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF CALIFORNIAGAMETEK LLC,Plaintiff,v.NHN USA, INC.; NHN CORPORATION;IJJI GAMES, LLC; and RED DUCK INC.Defendants.Case No.: ________________
COMPLAINT FOR INFRINGEMNT OFU.S. PATENT NO. 7,076,445DEMAND FOR JURY TRIAL
This is an action for patent infringement in which GAMETEK LLC submits this OriginalComplaint against Defendants named herein, namely NHN USA, INC.; NHN CORPORATION; andIJJI GAMES, LLC (collectively “Defendants”), as follows:
THE PARTIES
1. GAMETEK LLC (“GAMETEK” or “Plaintiff”) is a California limited liabilitycompany with a place of business at 500 Newport Center Drive, Suite 700, Newport Beach, CA92660.2. On information and belief, NHN USA, INC. is a Delaware Corporation with a placeof business at 3353 Michelson Drive #200, Irvine, CA 92612. Further, on information and belief,NHN CORPORATION is a Korean corporation with a place of business at 16th Fl., Green Factory,
 
'12
CV0503
BGS
WQH
 
 
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178-1 Jeongja-dong, Bundang-gu, Seongnam-si, Gyeonggi-do, Korea. NHN USA, INC. and NHNCORPORATION are collectively referred to as “NHN.”3. On information and belief, IJJI GAMES, LLC (“IJJI”) is a California limited liabilitycompany with a place of business at 3353 Michelson Drive #200, Irvine, CA 92612.4. On information and belief, RED DUCK INC. (“RED DUCK”) is a KoreanCorporation with a place of business at JBK Tower 7F, 108-6, Samseong-dong, Gangnam-gu, SeoulKorea 135-873.
JURISDICTION AND VENUE
5. This action arises under the patent laws of the United States, Title 35 of the UnitedStates Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).6. On information and belief, the Defendants are subject to this Court’s specific and/orgeneral personal jurisdiction, pursuant to due process and/or the California Long Arm Statute, due atleast to their substantial business in California, including related to the infringements alleged herein.Further, on information and belief, Defendants have interactive websites and/or games comprisinginfringing methods which are at least used in and/or accessible in California. Further, on informationand belief, Defendants regularly conduct and/or solicit business, engage in other persistent coursesof conduct, and/or derive substantial revenue from goods and services provided to persons and/orentities in California.7. Venue is proper in this district under 28 U.S.C. §§ 1391(b), 1391(c) and 1400(b).Without limitation, on information and belief, Defendants are subject to personal jurisdiction in thisdistrict. On information and belief, the Defendants are subject to this Court’s specific and/or generalpersonal jurisdiction, pursuant to due process and/or the California Long Arm Statute, due at least totheir substantial business in this district, including related to the infringements alleged herein.
 
 
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Further, on information and belief, Defendants have interactive websites and games comprisinginfringing methods which are at least used in and/or accessible in this district. Further, oninformation and belief, Defendants regularly conduct and/or solicit business, engage in otherpersistent courses of conduct, and/or derive substantial revenue from goods and services provided topersons and/or entities in this district.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,076,445
8. United States Patent No. 7,076,445 (“the ‘445 patent”), entitled “SYSTEM ANDMETHODS FOR OBTAINING ADVANTAGES AND TRANSACTING THE SAME IN ACOMPUTER GAMING ENVIRONMENT,” issued on July 11, 2006.9. GAMETEK is the present assignee of the entire right, title and interest in and to the‘445 patent, including all rights to sue for past and present infringement. Accordingly, GAMETEKhas standing to bring this lawsuit for infringement of the ‘445 patent.10. The various claims of the ‘445 patent cover, inter alia, a method of managing gamescomprising displaying a plurality of game objects, determining if the user has sufficientconsideration to purchase a game object, presenting an offer to purchase the game object dependentupon parameters comprising the tracked activity of the user and the indication that the user hassufficient consideration, permitting the user to purchase the game object without interrupting thegame, supplying the purchased game object to the user without interrupting the game, andincorporating the game object into the game.11. On information and belief, Defendants have been and now are infringing, including jointly, the ‘445 patent by actions comprising the making and/or using methods of managing a gamecomprising displaying a plurality of game objects, determining if the user has sufficient

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