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Graphics Properties Holdings v. LG Electronics et. al.

Graphics Properties Holdings v. LG Electronics et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-00389-UNA: Graphics Properties Holdings Inc. v. LG Electronics Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l5Kp for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-00389-UNA: Graphics Properties Holdings Inc. v. LG Electronics Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l5Kp for more info.

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Published by: PriorSmart on Mar 27, 2012
Copyright:Public Domain

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02/01/2013

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#15727722 v1
 
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
GRAPHICS PROPERTIES HOLDINGS, INC., ))) CIVIL ACTION NO.Plaintiff, ))v. ))LG ELECTRONICS INC.;LG ELECTRONICS USA, INC.;LG ELECTRONICS MOBILECOMM U.S.A.,INC.,)))JURY TRIAL DEMANDED)Defendants. )
COMPLAINT FOR PATENT INFRINGEMENT
1.
 
Plaintiff Graphics Properties Holdings, Inc. (“GPH” or “Plaintiff”), by andthrough its attorneys, hereby demands a jury trial and complains of Defendants LGElectronics Inc.; LG Electronics U.S.A., Inc.; LG Electronics MobileComm U.S.A., Inc.(collectively “Defendants” or “LG”) as follows:
NATURE OF THE ACTION
2.
 
This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. §§ 271,
et seq.,
to enjoin infringement and obtain damages resultingfrom Defendants’ unauthorized manufacture, use, sale, offer to sell and/or importation intothe 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. 8,144,158 (the “’158Patent”) entitled “Display System Having Floating Point Rasterization and Floating PointFramebuffering.” The claims and specification, as issued, as well as the United States PatentOffice Issue Notification, are attached as Exhibit A. Plaintiff seeks injunctive relief to
 
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#15727722 v1
 prevent Defendants from infringing the ‘158 Patent. In addition, Plaintiff seeks a recovery of monetary damages resulting from Defendants’ infringement of the ‘158 Patent.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 use inconsumer electronics devices, including but not limited to Defendants’ mobile phones.
THE PARTIES
 4.
 
Plaintiff GPH is a Delaware corporation with its principal place of business at56 Harrison Street, Suite 505, New Rochelle, New York 10801.5.
 
Plaintiff GPH is the lawful assignee of all right, title and interest in and to the’158 Patent.6.
 
GPH was formerly named Silicon Graphics, Inc. (“Silicon Graphics”). AsSilicon Graphics, GPH developed technology and intellectual property used in the graphics,computer processing, and display segments. Since the bankruptcy of Silicon Graphics, GPHhas been owned by private investment funds and other institutional investors.7.
 
GPH continues to manage and license its intellectual property, including thethe ’158 Patent.8.
 
Respondent LG Electronics, Inc. is located at LG Twin Towers, 20 Yeouido-dong, Yeongdeungpo-gu Seoul 150-721, South Korea.9.
 
LG Electronics, Inc. is in the business of developing, manufacturing, andselling consumer electronics and display devices and products containing same. Suchdevices include, but are not limited to, mobile phones, handheld computers, and other consumer electronics and display devices and products containing the same including, but
 
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not limited LG’s Thrill device, and other substantially similar devices.10.
 
On information and belief, LG Electronics, Inc. maintains operations in manycountries throughout the world, with production locations in many of those countries. LGElectronics, Inc. is the parent corporation of respondents LG Electronics U.S.A., Inc. and LGElectronics MobileComm U.S.A., Inc.11.
 
Respondent LG Electronics U.S.A., Inc. is a wholly-owned subsidiary of respondent LG Electronics, Inc.12.
 
LG Electronics U.S.A., Inc. is located at 1000 Sylvan Ave., Englewood Cliffs, NJ 07632.13.
 
On information and belief, Respondent LG Electronics U.S.A., Inc. managesthe North American operations of Respondent LG Electronics MobileComm U.S.A., Inc.,and the two entities provide sales and marketing support in North America for their ultimate parent, LG Electronics, Inc. concerning mobile phones, handheld computers, televisions andother consumer electronics and display devices including, but not limited LG’s Thrill device,and other substantially similar devices.14.
 
Respondent LG Electronics MobileComm U.S.A., Inc. is a wholly-ownedsubsidiary of respondent LG Electronics U.S.A., Inc.15.
 
LG Electronics MobileComm U.S.A., Inc. is located at 10101 Old GroveRoad, San Diego, CA 92131, and is managed by its parent LG Electronics U.S.A., Inc.16.
 
On information and belief, respondent LG Electronics MobileComm U.S.A.,Inc. provides a variety of devices, including mobile phones, handheld computers, televisionsand other consumer electronics and display devices including, but not limited LG’s Thrilldevice, and other substantially similar devices. LG Electronics MobileComm U.S.A., Inc.

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