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Unifi Scientific Batteries v. Sony Mobile Communications AB et. al.

Unifi Scientific Batteries v. Sony Mobile Communications AB et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:12-cv-00224: Unifi Scientific Batteries, LLC v. Sony Mobile Communications AB et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l5Mb for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:12-cv-00224: Unifi Scientific Batteries, LLC v. Sony Mobile Communications AB et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l5Mb for more info.

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Published by: PriorSmart on Mar 30, 2012
Copyright:Public Domain

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02/01/2013

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IN THE UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXASTYLER DIVISIONUNIFI SCIENTIFIC BATTERIES, LLC,
Plaintiff,v.
SONY MOBILE COMMUNICATIONS AB,SONY MOBILE COMMUNICATIONS (USA),INC. andTEXAS INSTRUMENTS, INC.
Defendants.
Case No. 6:12-cv-224PATENT CASEJURY TRIAL DEMANDEDCOMPLAINT
Unifi Scientific Batteries, LLC (“USB”) files this Complaint against Texas Instruments,Inc., Sony Mobile Communications AB and Sony Mobile Communications (USA), Inc.(collectively referred to as “Defendants”) for infringement of United States Patent No. 6,791,298(hereinafter referred to as “the ‘298 patent”).
THE PARTIES
1.
 
USB is a Texas limited liability company with its principal place of business at 3301 West Marshall Avenue, Suite 302, Longview, TX 75604.
TEXAS INSTRUMENTS, INC.
2. Defendant Texas Instruments, Inc. (“Texas Instruments”) is a Delawarecorporation with its principal place of business located at 12500 TI Blvd., Dallas, Texas 75243.This Court has personal jurisdiction over Texas Instruments because Texas Instrument, Inc.resides in Texas, has committed, and continues to commit, acts of infringement in the state of Texas, has conducted business in the state of Texas, and/or has engaged in continuous andsystematic activities in the state of Texas.
 
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SONY
3. Defendant Sony Mobile Communications AB is incorporated under the laws of Sweden with its principal place of business at Nya Vattentornet SE-221, 88 Lund, Sweden. ThisCourt has personal jurisdiction over Sony Mobile Communication AB because Sony MobileCommunications AB has committed, and continues to commit, acts of infringement in the stateof Texas, has conducted business in the state of Texas, and/or has engaged in continuous andsystematic activities in the state of Texas.4. Defendant Sony Mobile Communications (USA), Inc. is a subsidiary of SonyMobile Communications AB and is a Delaware corporation with its principal place of business at7001 Development Drive, Research Triangle, North Carolina 27709. This Court has personal jurisdiction over Sony Mobile Communications (USA), Inc. because Sony MobileCommunications (USA), Inc. has committed, and continues to commit, acts of infringement inthe state of Texas, has conducted business in the state of Texas, and/or has engaged incontinuous and systematic activities in the state of Texas. Defendants Sony MobileCommunications AB and Sony Mobile Communications (USA), Inc. are collectively referred toas “Sony.”
JURISDICTION AND VENUE
 5. This is an action for patent infringement under Title 35 of the United States Code.USB is seeking injunctive relief as well as damages.6. Jurisdiction is proper in this Court pursuant to 28 U.S.C. §§ 1331 (FederalQuestion) and 1338(a) (Patents) because this is a civil action for patent infringement arisingunder the United States’ patent statutes, 35 U.S.C. § 101
et seq
.
 
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7. Venue is proper under 28 U.S.C. §§ 1391(c) and 1400(b) because Defendantshave committed acts of infringement in this district and/or are deemed to reside in this district.8. This Court has personal jurisdiction over Defendants and venue is proper in thisdistrict because Defendants have committed, and continue to commit, acts of infringement in theState of Texas, including in this district and/or have engaged in continuous and systematicactivities in the State Texas, including in this district.
COUNT I(INFRINGEMENT OF U.S. PATENT NO. 6,791,298)
9. USB incorporates paragraphs 1 through 8 herein by reference.10. This cause of action arises under the patent laws of the United States, and inparticular, 35 U.S.C. §§ 271,
et seq.
11. USB is the assignee of the ‘298 patent, entitled “Monolithic Battery ChargingDevice,” with ownership of all substantial rights in the ‘298 patent, including the right to excludeothers and to enforce, sue and recover damages for past and future infringement. A true andcorrect copy of the ‘298 patent is attached as Exhibit A.12. The ‘298 patent is valid, enforceable and was duly issued in full compliance withTitle 35 of the United States Code.13. USB has been damaged as a result of Defendants’ infringing conduct described inthis Count. Defendants are, thus, liable to USB in an amount that adequately compensates it fortheir infringement, which by law, cannot be less than a reasonable royalty, together with interestand costs as fixed by this Court under 35 U.S.C. § 284.
TEXAS INSTRUMENTS (Direct Infringement)
14. On information and belief, Texas Instruments has and continues to directlyinfringe one or more claims of the ‘298 patent in this judicial district and/or elsewhere in Texas

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