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IN THE UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXASTYLER DIVISIONUNIFI SCIENTIFIC BATTERIES, LLC,
Plaintiff,v.
RESEARCH IN MOTION CORPORATION,RESEARCH IN MOTION, LTD.,SAMSUNG ELECTRONICS CO., LTD.,SAMSUNG ELECTRONICS AMERICA, INC.,SAMSUNG TELECOMMUNICATIONSAMERICA, LLC,AMAZON.COM, INC.,AMAZON TECHNOLOGIES, INC.,BARNESANDNOBLE.COM, LLC,BARNES & NOBLE, INC. andTEXAS INSTRUMENTS, INC.
Defendants.
Case No. 6:12-cv-223PATENT CASEJURY TRIAL DEMANDEDCOMPLAINT
Unifi Scientific Batteries, LLC (“USB”) files this Complaint against Texas Instruments,Inc., Research in Motion Corporation, Research In Motion, Ltd., Samsung Electronics Co., Ltd.,Samsung Electronics America, Inc., Samsung Telecommunications America, LLC,Amazon.com, Inc., Amazon Technologies, Inc., Barnes & Noble, Inc., and Barnesandnoble.com,LLC (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.
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TEXAS INSTRUMENTS, INC.
2. Defendant Texas Instruments, Inc. is a Delaware corporation with its principal place of business located at 12500 TI Blvd., Dallas, Texas 75243. This Court has personal jurisdiction over Texas Instruments, Inc. because Texas Instruments, Inc. resides in Texas andhas committed, and continues to commit, acts of infringement in the state of Texas, hasconducted business in the state of Texas, and/or has engaged in continuous and systematicactivities in the state of Texas.
RESEARCH IN MOTION
3. Defendant Research in Motion, Ltd. is a Canadian corporation with its principal place of business located at 295 Phillip Street, Waterloo, Ontario. This Court has personal jurisdiction over Research in Motion, Ltd. because Research in Motion, Ltd. has committed, andcontinues to commit, acts of infringement in the state of Texas, has conducted business in thestate of Texas, and/or has engaged in continuous and systematic activities in the state of Texas.4. Defendant Research in Motion Corporation is a Delaware corporation with its principal place of business located at 122 West John Carpenter Freeway, Suite 430, Irving,Texas. This Court has personal jurisdiction over Research in Motion Corporation becauseResearch in Motion Corporation has committed, and continues to commit, acts of infringementin the 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 Research in MotionCorporation and Research in Motion, Ltd. are collectively referred to as “RIM.”
SAMSUNG
5. Defendant Samsung Electronics Co., Ltd. is a Korean corporation with a principal place of business at Samsung Main Building, 250 2-ka, Taepyuung-Ro, Chung-Ku, Seoul,
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Korea. This Court has personal jurisdiction over Samsung Electronics Co., Ltd. becauseSamsung Electronics Co., Ltd. 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.6. Defendant Samsung Electronics America, Inc. is a New York corporation with its principal place of business located at 105 Challenger Road, Ridgefield Park, New Jersey 07660.This Court has personal jurisdiction over Samsung Electronics America, Inc. because SamsungElectronics America, Inc. has committed, and continues to commit, acts of infringement in thestate of Texas, has conducted business in the state of Texas, and/or has engaged in continuousand systematic activities in the state of Texas.7. Defendant Samsung Telecommunications America, LLC is a Delawarecorporation with its principal place of business located at 1130 Arapaho Rd., Richardson, Texas75081. This Court has personal jurisdiction over Samsung Telecommunications America, LLC because Samsung Telecommunications America, LLC 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 and systematic activities in the state of Texas. Defendants SamsungElectronics Co., Ltd., Samsung Electronics America, Inc. and Samsung TelecommunicationsAmerica, LLC are collectively referred to as “Samsung.”
AMAZON
8. Defendant Amazon.com, Inc. is a Delaware corporation with its principal place of business located at 410 Terry Avenue North, Seattle, Washington. This Court has personal jurisdiction over Amazon.com, Inc. because Amazon.com, Inc. has committed, and continues to
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