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Anu Ip v. General Imaging Company

Anu Ip v. General Imaging Company

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00226: Anu Ip, LLC v. General Imaging Company. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l5Us for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00226: Anu Ip, LLC v. General Imaging Company. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l5Us for more info.

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Published by: PriorSmart on Apr 18, 2012
Copyright:Public Domain

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02/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONANU IP, LLC §Plaintiff, §§ CIVIL ACTION NO. _________ v. §§§GENERAL IMAGING COMPANY §Defendant § JURY TRIAL DEMANDEDPLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff Anu IP LLC respectfully files this Original Complaint for patent infringementagainst Defendant General Imaging Company.
PARTIES
1.
 
Plaintiff Anu IP LLC (“Anu”) is a limited liability company organized under thelaws of the State of Texas, with its principal place of business at 3301 W. Marshall Ave., Suite303, Longview, Texas 75601.2.
 
Defendant General Imaging Company (“GIC”) is a company organized under thelaw of Delaware with a principal place of business at 2411 W. 190
th
Street #550, TorranceCalifornia, 90504.3.
 
Defendant may be served with process through its registered agent, DelawareCorporate Services Inc., 901 North Market Street, Suite 705, Wilmington, DE 19801.
JURISDICTION AND VENUE
4.
 
This is an action for patent infringement under the Patent Laws of the UnitedStates, 35 U.S.C. § 271,
et seq
.5.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
 
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6.
 
Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and 1400(b).
 FACTS
7.
 
Plaintiff is a Marshall, Texas-based company that owns U.S. Patent Nos.6,979,210 (“the ’210 patent”) and 7,090,515 (“the ’515 patent”). The ‘210 and ‘515 patents are attached as
 Exhibits A and B.
 8.
 
The ‘210 and ‘515 patents relate to memory storage devices that containretractable USB (universal serial bus) connectors. The ‘210 and ‘515 patents are validand enforceable.9.
 
Defendant manufactures, imports, sells, and offers for sale products that infringethe ‘210 and ‘515 patents, including but not limited to the Create camcorder/camera andthe DV1 HD Video Camera.10.
 
Defendant has engaged in acts of direct infringement in this judicial district.
CAUSE OF ACTION
 
A. Infringement of the ‘210 Patent
11.
 
Plaintiff incorporates the foregoing paragraphs as if fully set forth here.12.
 
Defendant has been, and is now, directly infringing the ‘210 patent in the State of Texas,in this judicial district, and elsewhere within the United States by, among other things,selling, offering for sale, or importing products and services covered by one or moreclaims of the ‘210 patent, all to the injury of Plaintiff.13.
 
Defendant’s acts of infringement have been willful, deliberate, and in reckless disregardof Plaintiff’s patent rights, and will continue unless permanently enjoined by this Court.
 
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14.
 
Plaintiff has been damaged by Defendant’s infringement of the ‘210 patent in an amountto be determined at trial, and has suffered and will continue to suffer irreparable loss andinjury unless Defendant is permanently enjoined from infringing the ‘210 patent.
B. Infringement of the ‘515 Patent
 15.
 
Plaintiff incorporates the foregoing paragraphs as if fully set forth here.16.
 
Defendant has been, and is now, directly infringing and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘515 patent in theState of Texas, in this judicial district, and elsewhere within the United States by, amongother things, selling, offering for sale, or importing products and services covered by oneor more claims of the ‘515 patent, all to the injury of Plaintiff.17.
 
Defendant’s acts of infringement have been willful, deliberate, and in reckless disregardof Plaintiff’s patent rights, and will continue unless permanently enjoined by this Court.18.
 
Plaintiff has been damaged by Defendant’s infringement of the ‘515 patent in an amountto be determined at trial, and has suffered and will continue to suffer irreparable loss andinjury unless Aluratek is permanently enjoined from infringing the ‘515 patent.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Anu IP LLC respectfully prays for the following relief againstDefendant General Imaging Company.A. A judgment in favor of Plaintiff that Defendant has infringed the ‘210 and ‘515 patents;B. A permanent injunction, enjoining Defendant, along with its officers, directors,agents, servants, employees, affiliates, divisions, branches, subsidiaries, and parents from

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