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Joao Control and Monitoring Systems v. Xanboo

Joao Control and Monitoring Systems v. Xanboo

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-03698-ABC-CW: Joao Control and Monitoring Systems LLC v. Xanboo Inc. Filed in U.S. District Court for the Central District of California, the Hon. Audrey B. Collins presiding. See http://news.priorsmart.com/-l5X8 for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-03698-ABC-CW: Joao Control and Monitoring Systems LLC v. Xanboo Inc. Filed in U.S. District Court for the Central District of California, the Hon. Audrey B. Collins presiding. See http://news.priorsmart.com/-l5X8 for more info.

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Published by: PriorSmart on May 02, 2012
Copyright:Public Domain

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02/01/2013

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Page 2COMPLAINT FOR PATENT INFRINGEMENT
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Plaintiff Joao Control & Monitoring Systems, LLC (“Plaintiff”), by andthrough its undersigned counsel, files this Complaint against Xanboo, Inc.(“Defendant” or “Xanboo”).
NATURE OF THE ACTION
1. This is a patent infringement action to stop Defendant’s infringement of Plaintiff’s United States Patent No. 7,277,010 entitled “Monitoring Apparatus andMethod” (hereinafter, “the ‘010 patent,” a copy of which is attached hereto asExhibit A), United States Patent No. 6,542,076 entitled “
Control, Monitoring and/or Security Apparatus
” (the “
076 patent”; a copy of which is attached hereto asExhibit B), United States Patent No. 6,542,077 entitled “Monitoring Apparatus for aVehicle and/or Premises” (the “‘077 patent”; a copy of which is attached hereto asExhibit C), and United States Patent No. 7,397,363 entitled “
Control and/or  Monitoring Apparatus and Method 
” (the “
363 patent”; a copy of which is attachedhereto as Exhibit D) (collectively referred to herein as the “patents-in-suit”).Plaintiff is the owner of the patents-in-suit and seeks injunctive relief and monetarydamages.
PARTIES
 2. Plaintiff is a limited liability company organized under the laws of theState of Delaware. Plaintiff maintains its principal place of business at 122 BellevuePlace, Yonkers, New York 10703. Plaintiff is the legal owner of the ’010 patent, the‘076 patent, the ‘077 patent and the ‘363 patent, which includes the right to exclude
 
 
Page 3COMPLAINT FOR PATENT INFRINGEMENT
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the Defendant from making, using, selling, offering to sell or importing in thisdistrict and elsewhere into the United States the patented invention(s) of the patents-in-suit, and the right to sublicense the patents-in-suit, collect damages, and sue for infringement and recover past damages from the Defendant.3. Upon information and belief, Defendant Xanboo is a corporationorganized and existing under the laws of the State of Delaware, with its principal place of business located at 286 Fifth Avenue, 4th Floor, New York, New York 10001.
JURISDICTION AND VENUE
 4. This action arises under the Patent Laws of the United States, 35 U.S.C.§ 1
et seq.
, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court hassubject matter jurisdiction over this case for patent infringement under 28 U.S.C. §§1331 and 1338(a).5. The Court has personal jurisdiction over Defendant because:Defendant is present within or has minimum contacts with the State of Californiaand the Central District of California; Defendant has purposefully availed itself of the privileges of conducting business in the State of California and in the CentralDistrict of California; Defendant has sought protection and benefit from the laws of the State of California; Defendant regularly conducts business within the State of California and within the Central District of California; and Plaintiff’s causes of 

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