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Advanced Printing Solutions v. Zebra Technologies

Advanced Printing Solutions v. Zebra Technologies

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-03544: Advanced Printing Solutions LLC v. Zebra Technologies Corporation. Filed in U.S. District Court for the Northern District of Illinois, the Hon. Rebecca R. Pallmeyer presiding. See http://news.priorsmart.com/-l5Zr for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-03544: Advanced Printing Solutions LLC v. Zebra Technologies Corporation. Filed in U.S. District Court for the Northern District of Illinois, the Hon. Rebecca R. Pallmeyer presiding. See http://news.priorsmart.com/-l5Zr for more info.

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Published by: PriorSmart on May 09, 2012
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02/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONADVANCED PRINTING SOLUTIONSLLC,
Plaintiff,
v.ZEBRA TECHNOLOGIESCORPORATION,
Defendant.Civil Action No. 1:12-cv-3544
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Advanced Printing Solutions LLC files this Complaint against ZebraTechnologies Corporation (“Defendant”) for infringement of U.S. Patent No. RE38111 (“the’111 patent”).
THE PARTIES
1.
 
Advanced Printing Solutions LLC (“APS”) is a limited liability companyorganized and existing under the laws of the State of Texas, with a principal place of businesslocated in Frisco, Texas.2.
 
Zebra Technologies Corporation (“Zebra”) is a Delaware corporation with aprincipal place of business in this Division of the Northern District of Illinois, at 475 Half DayRoad, Suite 500, Lincolnshire, Illinois. This Defendant may be served with process through itsregistered agents, C T Corporation System, 208 South LaSalle Street, Suite 814, Chicago, Illinois60604.
 
2
JURISDICTION AND VENUE
3.
 
APS brings this action for patent infringement under the patent laws of the UnitedStates, namely 35 U.S.C. §§ 271, 281, and 284-285, among others.4.
 
This Court has subject matter jurisdiction over the claims in this action pursuantto 28 U.S.C. §§ 1331, 1338(a), and 1367.5.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 (b), 1391(c)and 1400(b). Defendant resides in this judicial district, has committed acts of infringement inthis judicial district, has purposely transacted business in this judicial district, and/or has regularand established places of business in this judicial district.6.
 
Defendant is subject to this Court’s specific and general personal jurisdictionpursuant to due process and due at least to its substantial business in this State and judicialdistrict, including: (A) at least part of its infringing activities alleged herein; and (B) regularlydoing or soliciting business and, accordingly, deriving substantial revenue from goods andservices provided to Illinois residents.
PATENT INFRINGEMENT
7.
 
APS incorporates paragraphs 1 through 6 herein by reference.8.
 
APS is the assignee of the ’111 patent, entitled “Printer with Internal DocumentData Construction,” with ownership of all substantial rights in the ’111 patent, including the rightexclude others and to enforce, sue and recover damages for past and future infringement. A trueand correct copy of the ’111 patent is attached as Exhibit A.9.
 
The ’111 patent is valid, enforceable, and was duly issued in full compliance withTitle 35 of the United States Code.
 
310.
 
Defendant has infringed and continue to directly infringe one or more claims of the ’111 patent in this judicial district and elsewhere in Illinois and the United States by orthrough the testing, making, using, offering for sale, selling, and/or importing of certain printingdevices, a list of which is attached as Exhibit B. Defendant has been, and now is, directlyinfringing claims of the ’111 patent, including (for example, and without limitation) at leastclaims 17 and 18 of the ’111 patent, by or through the testing, making, using, offering for sale,selling, and/or importing of printing devices that are sold with,
inter alia
, an internal printercontroller, an external data stream input port operative to receive an external data streamincluding automatic document selection data, a document construction module in communicationwith the internal printer controller, and a document data printing mechanism that printsdocument data in a designated document format.11.
 
APS has been damaged as a result of Defendant’s infringing conduct describedherein. Defendant is, thus, liable to APS in an amount that adequately compensates it forDefendants’ infringements, which, by law, cannot be less than a reasonable royalty, togetherwith interest and costs as fixed by this Court under 35 U.S.C. § 284.
JURY DEMAND
APS hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of CivilProcedure.
PRAYER FOR RELIEF
APS requests that the Court find in its favor and against Defendant, and that the Courtgrant APS the following relief:a. Judgment that one or more claims of the ’111 Patent have been infringed, eitherliterally and/or under the doctrine of equivalents, by Defendant;

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