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American Vehicular Sciences v. Toyota Motor et. al.

American Vehicular Sciences v. Toyota Motor et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:12-cv-00405: American Vehicular Sciences LLC v. Toyota Motor Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6ih for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:12-cv-00405: American Vehicular Sciences LLC v. Toyota Motor Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6ih for more info.

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Published by: PriorSmart on Jun 27, 2012
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07/25/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASTYLER DIVISIONAMERICAN VEHICULAR SCIENCESLLCPlaintiff,v.TOYOTA MOTOR CORPORATION,TOYOTA MOTOR SALES, U.S.A., INC.SOUTHEAST TOYOTADISTRIBUTORS, LLC, AND GULFSTATES TOYOTA, INC.Defendants.§§§§§§§§§§§§§§§§§§§§Civil Action No. _________JURY TRIAL
 
PLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff American Vehicular Sciences LLC (“AVS”) files this Original Complaint forpatent infringement against Defendants Toyota Motor Corporation, Toyota Motor Sales, U.S.A.,Inc., Southeast Toyota Distributors, LLC, and Gulf States Toyota, Inc. (collectively “Toyota”).
 
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PARTIES
1.
 
Plaintiff AVS is a limited liability company existing under the laws of Texas withits principal place of business at 6136 Frisco Square Blvd., Suite 385, Frisco, Texas 75034.2.
 
Defendant Toyota Motor Corporation is a corporation existing under the laws of Japan with its principal place of business at 1 Toyota-cha, Toyota City, Aichi Prefecture 471-8571, Japan.3.
 
Defendant Toyota Motor Sales U.S.A., Inc. is a California corporation with itsprincipal place of business at 19001 S. Western Avenue, Torrance, CA 90501.4.
 
Defendant Southeast Toyota Distributors, LLC is a Delaware limited liabilitycompany with its principal place of business at 500 Jim Moran Boulevard, Deerfield Beach,Florida 33442.5.
 
Defendant Gulf States Toyota, Inc. is a Texas corporation with its principal placeof business at 1375 Enclave Parkway, Houston, Texas 77077.
 
JURISDICTION AND VENUE
6.
 
This is an action for patent infringement under the Patent Laws of the UnitedStates, 35 U.S.C. § 271.7.
 
This court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338(a).8.
 
Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and 1400 (b).
SUMMARY
9.
 
Dr. David Breed is one of the leading inventors in the field of automotivetechnology in the world today.
 
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10.
 
Dr. Breed is an inventor on more than 300 United States patents relating toautomotive technologies, including airbags, navigation systems, vehicle diagnostics, crashsensors, vehicle communications, systems monitoring, theft protection, and collision avoidance.11.
 
Dr. Breed has a Ph.D in Mechanical Engineering from Columbia University aswell as Bachelors’ and Masters’ degrees from the Massachusetts Institute of Technology.12.
 
Dr. Breed has received the National Highway Traffic Safety Administration'sAward for Safety Engineering and the prestigious H.H. Bliss award for his contributions to thedevelopment of the airbag.13.
 
Dr. Breed is a member of the Tau Beta Pi and Pi Tau Sigma engineering honorssocieties and has published numerous peer-reviewed articles.
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,738,697
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AVS incorporates the foregoing paragraphs as if fully set forth here.15.
 
On May 18, 2004, the USPTO duly and legally issued United States Patent No.6,738,697 B2 (“the ‘697 Patent”), entitled “Telematics System For Vehicle Diagnostics.” AVSowns the ‘697 Patent and holds the right to sue and recover damages for infringement thereof. Atrue and correct copy of the ‘697 Patent is attached as Exhibit A.16.
 
On information and belief, Toyota has been and now is directly infringing, and/orinducing infringement by others, and/or contributing to the infringement by others of the ‘697Patent in the state of Texas, in this judicial district, and elsewhere within the United States by,among other things, making, using, offering for sale, selling, or importing vehicles, including butnot limited to various model years of IS, ES, GS, LS, IS C, RX, GX, LX, IS F, LF A, CTh, RXh,GSh, LSh, and HS product, that include vehicle diagnostic systems, including but not limited tothe Lexus Enform system and other similar systems, that infringe or the use of which infringe

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