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Florida Atlantic University Research et. al. v. TPV Technology et. al.

Florida Atlantic University Research et. al. v. TPV Technology et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 9:12-cv-80701-KLR: Florida Atlantic University Research Corporation et. al. v. TPV Technology Limited et. al. Filed in U.S. District Court for the Southern District of Florida, the Hon. Kenneth L. Ryskamp presiding. See http://news.priorsmart.com/-l6jB for more info.
Official Complaint for Patent Infringement in Civil Action No. 9:12-cv-80701-KLR: Florida Atlantic University Research Corporation et. al. v. TPV Technology Limited et. al. Filed in U.S. District Court for the Southern District of Florida, the Hon. Kenneth L. Ryskamp presiding. See http://news.priorsmart.com/-l6jB for more info.

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Published by: PriorSmart on Jun 29, 2012
Copyright:Public Domain

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04/18/2014

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IN THE UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO.FLORTDA ATLANTIC UNIVERSITYRESEARCH CORPORATION ANDDOMAINE ASSOCIATES, LLCPlaintiffs,TPV TECHNOLOGY LIMITED;TOP VICTORY INTERNATIONALLIMITED;TOP VICTORY ELECTRONICS (FUJIAN)CO., LTD;TOP VICTORY ELECTRONICS(TAIWAN) CO., LTD;TPV ELECTRONICS (FUJIAN) CO., LTD;TPV INTERNATIONAL (USA), INCENVISION PERIPHERALS, INC.; ANDAOC INTERNATIONALDefendants. JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENTHUNTON
&
WILLIAMS LLP
11
11
Brickell
Avenue,
Suite
2500Miami, Florida 33 13
1
Telephone: (305) 8 10-2500Facsimile: (305)810-2460
Attorneys for Plaintiffs
 
COMPLAINT
Plaintiffs, Florida Atlantic University Research Corporation ("FAURC") and DomaineAssociates, LLC ("Domaine") (collectively, the "Plaintiffs"), hereby complain and allege againstDefendants TPV Technology Limited ("TPV Technology"), Top Victory International Limited("Top Victory International"), Top Victory Electronics (Fujian) Co.,Ltd. ("Top VictoryFujian"), Top Victory Electronics (Taiwan) Co., Ltd. ("Top Victory Taiwan"), TPV Electronics(Fujian) Co. Ltd. ("TPV Fujian"), TPV International (USA), Inc. ("TPV USA), EnvisionPeripherals, Inc. ("Envision Peripherals"), and AOC International
("AOC")
(collectively referredto as "TPV" and "Defendants") as follows:
I. NATURE OF THE ACTION
1. This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C.
$5
271,
et
seq.,to obtain damages resulting from Defendants'unauthorized manufacture, use, sale, offer to sell and/or importation into the United States forsubsequent use or sale of products, subsystems, components, and/or systems that infringe one ormore claims of United States Patent No. 5,349,385, titled "Adaptive Scan Converter," which listsas the sole inventor Dr. William E. Glenn and issued on September 20, 1994, a true and correctcopy of which is attached hereto as Exhibit
1
(the "'385 Patent").2. This action for patent infringement involves Defendants' manufacture, use, sale,offer for sale, andlor importation into the United States of infringing products, subsystems,components, and systems that operate using video scaling and scan converting technologies.
11. THE PARTIES
3.Plaintiff FAURC is a non-stock, non-profit, direct support organization organizedand existing under the laws of the State of Florida, with its principal place of business located at
 
777 Glades Road, Boca Raton, FL 33431, in the judicial district of the Southern District ofFlorida ("the Southern District of Florida").4.Plaintiff Domaine is a limited liability company organized and existing under thelaws of the State of Delaware, with its principal place of business located at 1750 Tysons Blvd.,Suite 530, McLean, VA 22102.5.Defendant TPV Technology is a Bermuda corporation having its registered officeat Canon's Court, 22 Victoria Street, Hamilton HM 12, Bermuda, and its principal place ofbusiness at Units 1208-16, 12/F, C-Bons International Center, 108 Wai Yip Street, Kwun Tong,Hong Kong. Upon information and belief, TPV Technology regularly conducts business in theState of Florida. TPV Technology makes, uses, sells, offers for sale, exports to and/or importsinto the United States certain products, subsystems, components, and systems that infringe one ormore of the claims of the '385 Patent, including products, subsystems, components and systemsthat are branded "AOC," and, on information and belief, directly and/or indirectly controls theoperations of its subsidiaries, including Defendants Envision Peripherals, TPV USA and/orAOC.
.
6.
Defendant Top Victory International is a British Virgin Islands corporationhaving its principal office at C/O Offshore Incorporations Limited, Offshore IncorporationsCentre, Road Town, British Virgin Islands, and is a subsidiary of TPV Technology. Uponinformation and belief, Top Victory International regularly conducts business in the State ofFlorida. Top Victory International makes, uses, sells, offers for sale, exports to and/or importsinto the United States certain products, subsystems, components, and systems that infringe one ormore of the claims of the '385 Patent, including products, subsystems, components and systemsthat are branded "AOC," and, on information and belief, directly and/or indirectly controls the

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