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UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF NEW YORK
)
ANDREA ELECTRONICS )
CORPORATION, )
) Civil Action No. ___________
Plaintiff, )
) COMPLAINT
v. )
) JURY TRIAL DEMANDED
)
TOSHIBA CORPORATION, )
TOSHIBA AMERICA, INC., and )
TOSHIBA AMERICA INFORMATION )
SYSTEMS, INC., )
)
Defendants )
)
____________________________________ )

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Andrea Electronics Corporation (Andrea), by and through its counsel,
Pepper Hamilton LLP, for its Complaint against defendants Toshiba Corporation, Toshiba
America, Inc. and Toshiba America Information Systems, Inc. (collectively, Toshiba or
Defendants) alleges as follows:
NATURE OF ACTION
1. This is an action for patent infringement under the patent laws of the
United States, 35 U.S.C. 271, et seq., to enjoin infringement and obtain damages resulting
from Defendants unauthorized and ongoing actions, in the state of New York and elsewhere,
of making, having made, using, selling, having sold, offering to sell, and/or importing or
having imported into the United States, certain personal computer products that infringe one
or more claims in U.S. Patent No. 5,825,898 (the 898 Patent), U.S. Patent No. 6,049,607
2:14-cv-4492