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1 MARTIN L. FINEMAN (CA State BarNo. 104413) DAVIS WRIGHT TREMAINE LLP 2 505 Montgomery Street, Suite 800 San Francisco, California 94111 3 Telephone: (415) 276-6500 Facsimile: (415) 276-6599 4 Email: martinfineman@dwt.com 5

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NIRO, HALLER & NIRO Raymond P. Niro (Member of the N.D. Cal. Bar) Joseph N. Hosteny (Pro Hac Vice Application forthcoming) Arthur A. Gasey (Pro Hac Vice Application forthcoming) 181 West Madison, Suite 4600 Chicago, IL 60602-4515 Phone: (312) 236-0733 Fax: (312) 236-3137 E-mail: miro@nshn.com jhosteny@nshn.com gasey@nnshn.com Attorneys for Plaintiff TECHNOLOGY LICENSING CORPORATION

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IN THE UNITED STATES DISTRICT COU T THE NORTHERN DISTRICT OF CALIFO SAN FRANCISCO DIVISION TECHNOLOGY LICENSING CORPORATION, Plaintiff,
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COMPLAINTF RPATENT INFRINGEMEN AND DEMAND FOR JURY TRIAL

6060

v.
GRASS VALLEY USA, LLC., Defendant.

COMPLAINT FOR PATENT INFRINGEME T

In this action for patent infringement, Plaintiff Technology Lice sing Corporation ("TLC") complains ofDefendant Grass Valley USA, LLC ("Grass Valley") as fol ows:

COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL TECHNOLOGY LICENSING CORPORATJONv GRASS VALLEY USA, LLC DWT 2070622lvl 0085000-000149

JURISDICTION AND VENUE

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I.

This is a claim for patent infringement arising under t e patent laws of the United

States, Title 35 ofthe United States Code 1, et seq. This Court has exclusive original

4 jurisdiction over the subject matter of this Complaint under 28 U.S.C. 1331 and 1338(a).
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Venue is proper under 28 U.S.C. 1391 and 1400(b) ecause the Defendant is

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subject to personal jurisdiction here, does business in this judicial dis ict, and has committed acts of infringement in this judicial district.

PARTIES

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3.

TLC is a Nevada corporation and has its principal plac of business at 711 South

Carson Street, Suite 6, Carson City, Nevada, 8970 I. TLC is the assig ee of all substantive rights in, and has standing to sue for infringement ofUnited States Patent No . RE 40,411, "Synchronizing Signal Separating Apparatus and Method," andRE 40 412, "Synchronizing Signal Separating Apparatus and Method." The patents are referred to below patents, respectively.
4.

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the '411 and '412

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Grass Valley is a limited liability corporation with head uarters at 475 Brannan

Street, San Francisco, California. Grass Valley makes and sells product used in, for example, recording and editing video. 5. Grass Valley sells products that are covered by at least c aims 1-8, 22 and 38 ofthe

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'411 patent, including at least the T2 iDDR Intelligent Digital Disk Rec rder and any product using the National Semiconductor LMH1981 Multi-Format Video Sync Separator. Additional products may be identified pursuant to discovery.

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6.

Grass Valley sells products that are covered by at least cl ims 1-4, 6, 10, 11,21-34, igital Disk Recorder and

and 39-41 of the '412 patent, including at least the T2 iDDR Intelligent

any product using the National Semiconductor LMH1981 Multi-Format Video Sync Separator.

PATENT INFRINGEMENT
7. TLC owns all right, title, and interest in and has standing o sue for damages for

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any past, present and future infringement of the '411 patent and the '412 patent.

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COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL TECHNOLOGY LICENSING CORPORATION v GRASS VALLEY USA, LLC DWT 2070622 I vI 0085000-000149

8.

Upon information and belief, Grass Valley has made, sed, offered for sale, sold,

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and/or imported products including those described in paragraph 5 a ave. These acts by Grass Valley have directly infringed at least claims 1-8,22 and 38 ofthe '4 1 patent within the meaning of35 U.S.C. 271(b). Grass Valley has induced infringement of the s me claims within the meaning of35 U.S.C. 27l(b). 9. Upon information and belief, Grass Valley has made, sed, offered for sale, sold,

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and/or imported products including those described in paragraph 6 ab ve. These acts by Grass Valley have directly infringed at least claims 1-4, 6, 10, 11,21-34, an 39-41 of the '412 patent within the meaning of35 U.S.C. 271(b). Grass Valley has induced i fringement of the same claims within the meaning of35 U.S.C. 27l(b).
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Grass Valley's infringement ofthe '411 and '412 patent has injured TLC, and TLC

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is entitled to recover damages adequate to compensate it for such infri gement, but in no event less than a reasonable royalty. 11. Grass Valley has been given notice of infringement of e ch of the patents. Its acts

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of infringement have nevertheless continued since notice was given. T e infringement is therefore willful.

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PRAYER FOR RELIEF

WHEREFORE, TLC respectfully requests this Court en r judgment against the

Defendant, and against its subsidiaries, successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation w th them, as follows:
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The entry of final judgment in favor ofTLC; An award to TLC of such damages as it shall prove at tri 1 against Defendant Grass

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Valley that is adequate to compensate for its infringement of the '4 1 and '412 patents, said 24 25 26 27 28 damages to be no less than a reasonable royalty, together with prejudg ent interest from the date infringement of each of the patents began;

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A determination that this case is exceptional pursuant t 35 U.S.C. 285 and an

award to TLC of the costs ofthis action and its reasonable attorneys' fee ; and
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COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL TECHNOLOGY LICENSING CORPORATION v GRASS VALLEY USA, LLC DWT 2070622lvl 0085000-000149

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Such other relief as TLC is entitled to recover under ny applicable law and as this

Court or ajury may determine to be proper and just. Dated: November 29, 2012. NIRO HALLER & NIR AINELLP

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By:

Attorneys for Plaintiff TECHNOLOGY LICEN ING CORPORATION

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COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL TECHNOLOGY LICENSING CORPORAT!ONv GRASS VALLEY USA. LLC DWT 2070622lvl 0085000-000149

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DEMAND FOR JURY TRIAL Plaintiff Technology Licensing Corporation hereby demands triable to a jury in this case. Dated: November 29, 2012. NIRO HALLER & NIR AINELLP trial by jury on all issues

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By:

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Attorneys for Plaintiff TECHNOLOGY LICEN lNG CORPORATION

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COMPLAINT FOR PATENT INFRINGEMENT AND DEMAND FOR JURY TRIAL TECHNOLOGY LICENSING CORPORATIONv GRASS VALLEY USA, LLC DWT 20706221 vi 0085000-000149

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