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401 B Street. Suite 1200 4 San Dieso. alifomia 92101 (t) 6l g.si.0t0z 5 ( 6le.23r.47ss
LLP
Development, LLC
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SOUTHERN DISTRICT OF CALIFORNIA '13 CV2871 LAB NLS 10 Fourte Desien & Development, LLC, a I Case No. California limited liability comany,' I ^^_ -__ COMPLAINT FOR PATENT 11
Plaintift
INFRINGEMENT
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1.
California limited liability company organized and existing under the laws of the
State of California,
California 94566.
2.
information and belief, a Chinese corporation doing business in the lJnited States,
the State of Califomia and within this judicial district, including without limitation by and through its subsidiary and/or affiliate companies, sales offlrces and research
P:007607894:07580.040
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and development (R&D) centers in San Jose, Califomia, Sunnyvale, California and
a.
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3. 4. 5.
This is a civil action for patent infringement arising under the patent
l, et seq.
This Court has personal jurisdiction over Defendant and venue in this
district and/or Defendant has placed infringing products into the stream of
commerce by sellingandlor offering to sell products into the United States and this
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judicial district with knowledge that such products would be shipped into and/or
used in the United States and this judicial district.
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At all times relevant to this action, Plaintiff is and has been the owner,
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24 infringing the '010 Patent pursuant to 35 U.S.C. section 271(a) in the State
of
25 California, this judicial district and elsewhere in the United States by designing, 26 making, manufacturing, operating, using, offering for sale, andlor selling within the 27 United States and/or importing into the United States, one or more devices (the 28 "Infringing Devices") that are covered by the inventions claimed in the '010 Patent.
P:007607894:075 80.040
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10. 11.
) product
infringing the '010 Patent pursuant to 35 U.S.C. section 271(b) and/or (c) by
intentionally inducing infringement and/or contributing to the infringement of the '010 Patent in the State of California, this judicial district and elsewhere in the
7 United States by providing and/or selling the Infringing Devices to customers and/or
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the '010 Patent. Because of its infringing acts and for its unauthorized use of the inventions claimed in the '010 Patent, Defendant is liable to Plaintiff for damages in
an amount no less fhan a reasonable royalty.
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will
has no adequate
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1. 3.
2t Patent;
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23 employees, attorneys and all others in active concert or participation with them from 24 further infringement of Plaintiffls patent rights; 25
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Awarding Plaintiff such other and fuither relief as this Court deems just
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and equitable.
Bv: /s/TANYA M.
SCHItrRT.TNG tschierl in sl.swss I aw. com Attorneys for Plaintiff Fourte Design Develoment. LLC
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P:007607894:07580.040
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