UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

AMOUNT, INC., Civil Action No. ________________ Plaintiff, v. AMAZON.COM, INC., Defendant. ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED

Plaintiff Amount, Inc. (hereinafter, Plaintiff or Amount), by and through its undersigned counsel, files this Original Complaint for Patent Infringement against Defendant Amazon.com, Inc. (Defendant or Amazon) as follows: NATURE OF THE ACTION 1. This is a patent infringement action to stop Defendants infringement of

Plaintiffs United States Patent No. 8,186,639 entitled Bracket For Tablet Electronic Device (hereinafter, the 639 Patent or the Patent-in-Suit). A copy of the Patent-in-Suit is attached hereto as Exhibit A. Plaintiff is the owner of the Patent-in-Suit and seeks injunctive relief and monetary damages. PARTIES 2. Amount is a corporation organized under the laws of Taiwan, and maintains its

principal place of business at No. 65, Dongxing St., Shulin Dist., New Taipei City, Taiwan 23850. Plaintiff is the owner of the Patent-in-Suit, and possesses all rights thereto, including the

exclusive right to exclude the Defendant from making, using, selling, offering to sell or importing in this district and elsewhere into the United States the patented invention(s) of the Patent-in-Suit, the right to sublicense the Patent-in-Suit, and to sue the Defendant for infringement and recover past damages. See Exhibit B. 3. Upon information and belief, Defendant is a corporation duly organized and

existing under the laws of the State of Delaware and having its principal place of business located at 410 Terry Avenue North, Seattle (King County), Washington, 98109. Upon

information and belief, Defendant is registered with the Office of the Secretary of State for the State of Washington since at least June 18, 1996 as having been incorporated in the State of Delaware. Defendant may be served through its registered agent, Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware, 19808. JURISDICTION AND VENUE 4. This action arises under the Patent Laws of the United States, 35 U.S.C. 1 et

seq., including 35 U.S.C. 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction over this case for patent infringement under 28 U.S.C. 1331 and 1338(a). 5. The Court has personal jurisdiction over Defendant because: Defendant has

minimum contacts within the State of Delaware and in the District of Delaware; Defendant has purposefully availed itself of the privileges of conducting business in the State of Delaware and in the District of Delaware; Defendant has sought protection and benefit from the laws of the State of Delaware; Defendant regularly conducts business within the State of Delaware and within the District of Delaware, and Plaintiffs causes of action arise directly from Defendants business contacts and other activities in the State of Delaware and in the District of Delaware.

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6.

More specifically, Defendant, directly and/or through its intermediaries, ships,

distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web page) its products and services in the United States, the State of Delaware, and the District of Delaware. Upon information and belief, Defendant has committed patent infringement in the State of Delaware and in the District of Delaware. Defendant solicits customers in the State of Delaware and in the District of Delaware. Defendant has many paying customers who are residents of the State of Delaware and the District of Delaware and who use Defendants products and services in the State of Delaware and in the District of Delaware. 7. 1400(b). COUNT I: INFRINGEMENT OF U.S. PATENT NO. 8,186,639 8. 9. Plaintiff re-alleges and incorporates by reference each of Paragraph 1-7 above. The 639 Patent was duly and legally issued by the United States Patent and Venue is proper in the District of Delaware pursuant to 28 U.S.C. 1391 and

Trademark Office on May 29, 2012 after full and fair examination. Plaintiff is the owner of the 639 Patent, and possesses all right, title and interest in the 639 Patent including the right to enforce the 639 Patent, and the right to sue Defendant for infringement and recover past damages. 10. On information and belief, Defendant controls the website, www.amazon.com,

(hereinafter, Defendants website) through which Defendant advertises, sells, offers to sell, and/or instructs customers how to use its products and services. 11. Plaintiff is informed and believes that Defendant infringes the 639 Patent, either

literally or under the doctrine of equivalents. Upon information and belief, Defendant has infringed and continues to infringe one or more claims of the 639 Patent by making, using,
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selling, offering to sell, and providing a portable, foldable bracket for holding a portable electronic device. 12. Defendant offers for sale on Defendants website the AmazonBasics Portable

Fold-Up Travel Stand for the iPad 4, iPad 2, Samsung Galaxy Tab 10.1 and 7.0, Kindle Fire, Kindle Fire HD, Kindle Touch (Model No. IPM-TAB1-AMZ; ASIN B006ZT4VA0) and the Arkon Portable Fold-Up Stand for Apple iPad, Galaxy Tab, Kindle Fire, Toshiba, Acer, ASUS, Nook and Other Tablets (Model No. IPM-TAB1; ASIN B000CKVOOY), both of which Defendant is authorized by Amount to sell through an exclusive licensing agreement with Arkon Resources, Inc. 13. However, Defendant offers for sale products from other companies without

authorization from Amount which, upon information and belief, infringe the 639 Patent, including but not limited to the products described in the following paragraphs. 14. Specifically, Defendant sells and offers to sell through Defendants website the

Lugulake 10pcs Black Portable Foldable Travel Stand for Google Nexus, Apple iPad, Samsung Galaxy Tab, and other 7 inch 9.7 inch 10.1 inch Android Tablet PCs (ASIN B00CFFFLR0) which, upon information and belief, infringes the 639 Patent. As evidence of Defendants infringing actions, images from Defendants website corresponding to said product listed are provided as Exhibit C. 15. Specifically, Defendant sells and offers to sell through Defendants website the

i.Trek Universal Fold Up Tablet PC and Ebook Stand for iPad 1/2, Amazon Kindle, B&N Nook, HP Touchpad, Samsung Galaxy Tab, Motorola Xoom, Acer Iconia, Viewsonic Viewpad, Asus EEEpad, Android Tablets (Model No. IPAD-ST; ASIN B0047ELBN0) which, upon

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information and belief, infringes the 639 Patent. As evidence of Defendants infringing actions, images from Defendants website corresponding to said product listed are provided as Exhibit D. 16. Specifically, Defendant sells and offers to sell through Defendants website the

SHARKK White Portable Fold-Up Stand for Apple iPad mini / iPad 2 / iPad 3 / The New iPad 4 With Retina Display / Galaxy Tab Nexus / Playbook / Xoom / Toshiba / Acer / Nook / and Other Tablets (Model No. STANDL; ASIN B006JD3F0Y) which, upon information and belief, infringes the 639 Patent. As evidence of Defendants infringing actions, images from Defendants website corresponding to said product listed are provided as Exhibit E. 17. Specifically, Defendant sells and offers to sell through Defendants website the

Xenda White Compact Portable Fold-Up Travel Stand Tablet Holder for Amazon Kindle Paperwhite - Amazon Kindle Paperwhite 3G - Apple Ipad (ASIN B00AM1Q4CK) which, upon information and belief, infringes the 639 Patent. As evidence of Defendants infringing actions, images from Defendants website corresponding to said product listed are provided as Exhibit F. 18. Plaintiff. 19. Upon information and belief, Defendant had actual knowledge of the Defendants aforesaid activities have been without authority and/or license from

specifications and issued claims of the Patent-in-Suit when it received a notice letter from counsel for Plaintiff dated March 12, 2013. Attached as Exhibit G is said notice letter. 20. Upon information and belief, Defendant had actual knowledge of the

specifications and issued claims of the Patent-in-Suit at the very latest on March 21, 2013 when a representative of Defendant responded to the March 12, 2013 notice letter by electronic message. Attached as Exhibit H is said electronic message along with a response from Plaintiff's counsel.

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21.

Despite its knowledge of the 639 Patent since at least March 21, 2013 and as

early as the date Defendant received the March 12, 2013 notice letter, and without a reasonable basis for continuing its infringing activities, on information and belief, Defendant continues to willfully infringe the 639 Patent. 22. Plaintiff is entitled to recover from Defendant the damages sustained by Plaintiff

as a result of Defendants wrongful acts in an amount subject to proof at trial, which, by law, cannot be less than a reasonable royalty, together with interest and costs as fixed by this Court under 35 U.S.C. 284. 23. Defendants infringement of Plaintiffs rights under the 639 Patent will continue

to damage Plaintiff, causing irreparable harm for which there is no adequate remedy at law, unless enjoined by this Court. JURY DEMAND 24. Plaintiff demands a trial by jury on all issues. PRAYER FOR RELIEF Plaintiff respectfully requests the following relief: A. An adjudication that one or more claims of the Patent-in-Suit has been infringed, either literally and/or under the doctrine of equivalents, by the Defendant; B. An award of damages to be paid by Defendant adequate to compensate Plaintiff for its past infringement and any continuing or future infringement up until the date such judgment is entered, including interest, costs, and disbursements as justified under 35 U.S.C. 284 and, if necessary to adequately compensate Plaintiff for Defendants infringement, an accounting of all infringing sales including, but not limited to, those sales not presented at trial;
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C.

A grant of permanent injunction pursuant to 35 U.S.C. 283, enjoining the Defendant from further acts of infringement with respect to the claims of the Patent-in-Suit;

D.

That, should Defendants acts of infringement be found to be willful from the time that Defendant became aware of the infringing nature of its actions, that the Court award treble damages for the period of such willful infringement pursuant to 35 U.S.C. 284.

E.

That this Court declare this to be an exceptional case and award Plaintiff its reasonable attorneys fees and costs in accordance with 35 U.S.C. 285; and,

F. \ \

Any further relief that this Court deems just and proper.

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Respectfully submitted this 27th day of March 2014 Attorneys for Plaintiff, Amount, Inc.

STAMOULIS & WEINBLATT LLC

s/ Stamatios Stamoulis Stamatios Stamoulis #4606 stamoulis@swdelaw.com Richard C. Weinblatt #5080 weinblatt@swdelaw.com Two Fox Point Centre 6 Denny Road, Suite 307 Wilmington, Delaware 19809 Telephone: (302) 999-1540 Steven W. Ritcheson, Pro Hac Vice Anticipated Email: swritcheson@hgdlawfirm.com 9800 D Topanga Canyon Boulevard, #347 Chatsworth, California 91311 Telephone: (818) 882-1030 Facsimile: (818) 337-0383 Jonathan R. Miller, Pro Hac Vice Anticipated Email: jmiller@hgdlawfirm.com Dara T. Jeffries, Pro Hac Vice Anticipated Email: djeffries@hgdlawfirm.com 3621 Vinings Slope, Suite 4320 Atlanta, Georgia 30339 Telephone: (404) 996-0863, 0867 Facsimile: (205) 547-5506, 5515 Ren A. Vazquez, Pro Hac Vice Anticipated Email: rvazquez@hgdlawfirm.com 18326 Buccaneer Terrace Leesburg, Virginia 20176 Telephone: (571) 206-1375 Facsimile: (205) 327-9114

HENINGER GARRISON DAVIS, LLC

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