Graphics Properties Holdings v. Research In Motion et. al.

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Official Complaint for Patent Infringement in Civil Action No. 1:11-cv-01161-UNA: Graphics Properties Holdings Inc. v. Research In Motion LTD. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See for more info.
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    #15208539 v1   IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE GRAPHICS PROPERTIES HOLDINGS,INC.,))) CIVIL ACTION NO.Plaintiff, ))v. ))RESEARCH IN MOTION LTD., ANDRESEARCH IN MOTION CORP.,)))))JURY TRIAL DEMANDED)Defendants. ) COMPLAINT FOR PATENT INFRINGEMENT 1.   Plaintiff Graphics Properties Holdings, Inc. (“GPH” or “Plaintiff”), byand through its attorneys, hereby demands a jury trial and complains of Defendants ResearchIn Motion Ltd., and Research In Motion Corp (collectively “Defendants”) as follows: NATURE OF THE ACTION 2.   This is an action for patent infringement arising under the patent lawsof the United States, 35 U.S.C. §§ 271, et seq., to enjoin infringement and obtain damagesresulting from Defendants’ unauthorized manufacture, use, sale, offer to sell and/or importation into the United States for subsequent use or sale of products, methods, processes,services and/or systems that infringe one or more claims of United States Patent No.6,650,327 (the “’327 Patent”) (attached as Exhibit A) entitled “Display System HavingFloating Point Rasterization and Floating Point Framebuffereing,” United States Patent No.6,816,145 (the “’145 Patent”) (attached as Exhibit B) entitled “Large Area Wide AspectRatio Flat Panel Display Having High Resolution For High Information Content Display,”  - 2 - #15208539 v1 and United States Patent No. 5,717,881 (the “881 Patent”) (attached as Exhibit C) entitled“Data Processing System for Processing One and Two Parcel Instructions.” Plaintiff seeksinjunctive relief to prevent Defendants from continuing to infringe Plaintiff’s patents. Inaddition, Plaintiff seeks a recovery of monetary damages resulting from Defendants’ pastinfringement of these patents.3.   This action for patent infringement involves Defendants manufacture,use, sale, offer for sale, and/or importation into the United States of infringing products,methods, processes, services and systems that are primarily used or primarily adapted for usein consumer electronics and display devices, including but not limited to Defendants’ mobile phones, telecommunication devices, and other consumer electronics and display devices. THE PARTIES  4.   Plaintiff GPH is a Delaware corporation with its principal place of  business at 56 Harrison Street, Suite 305C, New Rochelle, New York 10801.5.   Plaintiff GPH is the lawful assignee of all right, title and interest in andto the ’327, ’145 and ’881 Patents (collectively, the “Asserted Patents”).6.   GPH was formerly named Silicon Graphics, Inc. As Silicon Graphics,GPH developed technology and intellectual property used in the graphics, computer  processing, and display segments. GPH is owned by private investment funds and other institutional investors, following the bankruptcy of Silicon Graphics.7.   GPH continues to manage and license its intellectual property,including the ‘327 Patent, the ‘145 Patent, and the ‘881 Patent.8.   Defendant Research in Motion Ltd. is a foreign company organizedand existing under the laws of Canada, with its principal place of business at 295 Phillip  - 3 - #15208539 v1 Street, Waterloo, Ontario, Canada, N2L 3WB.9.   Research in Motion Ltd. is engaged in the manufacture and sale of consumer electronics and display devices and products containing same that are importedinto the United States. Such devices include, but are not limited to, mobile phones,telecommunication devices, and other consumer electronics and display devices and productscontaining same. Such devices include, but are not limited to the Playbook and Torchdevices, and other substantially similar devices.10.   Research in Motion Ltd.’s main manufacturing facility is located at451 Phillips Street, Waterloo, Canada, N2L 3X2, and partners with, among others, Quanta, aChinese manufacturer, to manufacture goods.11.   Research in Motion Ltd. identifies the United States as a major market,where 39.3% of their revenue was generated in 2010.12.   Additionally, in 2008, Research in Motion Ltd. opened their UnitedStates headquarters, Research in Motion Corp., located in Irving, Texas.13.   Defendant Research In Motion Corp. is a wholly-owned subsidiary of Defendant Research In Motion Ltd.14.   Defendant Research In Motion Corp. is located at 122 W. JohnCarpenter Parkway, Suite 430, Irving, Texas 75039.15.   As the United States headquarters for Defendants, Research in MotionCorp. is engaged in research and development, technical support, and business operations.On information and belief, Defendant Research In Motion Corp.’s business operationsinclude marketing and distributing consumer electronics and display devices and productscontaining same, including but not limited to, tablets, mobile phones, and telecommunication  - 4 - #15208539 v1 devices, in the United States. Such devices include, but are not limited to DefendantsPlaybook and Torch devices, and other substantially similar devices. Research In MotionLtd. and Research In Motion Corp. are referred to collectively as “Defendants.”16.   Plaintiff has been irreparably harmed by the Defendants’infringements of its valuable patent rights. Moreover, Defendants’ unauthorized andinfringing uses of Plaintiff’s patented systems and methods have threatened the value of thisintellectual property because Defendants’ conduct results in Plaintiff’s loss of its lawful patent rights to exclude others from making, using, selling, offering to sell and/or importingthe patented inventions.17.   Defendants’ disregard for Plaintiff’s property rights threatensPlaintiff’s relationships with existing licensees and potential licensees of Plaintiff’s consumer electronics and display device patents. The Defendants will derive a competitive advantageover any of Plaintiff’s existing licensees and future licensees from using Plaintiff’s patentedtechnology without paying compensation for such use. Accordingly, unless and until theDefendants’ continued acts of infringement are enjoined, Plaintiff will suffer further irreparable harm for which there is no adequate remedy at law. JURISDICTION AND VENUE  18.   This Court has jurisdiction over the subject matter of this patentinfringement action pursuant to 28 U.S.C. §§ 1331 and 1338(a).19.   Defendants are subject to personal jurisdiction in the State of Delaware because they regularly transact business in this judicial district and division by, among other things, offering their products and services to customers, business affiliates and partnerslocated in this judicial district. In addition, the Defendants have committed acts of direct
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