Magna Electronics v. Hyundai Mobis et. al.

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Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-11411-SFC-LJM: Magna Electronics, Inc. v. Hyundai Mobis, Co. Ltd. et. al. Filed in U.S. District Court for the Eastern District of Michigan, the Hon. Sean F. Cox presiding. See http://news.priorsmart.com/-l5LS for more info.
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  IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF MICHIGAN- - - - - - - -MAGNA ELECTRONICS INC. )))Plaintiff, )) Civil Action No. __________v. )) Honorable __________________HYUNDAI MOBIS, CO. LTD., )MOBIS AMERICA, INC., )MOBIS PARTS AMERICA, LLC, )MOBIS NORTH AMERICA, LLC )d/b/a MOBIS PARTS DETROIT, LLC; )AMERICAN AUTOPARTS, INC; )MOBIS ALABAMA, LLC; )MOBIS GEORGIA, LLC ))Defendants. )____________________________________)COMPLAINTMagna Electronics Inc. hereby complains of Hyundai Mobis, Co. Ltd., Mobis America,Inc., Mobis Parts America, LLC, Mobis North America, LLC, Mobis Parts Detroit, LLC,American Autoparts, Inc., Mobis Alabama, LLC and Mobis Georgia, LLC and alleges asfollows:THE PARTIES1. Magna Electronics Inc. is a corporation organized and existing under the laws of the State of Delaware, having a registered office of 2711 Centerville Road, Suite 400,Wilmington, Delaware 19808 and a principal place of business at 1870 Technology Drive, TroyMichigan 48083, is registered to do business in the State of Michigan and is doing business inthis District (hereinafter “Magna” or “Plaintiff”).  2. Defendant Hyundai Mobis, Co. Ltd. (“Hyundai Mobis”), upon information andbelief, is a Korean corporation with a business address of 679-4 ING Bldg., Yeoksam1-dong,Gangnam-gu, Seoul, 135-977, Republic of Korea.3. Defendant Mobis America, Inc. (“Mobis America”), upon information and belief,is a Delaware corporation with a principal place of business of 2821 Eastern Boulevard, Suite100, Montgomery, AL 36116, and a business address of 1395 Mitchell Young Rd., Montgomery,AL 36108.4. Defendant Mobis Parts America, LLC (“Mobis Parts”), upon information andbelief, is a Delaware limited liability company with a principal place of business of 13200 NW17 th St., Miami, FL 33182, a business address of 10805 NW 100th Street, Suite 11, Miami, FL33178, and a mailing address of 111 Peters Canyon Road, Irvine, CA 92606.5. Defendant Mobis North America, LLC (“Mobis NA”), upon information andbelief, is a is a Delaware limited liability company licensed to conduct business in the State of Michigan with a registered office of 6401 W. Fort St., Detroit, MI 48209, and registered with theState of Michigan to conduct business under the assumed name Mobis Parts Detroit, LLC(“Mobis Detroit”) with a business address of 23255 Commerce Dr., Farmington Hills, MI 48335,and conducts business under the assumed name Mobis North America-Michigan.6. Defendant American Autoparts, Inc. (“American AP”), upon information andbelief, is a Delaware Corporation with a business address of 3900 Stickney Avenue, Toledo, OH43608, which conducts business under the assumed name Mobis North America, LLC andconducts business under the assumed name Mobis North America, LLC MNA, and conductsbusiness under the assumed name Mobis North America-Ohio.2  7. Defendant Mobis Alabama, LLC (“Mobis Alabama”), upon information andbelief, is a Delaware limited liability company with a principal address of 2821 EasternBoulevard, Suite 100, Montgomery, AL 36116, and a business address of 1395 Mitchell YoungRd., Montgomery, AL 36108.8. Defendant Mobis Georgia, LLC (“Mobis Georgia”), upon information and belief,is a Delaware limited liability company with a business address of 7001 Kia Parkway, WestPoint, GA 31833.9. On information and belief Hyundai Mobis owns Mobis America, and MobisAmerica in turn owns Mobis Parts, Mobis NA which does business as Mobis Detroit, MobisAlabama and Mobis Georgia. On information and belief Hyundai Mobis owns American AP.On information and belief, Mobis America, Mobis Parts, Mobis NA, Mobis Detroit, AmericanAP, Mobis Alabama and Mobis Georgia are all owned, either directly or indirectly, andcontrolled by Hyundai Mobis. (The defendants are hereinafter collectively referred to as“Mobis” or “Defendants.”)10. In the alternative, on information and belief, Hyundai Mobis owns American AP,and American AP in turn owns Mobis NA which does business as Mobis Detroit.11. Defendants Mobis, upon information and belief, are doing business within theState of Michigan and within the Eastern District of Michigan, and are engaged in continuousand systematic business within the Eastern District of Michigan, and including the commissionof acts of infringement as hereinafter stated.JURISDICTION AND VENUE12. This action arises under the patent laws of the United States, Title 35 of theUnited States Code, §§1 et seq. 3  13. This Court has jurisdiction in this action under 28 U.S.C. §§1331 and 1338.Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391 and 1400.BACKGROUND ALLEGATIONS14. On April 24, 2001, United States Letters Patent No. 6,222,447 was duly andlegally issued to the predecessor in interest to Magna, as owner by assignment thereof, for aninvention entitled “Rearview Vision System With Indicia Of Backup Travel.”15. On March 15, 2011, a Re-examination Certificate was duly and legally issued tothe predecessor in interest to Magna for United States Letters Patent No. 6,222,447. A true andcorrect copy of United States Patent No. 6,222,447 and the Re-examination Certificate thereforeis attached hereto as Exhibit 1 (hereinafter the “’447 Patent”).16. On September 7, 1999, United States Letters Patent No. 5,949,331 was duly andlegally issued to the predecessor in interest to Magna, as owner by assignment thereof, for aninvention entitled “Display Enhancements For Vehicle Vision System.”17. On March 1, 2011, a Re-examination Certificate was duly and legally issued tothe predecessor in interest to Magna for United States Letters Patent No. 5,949,331. A true andcorrect copy of United States Patent No. 5,949,331 and the Re-examination Certificate thereforeis attached hereto as Exhibit 2 (hereinafter the “’331 Patent”).18. Magna is the owner, by valid assignment, of all right, title, and interest in and tothe ‘447 Patent and the ‘331 Patent, including the right to seek remedies and relief for pastinfringement thereof.19. The ‘447 and ‘331 Patents are currently undergoing reexamination in the UnitedStates Patent and Trademark Office.4
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