1 United States District Court Western District of Texas
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION ) AFFINITY LABS OF TEXAS, LLC, ) ) Plaintiff, ) ) v. ) ) Case No. 6:13-cv-364 SAMSUNG ELECTRONICS CO., LTD., ) SAMSUNG ELECTRONICS AMERICA, INC., ) JURY TRIAL DEMANDED AND SAMSUNG TELECOMMUNICATIONS ) AMERICA, LLC F/K/A SAMSUNG ) TELECOMMUNICATIONS AMERICA, L.P., ) ) Defendants. ) COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Affinity Labs of Texas, LLC (“Affinity Labs”) for its causes of action against Defendants, Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Samsung Telecommunications America, LLC f/k/a Samsung Telecommunications America, LP (collectively, “Samsung” and/or “Defendants”), states and alleges on knowledge and information and belief as follows: PARTIES 1. Plaintiff Affinity Labs is a Texas limited liability company having offices at 31884 RR 12, Dripping Springs, TX 78620. 2. On information and belief, Defendant Samsung Electronics Co., Ltd. is a Korean company having its principal place of business at 250 2-ga Taepyung-ro, Jung-gu, Seoul 100- 742, Korea. 1 1823831.1 3. On information and belief, Defendant Samsung Electronics America, Inc. is a New York corporation having its principal place of business at 85 Challenger Road, Ridgefield Park, NJ 07660. Samsung Electronics America, Inc. has been authorized to do business in the State of Texas by the Texas Secretary of State. Furthermore, Samsung Electronics America, Inc. has designated CT Corporation System, 350 N. Saint Paul Street, Suite 2900, Dallas, TX 75201, as its representative to accept service of process within the State of Texas. 4. On information and belief, Defendant Samsung Telecommunications America, LLC f/k/a Samsung Telecommunications America, L.P., is a Delaware limited liability company having its principal place of business at 1301 E.
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