In the United States District Court for the Eastern District of Texas Marshall Division
Case 2:20-cv-00107 Document 1 Filed 04/14/20 Page 1 of 51 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION SOVEREIGN PEAK VENTURES, LLC, § § Plaintiff, § § v. § JURY TRIAL DEMANDED § LG ELECTRONICS, INC., and § LG ELECTRONICS U.S.A., INC., § CIVIL ACTION NO. ____________ § Defendants. § § PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Sovereign Peak Ventures, LLC (“SPV”) files this Complaint against Defendants LG Electronics, Inc. (“LG KR”) and LG Electronics U.S.A., Inc., (“LG USA”) (collectively “LG” or “Defendants”) for infringement of U.S. Patent No. 8,374,152 (the “’152 patent”), U.S. Patent No. 8,442,569 (the “’569 patent”), U.S. Patent No. 8,467,723 (the “’723 patent”), U.S. Patent No. 8,792,453 (the “’453 patent”), U.S. Patent No. 9,414,059 (the “ʼ059 patent”), U.S. Patent No. 9,042,457 (the “ʼ457 patent”), and U.S. Patent No. 7,133,658 (the “ʼ658 patent), collectively, the “Asserted Patents.” THE PARTIES 1. Sovereign Peak Ventures, LLC is a Texas limited liability company, located at 1400 Preston Rd, Suite 289, Plano, TX 75093. 2. Upon information and belief, LG KR is a multinational corporation organized under the laws of Korea, with its principal place of business located at LG Twin Towers, 128 Yeoui- daero, Yeongdungpo-gu, Seoul 150-721, Republic of Korea. PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT 1 Case 2:20-cv-00107 Document 1 Filed 04/14/20 Page 2 of 51 PageID #: 2 3. Upon information and belief, LG USA is a corporation organized under the laws of the State of Delaware, with regular and established places of business in Texas at least at 21251- 2155 Eagle Parkway, Fort Worth, Texas 76177; 14901 Beach St, Fort Worth, TX 76177; and 9420 Research Blvd, Austin, Texas 78759.
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