Case 2:16-Cv-01362-JRG Document 101 Filed 08/16/17 Page 1 of 46 Pageid #: 2460
Case 2:16-cv-01362-JRG Document 101 Filed 08/16/17 Page 1 of 46 PageID #: 2460 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION NAGRAVISION SA and NAGRA FRANCE SAS, Plaintiffs, Case No.: 2:16-cv-1362-JRG vs. JURY TRIAL DEMANDED COMCAST CABLE COMMUNICATIONS, LLC, Defendant. SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs Nagravision SA and Nagra France SAS (collectively, “Plaintiffs”), by and through their undersigned attorneys, for their Second Amended Complaint against Defendant Comcast Cable Communications, LLC (“Defendant” or “Comcast”), hereby allege as follows, upon actual knowledge with respect to themselves and their own acts, and upon information and belief as to all other matters: NATURE OF THE ACTION 1. Plaintiffs bring this patent infringement action to stop Comcast from continuing its wrongful and unlicensed use of Plaintiffs’ patented technologies in its products and services, including Xfinity digital video, audio, and other content services (or any predecessor services) provided to Comcast’s customers with the Xfinity set-top boxes and other hardware provided to Comcast’s customers. 2. Comcast infringes the following of Plaintiffs’ United States Patents, which are attached hereto as Exhibits A, B, and C (collectively “the Asserted Patents”): Case 2:16-cv-01362-JRG Document 101 Filed 08/16/17 Page 2 of 46 PageID #: 2461 • U.S. Patent No. 7,725,740 (“the ’740 Patent”); • U.S. Patent No. 8,356,188 (“the ’188 Patent”); and • U.S. Patent No. RE40,334 (“the ’334 Patent”). 3. Comcast directly and indirectly infringes the Asserted Patents by making, using, testing, importing, offering for sale/lease, selling, and leasing infringing products and services to Comcast’s customers.
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