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Howard.Chen@Klgates.Com Howard Chen(SBN257393) Case3:10-cv-04458-EMC Document36 Filed05/27/11 Page1 of 13 1 Howard Chen (SBN 257393) [email protected] 2 Harold H. Davis, Jr. (SBN 235552) [email protected] 3 Rachel Davidson (SBN 215517) [email protected] 4 K&L GATES LLP Four Embarcadero Center, Suite 1200 5 San Francisco, California 94111 Telephone: 415.882.8200 6 Facsimile: 415.882.8220 7 Jeffrey M. Ratinoff (SBN 197241) [email protected] 8 K&L GATES LLP 630 Hansen Way 9 Palo Alto, CA 94304 Telephone: (650) 798-6700 10 Facsimile: (650) 798-6701 11 Attorneys for Plaintiffs WISTRON CORPORATION, WISTRON 12 INFOCOMM (TEXAS) CORPORATION, WISTRON INFOCOMM TECHNOLOGY 13 (AMERICA) CORPORATION, AOPEN INCORPORATED AND 14 AOPEN AMERICA INCORPORATED 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 WISTRON CORPORATION; WISTRON Case No. 3:10-CV-04458-EMC 19 INFOCOMM (TEXAS) CORPORATION; and WISTRON INFOCOMM TECHNOLOGY SECOND AMENDED COMPLAINT FOR 20 (AMERICA) CORPORATION; AOPEN DECLARATORY JUDGMENT OF NON- INCORPORATED and AOPEN AMERICA INFRINGEMENT AND INVALIDITY OF 21 INCORPORATED; U.S. PATENT NOS. 5,983,002; 6,401,222; 6,687,858; 7,251,752; 7,069,475; 7,409,601; 22 Plaintiffs, 6,691,181; 7,249,203; 7,472,207; 6,842,802; 7,366,804; AND 7,653,766 23 vs. 24 PHILLIP M. ADAMS & ASSOCIATES, LLC; AFTG-TG LLC; and PHILLIP M. ADAMS, 25 Defendants. 26 27 28 Second Amended Complaint for Declaratory Judgment of Non-Infringement and Invalidity Case No. 3:10-cv-04458-EMC Case3:10-cv-04458-EMC Document36 Filed05/27/11 Page2 of 13 1 1. Plaintiffs WISTRON CORPORATION (“Wistron Corp.”), WISTRON INFOCOMM 2 (TEXAS) CORPORATION; and WISTRON INFOCOMM TECHNOLOGY (AMERICA) 3 CORPORATION (“Wistron America”) (collectively “Wistron”); and Plaintiffs AOPEN 4 INCORPORATED (“AOpen Inc.”), and AOPEN AMERICA INCORPORATED (“AOpen 5 America”) (collectively “AOpen”); by and through their attorneys allege as follows: 6 THE PARTIES 7 2. Plaintiff Wistron Corp. is a Taiwan corporation with its principal place of business at 8 21F, 88, Sec. 1, Hsin Tai Wu. Rd., Hsichih, Taipei Hsien 221, Taiwan, R.O.C. Wistron Corp. is one 9 of the world’s largest original design manufacturers (“ODM”) for information and communication 10 technology (“ICT”) products. Wistron Corp. is in the business of designing, developing and 11 manufacturing computer products such as notebook computers, computer peripheral equipment and 12 other electronic products for customers to sell under their own brand names. Wistron Corp.’s 13 products are sold in this District. 14 3. Plaintiff Wistron Infocomm (Texas) Corporation has changed its name to SMS 15 Infocomm Corporation (“SMS” or “Wistron Texas”) and is a Texas corporation with its principal 16 place of business at 4051 Freeport Parkway, Suite 200, Grapevine, Texas 76051. SMS is a wholly- 17 owned subsidiary of Wistron Corp. and provides after-sales repair and servicing of products for 18 which Wistron Corp. was the original manufacturer. 19 4. Plaintiff Wistron America is a Texas corporation with its principal place of business at 20 800 Parker Square, Suite 285A, Flower Mound, Texas 75028. Wistron America is a wholly-owned 21 subsidiary of Wistron Corp. and provides Wistron customers in North America with sales support. 22 5. Plaintiff AOpen Inc. is a Taiwan corporation with its principal place of business at 23 No.68, Ruiguang Rd., Neihu District, Taipei, Taiwan, ROC. AOpen Inc. is in the business of 24 manufacturing and selling computer products such as notebook computers and computer peripheral 25 equipment. 26 6. Plaintiff AOpen America is a California corporation with its principal place of 27 business at 2890 Zanker Road, Suite 101 San Jose, CA 95134. AOpen America is a wholly owned 28 subsidiary of AOpen Inc. and is a leading manufacturer of ultra small-form-factor (uSFF) computer 2 Second Amended Complaint for Declaratory Judgment of Non-Infringement and Invalidity Case No. 3:10-cv-04458-EMC Case3:10-cv-04458-EMC Document36 Filed05/27/11 Page3 of 13 1 components and customizable platforms and a digital signage solution provider. 2 7. Defendant Phillip M. Adams & Associates, L.L.C. (“PMAA”) is a Utah limited 3 liability company with an address at 325 Federal Heights Circle, Salt Lake City, Utah 84103. PMAA 4 has an alternative address at P.O. Box 1207, Bountiful, Utah 84011. 5 8. Wistron and AOpen are informed and believe, and based thereon allege, that 6 Defendant AFTG-TG L.L.C. (“AFTG”) is now a Wyoming limited liability company with an address 7 at 325 N Federal Heights Circle, Salt Lake City, Utah 84103. 8 9. Wistron and AOpen are informed and believe, and based thereon allege, that 9 Defendant Phillip M. Adams (“Dr. Adams”) is a Nevada resident. Wistron and AOpen are further 10 informed and believe, and based thereon allege, that Dr. Adams is the principal owner and head of 11 both PMAA and AFTG, and that AFTG and PMAA function as patent holding companies and are the 12 alter egos of Dr. Adams. 13 10. Dr. Adams is listed as the inventor of United States Patent Nos. 5,983,002 (“the ‘002 14 patent”); 6,401,222 (“the ‘222 patent”); 6,687,858 (“the ‘858 patent”); 7,251,752 (“the ‘752 patent”); 15 7,069,475 (“the ‘475 patent”); and 7,409,601 (“the ‘601 patent”). Wistron and AOpen are informed 16 and believe, and based thereon allege, that Dr. Adams has assigned ownership of the aforementioned 17 patents to PMAA (“the PMAA patents”). 18 11. Dr. Adams is also listed as the inventor of United States Patent Nos. 6,691,181 (“the 19 ‘181 patent”); 7,249,203 (“the ‘203 patent”); 7,472,207 (“the ‘207 patent”); 6,842,802 (“the ‘802 20 patent”); 7,366,804 (“the ‘804 patent”); and 7,653,766 (“the ‘766 patent”). Wistron and AOpen are 21 informed and believe, and based thereon allege that Dr. Adams has assigned ownership of the 22 aforementioned patents to AFTG (“the AFTG patents”). 23 12. Wistron and AOpen further are informed and believe, and based thereon allege, that 24 the PMAA patents and AFTG patents are from the same patent family or families and/or relate to the 25 same claimed devices, systems, methods and technologies. 26 JURISDICTION AND VENUE 27 13. Wistron and AOpen file this Second Amended Complaint against Dr. Adams, PMAA 28 and AFTG (collectively “Defendants”) pursuant to the patent laws of the United States, Title 35 of 3 Second Amended Complaint for Declaratory Judgment of Non-Infringement and Invalidity Case No. 3:10-cv-04458-EMC Case3:10-cv-04458-EMC Document36 Filed05/27/11 Page4 of 13 1 the United States Code, with a specific remedy sought based upon the laws authorizing actions for 2 declaratory judgment in the federal courts of the United States, 28 U.S.C. §§ 2201 and 2202. 3 14. This Court has subject matter jurisdiction over this action, which arises under the 4 patent laws of the United States, pursuant to 28 U.S.C. §§ 1331, 1338(a), and under the Federal 5 Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202. 6 15. Personal jurisdiction and venue are proper in this District pursuant to 28 U.S.C. 7 §§ 1391 and 1400(b). Upon information and belief, Defendants conduct business in this District, 8 Wistron and AOpen reside and/or do business in this District, and a substantial part of the events that 9 give rise to this action occurred in this District. Upon information and belief, Defendants have 10 transacted and continue to transact business in California and this District by providing consulting 11 services, negotiating and entering into licensing agreements for some or all of the patents-in-suit with 12 companies based in California and this District, asserting some or all of the patents-in-suit against 13 alleged infringers as required by such license agreements, and participating in litigation concerning 14 the patents-in-suit in and directed at companies based in California and this District. 15 INTRADISTRICT ASSIGNMENT 16 16. This action is properly filed in the San Francisco Division of the Northern District of 17 California because Wistron, AOpen and Defendants do business within the San Francisco Division. 18 EXISTENCE OF AN ACTUAL CONTROVERSY 19 17. There is an actual controversy within the jurisdiction of this Court under 28 U.S.C. 20 §§ 2201 and 2202. 21 18. On or around June 21, 2010, in letters sent to Wistron and AOpen, respectively, 22 Defendants embarked upon an improper campaign of threats against Wistron and AOpen to file a 23 baseless patent infringement lawsuit against Wistron and AOpen for the purpose, and intended effect, 24 of disrupting the sale of Wistron and AOpen products, including notebook computers, in the United 25 States. 26 19. Defendants have repeatedly demanded that Wistron and AOpen enter into a royalty- 27 bearing license for the PMAA and AFTG patents. Defendants are claiming that certain Wistron and 28 AOpen products infringe one or more claims of the PMAA and AFTG patents, and have told Wistron 4 Second Amended Complaint for Declaratory Judgment of Non-Infringement and Invalidity Case No. 3:10-cv-04458-EMC Case3:10-cv-04458-EMC Document36 Filed05/27/11 Page5 of 13 1 and AOpen that if they do not take licenses to the PMAA and AFTG patents, Wistron and AOpen 2 may be subject to substantial liabilities. 3 20. As part of its improper campaign, Defendants referred Wistron and AOpen to the 4 previously-filed Lenovo case, Case No. 1:05-cv-64 TX-DN (D. Utah), in which infringement of 5 several of the patents-in-suit were alleged against other computer manufacturers and computer brand 6 companies such as Lenovo, Dell, Asus, Fujitsu and the like.
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