1- in the UNITED STATES DISTRICT COURT for the DISTRICT of MASSACHUSETTS VIATECH TECHNOLOGIES, INC., Plaintiff, V. ADOBE INC
Case 1:19-cv-11177-ADB Document 1 Filed 05/24/19 Page 1 of 30 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS VIATECH TECHNOLOGIES, INC., ) Civil Action No.: 19-11177 ) Plaintiff, ) ) COMPLAINT AND ) DEMAND FOR JURY TRIAL v. ) ) ADOBE INC., ) ) Defendant. ) ) COMPLAINT FOR PATENT INFRINGEMENT Plaintiff ViaTech Technologies, Inc. (“Plaintiff” or “ViaTech”), through its attorneys, for its Complaint against Adobe Inc. (“Defendant” or “Adobe”), alleges as follows: THE PARTIES 1. Plaintiff is a corporation organized and existing under the laws of the State of Delaware having a place of business at 1136 Ashbourne Circle, Trinity, Florida 34655, and has a registered agent in the District at 45 Bristol Drive, Suite 101, South Easton, Massachusetts 02375. 2. Defendant Adobe is a corporation organized and existing under the laws of the State of Delaware and having a place of business at One Newton Place, 275 Washington Street, 3rd Floor, Newton, Massachusetts 02458. JURISDICTION AND VENUE 3. This action arises under the patent laws of the United States, Title 35 of the United States Code. Subject matter jurisdiction is proper in this Court pursuant to 28 U.S.C. §§ 1331 and 1338(a). -1- Case 1:19-cv-11177-ADB Document 1 Filed 05/24/19 Page 2 of 30 4. Defendant Adobe is subject to this Court’s specific and general personal jurisdiction consistent with due process and the Massachusetts Long Arm Statute, Gen. Laws. ch. 223A, § 3. 5. Venue in this Judicial District is proper under 28 U.S.C. § 1400(b) because Defendant has committed acts of infringement and has a regular and established place of business within this District.
[Show full text]