In the United States District Court for the District of Delaware
Case 1:11-cv-00857-JBS-KW Document 5 Filed 10/11/11 Page 1 of 15 PageID #: 65 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE VIA TECHNOLOGIES, INC., a Taiwan corporation, IP-FIRST, LLC, a Delaware corporation, and CENTAUR TECHNOLOGY, INC., a California corporation, Plaintiffs, C.A. No.: 11-857-JBS-KW v. DEMAND FOR JURY TRIAL APPLE INC., a California Corporation, Defendant. FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs, VIA Technologies, Inc. (“VIA”), IP-First, LLC (“IP-First”), and Centaur Technology, Inc. (“Centaur”) (collectively, “Plaintiffs”) for their First Amended Complaint against Defendant, Apple Inc. (“Apple”), hereby allege as follows: Nature of the Action 1. This is a civil action arising under the laws of the United States relating to patents and the protection of patent rights, e.g., 35 U.S.C. § 271 et seq., alleging infringement by Apple of five U.S. Patents owned by Plaintiffs, specifically, U.S. Patent Nos. 6,253,311, 6,253,312, 6,754,810, 7,155,598, and 7,185,180. Parties 2. VIA is a corporation organized and existing under the laws of Taiwan, R.O.C., with its principal place of business at VIA Technologies, Inc., Taipei Headquarters, 1F, 535, Zhongzheng Rd., Xindian District, New Taipei City 231, Taiwan. VIA is a fabless supplier of power-efficient x86 processor platforms used in the PC, client, ultra-mobile, and embedded Case 1:11-cv-00857-JBS-KW Document 5 Filed 10/11/11 Page 2 of 15 PageID #: 66 markets that engages, among other things, in the design, research, development, manufacture, and distribution of semiconductor microprocessors and chipsets.
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