1- in the United States District Court for the District Of
Case 1:18-cv-00917-MN Document 134 Filed 09/26/19 Page 1 of 72 PageID #: 4378 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE VIRENTEM VENTURES, LLC, D/B/A ) ENOUNCE ) ) C.A. No. 18-917-MN ) Plaintiff, ) ) JURY TRIAL DEMANDED v. ) ) YOUTUBE, LLC; GOOGLE, LLC. ) ) Defendants. ) ) VIRENTEM VENTURES, LLC D/B/A ENOUNCE’S SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Virentem Ventures, LLC d/b/a Enounce, (“Plaintiff” or “Virentem” or “Enounce”), for its Second Amended Complaint against Defendants, YouTube, LLC (“YouTube”) and Google, LLC (“Google”) (collectively “Defendants”) alleges: THE PARTIES 1. Plaintiff Virentem, d/b/a Enounce, is a Delaware limited liability company duly organized and existing under the laws of the State of Delaware, with a principle place of business in the State of California. The address of the registered office of Virentem is 2666 E Bayshore Rd Ste C, Palo Alto, CA 94303. 2. On information and belief, Defendant YouTube is a corporation duly organized and existing under the laws of the State of Delaware, having its principal place of business at 901 Cherry Ave., San Bruno, CA 94066. 3. On information and belief, Google is a corporation duly organized and existing under the laws of the State of Delaware, having its principle place of business at 1600 Amphitheatre Pkwy, Mountain View, CA 94043. -1- Case 1:18-cv-00917-MN Document 134 Filed 09/26/19 Page 2 of 72 PageID #: 4379 JURISDICTION 4. This is an action arising under the patent laws of the United States. Accordingly, this Court has subject matter jurisdiction pursuant to 28 U.S.C.
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