And INSTAGRAM LLC. Defendants
Case 1:17-cv-01120-UNA Document 1 Filed 08/09/17 Page 1 of 26 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SEARCH AND SOCIAL MEDIA PARTNERS, LLC, C.A. No. __________ Plaintiffs v. JURY TRIAL DEMANDED FACEBOOK, INC.; INSTAGRAM, INC.; and INSTAGRAM LLC. Defendants. COMPLAINT Plaintiff SEARCH AND SOCIAL MEDIA PARTNERS, LLC, (“SSMP”) brings this action against defendant FACEBOOK, INC. (“FACEBOOK”), INSTAGRAM, INC. and INSTAGRAM, LLC (INSTRAGRAM, INC. and INSTRAGRAM, LLC collectively (“INSTAGRAM”), and hereby alleges as follows: THE PARTIES 1. SSMP is a limited liability company organized and existing under the laws of Delaware, having a place of business in Murfreesboro, TN. SSMP is the owner of a family of patents relating to social media networks including U.S. Patent Nos. 8,620,828 (the “’828 Patent”) and 8,719,176 (the “’176 Patent,” collectively the “Asserted Patents.”) 2. Upon information and belief, FACEBOOK is a Delaware corporation, having its corporate headquarters in Menlo Park, California. FACEBOOK provides social networking services through its website, www.facebook.com and m.facebook.com (the “Facebook Website”) and its mobile applications or apps available for several mobile platforms including iOS, Windows Phone, and Android (the “Facebook Apps”). FACEBOOK may be served with Case 1:17-cv-01120-UNA Document 1 Filed 08/09/17 Page 2 of 26 PageID #: 2 process via its registered agent, the Corporation Services Company, 251 Little Falls Drive, Wilmington, Delaware 19808. 3. Upon information and belief, INSTAGRAM, INC. is a Delaware corporation with its principle place of business in Menlo Park, California.
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