In the United States District Court for the Eastern District of Texas Tyler Division
Case 6:11-cv-00660-LED Document 1 Filed 12/08/11 Page 1 of 16 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Personalweb Technologies LLC Plaintiff, v. Civil Action No. 6:11-cv-660 EMC Corporation, and JURY TRIAL REQUESTED VMware, Inc. Defendants. COMPLAINT FOR PATENT INFRINGEMENT Plaintiff PersonalWeb Technologies LLC files this Complaint for Patent Infringement against EMC Corporation and VMware Inc. (collectively, “Defendants”) and states as follows: THE PARTIES 1. Plaintiff PersonalWeb Technologies LLC (“PersonalWeb” or “Plaintiff”) is a limited liability company organized under the laws of Texas with its principal place of business at 112 E. Line Street, Suite 204, Tyler, Texas, 75702. PersonalWeb was founded in August 2010 and is in the business of developing and distributing software based on its technology assets. 2. PersonalWeb protects its proprietary business applications and operations through a portfolio of patents that it owns, including 13 issued and pending United States patents. PersonalWeb is assignee and owner of eight patents at issue in this action: U.S. Patent Nos. 5,978,791, 6,415,280, 6,928,442, 7,802,310, 7,945,539, 7,945,544, 7,949,662, and 8,001,096. 3. Defendant EMC Corporation (“EMC”) is a Massachusetts Corporation with its principal place of business at 176 South Street, Hopkinton, Massachusetts. EMC is qualified to McKool 298950v1 Case 6:11-cv-00660-LED Document 1 Filed 12/08/11 Page 2 of 16 PageID #: 2 do business in the state of Texas, Filing No. 0007347306, and has appointed CT Corporation System, 350 N Saint Paul St.
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