Of 79 UNITED STATES DISTRICT COURT EASTERN DISTRICT of TEXAS MARSHALL DIVISION Plaintiff, V. Defendant. Civil Action
Case 2:18-cv-00060 Document 1 Filed 03/08/18 Page 1 of 79 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION DIFF SCALE OPERATION RESEARCH, LLC, Civil Action No._________ Plaintiff, v. JURY TRIAL DEMANDED CISCO SYSTEMS, INC. Defendant. COMPLAINT FOR PATENT INFRINGEMENT DIFF Scale Operation Research, LLC (“Plaintiff”), by its undersigned counsel, bring this action and make the following allegations of patent infringement relating to U.S. Patent Nos.: 7,881,413 (the, “‘413 patent”); 6,664,827 (the, “‘827 patent”); 7,106,758 (the, “‘758 patent”); 6,407,983 (the, “‘983 patent”); 6,847,609 (the, “‘609 patent”); 6,940,810 (the, “‘810 patent”); 6,990,110 (the, “‘110 patent”); 6,721,328 (the, “‘328 patent”); and 6,216,166 (the, “‘166 patent”); and 6,859,430 (the, “‘430 patent”) (collectively, the “patents-in-suit”). Defendant Cisco Systems, Inc. (“Cisco” or “Defendant”) infringes each of the patents-in-suit in violation of the patent laws of the United States of America, 35 U.S.C. § 1 et seq. INTRODUCTION This case arises from Cisco’s infringement of a portfolio of semiconductor and network infrastructure patents. This patent portfolio arose from the groundbreaking work of ADC Telecommunications, Inc. (“ADC Telecommunications”). Page 1 of 79 Case 2:18-cv-00060 Document 1 Filed 03/08/18 Page 2 of 79 PageID #: 2 In 1935, ADC Telecommunications, then known as the Audio Development Company1 was founded in Minneapolis, Minnesota by two Bell Laboratory engineers to create custom transformers and amplifiers for the broadcast radio industry.
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