1 in the United States District Court for the Northern
Case: 1:18-cv-06255 Document #: 1 Filed: 09/13/18 Page 1 of 19 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION COMPLEX MEMORY, LLC, Plaintiff Civil Action No.: 1:18-cv-6255 v. PATENT CASE MOTOROLA MOBILITY LLC Jury Trial Demanded Defendant COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Complex Memory, LLC (“Complex Memory”), by way of this Complaint against Defendant Motorola Mobility LLC (“Motorola” or “Defendant”), alleges as follows: PARTIES 1. Plaintiff Complex Memory is a limited liability company organized and existing under the laws of the State of Texas, having its principal place of business at 17330 Preston Road, Suite 200D, Dallas, Texas 75252. 2. On information and belief, Defendant Motorola is a Delaware limited liability company headquartered at 222 W. Merchandise Mart Plaza, Chicago, IL 60654. JURISDICTION AND VENUE 3. This is an action under the patent laws of the United States, 35 U.S.C. §§ 1, et seq., for infringement by Motorola of claims of U.S. Patent Nos. 5,890,195; 5,963,481; 6,658,576; 6,968,469; and 7,730,330 (“the Patents-in-Suit”). 4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 5. Motorola is subject to personal jurisdiction of this Court because, inter alia, on 1 Case: 1:18-cv-06255 Document #: 1 Filed: 09/13/18 Page 2 of 19 PageID #:2 information and belief, (i) Motorola is registered to transact business in the State of Illinois; (ii) Motorola conducts business in the State of Illinois and maintains a facility and employees within the State of Illinois; and (iii) Motorola has committed and continues to commit acts of patent infringement in the State of Illinois, including by making, using, offering to sell, and/or selling accused products and services in the State of Illinois, and/or importing accused products and services into the State of Illinois.
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