Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 1 of 18 PageID #: 1744
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Civil Action No. 10-389-LPS
`
`DEMAND FOR JURY TRIAL
`
`)))))))))))))))))))))))))))
`
`SOFTVIEW LLC,
`
`Plaintiff,
`
`
`
`v.
`
`
`
`
`
`APPLE INC.; AT&T MOBILITY LLC;
`DELL INC.; HTC CORP.; HTC
`AMERICA, INC.; EXEDEA, INC.;
`HUAWEI TECHNOLOGIES CO., LTD.;
`HUAWEI TECHNOLOGIES USA INC.;
`HUAWEI DEVICE USA INC.; KYOCERA
`CORP.; KYOCERA WIRELESS CORP.;
`LG ELECTRONICS, INC.; LG
`ELECTRONICS USA, INC.; LG
`ELECTRONICS MOBILECOMM U.S.A,
`INC.; MOTOROLA MOBILITY INC.;
`SAMSUNG ELECTRONICS CO., LTD.;
`SAMSUNG ELECTRONICS AMERICA,
`INC.; SAMSUNG
`TELECOMMUNICATIONS AMERICA,
`LLC.; SONY ERICSSON MOBILE
`COMMUNICATIONS AB; and SONY
`ERICSSON MOBILE
`COMMUNICATIONS (USA) INC,
`
`
`
`Defendants.
`
`PLAINTIFF SOFTVIEW LLC'S
`SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff SoftView LLC ("SoftView"), by and through its undersigned counsel, for its
`
`Second Amended Complaint against Apple Inc.; AT&T Mobility LLC; Dell Inc.; HTC
`
`Corp.; HTC America, Inc.; Exedea, Inc.; Huawei Technologies Co., Ltd.; Huawei
`
`Technologies USA; Huawei Device USA Inc.; Kyocera Corp.; Kyocera Wireless Corp.; LG
`
`Electronics, Inc.; LG Electronics USA, Inc.; LG Electronics MobileComm U.S.A, Inc.;
`
`Motorola Mobility Inc.; Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.;
`
`Motorola PX 1018_1
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 2 of 18 PageID #: 1745
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 2 of 18 PageID #: 653
`
`Telecommunications America LLC.; Sony Ericsson Mobile Communications AB; and Sony
`Telecommunications America LLC.; Sony Ericsson Mobile Communications AB; and Sony
`Telecommunications America LLC.; Sony Ericsson Mobile Communications AB; and Sony
`
`Ericsson Mobile Communications (USA) Inc. (collectively, "Defendants") alleges as
`Ericsson Mobile Communications (USA)
`Inc.
`(collectively, "Defendants") alleges as
`Ericsson Mobile Communications (USA)
`Inc.
`(collectively, "Defendants") alleges as
`
`follows:
`follows:
`follows:
`
`NATURE OF THE ACTION
`NATURE OF THE ACTION
`NATURE OF THE ACTION
`
`I.
`I.
`I.
`
`This is an action for patent infringement arising under the United States
`This is an action for patent infringement arising under the United States
`This is an action for patent infringement arising under the United States
`
`Patent Act, 35 U.S.C. § 101 et seq., including 35 U.S.C. § 271. This Court has subject
`Patent Act, 35 U.S.C. § 101 et seq., including 35 U.S.C. § 271. This Court has subject
`Patent Act, 35 U.S.C. § 101 et seq., including 35 U.S.C. § 271. This Court has subject
`
`matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a) in that this is a civil action
`matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a) in that this is a civil action
`matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a) in that this is a civil action
`
`arising out of the patent laws of the United States of America.
`arising out of the patent laws of the United States of America.
`arising out of the patent laws of the United States of America.
`
`JURISDICTION AND VENUE
`JURISDICTION AND VENUE
`JURISDICTION AND VENUE
`
`2.
`2.
`2.
`
`This Court has personal jurisdiction over the Defendants. On information
`This Court has personal jurisdiction over the Defendants. On information
`This Court has personal jurisdiction over the Defendants. On information
`
`and belief, Defendants have committed acts of infringement in this District, regularly do and
`and belief, Defendants have committed acts of infringement in this District, regularly do and
`and belief, Defendants have committed acts of infringement in this District, regularly do and
`
`solicit business in Delaware, and have availed themselves of the benefits and protections of
`solicit business in Delaware, and have availed themselves of the benefits and protections of
`solicit business in Delaware, and have availed themselves of the benefits and protections of
`
`Delaware law.
`Delaware law.
`Delaware law.
`
`3.
`3.
`3.
`
`Venue in this District is proper under 28 U.S.C. §§ 1391(c) and 1400(b)
`Venue in this District is proper under 28 U.S.C. §§ 1391(c) and 1400(b)
`Venue in this District is proper under 28 U.S.C. §§ 1391(c) and 1400(b)
`
`because, among other reasons, Defendants are subject to personal jurisdiction in this District
`because, among other reasons, Defendants are subject to personal jurisdiction in this District
`because, among other reasons, Defendants are subject to personal jurisdiction in this District
`
`and have committed acts of infringement in this District, and AT&T Mobility LLC, Dell
`and have committed acts of infringement in this District, and AT&T Mobility LLC, Dell
`and have committed acts of infringement in this District, and AT&T Mobility LLC, Dell
`
`Inc., Kyocera Wireless Corp., Motorola Mobility Inc., Samsung Telecommunications
`Inc., Kyocera Wireless Corp., Motorola Mobility Inc., Samsung Telecommunications
`Inc., Kyocera Wireless Corp., Motorola Mobility Inc., Samsung Telecommunications
`
`America, and Sony Ericsson Mobile Communications (USA) Inc. are incorporated in this
`America, and Sony Ericsson Mobile Communications (USA) Inc. are incorporated in this
`America, and Sony Ericsson Mobile Communications (USA) Inc. are incorporated in this
`
`District.
`District.
`District.
`
`THE PARTIES
`THE PARTIES
`THE PARTIES
`
`4.
`4.
`4.
`
`SoftView is a Washington limited liability company with its principal place
`SoftView is a Washington limited liability company with its principal place
`SoftView is a Washington limited liability company with its principal place
`
`of business at 112 Ohio St., Suite 202, Bellingham, Washington 98225.
`of business at 112 Ohio St., Suite 202, Bellingham, Washington 98225.
`of business at 112 Ohio St., Suite 202, Bellingham, Washington 98225.
`
`- 2 ­
`
`- 2 -- 2 -
`
`Motorola PX 1018_2
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 3 of 18 PageID #: 1746
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 3 of 18 PageID #: 654
`
`APPLE
`
`APPLE
`APPLE
`
`5.
`5.
`5.
`
`SoftView is infonned and believes that Apple Inc. ("Apple") is a California
`SoftView is infonned and believes that Apple Inc. ("Apple") is a California
`SoftView is infonned and believes that Apple Inc. ("Apple") is a California
`
`corporation with its principal place of business at 1 Infinite Loop, Cupertino, California
`corporation with its principal place of business at 1 Infinite Loop, Cupertino, California
`corporation with its principal place of business at 1 Infinite Loop, Cupertino, California
`
`95014.
`95014.
`95014.
`
`6.
`6.
`6.
`
`Apple makes, uses, offers to sell, and sells devices, including but not limited
`Apple makes, uses, offers to sell, and sells devices, including but not limited
`Apple makes, uses, offers to sell, and sells devices, including but not limited
`
`to devices sold under the trade names iPad, iPhone, and iPod Touch, which themselves
`to devices sold under the trade names iPad, iPhone, and iPod Touch, which themselves
`to devices sold under the trade names iPad, iPhone, and iPod Touch, which themselves
`
`include, without limitation, the Safari web browser (collectively, the "Apple Accused
`include, without
`limitation,
`the Safari web browser (collectively,
`the "Apple Accused
`include, without
`limitation,
`the Safari web browser (collectively,
`the "Apple Accused
`
`Products").
`Products").
`Products").
`
`AT&T
`AT&T
`AT&T
`
`7.
`7.
`7.
`
`SoftView is infonned and believes that AT&T Mobility LLC ("AT&T") is a
`SoftView is infonned and believes that AT&T Mobility LLC ("AT&T") is a
`SoftView is infonned and believes that AT&T Mobility LLC ("AT&T") is a
`
`Delaware limited liability company with its principal place of business at 208 S. Akard St.,
`Delaware limited liability company with its principal place of business at 208 S. Akard St.,
`Delaware limited liability company with its principal place of business at 208 S. Akard St.,
`
`Dallas, Texas 75202. AT&T is a wholly-owned subsidiary of AT&T Inc., a Delaware
`Dallas, Texas 75202. AT&T is a wholly-owned subsidiary of AT&T Inc., a Delaware
`Dallas, Texas 75202. AT&T is a wholly-owned subsidiary of AT&T Inc., a Delaware
`
`corporation with its principal place of business at 208 S. Akard St., Dallas, Texas 75202.
`corporation with its principal place of business at 208 S. Akard St., Dallas, Texas 75202.
`corporation with its principal place of business at 208 S. Akard St., Dallas, Texas 75202.
`
`AT&T's registered agent is The Corporation Trust Company, Corporation Trust Center,
`AT&T's registered agent is The Corporation Trust Company, Corporation Trust Center,
`AT&T's registered agent is The Corporation Trust Company, Corporation Trust Center,
`
`1209 Orange Street, Wilmington, Delaware 19801.
`1209 Orange Street, Wilmington, Delaware 19801.
`1209 Orange Street, Wilmington, Delaware 19801.
`
`DELL
`DELL
`DELL
`
`8.
`8.
`8.
`
`SoftView is infonned and believes that Dell Inc. ("Dell") is a Delaware
`SoftView is infonned and believes that Dell Inc. ("Dell") is a Delaware
`SoftView is infonned and believes that Dell Inc. ("Dell") is a Delaware
`
`corporation with its principal place of business at One Dell Way, Round Rock, Texas 78682.
`corporation with its principal place of business at One Dell Way, Round Rock, Texas 78682.
`corporation with its principal place of business at One Dell Way, Round Rock, Texas 78682.
`
`Dell's agent for service of process is Corporation Service Company, 2711 Centerville Road,
`Dell's agent for service of process is Corporation Service Company, 2711 Centerville Road,
`Dell's agent for service of process is Corporation Service Company, 2711 Centerville Road,
`
`Suite 400, Wilmington, Delaware 19808.
`Suite 400, Wilmington, Delaware 19808.
`Suite 400, Wilmington, Delaware 19808.
`
`9.
`9.
`9.
`
`Dell makes, uses, offers to sell, and sells devices having the Android
`Dell makes, uses, offers to sell, and sells devices having the Android
`Dell makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Streak and Venue (collectively, the "Dell Accused Products").
`trade names Streak and Venue (collectively, the "Dell Accused Products").
`trade names Streak and Venue (collectively, the "Dell Accused Products").
`
`- 3 ­
`- 3 -
`- 3 -
`
`Motorola PX 1018_3
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 4 of 18 PageID #: 1747
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 4 of 18 PageID #: 655
`
`HTe
`
`HTe
`HTe
`
`10.
`10.
`10.
`
`SoftView is informed and believes that HTC Corp. aIkIa High Tech
`SoftView is informed and believes that HTC Corp. aJk/a High Tech
`SoftView is informed and believes that HTC Corp. aJk/a High Tech
`
`Computer Corp. ("HTC COrp.") is a Taiwanese corporation with its principal place of
`Computer Corp. ("HTC COrp.") is a Taiwanese corporation with its principal place of
`Computer Corp. ("HTC COrp.") is a Taiwanese corporation with its principal place of
`
`business located at 23 Xinghua Rd., Taoyuan 330, Taiwan, Republic of China.
`business located at 23 Xinghua Rd., Taoyuan 330, Taiwan, Republic of China.
`business located at 23 Xinghua Rd., Taoyuan 330, Taiwan, Republic of China.
`
`11.
`11.
`11.
`
`SoftView is informed and believes that HTC America, Inc. ("HTC America")
`SoftView is informed and believes that HTC America, Inc. ("HTC America")
`SoftView is informed and believes that HTC America, Inc. ("HTC America")
`
`is a wholly-owned subsidiary of Defendant HTC Corp. and is incorporated under the laws of
`is a wholly-owned subsidiary of Defendant HTC Corp. and is incorporated under the laws of
`is a wholly-owned subsidiary of Defendant HTC Corp. and is incorporated under the laws of
`
`the State of Texas, with its principal place of business at 13920 SE Eastgate Way, Suite 400,
`the State of Texas, with its principal place of business at 13920 SE Eastgate Way, Suite 400,
`the State of Texas, with its principal place of business at 13920 SE Eastgate Way, Suite 400,
`
`Bellevue, Washington 98005.
`Bellevue, Washington 98005.
`Bellevue, Washington 98005.
`
`12.
`12.
`12.
`
`SoftView is informed and believes that Exedea, Inc. (tlExedea") is a wholly-
`SoftView is informed and believes that Exedea, Inc. ("Exedea") is a wholly-
`SoftView is informed and believes that Exedea, Inc. ("Exedea") is a wholly-
`
`owned subsidiary of HTC Corp. and is incorporated under the laws of the State of Texas,
`owned subsidiary of HTC Corp. and is incorporated under the laws of the State of Texas,
`owned subsidiary of HTC Corp. and is incorporated under the laws of the State of Texas,
`
`with its principal place of business at 5950 Corporate Drive, Houston, Texas 77036.
`with its principal place of business at 5950 Corporate Drive, Houston, Texas 77036.
`with its principal place of business at 5950 Corporate Drive, Houston, Texas 77036.
`
`Defendants HTC Corp., HTC America, and Exedea are collectively referred to herein as
`Defendants HTC Corp., HTC America, and Exedea are collectively referred to herein as
`Defendants HTC Corp., HTC America, and Exedea are collectively referred to herein as
`
`"HTC."
`"HTC."
`"HTC."
`
`13.
`13.
`13.
`
`HTC makes, uses, offers to sell, and sells devices having the Android
`HTC makes, uses, offers to sell, and sells devices having the Android
`HTC makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Aria, Desire, Dream, Eris, EVO, Hero, Incredible, Inspire, G I, G2, Legend,
`trade names Aria, Desire, Dream, Eris, EVO, Hero, Incredible, Inspire, G I, G2, Legend,
`trade names Aria, Desire, Dream, Eris, EVO, Hero, Incredible, Inspire, G I, G2, Legend,
`
`Magic, MyTouch, Nexus, Tattoo, Thunderbolt, Shift, and Wildfire (collectively, the "HTC
`Magic, MyTouch, Nexus, Tattoo, Thunderbolt, Shift, and Wildfire (collectively, the "HTC
`Magic, MyTouch, Nexus, Tattoo, Thunderbolt, Shift, and Wildfire (collectively, the "HTC
`
`Accused Products").
`Accused Products").
`Accused Products").
`
`HUAWEI
`HUAWEI
`HUAWEI
`
`14.
`14.
`14.
`
`SoftView is informed and believes that Huawei Technologies Co., Ltd.
`SoftView is informed and believes that Huawei Technologies Co., Ltd.
`SoftView is informed and believes that Huawei Technologies Co., Ltd.
`
`("Huawei Chinaf1
`) is a Chinese company, with its principal place of business at HQ Office
`("Huawei China") is a Chinese company, with its principal place of business at HQ Office
`("Huawei China") is a Chinese company, with its principal place of business at HQ Office
`
`Building, Huawei Industrial Base, Bantian, Longgang District, Shenzhen 518129, People's
`Building, Huawei Industrial Base, Bantian, Longgang District, Shenzhen 518129, People's
`Building, Huawei Industrial Base, Bantian, Longgang District, Shenzhen 518129, People's
`
`Republic of China.
`Republic of China.
`Republic of China.
`
`- 4­
`
`- 4-- 4-
`
`Motorola PX 1018_4
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 5 of 18 PageID #: 1748
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 5 of 18 PageID #: 656
`
`15.
`15.
`15.
`
`SoftView is infonned and believes that FutureWei Technologies, Inc. d/b/a!
`SoftView is infonned and believes that FutureWei Technologies, Inc. d/b/a!
`SoftView is infonned and believes that FutureWei Technologies, Inc. d/b/a!
`
`Huawei Technologies USA, Inc. ("Huawei USA") is a wholly owned subsidiary of Huawei
`Huawei Technologies USA, Inc. ("Huawei USA") is a wholly owned subsidiary of Huawei
`Huawei Technologies USA, Inc. ("Huawei USA") is a wholly owned subsidiary of Huawei
`
`China and is incorporated under the laws of the State of Texas, with its principal place of
`China and is incorporated under the laws of the State of Texas, with its principal place of
`China and is incorporated under the laws of the State of Texas, with its principal place of
`
`business at 5700 Tennyson Parkway, Suite 500, Plano, TX 75024.
`business at 5700 Tennyson Parkway, Suite 500, Plano, TX 75024.
`business at 5700 Tennyson Parkway, Suite 500, Plano, TX 75024.
`
`16.
`16.
`16.
`
`SoftView is infonned and believes that Huawei Device USA Inc. ("Huawei
`SoftView is infonned and believes that Huawei Device USA Inc. ("Huawei
`SoftView is infonned and believes that Huawei Device USA Inc. ("Huawei
`
`Device") is a subsidiary of Huawei China and is incorporated under the laws of the State of
`Device") is a subsidiary of Huawei China and is incorporated under the laws of the State of
`Device") is a subsidiary of Huawei China and is incorporated under the laws of the State of
`
`Texas, with its principal place of business at 5700 Tennyson Parkway, Suite 500, Plano, TX
`Texas, with its principal place of business at 5700 Tennyson Parkway, Suite 500, Plano, TX
`Texas, with its principal place of business at 5700 Tennyson Parkway, Suite 500, Plano, TX
`
`75024. Defendants Huawei China, Huawei USA, and Huawei Device are collectively
`75024. Defendants Huawei China, Huawei USA, and Huawei Device are collectively
`75024. Defendants Huawei China, Huawei USA, and Huawei Device are collectively
`
`referred to herein as "Huawei. II
`referred to herein as "Huawei."
`referred to herein as "Huawei. II
`
`17.
`17.
`17.
`
`Huawei makes, uses, offers to sell, and sells devices having the Android
`Huawei makes, uses, offers to sell, and sells devices having the Android
`Huawei makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Ascend, IDEOS, M860, and Comet (collectively, the "Huawei Accused
`the "Huawei Accused
`trade names Ascend, IDEaS, M860, and Comet (collectively,
`the "Huawei Accused
`trade names Ascend, IDEaS, M860, and Comet (collectively,
`
`Products").
`Products").
`Products").
`
`KYOCERA
`KYOCERA
`KYOCERA
`
`18.
`18.
`18.
`
`SoftView is infonned and believes that Kyocera Corp. ("Kyocera Corp.") is a
`SoftView is infonned and believes that Kyocera Corp. ("Kyocera Corp.") is a
`SoftView is infonned and believes that Kyocera Corp. ("Kyocera Corp.") is a
`
`Japanese Corporation with its principal place of business at 6 Takeda Tobadono-Cho,
`Japanese Corporation with its principal place of business at 6 Takeda Tobadono-Cho,
`Japanese Corporation with its principal place of business at 6 Takeda Tobadono-Cho,
`
`Fushimi-Ku, Kyoto 612-8501, Japan.
`Fushimi-Ku, Kyoto 612-8501, Japan.
`Fushimi-Ku, Kyoto 612-8501, Japan.
`
`19.
`19.
`19.
`
`SoftView is infonned and believes that Kyocera Wireless Corp. ("Kyocera
`SoftView is infonned and believes that Kyocera Wireless Corp. ("Kyocera
`SoftView is infonned and believes that Kyocera Wireless Corp. ("Kyocera
`
`Wireless") is incorporated under the laws of the State of Delaware, with its principal place
`Wireless") is incorporated under the laws of the State of Delaware, with its principal place
`Wireless") is incorporated under the laws of the State of Delaware, with its principal place
`
`of business at 10300 Campus Point Drive, San Diego, California 92121. Kyocera Wireless's
`of business at 10300 Campus Point Drive, San Diego, California 92121. Kyocera Wireless's
`of business at 10300 Campus Point Drive, San Diego, California 92121. Kyocera Wireless's
`
`registered agent for service of process is located at Corporation Service Company, 2711
`registered agent for service of process is located at Corporation Service Company, 2711
`registered agent for service of process is located at Corporation Service Company, 2711
`
`Centerville Road Suite 400, Wilmington, Delaware 19808. Defendants Kyocera Corp. and
`Centerville Road Suite 400, Wilmington, Delaware 19808. Defendants Kyocera Corp. and
`Centerville Road Suite 400, Wilmington, Delaware 19808. Defendants Kyocera Corp. and
`
`Kyocera Wireless are collectively referred to herein as "Kyocera."
`Kyocera Wireless are collectively referred to herein as "Kyocera."
`Kyocera Wireless are collectively referred to herein as "Kyocera."
`
`- 5 ­
`
`- 5 -- 5 -
`
`Motorola PX 1018_5
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 6 of 18 PageID #: 1749
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 6 of 18 PageID #: 657
`
`20.
`20.
`20.
`
`Kyocera makes, uses, offers to sell, and sells devices having the Android
`Kyocera makes, uses, offers to sell, and sells devices having the Android
`Kyocera makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Echo and Zio (collectively, the "Kyocera Accused Products").
`trade names Echo and Zio (collectively, the "Kyocera Accused Products").
`trade names Echo and Zio (collectively, the "Kyocera Accused Products").
`
`LG
`LG
`LG
`
`21.
`21.
`21.
`
`SoftView is
`SoftView is
`SoftView is
`
`informed and believes that LG Electronics, Inc. ("LG
`informed and believes
`that LG Electronics,
`Inc.
`("LG
`informed and believes
`that LG Electronics,
`Inc.
`("LG
`
`Electronics") is a Korean corporation with a principal place of business at LG Twin Towers
`Electronics") is a Korean corporation with a principal place of business at LG Twin Towers
`Electronics") is a Korean corporation with a principal place of business at LG Twin Towers
`
`20, Yeouido-dong, Yeongdeunspo-gu, Seoul 150-721, South Korea.
`20, Yeouido-dong, Yeongdeunspo-gu, Seoul 150-721, South Korea.
`20, Yeouido-dong, Yeongdeunspo-gu, Seoul 150-721, South Korea.
`
`22.
`22.
`22.
`
`SoftView is informed and believes that LG Electronics USA, Inc. C'LG
`SoftView is informed and believes that LG Electronics USA, Inc. ("LG
`SoftView is informed and believes that LG Electronics USA, Inc. ("LG
`
`Mobile") is a wholly owned subsidiary of LG Electronics and is incorporated under the laws
`Mobile") is a wholly owned subsidiary of LG Electronics and is incorporated under the laws
`Mobile") is a wholly owned subsidiary of LG Electronics and is incorporated under the laws
`
`of the State of Delaware, with its principal place of business at 1000 Sylvan A venue,
`of the State of Delaware, with its principal place of business at 1000 Sylvan Avenue,
`of the State of Delaware, with its principal place of business at 1000 Sylvan Avenue,
`
`Englewood Cliffs, New Jersey 07632. LG Mobile's registered agent for service of process is
`Englewood Cliffs, New Jersey 07632. LG Mobile's registered agent for service of process is
`Englewood Cliffs, New Jersey 07632. LG Mobile's registered agent for service of process is
`
`United States Corporation Company, 2711 Centerville Road, Suite 400, Wilmington,
`United States Corporation Company, 2711 Centerville Road, Suite 400, Wilmington,
`United States Corporation Company, 2711 Centerville Road, Suite 400, Wilmington,
`
`Delaware 19808.
`Delaware 19808.
`Delaware 19808.
`
`23.
`23.
`23.
`
`SoftView is informed and believes that LG Electronics MobileComm U.S.A,
`SoftView is informed and believes that LG Electronics MobileComm U.S.A,
`SoftView is informed and believes that LG Electronics MobileComm U.S.A,
`
`Inc. C'LG MobileComm") is a wholly owned subsidiary of LG Electronics and LG Mobile
`Inc. C'LG MobileComm") is a wholly owned subsidiary of LG Electronics and LG Mobile
`Inc. C'LG MobileComm") is a wholly owned subsidiary of LG Electronics and LG Mobile
`
`and is incorporated under the laws of the State of California, with its principal place of
`and is incorporated under the laws of the State of California, with its principal place of
`and is incorporated under the laws of the State of California, with its principal place of
`
`business at 10101 Old Grove Road, San Diego, CA 92131. Defendants LG Electronics, LG
`business at 10101 Old Grove Road, San Diego, CA 92131. Defendants LG Electronics, LG
`business at 10101 Old Grove Road, San Diego, CA 92131. Defendants LG Electronics, LG
`
`Mobile, and LG MobileComm are collectively referred to herein as "LG."
`Mobile, and LG MobileComm are collectively referred to herein as "LG."
`Mobile, and LG MobileComm are collectively referred to herein as "LG."
`
`24.
`24.
`24.
`
`LG makes, uses, offers to sell, and sells devices having the Android
`LG makes, uses, offers to sell, and sells devices having the Android
`LG makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Ally, Apex, Axis, Eve, GW620, Optimus, and Vortex (collectively, the "LG
`trade names Ally, Apex, Axis, Eve, GW620, Optimus, and Vortex (collectively, the "LG
`trade names Ally, Apex, Axis, Eve, GW620, Optimus, and Vortex (collectively, the "LG
`
`Accused Products"),
`Accused Products").
`Accused Products").
`
`- 6­
`
`- 6-- 6-
`
`Motorola PX 1018_6
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 7 of 18 PageID #: 1750
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 7 of 18 PageID #: 658
`
`MOTOROLA
`MOTOROLA
`
`MOTOROLA
`
`25.
`25.
`25.
`
`SoftView is informed and believes that Motorola Mobility Inc. ("Motorola")
`SoftView is informed and believes that Motorola Mobility Inc. ("Motorola")
`SoftView is informed and believes that Motorola Mobility Inc. ("Motorola")
`
`is incorporated under the laws of the State of Delaware, with its principal place of business
`is incorporated under the laws of the State of Delaware, with its principal place of business
`is incorporated under the laws of the State of Delaware, with its principal place of business
`
`at 600 North U.S. Highway 45, Libertyville, Illinois 60048.
`at 600 North U.S. Highway 45, Libertyville, Illinois 60048.
`at 600 North U.S. Highway 45, Libertyville, Illinois 60048.
`
`Motorola makes, uses, offers to sell, and sells devices having the Android
`26.
`26. Motorola makes, uses, offers to sell, and sells devices having the Android
`26.
`Motorola makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names iI, Atrix, Backflip, Bionic, Bravo, Charm, Citrus, CLIQ, Defy, Devour, Droid,
`trade names iI, Atrix, Backflip, Bionic, Bravo, Charm, Citrus, CLIQ, Defy, Devour, Droid,
`trade names iI, Atrix, Backflip, Bionic, Bravo, Charm, Citrus, CLIQ, Defy, Devour, Droid,
`
`FlipOut, FlipSide, and Zoom (collectively, the "Motorola Accused Products").
`FlipOut, FlipSide, and Zoom (collectively, the "Motorola Accused Products").
`FlipOut, FlipSide, and Zoom (collectively, the "Motorola Accused Products").
`
`SAMSUNG
`SAMSUNG
`SAMSUNG
`
`27.
`27.
`27.
`
`SoftView is informed and believes that Samsung Electronics Co., Ltd.
`SoftView is informed and believes that Samsung Electronics Co., Ltd.
`SoftView is informed and believes that Samsung Electronics Co., Ltd.
`
`("Samsung Electronics") is a corporation organized and existing under the laws of the
`("Samsung Electronics") is a corporation organized and existing under the laws of the
`("Samsung Electronics") is a corporation organized and existing under the laws of the
`
`Republic of Korea and has its principal place of business at Samsung Electronics Building,
`Republic of Korea and has its principal place of business at Samsung Electronics Building,
`Republic of Korea and has its principal place of business at Samsung Electronics Building,
`
`1320-10, Seocho 2-dong, Seocho-gu, Seoul 137-857, Republic of Korea.
`1320-10, Seocho 2-dong, Seocho-gu, Seoul 137-857, Republic of Korea.
`1320-10, Seocho 2-dong, Seocho-gu, Seoul 137-857, Republic of Korea.
`
`28.
`28.
`28.
`
`SoftView is informed and believes that Samsung Electronics America, Inc.
`SoftView is informed and believes that Samsung Electronics America, Inc.
`SoftView is informed and believes that Samsung Electronics America, Inc.
`
`("Samsung America") is incorporated under the laws of the State of New York, with its
`("Samsung America") is incorporated under the laws of the State of New York, with its
`("Samsung America") is incorporated under the laws of the State of New York, with its
`
`principal place of business at 105 Challenger Road, Ridgefield Park, NJ 07660.
`principal place of business at 105 Challenger Road, Ridgefield Park, NJ 07660.
`principal place of business at 105 Challenger Road, Ridgefield Park, NJ 07660.
`
`29.
`29.
`29.
`
`SoftView is informed and believes that Samsung Telecommunications
`SoftView is informed and believes that Samsung Telecommunications
`SoftView is informed and believes that Samsung Telecommunications
`
`America, LLC ("Samsung Telecom") is incorporated under the laws of the State of
`America, LLC ("Samsung Telecom") is incorporated under the laws of the State of
`America, LLC ("Samsung Telecom") is incorporated under the laws of the State of
`
`Delaware, with its principal place of business at 1301 E. Lookout Dr., Richardson, TX
`Delaware, with its principal place of business at 1301 E. Lookout Dr., Richardson, TX
`Delaware, with its principal place of business at 1301 E. Lookout Dr., Richardson, TX
`
`75082. Defendants Samsung Electronics, Samsung America, and Samsung Telecom are
`75082. Defendants Samsung Electronics, Samsung America, and Samsung Telecom are
`75082. Defendants Samsung Electronics, Samsung America, and Samsung Telecom are
`
`collectively referred to herein as "Samsung,"
`collectively referred to herein as "Samsung."
`collectively referred to herein as "Samsung."
`
`30.
`30.
`30.
`
`Samsung makes, uses, offers to sell, and sells devices having the Android
`Samsung makes, uses, offers to sell, and sells devices having the Android
`Samsung makes, uses, offers to sell, and sells devices having the Android
`
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`Operating System and a web browser, including but not limited to devices sold under the
`
`trade names Acclaim, Behold, Captivate, Continuum, Epic, Fascinate, Galaxy, Gem, i5500,
`trade names Acclaim, Behold, Captivate, Continuum, Epic, Fascinate, Galaxy, Gem, i5500,
`trade names Acclaim, Behold, Captivate, Continuum, Epic, Fascinate, Galaxy, Gem, i5500,
`
`- 7 ­
`- 7 -
`- 7 -
`
`Motorola PX 1018_7
`
`

`

`Case 1:10-cv-00389-LPS Document 108-3 Filed 09/30/11 Page 8 of 18 PageID #: 1751
`Case 1:10-cv-00389-LPS Document 61-1 Filed 04/22/11 Page 8 of 18 PageID #: 659
`
`Intercept, Mesmerize, Moment, Nexus, Spica, and Teos (collectively,
`the "Samsung
`Intercept, Mesmerize, Moment, Nexus, Spica, and Teos (collectively, the "Samsung
`Intercept, Mesmerize, Moment, Nexus, Spica, and Teos (collectively,
`the "Samsung
`
`Accused Products").
`Accused Products").
`Accused Products").
`
`SONY ERICSSON
`SONY ERICSSON
`SONY ERICSSON
`
`31.
`31.
`31.
`
`SoftView is
`SoftView
`is
`SoftView is
`
`infonned
`and
`believes
`infonned and believes
`infonned
`and
`believes
`
`that Sony Ericsson Mobile
`that Sony Ericsson Mobile
`that
`Sony Ericsson Mobile
`
`Communications AB ("Sony Ericsson Comm") is a Swedish Limited Liability Company
`Communications AB ("Sony Ericsson Comm") is a Swedish Limited Liability Company
`Communications AB ("Sony Ericsson Comm") is a Swedish Limited Liability Company
`
`with its principal place of business at Nya Vattentornet, SE-221 88 Lund, Sweden.
`with its principal place of business at Nya Vattentornet, SE-221 88 Lund, Sweden.
`with its principal place of business at Nya Vattentornet, SE-221 88 Lund, Sweden.
`
`Defendant Sony Ericsson Comm is the parent of the Sony Ericsson group of companies,
`Defendant Sony Ericsson Comm is the parent of the Sony Ericsson group of companies,
`Defendant Sony Ericsson Comm is the parent of the Sony Ericsson group of companies,
`
`which are located worldwide (including named Defendant Sony