Case 6:15-cv-00244-RWS-JDL Document 1 Filed 03/20/15 Page 1 of 4 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`Civil Action No. 6:15-cv-244
`
`JURY TRIAL DEMANDED
`
`
`ROTHSCHILD LOCATION
`TECHNOLOGIES LLC,
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`
`
`
`MOTOROLA SOLUTIONS, INC.,
`
`
`
`
`
`Defendant.
`
`
`
`
`
`ORIGINAL COMPLAINT
`
`Plaintiff Rothschild Location Technologies LLC (“Rothschild” or “Plaintiff”) files this
`
`Amended Complaint for patent infringement against Motorola Solutions, Inc. (“Motorola” or
`
`“Defendant”) alleging as follows:
`
`PARTIES
`
`1.
`
`Plaintiff Rothschild is limited liability company organized under the state of Texas
`
`having a principal place of business at 815 Brazos St., Ste. 500, Austin, TX 78701.
`
`2.
`
`On information and belief, Defendant Motorola is a corporation organized and
`
`existing under the laws of the State of Delaware, with its principal place of business located at
`
`1303 East Algonquin Road, Schaumburg, IL 60196. On information and belief, Motorola may be
`
`served via its registered agent, The Corporation Trust Company, 1209 Orange St., Wilmington,
`
`DE 19801.
`
`JURISDICTION AND VENUE
`
`3.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`Civil Action No. 6:15-cv-244
`
`JURY TRIAL DEMANDED
`
`
`ROTHSCHILD LOCATION
`TECHNOLOGIES LLC,
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`
`
`
`MOTOROLA SOLUTIONS, INC.,
`
`
`
`
`
`Defendant.
`
`
`
`
`
`ORIGINAL COMPLAINT
`
`Plaintiff Rothschild Location Technologies LLC (“Rothschild” or “Plaintiff”) files this
`
`Amended Complaint for patent infringement against Motorola Solutions, Inc. (“Motorola” or
`
`“Defendant”) alleging as follows:
`
`PARTIES
`
`1.
`
`Plaintiff Rothschild is limited liability company organized under the state of Texas
`
`having a principal place of business at 815 Brazos St., Ste. 500, Austin, TX 78701.
`
`2.
`
`On information and belief, Defendant Motorola is a corporation organized and
`
`existing under the laws of the State of Delaware, with its principal place of business located at
`
`1303 East Algonquin Road, Schaumburg, IL 60196. On information and belief, Motorola may be
`
`served via its registered agent, The Corporation Trust Company, 1209 Orange St., Wilmington,
`
`DE 19801.
`
`JURISDICTION AND VENUE
`
`3.
`
`This action arises under the patent laws of the United States, Title 35 of the United
`
`States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`
`
`Case 6:15-cv-00244-RWS-JDL Document 1 Filed 03/20/15 Page 2 of 4 PageID #: 2
`
`4.
`
`Venue is proper in this district under 28 U.S.C. §§ 1391(c) and 1400(b). On
`
`information and belief, Defendant has transacted business in this district, and has committed acts
`
`of patent infringement in this district.
`
`5.
`
`Defendant is subject to this Court’s specific and general personal jurisdiction
`
`pursuant to due process and/or the Texas Long Arm Statute, due at least to its substantial business
`
`in this forum, including: (i) at least a portion of the infringements alleged herein; and (ii) regularly
`
`doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving
`
`substantial revenue from goods and services provided to individuals in Texas and in this judicial
`
`district.
`
`U.S. PATENT NO. 7,917,285
`
`6.
`
`Plaintiff is the owner by assignment of United States Patent No. 7,917,285 (the
`
`“’285 Patent”) entitled “Device, system and method for remotely entering, storing and sharing
`
`addresses for a positional information device.” The ’285 Patent issued on March 29, 2011. A true
`
`and correct copy of the ’285 Patent is attached as Exhibit A.
`
`7.
`
`8.
`
`Mr. Leigh M. Rothschild is listed as the inventor on the ’285 Patent.
`
`On information and belief, to the extent any marking was required by 35 U.S.C.
`
`§ 287, predecessors in interest to the ’285 Patent complied with such requirements.
`
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. 7,917,285)
`
`Motorola has, pursuant to 35 U.S.C. § 271, infringed and continues to infringe, the
`
`9.
`
`’285 Patent in the State of Texas, in this judicial district, and/or elsewhere in the United States by,
`
`among other things, making, using, selling, offering to sell, and/or importing, without license,
`
`
`
`Case 6:15-cv-00244-RWS-JDL Document 1 Filed 03/20/15 Page 3 of 4 PageID #: 3
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`systems for remotely entering and sharing location information, such as Motorola’s Fleet
`
`Management.
`
`10. Motorola’s Fleet Management falls within the scope of at least claim 1 of the ’285
`
`Patent, as evidenced by Motorola’s product descriptions. For example, Motorola’s Fleet
`
`Management provides a system for remotely entering location information into a positional
`
`information
`
`device.
`
`
`
`See
`
`http://www.motorolasolutions.com/US-
`
`EN/Business+Solutions/Industry+Solutions/Transportation+and+Logistics/Fleet+Management+a
`
`nd+Delivery+Operations/Fleet+Management+Solutions. The Fleet Management server is
`
`configured to receive a request of at least one location, determine the address of the at least one
`
`location and transmit the determined address to the positional information device. For example,
`
`Fleet Management provides for “dispatching and scheduling” as well as “optimizing routes.” Id.
`
`11.
`
`As a result of Motorola’s infringement of the ’285 Patent, Plaintiff has suffered
`
`monetary damages in an amount not yet determined, and will continue to suffer damages in the
`
`future unless Motorola’s infringing activities are enjoined by this Court..
`
`12.
`
`Unless a permanent injunction is issued enjoining Motorola and its agents, servants,
`
`employees, attorneys, representatives, affiliates, and all others acting on their behalf from
`
`infringing the ’285 Patent, Plaintiff will be irreparably harmed.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff respectfully requests that this Court enter:
`
`1.
`
`2.
`
`A judgment in favor of Plaintiff that Motorola has infringed the ’285 Patent;
`
`A permanent injunction enjoining Motorola and its officers, directors, agents
`
`servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in
`
`
`
`Case 6:15-cv-00244-RWS-JDL Document 1 Filed 03/20/15 Page 4 of 4 PageID #: 4
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`active concert therewith from infringement of the ’285 Patent, or such other equitable relief the
`
`Court determines is warranted;
`
`3.
`
`A judgment and order requiring Motorola pay Plaintiff its damages, costs,
`
`expenses, and prejudgment and post-judgment interest for Defendant’s infringement of the ’285
`
`Patent as provided under 35 U.S.C. § 284, and an accounting of ongoing post-judgment
`
`infringement;
`
`4.
`
`Any and all other relief, at law or equity, to which Plaintiff may show itself to be
`
`entitled.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of
`
`any issues so triable by right.
`
`DATED March 20, 2015.
`
`
`
`
`
`
`
`Respectfully submitted,
`By: /s/ Hao Ni
`
`Hao Ni
`Texas Bar No. 24047205
`hni@nilawfirm.com
`Timothy T. Wang
`Texas Bar No. 24067927
`twang@nilawfirm.com
`Neal G. Massand
`Texas Bar No. 24039038
`nmassand@nilawfirm.com
`Stevenson Moore V
`Texas Bar No. 24076573
`smoore@nilawfirm.com
`
`NI, WANG & MASSAND, PLLC
`8140 Walnut Hill Ln., Ste. 500
`Dallas, TX 75231
`Tel: (972) 331-4600
`Fax: (972) 314-0900
`
`ATTORNEYS FOR PLAINTIFF
`ROTHSCHILD LOCATION
`TECHNOLOGIES, LLC
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