Case 2:22-cv-11403-TGB ECF No. 1, PageID.2 Filed 03/29/22 Page 2 of 16 registered agent, Corporation Service Company, 50 West Broad Street, Suite 1330, Columbus, Ohio 43215.
Defendants, both directly and through their subsidiaries or intermediaries (including distributors, retailers, and others), have purposefully and voluntarily placed one or more infringing products and/or services, as described below, into the stream of commerce with the
These infringing products and/or services have been and continue to be made, used, sold, offered for sale, purchased, and/or imported by customers and/or consumers in the Southern District of Ohio.
The inventors saw an opportunity to create a new wireless communication system meant to address those flaws while incorporating cutting-edge Orthogonal Frequency-Division Multiple Access (OFDMA) based technologies, and, starting in the 2004-2005 timeframe, they filed patents on the work.
Similarly, Honda’s advertising, sales, design, development, and/or technical materials related to the 3GPP LTE/4G and/or 5G/NR standards associated with the Accused Products contained and continue to contain instructions, directions, suggestions, and/or invitations Case 2:22-cv-11403-TGB ECF No. 1, PageID.11 Filed 03/29/22 Page 11 of 16 that invite, entice, lead on, influence, encourage, prevail on, move by persuasion, and/or cause its subsidiaries, distributors, retailers, dealerships, customers, and the public to directly infringe at least one claim of each of the Patents-in-Suit, either literally or under the doctrine of equivalents.