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Case 2:07-cv-00146-LED Document 1 Filed 04/18/2007 Page 1 of 4
1. This is a claim for patent infringement arising under the patent laws of the
United States, Title 35 of the United States Code. This Court has exclusive jurisdiction
principal place of business at 1000 E. William Street, Suite 204, Carson City, Nevada
89701.
4. Together, Plaintiffs own the right, title and interest in and have standing to
sue for infringement of United States Patent No. 5,072,412 (the “‘412 Patent”) entitled
“User Interface With Multiple Workspaces for Sharing Display System Objects” which
Dockets.Justia.com
Case 2:07-cv-00146-LED Document 1 Filed 04/18/2007 Page 2 of 4
5. Apple Inc. (“Apple”) is a California corporation that has its principal offices
6. Apple transacts business in this judicial district and has committed acts of
infringement in this judicial district, at least by selling and offering for sale its Mac OS X
v10.4 “Tiger” operating system which is accused of infringing the ‘412 Patent in this
8. Apple has infringed, and is now directly infringing at least claim 21 of the
'412 Patent through, among other activities, the manufacture, use, sale, offer for sale
and/or importation into the United States of its Mac OS X v10.4 “Tiger” operating
system. Apple has also infringed at least claim 21 of the ‘412 Patent by knowingly and
intentionally aiding, assisting and encouraging the infringement of others through the
manufacture, sale, offer for sale and/or importation into the United States of the Mac OS
has injured Plaintiffs and Plaintiffs are entitled to recover damages adequate to
compensate them for such infringement, but in no event less than a reasonable royalty.
Based upon information and belief, Plaintiffs’ damages incurred to date exceed $20
million.
10. Apple has received notice of its infringement of the ‘412 Patent pursuant
to 35 U.S.C. §287.
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Case 2:07-cv-00146-LED Document 1 Filed 04/18/2007 Page 3 of 4
has been willful and deliberate and has injured and will continue to injure Plaintiffs,
unless and until this Court enters an injunction prohibiting further infringement of the
‘412 Patent.
Corporation respectfully request this Court enter judgment against defendant Apple Inc.,
and against its subsidiaries, successors, parents, affiliates, officers, directors, agents,
servants, employees, and all persons in active concert or participation with it, granting
the date the infringement began, but in no event less than a reasonable
F. Such other relief that plaintiffs are entitled to under law and any other and
further relief that this Court or a jury may deem just and proper.
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Case 2:07-cv-00146-LED Document 1 Filed 04/18/2007 Page 4 of 4
Jury Demand
Respectfully submitted,
____________________________________
T. John Ward, Jr.
State Bar No. 00794818