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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN

TRW AUTOMOTIVE U.S. LLC., PLAINTIFF, v. MAGNA ELECTRONICS INC. DEFENDANT. JURY TRIAL DEMANDED COMPLAINT Plaintiff TRW Automotive U.S. LLC (TRW), for its Complaint against Defendant Magna Electronics Inc. (Magna), states as follows: PARTIES AND JURISDICTION 1. This action arises under the Patent Laws of the United States, United States Code, Civil Action No.

Title 35, 1, et. seq. The Court has jurisdiction over the subject matter of this action pursuant 28 USC 1331 and 1338. 2. TRW is a Delaware corporation with a facility at 12001 Tech Center Dr., Livonia,

Michigan 48150. 3. Magna is a Delaware corporation, registered to do business in the State of

Michigan with a registered office of 601 Abbott Road, East Lansing, Michigan 48823 and is doing business in this District. 4. Magna has been and still is making, using, selling and/or offering for sale, and

contributing and inducing others to make, use, sell and offer for sale: (1) image enhancing systems for vehicles, including but not limited to rear-view vehicle cameras and (2) apparatuses

for road profile prediction that fall within the scope of the patent asserted below, generally throughout the United States and in this judicial district in particular, in violation of 35 U.S.C. 271. COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,807,287 5. reference. 6. United States Patent No. 6,807,287 entitled Road Profile Prediction TRW re-alleges paragraphs 1-4 above, inclusive, which are incorporated by

(hereinafter, the 287 patent, a copy of which is attached hereto as Exhibit A), was duly and legally issued on October 19, 2004. 7. TRW is the owner by assignment of all right, title and interest in the 287 patent,

including the right to sue for past acts of infringement. 8. Magna has been and is now infringing the 287 patent, in violation of 35 U.S.C.

271(a) by at least its manufacture, use, sales and offers for sale and importation of apparatuses for road profile prediction, including but not limited to Magnas camera-based driver assistance system, and methods of use of the same as claimed in the 287 patent. 9. Magna has been and is now infringing the 287 patent, in violation of 35 U.S.C.

271(b) and (c) through its contribution and inducement of others to make, use, sell, offer for sale and import apparatuses for road profile prediction, including but not limited to Magnas camerabased driver assistance system, and methods of use of the same as claimed in the 045 patent. COUNT II: INFRINGEMENT OF U.S. PATENT NO. 8,233,045 10. reference. 11. United States Patent No. 8,233,045 entitled Method and Apparatus for Distortion TRW re-alleges paragraphs 1-9 above, inclusive, which are incorporated by

Correction and Image Enhancing of a Vehicle Rear Viewing System (hereinafter, the 045 2

patent, a copy of which is attached hereto as Exhibit B), was duly and legally issued on July 31, 2012. 12. TRW is the owner by assignment of all right, title and interest in the 045 patent,

including the right to sue for past acts of infringement. 13. Magna has been and is now infringing the 045 patent, in violation of 35 U.S.C.

271(a) by at least its manufacture, use, sales and offers for sale and importation of image enhancing systems for vehicles, including but not limited to Magnas Rear Vision Cameras, and methods of use of the same as claimed in the 045 patent. 14. Magna has been and is now infringing the 045 patent, in violation of 35 U.S.C.

271(b) and (c) through its contribution and inducement of others to make, use, sell, offer for sale and import image enhancing systems for vehicles, including but not limited to Magnas Rear Vision Cameras, and methods of use of the same as claimed in the 045 patent. REQUEST FOR RELIEF WHEREFORE, TRW respectfully requests that the Court enter a judgment: A. B. Declaring that Magna has infringed the 287 and 045 Patents. Enjoining Magna, its subsidiaries, agents, officers, employees, directors, licensees, servants, successors, assigns and all others acting in privity or in concert with them, from infringing, actively inducing infringement or contributing to infringement of the 287 and 045 Patents. Awarding TRW damages adequate to compensate for Magnas infringing activities, together with interest; Awarding TRW such other and further relief as the Court may deem just and proper. JURY DEMAND Plaintiff TRW demands a trial by jury as to all claims and all issues properly triable thereby.

C.

D.

Dated: June 24, 2013

Respectfully submitted, TRW AUTOMOTIVE U.S. LLC By: /s/ Allan J. Sternstein One Of Their Attorneys

Allan J. Sternstein Timothy K. Sendek Michael S. Golenson DYKEMA GOSSETT PLLC 10 South Wacker Drive Suite 2300 Chicago, Illinois 60606.7509 312 876 1700 Mark J. Magyar DYKEMA GOSSETT PLLC 300 Ottawa Ave., N.W. Suite 700 Grand Rapids, MI 49503 616-776-7500