Google, Inc. v. Eolas Technologies Inc. et al

Filing 1

COMPLAINT against Eolas Technologies Incorporated. The Regents of the University of California. Filed byGoogle, Inc.(Filing fee $400.00, receipt number 0971-8262256.). (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Civil Cover Sheet)(Mitro, Keith) (Filed on 12/30/2013) Modified on 12/31/2013 (ha, COURT STAFF). Modified on 1/3/2014 (jlmS, COURT STAFF).

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Exhibit C MCKOOL SMITH John B. Campbell Direct Dial: (512) 692-8730 Jcampbell~mckoolsmith.com 300 W. 6th Street Suite 1700 Austin, TX 78701 Telephone: (512) 692-8700 Facsimile: (512) 692-8744 December 19, 2013 VIA CERTIFIED MAIL Google Inc. c/o Corporation Service Company d/b/a CSC 701 Brazos Street, Suite 1050 Austin, Texas 78701-3232 RE: Infringement of United States Patent Nos. 8,082,293 and 8,086,662 Dear Google Inc., I write on behalf of our client Eolas Technologies Incorporated, who has an exclusive license to United States Patent Nos. 8,082,293 and 8,086,662 ("the '293 and '662 Patents"). The '293 and '662 Patents are entitled "Distributed hypermedia method and system for automatically invoking external application providing interaction and display of embedded objects within a hypermedia document" and were issued on December 20, 2011 and December 27, 2011, respectively. Copies of the '293 and '662 Patents are enclosed for your convenience. We are making you aware of the '293 and '662 Patents because we believe that by making, using, selling, offering to sell, and/or importing in or into the United States: (i) web pages and content to be interactively presented in browsers, including, without limitation, the web pages and content accessible via www.google.com and maintained on servers located in and/or accessible from the United States under the control of Google; (ii) software, including, without limitation, browser software and software that allows content to be interactively presented in and/or served to browsers, including, without limitation, Chrome for Windows and Chrome for the Mac; and/or (iii) computer equipment, including, without limitation, computer equipment that stores, serves, and/or runs any of the foregoing that Google directly infringes the '293 and '662 Patents. In addition, we believe that Google indirectly infringes one or more claims of the '293 and '662 Patents by active inducement under 35 U. S.C. § 27 1(b) by inducing and continuing to induce users of the web pages, software, and computer equipment identified above to directly infringe one or more claims of the '293 and '662 Patents. We believe Google indirectly infringes one or more claims of the '293 and '662 Patents by contributory infringement under 35 U.S.C. § 271(c) by providing the web pages, software, and computer equipment identified above to users of said web pages, software, and computer equipment. Please provide us with assurance that you will immediately cease and desist from engaging in the foregoing acts that constitute infringement of the '293 and '662 Patents. McKool Smith Austin I Dallas I Houston I McKool 947471vl A Professional Corporation -Attorneys Los Angeles I Marshall I New York I Silicon Valley I Washington, DC December 19, 2013 Page 2 Best regards, John B. Campbell JBC Enclosures cc: Doug Lumish Latham & Watkins 140 Scott Drive Menlo Park, CA 94025 McKool 947471v I MC~oo SMIH PROFESSIONAL CORPORATION - ATI-ORNEYS 300 W. 6iii STRI~ET, 17TH F,.on Austin, Texas 78701-3232 CSC 701 Brazos Street, Suite 1050 Google Inc. c/o Corporation Service Company d/b/a ?000 1670 0011 5380 000.3 *0$08.172 01I221

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