IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SDI TECHNOLOGIES, INC.

, Plaintiff,
v.
) ) ) )

)
) ) ) )

C.A. No. _ _ __
DEMAND FOR JURY TRIAL

BOSE CORPORATION, Defendant.

COMPLAINT FOR PATENT INFRINGEMENT

For its Complaint, plaintiff alleges as follows:

PARTIES, JURISDICTION, AND VENUE

1.

Plaintiff SDI Technologies, Inc. ("SDI") is a corporation organized and

existing under the laws of the State of Delaware and having its principal place of business at 1299 Main Street, Rahway, NJ. 2. Defendant Bose Corporation ("BOSE") is a corporation organized and

existing under the laws of the State of Delaware and having its principal place of business at The Mountain, Framingham, MA. 3. This infringement action arises under the patent laws of the United States,

Title 35 of the United States Code. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 1331 and 1338(a). 4. Upon information and belief, defendant Bose resides in this judicial

District pursuant to 28 U.S.C. 1391(c), and venue in this judicial District is proper under 28 U.S.C. 1391(c) and 1400(b).

THE PATENT-IN-SUIT 5. Plaintiff SDI is a global leader in the research and development,

manufacture, and sale of high quality sound systems and other consumer products. SDI currently markets and sells a line of speaker systems under the iHome brand. 6. Plaintiff SDI is the owner by assignment of United States Patent

No. 7,738,247 ("the '247 Patent"), entitled "Removable and Replaceable Docking Unit." The '247 Patent was duly and legally issued by the United States Patent and Trademark Office to inventor Thomas Choi on June 15, 2010. A copy of the '247 patent is attached hereto as Exhibit A. 7. Many of SDI's e award-winning iHome speaker products incorporate the

patented technology in the '24 7 Patent. COUNT I

INFRINGEMENT OF U.S. PATENT No.

7,738,247

8.

Plaintiff SDI re-alleges and incorporates herein by reference the

allegations set forth in the preceding paragraphs of this Complaint. 9. Defendant Bose manufactures and sells consumer electronics, including a

remote-controlled speaker system known as the SoundDock 10 digital music system. 10. Defendant Bose, through its manufacture, use, offering for sale, sale,

and/or importation ofthe SoundDock 10 and any other like models has infringed the '247 patent, literally and/or by equivalents, in this judicial District and elsewhere, and will continue to infringe unless enjoined by this Court. 11. Plaintiff SDI has been irreparably harmed by Bose's infringement to an

extent not yet determined, and will continue to be irreparably harmed in the future unless Bose is enjoined from its infringing activities by this Court.
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PRAYER FOR RELIEF

WHEREFORE, plaintiff SDI requests the following relief: A. That this Court adjudge and decree that Bose has infringed the '247 Patent

under 35 U.S.C. 271;

B.

That this Court preliminarily and permanently enjoin Bose and its officers,

agents, servants, employees, representatives, successors, and assigns, and all others acting in active concert or participation with them, from continued infringement of the '247 Patent; C. That this Court award plaintiff SDI damages resulting from Bose's

infringement, including an accounting of all infringing sales not presented at trial and an award by the Court of any additional damages for any such infringing sales; D. of 35 U.S.C. 285;
E.

That this Court declare this to be an exceptional case within the meaning

That this Court award plaintiff SDI its costs in this action, together with

reasonable attorneys' fees and pre-judgment and post-judgment interest; and F. That this Court grant plaintiff SDI such other relief as is just and proper.

Smith II (#3778) Jeremy . Tigan (#5239) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 (302) 658-9200 rsmith@mnat.com jtigan@mnat.com Attorneys for SDI Technologies, Inc.

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OF COUNSEL: Matthew B. Lowrie Aaron W. Moore FOLEY & LARDNER LLP 111 Huntington A venue Boston, MA 02199 (617) 342-4000 November 15,2011
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