IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
High Tech Computer Corp., a/k/a HTC Corp.,
HTC (B.V.I.) Corp., HTC America, Inc.,
JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Apple Inc. (“Apple”), for its Complaint against High Tech Computer Corp.,
a/k/a/ HTC Corp. (“HTC Corp.”), HTC (B.V.I.) Corp. (“HTC BVI”), HTC America, Inc. (“HTC
America”), and Exedea, Inc. (“Exedea”) (collectively, “Defendants”), hereby alleges as follows:
Plaintiff Apple is a corporation organized under the laws of the state of California
with its principal place of business at 1 Infinite Loop, Cupertino, California 95014. Apple is a
leading designer and manufacturer of innovative computer technologies, including personal
computers, mobile communications devices, portable digital music and video players, and related
Upon information and belief, Defendant HTC Corp. is a corporation organized
and existing under the laws of Taiwan with its principal place of business at 23 Xinghau Road,
Taoyuan 330, Taiwan, Republic of China. Upon information and belief, Defendant HTC Corp.
Case 1:99-mc-09999 Document 92 Filed 03/02/10 Page 1 of 16
is engaged in the design, manufacture, importation into the United States, and sale after
importation of mobile communication devices and services.
Upon information and belief, Defendant HTC BVI is a wholly-owned subsidiary
of Defendant HTC Corp. and is incorporated under the laws of the British Virgin Islands with its
principal place of business at 3F, Omar Hodge Building, Wickhams Cay I, P.O. Box 362, Road
Town, Tortola, British Virgin Islands. Upon information and belief, Defendant HTC BVI is
engaged in global investing and related activities on behalf of its parent, Defendant HTC Corp.
and is itself a parent company of additional Defendants.
Upon information and belief, Defendan