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ADOBE SYSTEMS INC v MACROMEDIA INC Click to find out why . . .



Keywords & Phrases
CaseNo: ASIVMI167337, CourtName: AND TRADEMARK ACT, 35 U.S.C. ET SEQ. THIS COURT HAS SUBJECT MATTER JURISDICTION, Plaintiff: ADOBE SYSTEMS INC, State: DE Delaware, UniqueCaseRef: LCD>ASIVMI167337, Adobe, Macromedia, Patent, Infringement, Adobe Alleges, Tabbed Palettes, Competes, Incorporate, Acts, Feature, Photoshop, Flash, Damages, Conference, Industry Standard, Induce, Commit, Enjoining, Acting, District, Delaware Corporation, San Francisco, Graphics, Imageready, Golivetm, Livemotion, Interface, Marketing, Functionality , ContentID: 120249943

Case Documents
1   COMPLAINT
[ see first page and extracted highlights below  ] ItemID: 123628
8 pages
PDF
Total Documents: 1 document , 8 pages
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1 . COMPLAINT

EXTRACTED KEY WORDS
MACROMEDIA
PATENT
INFRINGEMENT
ADOBE ALLEGES
TABBED PALETTES
COMPETES
INCORPORATE
COURT
ACTS
FEATURE
PHOTOSHOP
FLASH
DAMAGES
CONFERENCE
INDUSTRY STANDARD
INDUCE
COMMIT
ENJOINING
ACTING
DISTRICT
DELAWARE CORPORATION
SAN FRANCISCO
GRAPHICS
IMAGEREADY
GOLIVETM
LIVEMOTION
INTERFACE
MARKETING
FUNCTIONALITY
                      IN THE UNITED STATES DISTRICT COURT

                           FOR THE DISTRICT OF DELAWARE


ADOBE SYSTEMS INCORPORATED,

                       Plaintiff,

       v.                                        Civil Action. No. ___________

MACROMEDIA, INC.,                                DEMAND FOR JURY TRIAL

                       Defendant.


                     COMPLAINT FOR PATENT INFRINGEMENT

              Plaintiff ADOBE SYSTEMS INCORPORATED ("Adobe") alleges as

follows:

                                     JURISDICTION

              1.       This is an action for patent infringement arising under the Patent

and Trademark Act, 35 U.S.C. § 1  et seq.  This Court has subject matter jurisdiction

under 28 U.S.C. § 1338.

                                         VENUE

              2.       Venue is proper in this judicial district under 28 U.S.C. § 1391.

                                        PARTIES

              3.       Adobe is a Delaware corporation with its principal place of

business located at 345 Park Avenue, San Jose, California 95110.



               4.      Adobe alleges on information and belief that Macromedia, Inc.

("Macromedia") is a Delaware corporation with its principal place of business located at

600 Townsend Street, San Francisco, California 94103.

                             ADOBE AND ITS PRODUCTS
SNIPPETS:
  • IN THE UNITED STATES DISTRICT COURT
  • Plaintiff ADOBE SYSTEMS INCORPORATED alleges as
  • This is an action for patent infringement arising under the Patent
  • Adobe alleges on information and belief that Macromedia,
  • is a Delaware corporation with its principal place of business located at
  • 600 Townsend Street, San Francisco, California 94103.
  • Adobe ImageReadytm, Adobe Illustrator®, Adobe Acrobat®, Adobe GoLivetm, Adobe
  • generally described as the Adobe User Interface or the "Adobe UI."
  • Adobe devotes substantial resources to marketing and advertising
  • Adobe UI and the functionality therein.
  • The tabbed palette feature is an immediately recognizable portion
  • Adobe and Macromedia compete in the field of Web design tools.
  • Adobe's Photoshop and ImageReady products compete with Macromedia's Fireworks
  • Adobe's LiveMotion product competes with Macromedia's Flashtm authoring product;
  • has been the existence of the Adobe UI, including tabbed palettes.
  • previewed the upcoming release of Flash 5.0 on March 27,
  • flashforward2000 conference by showing the UI and asking the audience whether it
  • would be more familiar to graphics professionals who use industry standard products.
  • Adobe alleges on information and belief that the reference to industry standard products
  • Macromedia product to incorporate the new Macromedia UI.
  • and continues to induce others to infringe and/or has committed and continues to commit
  • acts of contributory infringement of, one or more claims of the `528 Patent.
  • injunction is issued enjoining Macromedia and its agents, servants, employees, attorneys,
  • representatives, and all others acting on their behalf, from infringing the `528 Patent,
  • Adobe has suffered monetary damages in an amount not
  •    |