UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PRINCETON DIGITAL IMAGE CORPORATION, Plaintiff, v.

KYOCERA COMMUNICATIONS, INC., a Delaware Corporation; KYOCERA ELECTRONIC DEVICES, LLC, a Delaware Limited Liability Company; KYOCERA WIRELESS CORPORATION, a Delaware Corporation; KYOCERA AMERICA, INC., a California Corporation; KYOCERA INTERNATIONAL, INC., a California Corporation; KYOCERA DOCUMENT SOLUTIONS AMERICA, INC., a California Corporation, registered as a foreign corporation in Delaware; KYOCERA DOCUMENT SOLUTIONS DEVELOPMENT AMERICA, INC., a California Corporation; and KYOCERA CORPORATION, a Japanese Corporation, Defendants. COMPLAINT Plaintiff, Princeton Digital Image Corporation (hereafter Princeton), brings this action against Defendants Kyocera Communications, Inc., Kyocera Electronic Devices LLC, Kyocera Wireless Corporation, Kyocera America, Inc., Kyocera International, Inc., Kyocera Document ) ) ) ) ) ) ) ) ) ) ) ) Case No. ) ) JURY TRIAL DEMANDED ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Solutions America, Inc., Kyocera Document Solutions Development America, Inc., and Kyocera Corporation (hereinafter collectively Kyocera Defendants), and in support thereof alleges as follows: THE PARTIES 1. of Texas. 2. Defendant Kyocera Communications, Inc. is a Delaware corporation having as its Plaintiff Princeton is a corporation organized and doing business under the laws

agent for service of process Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808. Upon information and belief, Defendant Kyocera Communications, Inc. regularly conducted and transacted business in Delaware within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 3. Defendant Kyocera Electronic Devices, LLC is a Delaware limited liability

company having as its agent for service of process Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808. Upon information and belief, Defendant Kyocera Electronic Devices, LLC regularly conducted and transacted business in Delaware within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 4. Defendant Kyocera Wireless Corporation is a Delaware corporation having as its

agent for service of process Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808. Upon information and belief, Defendant Kyocera Wireless Corporation regularly conducted and transacted business in Delaware within this Judicial District, and

throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 5. Defendant Kyocera America, Inc. is a California corporation having its principal

place of business at 8611 Balboa Avenue, San Diego, California 92123, and having as its agents for service of process CSC Lawyers Incorporation Service, 2710 Gateway Oaks Drive, Suite 150N, Sacramento, CA 95833. Upon information and belief, Defendant Kyocera America, Inc. regularly conducted and transacted business in Delaware and within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 6. Defendant Kyocera International, Inc. is a California corporation having its

principal place of business at 8611 Balboa Avenue, San Diego, California 92123, and having as its agents for service of process CSC Lawyers Incorporation Service, 2710 Gateway Oaks Drive, Suite 150N, Sacramento, CA 95833. Upon information and belief, Defendant Kyocera International, Inc. regularly conducted and transacted business in Delaware and within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 7. Defendant Kyocera Document Solutions America, Inc. is a California Corporation

with its principal place of business at 225 Sand Road, Fairfield, NJ 07004. Defendant Kyocera Document Solutions America, Inc. is registered as a foreign corporation in the State of Delaware, having as its agents for service of process Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808. Upon information and belief, Defendant Kyocera Document Solutions America, Inc. regularly conducted and transacted business in Delaware and within this

Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 8. Defendant Kyocera Document Solutions Development America, Inc. is a

California Corporation with its principal place of business at 225 Sand Road, Fairfield, NJ 07004, and having as its agent for service of process Atsushi Yuki, 1855 Gateway Boulevard, Concord, CA 94520. Upon information and belief, Defendant Kyocera Document Solurions Development America, Inc. is a subsidiary corporation of Defendant Kyocera Document Solutions, America. Upon information and belief, Kyocera Document Solutions Development America, Inc. regularly conducted and transacted business in Delaware and within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. 9. On information and belief, Defendant Kyocera Corporation is a Japanese

corporation with its principal place of business at 6 Takeda Tobadono-cho, Fushimi-ku, Kyoto,612-8501, Japan. Upon information and belief, Defendant Kyocera Corporation is an alien corporation to the United States of America and is a nonresident corporation of Delaware who engages in business in this state, but does not maintain a regular place of business in this state and which has not designated an agent for service of process in this state. Upon information and belief, Kyocera Corporation regularly conducted and transacted business in Delaware and within this Judicial District, and throughout the United States, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. On information and belief, Kyocera Corporation resides in this jurisdiction within the meaning of 28 U.S.C. 1400(b). This proceeding arises, in part, out of business done in this state. Kyocera Corporation may be served with process in Korea pursuant to the Hague Convention on the Service Abroad

of Judicial and Extrajudicial Documents, Article 1, November 15, 1965 T.I.A.S. No. 6638, 20 U.S.T. 361 (U.S. Treaty 1969). JURISDICTION AND VENUE 10. This is an action for patent infringement of a United States patent. Accordingly,

this action arises under the patent laws of the United States of America, 35 U.S.C. 1 et seq. 11. Jurisdiction for this action is based on 35 U.S.C. 271 and 28 U.S.C. 1331,

1338(a), and 1400(b). 12. Upon information and belief, Kyocera Defendants have solicited and done

business in the State of Delaware, and have attempted to derived financial benefit from doing business with residents of the State of Delaware, including financial benefits directly related to the instant cause of action for patent infringement. 13. Upon information and belief, Kyocera Defendants have committed acts of patent

infringement in this district, and, therefore, this Court also has specific jurisdiction of Kyocera Defendants. 14. Upon information and belief, promotional and sales material associated with

Kyocera Defendants infringing products has been made available and distributed in print and on the Internet within this judicial district. 15. Venue is proper in this judicial district under 28 U.S.C. 1391 and 1400(b) in

that, among other things, several Kyocera Defendants are registered in the State of Delaware as domestic and foreign corporations, and acts of infringement complained of have been committed in this judicial district.

BACKGROUND 16. On March 14, 1989, United States Patent No. 4,813,056 (hereafter the 056

Patent) was duly and legally issued to Nicola J. Fedele, as the inventor thereof, and at all applicable times was valid and subsisting. A copy of the 056 Patent, which is entitled Modified Statistical Coding of Digital Signals, is attached hereto as Exhibit A. 17. Nicola J. Fedele originally assigned his rights to the 056 Patent to General

Electric Company, which assigned all rights, title and interest in and to the 056 Patent to Princeton Digital Image Compression, LLC. Princeton Digital Image Compression, LLC has assigned all rights, title and interest in and to the 056 Patent to Princeton Digital Image Corporation, Plaintiff herein, the current holder of the 056 Patent. FACTS AND STATEMENT OF CLAIM 18. Plaintiff Princeton repeats and re-alleges each and every statement contained in

the preceding paragraphs as if fully set forth at length herein. 19. Kyocera Defendants have infringed the 056 Patent in that without authority it

made, used, offered to sell, sold, and/or imported products and methods that infringed the 056 Patent, including, but not limited to, cell phones employing cameras and certain Mita and other copier, scanner and multi-function products. 20. Upon information and belief, Kyocera Defendants have induced others to

manufacture, import, use, sell, and/or offer to sell products that infringe one or more claims of the 056 Patent in that Kyocera Defendants induced others to manufacture, import, use, sell, and/or offer to sell the infringing products at a time when it knew that such actions constituted patent infringement. Kyocera Defendants actions constituted a contributory infringement of the 056 Patent in violation of 35 U.S.C. 271(c) and/or the active inducement of others under 35

U.S.C. 271(b) to engage in direct infringement under 35 U.S.C. 271(a) with a knowledge of and an intent to induce specific infringement. 21. On information and belief, Kyocera Defendants jointly infringed the 056 Patent

through knowing, significant, active, and intentional actions with one or more persons and/or entities to manufacture, import, distribute, offer to sell, sell, and use Defendants infringing products. 22. Because of the relationship between Defendants, infringements of the 056 patent

arise out of the same transaction or series of transactions, and involve common issues of fact. 23. Defendants were given notice of infringement of the 056 Patent on or before

May 16, 2006. Despite that notice, Defendants continued to infringe the 056 Patent. 24. Upon information and belief, Defendants acts of infringement of the 056 Patent

were both deliberate and willful. 25. Princeton is entitled to recover from Defendants those damages sustained as a

result of Defendants wrongful acts of infringement of the 056 Patent in an amount subject to proof at trial. PRAYER AND RELIEF WHEREFORE, Princeton prays for the following relief: A. a judgment declaring that Defendants, jointly and/or severally, and any joint

infringers, have infringed Plaintiff Princetons 056 Patent; B. recover damages from Defendants resulting from Defendants infringement, and

that said damages be enhanced in view of Defendants willful and wanton conduct; C. recover interest and costs pursuant to 35 U.S.C. 284 and attorneys fees

pursuant to 35 U.S.C. 285; and

D. circumstances.

such other and further relief as the Court deems just and proper under the

JURY DEMAND Plaintiff Princeton demands a trial by jury of all issues properly triable by jury in this action.

Respectfully submitted,

OKELLY ERNST & BIELLI, LLC Dated: December 26, 2012 /s/ Sean T. OKelly Sean T. OKelly (No. 4349) 901 N. Market Street, Suite 1000 Wilmington, Delaware 19801 (302) 778-4000 (302) 295-2873 (facsimile) sokelly@oeblegal.com Attorneys for Plaintiff Princeton Digital Image Corporation