Professional Documents
Culture Documents
I
(ORDINARY ORIGINAL CIVIL JURISDICTION)
VERSUS
INDEX II
IA No. of 2014
In
CS (OS) No. of 2014
VERSUS
1. That the Plaintiffs have filed the present suit for permanent
Plaintiffs crave the leave of this Hon'ble Court to rely upon the
Avenue, 15th Floor, New York, New York 10017. The Plaintiff
No.1, which is a wholly owned subsidiary of Vringo, Inc., i.e .
Avenue, 15th Floor, New York, NY 10017. The Plaintiff No. 2 was
of Directors.
The Plaintiff No.2 currently offers its social and video ringtone
the suit patent was filed on 14.2.1997 seeking priority from the
and interests inter alia in the suit patent for the entire term of
the patent including rights that enure upon the patent prior to
Plaintiff No.1.
7. That both the aforesaid assignments have been confirmed and
have been filed with the Chennai Patent Office and the same
'572 and has the statutory right to prevent anyone from using
herein below.
MSC
BTS 1
..
BTS 2 41
Handover control
BTS M
Register 1 Counter 1
,_.J32
Register 2 ~---
Counter 2
Register M Counter M
of:
threshold value 'N' maybe set for each base station and for
are set out in detail in the Complete Specification and the same
& devices, etc. The Defendants Nos. 3 and 4 sell their devices
13. That the Defendants are infringing the suit patent of the
Plaintiff No.1 by
14. That by vi'rtue of Section 48 of the Patents Act, 1970 during the
life time and subsistence of the suit patent - the Plaintiff No.1 is
legally entitled to prevent any third party who does not have its
has instituted this suit for infringement of its patent and is filing
have any office in India and hence a greater need to secure the
inasmuch as the Plaintiff No.1 's rights in the suit patent are
17. That the suit patent was brought to the notice of the
the present case are different, thus, the Plaintiffs are instituting
No. l's right in the suit patent in accordance with the relevant
the expert affidavit being filed by the Plaintiffs with the present
19. That in light of the fact that the Plaintiff no.1 has valid and
existing rights in the suit pate.nt, the prima facie case exists in
its favour. Further, as the Plaintiff no.1 has duly informed the
illegally earn profits are infringing the Plaintiff No.1 's right in
the suit patent. Also, irreparable harm and loss shall be caused
by the Defendants.
PRAYER:
information:
suit:
v. Any other order/s which this Hon'ble Court may deem fit and
New Delhi
Certified l
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142737
Sandra J. Tallman
Special Deputy Secretary of State
VERSUS
AFFIDAVIT
Affidavit of Mr. David L Cohen S/o Mr. Ben T. Cohen, aged about 42
years, working at Vr.ingo Inc. at 780, Third Avenue, .15th Floor, New
as under:
same are not being repeated herein for the sake of brevity.
that the contents of the same are true and correct as per my
1-e.
~~~~t~f 1teNe~ 0Y~rk, ~ 4. ~.7J. . . . . .... . . .~~~- -
1
} ss.: ....... .. ..
l, NORMAN GOO M/N, C ounty Clerk and Cleric of the Supreme C o urt at the State al
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
belief. I say that no part of it is false and nothing material has been
DEPONENT
David L Cohen
S-to.-te.d New yor l . <; s, Chief Legal and IP Officer
Covrrty o~ Nt\V Yori:. . Vringo Inc.
Vringo Infrastructure Inc.
Swotn torrtL-th1s 17th
ao.y
rtf TcJ.'MJfAry Aol~
!<ltm~-~
SAM G. LEFFELL \ \
.*' '
Notaiy Public, State of New York
No. 01LE6283831
Qualifled In New York County
Commission Explree June 17, 2017
BEFORE THE HIGH COURT OF DELHI AT NEW DELHI
(Ordinary Original Civil Jurisdiction)
IA No. of 2014
In
CS(OS) NO. of 2014
VERSUS
1. That the Plaintiffs have filed the present suit for permanent
Plaintiffs crave the leave of this Hon'ble Court to rely upon the
and that the Defendants were indeed infringing the suit patent.
PRAYER
3. Any further orders that this Hon'ble Court may deem fit and
proper in the int erest of justice and equity.
New Delhi
Dated: January, 20 14
0
Certified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142738
VERSUS
AFFIDAVIT
Affidavit of Mr. David L Cohen S/o Mr. Ben T. Cohen, aged about 42
years, working at Vringo Inc. at 780, Third Avenue, 15th Floor, New
as under:
same are not being repeated herein for the sake of brevity.
that the contents of the same are true and correct as per my
~':~':. ~1 07';J,;0f~,;, I"' 549 66
1, NORMAN GOODM/ N, County Clerk and Cleric of the Suprem e Court ot the State o1
~~ ':'.:' '.
N1~w York, In and for t he County cw Yo rk, a Court of R~~n having by law a seal,
;~;;~;~::~:::~.:,c;:~:;': :, ":~;;::'.Ii:~~.~~
time of taking the same a NOT A BLI C in and for the State of
qualitied to act as such; that pursuant to law, a commiHion or a cc i
,, .::.~:~:~'.'. . .
tc of his official character, with his
autograph signature has been 6lcJ in mv office; that ac the time o f talc.in such proof, acknowled~mcnt or oath, he
was tlulv authorized to take the sarnc; thlt I nm well acquainted with the handwriting of such N O TARY PUBLI
or have compared the signature on the Qnnexed Instrument with his autograph signature deposited In my offic .-..---
1 believe that such signature is genuine.
IN WITNESS WHEREOF, l have here unto set my hand affixed my official seal thb
J
F~E;~i'o''$;J;O'''"''JAN ..2i2a1~~ .::
County Cln'k and Cl"k oj t Suprtrr:~ C0tirt, N nu York COt1nly \I
---- -
own knowledge and as per information received and believed to
~DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
Verified at 07; .}J\ LJ51.j\ on this Iq. day of January, 2014 that
the contents of my above affidavit are true to my knowledge and
belief. I say that no part of it is false and nothing material has been
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
SAM G. LEFFELL
Notary Publlo,Slate of New York
No. 01LE62.83831
~
Qualified In New York Countv
CaM1isSiOfl Explrel June 17, 2017
~N \
\
- 1
:) /
):> /
....
BEFORE THE HIGH COURT OF DELHI AT NEW DELHI
(Ordinary Original Civil Jurisdiction)
IA No. of 2014
In
CS(OS) NO. of 2014
VERSUS
under:
1. That the Plaintiffs have filed the present suit for permanent
rely upon the averments set forth in the instant suit, the
brevity.
the same.
PRAYER
b. Any other order/s which this Hon'ble Court may deem fit
and proper in the interest of justice of equity;
C~rtified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142739
Sandra J. Ta llman
*! Special Deputy Secretary of State
VERSUS
AFFIDAVIT
Affidavit of Mr. David L Cohen S/o Mr. Ben T. Cohen, aged about 42
years, working at Vringo Inc. at 780, Third Avenue, 15th Floor, New
as under:
same are not being repeated herein for the sake of brevity.
that the contents of the same are true and correct as per my
State of New York
County of New Yorlc, } ss.:
~972 Forru l
own knowledge and as per information received and believed to
DEPONENT
David L Coheri
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
belief. I say that no part of it is false and nothing material has been
DEPONENT
David L Cohen
St-o:te. of N4.wy0 t"K Chief Legal and IP Officer
: ~J :
Covrrly o t lVl.w yor k Vringo Inc.
Vringo Infrastructure Inc.
S1MJtn ~ ~ i'hlS 17-tn
do.y of- JMiv4 ry ~ 11
fMfL61 tp-
SAM G. LEFFELL
NotarY Public, State of New York
No. 01LE~bxintv
co~::='~:, June 17, 2017
BEFORE THE HIGH COURT OF DELHI AT NEW DELHI
(Ordinary Original Civil Jurisdiction)
IA No. of 2014
In
CS(OS) NO. of 2014
VERSUS
brevity.
such documents.
both sides;
c. Any other order/s which this Hon'ble Court may deem fit
New.Delhi
1. Country: .
United States of. America
Certified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142740
Sandra J. Tallman
Special Deputy Secretary of State
VERSUS
AFFIDAVIT
Affidavit of Mr. David L Cohen S/o Mr. Ben T. Cohen, aged about 42
years, working at Vringo Inc. at 780, Third Avenue, 15th Floor, New
as under:
l 2.
and depose the present affidavit on behalf of both the Plaintiffs.
same are not being repeated herein for the sake of brevity.
that the contents of the same an~ true and correct as per my
FEE PAID $3.00
~
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
belief. I say that no part of it is false and nothing material has been
k~.~
SAM G. LEFFELL
Notary Public, Slate of New York
No. 01LE6283831
Quallfled In New York County .-..- "
Commission Expires June 17, t017
~ --
- ---
IA No. of 2014
In
CS(OS) No. of 2014
VERSUS
brevity.
PRAYER
pleased to: -
New Delhi
Certified
5. at New York City, New York 6. the 21st day of January 2014
l
1
8. No. NYC-142741
' l
_J
9. Seal/Stamp 10. Signature
Sandra J. Tallman
*! Special Deputy Secretary of State
~!
VERSUS
AFFIDAVIT
Affidavit of Mr. David L Cohen S/o Mr. Ben T. Cohen, aged about 42
years, working at Vringo Inc. at 780, Third Avenue, 15th Floor, New
as under:
same are not being repeated herein for the sake of brevity.
that the contents of the same are true and correct as per my
_.,.,,..
.'
~ .
own knowledge and as per information received and believed to
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
belief. I say that no part of it is false and nothing material has been
DEPONENT
\ \,,
SAM G. LEFFElL '1
.1
Notary PUbllc, State of New YOfk ) ('t .I
No. 01LE6283831 (' J
Qualified In New York Countv
Commission expires June 17, 2017
.. .
~: J 1
,.. /
-----
IN THE HIGH COURT OF DELHI AT NEW DELHI
(ORDINARY ORIGINAL CIVIL JURISDICTION)
~1
CS (OS) No. of 2014
VERSUS
declare as under:
the Plaintiff in the present suit which are all true print
procured .
printer used for the purpose of taking the print outs are
-
~---
-
O
Certified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142749
Sandra J. Tallman
Special Deputy Secretary of State
JAN 2 1 7.01~
CoU11ty CIN"k a~ CltTk of
I.
I say that in view of the facts and circumstances
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
VERIFICATION
VERSUS
INDEX III
New Delhi
VERSUS
LIST OF RELIANCE
s. Particulars Pages
No
1. All such documents by virtue of which it is
established that all the rights in the Patent IN
200572 vest with the Plaintiff No.1 along with
documents pertaining to the subject matter,
validity etc of the aforesaid patent.
New Delhi
VERSUS
KNOW ALL to whom these present shall come that I, David L Cohen,
Authorised Signatory of Vringo Inc. at 780, Third Avenue, 15th Floor, New
York, NY 10017, United States of America above named Plaintiff no.1 do
hereby appoint
To file and take back documents to admit and/or deny the documents
of opposite party.
To deposit, draw and receive money, cheques, cash and grant receipts
thereof and to do all other acts and things which may be necessary to be
done for the progress and in the course of the prosecution of the said case.
~~--
And I/we the undersigned do hereby agree to ratify and confirm all
acts done by the Advocate or his substitute in the matter as my/ our own
~
acts, as if done by me/us to all intents and purposes.
And I/we undersigned do hereby agree not to hold the advocate or his
substitute responsible for the result of the said case. The adjournment costs
whenever ordered by the Court shall be of the Advocate which he shall
receive and retain himself.
~~~1Mi,,J!ftV!Jli{I
'{jef~~~~ J'!fll ~(Joo;
'?<~-11, Jangpura Ex~n~n
~&tJ
':..~'Y,.;O:.
(\ David ~~~~~~
'?'~ New Delhi 't: / - ~ . Chief Legal and IP Officer
',(f Ph: 91-11-24314741 .~ ~) Vringo Inc.
~ Fax: 91-11-24312895 ~~ 1 Vringo Infrastructure, Inc.
singhandsingh@vsnl.com
~~
S-t-ate of New Yc. rk
Co1.1nty .o.f New yor/c :ss:
S~rn To tl1l fh15 f1f+i
Jay ot$nvary ~ol 1
k4.tj!)
SAM G. LEFFELL
Notary Publlc,.Slate of New Yolk
No. 01LE6283831
Quallfled tn New York County
Commission expires June 17, 2017
..
- .;---
IN THE HIGH COURT OF DELHI AT NEW DELHI
(Ordinary Original Civil Jurisdiction)
VERSUS
lndiaMART InterMESH Limited & Ors. ....... Defendants
KNOW ALL to whom these present shall come that I, David L Cohen,
Authorised Signatory of Vringo Infrastructure Inc. at 780, Third Avenue,
15th Floor, New York, NY 10017, United States of America above named
Plaintiff no. l do hereby appoint
To file and take back documents to admit and/or deny the documents
of opposite party.
To deposit, draw and receive money, cheques, cash and grant receipts
thereof and to do all other acts and things which may be necessary to be
done for the progress and in the course of the prosecution of the said case.
And I/we the undersigned do hereby agree to ratify and confirm all
acts done by the Advocate or his substitute in the matter as my/ our own
acts, as if done by me/us to all intents and purposes.
And I/we undersigned do hereby agree not to hold the advocate or his
substitute responsible for the result of the said case. The adjournment costs
whenever ordered by the Court shall be of the Advocate which he shall
receive and retain himself.
1
~
~~Jif~~Arlv~c'f.#./J
Y ~~k P/!'~r" W11-~
1 '~s
CLIENT
~ F-11, Jangpura Extension ~~ ~ David L Cohen
New Delhi - .cJ.,}) Chief Legal and IP Officer
Ph: 91-11-24314741 #' Vringo Inc.
Fax: 91-11-24312895 ~ Ai Vringo Infrastructure, Inc.
Si nghandsingh@vsnl.com .'vw~