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VERSUS
IndiaMART InterMESH Limited & Ors. .. .. Defendants
INDEX I
"'". . . . --:;
\ . .
INDEX III
New Delhi
'
I
VERSUS
INDEX I
2. Opening sheet
2.
l
~-r
3. Memo of parties
New Delhi
To .
The Deputy Registrar,
Delhi High Court of Delhi,
New Delhi.
VERSUS
.... Defendants
URGENT APPLICATION
Sir,
activities."
New Delhi
Versus
ADVOCATES
Plaintiff(s)/Petitioner(s) Defendant(s)/Respondent(s)
S. No. No. of Yr. Filled by Provisions of Laws Nature of Relief Sought Remarks
Pltff/Def
VERSUS
2. Vringo, Inc.
780 Third Avenue, 15th Floor
New York, NY 10017
United States of America
........... Plaintiff No.2
VERSUS
Also at:
AND
2. XU Dejun
Chief Executive Officer
ZTE Telecom India Private Limited
5th Floor
Tower Building No. 10, DLF Cyber City
Phase-II
Gurgaon-122002
Haryana
....... Defendant No.2
Also at:
Also at:
New Delhi
2. Vringo, Inc.
780 Third Avenue, 15th Floor
New York, NY 10017
United States of America
........... Plaintiff No.2
VERSUS
Also at:
AND
2. XU Dejun
Chief Executive Officer
ZTE Telecom India Private Limited
5th Floor
Tower Building No. 10, DLF Cyber City
Phase-II
Gurgaon-122002
Haryana
....... Defendant No.2
Also at:
Also at:
-
1st Floor, Block A,
Vatika Business Park, .
Sector-49, Sohna Road,
Gurgaon-Haryana
......... . Defendant No.3
radio technology.
technology.
Directors.
filed before the Chennai Patent Office are being filed in the -
present proceedings. Further, documents evidencing the
being filed.
jurisdictions as well.
MS
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D
000
000
000
000
MSC
BTS 1
..
BTS 2 41
Handover control
BTSM
431 ' -
Register 1 Counter 1
422
....--------;,.....-'
Register 2 Counter 2
Register M Counter M
above.
comprises of:
13. Thus, by way of the suit patent, the load on the macrocell
14. That the claims of the suit patent which define the scope of
CLAIMS:
11-
{T), and classified measurement results above the
threshold level {T) is taken as acceptable and
measurement results below the threshold level {T) or
missing measurement results are taken as unacceptable.
same.
company in India.
,,
16. That the Defendant No.4 is one of the largest
17. That the Defe.ndants are infringing the suit patent of the
Plaintiff No.1 by
Defendant No.4 was not and is not licensed for the suit
patent.
-
18. That by virtue of Section 48 of the Patents Act, 1970
during the life time and subsistence of the suit patent - the
DAMAGES:
charts filed along with the suit by the Plaintiffs qua ZTE's
technology in India.
a. UK
b. Germany
c. France
d. Australia
CAUSE OF ACTION:
24. The cause of action arose for the first time when the
JURISDICTION:
25. That this Hon'ble Court has jurisdiction to try and entertain
Hon'ble Court.
COURT FEES
being affixed;
the Plaintiffs.
being paid.
PRAYER:
Defendants:
200572.
the Plaintiffs.
Certified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYCM142748
*! Sandra J. Tallman
Special Deputy Secretary of State
JAN 2. 1 2074 COM11ty Cltrk ond Cltrk of t Suprnnt CO'Mrl, NroJ Yora COtU1ty
.:
~ ..
.
.
.,,. ,,
I ,
/
/ v. Any further order(s) which this Hon'ble Court may deem
Defendant.
l
j THROUGH
PLAINTIFF
I ::_
David L. Cohen
!
I . (Authorized Signatory}
THROUGH
New Delhi
Date:
VERIFICATION:
Verified at f'-J); .0-t (J(~ on thisl_:+, day of January, 2014
Court. ~ \ '
St-o.-t-e. ot Ne.w
Covrrty r>f Ne.~ Yort ..
Yor ~ :5 S" : ifr) '-y' l
David 1:. ,,..C6hen
(Authorized Signatory)
5WO('T\ i;, 1'i1.L -tti I S 17-th
day at Ja.nvo.ry iar1
k<Lfli!
Notaiy Publlc, State of New York
Nn. 01LE82838a1 .
.,
, - - - - - - - - -- - -- -- ------ -------
Certified
5. at New York City, New York 6. the 21st day of January 2014
8. No. NYC-142746
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:
read as part and parcel of the present affidavit as the same are
3. That I have perused the accompanying plaint and I say that the
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
\lr-inril"I Tnfr::1c:tr11rh 1rP Tnr _
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/ VERIFICATION
DEPONENT
David L Cohen
Chief Legal and IP Officer
Vringo Inc.
Vringo Infrastructure Inc.
SAM G.1.EFFELL
Notary Public,,State of New YOl1<
No. 01LE6283831
Quallfled In New York County
Commission E>cpiresJune 17, 2.017