IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

EXOTABLET LTD., Plaintiff, v. JURY TRIAL DEMANDED NEGRI ELECTRONICS, INC., Defendant. Civil Action No. ________________

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, ExoTablet Ltd., for its Complaint against Defendant, Negri Electronics, Inc., alleges as follows: INTRODUCTION 1. This is an action for patent infringement arising under the patent laws

of the United States, Title 35, United States Code. THE PARTIES 2. Plaintiff, ExoTablet Ltd. (hereinafter ExoTablet) is an entity formed

in the United Kingdom with a principal place of business at Temple House, 20 Holywell Row, London EC2A 4XH, United Kingdom. 1

3.

On information and belief, Defendant Negri Electronics, Inc.

(hereinafter Defendant) is a Nevada Corporation with a principal place of business located at 4045 South Buffalo Drive, Suite #A101-614, Las Vegas, Nevada 89147. 4. On information and belief, Defendant has in the past and continues to

offer for sale and sell Padfone and Padfone 2 as shown, for example, at http://negrielectronics.com/catalogsearch/result/?q=padfone#. UO29faztMyM. JURISDICTION AND VENUE 5. This Court has subject matter jurisdiction over all causes of action set

forth herein pursuant to 28 U.S.C. 1331 and 1338(a) because this action arises under the patent laws of the United States, Title 35, United States Code, including 35 U.S.C. 271 et seq. 6. This Court has personal jurisdiction over Defendant as: (i) Defendant

maintains regular and systematic business contacts with the State of Georgia and within this judicial district and division; (ii) Defendant purposely, regularly, and continuously conducts business in the State of Georgia and within this judicial district and division; (iii) Defendant purposefully directs its activities at residents of the State of Georgia; (iv) the cause of action set forth herein arises out of or relates to the Defendants activities in the State of Georgia; and (v) the exercise of jurisdiction over Defendant will not offend the traditional notions of fair play and 2

substantial justice. 7. Venue is proper in this judicial district and division pursuant to 28

U.S.C. 1331, 1338(a), 1391, and 1400(b). COUNT ONE: PATENT INFRINGEMENT (U.S. Patent No. 7,477,919) 8. ExoTablet realleges and incorporates herein the preceding allegations

of this Complaint as if fully set forth herein. 9. On January 13, 2009, the United States Patent and Trademark Office

duly and legally issued United States Patent No. 7,477,919, entitled Handheld input/output device providing enhanced user interface for a mobile telephone. A true and correct copy of U.S. Patent No. 7,477,919 is attached hereto as Exhibit A. 10. ExoTablet is the owner, by assignment, of all right, title, and interest in

and to U.S. Patent No. 7,477,919 (hereinafter the 919 Patent), including the right to bring suit for past, present, and future patent infringement, and to collect past, present, and future damages. 11. 12. 13. The 919 Patent is valid. The 919 Patent is enforceable. Defendant has in the past and continues to infringe one or more claims

of the 919 Patent in violation of 35 U.S.C. 271(a). Defendants infringing acts 3

include Defendants offer for sale and/or sale of Padfone and Padfone 2 input/output devices that provide an enhanced user interface for a mobile telephone. 14. Representative examples of Defendants infringing Padfone and

Padfone 2 devices include, but are not necessarily limited to, Defendants offer for sale and/or sale of the Padfone and Padfone 2 input/output devices that provide an enhanced user interface for a mobile telephone shown in Exhibit B. 15. On information and belief, customers who reside in the State of

Georgia, including the Northern District of Georgia, may purchase Defendants products, including Padfone and Padfone 2 input/output devices that provide an enhanced user interface for a mobile telephone, directly from Defendant. 16. On information and belief, Defendants infringement of one or more

claims of the 919 Patent has been, and continues to be, objectively reckless, willful, and deliberate, entitling ExoTablet to increased damages pursuant to 35 U.S.C. 284 and to attorneys fees pursuant to 35 U.S.C. 285. 17. ExoTablet has and continues to suffer damages as a direct and

proximate result of Defendants infringement of one or more claims of the 919 Patent and will suffer additional and irreparable damages unless Defendant is permanently enjoined by this Court from continuing its infringement. ExoTablet has no adequate remedy at law. 4

18.

ExoTablet is entitled to: (i) damages adequate to compensate it for

Defendants infringement of the 919 Patent, which amounts to, at a minimum, a reasonable royalty; (ii) ExoTablets lost profits; (iii) treble damages; (iv) attorneys fees; (v) costs; and (vi) a preliminary and thereafter permanent injunction. PRAYER FOR RELIEF WHEREFORE, ExoTablet seeks the following relief: a. That Defendant is enjoined from further infringement of the 919

Patent pursuant to 35 U.S.C. 283; b. That Defendant is ordered to pay damages adequate to compensate

ExoTablet for Defendants infringement of the 919 Patent pursuant to 35 U.S.C. 284; c. That Defendant is ordered to pay ExoTablet ExoTablets lost profits

due to Defendants infringement of the 919 Patent pursuant to 35 U.S.C. 284; d. That Defendant is ordered to pay ExoTablet treble damages pursuant to

35 U.S.C. 284; e. That Defendant is ordered to pay prejudgment interest pursuant to 35

U.S.C. 284; f. That Defendant is ordered to pay all costs associated with this action

pursuant to 35 U.S.C. 284; 5

g.

That Defendant is ordered to pay ExoTablets attorneys fees pursuant

to 35 U.S.C. 285; and h. That ExoTablet is granted such other and additional relief as the Court

deems just and proper. DEMAND FOR JURY TRIAL Pursuant to Fed. R. Civ. P. 38(b), ExoTablet demands a trial by jury of all issues triable of right by a jury. Respectfully submitted, this 25th day of January, 2013.

/s/ Stephen R. Risley Stephen R. Risley Georgia Bar No. 919545 Robert B. Dulaney III Georgia No. 232576 SMITH RISLEY TEMPEL & SANTOS LLC Two Ravinia Drive, Suite 700 Atlanta, GA 30346 Telephone: (770) 709-0080 Facsimile: (770) 804-0900 Email: [email protected] Email: [email protected]