IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 12-1055

LANTEK ELECTRONICS, INC., Plaintiff, v. EXTREME BROADBAND ENGINEERING, LLC, Defendant.

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Lantek Electronics, Inc. (Plaintiff or Lantek Electronics) for its Complaint against Defendant Extreme Broadband Engineering, LLC (Defendant or Extreme), alleges the following: THE PARTIES 1. Lantek Electronics, Inc. (Lantek Electronics) is a Taiwanese corporation with

its primary place of business at Lane 369, #9, Ta Tung Road, HSO Chih, Taipei, Taiwan. 2. Extreme Broadband Engineering, LLC is a New Jersey limited liability company

with its primary place of business at Gedi Corporate Park, 490 Highway 33 West, Millstone Township, New Jersey 08535-08114. Upon information and belief, Extreme makes, uses, sells, offers to sell and/or imports products throughout the United States, including in this judicial district and introduces infringing products into the stream of commerce knowing that they would be sold in this judicial district and elsewhere in the United States.

JURISDICTION AND VENUE 3. This is an action for patent infringement arising under the Patent Laws of the

United States, Title 35 of the United States Code. 4. 1338. 5. This Court has personal jurisdiction over the Defendant. Upon information and This Court has subject matter jurisdiction under 28 U.S.C. 1331, 1332 and

belief, Extreme has transacted substantial business in this judicial district, including through directing sales to Colorado. Upon information and belief, Extreme has committed, contributed to, and/or induced acts of patent infringement in this judicial district. 6. Venue is proper in this judicial district under 28 U.S.C. 1391. GENERAL ALLEGATIONS 7. Lantek Electronics designs, builds and markets high-quality electronic

components and devices used in the cable-television and related industries. Lantek Electronics has applied for and received United States and several foreign patents relating to inventions its employees developed. 8. In or around 2002, Defendant began doing business with Lantek Electronics

through its agent Lantek USA, LLC (Lantek USA). Specifically, Extreme contracted for Lantek Electronics to manufacture certain devices relating to the cable-television industry that Extreme intended to market and sell under its own brand name. 9. facilities. Lantek Electronics manufactured these devices for Extreme at Lanteks overseas

10.

Upon information and belief, many of Extremes customers for these devices

were cable-television providers in the United States, including providers with a presence in this judicial district. 11. In order to meet the stringent testing requirements of Extremes customers,

Lantek Electronics used its proprietary technology to design and manufacture the high-quality devices it built for Extreme. 12. During the period it worked with Extreme, Lantek Electronics obtained patents

for key aspects of the proprietary technology it was using in these devices. 13. The devices Lantek Electronics made for Extreme were successful, and Extreme

purchased more than twenty-three million of these devices between 2003 and 2009. 14. In or around 2007, Extreme ended its exclusive manufacturing relationship with

Lantek Electronics and began using other overseas manufacturers to build its devices. 15. Upon information and belief, Extreme had its other manufacturers produce low-

quality products that did not use Plaintiffs patented and proprietary technology. 16. In late 2011, Plaintiff learned that Extreme had only briefly used the low-quality

design and then switched to the previous design that used Plaintiffs patented technology. 17. Upon information and belief, Extreme had its manufacturers change to this

infringing design because its customers were not satisfied with the low-quality devices that did not include Plaintiffs patented technology. 18. Extremes manufacture, use, sale and/or import of devices that make unauthorized

use of Plaintiffs technology infringes two of its U.S. patents.

FIRST CLAIM FOR RELIEF PATENT INFRINGEMENT OF U.S. PATENT NO. 6,755,665 (35 U.S.C. 271) 19. The allegations set forth in the foregoing paragraphs 1 through 18 are

incorporated into this First Claim for Relief. 20. On June 29, 2004, U.S. Patent No. 6,755,665 (the 665 Patent), entitled

Connector Insert for an Output Connector to Transmit Signal, was duly and legally issued by the United States Patent and Trademark Office to inventor Shan-Jui Lu and has been duly and legally assigned to Lantek Electronics. A copy of the 665 Patent is attached as Exhibit A. 21. Upon information and belief, Defendant Extreme has infringed and continues to

infringe one or more claims of the 665 Patent in this judicial district and elsewhere by making, using, selling, offering for sale, and/or importing into the United States without authority products that infringe and/or perform processes that infringe one or more claims of the 665 Patent (Extremes Accused Products for the 665 Patent). 22. Upon information and belief, Extremes Accused Products for the 665 Patent

include, but are not limited to, products that contain a specially shaped connector that maximizes contact points and avoids detachment, including, for example, Extremes signal splitters, directional couplers, and amplifiers. Upon information and belief, this includes Extremes BDS signal splitters, BDPS signal splitters, BDC directional couplers, IPS signal splitters, and IPA amplifiers. 23. Upon information and belief, Extreme has induced and continues to induce others

to infringe one or more claims of the 665 Patent in violation of 35 U.S.C. 271(b) by, among other things, actively and knowingly aiding and abetting others to infringe, including, but not

limited to, its customers, whose use of such products constitutes direct infringement of one or more claims of the 665 Patent. 24. Upon information and belief, Extreme has committed and continues to commit

acts of contributory infringement of one or more claims of the 665 Patent in violation of 35 U.S.C. 271(c) in that Extreme has made, used, sold, offered to sell, and/or imported, or continues to make, use, sell, offer to sell, and/or import products including Extremes Accused Products for the 665 Patent, which have no substantial non-infringing uses, and provides such products to its customers, whose use of such products constitutes direct infringement of one or more claims of the 665 Patent. 25. Because of Extremes infringement, inducement of infringement, and contributory

infringement of the 665 Patent, Plaintiff has suffered damages and will continue to suffer damages in the future. SECOND CLAIM FOR RELIEF PATENT INFRINGEMENT OF U.S. PATENT NO. 6,788,166 (35 U.S.C. 271) 26. The allegations set forth in the foregoing paragraphs 1 through 25 are

incorporated into this Second Claim for Relief. 27. On September 7, 2004, U.S. Patent No. 6,788,166 (the 166 patent), entitled

Harmonic Wave Distortion Suppressor, was duly and legally issued by the United States Patent and Trademark Office to inventor Shan-Jui Lu and has been duly and legally assigned to Lantek Electronics. A copy of the 166 Patent is attached as Exhibit B. 28. Upon information and belief, Defendant Extreme has infringed and continues to

infringe one or more claims of the 166 Patent in this judicial district and elsewhere by making, using, selling, offering for sale, and/or importing into the United States without authority

products that infringe and/or perform processes that infringe one or more claims of the 166 Patent (Extremes Accused Products for the 166 Patent). 29. Upon information and belief, Extremes Accused Products for the 166 Patent

include, but are not limited to, products that contain specially coated bodies with connecting pins that charge and discharge locally and prevent an iron core in the attached electronic device from magnetization, including, for example, Extremes signal splitters and directional couplers. Upon information and belief, this includes Extremes BDS signal splitters, BDPS signal splitters, BDC directional couplers, and IPS signal splitters. 30. Upon information and belief, Extreme has induced and continues to induce others

to infringe one or more claims of the 166 Patent in violation of 35 U.S.C. 271(b) by, among other things, actively and knowingly aiding and abetting others to infringe, including, but not limited to, its customers, whose use of such products constitutes direct infringement of one or more claims of the 166 Patent. 31. Upon information and belief, Extreme has committed and continues to commit

acts of contributory infringement of one or more claims of the 166 Patent in violation of 35 U.S.C. 271(c) in that Extreme has made, used, sold, offered to sell, and/or imported, or continues to make, use, sell, offer to sell, and/or import products including Extremes Accused Products for the 166 Patent, which have no substantial non-infringing uses, and provides such products to its customers, whose use of such products constitutes direct infringement of one or more claims of the 166 Patent. 32. Because of Extremes infringement, inducement of infringement, and contributory

infringement of the 166 Patent, Plaintiff has suffered damages and will continue to suffer damages in the future.

PRAYER FOR RELIEF Wherefore, Plaintiff demands judgment granting the following relief against Extreme and against its parents, subsidiaries, affiliates, agents, servants, employees, licensees, and all other persons acting or attempting to act in active concert or participation with one or more of them, or on their behalf: A. A judgment in favor of Plaintiff that Extreme has infringed, directly and/or

indirectly, or by way of inducing and/or contributing to the infringement of, the 665 and 166 Patents, and injunctive relief necessary to prevent continued infringement of these patents; B. An award of damages adequate to compensate Plaintiff for the direct and/or

indirect infringement, inducement of infringement, and contributory infringement, together with pre- and post-judgment interest; C. D. Increased damages pursuant to 35 U.S.C. 284; A finding that this case is exceptional and an award to Plaintiff of its attorneys

fees, expenses and costs pursuant to 35 U.S.C. 285; and E. Such other and further relief as this Court may deem just and proper.

JURY DEMAND Plaintiff demands a trial by jury.

Dated: April 19, 2012

Respectfully submitted, JIN, SCHAUER & SAAD LLC By: /s/ Kevin E. McReynolds Tarek F.M. Saad Kevin E. McReynolds Jin, Schauer & Saad LLC 600 Seventeenth Street, Suite 2700-S Denver, CO 80202 Telephone: (720) 889-2211 Facsimile: (720) 889-2222 E-mail: tsaad@jinslaw.com kmcreynolds@jinslaw.com ATTORNEYS FOR PLAINTIFF LANTEK ELECTRONICS, INC.