UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION Civil Action No.

on No. 1:12-CV-1724 JURY TRIAL DEMANDED

BELDEN INC., Plaintiff, v. HITACHI CABLE AMERICA INC. and HITACHI CABLE MANCHESTER, INC., Defendants.

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Belden Inc. (Plaintiff or Belden) for its Complaint against Defendants Hitachi Cable America Inc. and Hitachi Cable Manchester, Inc. (collectively, Hitachi or Defendants), to the best of its knowledge, information and belief, hereby alleges as follows: NATURE OF THE ACTION 1. This is an action for infringement of United States Patent Nos. 5,563,377,

6,074,503, 7,135,641, 7,663,061 and 7,977,575 (collectively, the Patents-in-Suit). As alleged herein, Defendants individually, jointly and/or with others have infringed (literally and/or by equivalents), and continue to infringe, Beldens patent rights by making, using, importing, selling, and/or offering to sell within the United States data communications cable products covered by one or more patent claims, and/or by contributing to or inducing such infringement. PARTIES 2. Plaintiff Belden is a Delaware corporation, having a place of business at 2200

U.S. Highway 27 South, Richmond, Indiana 47374.

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On information and belief, Defendant Hitachi Cable America Inc. is a New York

corporation having its principal place of business at 10 Bank Street, Suite 590, White Plains, New York 10606-1947. 4. On information and belief, Defendant Hitachi Cable Manchester, Inc. is a

Delaware corporation having its principal place of business at 900 Holt Avenue, East Industrial Park, Manchester, New Hampshire 03109. JURISDICTION AND VENUE 5. This action arises under the patent laws of the United States, Title 35 of the

United States Code. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 1331, 1332, 1338(a) and 1367. 6. On information and belief, Defendants, independently, jointly, and/or at the

direction of one another, manufacture, and export, sell, and/or offer to sell the data communications cables that are the subject of this action to customers in the United States, including customers in this District and elsewhere in Indiana. 7. On information and belief, Defendants regularly do business or solicit business in

this District and in Indiana. 8. On information and belief, Defendants engage in other persistent courses of

conduct and derive substantial revenue from products and/or services provided to individuals in this District and in Indiana. 9. On information and belief, Defendants have purposefully established substantial,

systematic and continuous contacts with this District and should reasonably expect to be haled into court here. 10. The Courts exercise of jurisdiction over Defendants will not offend traditional

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notions of fair play and substantial justice. 11. 12. Accordingly, personal jurisdiction over Defendants is proper in this District. Venue is proper in this District under 28 U.S.C. 1391 and 1400(b). Defendants,

without limitation, have committed acts of infringement in the State of Indiana and this District, Defendants do business in Indiana and in this District, and Defendants are subject to personal jurisdiction in this District. COUNT I (Infringement of U.S. Patent No. 6,074,503) 13. Belden incorporates by reference the allegations in paragraphs 1 through 12 of

this Complaint. 14. Belden is the owner of United States Patent No. 6,074,503 (the 503 Patent)

entitled Making Enhanced Data Cable with Cross-Twist Cabled Core Profile, and has the right to sue on the 503 Patent. A copy of the 503 Patent is attached as Exhibit A. 15. Defendants have infringed (literally and/or by equivalents), and are continuing to

infringe, the 503 Patent by making, using, importing, selling, and/or offering to sell data communications cable products manufactured by a method that is covered by one or more of the 503 Patent claims within the United States, and/or by contributing to or inducing such infringement. 16. For example, on information and belief, Defendants individually, jointly, and/or

with others make, use, import, sell and/or offer to sell within the United States infringing Category 6 and above cables, including without limitation, for example, their Supra 10G, Supra 660, Premium, Plus, Category 6 GoldLAN hybrid, Enhanced Category 6 DataMaster Patch, Multi-Net Bonded Jacket and Category 6 Outdoor cables.

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On information and belief, Defendants had knowledge of the 503 Patent before

the filing of this Complaint. 18. Defendants infringement of the 503 Patent is and has been willful, has caused

and will continue to cause Belden to suffer substantial damages, and has caused and will continue to cause Belden to suffer irreparable harm for which there is no adequate remedy at law. COUNT II (Infringement of U.S. Patent No. 7,135,641) 19. Belden incorporates by reference the allegations in paragraphs 1 through 18 of

this Complaint. 20. Belden is the owner of United States Patent No. 7,135,641 (the 641 Patent)

entitled Data Cable With Cross-Twist Cabled Core Profile, and has the right to sue on the 641 Patent. A copy of the 641 Patent is attached as Exhibit B. 21. Defendants have infringed (literally and/or by equivalents), and are continuing to

infringe, the 641 Patent by making, using, importing, selling, and/or offering to sell data communications cable products covered by one or more of the 641 Patent claims within the United States, and/or by contributing to or inducing such infringement. 22. For example, on information and belief, Defendants individually, jointly, and/or

with others make, use, import, sell and/or offer to sell within the United States infringing Category 6 and above cables, including without limitation, for example, their Supra 10G cables. 23. On information and belief, Defendants had knowledge of the 641 Patent before

the filing of this Complaint.

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Defendants infringement of the 641 Patent is and has been willful, has caused

and will continue to cause Belden to suffer substantial damages, and has caused and will continue to cause Belden to suffer irreparable harm for which there is no adequate remedy at law. COUNT III (Infringement of U.S. Patent No. 7,663,061) 25. Belden incorporates by reference the allegations in paragraphs 1 through 24 of

this Complaint. 26. Belden is the owner of United States Patent No. 7,663,061 (the 061 Patent)

entitled High Performance Data Cable, and has the right to sue on the 061 Patent. A copy of the 061 Patent is attached as Exhibit C. 27. Defendants have infringed (literally and/or by equivalents), and are continuing to

infringe, the 061 Patent by making, using, importing, selling, and/or offering to sell data communications cable products covered by one or more of the 061 Patent claims within the United States, and/or by contributing to or inducing such infringement. 28. For example, on information and belief, Defendants individually, jointly, and/or

with others make, use, import, sell and/or offer to sell within the United States infringing Category 6 and above cables, including without limitation, for example, their Supra 10G, Supra 660, Premium, Plus, Category 6 GoldLAN hybrid, Enhanced Category 6 DataMaster Patch, Multi-Net Bonded Jacket and Category 6 Outdoor cables. 29. On information and belief, Defendants had knowledge of the 061 Patent before

the filing of this Complaint. 30. Defendants infringement of the 061 Patent is and has been willful, has caused

and will continue to cause Belden to suffer substantial damages, and has caused and will

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continue to cause Belden to suffer irreparable harm for which there is no adequate remedy at law. COUNT IV (Infringement of U.S. Patent No. 7,977,575) 31. Belden incorporates by reference the allegations in paragraphs 1 through 30 of

this Complaint. 32. Belden is the owner of United States Patent No. 7,977,575 (the 575 Patent)

entitled High Performance Data Cable, and has the right to sue on the 575 Patent. A copy of the 575 Patent is attached as Exhibit D. 33. Defendants have infringed (literally and/or by equivalents), and are continuing to

infringe, the 575 Patent by making, using, importing, selling, and/or offering to sell data communications cable products covered by one or more of the 575 Patent claims within the United States, and/or by contributing to or inducing such infringement. 34. For example, on information and belief, Defendants individually, jointly, and/or

with others make, use, import, sell and/or offer to sell within the United States infringing Category 6 and above cables, including without limitation, for example, their Supra 10G, Supra 660, Premium, Plus, Category 6 GoldLAN hybrid, Enhanced Category 6 DataMaster Patch, Multi-Net Bonded Jacket and Category 6 Outdoor cables. 35. On information and belief, Defendants had knowledge of the 575 Patent before

the filing of this Complaint. 36. Defendants infringement of the 575 Patent is and has been willful, has caused

and will continue to cause Belden to suffer substantial damages, and has caused and will continue to cause Belden to suffer irreparable harm for which there is no adequate remedy at law.

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COUNT V (Infringement of U.S. Patent No. 5,563,377) 37. Belden incorporates by reference the allegations in paragraphs 1 through 36 of

this Complaint. 38. Belden is the owner of United States Patent No. 5,563,377 (the 377 Patent)

entitled Telecommunications Cable, and has the right to sue on the 377 Patent. A copy of the 377 Patent is attached as Exhibit E. 39. Defendants have infringed (literally and/or by equivalents), and are continuing to

infringe, the 377 Patent by making, using, importing, selling, and/or offering to sell data communications cable products covered by one or more of the 377 Patent claims within the United States, and/or by contributing to or inducing such infringement. 40. For example, on information and belief, Defendants individually, jointly, and/or

with others make, use, import, sell and/or offer to sell within the United States infringing Category 5e and above cables, including without limitation, for example, their ECO, Category 5e and 350 Category 5e cables. 41. On information and belief, Defendants had knowledge of the 377 Patent before

the filing of this Complaint. 42. Defendants infringement of the 377 Patent is and has been willful, has caused

and will continue to cause Belden to suffer substantial damages, and has caused and will continue to cause Belden to suffer irreparable harm for which there is no adequate remedy at law. PRAYER FOR RELIEF WHEREFORE, Belden requests that this Court enter judgment as follows ordering that: (a) Defendants infringe the Patents-in-Suit patents by their making, using, offering

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for sale, selling and/or offering to sell data communications cable products covered by one or more of the claims of the Patents-in-Suit within the United States, and/or by contributing to or inducing such infringement; (b) (c) Defendants infringement of the Patents-in-Suit is willful; Defendants and their affiliates, subsidiaries, officers, directors, employees, agents,

representatives, licensees, successors, assigns, and all those acting for any of them or on their behalf, or acting in concert with them, be preliminarily and permanently enjoined from further infringement of Beldens patent rights; (d) Plaintiff be awarded compensatory damages and costs, with prejudgment and

post-judgment interest; (e) (f) Plaintiff be awarded treble damages for willful patent infringement; This case be declared to be exceptional in favor of Plaintiff under

35 U.S.C. 285, and that Plaintiff be awarded its costs, attorneys fees, and other expenses incurred in connection with this action; and (g) Plaintiff be awarded such other relief as the Court deems just and proper.

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JURY DEMAND Belden respectfully demands a trial by jury on all issues so triable.

Respectfully submitted, Date: November 21, 2012 /s/ Holiday W. Banta___________ Holiday W. Banta Indiana State Bar No. 17852-49 Email: H.Banta@icemiller.com Adam Arceneaux Indiana State Bar No. 17219-49 Email: Adam.Arceneaux@icemiller.com ICE MILLER LLP One American Square, Suite 2900 Indianapolis, IN 46282-0200 Telephone: (317) 236-5882 Facsimile: (317) 592-4226 Attorneys for Plaintiff Belden Inc.

I/3020702.1

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