Kageta Tech LLC v. Ford Motor Co.

I. Factual Background

24 Plaintiff Kageta Tech is an LLC organized under 25 California law, located in El Dorado Hills, California. (First 26 Am. Compl. (“FAC”) ¶ 1.) Scott Kageta, the manager of Kageta 27 Tech and the named inventor of the patents at issue, resides in 28 1 El Dorado Hills, California. (Id. ¶ 2.) 2 Defendant Ford Motor Company is a Delaware corporation 3 with its headquarters in Dearborn, Michigan. (See id. ¶ 3; Decl. 4 of Murugan Sundaram Ramasamy (“Ramasamy Decl.”) (Docket No. 27-2) 5 ¶ 9.) Ford sells automobiles, automobile parts, and automobile 6 accessories. (FAC ¶ 4.) 7 This case concerns defendant’s automobile accessory kit 8 that includes a camera intended to be mounted on the back of a 9 trailer or other towed vehicle and an interface designed to be 10 installed near a truck bumper for connecting the camera to the 11 truck’s video system. (See id. ¶ 5.) Plaintiff alleges that the 12 accessory kit contains “a component intended to be installed on a 13 truck that has connectors on one side for connecting wires from 14 the truck and connectors on the other side for connecting wires 15 from a trailer or other…