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2 business at 3000 Minuteman Road, M/S 109, Andover, MA 01810. Plaintiffs Koninklijke Philips N.V. and U.S. Philips Corporation are collectively referred to in this Complaint as “Philips.” 4.

Upon information and belief, Defendant Nintendo Co. Ltd.is a corporation organized and existing under the laws of Japan, having a principal place of business at 11-1, Kamitoba, Hokotate-cho, Minami-Ku, Kyoto, 601-8116, Japan. 5.

Upon information and belief, Defendant Nintendo of America is a corporation organized and existing under the laws of the State of Washington with its principal place of business at 4600 150th Avenue, Northeast, Redmond, Washington 98052. 6.

Upon information and belief, Defendant Nintendo America is a wholly-owned subsidiary of Defendant Nintendo J apan. Nintendo Co. Ltd. and Nintendo of Ameri ca are sometimes collectively referred to in this Complaint as “Nintendo.”

Factual Background

7.

Philips is a world-renowned company that has expended enormous efforts in recent decades to achieve advancements in research and development in various technological fields. Philips has engaged in the field of applied electronics and has conducted r esearch in areas relating to visual representati on of spatial processes and to automatic processes. The present patents-in-suit stem from these fi elds of research and development and claims protection for an interactive system for which a user can remotely control devices in an intuitive manner. Such intuitive remote control mechanisms are used in present-day home video game consoles.

Interactive Virtual Modeling Products

8.