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					  Case 3:10-cv-01475-BR       Document 1        Filed 12/03/10   Page 1 of 6   Page ID#: 1



Joseph Mohr (OR SBN 053274)
Email: joey@mohriplaw.com
Mohr Intellectual Property Law Solutions, PC
522 SW 5th Avenue, Suite 1390                                       filbtio DEC 03 IQOOusbc-qrp
Portland, OR 97204
Telephone 503-336-1214.
Facsimile: 866-387-6875



Peter A. Haas (OR SBN 020552)
Email: peterahaas@flatfee-ip.com
Peter A Haas Esquire LLC,
1929 SW 13th Ave. Portland, OR97201
Telephone: 503-319-3024




                     IN THE UNITED STATES DISTRICT COURT

                           FOR THE DISTRICT OF OREGON

                                   PORTLAND DIVISION
STENBOCK & EVERSON, an Oregon                       civiiActioCMolO-1475 flR~,
corporation, Plaintiff,

                                                    PLAINTIFF'S ORIGINAL COMPLAINT
RUNWAYFINDER, LLC, dba                              FOR PATENT INFRINGEMENT
Runwayfinder.com, Defendant

                                                    DEMAND FOR JURY TRIAL




PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT


                                               -1
 Case 3:10-cv-01475-BR         Document 1        Filed 12/03/10   Page 2 of 6     Page ID#: 2




                               I.      NATURE OF THE ACTION

1.    PlaintiffStenbock & Everson ('' Stenbock & Everson") demands a jury trial on all issues

      and brings this complaint for patent infringement against Runwayfinder, LLC dba

      Runwayfinder.com.



                              II.     JURISDICTION AND VENUE


2.    This is an action for patent infringement arising under the Patent Act of the United States,

      35 U.S.C. 271 and 281. This Court has subject matterjurisdiction over the matters

      complained of under 28 U.S.C. 1338(a) and 1331.

3.    Venue is proper in this judicial district pursuant to 28 U.S.C. 1400(b) and 1391(c), as

      defendant Runwayfinder, LLC ("Runwayfinder") has committed acts of patent

      infringement in this judicial district.




                                       III.     THE PARTIES


4.    Stenbock & Everson ("Stenbock") is a corporation organized andexisting under thelaws

      of the State of Oregon and has itsprincipal place of business at 22781 Airport Road NE

      D-l, Aurora, OR, 97002. Stenbock & Everson designs, develops, markets andsupports

      internet based flight planning products that enhance and improve the ability ofpilots to

      create flight plans.

5..   On information andbelief, Runwayfinder, LLC ("Runwayfinder") is a for profit limited

      liability company organized under the laws ofthe State ofWashington. Runwayfinder's
PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
     Case 3:10-cv-01475-BR        Document 1        Filed 12/03/10   Page 3 of 6     Page ID#: 3



         principal placeof business is located on MercerIsland, Washington. Runwayfinder

         develops, markets and supports Internet-based flightplanning products for pilots.




                                  IV.     FACTUAL BACKGROUND



6.       Stenbock& Everson is the manufacturer and publisher of an internet based flight

         planning product for pilots to create flight plans.



7.       Stenbock & Everson's proprietary internet based flight management plan, developed at

         substantial cost, is protected by U.S. Patent No. 7,640,098 (the "098" patent) attached as

         Exhibit 1.




8.       On August 10,2010, Stenbock & Everson sent the following demand letter to

         Runwayfinder, LLC. Said demand letter is attached as Exhibit 2. No response was

         received from Runwayfinder, LLC.



              V.      FHtST CAUSE OF ACTION FOR PATENT INFRINGEMENT




9.       Stenbock & Everson repeats and realleges, as if set forth in full, paragraphs 1 through 8

         of this Complaint.




PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT


                                                  -3-
 Case 3:10-cv-01475-BR          Document 1        Filed 12/03/10     Page 4 of 6      Page ID#: 4



10.   On December 29,2009, the '098 patent, entitled "Process for Generating TravelPlans on

      the Internet" was granted to Stenbock. Since its issuance, Stenbock has been, and

      continues to be, the owner of all right, title and interest in and to the '098 patent.

11.   Defendant Runwayfinder is infringing at least one of the claims of the '098 patent, in this

      judicial district and elsewhere, in connectionwith its activitiespertaining to the web

      based version of its product located at www.runwayfinder.com

12.   Unless enjoined by the Court, Runwayfinder will continue to infringe Stenbock's '098

      Patent


13.   As a direct and proximate result of Runwayfinder's conduct, Stenbock has suffered and

      will continue to suffer irreparable injury, for which it has no adequate remedy at law.

      Stenbock has also been damaged, and, until an injunction issues, will continue to be

      damaged in its business and reputation in an amount yet to be determined. Moreover, the

      wilful and deliberate nature of Runwayfinder's infringement renders this an exceptional

      case, and thus Stenbock is further entitled to treble damages, as well as its actual

      attorneys' fees and litigation costs.

                               VI.      JURY TRIAL DEMAND


14.   Stenbock & Everson demands a jury trial on all issues.




PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
  Case 3:10-cv-01475-BR         Document 1        Filed 12/03/10     Page 5 of 6      Page ID#: 5




                                VH.     PRAYER FOR RELIEF


WHEREFORE, Stenbock prays for judgment against defendant Runwayfinder as follows:

1. For a judicial determination and declaration that the '098 patent is infringed by the internet

based flight planning product(s) located at www.runwayfinder.com.

2. For a judicial determination and declaration that Runwayfinder's infringement of the '098

patents is wilful.

3. For an order preliminarily and permanently enjoining Runwayfinder, its officers, directors,

shareholders, agents, servants, employees and attorneys, and all entities and individuals acting in

concert with them or on their behalf, from infringing the '098 patent.

4. For damages according to proof, trebled;

5. For Stenbock & Everson's attorneys' fees and litigation costs; and

6. For such other and further relief as the Court may deem just and proper.

Dated: December 3       ,2010




PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
 Case 3:10-cv-01475-BR      Document 1   Filed 12/03/10   Page 6 of 6   Page ID#: 6




Respectfully submitted,




       Joseph Mohr
       MOHR INTELLECTUAL PROPERTY LAW SOLUTIONS, P.C.




                "•//'
         '   lr% J
                k
       Peter A. Haas
       Peter A Haas Esquire LLC




PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

				
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