GeoTag case 569

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					        Case 2:10-cv-00569-TJW Document 1   Filed 12/17/10 Page 1 of 14



                    IN THE UNITED STATES DISTRICT COURT
                     FOR THE EASTERN DISTRICT OF TEXAS
                             MARSHALL DIVISION
GEOTAG, INC.

       PLAINTIFF,

  v.                                        CIVIL ACTION NO. _______________

GEORGIO ARMANI S.P.A.;
ADIDAS A.G.;
ASICS CORP.;
BULLSEYE SOLUTIONS, INC. D/B/A
BULLSEYE SOLUTIONS;
CARTIER S.A.;
CHANEL S.A.;
CHRISTIAN DIOR S.A.;
CONN’S INC.;
CONN'S APPLIANCES, INC.;
ELECTRIC VINE, INC. D/B/A BULLSEYE
SOLUTIONS GROUP, INC. D/B/A
BULLSEYE SOLUTIONS GROUP D/B/A
BULLSEYE SOLUTIONS;
GRACO N.V.;
GUCCI GROUP NV;
IQ SERVICES GROUP, INC. D/B/A IQ
SERVICES GROUP D/B/A
XTREMELOCATOR.COM D/B/A
IQSERVICES D/B/A IQSERVICES.COM;
IQ SERVICES, INC. D/B/A
XTREMELOCATOR.COM D/B/A
IQSERVICES D/B/A IQSERVICES.COM;
KNOW-WHERE SYSTEMS, INC.;
KUBOTA CORPORATION OF JAPAN;
LELY HOLDING S.À R.L.;
LELY INDUSTRIES N.V.;
MARKET BASKET, INC. D/B/A MARKET
BASKET FOOD STORES;
MEDELA AG MEDICAL TECHNOLOGY;
MEDELA AG;
ROLEX SA;
VAN CLEEF & ARPELS, S.A.; AND
XIONETIC TECHNOLOGIES, INC. D/B/A
FINDLOCATION.COM.

       DEFENDANTS.                          JURY TRIAL DEMANDED
         Case 2:10-cv-00569-TJW Document 1            Filed 12/17/10 Page 2 of 14




                       COMPLAINT FOR PATENT INFRINGEMENT

   Plaintiff GEOTAG, INC. files this Complaint against GEORGIO ARMANI S.P.A.;

ADIDAS A.G.; ASICS CORP.; CARTIER S.A.; CHANEL S.A.; CHRISTIAN DIOR S.A.;

CONN’S INC.; CONN'S APPLIANCES, INC.; ELECTRIC VINE, INC. D/B/A BULLSEYE

SOLUTIONS GROUP D/B/A BULLSEYE SOLUTIONS; BULLSEYE SOLUTIONS, INC.

D/B/A BULLSEYE SOLUTIONS; GRACO N.V.; GUCCI GROUP NV; IQ SERVICES

GROUP,       INC.    D/B/A      XTREMELOCATOR.COM          D/B/A    IQSERVICES      D/B/A

IQSERVICES.COM; IQ SERVICES, INC. D/B/A XTREMELOCATOR.COM D/B/A

IQSERVICES D/B/A IQSERVICES.COM; KNOW-WHERE SYSTEMS, INC.; KUBOTA

CORPORATION OF JAPAN; LELY HOLDING S.À R.L.; LELY INDUSTRIES N.V.;

MARKET BASKET, INC. D/B/A MARKET BASKET FOOD STORES; MEDELA AG

MEDICAL TECHNOLOGY; MEDELA AG; ROLEX SA; VAN CLEEF & ARPELS, S.A.;

AND XIONETIC TECHNOLOGIES, INC. D/B/A FINDLOCATION.COM (collectively

“Defendants”), as follows:

                                            PARTIES

       1.      Plaintiff GEOTAG, INC. (“GEOTAG” or “Plaintiff”) is a Delaware Corporation

with a place of business in Plano, Texas.

       2.      On information and belief, Defendant GEORGIO ARMANI S.P.A. (“ARMANI”)

has a place of business in Milan, Italy.

       3.      On information and belief, Defendant ADIDAS A.G. (“ADIDAS”) has a place of

business in Herzogenaurach, Germany.

       4.      On information and belief, Defendant ASICS CORP. (“ASICS”) has a place of

business in Kobe, Japan.


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         Case 2:10-cv-00569-TJW Document 1          Filed 12/17/10 Page 3 of 14



       5.      On information and belief, Defendants ELECTRIC VINE, INC. D/B/A

BULLSEYE SOLUTIONS GROUP D/B/A BULLSEYE SOLUTIONS (“ELECTRIC VINE”)

has a place of business in Somerset, New Jersey.

       6.      On information and belief, Defendants BULLSEYE SOLUTIONS, INC. D/B/A

BULLSEYE SOLUTIONS (“BULLSEYE SOLUTIONS”) has a place of business in Somerset,

New Jersey. Hereinafter ELECTRIC VINE and BULLSEYE are collectively referred to as

“BULLSEYE.”

       7.      On information and belief, Defendant CARTIER S.A. (“CARTIER”) has a place

of business in Paris, France.

       8.      On information and belief, Defendant CHANEL S.A. (“CHANEL”) has a place of

business in Cedex, France.

       9.      On information and belief, Defendant CHRISTIAN DIOR S.A. (“DIOR”) has a

place of business in Paris, France.

       10.     On information and belief, Defendant CONN'S APPLIANCES, INC. has a place

of business in Beaumont, Texas.

       11.     On information and belief, Defendant CONN’S INC. has a place of business in

Beaumont, Texas.       Hereinafter CONN’S APPLICANCES, INC. and CONN’S INC. are

collectively referred to as “CONNS.”

       12.     On information and belief, Defendant GRACO N.V. (“GRACO”) has a place of

business in Belgium.

       13.     On information and belief, Defendant GUCCI GROUP NV (“GUCCI”) has a

place of business in Amsterdam, Netherlands.




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         Case 2:10-cv-00569-TJW Document 1                  Filed 12/17/10 Page 4 of 14



       14.    On information and belief, Defendant IQ SERVICES GROUP, INC. D/B/A

XTREMELOCATOR.COM D/B/A IQSERVICES D/B/A IQSERVICES.COM (“IQSGI”) has a

place of business in Finton, Michigan.

       15.    On    information    and   belief,       Defendant    IQ    SERVICES,    INC.   D/B/A

XTREMELOCATOR.COM D/B/A IQSERVICES D/B/A IQSERVICES.COM (“IQSI”) has a

place of business in Finton, Michigan. Hereinafter, IQSGI and IQSI are collectively referred to

as “IQSERVICES.”

       16.    On information and belief, Defendant KNOW-WHERE SYSTEMS, INC.;

(“KNOW WHERE SYSTEMS”) has a place of business in Agoura, California.

       17.    On information and belief, Defendant KUBOTA CORPORATION OF JAPAN

(“KUBOTA”) has a place of business in Osaka, Japan.

       18.    On information and belief, Defendant LELY HOLDING S.À R.L. has a place of

business in Weverskade, Netherlands.

       19.    On information and belief, Defendant LELY INDUSTRIES N.V. has a place of

business in Weverskade, Netherlands. Hereinafter, LELY HOLDING S.À R.L. and LELY

INDUSTRIES N.V. are collectively referred to as “LELY.”

       20.    On information and belief, Defendant MARKET BASKET, INC. D/B/A

MARKET BASKET FOOD STORES (“MARKET BASKET”) has a place of business in

Nederland, Texas.

       21.    On     information   and    belief,       Defendant        MEDELA   AG     MEDICAL

TECHNOLOGY has a place of business in Baar, Switzerland.




                                                   4
         Case 2:10-cv-00569-TJW Document 1             Filed 12/17/10 Page 5 of 14



       22.     On information and belief, Defendant MEDELA AG has a place of business in

Baar, Switzerland. Hereinafter, MEDELA AG MEDICAL TECHNOLOGY and MEDELA AG

are collectively referred to as “MEDELA.”

       23.     On information and belief, Defendant ROLEX SA (“ROLEX”) has a place of

business in Geneva, Switzerland.

       24.     On information and belief, Defendant VAN CLEEF & ARPELS, S.A. (“VAN

CLEEF”) has a place of business in Paris, France.

       25.     On information and belief, Defendant XIONETIC TECHNOLOGIES, INC.

D/B/A FINDLOCATION.COM (“XIONETIC”) has a place of business in Bozeman, Montana.

                               JURISDICTION AND VENUE

       26.     This action arises under the patent laws of the United States, Title 35 of the

United States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331

and 1338(a). On information and belief, the Defendants are subject to this Court’s specific and

general personal jurisdiction, pursuant to due process and/or the Texas Long Arm Statute, due at

least to their substantial business in this forum, including related to the infringements alleged

herein. Further, on information and belief, Defendants have interactive websites comprising

infringing methods and apparatuses which are at least used in and/or accessible in this forum.

Further, on information and belief, Defendants are subject to the Court’s general jurisdiction,

including from regularly doing or soliciting business, engaging in other persistent courses of

conduct, and/or deriving substantial revenue from goods and services provided to persons or

entities in Texas.

       27.     Venue is proper in this district under 28 U.S.C. §§ 1391(b), 1391(c) and 1400(b).

Without limitation, on information and belief, Defendants are subject to personal jurisdiction in



                                               5
         Case 2:10-cv-00569-TJW Document 1                 Filed 12/17/10 Page 6 of 14



this district. On information and belief, the Defendants are subject to this Court’s specific and

general personal jurisdiction in this district, pursuant to due process and/or the Texas Long Arm

Statute, due at least to their substantial business in this district, including related to the

infringements alleged herein. Further, on information and belief, Defendants have interactive

websites comprising infringing methods and apparatuses which are at least used in and/or

accessible in this district. Further, on information and belief, Defendants are subject to the

Court’s general jurisdiction in this district, including from regularly doing or soliciting business,

engaging in other persistent courses of conduct, and/or deriving substantial revenue from goods

and services provided to persons or entities in this district.

       28.     Further, venue of this action is appropriate and convenient because this Court

previously heard a parallel action for infringement of the same ‘474 patent in Geomas

(International), Ltd., et al. vs. Idearc Media Services-West, Inc., et al., Civil Action No. 2:06-

CV-00475-CE (“the Geomas Lawsuit”). In the Geomas Lawsuit this Court considered and

construed the terms and claims of the ‘474 patent, as set forth in the Court’s Memorandum

Opinion and Order issued on November 20, 2008.

                                               COUNT I

                      INFRINGEMENT OF U.S. PATENT NO. 5,930,474

       29.     United States Patent No. 5,930,474 (the “‘474 patent”), entitled “Internet

Organizer for Accessing Geographically and Topically Based Information,” duly and legally

issued on July 29, 1999.

       30.     GEOTAG is the assignee of the ‘474 Patent and it has standing to bring this

lawsuit for infringement of the ‘474 Patent.




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         Case 2:10-cv-00569-TJW Document 1              Filed 12/17/10 Page 7 of 14



       31.     The claims of the ‘474 Patent cover, inter alia, systems and methods which

comprise associating on-line information with geographic areas, such systems and methods

comprising computers, an organizer, and a search engine configured to provide a geographical

search area wherein at least one entry associated with a broader geographical area is dynamically

replicated into at least one narrower geographical area, the search engine further configured to

search topics within the selected geographical search area.

       32.     On information and belief, all Defendants named herein have infringed the ‘474

patent pursuant to 35 U.S.C. § 271 through actions comprising the making, using, selling,

importing and/or offering for sale in the United States systems and methods which comprise

associating on-line information with geographic areas and which are covered by one or more

claims of the ‘474 patent.

       33.     On information and belief, ARMANI has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the store locator at

www.armani.com; www.armanistores.com; and www.emporioarmani.com.

       34.     On information and belief, ADIDAS has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the store finder at

wwww.adidas.com.



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         Case 2:10-cv-00569-TJW Document 1             Filed 12/17/10 Page 8 of 14



       35.     On information and belief, ASICS has infringed the ‘474 patent in violation of 35

U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the search for local

retailer at www.asicsamerica.com.

       36.     On information and belief, BULLSEYE has infringed the ‘474 patent in violation

of 35 U.S.C. § 271 through actions comprising the making, using, selling and/or offering for sale

in the United States systems and methods which comprise associating on-line information with

geographic areas and which are covered by one or more claims of the ‘474 patent.             On

information and belief, such systems and methods comprise the locator provider at

http://bullseye.electricvine.com.

       37.     On information and belief, CARTIER has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the find a boutique at

www.cartier.us.

       38.     On information and belief, CHANEL has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474




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         Case 2:10-cv-00569-TJW Document 1              Filed 12/17/10 Page 9 of 14



patent. On information and belief, such systems and methods comprise the store locator at

www.chanel.com, including www.chanel.com/en_US.

       39.     On information and belief, CONNS has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling and/or offering for sale in

the United States systems and methods which comprise associating on-line information with

geographic areas and which are covered by one or more claims of the ‘474 patent.              On

information and belief, such systems and methods comprise the store locator at www.conns.com.

       40.     On information and belief, DIOR has infringed the ‘474 patent in violation of 35

U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the store locator at

www.dior.com; diorhomme.com; and www.diorcoture.com.

       41.     On information and belief, GRACO has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the where to buy at

www.graco.com.

       42.     On information and belief, has infringed the ‘474 patent in violation of 35 U.S.C.

§ 271 through actions comprising the making, using, selling, importing and/or offering for sale in

the United States systems and methods which comprise associating on-line information with




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        Case 2:10-cv-00569-TJW Document 1             Filed 12/17/10 Page 10 of 14



geographic areas and which are covered by one or more claims of the ‘474 patent.             On

information and belief, such systems and methods comprise the store finder at www.gucci.com.

       43.    On information and belief, IQSERVICES has infringed the ‘474 patent in

violation of 35 U.S.C. § 271 through actions comprising the making, using, selling and/or

offering for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the locator provider at

http://www.xtremelocator.com; and http://www.iqservices.com/.

       44.    On information and belief, KNOW WHERE SYSTEMS has infringed the ‘474

patent in violation of 35 U.S.C. § 271 through actions comprising the making, using, selling

and/or offering for sale in the United States systems and methods which comprise associating on-

line information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the locator provider at

http://know-where.com.

       45.    On information and belief, KUBOTA has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the dealer locator at

www.kubota.com.

       46.    On information and belief, LELY has infringed the ‘474 patent in violation of 35

U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line



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        Case 2:10-cv-00569-TJW Document 1             Filed 12/17/10 Page 11 of 14



information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the dealer locator at

www.lely.com.

       47.    On information and belief, MARKET BASKET has infringed the ‘474 patent in

violation of 35 U.S.C. § 271 through actions comprising the making, using, selling and/or

offering for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the store locator at

www.marketbasketfoods.com.

       48.    On information and belief, MEDELA has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the where to buy/rent at

www.medela.us and www.medelabreastfeedingus.com.

       49.    On information and belief, ROLEX has infringed the ‘474 patent in violation of

35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or offering

for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the dealer locatorfinder

at www.rolex.com.

       50.    On information and belief, VAN CLEEF has infringed the ‘474 patent in violation

of 35 U.S.C. § 271 through actions comprising the making, using, selling, importing and/or



                                              11
         Case 2:10-cv-00569-TJW Document 1               Filed 12/17/10 Page 12 of 14



offering for sale in the United States systems and methods which comprise associating on-line

information with geographic areas and which are covered by one or more claims of the ‘474

patent. On information and belief, such systems and methods comprise the boutique search at

www.vancleef-arpels.com.

        51.     On information and belief, XIONETIC has infringed the ‘474 patent in violation

of 35 U.S.C. § 271 through actions comprising the making, using, selling and/or offering for sale

in the United States systems and methods which comprise associating on-line information with

geographic areas and which are covered by one or more claims of the ‘474 patent.                 On

information and belief, such systems and methods comprise the store and product locators at

www.findlocation.com.

        52.     To the extent that facts learned during the pendency of this case show that

Defendants' infringement is, or has been willful, GEOTAG reserves the right to request such a

finding at time of trial.

        53.     As a result of Defendants’ infringing conduct, Defendants have damaged

GEOTAG. Defendants are liable to GEOTAG in an amount that adequately compensates

GEOTAG for their infringement, which, by law, can be no less than a reasonable royalty.

                                        PRAYER FOR RELIEF

        WHEREFORE, GEOGAG respectfully requests that this Court enter:

        1.      A judgment in favor of GEOTAG that Defendants have infringed the ‘474 patent;

        2.      A permanent injunction enjoining Defendants, and their officers, directors, agents,

servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in

active concert therewith from infringement, inducing the infringement of, or contributing to the

infringement of the ‘474 patent;



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         Case 2:10-cv-00569-TJW Document 1               Filed 12/17/10 Page 13 of 14



        3.      A judgment and order requiring Defendants to pay GEOTAG its damages, costs,

expenses, and prejudgment and post-judgment interest for Defendants’ infringement of the ‘474

patent as provided under 35 U.S.C. § 284;

        4.      An award to GEOTAG for enhanced damages as provided under 35 U.S.C. § 284;

        5.      A judgment and order finding that this is an exceptional case within the meaning

of 35 U.S.C. § 285 and awarding to GEOTAG its reasonable attorneys’ fees; and

        6.      Any and all other relief to which GEOTAG may show itself to be entitled.

                                       DEMAND FOR JURY TRIAL

        Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, GEOTAG requests a

trial by jury of any issues so triable by right.



December 17, 2010                                   Respectfully submitted,

                                                    GEOTAG, INC.

                                                    By: /s/ John J. Edmonds
                                                    John J. Edmonds – Lead Counsel
                                                    Texas Bar No. 789758
                                                    Michael J. Collins
                                                    Texas Bar No. 4614510
                                                    Stephen F. Schlather
                                                    Texas Bar No. 24007993
                                                    COLLINS, EDMONDS & POGORZELSKI, PLLC
                                                    1616 S. Voss Road, Suite 125
                                                    Houston, Texas 77057
                                                    Telephone: (281) 501-3425
                                                    Facsimile: (832) 415-2535
                                                    jedmonds@cepiplaw.com
                                                    mcollins@cepiplaw.com
                                                    sschlather@cepiplaw.com

                                                    L. Charles van Cleef
                                                    Texas Bar No. 786305
                                                    Van Cleef Law Office
                                                    500 N Second Street
                                                    Longview, Texas 75601

                                                   13
Case 2:10-cv-00569-TJW Document 1   Filed 12/17/10 Page 14 of 14



                              (903) 238-8244
                              (903) 248-8249 Facsimile
                              charles@vancleef.net

                              ATTORNEYS FOR PLAINTIFF
                              GEOTAG, INC.




                             14
                                      Case 2:10-cv-00569-TJW Document 1-1                                                                  Filed 12/17/10 Page 1 of 1
  ~JS      44 (Rev. 12/07) 	                                                                  CIVIL COVER SHEET
 The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service ofpleadings or other papers as required by law, except as provided
 by local rules ofcourt This form, approved by the Judicial Conference ofthe United States in September 1974, is required for the use ofthe Clerk of Court for the purpose of mitiating
 the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)                                                                                                                .

 I. (a) PLAINTIFFS                                                                                                                DEFENDANTS
Geotag, Inc.                                                                                                                       Georgio Armani S.P.A., et al.


      (b) County of Residence of First Listed Plaintiff                            Collin County, Texas                           County of Residence of First Listed Defendant
                                           (EXCEPT IN U.S. PLAINTIFF CASES)                                                                                         (IN U.S. PLAINTIFF CASES ONLY)
                                                                                                                                          NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
                                                                                                                                                    LAND INVOLVED.


      (c) Attorney's (Finn Name, Address, and TelZ'hone Number)                                                                   Attorneys (If Known)
John J. Edmonds, Collins, Edmonds & I-'ogorzelskl, PLLC, 1616 S. Voss
Rd., Suite 125, Houston, Texas 77057

  II. BASIS OF JURISDICTION                                          (place an "X" in One Box Only)                   III. 	CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Box for Plaintiff
                                                                                                                              (For Diversity Cases Only)        and One Box for Defendant)
 o    I     U.S. Govenunent                          ~ 3 Federal Question                                                                                   PTF       DEF                                             PTF        DEF
               Plaintiff                                        (U.S. Govenunent Not a Party)                            Citizen ofThis State               0   I     0    1 	 Incorporated or Principal Place         0    4    0 4
                                                                                                                                                                               of Business In This State

 o2         U.S. Govenunent                          o   4    Diversity                                                  Citizen of Another State           o   2     0     2   Incorporated and Principal Place       o    5    0   5
               Defendant                                                                                                                                                           of Business In Another State
                                                                (Indicate Citizenship of Parties in Item III)
                                                                                                                                                            o   3     0     3 	 Foreign Nation                         o    6    0 6

 IV. NATURE OF SUIT (Placean"X"inOneBoxOnlv)
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 o   110 It!surance                                  PERSONAL INJURY                         PERSONAL INJURY             o 610 Agriculture                      o   422 Appeal 28 USC 158          0   400 State Reapportionment
 o   120 Marine                                  0   310 Airplane                    0        362 Personal Injury ­      0620 Other Food & Drug                 o   423 Withdrawal                 0   410 Antitrust
 o   130 Miller Act                              0   315 Airplane Product                         Med. Malpractice       o 625 Drug Related Seizure                     28 USC 157                 0   430 Banks and Banking
 o   140 Negotiable Instrument                           Liability                   0       365 Personal Injury -               of Property 21 USC 881                                            0   450 Commerce
 o   ISO Recovery of Overpayment                 0   320 Assault, Libel &                         Product Liability      o 630 Liquor Laws                      r;!·?i.iPR~PE&1!fi(                0   460 Deportation
         & Enforcement ofJudgment                        Slander                     0       368 Asbestos Personal       o 640 R.R. & Truck                     o 820 Copyrights                   0   470 Racketeer Influenced and
 o   151 Medicare Act                            0   330 Federal Employers'                       Injury Product         o 650 Airline Regs.                    ~ 830 Patent                               Corrupt Organizations
 o   152 Recovery of Defaulted                           Liability                                Liability              o 660 Occupational                     o 840 Trademark                    0   480 Consumer Credit
         Student Loans                           0   340 Marine                       PERSONAL PROPERTY                          Safety/Health                                                     0   490 Cable/Sat TV
         (Excl. Veterans)                        0   345 Marine Product              0 370 Other Fraud                   o   690 Other                                                             0   810 Selective Service
 o   153 Recovery ofOverpayment                          Liability                   0 371 Truth in Lending                                                               ~                        0   850 Securities/Commoditiesl
         of Veteran's Benefits                   0   350 Motor Vehicle               0       380 Other Personal          o 710 Fair Labor Standards             o   861 HlA (1395ff)                       Exchange
 o   160 Stockholders' Suits                     0   355 Motor Vehicle                           Property Damage                 Act                            o   862 Black Lung (923)           0   875 Customer Challenge
 o   190 Other Contract                                  Product Liability           0       385 Property Damage         o   720 Labor/Mgmt. Relations          o   863 DlWCIDIWW (405(g»                  12 USC 3410
 o   195 Contract Product Liability              0   360 Other Personal                          Product Liability       o   730 LaborlMgmt.Reporting           o   864   ssmTitle XVI             0   890 Other Statutory Actions
 o   196 Franchise                                       Injury                                                                 & Disclosure Act                o   865 RSI (405(g»                0   891 Agricultural Acts
                                                                                                                         o   740 Railway Labor Act                                                 0   892 Economic Stabilization Act
 o 210 Land Condemnation                         0   441 Voting                      0       510 Motions to Vacate       o   790 Other Labor Litigation         o   870 Taxes (U.S. Plaintiff      0   893 Environmental Matters
 o 220 Foreclosure                               0   442 Employment                              Sentence                o   791 Empl. Ret. Inc.                         or Defendant)             0   894 Energy Allocation Act
 o 230 Rent Lease & Ejectment                    0   443 Housing!                            Habeas Corpus:                      Security Act                   o   87 I IRS-Third Party           0   895 Freedom ofInformation
 o 240 Torts to Land                                    Accommodations               0       530 General                                                                 26 USC 7609                       Act
 o 245 Tort Product Liability                    0   444 Welfare                     0       535 Death Penalty                                                                                     0   900Appeal of Fee Detennination
 o 290 All Other Real Property                   0   445 Amer. wfDisabilities­       0       540 Mandamus & Other       f0462                    ~j;':;:~
                                                                                                                                                                                                           Under Equal Access
                                                        Employment                   0       550 Civil Rights            o 463 Habeas Corpus ­                                                             to Justice
                                                 0   446 Amer. w/Disabilities ­      0       555 Prison Condition             Alien Detainee                                                       0   950 Constitutionality of
                                                        Other                                                            o 465 Other Immigration                                                           State Statutes
                                                 0   440 Other Civil Rights                                                     Actions




 V. ORIGIN                           (Place an "X" in One Box Only)                                                                                                                                                 Appeal to District
 1St 1 Original                  o     2 Removed from                     0 3 Remanded from                     o      4 Reinstated or 0         5 Transferr~d from 0 6 Multidistrict                   ,..., 7 Judge from
                                                                                                                                                                                                        U           Magistrate
            Proceeding                     State Court                              Appellate Court                      Reopened                   anoth.er dIstrIct                 Litigation
                                                                                                                                                     s eel                                                          Jud ment
                                                         Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
                                                          Title 35 of the United States Cod
 VI. CAUSE OF ACTION t:B~r~ie7fd7e~sc""r~ip~tio.l;;!.n.l.loo:":f~c.u.au~s::':e:::I....l:;:~~~:::::.l=i:'-'------------------------------

                                                          P       nt Infrin              t
 VII. REQUESTED IN                                       o    CHECK IF THIS IS A CLASS ACTION                                DEMAND $                                       CHECK YES only if demanded in complaint:
            COMPLAINT:                                        UNDER F.R.C.P. 23                                                                                             JURY DEMAND:                ~ Yes         C'J No
 VIII. RELATED CASE(S)
                                                             (See instructions):
              IF   ANY 	                                                            JUDGE           T. John Ward                                                    DOCKET NUMBER 2:10-cv-265/2:10-cv-272

 DATE




   RECEIPT #                               AMOUNT                                             APPLYING IFP 	
                                                                                                                -------                          JUDGE                                 MAG. JUDGE
                                                                                                                                                                                                       ------------

				
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