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Stambler v. Ally Financial et. al.

Stambler v. Ally Financial et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00608: Stambler v. Ally Financial Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6LP for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00608: Stambler v. Ally Financial Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6LP for more info.

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Published by: PriorSmart on Sep 22, 2012
Copyright:Public Domain

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02/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONLEON STAMBLER,
 Plaintiff,
v.ALLY FINANCIAL INC. and ALLY BANK,
 Defendants.
§§§§§§§§§Civil Action No. 2:12-cv-608JURY TRIAL DEMANDEDPLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff LEON STAMBLER files this Original Complaint for Patent Infringementagainst ALLY FINANCIAL INC. and ALLY BANK, alleging as follows:
I. THE PARTIES
 1.
 
Plaintiff LEON STAMBLER (“Stambler”) is an individual residing in Parkland,Florida.2.
 
Defendant ALLY FINANCIAL INC. is a Delaware corporation with its principalplace of business in Detroit, Michigan. This Defendant may be served with process through itsregistered agent, The Corporation Trust Company, Corporation Trust Center, 1209 OrangeStreet, Wilmington, Delaware 19801.3.
 
Defendant ALLY BANK (a subsidiary of Ally Financial Inc.) is a Utahcorporation with its principal place of business in Midvale, Utah. This Defendant may be servedwith process through its registered agent, Corporation Service Company, 2711 Centerville RoadSuite 400, Wilmington, Delaware 19808.
 
 2
II. JURISDICTION AND VENUE
4.
 
This is an action for patent infringement arising under 35 U.S.C. §§ 271, 281, and284-285, among others. This Court has subject matter jurisdiction of this action under Title 28U.S.C. §1331 and §1338(a).5.
 
The Court has general and specific personal jurisdiction over each Defendant, andvenue is proper pursuant to 28 U.S.C. §§ 1391 and 1400(b). Each Defendant has substantialcontacts with the forum as a result of pervasive business activities conducted within the State of Texas and within this District. On information and belief, each Defendant regularly solicitsbusiness in Texas and in this District, and derives substantial revenue from products, systems,and/or services provided to individuals or entities residing in Texas and in this District. EachDefendant provides secure online transaction services directly to customers in this Districtthrough its interactive website(s). Specifically, each Defendant conducts business relating tosecure online banking, including online bill pay, with and for customers residing in this Districtthrough interactive website(s) (
e.g.
, ally.com). Through the provisions of such products and/orservices, each Defendant has committed and continues to commit acts of patent infringement inthe State of Texas and in this District.
III. PATENT INFRINGEMENT
6.
 
On August 11, 1998, United States Patent No. 5,793,302 (“the ‘302 patent”) wasduly and legally issued for a “Method for Securing Information Relevant to a Transaction.” Atrue and correct copy of the ‘302 patent is attached hereto as Exhibit A.7.
 
On October 26, 1999, United States Patent No. 5,974,148 (“the ‘148 patent”) wasduly and legally issued for a “Method for Securing Information Relevant to a Transaction.” Atrue and correct copy of the ‘148 patent is attached hereto as Exhibit B.
 
 38.
 
On August 10, 1999, United States Patent No. 5,936,541 (“the ‘541 patent”) wasduly and legally issued for a “Method for Securing Information Relevant to a Transaction.” Atrue and correct copy of the ‘541 patent is attached hereto as Exhibit C.9.
 
Stambler is the inventor and owner of all rights, title, and interest in and to the‘302, ‘148, and ‘541 patents, and Stambler possesses all rights of recovery under them.
COUNT I (INFRINGEMENT OF U.S. PATENT NO. 5,793,302)
10.
 
Defendants ALLY FINANCIAL INC. and ALLY BANK (together, “Ally Bank”)have infringed and continue to infringe, directly, and/or through the inducement of others,claimed methods of the ‘302 patent.11.
 
Ally Bank has been and now is directly infringing claims of the ‘302 patent,including (for example) at least claims 41 and 47 of the ‘302 patent, by performing secure onlinetransactions initiated using Ally Bank’s secure online banking products and/or services (
e.g.
,Ally Online Banking, Ally Auto Online Services) accessible through Ally Bank’s interactiveonline website(s) (
e.g.
, ally.com) and, upon information and belief, claim 8 of the ‘302 patent byengaging in encrypted communications between computers or other devices owned by AllyBank.12.
 
Ally Bank has been and now is inducing its customers’ direct infringement of claims of the ‘302 patent, including (for example) at least claim 8 of the ‘302 patent, by requiringcustomers to use SSL and/or TLS to secure information communicated using Ally Bank’s secureonline banking products and/or services (
e.g.
, Ally Online Banking, Ally Auto Online Services)accessible through Ally Bank’s interactive online website(s) (
e.g.
, ally.com).

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