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Stambler v. Capital One Financial et. al.

Stambler v. Capital One Financial et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00609: Stambler v. Capital One Financial Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6LQ for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:12-cv-00609: Stambler v. Capital One Financial Corporation et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l6LQ 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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 1
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONLEON STAMBLER,
 Plaintiff,
v.CAPITAL ONE FINANCIALCORPORATION; CAPITAL ONE BANK(USA), NATIONAL ASSOCIATION;CAPITAL ONE, NATIONALASSOCIATION; and CAPITAL ONESERVICES, LLC f/k/a CAPITAL ONESERVICES, INC.,
 Defendants.
§§§§§§§§§§§§§§§Civil Action No. 2:12-cv-609JURY TRIAL DEMANDEDPLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff LEON STAMBLER files this Original Complaint for Patent Infringementagainst the above-named Defendants, alleging as follows:
I. THE PARTIES
 1.
 
Plaintiff LEON STAMBLER (“Stambler”) is an individual residing in Parkland,Florida.2.
 
Defendant CAPITAL ONE FINANCIAL CORPORATION is a Delawarecorporation with its principal place of business in McLean, Virginia. This Defendant may beserved with process through its registered agent, Corporation Service Company, 2711 CentervilleRoad Suite 400, Wilmington, Delaware 19808.3.
 
Defendant CAPITAL ONE BANK (USA), NATIONAL ASSOCIATION (asubsidiary of Capital One Financial Corporation) is a federally-chartered banking institution with
 
 2its principal place of business in Glen Allen, Virginia. This Defendant may be served withprocess through its registered agent, Corporation Service Company, 11 South 12
th
Street,Richmond, Virginia 23218.4.
 
Defendant CAPITAL ONE, NATIONAL ASSOCIATION (a subsidiary of Capital One Financial Corporation) is a federally-chartered banking institution with its principalplace of business in McLean, Virginia. This Defendant may be served with process through itsregistered agent, Corporation Service Company, 2711 Centerville Road Suite 400, Wilmington,Delaware 19808.5.
 
Defendant CAPITAL ONE SERVICES, LLC f/k/a CAPITAL ONE SERVICES,INC. (a subsidiary of Capital One Financial Corporation) is a Delaware limited liability companywith its principal place of business in McLean, Virginia. This Defendant may be served withprocess through its registered agent, Corporation Service Company, 2711 Centerville Road Suite400, Wilmington, Delaware 19808.
II. JURISDICTION AND VENUE
6.
 
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).7.
 
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. Each
 
 3Defendant 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
., capitalone.com). Through the provisions of such productsand/or services, each Defendant has committed and continues to commit acts of patentinfringement in the State of Texas and in this District.
III. PATENT INFRINGEMENT
8.
 
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.9.
 
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.10.
 
Stambler is the inventor and owner of all rights, title, and interest in and to the‘302 and ‘148 patents, and Stambler possesses all rights of recovery under them.
COUNT I (INFRINGEMENT OF U.S. PATENT NO. 5,793,302)
11.
 
Defendants CAPITAL ONE FINANCIAL CORPORATION, CAPITAL ONEBANK (USA), NATIONAL ASSOCIATION, CAPITAL ONE, NATIONAL ASSOCIATION,and CAPITAL ONE SERVICES, LLC f/k/a CAPITAL ONE SERVICES, INC. (together,“Capital One”) have infringed and continue to infringe, directly, and/or through the inducementof others, claimed methods of the ‘302 patent.12.
 
Capital One 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 online

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