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Metasearch Systems v. Expedia et. al.

Metasearch Systems v. Expedia et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-01188-UNA: Metasearch Systems LLC v. Expedia Inc. et. al.. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l6Md for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-01188-UNA: Metasearch Systems LLC v. Expedia Inc. et. al.. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l6Md for more info.

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Published by: PriorSmart on Sep 24, 2012
Copyright:Public Domain

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02/01/2013

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UNITED STATES DISTRICT COURTDISTRICT OF DELAWARE
METASEARCH SYSTEMS, LLC,Plaintiff,v.EXPEDIA, INC., HOTELS.COM LP,HOTELS.COM GP, LLC, andHOTWIRE, INC.,Defendant.)))))))))))
Case No. _______________JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Metasearch Systems, LLC (“Metasearch Systems”) for its causes of action against Defendants Expedia, Inc. (“Expedia”), Hotels.com, L.P. (“Hotels.com,L.P.,” or collectively with Hotels.com GP, LLC, “Hotels.com”), Hotels.com GP, LLC(“Hotels.com GP,” or collectively with Hotels.com, L.P., “Hotels.com”), and Hotwire,Inc. (“Hotwire”) states and alleges as follows:
THE PARTIES
 1.
 
Plaintiff Metasearch Systems is a Delaware limited liability company.Metasearch Systems is the exclusive licensee of 14 United States patents, as well aspending United States patent application(s) and foreign patents. All patents and pendingapplication(s) relate to sophisticated technologies, including metasearching and client-server multitasking technologies (collectively, the “Metasearch Systems Portfolio”). The
 
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Metasearch Systems Portfolio covers technologies developed by Metasearch Systems’President and CEO, Harvey Lunenfeld.2.
 
Defendant Expedia is a Delaware corporation having its principal place of business at 333 108th Avenue NE, Bellevue, WA 98004, and doing business throughoutthis judicial district and throughout the United States.3. Defendant Hotels.com, L.P. is a Texas limited partnership, with itscorporate headquarters and principal place of business at 10440 North CentralExpressway, Suite 400, Dallas, TX 75231. Hotels.com, L.P. is an affiliate of Expedia.4. Defendant Hotels.com GP, LLC is a Texas limited liability company withits corporate headquarters and principal place of business at 10440 North CentralExpressway, Suite 400, Dallas, TX 75231. Hotels.com GP, LLC is a wholly ownedsubsidiary of Expedia.5. Defendant Hotwire, Inc. is a Delaware corporation, with its corporateheadquarters and principal place of business at 333 Market Street, Suite 100, SanFrancisco, CA 94105. Hotwire is a wholly owned subsidiary of Expedia.
JURISDICTION AND VENUE
 6.
 
This Court has subject matter jurisdiction over this action pursuant to 28U.S.C. §§ 1331 and 1338(a), in that this civil action arises under the federal patentstatutes, 35 U.S.C. §§ 271 and 281-285.7.
 
This Court has personal jurisdiction over Expedia, Hotels.com LP,Hotels.com GP, and Hotwire because they have committed acts giving rise to this actionwithin Delaware and within this judicial district and have established minimum contacts
 
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within this forum such that the exercise of jurisdiction over Expedia, Hotels.com LP,Hotels.com GP, and Hotwire would not offend the traditional notions of fair play andsubstantial justice.8.
 
For example, Expedia, Hotels.com, L.P., Hotels.com GP, and Hotwire havecommitted acts of infringement in this District, by offering combined flight, hotel, and/orcar travel booking services on its website that infringe claims of United States PatentNos. 8,239,451, 8,171,079, 8,073,904, 7,490,091, 7,421,468, and 7,277,918.9.
 
Joinder of the Defendants in this action is proper under 35 U.S.C. § 299.Upon information and belief, Defendant Expedia, as the parent company, is responsiblefor the operations of Defendant Hotwire, Defendant Hotels.com, L.P., and DefendantHotels.com GP. Metasearch Systems seeks relief against the Defendants jointly,severally, or in the alternative with respect to the same transactions, occurrences, or seriesof transactions or occurrences relating to the Defendants’ patent infringement. Inaddition, questions of fact common to all Defendants will arise in this action.10.
 
On information and belief, at least some of the IP addresses used byHotels.com’s metasearch engine trace back to IP addresses belonging to Expedia.11.
 
Expedia markets a network of sites, including Hotels.com and Hotwire, forconsolidated advertising. For example, Expedia states:“Get the word out—Expedia, Inc.’s network of sites, which includes Expedia.com,Hotels.com and Hotwire.com, has the largest global footprint of any online travelsite. Our travel lifestyle media platform provides you with unprecedented visibilityand connects you with active, in-market consumers, no matter where they are.”

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