On June 13, 2006, U.S. Patent No. 7,062,281 B2 (“the ‘281 patent”) was issuedby the United States Patent and Trademark Office (“USPTO”) for a “Multi-Mode PagingSystem.” A true and correct copy of the ‘281 patent is attached as Exhibit B.
Long Range is the owner by assignment of the ‘281 patent and has the right tobring an action for infringement of the ‘281 patent. The Plaintiff, Long Range Systems L.L.C. isthe owner of all right, title and interest by assignment from Long Range2, Inc. (f/k/a Long RangeSystems, Inc.)
the original assignee of the patent. The assignment from the inventors to LongRange Systems, Inc. was recorded on May 28, 2002, Reel: 012949, Frame: 0224. Theassignment from Long Range 2, Inc. to Long Range Systems, L.L.C. was recorded on August 30,2012, Reel: 28878, Frame 0658.
COUNT 1: INFRINGEMENT OF THE ‘751 PATENT
Plaintiff refers to and incorporates all preceding paragraphs as though fully setforth herein.12.
Defendant HME has infringed and continues to infringe – directly, contibutorily,and/or by active inducement – one or more claims of the ‘751 patent, by making, importing,offering to sell, selling, causing to be supplied, using, and/or causing to be used systems andmethods that embody or practice the inventions claimed in the ‘751 patent. Such systems andmethods include SmartCall SMS.13.
For example, Defendant directly infringes the ‘751 patent by selling and/oroffering to sell HME’s SmartCall SMS system in this judicial district.14.
Alternatively, Defendant indirectly infringes the ‘751 patent by contributing toand/or actively inducing its food establishment clients to operate SmartCall SMS. Defendant’s
Long Range Systems, Inc. filed a change of name with the Texas Secretary of State on December 14, 2011thereby changing its name from Long Range Systems, Inc. to Long Range 2, Inc.