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MICROLOG CORP v. CISCO SYSTEMS, INC

MICROLOG CORP v. CISCO SYSTEMS, INC

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Published by PatentBlast
MICROLOG CORP v. CISCO SYSTEMS, INC
MICROLOG CORP v. CISCO SYSTEMS, INC

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Published by: PatentBlast on Feb 02, 2013
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07/22/2013

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1
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASTYLER DIVISIONMICROLOG CORP.,
 Plaintiff 
,V.CISCO SYSTEMS, INC.,
et al.,
 
 Defendants
.§§§§§§§§§CIVIL ACTION NO. 6:11-CV-489-LEDJURY TRIAL DEMANDEDAMENDED COMPLAINT FORPATENT INFRINGEMENT AND JURY DEMAND
Plaintiff Microlog Corp., (“Plaintiff” or “Microlog”), by and through its attorneys, for itsAmended Complaint against Defendants demanding trial by jury, hereby alleges as follows:
I.
 
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. § 271(a), to enjoin and obtain damages resulting from Defendants’unauthorized infringement of United States Patent No. 7,092,509, issued on August 15, 2006, for“Contact Center System Capable of Handling Multiple Media Types of Contacts and Method forUsing the Same” naming John C. Mears of Gaithersburg, Maryland, Gary E. Korzeniowski of New Market, Maryland, William R. Lewis, Jr. of Ellicott City, Maryland, and Ly K. Peang-Methof Gaithersburg, Maryland as inventors (the “’509 Patent), a true and correct copy of which isattached hereto as
Exhibit 1
.
II.
 
PARTIES
2.
 
Microlog is a corporation organized and existing under the laws of the State of Delaware and headquartered in Gaithersburg, Maryland.
6:13CV116SEVERED FROM
 
23.
 
Cisco Systems, Inc. is a corporation organized and existing under the laws of theState of California, with a principal place of business at 170 West Tasman Drive, San Jose,California 95134.4.
 
Aspect Software, Inc. is a corporation organized and existing under the laws of the State of Delaware, with a principal place of business at 300 Apollo Drive, Chelmsford,Massachusetts 01824.5.
 
RightNow Technologies, Inc. is a corporation organized and existing under thelaws of the State of Delaware, with a principal place of business at 600 Las Colinas Blvd. East,Suite 1500, Irving, Texas 75039.6.
 
Moxie Software, Inc. is a corporation organized and existing under the laws of theState of Delaware, with a principal place of business at Barton Oaks II, Suite 100, 901 S. MoPacExpressway, Austin, Texas 78746.7.
 
Contact Solutions, Inc. is a corporation organized and existing under the laws of the State of Delaware, with a principal place of business at 11950 Democracy Drive, Suite 250,Reston, Virginia 20190.8.
 
Nationwide Mutual Insurance Company is a corporation organized and existingunder the laws of the State of Ohio, with a principal place of business at 11603 West CokerLoop, San Antonio, Texas 78216.9.
 
Stonebridge Life Insurance Company is a corporation organized and existingunder the laws of the State of Vermont, with a principal place of business at 2700 W. PlanoParkway, Plano, Texas 75075-8200.
 
310.
 
Frito-Lay, Inc. is a corporation organized and existing under the laws of the Stateof Delaware, with a principal place of business at 7701 Legacy Drive, Plano, Texas 75024.11.
 
On information and belief, Genesys Telecommunications Laboratories, Inc. is acorporation organized and existing under the laws of the State of California, with a principalplace of business at 2001 Junipero Serra Blvd., Daly City, California 94014.
III.
 
JURISDICTION AND VENUE
12.
 
This is an action for patent infringement which arises under the Patent Laws of the United States, in particular, 35 U.S.C. §§271(a), 281, 283, 284 and 285. This Court hasexclusive jurisdiction over the subject matter of this action under 28 U.S.C. §§1331 and 1338(a).13.
 
Defendants are subject to personal jurisdiction in Texas because they regularlytransact business in this judicial district and division by, among other things, offering theirproducts and services to customers, business affiliates and partners located in this judicial districtand division.14.
 
Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b), 1391(c), and1400(b) because the Defendants are subject to personal jurisdiction in this district.
 IV.
 
FACTUAL ALLEGATIONSMICROLOG
15.
 
Microlog has provided call and contact center management to public and privatesector clients for over 40 years. It is a pioneer in the field of integrated all-in-one contactmanagement centers that support multiple communication media. Its customers have included

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