3. This is an action for patent infringement pursuant to 35 U.S.C. §101, et. seq.
JURISDICTION AND VENUE
4. This Court has jurisdiction over the subject matter
this action pursuant to 28U.S.C. §§1331 and 1338.5.
§§1391 and 1400(b).
On August 18, 2009, U.S. Patent No. 7,575,158 (the
patent") was duly andlegally issued to David M. Barcelou. A true and correct copy
158 patent is attached heretoas Exhibit A.
license, Automated Transactions is the exclusive licensee
the '158 patentwith the right to sue for past and future infringement and collect damages therefore in its ownname.
The '158 patent discloses and claims, among other things, integrated banking andtransaction machines. Claims 1-3, 11-13 and
state as follows:
integrated banking and transaction machine for use
aconsumer to purchase access to retail ATM services, comprising:an automated teller machine; ·a user interface to the automated teller machine;means for identifying the user to the automated teller machine,further comprising a smart card/magnetic stripe reader/encoder anda sensor;an Internet interface to an Internet connection to the automatedteller machine that uses encryption services and security services toprovide the user access to the user interface and retail A