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Automated Transactions v. Llewellyn-Edison Savings Bank

Automated Transactions v. Llewellyn-Edison Savings Bank

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00965-WJM-MF: Automated Transactions LLC v. Llewellyn-Edison Savings Bank. Filed in U.S. District Court for the District of New Jersey, the Hon. William J. Martini presiding. See http://news.priorsmart.com/-l7Ge for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00965-WJM-MF: Automated Transactions LLC v. Llewellyn-Edison Savings Bank. Filed in U.S. District Court for the District of New Jersey, the Hon. William J. Martini presiding. See http://news.priorsmart.com/-l7Ge for more info.

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Published by: PriorSmart on Feb 20, 2013
Copyright:Public Domain

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02/20/2013

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Joshua M. LevyTannenbaum HelpemSyracuse
&
Hirschtritt LLP900 Third AvenueNew York, New York 10022(212) 508-6700
Attorney
for
PlaintiffAutomated Transactions
LLC
UNITED STATES DISTRICT COURT
FOR
THEDISTRICT OF NEW JERSEY
--------------------------------------------------------------------------
](
AUTOMATED TRANSACTIONS LLC,
Plaintiff,
-
v.-
LLEWELLYN-EDISON SAVINGS BANK,
Defendant.
--------------------------------------------------------------------------
](
COMPLAINT
Civil Action No.
___
COMPLAINT ANDDEMAND FOR JURYTRIAL.
Plaintiff Automated Transactions LLC ("Automated Transactions") alleges as follows:
PARTIES
I. Automated Transactions is a limited liability company organized and e](istingunder the laws
of
the state
of
Delaware, having a principal place
of
business at 2711 CentervilleRoad, Suite 400, Wilmington, DE 19808.2. Upon information and belief, Llewellyn-Edison Savings Bank ("Llewellyn") is astate or federally chartered savings bank with a principal place
of
business at 474 ProspectAvenue, West Orange, New Jersey 07052.
975865
 
NATURE OF ACTION
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
of
this action pursuant to 28U.S.C.
§§
1331 and 1338.
5.
Venue is proper in this judicial district under 28 U.S.
C.§§
1391 and 1400(b).
FIRST CLAIM FOR RELIEF
6.
On August 18,2009, U.S. Patent No. 7,575,158 (the
'"158
patent") was duly andlegally issued to David M. Barcelou. A true and correct copy
of
the '158 patent is attached heretoas Exhibit A.
7.
By
license, Automated Transactions is the exclusive licensee
ofthe
'158 patentwith the right to sue for past and future infringement and collect damages therefore in its ownname.
8.
The '15 8 patent discloses and claims, among other things, integrated banking andtransaction machines. Claims 1-3, 11-13 and
15
state as follows:
1.
An
integrated banking and transaction machine for use
by
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 to
2
 
provide
the
user access to the
user
interface and retail
ATM
service; andaccess to the automated teller machine
user
interface whereuponthe
consumer
may
selectively dispense currency
using
the
integrated banking and transaction machine providing
the
retail
ATM
service;wherein the consumer can purchase access to the retail
ATM
service through use
of
the user interface
and
Internet servicesconnections.2.
The
integrated banking
and
transaction machine according to claim
I,
further comprising
means
for consummating the purchase
with
cash.3.
The
integrated banking and transaction machine according to claim
1,
further comprising
means
for consummating the purchase
with
bills.
II.
The
integrated banking and transaction
machine
according to
claim
1, further comprising means for consummating
the
purchase
with
a credit card.12.
The
integrated banking and transaction machine according to
claim
1, further comprising means for consummating the purchasewith a debit card.13.
The
integrated banking and transaction
machine
according to
claim
1, further comprising means for consummating the purchase
with
a stored value card.15.
The
integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchase
with an
identification card9. Llewellyn is using
ATMs
within this judicial district
which
incorporate everyelement
of
the above claims
or
substantial equivalents
thereof
Therefore, Llewellyn is directly
or
indirectly infringing at least the above claims
of
the
'158
patent, either literally
or
under thedoctrine
of
equivalents,
and
is liable for infringement
of
the
'158
patent pursuant to 35 U.S. C.§271.3

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