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Worqflow Technologies v. Invensys Systems

Worqflow Technologies v. Invensys Systems

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 4:13-cv-00642: Worqflow Technologies, LLC v. Invensys Systems, Inc. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l7MV for more info.
Official Complaint for Patent Infringement in Civil Action No. 4:13-cv-00642: Worqflow Technologies, LLC v. Invensys Systems, Inc. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l7MV for more info.

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Published by: PriorSmart on Mar 11, 2013
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IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF TEXASHOUSTON DIVISION
WORQFLOW TECHNOLOGIES, LLC,Plaintiff,v.INVENSYS SYSTEMS, INC.,Defendant.Case No. 4:13-CV-642
 JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
 This is an action for patent infringement in which Worqflow Technologies, LLC(“Worqflow” or “Plaintiff”) makes the following allegations against Invensys Systems, Inc.(“Invensys” or “Defendant”).
PARTIES
1.
 
Plaintiff Worqflow is a California limited liability company with its principalplace of business at 547 South Marengo Ave., Ste. 104, Pasadena, CA 91101.2.
 
On information and belief, Invensys is a Massachusetts corporation with itsprincipal place of business at 33 Commercial St., Foxboro, MA 02035. On information andbelief, Invensys may be served with process by serving its registered agent, Registered AgentSolutions, Inc., at 1701 Directors Blvd., Ste. 300, Austin, TX 78744.
 JURISDICTION AND VENUE
 3.
 
 This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and1338(a).
 
-2-4.
 
Venue is proper in this district under 28 U.S.C. §§ 1391(c) and 1400(b). Oninformation and belief, Invensys has transacted business in this district, and has committed actsof patent infringement in this district.5.
 
Further, on information and belief, Invensys maintains documents and witnessesrelated to this action within the subpoena power of this Court. Invensys lists 10900 Equity Dr.,Houston, TX 77041 as its corporate address for Invensys Operations Management. See thescreenshot for Invensyss Skelta BPM contact us window retrieved from http://www.skelta.com,  a true and correct copy of which is attached hereto as Exhibit A. Invensys states that InvensysOperations Management “is a leading provider of automation and information technology,systems, software solutions, services and consulting to the global manufacturing andinfrastructure industries. Headquartered in Houston, Texas.” See Invensys’s Skelta BPMcompany page retrieved from http://www.skelta.com/company/ a true and correct copy of which is attached hereto as Exhibit B.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 5,630,069
6.
 
Plaintiff is the owner by assignment of United States Patent No. 5,630,069 (“the069 Patent”) entitled “Method and Apparatus for Creating Workflow Maps of BusinessProcesses” – including all rights to recover for past and future acts of infringement. The 069Patent issued on May 13, 1993. A true and correct copy of the ‘069 Patent is attached hereto asExhibit C.7.
 
On information and belief, Invensys has been and now is infringing the 069Patent in this judicial district, and elsewhere in the United States through its use of at least anbusiness process management and workflow software suite. Acts of infringement by Invensysinclude, without limitation, utilizing computer based systems and methods for creating a
 
-3-representation of a business process and its associated workflows that include every element of atleast one claim of the 069 Patent within the United States. Such infringing acts includemethods, for example, such as those used by Invensys in executing its Skelta BPM software(“Accused Methods”). Invensys is thus liable for infringement of the 069 Patent under 35U.S.C. § 271.8.
 
Invensys infringes at least Claim 26 of the ‘069 Patent, by way of example only,and without limitation on Worqflow’s assertion of infringement by Invensys of other claims of the 069 Patent. Claim 26 of the 069 Patent reads as follows:26. A computer based method for creating a representation of a business processand its associated workflows, said method comprising the steps of:a) executing a computer program by a computer;b) said program generating when said program is executed by said computer i) acomponent representation of at least a predetermined subset of said businessprocess in terms of its workflows, ii) at least a predetermined subset of linksbetween said workflows based upon a predetermined set of workflow rules, andiii) conditional links between said workflows, each of said conditional linksincluding a conditional junction, an origin link between a source workflow andsaid conditional junction and at least one target link between said conditional junction and a corresponding number of target workflows.9.
 
Invensys practices through its Accused Methods at least “a computer basedmethod for creating a representation of a business process and its associated workflows.” This ismade clear by Invensyss compliance with the Business Process Modelling Notations (BPMN)standards in its Skelta Accused Methods. Invensys has stated that Skelta BPM is “BPMNCompliant.” See Invensys’s Skelta BPMN Overview brochure retrieved fromhttp://www.skelta.com/bpm-resources/downloads/product-resources/Skelta-BPM-Overview.pdf , a true and correct copy of which is attached as Exhibit D. Invensys has also stated that “Skeltafollows the industry standard BPMN (Business Process Modelling Notations) for modeling.”See the final page of Invensys’s ROI of BPM whitepaper retrieved from

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