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Linex Technologies v. Juniper Networks

Linex Technologies v. Juniper Networks

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 9:13-cv-80292-KAM: Linex Technologies, Inc. v. Juniper Networks, Inc. Filed in U.S. District Court for the Southern District of Florida, the Hon. Kenneth A. Marra presiding. See http://news.priorsmart.com/-l7RJ for more info.
Official Complaint for Patent Infringement in Civil Action No. 9:13-cv-80292-KAM: Linex Technologies, Inc. v. Juniper Networks, Inc. Filed in U.S. District Court for the Southern District of Florida, the Hon. Kenneth A. Marra presiding. See http://news.priorsmart.com/-l7RJ for more info.

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Published by: PriorSmart on Mar 22, 2013
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07/08/2013

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IN THE UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
CASE NO.:________________________ LINEX TECHNOLOGIES, INC.,Plaintiff,v.JUNIPER NETWORKS, INC.,Defendant.
COMPLAINT
Plaintiff, Linex Technologies, Inc., brings this action for patent infringementagainst Juniper Networks, Inc., and states as follows:
The Parties
1. Linex is a Delaware corporation with its principal place of business in PalmBeach Gardens, Florida. Linex employs sophisticated electrical engineers who havesuccessfully patented numerous inventions in a variety of fields, including wireless networking.2. Linex engineers have more than 125 years of combined experience in wirelesscommunications, have published numerous papers in this area of communications, are theinventors of more than 150 patents in the wireless area and hold numerous awards for their contributions to this field.3. Juniper is a Delaware corporation with its principal place of business inSunnyvale, California. Juniper makes and sells wireless networks and wireless network components, which infringe on at least two patents owned by Linex.
 
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Jurisdiction and Venue
4. This action arises under the patent laws of the United States, 35 U.S.C. § 1
et  seq.,
and jurisdiction is properly based under §§ 271 and 281, and 28 U.S.C. § 1338(a).5. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and (c).6. Juniper is subject to jurisdiction of Florida courts pursuant to Fla. Stat.§48.193(1)(a) and (b) because it conducts business activities in Florida and within this judicialdistrict, including regularly doing or soliciting business, engaging in conduct and derivingsubstantial revenue from the sale of its infringing products in Florida. Juniper is registered to do business in Florida and maintains a registered agent in the state of Florida. Upon informationand believe, Juniper maintains a sales office in Ft. Lauderdale, Florida, from which it regularlysells infringing products.
Background of Mesh Networks
7. This case involves an emerging communications technology known as “meshnetworks.Mesh networks efficiently connect large numbers of remote stations to centralstations or gateways by using nodes. The nodes "talk" to each other through hardware andsoftware to facilitate their interaction. By hopping from one mesh node to the next, the nodescan automatically choose the quickest and the most reliable path for information to be sent andreceived by the remote stations.8. Effort to standardize mesh networks have resulted in several published standardsincluding IEEE 802.11s and IEEE 802.15.4.
Count I - Patent Infringement (‘377 patent)
9. Linex owns United States Patent No. 6,493,377 entitled "Distributed Network,Spread-Spectrum System" which was issued on December 10, 2002 ("the '377 patent").
See
 
3
 Exhibit A.
The ‘377 patent encompasses an invention for distributed networks having a plurality of remote stations and plurality of nodes commonly referred to as a “mesh”network.10. The '377 patent is presumed valid under 35 U.S.C. § 282.11. Linex has the exclusive right to enforce and license the '377 patent.12. Juniper manufactures and sells mesh networks and mesh network components,including but not limited to: Juniper WLA632 Wireless LAN Access Point, Juniper WLA532Wireless LAN Access Point, Juniper WLA522 Wireless LAN Access Point, Juniper WLA322Wireless LAN Access Point, Juniper WLA321 Wireless LAN Access Point, Juniper WLM1200Ringmaster Appliance, Juniper WLM Ringmaster Software, and Juniper WLM RingmasteLicenses. These products infringe the ‘377 patent either literally or under the doctrine of equivalents making Juniper liable for direct patent infringement, contributory patentinfringement, or inducement of patent infringement.13. Juniper is aware of the ‘377 patent and Linex’s exclusive right to enforce andlicense the patent. Upon information and belief, Juniper was and is aware that the products itmanufactures and sells infringe the ‘377 patent. Linex wrote to Juniper on March 8, 2012 toexplain its patented technology and to offer Juniper the opportunity to discuss a licensingarrangement. Linex also contacted the CEO of Juniper on April 19, 2012. Juniper neveresponded to Linex’s offer.14. Juniper’s unlicensed manufacture and sale of the products listed aboveinfringe the '377 patent causing injury to Linex. As a result of this infringement, Linex isentitled to recover compensatory damages that at a minimum are equal to a reasonableroyalty.

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