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Protegrity v. SafeNet

Protegrity v. SafeNet

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-00440: Protegrity Corporation v. SafeNet, Inc. Filed in U.S. District Court for the District of Connecticut, no judge yet assigned. See http://news.priorsmart.com/-l7Uw for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-00440: Protegrity Corporation v. SafeNet, Inc. Filed in U.S. District Court for the District of Connecticut, no judge yet assigned. See http://news.priorsmart.com/-l7Uw for more info.

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Published by: PriorSmart on Apr 01, 2013
Copyright:Public Domain

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04/01/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF CONNECTICUT
 ____________________________________ PROTEGRITY CORPORATION )a Cayman Islands Company, ))Plaintiff, )) Civil Action No. 3:13-cv-00440v. ))SAFENET, INC. )a Delaware Corporation, ))Defendant. ) JURY TRIAL DEMAND ____________________________________)
COMPLAINT
Plaintiff, PROTEGRITY CORPORATION, by and through its undersigned attorneys,alleges, upon information and belief, as follows: THE PARTIES1.
 
Plaintiff, Protegrity Corporation, is a corporation incorporated under the laws of the country of The Cayman Islands, with its principal operating subsidiary in the United States,Protegrity USA, Inc., a Delaware Corporation, having its principal place of business at 5 HighRidge Park, Stamford, Connecticut 06905.2.
 
Upon information and belief, Defendant, Safenet, Inc. is a DelawareCorporation, having its principal place of business in the State of Maryland and having anoffice at 4690 Millennium Drive, Belcamp, MD 21017.3.
 
 This action has arisen under the patent laws of the United States, Title 35 United-
1
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States Code, Section 271
et seq.
4.
 
 Jurisdiction of this action arises under 28 U.S.C. §1338(a). Venue is predicatedunder 28 U.S.C. §1391(c).COUNT I1.
 
On March 19, 2013, United States Patent Number 8,402,281 (hereinafter “’281Patent”) entitled "Data Security System for a Database" was duly and regularly issued. A copyof the 281 Patent is attached hereto as Exhibit "A".2.
 
Plaintiff is the owner of the ‘281 Patent.3.
 
Upon information and belief, Defendant has directly or contributorily infringedor induced the infringement of the claims of 281 Patent by having made, used or sold databasesecurity systems that duly embody the invention as claimed therein; such infringement waswillful and deliberate; the infringement by Defendant of said Plaintiff's ‘281 Patent hasdeprived Plaintiff of sales which it otherwise would have made and has in other respectsinjured Plaintiff and will cause Plaintiff added injury and loss of profits unless enjoined by thisCourt.4.
 
 The Plaintiff has been damaged by the acts of infringement complained oherein.5.
 
 The Plaintiff has no adequate remedy without the intervention of this Court.6.
 
 This case is "exceptional" within the meaning of 35 USC § 285.-
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