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Automated Transactions v. Southbridge Savings Bank et. al.

Automated Transactions v. Southbridge Savings Bank et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00502-SLR: Automated Transactions LLC v. Southbridge Savings Bank et. al. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l7VC for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00502-SLR: Automated Transactions LLC v. Southbridge Savings Bank et. al. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l7VC for more info.

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Published by: PriorSmart on Apr 03, 2013
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04/03/2013

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970473
UNITEDSTATESDISTRICTCOURTFORTHEDISTRICTOFMASSACHUSETTS
-------------------------------------------------------------------------- xCivil Action No. ________
JURYTRIALDEMANDED.
AUTOMATED TRANSACTIONS LLC,
 Plaintiff  
,- v. -SOUTHBRIDGE SAVINGS BANK and GREEN VALLEYBANCORP, MHC
 Defendants.
:::::::::::::-------------------------------------------------------------------------- x
COMPLAINT
Plaintiff Automated Transactions LLC (“Automated Transactions”) alleges as follows:
PARTIES
1. Automated Transactions is a limited liability company organized and existingunder 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, Southbridge Savings Bank is a Massachusetts state-chartered savings bank with a principal place of business at 253 Main Street #257, Southbridge,MA 1550.3. Upon information and belief, Green Valley Bancorp, Mhc is the holding companyfor Southbridge Savings Bank (jointly “Southbridge”) with a principal place of business at 253Main Street #257, Southbridge, MA 1550, and controls Southbridge Savings Bank as its
 
2subsidiary. Green Valley Bancorp, Mhc. is liable for the purchase of the infringing automatedteller machines (“ATMs”) by its subsidiary, Southbridge Savings Bank, and their infringing use.
NATUREOFACTION
4. This is an action for patent infringement pursuant to 35 U.S.C. § 101, et. seq.
JURISDICTIONANDVENUE
5. This Court has jurisdiction over the subject matter of this action pursuant to 28U.S.C. §§1331 and 1338.6. Venue is proper in this judicial district under 28 U.S.C. §§1391 and 1400(b).
FIRSTCLAIMFORRELIEF
7. 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.8. By license, Automated Transactions is the exclusive licensee of the ‘158 patentwith the right to sue for past and future infringement and collect damages therefore in its ownname.9. The ‘158 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;
 
3an Internet interface to an Internet connection to the automatedteller machine that uses encryption services and security services to provide the user access to the user interface and retail ATMservice; andaccess to the automated teller machine user interface whereuponthe consumer may selectively dispense currency using theintegrated banking and transaction machine providing the retailATM service;wherein the consumer can purchase access to the retail ATMservice through use of the user interface and Internet servicesconnections.2. The integrated banking and transaction machine according to claim1, further comprising means for consummating the purchase withcash.3. The integrated banking and transaction machine according to claim1, further comprising means for consummating the purchase with bills.11. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchasewith a credit card.12. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchasewith a debit card.13. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchasewith a stored value card.15. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchasewith an identification card10. Southbridge is using ATMs within this judicial district which incorporate everyelement of the above claims or substantial equivalents thereof. Therefore, Southbridge is directlyor indirectly infringing at least the above claims of the ‘158 patent, either literally or under the

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