Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Princeton Digital Image v. FTD Group et. al.

Princeton Digital Image v. FTD Group et. al.

Ratings: (0)|Views: 25|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00518-UNA: Princeton Digital Image Corporation v. FTD Group Inc. et al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7Vu for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00518-UNA: Princeton Digital Image Corporation v. FTD Group Inc. et al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l7Vu for more info.

More info:

Published by: PriorSmart on Apr 03, 2013
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

04/03/2013

pdf

text

original

 
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
 PRINCETON DIGITAL IMAGE CORPORATION,Plaintiff,v.FTD GROUP, INC. and UNITED ONLINE, INC.,Defendants.Case No. JURY TRIAL DEMANDED
COMPLAINT
Princeton Digital Image Corporation (hereafter “Princeton”), Plaintiff, brings this actionagainst FTD Group, Inc. and United Online, Inc. (hereafter “Defendants”), and alleges that:
PARTIES
1.
 
Plaintiff Princeton is a corporation organized and doing business under the lawsof Texas.2.
 
Upon information and belief, Defendants are each Delaware corporations. EachDefendant has as its agent for service of process National Registered Agents, Inc., 160 GreentreeDrive, Suite 101, Dover, DE 19904. Upon information and belief, each Defendant regularlyconducts and transacts business in Delaware within this Judicial District, and throughout theUnited States, itself and/or through one or more subsidiaries, affiliates, business divisions, orbusiness units.
 JURISDICTION AND VENUE
3.
 
 This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. § 271,
et seq
.4.
 
 This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338(a).
 
25.
 
 This Court has personal jurisdiction over Defendants since, on information andbelief, each Defendant has transacted business in this judicial district, directly or throughintermediaries, and/or committed acts of infringement in this judicial district.6.
 
Venue in this district over Defendants is proper under 28 U.S.C. § 1391(c) and (d)and 1400(b).
BACKGROUND
7.
 
On March 14, 1989, United States Patent No. 4,813,056 (hereafter “the 056Patent”) was duly and legally issued to Nicola J. Fedele, as the inventor thereof, and at allapplicable times was valid and subsisting. A copy of the ‘056 Patent, which is entitled “ModifiedStatistical Coding of Digital Signals,” is attached hereto as Exhibit “A”.8.
 
Nicola J. Fedele originally assigned his rights to the 056 Patent to GeneralElectric Company, which assigned all rights, title and interest in and to the 056 Patent toPrinceton Digital Image Compression, LLC. Princeton Digital Image Compression, LLC hasassigned all of its rights, title and interest in and to the ‘056 Patent to Princeton Digital ImageCorporation, Plaintiff herein, the current holder of the ‘056 Patent.
INFRINGEMENT OF THE `056 PATENT
9.
 
Upon information and belief, Defendants infringed the ’056 patent in violation of 35 U.S.C. § 271(a) by using the patented invention to,
inter alia
, encode images in a manner thatinfringed claims 18, 19, 20, 21 and 23 of the 056 patent. For example, upon information andbelief, Defendants encoded image data into JPEG files for purposes of producing JPEG imagesof products sold through Defendants’ websites and/or converting existing images of suchproducts into JPEG images of said products having different sizes and/or image quality, all fordisplay on Defendants’ websites (including www.ftd.com) for the purpose of selling saidproducts.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->