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Automated Transactions v. Heritage Family Credit Union

Automated Transactions v. Heritage Family Credit Union

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00506-SLR: Automated Transactions LLC v. Heritage Family Credit Union. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l7W9 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00506-SLR: Automated Transactions LLC v. Heritage Family Credit Union. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l7W9 for more info.

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Published by: PriorSmart on Apr 04, 2013
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U.S.01STF:;
DISTRICT
i)
C'.
..-!t
:.:'
..
UNITED STATES
DISTRICT COURT
FOR
THEDISTRICT
OF
VERMONT
20120EC
-3
PH
2:
32
--------------------------------------------------------------------------
}C
CLERK
...-:yc..
BY_.,
__
~~~~~-----
DEPUT'(
CLERK
AUTOMATED TRANSACTIONS LLC, Civil Action No.
2":/Z-c,,·
il7D
Plaintiff,
-
v.
JURY TRIAL
DEMANDED.HERITAGE FAMILY CREDIT In'JION
Defendant.
--------------------------------------------------------------------------
}C
COMPLAINT
Plaintiff Automated Transactions LLC ("Automated Transactions") alleges as follows:
PARTIES
1.
Automated Transactions is a limited liability company organized and
e}Cisting
under 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, Heritage Family Credit Union ("Heritage") is acommunity credit union with a principal place
of
business at 30 Allen St., Rutland, VT 05701.NATURE
OF
ACTION
3. This is an action for patent infringement pursuant to 35 U.S.c. §101, et. seq.
JURISDICTION
AND VENUE
4.
This Court has jurisdiction over the subject matter
of
this action pursuant to
28
U.S.C.
§§
1331
and 1338.
970470
LAW OFFICES
I;
EIS, URSO, EWALD
i;.
ANDERSON,
PLLC
,!
NORTH MAIN
STREET
p.
O.
BOXS90
iunAND,
VERMONT
05702-oS90
 
LAW OFFICES
I;
EIS,URSa. EWALD
'::
ANDERSON.
PLLC
,:
NORTH
MAIN
STREET
RO.
BOX
890
IIUT1..AND.
VERMONT
05702-0890
5.
Venue is proper in this judicial district under
28
U.S.C. §§1391 and 1400(b).
FIRST CLAIM FOR RELIEF
6. On August 18,2009, U.S. Patent No. 7,575,158 (the '''158 patent") was dulyand legally issued to David M. Barcelou. A true and correct copy
of
the '158 patent is attachedhereto as Exhibit A.
7.
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.
8.
The '158 patent discloses and claims, among other things, integrated bankingand transaction 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 A TM 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/encoderand a sensor;an Internet interface to an Internet connection to the automatedteller machine that uses encryption services and security servicesto 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 retailA
TM
service;wherein the consumer can purchase access to the retail ATMservice through use
of
the user interface and Internet servicesconnections.
2
 
LAW OFFICES
I;
ElS, URSO, EWALDANDERSON, PLLC
; :
NORTH MAIN
ST'REET
P.
O.
BOX
890
I
tlJTI..AND,
VERMONT
05702-0890
2.
The integrated banking and transaction machine according toclaim
1,
further comprising means for consummating the purchasewith cash.3. The integrated banking and transaction machine according toclaim
1,
further comprising means for consummating the purchasewith 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 card9. Heritage is using ATMs within this judicial district which incorporate everyelement
of
the above claims
or
substantial equivalents thereof. Therefore, Heritage is directly orindirectly infringing at least the above claims
of
the '158 patent, either literally or under thedoctrine
of
equivalents, and is liable for infringement
ofthe
'158 patent pursuant to 35 U.S.C.§271.10. Heritage was made aware
of
the '158 patent and Heritage's infringement thereofby a letter sent to the Bank
on
about June 20, 2012 and through a subsequent letter
on
October,15,2012 to Mr. Ron Hance, President.11. Heritage also provides the above ATMs for use by customers and others withinthis judicial district, and provides those customers and others with detailed explanations,instructions and information as to arrangements, applications and uses
of
these ATMs that
3 

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