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MyKey Technology v. Tefkat

MyKey Technology v. Tefkat

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00413-LA: MyKey Technology, Inc. v. Tefkat LLC. Filed in U.S. District Court for the Eastern District of Wisconsin, the Hon. Lynn Adelman presiding. See http://news.priorsmart.com/-l828 for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00413-LA: MyKey Technology, Inc. v. Tefkat LLC. Filed in U.S. District Court for the Eastern District of Wisconsin, the Hon. Lynn Adelman presiding. See http://news.priorsmart.com/-l828 for more info.

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Published by: PriorSmart on Apr 15, 2013
Copyright:Public Domain

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07/26/2013

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Defendants.
*** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *COMPLAINT
Plaintiff MyKey Technology Inc. (“MyKey” or “Plaintiff”), for its Complaint againstDefendants TEFKAT LLC (“TEFKAT”) and Robert Botchek (collectively, “Defendants”), statesand alleges as follows:
 THE PARTIES
1.
 
MyKey is a Delaware corporation with its principal place of business at 7851 CBeechcraft Avenue, Gaithersburg, Maryland 20879.2.
 
Defendant TEFKAT is a Wisconsin corporation having its principal place of business at 16945 Hidden Creek Ct., Brookfield, Wisconsin 53005. TEFKAT is formerly known
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLANDSouthern Division, GreenbeltMYKEY TECHNOLOGY INC., **7851 C Beechcraft Avenue
, *
Gaithersburg, MD 20879 **Montgomery County **
Plaintiff,
**v
.
* Case No.
*
 TEFKAT LLC, * JURY TRIAL DEMANDED*16945 Hidden Creek Court, *Brookfield, WI 53005 **And **ROBERT BOTCHEK **16945 Hidden Creek Court, *Brookfield, WI 53005 *
 
 2as Tableau LLC prior to May 10, 2010.3.
 
Defendant Robert Botchek is an individual residing at 16945 Hidden Creek Ct.,Brookfield, Wisconsin 53005. Robert Botchek is the registered agent and owner of TEFKAT.
 JURISDICTION AND VENUE
4.
 
 This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
etseq
., including 35 U.S.C. § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C.§§ 1331 and 1338(a).5.
 
Defendants are subject to personal jurisdiction in this judicial district becauseeach Defendant has conducted and does conduct business within the State of Maryland. EachDefendant, directly or through a sham corporation, shipped, distributed, offered for sale, sold,and advertised (including the provision of an interactive web page) products in the United States,the State of Maryland, and the District of Maryland. Each Defendant has purposefully andvoluntarily placed one or more infringing products, as described below, into the stream of commerce with the expectation that they would be purchased by consumers within the District of Maryland. These infringing products had been purchased by consumers within the District of Maryland. Each Defendant has committed the tort of patent infringement within the State of Maryland and, more particularly, within the District of Maryland.6.
 
Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b), 1391(c) and1391(d) and 28 U.S.C. § 1400(b). Defendants reside in this district because they are subject topersonal jurisdiction in this district.
BACKGROUND
7.
 
MyKey owns all of the rights, title and interests in U.S. Patent No. 6,813,682 (the“’682 patent”), U.S. Patent No. 7,159,086 (the “’086 patent”) and U.S. Patent No. 7,228,379 (the
 
 3“’379 patent”) (collectively, the “patents-in-suit”).8.
 
 The ’682 patent, entitled Write Protection for Computer Long-Term MemoryDevices,” was duly and legally issued by the United States Patent and Trademark Office onNovember 2, 2004, after full and fair examination. A copy of the 682 patent is attached heretoas Exhibit A. MyKey has made, offered for sale, and sold within the United States products thatembody the claimed invention of the ’682 patent and that are marked with the ’682 patentnumber.9.
 
 The ’086 patent, entitled Systems and Methods For Creating Exact Copies OComputer Long-Term Storage Devices,” was duly and legally issued by the United States Patentand Trademark Office on January 2, 2007, after full and fair examination. A copy of the 086patent is attached hereto as Exhibit B. MyKey has made, offered for sale, and sold within theUnited States products that embody the claimed invention of the ’086 patent and that are markedwith the ’086 patent number.10.
 
 The ’379 patent, entitled Systems and Methods For Removing Data Stored OnLong-Term Memory Devices,” was duly and legally issued by the United States Patent and Trademark Office on June 5, 2007, after full and fair examination. A copy of the ’379 patent isattached hereto as Exhibit C. MyKey has made, offered for sale, and sold within the UnitedStates products that embody the claimed invention of the ’379 patent and that are marked withthe ’379 patent number.
COUNT IINFRINGEMENT OF THE ’682 PATENT
11.
 
MyKey incorporates each of the preceding paragraphs 1-10 as if fully set forthherein.

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