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Automated Transactions v. Enterprise National Bank

Automated Transactions v. Enterprise National Bank

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00589-SLR: Automated Transactions LLC v. Enterprise National Bank. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l82k for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00589-SLR: Automated Transactions LLC v. Enterprise National Bank. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l82k for more info.

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Published by: PriorSmart on Apr 16, 2013
Copyright:Public Domain

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04/16/2013

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Daniel
A.
SuckermanTannenbaum HelpemSyracuse
&
Hirschtritt
LLP
900 Third AvenueNew York, New York 10022(212) 508-6700
Attorney
for
PlaintiffAutomated Transactions
LLC
UNITED STATES DISTRICT COURT FOR THEDISTRICT OF NEW JERSEY
----"---------------------------------------------------------------------
)[
AUTOMATED TRANSACTIONS LLC,
Plaintiff,
-
v.-
ENTERPRISE NATIONAL BANK,
Defendant.
--------------------------------------------------------------------------
)[
COMPLAINT
Civil Action No.
___
COMPLAINT ANDDEMAND
FOR
JURYTRIAL.
Plaintiff Automated Transactions LLC ("Automated Transactions") alleges as follows:
PARTIES
I. Automated Transactions is a limited liability company organized and ellistingunder the laws
ofthe
state
of
Delaware, having a principal place
of
business at 2711 CentervilleRoad, Suite 400, Wilmington,
DE
19808.2. Upon information and belief, Enterprise National Bank ("Enterprise") is state orfederally chartered savings bank with a principal place
of
business at 490 Boulevard, Kenilworth,
NJ
7033.
975856
 
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 1338.5. 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 duly andlegally issued to David M. Barcelou. A true and correct copy
of
the '158 patent is attached heretoas Exhibit
A.
7.
By
license, Automated Transactions is the exclusive licensee
of
the '15 8 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 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;an Internet interface to an Internet connection to the automatedteller machine that uses encryption services and security services to
2
 
provide the user access to the user interface and retail
ATM
service; andaccess to the automated teller machine user interface whereuponthe consumer
may
selectively dispense currency using theintegrated banking and transaction machine providing the retail
ATM
service;wherein the consumer can purchase access to the retail
ATM
service 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
with
cash.3.
The
integrated banking and transaction machine according to claim
1,
further comprising means for consummating the purchase withbills.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 purchase
with
a debit card.13. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchase
with
a stored value card.15. The integrated banking and transaction machine according toclaim 1, further comprising means for consummating the purchase
with
an identification card9. Enterprise is using ATMs within this judicial district which incorporate everyelement
of
the above claims
or
substantial equivalents thereof. Therefore, Enterprise is directly orindirectly infringing at least the above claims
ofthe
'158 patent, either literally or under thedoctrine
of
equivalents, and is liable for infringement
of
the '158 patent pursuant to 35 U.S.C.§271.3

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