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Automated Transactions v. Bath Savings Institution

Automated Transactions v. Bath Savings Institution

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00582-SLR: Automated Transactions LLC v. Bath Savings Institution. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l837 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00582-SLR: Automated Transactions LLC v. Bath Savings Institution. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-l837 for more info.

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Published by: PriorSmart on Apr 17, 2013
Copyright:Public Domain

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07/11/2014

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970938
UNITED STATES DISTRICT COURT FOR THEDISTRICT OF MAINE
--------------------------------------------------------------------------xCivil Action No. _________ 
 JURY TRIAL DEMANDED.
AUTOMATED TRANSACTIONS LLC,
Plaintiff 
,- v. -BATH SAVINGS INSTITUTION,
Defendant.
:::::::::::::--------------------------------------------------------------------------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, Bath Savings Institution (“Bath”) is a state charteredbank with a principal place of business at 105 Front Street, Bath, ME 4530.
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 28U.S.C. §§1331 and 1338.
 
 25.
 
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 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 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 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 retailATM service;wherein the consumer can purchase access to the retail ATMservice through use of the user interface and Internet servicesconnections.
 
 32. 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.
 
Bath is using ATMs within this judicial district which incorporate every elementof the above claims or substantial equivalents thereof. Therefore, Bath is directly or indirectlyinfringing at least the above claims of the ‘158 patent, either literally or under the doctrine of equivalents, and is liable for infringement of the ‘158 patent pursuant to 35 U.S.C. §271.10.
 
Bath was made aware of the ‘158 patent and Bath’s infringement thereof by aletter sent to the Bank on about August 15, 2012 to Mr. Glen L. Hutchinson, President.11.
 
Bath also provides the above ATMs for use by customers and others within this judicial district, and provides those customers and others with detailed explanations, instructionsand information as to arrangements, applications and uses of these ATMs that promote anddemonstrate how to use these ATMs in an infringing manner. These acts constitute inducementto infringe the above claims of the ‘158 patent, either literally or under the doctrine of 

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