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Automated Transactions v. Dannemora Federal Credit Union

Automated Transactions v. Dannemora Federal Credit Union

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Published by PatentBlast
Automated Transactions v. Dannemora Federal Credit Union
Automated Transactions v. Dannemora Federal Credit Union

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Published by: PatentBlast on Apr 18, 2013
Copyright:Attribution Non-commercial

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04/18/2013

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UNITED STATES DISTRICT COURT FOR THENORTHERN DISTRICT OF NEW YORK 
-------------------------------------------------------------------------xAUTOMATED TRANSACTIONS LLC,
Plaintiff 
,- v. -DANNEMORA FEDERAL CREDIT UNION,
Defendant.
:::::::::::::-------------------------------------------------------------------------xCivil Action No. _________ 
COMPLAINT JURY TRIAL DEMANDED.
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, Dannemora Federal Credit Union (“Dannemora”) isa community credit union with a principal place of business at122 New York Road, Dannemora,NY 12903.
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.
8:13-CV-0194(TJM/CFH)
 
 
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.
 
Dannemora is using ATMs within this judicial district which incorporate everyelement of the above claims or substantial equivalents thereof. Therefore, Dannemora is directlyor indirectly infringing at least the above claims of the ‘158 patent, either literally or under thedoctrine of equivalents, and is liable for infringement of the ‘158 patent pursuant to 35 U.S.C.§271.10.
 
Dannemora was made aware of the ‘158 patent and Dannemora’s infringementthereof by a letter sent to the Bank on about February 7, 2013 addressed to Randall Martin,President.11.
 
Dannemora 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

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