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Automated Transactions v. First Bank

Automated Transactions v. First Bank

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Published by PatentBlast
Automated Transactions v. First Bank
Automated Transactions v. First Bank

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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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Daniel
A.
SuckermanTannenbaum HelpemSyracuse
&
Hirschtritt LLP900 Third A venueNew 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.-
FIRST BANK,
Defendant.
--------------------------------------------------------------------------
)[
COMPLAINT
Civil Action No.
___
COMPLAINT ANDDEMAND FOR JURYTRIAL.
Plaintiff Automated Transactions LLC ("Automated Transactions") alleges
as
follows:
PARTIES
1.
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, First Bank ("First") is a state or federally charteredsavings bank with a principal place
of
business at 2465 Kuser Rd., Suite 101, Hamilton, NJ08690.
975860
 
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.
Venueisproperinthisjudicialdistrictunder28U.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 '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 services to2
 
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 claim
1,
further comprising means for consummating the purchase withcash.
3.
The integrated banking and transaction machine according to claim
1,
further comprising means for consummating the purchase
with
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 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 purchasewith an identification card9. First is using ATMs within this judicial district which incorporate every element
ofthe
above claims
or
substantial equivalents thereof. Therefore, First 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. §271.3

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