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MLP Technology v. LifeMed ID

MLP Technology v. LifeMed ID

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00909: MLP Technology, Inc. v. LifeMed ID, Inc. Filed in U.S. District Court for the Northern District of Ohio, no judge yet assigned. See http://news.priorsmart.com/-l84w for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00909: MLP Technology, Inc. v. LifeMed ID, Inc. Filed in U.S. District Court for the Northern District of Ohio, no judge yet assigned. See http://news.priorsmart.com/-l84w for more info.

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Published by: PriorSmart on Apr 23, 2013
Copyright:Public Domain

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09/05/2013

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1
UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF OHIO
 
MLP TECHNOLOGY, INC.
an Ohio corporation,Plaintiff,v.
LIFEMED ID, INC.
a California corporation,Defendant.Civil Action No.
DEMAND FOR JURY TRIALCOMPLAINT FOR PATENT INFRINGEMENT
 1.
 
Plaintiff MLP Technology, Inc. (“MLP”) brings this action seeking monetarydamages and injunctive relief against Defendant, LifeMed ID, Inc. (“LifeMed”), to remedyLifeMed’s infringement of United States Patent No. 8,234,125 (“the 125 Patent”), in violationof the Patent Act of the United States, 35 U.S.C. §§ 1 et seq., and the harm caused thereby. (Atrue and correct copy of the 125 Patent is attached hereto as Ex. A.)For its Complaint against LifeMed, MLP alleges as follows:
PARTIES
 2.
 
Plaintiff MLP is a corporation organized and existing under the laws of Ohio,having its principal place of business at 13020 Tilden Road, Hiram, Ohio 44234.3.
 
Plaintiff MLP owns the entire right, title, and interest in the ‘125 Patent, describedbelow, for health care data management.
 
24.
 
On information and belief, Defendant LifeMed is a corporation organized andexisting under the laws of California, with a principal place of business at 6349 AuburnBoulevard, Citrus Heights, California 95621.
 JURISDICTION AND VENUESubject Matter Jurisdiction
5.
 
 This is an action arising under the patent laws of the United States.6.
 
 This court has jurisdiction over the subject matter of this action pursuant to 28U.S.C. §§ 1331, 1332, and 1338(a).
Personal Jurisdiction
7.
 
LifeMed, directly and/or through third parties, is doing business in this District byselling, offering to sell, and otherwise making available its products, including SecureReg ID,SecureReg Integrated, SecureReg Link, SecureReg EMS Gateway, SecureReg Patient DataExchange, and Patient Identity Card products.8.
 
Below is a map that LifeMed represents indicates the locations of its “TrainedIntegrators, Educators, Deployment, and Servicing Locations.” This map is from a presentationgiven by LifeMed’s CEO David Batchelor at the American Medical Association’s HealthSecurity Card Conference on April 24, 2012. (See Ex. B at Slide 21, http://www.ama-assn.org/resources/doc/cphpdr/hsc-batchelor.pdf )The map shows that LifeMed has sold oroffered for sale its products and services (collectively referred to as “solutions”) in this District.(See,
e.g.
, dots labeled 53 and 54 in the map below). The dots on the map are referred to in theslide as “Distribution Locations.”
 
39.
 
 The personal jurisdiction of this Court over LifeMed is proper because LifeMedhas committed and continues to commit acts of infringement in violation of 35 U.S.C. § 271 andplace infringing solutions into the stream of commerce, via an established distribution channel,with the knowledge and/or understanding that such products are sold in Ohio, including in thisDistrict. These acts cause injury to MLP within the District.10.
 
Personal jurisdiction is also proper because, upon information and belief,LifeMed has derived and continues to derive substantial revenue from the sale of infringingsolutions distributed within the District, and/or expects or should reasonably expect their actionsto have consequences within the District and derive substantial revenue from interstate andinternational commerce. 

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