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Robert Bosch Healthcare Systems v. CardioCom et. al.

Robert Bosch Healthcare Systems v. CardioCom et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00349: Robert Bosch Healthcare Systems, Inc. v. CardioCom, LLC et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l86H for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00349: Robert Bosch Healthcare Systems, Inc. v. CardioCom, LLC et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l86H for more info.

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Published by: PriorSmart on Apr 26, 2013
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08/19/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISION
ROBERT BOSCH HEALTHCARESYSTEMS, INC.,Plaintiff §§§§§§§§§§§v.CARDIOCOM, LLC, and ABBOTTDIABETES CARE, INC.,Defendants.
CIVIL ACTION NO. 2:13-cv-349 JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Robert Bosch Healthcare Systems, Inc. (“Bosch”), by and through itsundersigned counsel, hereby alleges as follows:
PARTIES
1.
 
Plaintiff Bosch is a Michigan corporation with its principal place of business at2400 Geng Road, Suite 200, Palo Alto, California 94303.2.
 
Defendant Cardiocom, LLC (“Cardiocom”) is a Minnesota corporation with itsprincipal place of business at 7980 Century Boulevard, Chanhassen, Minnesota 55317.3.
 
Defendant Abbott Diabetes Care, Inc. (“Abbott”) is a Delaware corporation withits principal place of business at 1360 South Loop Road, Alameda, California 94502.4.
 
Abbott has been joined as a defendant in this action pursuant to Rule 19 of theFederal Rules of Civil Procedure because, after being invited to join voluntarily as co-plaintiff inprosecuting this action, Abbott has declined to do so. As an exclusive field of use licensee toBosch’s patents being asserted herein, Abbott is jointly interested with Bosch in the relief soughtand should be realigned by this Court as a plaintiff pursuant to
Independent Wireless Telegraph
 
-2-
Co. v. Radio Corp. of America
, 269 U.S. 459, 468 (1926). In the alternative, if Abbott is notsubject to service of process in this District, Abbott should be joined by the Court as aninvoluntary plaintiff pursuant to Rule 19(a)(2). Joinder will not divest the Court of subjectmatter jurisdiction.
 JURISDICTION AND VENUE
5.
 
 This is an action arising under the patent laws of the United States, Title 35 of theUnited States Code. This court has jurisdiction over the subject matter of this action pursuant to28 U.S.C. §§ 1331 and 1338(a). Venue in this district is proper pursuant to 28 U.S.C. §§ 1391(b)and 1400(b).
BOSCH’S PATENTS
6.
 
On April 7, 2009, the United States Patent Office (“PTO”) duly and lawfullyissued U.S. Patent No. 7,516,192 (“the 192 Patent”), entitled “Networked System for InteractiveCommunication and Remote Monitoring of Individuals.” A true and correct copy of the 192Patent is attached hereto as Exhibit A.7.
 
On September 8, 2009, the United States Patent Office (“PTO”) duly and lawfullyissued U.S. Patent No. 7,587,469 (“the 469 Patent”), entitled “Audio Instructions forAppliances.” A true and correct copy of the 469 Patent is attached hereto as Exhibit B.8.
 
On August 8, 2010, the United States Patent Office (“PTO”) duly and lawfullyissued U.S. Patent No. 7,769,605 (“the ’605 Patent”), entitled “Multiple Patient MonitoringSystem for Proactive Health Management.” A true and correct copy of the ’605 Patent isattached hereto as Exhibit C.9.
 
On November 23, 2010, the United States Patent Office (“PTO”) duly andlawfully issued U.S. Patent No. 7,840,420 (“the 420 Patent”), entitled “Multiple Patient
 
-3-Monitoring System for Proactive Health Management.” A true and correct copy of the 420Patent is attached hereto as Exhibit D.10.
 
On January 11, 2011, the United States Patent Office (“PTO”) duly and lawfullyissued U.S. Patent No. 7,870,249 (“the 249 Patent”), entitled “Networked System for InteractiveCommunication and Remote Monitoring of Individuals.” A true and correct copy of the 249Patent is attached hereto as Exhibit E.11.
 
On April 5, 2011, the PTO duly and lawfully issued U.S. Patent No. 7,921,186(“the 186 Patent”), entitled “Networked System for Interactive Communication and RemoteMonitoring of Individuals.” A true and correct copy of the 186 Patent is attached hereto asExhibit F.12.
 
Bosch is the owner by assignment of the ’192, ’469, ’605, ’420, ’249, and ’186Patents (“the Patents-in-Suit”).
BOSCH’S TECHNOLOGY
13.
 
 The Patents-in-Suit relate to the field of remote health monitoring, which waspioneered by Health Hero Network, now part of Bosch. Remote health monitoring helps patientswith chronic conditions achieve better of quality of life and enables health care providers tomanage larger numbers of patients.14.
 
Remote health monitoring is a completely different approach from traditionalpatient care. Accordingly, Health Hero Network initially met with great resistance andskepticism in the health care industry. Over time, Health Hero Network, and later Bosch, hasachieved greater acceptance for its remote health monitoring technology through extensiveefforts and by demonstrating benefits such as a 50% reduction in hospital admissions.15.
 
Bosch continues to develop and sell remote health monitoring solutions, including

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