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Relay IP v. BT Group et. al.

Relay IP v. BT Group et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00771-UNA: Relay IP Inc. v. BT Group plc et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89h for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00771-UNA: Relay IP Inc. v. BT Group plc et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89h for more info.

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Published by: PriorSmart on May 06, 2013
Copyright:Public Domain

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05/06/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
C.A. No. __________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Relay IP, Inc. (“Relay IP”) alleges the following for its complaint againstDefendants BT Group plc and BT, Inc.
THE PARTIES
1.
 
Plaintiff Relay IP, Inc. is a corporation formed under the laws of the state of Delaware having its principal place of business at 2331 Mill Road, Suite 100, Alexandria, VA22314.2.
 
Defendant BT Group plc is a corporation organized under the laws of the UnitedKingdom with a principal office at BT Centre, 81 Newgate Street, London EC1A 7AJ. Oninformation and belief, Defendant BT Group plc conducts business in the United States generallyand in this District through its subsidiaries, including the other named Defendant.3.
 
Defendant BT Inc. is a corporation organized under the laws of the state of Delaware with a principal office at 7301 N. State Highway 161, Suite 400, Irving, TX 75039.Defendant BT Inc. may be served with process via its registered agent, Corporation Agents, Inc.,2711 Centerville Road, Suite 400, Wilmington, DE 19808.RELAY IP, INC.,Plaintiff,v.BT GROUP PLC & BT, INC.,Defendant.
 
 2
 
JURISDICTION AND VENUE
4.
 
This is a patent infringement action. The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1338.5.
 
The Court has personal jurisdiction under the Delaware long arm statute asDefendants have availed themselves of the rights and benefits of this District by conducting business in this jurisdiction, including by offering their products and services via the internet,which is accessible in this District. Defendant BT Inc. is also incorporated in this State andtherefore subject to personal jurisdiction.6.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because Defendant BT, Inc. resides in this District and substantial acts of infringement haveoccurred in this District.
COUNT ONEINFRINGEMENT OF U.S. PATENT NO. 5,331,637
7.
 
On July 19, 1994, U.S. Patent No. 5,331,637 (the “’637 Patent”) entitled“Multicast Routing Using Core Based Trees” was duly and legally issued by the United StatesPatent and Trademark Office. A true and correct copy of the ’637 Patent is attached as Exhibit Ahereto.8.
 
Plaintiff Relay IP is the sole and exclusive owner of all right, title, and interest inthe ’637 Patent and holds the exclusive right to take all actions, including the filing of this patentinfringement lawsuit, necessary to enforce its rights to the ’637 Patent. Relay IP also has theright to recover all damages for past, present, and future infringement of the ’637 Patent and toseek injunctive relief as appropriate under the law.9.
 
Defendants have infringed and continue to directly infringe one or more claims of the ’637 Patent, including at least Claim 1, by using the method claimed in distributing data
 
 3
 
and/or data feeds via distribution networks, including but not limited to their BT RadianzServices, which practice the Protocol Independent Multicast-Sparse Mode standard (“PIM-SM”)for multicast routing.
1
In practicing the PIM-SM standard, Defendants directly infringe one or more claims of the ’637 Patent, including at least Claim 1. Defendants’ act of practicing thePIM-SM standard constitutes infringement under 35 U.S.C. §271 for which they are directlyliable.10.
 
As a result of Defendants’ infringement, Plaintiff Relay IP has been damagedmonetarily and is entitled to adequate compensation of no less than a reasonable royalty pursuantto 35 U.S.C. § 284.
JURY DEMAND
Plaintiff requests a jury on all issues so triable.
1
 
See, e.g.
, RFC 4601 at http://tools.ietf.org/html/rfc4601.

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