Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Relay IP v. Bloomberg

Relay IP v. Bloomberg

Ratings: (0)|Views: 51 |Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00770-UNA: Relay IP Inc. v. Bloomberg L.P. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89q for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00770-UNA: Relay IP Inc. v. Bloomberg L.P. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89q for more info.

More info:

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

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

01/30/2014

pdf

text

original

 
 
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 againstDefendant Bloomberg L.P.
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 Bloomberg L.P. is a limited partnership organized under the laws of the state of Delaware with a principal office at 731 Lexington Avenue, New York, NY, 10022.Defendant Bloomberg L.P. may be served with process via its registered agent, CorporationService Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808.
JURISDICTION AND VENUE
3.
 
This is a patent infringement action. The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1338.4.
 
The Court has personal jurisdiction over Defendant, as it is incorporated in thisState.RELAY IP, INC.,Plaintiff,v.BLOOMBERG L.P.,Defendant.
 
 25.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because Defendant resides in this District.
COUNT ONEINFRINGEMENT OF U.S. PATENT NO. 5,331,637
6.
 
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.7.
 
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.8.
 
Defendant has infringed and continues to directly infringe one or more claims of the ’637 Patent, including at least Claim 1, by using the method claimed in distributing dataand/or data feeds via distribution networks, which practice the Protocol Independent Multicast-Sparse Mode standard (“PIM-SM”) for multicast routing.
1
In practicing the PIM-SM standard,Defendant directly infringes one or more claims of the ’637 Patent, including at least Claim 1.Defendant’s act of practicing the PIM-SM standard constitutes infringement under 35 U.S.C.§271 for which it is directly liable.9.
 
As a result of Defendant’s 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.
1
 
See, e.g.
, RFC 4601 at http://tools.ietf.org/html/rfc4601.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->