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Relay IP v. Juniper Networks

Relay IP v. Juniper Networks

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00779-UNA: Relay IP Inc. v. Juniper Networks Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89v for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00779-UNA: Relay IP Inc. v. Juniper Networks Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l89v for more info.

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

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11/22/2013

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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 againstDefendant Juniper Networks, 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 Juniper Networks Inc. is a corporation organized under the laws of theState of Delaware with a principal office at 1194 North Mathilda Avenue, Sunnyvale, CA 94089.Defendant Juniper Networks Inc. may be served with process via its registered agent, TheCorporation Trust Company, at 1209 Orange Street, Wilmington, DE 19801.
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. Defendant has also availed itself, under the Delaware long arm statute, of the rights andRELAY IP, INC.,Plaintiff,v.JUNIPER NETWORKS, INC.,Defendant.
 
 
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 benefits of this District by conducting business in this jurisdiction, including by promoting products for sale via the internet, which are accessible to and accessed by residents of thisDistrict.5.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because Defendant resides in this District and substantial acts of infringement have occurred inthis 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 testing equipmentthat it sells and has sold for use by its customers to also practice the method of at least Claim 1of the ’637 Patent. Such equipment includes, for example and without limitation, equipmentfrom the following product lines and all other routing platforms that support/enable the practiceof the PIM-SM standard:E Series (ERX310)E Series (ERX705/ERX710)
 
 
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E Series (ERX1410)E Series (ERX1440)E Series (ERX120)E Series (ERX320)J Series (J2320)J Series (J2350)J Series (J4350)J Series (J6350)LN Series (LN1000 Mobile Secure Router)M Series (M7i)M Series (M10i)M Series (M120)M Series (M320)MX Series 3D Edge Routers (MX5)MX Series 3D Edge Routers (MX10)MX Series 3D Edge Routers (MX40)MX Series 3D Edge Routers (MX80)MX Series 3D Edge Routers (MX240)MX Series 3D Edge Routers (MX480)MX Series 3D Edge Routers (MX960)EX Series, EX2200 Ethernet Switch (EX2200-24T)EX Series, EX2200 Ethernet Switch (EX2200-24P)EX Series, EX2200 Ethernet Switch (EX2200-48T)EX Series, EX2200 Ethernet Switch (EX2200-48P)EX Series, EX3200 Ethernet Switches (EX3200-24T)EX Series, EX3200 Ethernet Switches (EX3200-24P)EX Series, EX3200 Ethernet Switches (EX3200-48T)EX Series, EX3200 Ethernet Switches (EX3200-48P)EX Series, EX4200 Ethernet Switches With Virtual Chassis Technology(EX4200-24F)EX Series, EX4200 Ethernet Switches With Virtual Chassis Technology(EX4200-24P/24PX)EX Series, EX4200 Ethernet Switches With Virtual Chassis Technology(EX4200-24T)EX Series, EX4200 Ethernet Switches With Virtual Chassis Technology(EX4200-48T)EX Series, EX4200 Ethernet Switches With Virtual Chassis Technology(EX4200-48P/48PX)EX Series, EX4500 Ethernet Switch With Virtual Chassis Technology (EX4500with two uplink modules (4 x 10GbE SFP+ ports)EX Series, EX6200 Line of Ethernet Switches (EX6210)EX Series, EX8208 Ethernet SwitchEX Series, EX8216 Ethernet SwitchXRE200 External Routing EngineQFX Series, QFX3000 QFABRIC SwitchQFX Series, QFX3008 QFABRIC INTERCONNECT

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