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PRN Technologies d/b/a Scan Script v. Walgreen

PRN Technologies d/b/a Scan Script v. Walgreen

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-12286-AC-RSW: PRN Technologies d/b/a Scan Script v. Walgreen Co. Filed in U.S. District Court for the Eastern District of Michigan, the Hon. Avern Cohn presiding. See http://news.priorsmart.com/-l8ti for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-12286-AC-RSW: PRN Technologies d/b/a Scan Script v. Walgreen Co. Filed in U.S. District Court for the Eastern District of Michigan, the Hon. Avern Cohn presiding. See http://news.priorsmart.com/-l8ti for more info.

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Published by: PriorSmart on May 22, 2013
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09/17/2013

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 IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF MICHIGANPRN TECHNOLOGIES, INC.d/b/a SCAN SCRIPT,a Michigan corporationPlaintiff Case No.:v.WALGREEN CO.,an Illinois corporationDefendant__________________________________________
COMPLAINT & JURY DEMAND
NOW COMES Plaintiff PRN Technologies, Inc. (“PRN”), by and through itsattorneys, Carlson, Gaskey & Olds, P.C., and for its Complaint against Defendant Walgreen Co.(“Walgreen”) states as follows:
INTRODUCTION
1.
 
This is an action for patent infringement brought by PRN against Walgreenpursuant to Title 35 of the Unites States Code.
PARTIES
2.
 
PRN is a Michigan corporation having its principal place of business at 6200Argyle, Dearborn, MI 48126.3.
 
Walgreen is an Illinois corporation with its primary place of business at 108Wilmot Road, Deerfield, IL 60015.
JURISDICTION AND VENUE
4.
 
This Court has original subject matter jurisdiction over the claims in this actionpursuant to 28 U.S.C. §1331 (federal question) and §1338 (patents).
 
 25.
 
Walgreen is subject to personal jurisdiction in this Court. In particular, this Courthas personal jurisdiction over Walgreen because Walgreen has engaged in continuous,systematic and substantial activities within this judicial district, including substantial marketingand sales of products in this judicial district. Upon information and belief, Walgreen hasapproximately 233 store locations in Michigan, including many in this judicial district.Furthermore, upon information and belief, this Court has personal jurisdiction over Walgreen inthis case because Walgreen has committed acts giving rise to PRN’s claim for patentinfringement within and directed to this judicial district.6.
 
Venue in this Court is proper pursuant to 28 U.S.C. §1391(b) and (c) and 28U.S.C. §1400(b).
PRN’S PATENT
7.
 
PRN incorporates and re-alleges Paragraphs 1 through 6 as each were fully setforth.8.
 
On March 29, 2005, the United States Patent and Trademark Office duly andlawfully issued United States Letters Patent No. 6,871,783 (“the ‘783 patent”), entitled “Methodof Dispensing Medical Prescriptions.A true and correct copy of the ‘783 patent is attachedhereto as Exhibit 1.9.
 
The ‘783 patent names William Kaafarani and Mohamad Bazzi as inventors.10.
 
PRN is the owner by assignment of all right, title and interest in the ‘783 patent.11.
 
The ‘783 patent generally relates to,
inter alia
, a novel method of dispensingmedical prescriptions.
 
 3
COUNT I - WALGREEN’S DIRECT INFRINGEMENT OF THE ‘783 PATENT
12.
 
PRN incorporates and re-alleges Paragraphs 1 through 11 as each were fully setforth.13.
 
The ‘783 patent remains valid, enforceable and unexpired.14.
 
Upon information and belief, Walgreen is directly infringing and has directlyinfringed the ‘783 patent, including, without limitation, by making, using, selling, offering forsale, and/or importing, without license or authority, a method and/or system of dispensingmedical prescriptions covered by the ‘783 patent, including but not limited to Walgreen’sPharmacy Prescription System including at least Walgreen’s Phone Applications, and MobileConnects, which include a system and method for scanning, refilling, monitoring, andnotifications related to dispensing medical prescriptions (hereinafter the “accused system”).15.
 
The accused system falls within the scope of one or more claims of the ‘783patent. Upon information and belief, Walgreen directly infringes at least claims 1 and 2 of the‘783 patent.16.
 
Upon information and belief, Walgreen’s has actual knowledge of the ‘783 patent.17.
 
Upon information and belief, Walgreen’s infringement has been and continues tobe willful and deliberate.18.
 
As a result of Walgreen’s infringement, PRN will suffer severe and irreparableharm, unless that infringement is enjoined by this Court, and has suffered substantial damages.
PRAYER FOR RELIEF
WHEREFORE, PRN requests judgment in its favor against Walgreen for the followingrelief:A.
 
An Order adjudging that Walgreen has infringed the ‘783 patent;

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