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GlobeTecTrust v. CenturyLink

GlobeTecTrust v. CenturyLink

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00952-UNA: GlobeTecTrust LLC v. CenturyLink Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8vd for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00952-UNA: GlobeTecTrust LLC v. CenturyLink Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8vd for more info.

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Published by: PriorSmart on May 30, 2013
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05/30/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWAREGLOBETECTRUST LLCPlaintiff,v.CENTURYLINK, INC.Defendant.Civil Action No. ___________JURY TRIAL DEMANDED
 
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff GlobeTecTrust LLC, files this complaint for patent infringement againstDefendant CenturyLink, Inc.:
THE PARTIES
1.
 
Plaintiff GlobeTecTrust LLC (“GlobeTecTrust”) is a Delaware limitedliability company with its principal place of business located at GlobeTecTrust LLC, c/oWilmington Trust SP Services, Inc., 1105 North Market Street, Suite 1300, Wilmington,Delaware 19801.2.
 
On information and belief, Defendant CenturyLink, Inc. (“Defendant”) is aLouisiana corporation with a principal place of business at 100 CenturyLink Drive,Monroe, Louisiana, 71203. Defendant has appointed CT Corporation System, 5615Corporate Boulevard, Suite 400B, Baton Rouge, Louisiana 70808, as its agent for serviceof process.
 
2
JURISDICTION
3.
 
This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331and 1338(a).4.
 
On information and belief, Defendant is subject to this Court's jurisdictionbecause Defendant has, upon information and belief, transacted business in the Districtand in the State of Delaware. Specifically, Defendant either directly and/or throughintermediaries, upon information and belief, ships, distributes, offers for sale, and/or sells(including via the provision of such services over the Internet) products and services inthis District. Defendant thus has, upon information and belief, minimum contacts withthis District and State, has purposefully availed itself of the privileges of conductingbusiness in this District and State, regularly conducts and solicits business within theState of Delaware, and has committed acts of patent infringement in this District andState.5.
 
Venue is proper in this district under 28 U.S.C. §§ 1391(b) and (c), and1400(b).
COUNT I(Infringement of U.S. Patent No. 6,272,548)
6.
 
GlobeTecTrust incorporates and realleges the allegations of paragraphs 1-5 asif fully set forth herein.7.
 
On August 7, 2001, the USPTO duly and legally issued U.S. Patent No.6,272,548 (the “’548 patent”), entitled “Dead Reckoning Routing of Packet Data Withina Network of Nodes Having Generally Regular Topology,” to David Cotter and Martin
 
3C. Tatham, who assigned their rights and interests in the ’548 patent to BritishTelecommunications Public Limited Company. A true and correct copy of the ’548patent is attached as Exhibit A.8.
 
GlobeTecTrust is the exclusive licensee of the ’548 patent and has the legalright to enforce rights under the ’548 patent, sue for infringement, and seek all availablerelief and damages.9.
 
Upon information and belief, Defendant is infringing (literally and/or underthe doctrine of equivalents) the ’548 patent in this District and throughout the UnitedStates by, among other things, making, using, importing, offering for sale and/or selling acommunications network that includes nodes as claimed in the ’548 patent that routenetwork traffic according to the method claimed in the ’548 patent. Defendant’sinfringing networks include, without limitation, networks utilizing a Multiprotocol LabelSwitching (MPLS) architecture, which allows Defendant to sell MPLS-based productsand services, such as CenturyLink IQ Networking Private Port. (See
http://www.centurylink.com/business/products/products-and-services/data-networking/mpls-private-port.html
: “CenturyLink IQ Networking Private Port connectsyour remote locations using IP/MPLS-based technology to create an enterprise-widenetwork designed to carry real-time and data applications over a single customerinterface.”)10.
 
Defendant committed these acts of infringement without license orauthorization.

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