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GlobeTecTrust v. Sprint Nextel

GlobeTecTrust v. Sprint Nextel

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00951-UNA: GlobeTecTrust LLC v. Sprint Nextel Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8v9 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00951-UNA: GlobeTecTrust LLC v. Sprint Nextel Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8v9 for more info.

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Published by: PriorSmart on May 30, 2013
Copyright:Public Domain

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04/04/2014

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1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
GLOBETECTRUST LLC,Plaintiff,v.SPRINT NEXTEL CORPORATION,Defendant.C.A. No. ___________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff GlobeTecTrust LLC files this complaint for patent infringement againstDefendant Sprint Nextel Corporation:
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 Sprint Nextel Corporation(“Defendant”) is a Kansas corporation with its principal place of business located at 6200Sprint Parkway, Overland Park, Kansas 66251. Defendant has appointed CorporationService Company, 2900 SW Wanamaker Drive, Suite 204, Topeka, Kansas 66614, as itsagent for service of process.
 
 
2
JURISDICTION
3.
 
This action arises under the patent laws of the United States, Title 35 of the United States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§1331 and 1338(a).4.
 
On information and belief, Defendant is subject to this Court’s jurisdiction because 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 conducting business 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 as if 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 MartinC. Tatham, who assigned their rights and interests in the ’548 patent to British
 
 
3Telecommunications Public Limited Company. A true and correct copy of the ’548 patent is attached as Exhibit A.8.
 
GlobeTecTrust is the exclusive licensee of the ’548 patent and has thelegal right to enforce rights under the ’48 patent, sue for infringement, and seek allavailable relief and damages.9.
 
Upon information and belief, Defendant is infringing (literally and/or under the doctrine of equivalents) the ’548 patent in this District and throughout theUnited States by, among other things, making, using, importing, offering for sale and/or selling a communications network that includes nodes as claimed in the ’548 patent thatroute network traffic according to the method claimed in the ’548 patent. Defendant’sinfringing networks include, without limitation, networks utilizing a Multiprotocol LabelSwitching (MPLS) architecture, such as Sprint Global MPLS, on which Defendant provides its voice and Internet services. (See
http://convergence.sprint.com/mpls.aspx
:“Sprint Global Multi-Protocol Label Switching (MPLS) gives you the full power of our …flexible IP foundation to deploy converged network and Unified Communications(UC) strategies….”)10.
 
Defendant committed these acts of infringement without license or authorization.11.
 
As a result of Defendant’s infringement of the ’548 patent, GlobeTecTrusthas suffered monetary damages in an amount not yet determined, and will continue tosuffer damages in the future unless Defendant’s infringing activities are enjoined by thisCourt.

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