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Relay IP Inc.

Relay IP Inc.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01077-UNA: Relay IP Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8B8 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01077-UNA: Relay IP Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8B8 for more info.

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Published by: PriorSmart on Jun 17, 2013
Copyright:Public Domain

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02/16/2014

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 1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
C.A. No. __________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Relay IP, Inc. (“Plaintiff”) alleges the following for its complaint againstDefendant Essex Radez LLC (“Defendant”).
THE PARTIES
1.
 
Plaintiff 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, VA 22314.2.
 
Defendant is a limited liability company organized under the laws of the state of Illinois with a principal office at 440 South LaSalle Street, Suite 1111, Chicago, Illinois 60605.Defendant may be served with process via its registered agent, Stephen Radez, 440 SouthLaSalle Street, Suite 1111, Chicago, Illinois 60605.
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 under the Delaware long arm statute over Defendant as it has availed itself of the rights and benefits of this District by conducting businessin this jurisdiction, including by offering its services via the internet, which is accessible in thisDistrict. Defendant also regularly does business with companies resident in this District.RELAY IP, INC.,Plaintiff,v.ESSEX RADEZ LLC,Defendant.
 
 25.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because substantial acts of infringement have occurred in this District in this District andDefendant is subject to jurisdiction here.
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 is the sole and exclusive owner of all right, title, and interest in the ’637Patent 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. Plaintiff 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 network(s), which practice multicast routing methods,including but not limited to Protocol Independent Multicast-Sparse Mode standard (“PIM-SM”).
1
 Upon information and belief, at least Defendant’s V-Tick network practices at least Claim 1 bydistributing data and/or data feeds via distribution network(s) in accordance with the PIM-SMstandard. Defendant’s acts of practicing such methods, including the PIM-SM standard,constitute infringement under 35 U.S.C. §271 for which it is directly liable.
1
 
See, e.g.
, RFC 4601 at http://tools.ietf.org/html/rfc4601.

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