Plaintiff ImageWare Systems, Inc.,
hereby complains of WCC ServicesUS, Inc.
WCC Group B.V., (
), and DOES 1 through 10(collectively,
and alleges as follows:
NATURE OF THE ACTION
This is an action for patent infringement under the patent laws of the United States,35 U.S.C. § 271,
ImageWare is a publicly-traded software company based in San Diego, Californiathat develops, markets and sells highly innovative technology solutions for the identitymanagement industry, particularly for government, border control, healthcare, financial services,and electronic and mobile commerce applications.
flagship product is its
Biometric Engine®, which is the
first and only patented multi-modal, device- andalgorithm-independent biometric fusion platform that can search for, screen and authenticateindividuals using more than a dozen biometric modalities, including fingerprint, finger vein, palm vein, face, and iris
(among others). ImageWare’s suite of multimodal biometric fusion
products and software provide optimized identity enrollment, management and authenticationsolutions for a variety of applications, including secure credentialing, controlled access, nationalidentification, border control, watch list, voter registration, driver license, and airport security purposes (among many others). ImageWare is organized and existing under the laws of the Stateof Delaware, with its principal place of business located at 10815 Rancho Bernardo Road, Suite310, San Diego, California 92127.3.
ImageWare is informed and believes and based thereon alleges that DefendantWCC Services is a corporation organized and existing under the laws of the State of Delaware,with its principal place of business located at 228 Hamilton Ave, #300, Palo Alto, California9430.4.
ImageWare is informed and believes and based thereon that Defendant WCCGroup is a corporation organized and existing under the laws of the Country of The Netherlands,with its principal place of business located at Savannahweg 17, 3542 AW Utrecht, The