Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
Colorado Remediation Technologies v. Panda Distribution

Colorado Remediation Technologies v. Panda Distribution

Ratings: (0)|Views: 50 |Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-02204: Colorado Remediation Technologies, LLC, v. Panda Distribution, Inc. Filed in U.S. District Court for the District of Colorado, no judge yet assigned. See http://news.priorsmart.com/-l8VN for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-02204: Colorado Remediation Technologies, LLC, v. Panda Distribution, Inc. Filed in U.S. District Court for the District of Colorado, no judge yet assigned. See http://news.priorsmart.com/-l8VN for more info.

More info:

Published by: PriorSmart on Aug 16, 2013
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

08/16/2013

pdf

text

original

 
- 1 -IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADOCivil Action No.COLORADO REMEDIATION TECHNOLOGIES, LLC,a Colorado limited liability company,Plaintiff,v.PANDA DISTRIBUTION, INC. D/B/A PANDA SECURITY USA,a Florida corporation,Defendant.
COMPLAINT FOR PATENT INFRINGEMENT ANDDEMAND FOR JURY TRIAL
Plaintiff Colorado Remediation Technologies, LLC ("CRT") files this Complaint againstDefendant Panda Distribution, Inc. d/b/a Panda Security USA ("Panda") alleging as follows:
I. THE PARTIES
 1.
 
CRT is a Colorado limited liability company with a principal place of businesslocated in Denver, Colorado.2.
 
Upon information and belief, Panda is a Florida corporation with a principal placeof business located at 2600 Lake Lucien Drive, Suite 115, Maitland, FL 32751. Panda can beserved with process through its registered agent, Almira Nunn, 2600 Lake Lucien Drive, Suite115, Maitland, FL 32751.
 
- 2 -
II. JURISDICTION AND VENUE
3.
 
This Court has exclusive jurisdiction of this action for patent infringement pursuant to 28 U.S.C. § 1338(a).4.
 
This Court has jurisdiction over the subject matter of this action pursuant to 28U.S.C. §§ 1331 and 1338(a).5.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and 1400.6.
 
Upon information and belief, Panda has minimum contacts with this judicialdistrict such that this forum is a fair and reasonable one. Panda regularly conducts businesswithin the District of Colorado and has also committed such purposeful acts and/or transactionsin Colorado that it reasonably knew and/or expected that it could be hauled into court as aconsequence of such activity, including the offering for sale and sale in Colorado of theinfringing products that are the subject of this action.7.
 
Venue over this action is proper in this Court under 28 U.S.C. §§ 1391(b), (c) and 1400(b).
III. THE PATENTS-IN-SUIT
8.
 
On February 16, 2010, United States Patent No. 7,665,119 ("the '119 Patent") wasduly and legally issued for "Policy-Based Selection of Remediation." A true and correct copy of the '119 Patent is attached as Exhibit A.9.
 
On December 25, 2012, United States Patent No. 8,341,691 ("the '691 Patent")was duly and legally issued for "Policy-Based Selection of Remediation." A true and correctcopy of the '691 Patent is attached as Exhibit B.10.
 
CRT is the owner by assignment of all right, title and interest in and to the '119Patent and the '691 Patent, with full and exclusive rights to bring suit to enforce these patents,
 
- 3 -including the right to bring suit and collect damages for past infringement. All ownership rightsto the '119 Patent and '691 Patent were assigned to CRT by virtue of an assignment, which wasrecorded with the United States Patent and Trademark Office (USPTO) on November 1, 2011 atReel 027154, Frame 0556.11.
 
The '119 Patent and '691 Patent generally relate to policy-based selection of remediation(s) and deployment of the selected remediation(s) to a device, such as a laptopcomputer, desktop computer or mobile device, that has been potentially the subject of unauthorized activity or manipulation.12.
 
The Abstract of the '119 Patent and '691 Patent relevantly provides:A method, of automatically determining one or more remediations for a device thatincludes a processor, may include: receiving values of a plurality of parameters whichcollectively characterize an operational state of the device, there being at least one policyassociated with at least a given one of the plurality of parameters, policy defining as acondition thereof one or more potential values of, or based upon, the given parameter,satisfaction of the condition potentially being indicative of unauthorized activity or manipulation of the device; automatically determining, from the received parameter values, whether the conditions for any policies are satisfied, respectively; and automatically selecting one or more remediations for the device according to the satisfied  policies, respectively.13.
 
Independent Claims 1 and 26 of the '119 Patent read:1. A method of automatically determining one or more remediations for a devicethat includes a processor, the method comprising:receiving values of a plurality of parameters which collectively characterize anoperational state of the device, there being at least one policy associated with at least agiven one of the plurality of parameters, the at-least-one policy defining as a conditionthereof one or more potential values of, or based upon, the given parameter, violation of the condition potentially being indicative of unauthorized activity or manipulation of thedevice;automatically determining, from the received parameter values, whether theconditions for any policies are violated, respectively;automatically selecting one or more remediations for the device according to theviolated policies, respectively; and 

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->