INFRINGEMENT OF U.S. PATENT 6,480,894
Defendant has directly and/or indirectly infringed and continues to directly and/or indirectly infringe one or more claims of the
894 patent in this District or otherwise within theUnited States by its manufacture, use, sale, importation, licensing and/or offer for sale, withoutauthority: (i) web pages, content, and/or services presented and/or served to users from multipleweb engines while maintaining session state, including, without limitation, the web pages,content, and/or services accessible via https://webbanking.comerica.com/comerica andmaintained on servers located in and/or accessible from the United States under the control of Defendant; (ii) software, including, without limitation, software that allows web pages, content,and/or services to be presented and/or served to users from multiple web engines whilemaintaining session state; (iii) computer equipment, including, without limitation, computer equipment that stores, serves, and/or runs any of the foregoing; and/or (iv) and services storing,updating and/or maintaining information about financial transactions made on
website during a session, including, at least, but not limited to transfer of funds between accountsand bill payment on its website at https://webbanking.comerica.com/comerica, as well as any predecessor products or services of any of the foregoing.11.
Defendant also has infringed and continues to infringe one of more claims of the
‘894 patent by contributing to and/or actively inducing others to
use, sell, import, and/or offer for sale infringing products and/or services. Defendant indirectly infringes one or more claims of the
patent by active inducement under 35 U.S.C. § 271(b). Defendant has induced andcontinues to induce users of the web pages, content, services, software, computer equipmentand/or services identified above to directly infring
e one or more claims of the ’894
patent.Defendant indirectly infringe
s one or more claims of the ’894
patent by contributoryinfringement under 35 U.S.C. § 271(c). By providing the web pages, software, computer equipment, and/or services identified above, Defendant contributes to the direct infringement of users of said web pages, software, computer equipment, and/or services. Defendant is liable for
its infringement of the ‘894 patent pursuant to 35 U.S.C. § 271.