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Data Speed Technology LLC

Data Speed Technology LLC

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01450-UNA: Data Speed Technology LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8Wj for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01450-UNA: Data Speed Technology LLC. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l8Wj for more info.

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Published by: PriorSmart on Aug 19, 2013
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08/19/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
DATA SPEED TECHNOLOGY LLC,Plaintiff,vs.THOMSON REUTERS CORPORATION,THOMSON REUTERS U.S.A. INC.,THOMSON REUTERS U.S. LLC,Defendants.
 
)))))))))C.A. No. ________________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
This is an action for patent infringement in which Plaintiff Data Speed Technology LLCmakes the following allegations against Defendants Thomson Reuters Corporation,
ThomsonReuters U.S.A. Inc., and Thomson Reuters U.S. LLC
(collectively, the “Defendants”).
BACKGROUND
1.
 
Kenneth H. Conner is a life-long computer engineer with knowledge andexperience with many technologies including: mainframe computers, application software,operating systems, cellular communications, and networking. This experience comes fromworking with technology giants including Digital Equipment Corporation, Argonne NationalLaboratory, Bell Labs, Motorola, and Lucent. In early 1993, Mr. Conner, along with James. GHunter, Gregory P. Spar, and Bruce Anderson invented a new information management andstorage system that enabled multiple computers to independently read and write to a massstorage device in a relatively high speed manner on a first come, real time basis. For example,the computer first accessing a particular memory address space or file would have the exclusiveability to write to that file and the file would be locked to subsequent computers attempting to
 
 2
write to it, which allowed multiple computers to use a mass storage device in a high speedmanner without conflict. By the summer of 1993, the team had developed a working functional prototype of their invention. On November 9, 1993, the team filed an application for patent onthe invention, and on February 2, 1999, the U.S. Patent and Trademark Office issued U.S. Patent No. 5,867,686 (the “Conner Patent”).
PARTIES
2.
 
Plaintiff Data Speed Technology LLC (“Data Speed Tech”) is a Delaware limitedliability company.3.
 
On information and belief, Defendant Thomson Reuters Corporation is aCanadian Corporation with its principal place of business at 3 Times Square, New York, NewYork 10036.4.
 
On information and belief, Defendant Thomson Reuters U.S.A. Inc. is acorporation organized under the laws of the state of Delaware with a principal office at 3 TimesSquare, New York, NY 10036. On information and belief, Defendant Thomson Reuters U.S.A.Inc. may be served with process via its registered agent, The Prentice-Hall Corporation System,Inc., 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.5.
 
On information and belief, Defendant Thomson Reuters U.S. LLC is a limitedliability company organized under the laws of the state of Delaware with a principal office at 3Times Square, New York, NY 10036. On information and belief, Defendant Thomson ReutersU.S. LLC may be served with process via its registered agent, Corporation Service Company,2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
 
 3
JURISDICTION AND VENUE
6.
 
This action arises under the patent laws of the United States, 35 U.S.C. § 1,
et  seq
., including § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331and 1338(a).7.
 
This Court has specific and general personal jurisdiction over Defendants because, among other reasons, Defendants have availed themselves of the rights and benefits of Delaware by incorporating under Delaware law, Defendants have done business in this District,have committed and continue to commit acts of patent infringement in this District, and/or haveharmed and continues to harm Data Speed Tech in this District, by, among other things, using,selling, offering for sale, and importing infringing products and services in this District.8.
 
Venue is proper in this district under 28 U.S.C. §§ 1391(b)-(d) and 1400(b) because, among other reasons, Defendants are subject to personal jurisdiction in this District,Defendants have committed and continue to commit acts of patent infringement in this Districtand/or Defendants are incorporated in this district. On information and belief, for example,Defendants have used, sold, offered for sale, and imported infringing products in this District.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 5,867,686
9.
 
Data Speed Tech is the owner by assignment of the Conner Patent, entitled “HighSpeed Real-Time Information Storage System.” A true and correct copy of the Conner Patent isattached as Exhibit A.10.
 
Defendants have been and now are directly infringing the Conner Patent, literallyand under the doctrine of equivalents, in this judicial District and elsewhere in the United States by, among other things, making, using, importing, offering for sale, and/or selling electronicinformation management and storage products and services that use a method of providing

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