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Parallel Networks v. SAP America

Parallel Networks v. SAP America

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Published by PatentBlast
Parallel Networks v. SAP America
Parallel Networks v. SAP America

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Published by: PatentBlast on Aug 27, 2013
Copyright:Attribution Non-commercial

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08/27/2013

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01:14037249.1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
 
PARALLEL NETWORKS, LLC,Plaintiff 
 ,
v.SAP AMERICA, INC.,Defendant
.
))))))))))) C.A. No.__________ 
JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Parallel Networks, LLC (“Parallel”) files this Complaint for patent infringementagainst Defendant SAP America, Inc. (“SAP” or “Defendant”) and alleges as follows:
PARTIES
1.
 
Plaintiff Parallel Networks, LLC is a Delaware limited liability company havingits principal place of business at 1105 N. Market St., Suite 300, Wilmington, Delaware 19801.
2.
 
On information and belief, SAP is a corporation organized under the laws of theState of Delaware, and has a principal place of business at 3999 West Chester Pike, NewtownSquare, Pennsylvania 19073 and/or is conducting business through an affiliate located at thisaddress.
JURISDICTION AND VENUE
3.
 
This civil action for patent infringement arises under the Patent Laws of theUnited States, 35 U.S.C. §§ 1
et seq.
This Court has jurisdiction over the claims presented herein pursuant to 28 U.S.C. §§ 1331 and 1338(a).
 
 2
4.
 
On information and belief, SAP makes, imports, uses, sells, and/or offers for salethe Accused Instrumentalities (as defined below) within the United States, including this District,that infringe one or more claims of United States Patent No. 7,571,217 entitled “METHOD ANDSYSTEM FOR UNIFORM RESOURCE LOCATOR TRANSFORMATION” (the “'217Patent”). The '217 Patent was duly and legally issued by the United States Patent and Trademark Office on August 4, 2009. A true and correct copy of the '217 Patent is attached hereto asExhibit 1.
5.
 
On information and belief, SAP makes, imports, uses, sells, and/or offers for salethe Accused Instrumentalities (as defined below) within the United States, including this District,that infringe one or more claims of United States Patent No. 8,352,570 entitled “METHOD ANDSYSTEM FOR UNIFORM RESOURCE LOCATOR TRANSFORMATION” (the “'570Patent”). The '570 Patent was duly and legally issued by the United States Patent and Trademark Office on January 8, 2013. A true and correct copy of the '570 Patent is attached hereto asExhibit 2.
6.
 
The '217 Patent and '570 Patent are collectively referred to herein as the“Asserted Patents.”
7.
 
Parallel is the owner by assignment of all rights, title, and interests in theAsserted Patents, and is entitled to sue for past and future infringement thereof.
8.
 
On information and belief, SAP is engaged in the business of developing and selling enterprise software and software-related services. More particularly, SAP offers NetWeaver Application Server software that includes SAP’s Web Dispatcher software. SAP’s NetWeaver Application Server software with the Web Dispatcher software, (these and any and all similar products referred to herein as the “Accused Instrumentalities”) perform and/or 
 
 3facilitate caching.
See
 http://help.sap.com/saphelp_nw73ehp1/helpdata/en/48/99da1bec0973e9e10000000a42189b/frameset.htm (last visited August 22, 2013).
9.
 
On information and belief, SAP markets, offers for sale, and sells theAccused Instrumentalities in this District via an interactive website,
http://www.sap.com/index.epx
, that offers products for sale through an “SAP Store,” and alsoencourages a potential customer to call and purchase directly from SAP. On informationand belief, SAP also markets, offers for sale, and sells the Accused Instrumentalities via“Partners” in this District.10.
 
On information and belief, SAP directly and/or indirectly imports,manufactures, uses, offers for sale, and/or sells the Accused Instrumentalities within theUnited States, including this District, that infringe one or more claims of the Asserted Patents.11.
 
Venue is proper in this District pursuant to 28 U.S.C. § 1400(b).
GENERAL ALLEGATIONS
12.
 
On information and belief, SAP is engaged in the business of developing, makingor having made, using, offering for sale and selling the Accused Instrumentalities. Among themany features of the Accused Instrumentalities is the ability to perform transparent cacheswitching. On information and belief, each of the Accused Instrumentalities constitute anintegrated hardware and software solution that acts, among other capacities, as a caching server that receives requests for web content comprising URL and header information. On informationand belief, each of the Accused Instrumentalities determines whether requested content iscached, and provides web address translation and request/response rewrite in connection with

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