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Pictometry International v. Geospan

Pictometry International v. Geospan

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 0:13-cv-02359: Pictometry International Corporation v. Geospan Corporation. Filed in U.S. District Court for the District of Minnesota, no judge yet assigned. See http://news.priorsmart.com/-l8ZV for more info.
Official Complaint for Patent Infringement in Civil Action No. 0:13-cv-02359: Pictometry International Corporation v. Geospan Corporation. Filed in U.S. District Court for the District of Minnesota, no judge yet assigned. See http://news.priorsmart.com/-l8ZV for more info.

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Published by: PriorSmart on Aug 28, 2013
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08/29/2013

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UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTAPICTOMETRY INTERNATIONALCORPORATION
, a DelawareCorporation,Plaintiff,v.
GEOSPAN CORPORATION
, aMinnesota CorporationDefendant.§§§§§§§§§§§Case No. _______________________ 
JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff, Pictometry International Corp. (“Pictometry”), by and through its counsel, brings this complaint against Geospan Corp. (“Geospan”), as follows:
PARTIES
1. Pictometry is a Delaware corporation which has its principal place of business inRochester, New York.2. Geospan is a Minnesota Corporation which has its principal place of businesslocated at 10900 73
rd
Ave. North, Suite 36, Maple Grove, Minnesota.
JURISDICTION AND VENUE
3. Pictometry incorporates each of its previous allegations.4. This is a civil action for patent infringement under the patent laws of the UnitedStates and, more specifically, under Title 35 U.S.C. §§ 271, 281, 283, 284, and 285.
 
5. This action involves a federal question in that it arises from Geospan’sinfringement of Pictometry’s patent rights, and jurisdiction over the present subject matter isconferred upon this Court pursuant to 28 U.S.C. §§ 1331 and 1338(a).6. This Court has general personal jurisdiction over Geospan in this action as it isregistered in, and maintains a principal place of business within, the State of Minnesota.7. Venue is proper in this District pursuant to 28 U.S.C. §§ 1400, and 1391(b) and(c).
BACKGROUND
8. Since its inception in 1995, Pictometry’s business has been devoted entirely toaerial photogrammetry.
1
Using its proprietary methods and apparatuses, Pictometry’s aircraft flyover a specified geographic area and, using digital cameras, capture orthogonal and obliqueimages of virtually every square foot of the area, including every structure or other featurecontained therein. Pictometry pioneered the ability to capture oblique aerial images, i.e., imagescaptured at an angle, typically 45 degrees, and process them “on the fly” such that the geographiccoordinates (longitude, latitude, and elevation) of each pixel in each image was calculated atmoment the oblique aerial image was captured. The apparatuses and processes developed byPictometry enable the creation of a photographic map on which accurate measurements of distances, areas, and heights of features shown in the images can be made.9. United States Patent 7,424,133 (“the ‘133 Patent”), entitled METHOD ANDAPPARATUS FOR CAPTURING, GEOLOCATING AND MEASURING OBLIQUEIMAGES, issued September 9, 2008. A copy of the ‘133 Patent is attached hereto as Exhibit 1.10. Pictometry is the owner by assignment of the ‘133 Patent.
 
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Photogrammetry is the science of making measurements on photographs.
 
 
11. As a part of its on-going efforts to lead the field in aerial photogrammetry,Pictometry has expended considerable amounts of time, expertise, and money on the researchand development, patenting, marketing, promotion, manufacture, and distribution of its obliqueaerial technologies. As result of such efforts, Pictometry has developed new and more advancedmethods and apparatuses that enable users to,
inter alia
, display, geolocate, and take highlymeasurements from the captured and processed oblique aerial images; technologies which areencompassed in the claims of the ‘133 Patent.12. Since its inception in 1994, Geospan’s business has been devoted primarily to theuse of terrestrial photogrammetry. Geospan uses ground-based vehicles, such as vans, to carry photographic and computer equipment, along with sophisticated tracking systems. Geospanacquires video images of the areas adjacent to the streets driven by the vans and processes suchimages so that the location of objects appearing in the images can be determined. More recently,Geospan has expanded its business into aerial photogrammetry.13. Geospan maintains a website atwww.geospan.com. A true and correct copy of excerpts from Geospan’s website as accessed and printed August 27, 2013, are attached hereto asExhibit 2.14. As shown on Geospan’s website, Geospan offers technology that enables a user tomake measurements on oblique aerial images stored on a database. Geospan markets thistechnology as a part of its GEOVISTA® Products and Services. (Ex. 2, pp. 1-3)15. The photogrammetric services described and depicted on Geospan’s websiteinfringe one or more claims of the ‘133 Patent.16. Sometime prior to January 19, 2011, the City of Branson, Missouri issued aRequest For Proposal (“RFP) for Digital Orthophotography, Oblique Imagery, & Digital

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