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Relay IP v. Brocade Communications Systems

Relay IP v. Brocade Communications Systems

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Published by PatentBlast
Relay IP v. Brocade Communications Systems
Relay IP v. Brocade Communications Systems

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Published by: PatentBlast on Sep 02, 2013
Copyright:Attribution Non-commercial

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12/11/2013

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 1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
RELAY IP, INC.,Plaintiff,v.BROCADE COMMUNICATIONSSYSTEMS, INC.,Defendant.C.A. No. _________ 
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Relay IP, Inc. (“Relay IP”) alleges the following for its complaint againstDefendant Brocade Communications Systems, Inc.
THE PARTIES
1.
 
Plaintiff Relay IP, Inc. is a corporation formed under the laws of the State of Delaware having its principal place of business at 2331 Mill Road, Suite 100, Alexandria, VA22314.
2.
 
Defendant Brocade Communications Systems, Inc. is a corporation organizedunder the laws of the State of Delaware with a principal office at 130 Holger Way, San Jose, CA95134. Defendant Brocade Communications Systems Inc. may be served with process via itsregistered agent, The Corporation Trust Company, 1209 Orange Street, Wilmington, DE 19801.
 JURISDICTION AND VENUE
3.
 
This is a patent infringement action. The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1338.4.
 
The Court has personal jurisdiction over Defendant, as it is incorporated in thisState. Defendant has also availed itself, under the Delaware long arm statute, of the rights and
 
 2 benefits of this District by conducting business in this jurisdiction, including by promoting products for sale via the Internet, which are accessible to and accessed by residents of thisDistrict.5.
 
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because Defendant resides in this District and substantial acts of infringement have occurred inthis District.
COUNT ONEINFRINGEMENT OF U.S. PATENT NO. 5,331,637
6.
 
On July 19, 1994, U.S. Patent No. 5,331,637 (the “’637 Patent”) entitled“Multicast Routing Using Core Based Trees” was duly and legally issued by the United StatesPatent and Trademark Office. A true and correct copy of the ’637 Patent is attached as Exhibit Ahereto.7.
 
Plaintiff Relay IP is the sole and exclusive owner of all right, title, and interest inthe ’637 Patent and holds the exclusive right to take all actions, including the filing of this patentinfringement lawsuit, necessary to enforce its rights to the ’637 Patent. Relay IP also has theright to recover all damages for past, present, and future infringement of the ’637 Patent and toseek injunctive relief as appropriate under the law.8.
 
Defendant has infringed and continues to directly infringe one or more claims of the ’637 Patent, including at least Claim 1, by using the method claimed in testing equipmentthat it sells and has sold for use by its customers to also practice the method of at least Claim 1 of the ’637 Patent. Such equipment includes the following and all other routing platforms thatsupport/enable the practice of the PIM-SM standard:FastIron CX 624SFastIron CX 648SFastIron CX 624S-FFastIron CX 624S-HPOE
 
 3FastIron CX 648S-HPOEFastIron FES2402-POE-PREMFastIron FES4802-POE-PREMFastIron SuperXFastIron SX 800FastIron SX 1600Brocade FCX 624Brocade FCX 648Brocade FCX 624SBrocade FCX 648SBrocade FCX 624S-FBrocade FCX 624S-HPOEBrocade FCX 648S-HPOETurboIron 24XBigIron RX-4BigIron RX-8BigIron RX-16 NetIron CES 2000 SeriesFastIron FESX424FastIron FESX624FastIron FESX424-POEFastIron FESX448FastIron FESX648FastIron FESX424HFFastIron FESX624HFBrocade MLXe-4Brocade MLX-4Brocade MLXe-8Brocade MLX-8Brocade MLXe-16Brocade MLX-16Brocade MLXe-32Brocade MLX-32 NetIron XMR 4000 NetIron XMR 8000 NetIron XMR 16000 NetIron XMR 32000 NetIron CER 2024C NetIron CER 2024F NetIron CER 2048C NetIron CER 2048F NetIron CER 2048CX NetIron CER 2048FXFastIron FWS624FastIron FWS624-EPREMFastIron FWS624-POE

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