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Eclipse IP v. Delta Air Lines

Eclipse IP v. Delta Air Lines

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-06647-DMG-FFM: Eclipse IP LLC v. Delta Air Lines Inc. Filed in U.S. District Court for the Central District of California, the Hon. Dolly M. Gee presiding. See http://news.priorsmart.com/-l96k for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-06647-DMG-FFM: Eclipse IP LLC v. Delta Air Lines Inc. Filed in U.S. District Court for the Central District of California, the Hon. Dolly M. Gee presiding. See http://news.priorsmart.com/-l96k for more info.

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Published by: PriorSmart on Sep 14, 2013
Copyright:Public Domain

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04/04/2014

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1
Matt Olavi, Esq. (Bar No. 265945)2molavi@olavidunne.comBrian
J.
Dunne, Esq. (Bar No. 275689)bdunne@olavidunne.com
4
OLA
VI DUNNE LLP
800 Wilshire Blvd., Suite 320
5
Los Angeles, California 900176Telephone: (213) 516-7900Facsimile: (213) 516-7910
7
8
Attorneys for PlaintiffEclipse
IP
LLC
SEP
I I
2013
~.f!IITRAL
lliSTRIGT
Df
CAliFORNIA
H'l -
ilf:PiiiY
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. .
·-·-
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9
UNITED STATES DISTRICTCOURTCENTRAL DISTRICT
J.
,ORNI~
·-
11
ECLIPSE
IP
LLC, a Florida Limited ) Case
tM
13 0 6 6 4
7
10
12
Liability Company, )
)
COMPLAINT
FOR
PATENT
)
INFRINGEMENT
13
Plaintiff,
)
)
TRIAL BY JURY DEMANDED
4
v.
15
)
16DELTA AIR LINES, INC., a Delaware )Corporation, )
17
)
1819
20
21
22
23
24
25
26
27
28
Defendant. )
______________________
)
COMPLAINT FOR PATENT INFRINGEMENT
 
1
Plaintiff Eclipse IP LLC ("Eclipse"), by and through counsel, complains .2
3
4
56
7
8
9
10
11
12
against Delta Air Lines, Inc. ("Delta") as follows:
NATURE
OF LAWSUIT
I.
This is a suit for patent infringement arising under the patent laws
of
the United States, Title 35
of
the United States
Code§
1
et
seq.
This Court hasexclusive jurisdiction over the subject matter
of
the Complaint under
28
U.S.C.
§§
1331 and 1338(a).
PARTIES
ANDPATENTS
2.
Eclipse is a company organized under the laws
of
Florida and having
13
a principal place
of
business at 115 NW
17th
St, Delray Beach, Florida 33444.
1415
~
.),
Eclipse owns all right, title, and interest in and has standing to sue for16infringement
ofUnited
States Patent No. 7,119,716 ("the '716 patent"), entitled
17
"Response systems and methods for notification systems for modifying future
18
notifications" (Exhibit A) and United States Patent No. 7,504,966 ("the '966
19
20patent"), entitled "Response systems and methods for notification systems for
21
modifying future notifications" (Exhibit
B)
(collectively, "the Eclipse Patents").
4.
On information and belief, Delta is a corporation existing under thelaws ofDelaware.
5.
On information and belief, Delta does regular business in this Judicial
222324
25
26
District and conduct leading to Delta's acts
of
infringement has occurred in this27
28
Judicial District.
I
COMPLAINT
FOR
PATENT INFRINGEMENT
 
JURISDICTION
AND
VENUE
6.
This Court has personal jurisdiction over Delta because it has engaged
1
2
3
4in continuous and systematic business in California; upon information and belief,
5
derives substantial revenues from commercial activities in California; and, upon
6
7
8
9
10
11
12
13
14
15
16
171819
20
2122
23
information and belief, is operating and/or supporting products or services that fallwithin one
or
more claims
of
Eclipse's patents in this District.
7.
Venue
is
proper in this District under 28 U.S.C.
§§
139l(b) and (c)and 28 U.S.C. § 1400(a) at least because the claim arises in this Judicial District,Delta
may
be found and transacts business in this Judicial District, and injuriessuffered by Plaintiff took place in this Judicial District. Delta is subject to thegeneral and specific personal jurisdiction
of
this Court at least because
of
itscontacts with the State
of
California.
FACTUAL BACKGROUND
8.
On information and belief, Delta is an airline that offers domestic andinternational flights from cities across the United States, including many from LosAngeles.
9.
On infonnation and belief, Delta creates and maintains a timetable for
24
every scheduled Delta flight, which includes a scheduled departure time
and
a
25
scheduled arrival time for every Delta flight.
26
27
10.
On
information and belief, Delta, either
on
its
own
or through its
28
agents, monitors the location
of
its various airplanes, and based at least in part on
2
COMPLAINT
FOR
PATENT INFRINGEMENT

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