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Eclipse IP v. United Airlines

Eclipse IP v. United Airlines

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-06653-BRO-CW: Eclipse IP LLC v. United Airlines Inc. Filed in U.S. District Court for the Central District of California, the Hon. Beverly Reid O'Connell presiding. See http://news.priorsmart.com/-l96m for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-06653-BRO-CW: Eclipse IP LLC v. United Airlines Inc. Filed in U.S. District Court for the Central District of California, the Hon. Beverly Reid O'Connell presiding. See http://news.priorsmart.com/-l96m for more info.

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

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04/11/2014

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1
Matt Olavi, Esq. (Bar No. 265945)
3
molavi@olavidunne.com2
Brian
J.
Dunne, Esq. (Bar No. 275689)bdunne@olavidunne.com
4
OLA
VI DUNNE
LLP
FILED
C~f1\(.
IJ.S.
DISTRICT
COURT
SEP
I I
zot3
00 Wilshire Blvd., Suite 320
5
Los Angeles, California 900176Telephone: (213) 516-7900Facsimile: (213) 516-7910
cENTI\Ai.
i:liSTfiiCf
OF
CAUFORN!A
BY
DEPUTY
7
8
Attorneys
for
PlaintiffEclipse
IP
LLC
9
10UNITED STATES DISTRICT
COURT
CENTRAL DISTRICT
OF
CALIFORNIA
.
11
E~L!~SE
IP LLC, a Florida Limited
t-·
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A~~r<?
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665
3
)
12
L1ab1hty Company,
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COMPLAINTFORPATENT
1314
v.
15
Plaintiff, )
INFRINGEMENT
)
)
TRIAL
BY JURY
DEMANDED
)
16
UNITED AIRLINES, INC., a Delaware )Corporation, )
17
)
1819
20
2122
23
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26
27
28
Defendant. )
COMPLAINT
FOR
PATENT INFRINGEMENT
 
1
Plaintiff Eclipse IP LLC ("Eclipse"), by and through counsel, complains
2
3
4
56
7against United Airlines, Inc. ("United") as follows:
NATURE
OF
LAWSUIT
1.
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 has8exclusive jurisdiction over the subject matter
of
the Complaint under
28
U.S.
C.
9
10
11
12
§§
1331 and 1338(a).
PARTIES
AND PATENTS
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.
14
15
Eclipse owns all right, title, and interest in and has standing to sue for
16
infringement
of
United 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); United States Patent No. 7,482,952 ("the '952 patent"),
19
20entitled "Response systems and methods for notification systems for modifying
21
22
23
future notifications" (Exhibit B); and United States Patent No. 7,504,966 ("the '966patent"), entitled "Response systems and methods for notification systems for.
24
modifYing future notifications" (Exhibit
C)
(collectively, "the Eclipse Patents").
25
4.
On information and belief, United
is
a corporation existing under the
26
27
laws
of
Delaware.
28
I I I
I
COMPLAINT
FOR
PATENT INFRINGEMENT
 
1
2
3
4
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6
7
8
9
10
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12
13
141516171819
20
21
22
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5.
On information and belief, United does regular business in thisJudicial District and conduct leading to United's acts
of
infringement has occurredin this Judicial District.
JURISDICTION
AND
VENUE
6.
This Court has personal jurisdiction over United because it hasengaged in continuous and systematic business in California; upon information andbelief, derives substantial revenues from commercial activities in California; and,upon information and belief, is operating and/or supporting products or servicesthat fall within 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,United may be found and transacts business in this Judicial District, and injuriessuffered by Plaintiff took place in this Judicial District. United
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, United
is
an airline that offers domestic24and international flights from cities across the United States, including many from
25
Los Angeles.
26
27
28
IllIll
2
COMPLAINT FOR
PATENT INFRINGEMENT

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