Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
Employment Law Compliance, Inc. v. Texas Automobile Dealers Association

Employment Law Compliance, Inc. v. Texas Automobile Dealers Association

Ratings: (0)|Views: 11|Likes:
Published by PatentBlast
Employment Law Compliance, Inc. v. Texas Automobile Dealers Association
Employment Law Compliance, Inc. v. Texas Automobile Dealers Association

More info:

Published by: PatentBlast on Sep 25, 2013
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

09/25/2013

pdf

text

original

 
COMPLAINT FOR PATENT INFRINGEMENT Page 1
COMPLAINT FOR PATENT INFRINGEMENT
 Plaintiff 
Employment Law Compliance, Inc. (“ELC”) files this Complaint for Patent
Infringement against Texas Automobile Dealers Association, a Texas Non-Profit Corporation
(“TADA”),
Sonic-
Lute Riley, LP (“Sonic
-
LR”), Sonic
-
Massey Cadillac, LP (“Sonic
-
MC”) and
Sonic-
Richardson F, LP (“Sonic
-
RF”), KPA Services, LLC (“KPA”) and HotlinkHR, Inc.(“Hotlink”) (collectively referred to as “Defendants”) for infringement of United States Patent Number 7,330,817 (“the ‘817 Patent”) pursuant
to 35 U.S.C. § 271.
NATURE OF THE ACTION
1.
 
This is an action for patent infringement under Title 35 of the United States Code.2.
 
Defendants make, use, sell, offer for sale, and/or import into the United States products that fall within the scope of one or more claims of the
‘817
Patent.
IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXASDALLAS DIVISION
EMPLOYMENT LAW COMPLIANCE, INC.,
§§Plaintiff, §§vs. § Case No.§§ Jury Trial DemandedTEXAS AUTOMOBILEDEALERS ASSOCIATION,SONIC-LUTE RILEY, LP,SONIC-MASSEY CADILLAC, LP,SONIC-RICHARDSON F, LP,KPA SERVICES, LLC andHOTLINKHR, INC.§§§§§§§§Defendants. §
 
COMPLAINT FOR PATENT INFRINGEMENT Page 2
3.
 
ELC seeks damages pursuant to 35 U.S.C. § 284,
among other relief, for Defendants’
infringement of the
‘817
Patent.
THE PARTIES
 4.
 
Plaintiff ELC is a corporation organized and existing under the laws of the State of Georgia with is principal place of business in Atlanta, Georgia. ELC does businesswith clients in Texas and, more specifically, in the Northern District of Texas.5.
 
TADA is a Texas Non Profit Corporation organized and existing under the laws of the State of Texas with its principal place of business located at 1108 LaVaca, Suite800, Austin, Texas 78701.6.
 
On information and belief, TADA has been and is promoting and actively inducingthe use of and using, importing, selling and/or offering for sale products that infringeone or more claims of the
‘8
17 Patent.7.
 
TADA is doing business in the United States and, more particularly, in the NorthernDistrict of Texas by promoting and actively inducing the use of and using, importing,selling and/or offering for sale products that infringe one or more claims of the
‘817
Patent.8.
 
Service may be made upon TADA by serving its registered agent for service of  process William L. Wolters at 1108 Lavaca, Suite 800, Austin, Texas 78701.9.
 
On information and belief, Sonic-LR is a Limited Partnership organized and existingunder the laws of the State of North Carolina with its principal place of business inTexas located at 1331 North Central Expressway, Richardson, Dallas County, Texas75080.
 
COMPLAINT FOR PATENT INFRINGEMENT Page 3
10.
 
Sonic-LR has been and is using products that infringe one or more claims of the
‘817
Patent.11.
 
Sonic-LR is doing business in the United States and, more particularly, in the Northern District of Texas by using products that infringe one or more claims of the
‘817
Patent.12.
 
Service may be made upon Sonic-LR through its registered agent for service of  process CT Corporations System, 350 N. St. Paul, Suite 2900, Dallas, Texas 75201.13.
 
Upon information and belief, Sonic-MC is a Limited Partnership organized andexisting under the laws of the State of North Carolina with its principal place of  business in Texas located at 11675 LBJ Freeway, Garland, Dallas County, Texas75041.14.
 
Sonic-MC has been and is using products that infringe one or more claims of the
‘817
Patent.15.
 
Sonic-MC is doing business in the United States and, more particularly, in the Northern District of Texas by using products that infringe one or more claims of the
‘817
Patent.16.
 
Service may be made upon Sonic-MC through its registered agent for service of  process CT Corporations System, 350 N. St. Paul, Suite 2900, Dallas, Texas 75201.17.
 
Upon information and belief, Sonic-RF is a Limited Partnership organized andexisting under the laws of the State of North Carolina with its principal place of  business in Texas located at 1819 North Central Expressway, Richardson, DallasCounty, Texas.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->