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RPost Communications Limited et. al.

RPost Communications Limited et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00959: RPost Communications Limited et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9up for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00959: RPost Communications Limited et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l9up for more info.

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Published by: PriorSmart on Nov 19, 2013
Copyright:Public Domain

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALLDIVISIONRPOST HOLDINGS, INC.andRPOSTCOMMUNICATIONSLIMITED,Plaintiffs,v.SOPHOS, INC.Defendant.Civil Action No.2:13-cv-959JURY TRIAL DEMANDED
ORIGINALCOMPLAINT
In this ComplaintagainstDefendantSophos,Inc.,Plaintiffsallege, based on theirownknowledge with respect to theirown actions and basedoninformation and belief with respect to allother actions, as follows:
NATURE OF THE ACTION
1.This actionfor willful patent infringementarises under the Patent Laws of theUnited States, namely, 35 U.S.C. §§ 1 et seq.
PARTIES
2.
Plaintiff RPost Communications Limited (“RPC”) is a corporation organized
under the laws of the Nation of Bermuda.It isthe owner of United States Patent No. 8,504,628
(“the ’628patent”)entitled “
System and Method for Verifying Delivery and Integrity of Electronic Messages
.”
RPC is also the owner o
f United States Patent No. 8,468,199 (“the ’199 patent”) entitled “System and Method for Verifying Delivery and Integrity of Electronic
Messages.
RPC is also the owner of United States Patent No. 8,224,913
(“the ’913patent”)entitled “System and Method for Verifying Delivery and Integrity of Electro
nic Messages.
 
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RPC is also the owner of United States Patent No. 8,209,389
(“the ’389patent”) entitled “Systemand Method for Verifying Delivery and Integrity of Electronic Messages.”
The
’628, ’199
,
’913and ’389
patents wereduly and legally issued bythe United States Patent and Trademark OfficeonAugust 6, 2013; June 18,2013; July 17, 2012; and June 26, 2012respectively,after full andfair examination.The
’628, ’199, ’913 and ’389 patents
arevalid and enforceable.True andcorrect copies of the
’628, ’199, ’913 and ’389 patents
areattached as Exhibits A, B,C, and Drespectively.3.Plaintif
RPost Holdings, Inc. (“RPH”) is a corporation organized under the laws
of the State of Delawarehavingaplace ofbusinessat 555 Republic Drive #200Plano, Texas75074.It isan exclusive licenseefrom RPC of the
’628, ’199, ’913 and ’389 patents
.
4.
On informationand belief, DefendantSophos, Inc. is aMassachusettscorporationhaving a principal place of business at3Van De Graaff Drive, Burlington,Massachusetts,01803.Sophosprovides technologies that allow users to track, report,analyze, and authenticatedata regarding electronic messages, including but not limited toSophos
’s
Unified ThreatManagement, Enduser Protection Suites, SafeGuard Encryption, Secure Email Gateway, ServerSecurity, PureMessage, SafeGuard MailGateway, Sophos Email Appliance, PrivateCrypto, SPXEncryption, and Astaro Security Gateway/Sophos UTM Unified Threat Management products.5.Sophoshas committed acts of infringementand other unlawful acts in this judicialdistrict and does regular business in this judicial district, including providing the technologiesaccused of infringement in this judicial district.6.Oninformation and belief,Sophosis a nonresident of Texas who engages inbusiness in this state, but does not maintain a regular place of business in this state or adesignated agent for service of process in this state.Oninformation and belief,Sophosresides in
 
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this jurisdiction within the meaning of 28 U.S.C. §1400(b). This proceeding arises, in part, outof business done in this state.Upon information and belief,SophoshasappointedCTCorporation System,155 Federal Street Suite700,Boston,Massachusetts02110as its agent forservice of process.
JURISDICTION AND VENUE
7.This Court hassubject matter jurisdiction over this actionunder28 U.S.C. §§1331and1338(a).8.Venue is proper in this district under 28 U.S.C. §§ 1391(b)(2),(c), (d)and/or1400(b). On information and belief,Defendantconductsbusiness in this district, the claimsalleged in this Complaint arise in this district,andthe acts of infringement have taken place andare continuing to take place in this district.9.On information and belief,Defendantis
subject to this Court’s general and
specific personal jurisdiction becauseDefendantshaveminimum contacts within the State of Texas and the Eastern District of Texas, including via thewebsitewww.sophos.com, underdueprocess and/or the Texas Long Arm Statute,Defendanthaspurposefully availed themselvesof the privileges of conducting business in the State of Texas and in theEastern District of Texas;Defendantregularly conductsand solicitsbusiness within the State of Texas and within theEasternDistrict of Texas; andPlaintiffs
causes of action arise directly fromDefendant
sbusiness contacts and other activities in the State of Texas and in the Eastern District of Texas.10.Upon information and belief, Defendant had knowledge or wasaware of the
’628,’199, ’913 and ’389 patents
before the filing of the Original Complaint because products markedwith the patent numbers of one or more of these patents are made, offered for sale, and sold inthe United States, including but not limited to by RPost.RPost marks products with the patentnumber of one or more of the
’628, ’199, ’913 and ’389 patents
, among other places, in the

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