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
MacroPoint v. Salebug.com et. al.

MacroPoint v. Salebug.com et. al.

Ratings: (0)|Views: 77|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00312: MacroPoint, LLC v. Salebug.com, LLC et. al. Filed in U.S. District Court for the Northern District of Ohio, no judge yet assigned. See http://news.priorsmart.com/-l9Uz for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00312: MacroPoint, LLC v. Salebug.com, LLC et. al. Filed in U.S. District Court for the Northern District of Ohio, no judge yet assigned. See http://news.priorsmart.com/-l9Uz for more info.

More info:

Published by: PriorSmart on Feb 13, 2014
Copyright:Public Domain

Availability:

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

02/13/2014

pdf

text

original

 
IN
THE
UNITED STATES DISTRICT
OURT
FOR
THE
NORTHERN DISTRICT
OF OHIO
EASTERN DIVISION MACROPOINT,
LL
6050 Oak Tree Boulevard Suite 150 Cleveland, Ohio 44131 Plaintiff
v
SALEBUG.COM,
LL
5930 A Harbour Park Drive Midlothian, VA 23112
PEGASUS TRANSTECH CORPORATION
4010 Boy Scout Boulevard Suite 300 Tampa, FL 33607
) ) )
) Civil Action No.:
) ) ) ) ) )
Judge:
COMPLAINT
FOR
PATENT INFRINGEMENT DEMAND
FOR
JURY
TRIAL
Defendants. )
~
Plaintiff, MacroPoint, LLC ( referred to herein as MacroPoint ), brings this action against Defendants, Salebug.com, LLC (referred to herein as Salebug.com ) and Pegasus TransTech Corporation (referred to herein as Pegasus ), and hereby complain and aver as follows: I. This is an action for injunctive and monetary relief to recover for the damage caused by and to prevent further damage arising from the unlawful and unauthorized use
of
MacroPoint's intellectual property through the infringement ofMacroPoint's patent rights under
35
U.S.C.
§
271
by Defendants. Specifically, MacroPoint complains and avers that Defendants infringe claims
of
United States Letters Patent No. 8,604,943, entitled, Systems and Methods for Monitoring Location
of
Freight Carried by a Vehicle (the ' 943 Patent ).
7996799
v
 
THE P RTIES
2
MacroPoint is a limited liability company organized and existing under the laws
of
the State
of
Ohio, with a principal place
of
business at 6050 Oak Tree Boulevard, Suite 150, Cleveland, OH 44131. MacroPoint is a software and application developer that provides cellular phone based solutions for operations such as location tracking, mobile communication, order updates, work activity updates, on-board diagnostic reporting, and text messaging. MacroPoint is the owner
of
he 943 Patent.
3
Upon information and belief, Defendant Sale bug.
com
is a limited liability company existing under the laws
of
the Commonwealth
of
Virginia with a principal place
of
business at 5930 A Harbour Park Drive, Midlothian, VA 23112.
4
Upon information and belief, Defendant Salebug.com holds itself out to be Salebug, LLC, which has an address at P.O. Box 3309, Reston,
V
20195; however, further upon information and belief, Salebug, LLC is a trade name or fictitious business name through which Salebug.com does business, and Salebug.com and Salebug, LLC are one and the same. 5. Upon information and belief, Defendant Pegasus is a corporation existing under the laws
of
the State
of
Florida with a principal place
of
business at 401 0 Boy Scout Boulevard, Suite 300, Tampa, FL 33607.
JURISDICTION ND VENUE
6
This Court has subject matter jurisdiction over this controversy concerning patent infringement pursuant to Title
35
U.S.C. § 271 and §
281
and Title 28 U.S.C. § 1331 and
§
1338(a). 7. This Court has specific personal jurisdiction over Defendant Salebug.com because, among other things, Salebug.com has sold and continues to offer to sell products and 2
7996799
v1
 
services that infringe the '943 Patent in Ohio through publicly available websites and online retailers. This Court has specific personal jurisdiction over Defendant Pegasus because, among other things, Pegasus directs its customers to download products and use services that infringe the '943 Patent
in
Ohio.
8
This Court has general personal jurisdiction over all the Defendants because, among other things, on information and belief, each Defendant regularly solicits and transacts business in Ohio and in this judicial district, each Defendant engages in a persistent course
o
conducting business in Ohio, and each Defendant derives substantial revenue from goods and services sold in Ohio and this judicial district.
9
Venue is proper in this judicial district under 28 U.S.C.
§§
1391 and 1400.
RELEV NT F CTS
10
Macro Point is the owner
o
the '943 Patent, which was
du1y
and lawfully issued on December 10, 2013, to Bennett H. Adelson as the inventor. A true and correct copy
o
the '943 Patent is attached hereto as Exhibit
A
MacroPoint is the owner
o
all right, title and interest in the '943 Patent, including the right to sue and recover damages for infringement
o
the '943 Patent and obtain a preliminary or permanent injunction. 11. MacroPoint designs, develops, markets and sells software products and services that facilitate location tracking and management
o
freight in transit. 12. Salebug.com develops, produces, offers for sale or sells software products and services that directly infringe, or that contribute to or induce infringement
o
one
or
more claims
o
the '943 Patent. Pegasus offers for sale, sells, or instructs its customers to procure software products and use services that directly infringe, or that contribute to
or
induce infringement
o
one or more claims
o
the '943 Patent. The infringing products and services include a Trucker 3
7996799
v

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)//-->