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Charles Smith Enterprises v. North Plains Systems Holdings

Charles Smith Enterprises v. North Plains Systems Holdings

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00205-UNA: Charles Smith Enterprises LLC v. North Plains Systems Holdings LP. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9Vz for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00205-UNA: Charles Smith Enterprises LLC v. North Plains Systems Holdings LP. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9Vz for more info.

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Published by: PriorSmart on Feb 18, 2014
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02/18/2014

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01:15038574.1
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CHARLES SMITH ENTERPRISES, LLC, Plaintiff, v.  NORTH PLAINS SYSTEMS HOLDINGS, LP, Defendant. Civil Action No. ________________ JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Charles Smith Enterprises, LLC (“CSE”) for its Complaint against Defendant  North Plains Systems Holdings, LP (“NORTH PLAINS”) for injunctive and declaratory relief and damages, including treble or multiple damages, for patent infringement, states and alleges as follows:
NATURE OF THE ACTION
1.
 
Plaintiff CSE is the owner of United States Patent No. 6,877,010 (“the ’010 Patent”). 2.
 
Plaintiff CSE is the owner of United States Patent No. 7,756,876 (“the ’876 Patent”). 3.
 
Plaintiff CSE is the owner of United States Patent No. 8,060,515 (“the ’515 Patent”). 4.
 
This is a civil action for the infringement of the ’010 Patent, the ’876 Patent, and the ’515 Patent (collectively, the “Patents-in-Suit”), including the willful infringement of the Patents-in-Suit by Defendant NORTH PLAINS.
 
 - 2 -
 01:15038574.1
5.
 
The technology at issue generally involves customizable logging and content management systems for indexing media. The systems include a timer object that provides a time reference upon request in connection with the media and a logger object that logs  predefined events that occur in the media by associating the events with the respective time references from the timer object. The systems can be configured to automatically log predefined events, such as through video analysis, audio analysis, or text analysis.
PARTIES
6.
 
Plaintiff CSE is a Delaware limited liability company with its principal place of  business located at 5 The Crossing, North Caldwell, New Jersey 07006. 7.
 
Plaintiff CSE has invested substantial time and money in researching, acquiring, marketing, and commercializing the technology embodied in the Patents-in Suit. 8.
 
Plaintiff CSE additionally owns pending U.S. patent application Ser. No. 13/279,942, entitled “System and Method for Computer-Assisted Manual and Automatic Logging of Time-Based Media,” which is a continuation of and claims priority to U.S. patent application Ser. No. 09/806,008 filed Sep. 20, 2001, which issued as the ’010 Patent. 9.
 
Plaintiff CSE’s interests in the exploitation of its patented technology in the United States and abroad have been and continue to be harmed by Defendant NORTH PLAINS’s infringement of the Patents-in-Suit. 10.
 
Defendant NORTH PLAINS is a Delaware corporation with its principal place of  business located 510 Front Street West 4th Floor, Toronto, Ontario M5V 3H3, Canada. Defendant NORTH PLAINS provides digital asset management (DAM) solutions worldwide, including its Telescope
TM
 DAM systems that allow customers control and rapid access to millions of images, videos and other rich media files for commercial use and re-use. On
 
 - 3 -
 01:15038574.1
information and belief, Defendant NORTH PLAINS transacts business within the State of Delaware and has committed acts of patent infringement as hereinafter set forth within the State of Delaware.
JURISDICTION AND VENUE
11.
 
This action arises under the patent laws of the United States, Title 35 of the United States Code § 100
et seq.
, and in particular §§ 271, 281, 283, 284 and 285, and is intended to redress infringement of the Patents-in-Suit. 12.
 
This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 13.
 
This Court has personal jurisdiction over Defendant NORTH PLAINS, and venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 (b)-(c) and 1400(b), in that Defendant NORTH PLAINS is a Delaware corporation and is committing acts of patent infringement within the United States and in this judicial district, either directly or indirectly, including the infringing acts alleged herein, and will continue to do so unless enjoined by this Court. Defendant NORTH PLAINS directly or through intermediaries (including distributors, retailers, and others), ships, distributes, offers for sale, sells, and advertises its products and services in the United States and in this judicial district, including but not limited to Telescope
TM
 DAM systems. Defendant NORTH PLAINS has purposefully and voluntarily sold infringing software and performed infringing services with the expectation that they will be  purchased and used by consumers in this judicial district.
THE PATENTS-IN-SUIT
14.
 
Plaintiff CSE is the owner of the ’010 Patent. The ’010 Patent is entitled “System and Method for Computer-Assisted Manual and Automatic Logging of Time-Based Media.”

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