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Protegrity v. Voltage Security

Protegrity v. Voltage Security

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Protegrity Corp v. Voltage Security Inc. Filed in U.S. District Court for the District of Connecticut, no judge yet assigned. See http://news.priorsmart.com/-l9ZJ for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Protegrity Corp v. Voltage Security Inc. Filed in U.S. District Court for the District of Connecticut, no judge yet assigned. See http://news.priorsmart.com/-l9ZJ for more info.

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Published by: PriorSmart on Mar 01, 2014
Copyright:Public Domain

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03/01/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT
 ____________________________________ PROTEGRITY CORPORATION ) a Cayman Islands Company, ) ) Plaintiff, ) ) Civil Action No. 3:14-cv-00257 v. ) ) VOLTAGE SECURITY, INC. ) a California Corporation, ) ) Defendant. ) JURY TRIAL DEMAND  ____________________________________)
COMPLAINT AND JURY DEMAND
Plaintiff, PROTEGRITY CORPORATION, by and through its undersigned attorneys, alleges, upon information and belief, as follows: THE PARTIES 1.
 
Plaintiff, Protegrity Corporation, is a corporation incorporated under the laws of the country of The Cayman Islands, with its principal operating subsidiary in the United States, Protegrity USA, Inc., a Delaware Corporation, having its principal place of business at 5 High Ridge Park, Stamford, Connecticut 06905. 2.
 
Upon information and belief, Defendant, Voltage Security, Inc., is a California Corporation, having its principal place of business in the State of California and having an office at 20400 Stevens Creek Boulevard, Suite 500, Cupertino, CA 95014. 3.
 
This action has arisen under the patent laws of the United States, Title 35 United States Code, Section 271
et seq.
4.
 
Jurisdiction of this action arises under 28 U.S.C. §1338(a). Venue is predicated
 
under 28 U.S.C. §1391(c). COUNT I 5.
 
On February 25, 2014, United States Patent Number 8,661,263 (hereinafter “’263 Patent”) entitled "Meta-Complete Data Storage " was duly and regularly issued. A copy of the ‘263 Patent is attached hereto as Exhibit "A". 6.
 
Plaintiff is the owner of the ‘263 Patent. 7.
 
U.S. Patent Application No. 11/904,791 (“’791 Application”) is the application that matured into the ‘263 Patent. 8.
 
Voltage was aware of the ‘791 Application during prosecution of the ‘791 Application. 9.
 
Voltage has been aware of the ‘263 Patent since at least its date of issuance. 10.
 
Voltage has been aware of the ‘263 Patent since the ‘791 Application published. 11.
 
Upon information and belief, Defendant has directly or contributorily infringed or induced the infringement of the claims of ‘263 Patent by having made, used or sold database security systems including Voltage’s Embedded Format Preserving Encryption or other similar encryption systems that embed policy information within the encrypted data, such systems and methods duly embody the invention as claimed in the ‘263 Patent; such infringement was willful and deliberate; the infringement by Defendant of said Plaintiff's ‘263 Patent has deprived Plaintiff of sales which it otherwise would have made and has in other respects injured Plaintiff and will cause Plaintiff added injury and loss of profits unless enjoined by this Court. 12.
 
Voltage has actively induced its customers to practice the claims of the ‘263 Patent by
inter alia
inducing its customers to use the accused systems in accordance with their designed operation. -
2
 -
 
13.
 
Voltage has actively induced its customers to secure data stored in its customers databases, such storage of data using the accused methods and system infringing the claims of the ‘263 Patent. 14.
 
Voltage has contributed to its customers direct infringement of the ‘263 Patent. 15.
 
Voltage’s accused systems are a component of the patented invention and constitute a material part of the invention with no substantial noninfringing uses. For example, Voltage’s accused systems are designed for and operate to protect data stored in a database using the methods and systems claimed in the ‘263 Patent. 16.
 
The Plaintiff has been damaged by the acts of infringement complained of herein. 17.
 
The Plaintiff has no adequate remedy without the intervention of this Court. 18.
 
This case is "exceptional" within the meaning of 35 USC § 285. -
3
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