The Patent-in-Suit, U.S. Patent No. RE43,462,
Video Monitoring and Conferencing System
was reissued on June 12, 2012; it is a reissue of United States Patent No. 5,6
25,410 (the ’410 Patent), which
was duly and legally issued by the United States Patent and Trademark Office on April 29, 1997. A copy of the Patent-in-Suit is attached hereto as Exhibit A.
The independent claims in the reissued ’462 Patent are substantially identical to the correspond
claims in the original ’410 Patent.
HTS is the exclusive owner of all rights, title, and interest in the Patent-in-Suit, including the right to exclude others and to enforce, sue and recover damages for past and future infringement thereof. 13.
The named inventors, Messrs. Ken Washino and Barry Schwab, have collaborated on a number of other pioneering inventions resulting in patents in the areas of video archiving, video downloading and digital cinema. 14.
Mr. Schwab is a named inventor on more than thirty patents, ranging from consumer products to secure network computing.
INFRINGEMENT OF THE PATENT-IN-SUIT
HTS incorporates paragraphs 1 through 14 by reference as if fully stated herein. 16.
The Patent-in-Suit is valid and enforceable. 17.
Defendant has directly infringed, and continues to directly infringe, one or more claims of the Patent-in-Suit under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by making, using, selling, offering for sale, and/or importing products and/or methods embodying the patent and therefore encompassed by those claims.