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Automated Transactions v. Vermont Federal Credit Union

Automated Transactions v. Vermont Federal Credit Union

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Automated Transactions LLC v. Vermont Federal Credit Union. Filed in U.S. District Court for the District of Vermont, no judge yet assigned. See http://news.priorsmart.com/-laaM for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Automated Transactions LLC v. Vermont Federal Credit Union. Filed in U.S. District Court for the District of Vermont, no judge yet assigned. See http://news.priorsmart.com/-laaM for more info.

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Published by: PriorSmart on Mar 31, 2014
Copyright:Public Domain

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03/31/2014

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF VERMONT AUTOMATED TRANSACTIONS LLC, Plaintiff
.
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V.
) ) )
) Docket No.
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VERMONT FEDERAL CREDIT UNION, Defendant
) )
COMPLAINT Plaintiff Automated Transactions LLC ( Automated Transactions ) alleges as follows: Nature
o
Action
1.
This is an action for patent infringement pursuant to 35 U.S.C. § 101, et. seq. Parties
2.
Automated Transactions is a limited liability company organized and existing under the laws
o
the state
o
Delaware, having a principal place
o
business at 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.
3.
Upon information and belief, Vermont Federal Credit Union ( Vermont Federal ) is a community credit union with a principal place ofbusiness at 84 Pine St. (100 Financial Plaza),
P.
0.
Box 407, Burlington, Vermont 05402-0407.
gr ~~e~
I
TTORNEYS
AT LAW
76 St. Paul Street Post Office Box 369 Burlington, Vermont 05402-0369
A PROFESSIO='IAL
CORPORA TJON
 
Jurisdiction and Venue
4
This Court has jurisdiction over the subject matter
of
this action pursuant to
28
U.S.C. §§1331 and 1338.
5
Venue is proper in this judicial district under
28
U.S.C.
§§
1391
and 1400(b). FIRST CLAIM FOR RELIEF
6
On August 18,2009, U.S. Patent No. 7,575,158 (the '158 patent ) was duly and legally issued to David
M
Barcelou. A true and correct copy
ofthe
'158 patent is attached hereto as Exhibit
A.
7
By license, Automated Transactions is the exclusive licensee
of
the '158 patent with the right
to
sue for past and future infringement and collect damages therefore in its own name.
8
The '158 patent discloses and claims, among other things, integrated banking and transaction machines. Claims 1-3, 11-13 and
15
state as follows:
1
An integrated banking and transaction machine for use by a consumer to purchase access to retail A TM services, comprising: an automated teller machine; a user interface
to
the automated teller machine; means for identifying the user
to
the automated teller machine, further comprising a smart card/magnetic stripe reader/encoder and a sensor; an Internet interface to an Internet connection to the automated teller machine that uses encryption services and security services to provide the user access to the user interface and retail A TM service; and access
to
the automated teller machine user interface whereupon the consumer may selectively dispense currency using the integrated banking and transaction machine providing the retail A TM service;
gr ~~e~
IATTORNEY AT AW
76 St. Paul Street Post Office
llox
369 llurlington, Vermont 05402-0369
A
PROFESSIONAl
CORPORATION
 
wherein the consumer can purchase access to the retail A TM service through use
of
the user interface and Internet services connections. 2. The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with cash.
3.
The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with bills.
11.
The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with a credit card. 12. The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with a debit card. 13. The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with a stored value card. 15. The integrated banking and transaction machine according to claim
1
further comprising means for consummating the purchase with an identification card.
9.
Vermont Federal is using ATMs within this judicial district which incorporate every element
of
the above claims or substantial equivalents thereof. Therefore, Vermont Federal is directly or indirectly infringing at least the above claims
of
the 158 patent, either literally or under the doctrine
of
equivalents, and is liable for infringement
of
the
158 patent pursuant to 35
u.s.c.
§271. 10. Vermont Federal was made aware
ofthe
158 patent and Vermont Federal s infringement thereof by a letter sent to Vermont Federal with an offer to license the patent.
11.
Vermont Federal also provides the above ATMs for use
by
customers and others within this judicial district, and provides those customers and others with detailed explanations, instructions and information as to arrangements, applications and uses
of
these ATMs that
gr ~~e~
IATTORNFYWCAW
76 St. Paul Street Post Office
Box
369
Burlington,
Vermont
05402-0369
A PROFE)SJONAL
CORPORATION
-
3-

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