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Automated Transactions v. M&T Bank

Automated Transactions v. M&T Bank

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00506-SLR: Automated Transactions LLC v. M&T Bank Corporation. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-lagW for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00506-SLR: Automated Transactions LLC v. M&T Bank Corporation. Filed in U.S. District Court for the District of Delaware, the Hon. Sue L. Robinson presiding. See http://news.priorsmart.com/-lagW for more info.

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Published by: PriorSmart on Apr 21, 2014
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04/21/2014

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK
-------------------------------------------------------------------------x Civil Action No. 13-CV-1155
JURY TRIAL DEMANDED.
AUTOMATED TRANSACTIONS LLC,
Plaintiff 
, - v. - M & T BANK CORPORATION,
 Defendant.
: : : : : : : : : : : : : -------------------------------------------------------------------------x
COMPLAINT
Plaintiff Automated Transactions LLC (“Automated Transactions”) alleges as follows:
PARTIES
1.
 
Automated Transactions is a limited liability company organized and existing under the laws of the state of Delaware, having a principal place of business at 2711 Centerville Road, Suite 400, Wilmington, DE 19808. 2.
 
Upon information and belief, M & T Bank Corporation (“M & T”) is a state chartered natural person credit union with a principal place of business at One M & T Plaza, Buffalo, NY 14203.
NATURE OF ACTION
3.
 
This is an action for patent infringement pursuant to 35 U.S.C. §101, et. seq.
 
 
2
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 of the ‘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 ATM 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 ATM service; and access to the automated teller machine user interface whereupon the consumer may selectively dispense currency using the
 
 
3integrated banking and transaction machine providing the retail ATM service; wherein the consumer can purchase access to the retail ATM 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.
 
M & T is using ATMs within this judicial district which incorporate every element of the above claims or substantial equivalents thereof. Therefore, M & T 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.
 
M & T was made aware of the ‘158 patent and M & T’s infringement thereof by filing a Complaint and providing a non-service courtesy copy thereof.

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