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Interface IP Holdings v. Six Continents Hotels

Interface IP Holdings v. Six Continents Hotels

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00509-UNA: Interface IP Holdings LLC v. Six Continents Hotels Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lah4 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00509-UNA: Interface IP Holdings LLC v. Six Continents Hotels Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lah4 for more info.

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Published by: PriorSmart on Apr 22, 2014
Copyright:Public Domain

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04/22/2014

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 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
Interface IP Holdings LLC, ) ) Plaintiff, ) ) v. ) Civil Action No. _____________ ) Six Continents Hotels, Inc., ) )
DEMAND FOR JURY TRIAL
Defendant. ) )
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Interface IP Holdings LLC (“Interface IP”), by and through its undersigned counsel, files this Complaint for Patent Infringement against Defendant Six Continents Hotels, Inc. (“Defendant”) as follows:
The Parties
 1.
 
Plaintiff Interface IP is a limited liability company duly organized and existing under the laws of California, having its principal place of business in Foster City, California. 2.
 
Upon information and belief, Defendant is a corporation organized and existing under the laws of Delaware, with its principal place of business in Atlanta, Georgia.
Nature of the Action
3.
 
This is a civil action for the infringement of United States Patent No. 7,406,663 (“the ’663 patent”) (or, “the Patent-in-Suit”) under the Patent Laws of the United States 35 U.S.C. § 1
et seq.
 
Jurisdiction and Venue
4.
 
This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338(a) because this action arises under the patent laws of the United
 
States, i5DefendaUpon in patent incontinue61400(b). 7Field Wiand lawf is attach8for infri911 of the ’ by using least claishown bcluding 35 .
 
This t is incorpoormation aringement is to harm In.
 
Venu .
 
On Judth Adjustlly issued d hereto as .
 
Interf gement the.
 
Parag0.
 
Defe663 patent and/or oper m 1 includilow: .S.C. § 27ourt has perated in Deld belief, Den Delaware erface IP in is proper ily 29, 2008,ent For Inpy the UniteExhibit A. ce IP owns eof, includi
Infrin
raphs 1-8 ar dant has dir nder 35 U.ting one or g,
e.g.
, the
et seq
. rsonal jurisaware and cfendant has and elsewh Delaware. this judici
Pa
 the ’663 pat Of Varia States Pat the ’663 pag past infri
gement of
e incorporatectly infrin.C. § 271(amore graphraphical in-2- iction over onducts or committed re in the Ul district pu
ent-in-Suit
tent, titled “le Data Via nt and Trad ent and holgement.
Count .S. Patent
ed by refereed, and con), literally aical input d ut device aDefendant as conductnd/or parti
 
ited States, rsuant to 28 Graphical IA Browser emark Offis the right
No. 7,406,6
nce as if fultinues to dir d/or under vices on its t www.ihg.ecause, amd business iipated in thand has har  U.S.C. §§  put Device Based Dispe (“PTO”). o sue and r 
63
ly restated ectly infrinthe doctrinewebsites thom/hotels/ung other thn Delaware.e commissimed and 391 and With Dynalay,” was d  The ’663 pcover damaerein.
 
e, at least c of equivalet practice as/en/reservngs, . n of ic ly atent ges aim
 
nts, t tion
 
-3- 11.
 
Defendant has indirectly infringed and continues to indirectly infringe the ’663  patent under 35 U.S.C. § 271(b), literally and/or under the doctrine of equivalents, by actively, knowingly, and intentionally inducing infringement of the ’663 patent by others (
e.g.,
 Defendant’s customers, distributors, partners, and/or third parties). 12.
 
Defendant has been aware of the ’663 patent at least since April 8, 2014. 13.
 
Since Defendant has been on notice of the ’663 patent, Defendant has actively, knowingly, and intentionally induced, and continues to actively, knowingly, and intentionally induce, infringement of the ’663 patent by others (
e.g.,
 Defendant’s customers, distributors,  partners, and/or third parties) by using and/or operating one or more graphical input devices on its websites that practice at least claim 1 of the ’663 patent including,
e.g.
, www.ihg.com/hotels/us/en/reservation, knowing of the ’663 patent, knowing that others will use and/or operate its websites in an infringing manner, and knowing and intending to encourage and facilitate those infringing uses and/or operations of its websites through the creation and/or dissemination of promotional and marketing materials, including links to its websites. 14.
 
To date, upon information and belief, Defendant continues the relevant operations of its websites and has not provided its customers and/or users of its websites instructions on how to avoid infringement since Defendant had notice of the ’663 patent. Defendant continues to disseminate the same promotional and marketing materials, including links to its websites, as  before. 15.
 
To date, upon information and belief, Defendant has not produced or relied upon an opinion of counsel related to the ’663 patent. 16.
 
Interface IP has been and continues to be damaged by Defendant’s infringement of the ’663 patent.

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