Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
MAZ Encryption Technologies v. Fujitsu America et. al.

MAZ Encryption Technologies v. Fujitsu America et. al.

Ratings: (0)|Views: 15|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00555-UNA: MAZ Encryption Technologies LLC v. Fujitsu America Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lan2 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00555-UNA: MAZ Encryption Technologies LLC v. Fujitsu America Inc. et. al. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lan2 for more info.

More info:

Published by: PriorSmart on Apr 28, 2014
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

04/28/2014

pdf

text

original

 
1
INTHEUNITEDSTATESDISTRICTCOURTFORTHEDISTRICTOFDELAWARE
MAZ ENCRYPTION TECHNOLOGIES LLC,Plaintiff,v.FUJITSU AMERICA, INC. and FUJITSU LIMITED,Defendants.)))))))))C.A. No. ________________ 
JURYTRIALDEMANDEDCOMPLAINTFORPATENTINFRINGEMENT
This is an action for patent infringement in which Plaintiff MAZ EncryptionTechnologies LLC (“MAZ” or “Plaintiff”) makes the following allegations against DefendantsFujitsu America, Inc. and Fujitsu Limited (collectively, “Defendants”):
BACKGROUND
1. Stephen J. Zizzi is an accomplished electrical engineer and the inventor of UnitedStates Patent No. 8,359,476 (“’476 patentor the “Asserted Patent”). In 1996, Mr. Zizzi andChris Mahne, an entrepreneur and co-inventor on another patent, launched MAZ Technologies,Inc. to develop software security products. Mr. Mahne was the President of MAZ Technologies,Inc., and Mr. Zizzi was the Chief Technology Officer. While at MAZ Technologies, Inc., Mr.Zizzi developed novel technologies relating to electronic information and document securityusing file-level and biometric encryption. The MAZ technology includes, among other things,information security that is transparent and seamless to the users.
PARTIES
2. MAZ is a Delaware limited liability company.
 
23. On information and belief, Defendant Fujitsu America, Inc. is a Californiacorporation with principal office at 1250 East Arques Avenue, Sunnyvale, California 94085-3470. Defendant Fujitsu America, Inc. has appointed C T Corporation System, 818 W. SeventhStreet, 2
nd
Floor, Los Angeles, CA 90017, as its agent for service of process.4. On information and belief, Defendant Fujitsu Limited is a Japanese company with principal office at Shiodome City Center, 1-5-2 Higashi-Shimbashi, Minato-ku, Tokyo 105-7123, Japan. On information and belief, Defendant Fujitsu America, Inc. is a wholly ownedsubsidiary of Defendant Fujitsu Limited.
JURISDICTIONANDVENUE
5. This action arises under the patent laws of the United States, 35 U.S.C. § 1,
 et  seq.
, including § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331and 1338(a).6. This Court has personal jurisdiction over Defendants because, among other reasons, Defendants have done business in this District, have committed and continue to commitacts of patent infringement in this District, and have harmed and continue to harm MAZ in thisDistrict, by, among other things, using, selling, offering for sale, and/or importing infringing products and/or services in this District.7. Venue is proper in this District under 28 U.S.C. §§ 1391(b)-(d) and 1400(b) because, among other reasons, Defendants are subject to personal jurisdiction in this District,have committed and continue to commit acts of patent infringement in this District. For example, on information and belief, Defendants have used, sold, offered for sale, and/or imported infringing products and/or services in this District.
 
3
COUNTIINFRINGEMENTOFU.S.PATENTNO.8,359,476
8. MAZ is the owner by assignment of the 476 Patent, entitled UseAuthentication System And Method For Encryption And Decryption.The application for the‘476 Patent was filed on December 1, 2010. The patent issued on January 22, 2013. A true andcorrect copy of the ‘476 Patent is attached as Exhibit A.9. Defendants have been and now are directly and/or indirectly infringing the ‘476Patent literally and/or through the doctrine of equivalents, in this judicial District and elsewherein the United States, by, among other things, making, using, importing, offering for sale, and/or selling bio-metric computer encryption systems configured to authenticate a user for encryptionor decryption. The infringing products and services include, for example, Defendants’ securitysystem with fingerprint/biometric software and reader (including but not limited to,
 e.g.,
OmniPass), and Defendants’ products and services incorporating the same (including but notlimited to,
 e.g.
, Fujitsu LIFEBOOK Notebook and Tablet with Fingerprint Sensor, e.g. the SSeries, U Series, E Series, P Series, T Series, STYLISTIC Series), and all versions and variationsthereof since the issuance of the ‘476 patent.10. On information and belief, Defendants had actual knowledge of the ‘476 Patent atleast as early as in February 2013, when MAZ filed its complaint against Fujitsu Frontech NorthAmerica Inc. in the Delaware District Court Case No. 13-CV-00301-LPS, asserting the ‘476Patent. Further, on information and belief, Defendants were notified of the ‘476 Patent when thisComplaint was filed.11. MAZ is informed and believes, and thereon alleges, that Defendants havecontributorily infringed and are currently contributorily infringing the ‘476 Patent in violation of 35 U.S.C. § 271(c), by selling or offering for sale to third parties (
e.g.,
 Defendants’ customers),

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->