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Golden Hour Data Systems v. Reach Air Medical Services

Golden Hour Data Systems v. Reach Air Medical Services

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Golden Hour Data Systems, Inc. v. Reach Air Medical Services, LLC. Filed in U.S. District Court for the Southern District of California, no judge yet assigned. See http://news.priorsmart.com/-lani for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Golden Hour Data Systems, Inc. v. Reach Air Medical Services, LLC. Filed in U.S. District Court for the Southern District of California, no judge yet assigned. See http://news.priorsmart.com/-lani for more info.

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Published by: PriorSmart on Apr 28, 2014
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04/28/2014

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
COMPLAINT FOR PATENT INTINGEMENT
Guillermo Cabrera (SBN 190303)
The Cabrera Firm, APC
600 West Broadway, Suite 700 San Diego, CA 92101 v. 619.500.4880 f. 619.785.3380 E-mail: gil@cabrerafirm.com Manuel de la Cerra (SBN 189313)
The Law Office of Manuel de la Cerra
6885 Catamaran Drive Carlsbad, CA 92011 v. 760.809.5520 f: 760.269.3542 E-mail: manny@delacerralaw.com Attorneys for Plaintiff GOLDEN HOUR DATA SYSTEMS, INC. UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA SAN DIEGO DIVISION GOLDEN HOUR DATA SYSTEMS, INC., a California Corporation, Plaintiff, v. REACH AIR MEDICAL SERVICES, LLC, a California Limited Liability Company, Defendant.
COMPLAINT FOR PATENT INFRINGEMENT OF U.S.PAT. NOS. 6,117,073, 7,668,736; & 7,734,481. DEMAND FOR JURY TRIAL
Plaintiff Golden Hour Data Systems, Inc. hereby complains of Defendant REACH AIR MEDICAL SERVICES, LLC (REACH) for infringement of United States Patent Nos. 6,117,073 (‘073 Patent), 7,668,736 (‘736 Patent), and 7,734,481 (‘481 Patent; collectively the Patents-In-Suit), and alleges as follows:
PARTIES
1.
 
Plaintiff Golden Hour Data Systems, Inc. is a California corporation with a  principal place of business at 10052 Mesa Ridge Ct #200, San Diego, CA 92121
'14
CV1059
 JMA
JAH
 
 
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2
COMPLAINT FOR PATENT INTINGEMENT
2.
 
Plaintiff is informed and believes, and on that basis alleges, that Defendant REACH is a California Limited Liability Company with a principal place of business at 451 Aviation Blvd. Ste. 101, Santa Rosa, CA 95403. 3.
 
Plaintiff is informed and believes, and on that basis alleges, that Defendant REACH does business in this judicial district and has committed acts of infringement in this  judicial district.
JURISDICTION AND VENUE
4.
 
This Court has personal jurisdiction over REACH under Fed. R. Civ. P. 4(k)(1)(A) and California’s long-arm statute, Cal. Civ. Proc. Code § 410.10, as REACH has continuous  business contacts with the State of California, has a business presence in the State of California and has committed the complained-of acts in the State of California, thereby causing damage to Plaintiff in this judicial district. 5.
 
This Court has subject matter jurisdiction pursuant to the patent laws of the United States, 35 U.S.C. §§ 1 et seq., and pursuant to 28 U.S.C. § 1331 and 28 U.S.C. §1338(a). 6.
 
Venue is proper in this district under 28 U.S.C. § 1400(b) because REACH resides in this judicial district as defined by 28 U.S.C. § 1391. 7.
 
Plaintiff is informed and believes, and on that basis alleges, that REACH has operated, and continues to operate, a base of operations from 1111 Airport Road, Imperial CA 92251, located in this judicial district. (
See
 Exhibit A, which is a true and correct copy of a screenshot from REACH’s website at <http://www.reachair.com/purpose/pdfs/R9.pdf > illustrating the areas of business REACH covers.) This contact is systematic and continuous and supports a finding of personal jurisdiction and venue in this district.
BACKGROUND FACTS
 8.
 
On September 12, 2000, United States Patent No. 6,117,073 entitled “Integrated Emergency Medical Transportation Database System” was duly and legally issued to Scott Jones, and Kevin Hutton. A true copy of the ‘073 Patent is attached hereto as Exhibit B. 9.
 
Plaintiff Golden Hour Data Systems, Inc. is the owner by assignment of the ‘073 Patent with full and exclusive right to bring suit to enforce this patent. The assignment has been
 
 
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3
COMPLAINT FOR PATENT INTINGEMENT
recorded with the USPTO and can be found at reel/frame 014523/0082. 10.
 
The ‘073 Patent relates generally to “an integrated medical database system for [] emergency medical transportation.”
See
 ‘073 Patent at Abstract. 11.
 
On February 23, 2010, United States Patent No. 7,668,736 entitled “Integrated Emergency Medical Transportation Database and Virtual Private Network System” was duly and legally issued to Scott Jones, Rany Polany and Kevin Hutton. A true copy of the ‘736 Patent is attached hereto as Exhibit C. 12.
 
Plaintiff Golden Hour Data Systems, Inc. is the owner by assignment of the ‘736 Patent with full and exclusive right to bring suit to enforce this patent. The assignment has been recorded with the USPTO and can be found at reel/frame 014524/0244. 13.
 
The ‘736 Patent relates generally to a “system and method for providing secure data communications and user access authorization for an integrated emergency medical transportation database.”
See
 ‘736 Patent at Abstract. 14.
 
On June 8, 2010, United States Patent No. 7,734,481 entitled “Compliance Audit For Integrated Emergency Medical Transportation Database System” was duly and legally issued to Kevin Hutton, and Scott Jones. A true copy of the ‘481 Patent is attached hereto as Exhibit D. 15.
 
Plaintiff Golden Hour Data Systems, Inc. is the owner by assignment of the ‘481 Patent with full and exclusive right to bring suit to enforce this patent. The assignment has been recorded with the USPTO and can be found at reel/frame 014527/0040. 16.
 
The ‘481 Patent relates generally to “an integrated medical database system for [] emergency medical transportation.”
See
 ‘481 Patent at Abstract. 17.
 
REACH is an air ambulance service company serving several large regions of California. REACH uses integrated dispatch, clinical and billing when providing its air ambulance services and billing both payors and patients for those services. 18.
 
REACH has been and is infringing and/or inducing others to infringe the Patents-In-Suit, by making, and using emergency medical management, reporting and billing software that is covered by one or more claims of the Patents-In-Suit. REACH’s acts of infringement have occurred within this district and elsewhere throughout the United States.

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