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Quest Licensing Corporation

Quest Licensing Corporation

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00563-UNA: Quest Licensing Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lanA for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00563-UNA: Quest Licensing Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-lanA for more info.

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Published by: PriorSmart on May 07, 2014
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05/07/2014

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
QUEST LICENSING CORPORATION Plaintiff, v. INTERACTIVE DATA CORPORATION Defendant. Civil Action No.
Jury Trial Demanded COMPLAINT
Plaintiff Quest Licensing Corporation (“Quest” or “Plaintiff”) hereby alleges patent infringement of U.S. Patent No. 7,194,468 (the “‘468 patent”) against Interactive Data Corporation (“IDC”), as follows:
PARTIES
 1.
 
Plaintiff Quest Licensing Corporation is a Delaware corporation with a principal place of  business at 19 Fortune Lane, Jericho, New York 11753. 2.
 
Defendant IDC is a Delaware corporation with its principal place of business at 5 Speen Street, Framingham, Massachusetts 01701 and has appointed Corporation Trust Company as its registered agent for service of process.
JURISDICTION AND VENUE
 3.
 
This action arises under the Patent Laws of the United States, including 35 U.S.C. § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a). 4.
 
On information and belief, IDC regularly transacts business in the District of Delaware. 5.
 
IDC has previously admitted that it transacts business in the District of Delaware.
 
 26.
 
IDC has previously admitted that it is subject to this Court’s specific and general personal  jurisdiction and that the District of Delaware is a proper venue in litigation against it under 28 U.S.C. §§ 1391(b)-(c) and 1400(b). 7.
 
IDC is therefore subject to this Court’s specific and general personal jurisdiction. 8.
 
Venue is proper pursuant to 28 U.S.C. §§ 1391(b)-(c) and 1400(b).
THE ‘468 PATENT
9.
 
Quest is the owner of all rights by assignment of the ‘468 patent, entitled “Apparatus and a Method for Supplying Information,” with the right to pursue claims for infringement. 10.
 
The United States Patent and Trademark office issued the ‘468 patent on March 20, 2007. A true and correct copy of the ‘468 patent is attached to this Complaint as Exhibit A.
CLAIMS FOR RELIEF COUNT I – DIRECT INFRINGEMENT
11.
 
Plaintiff repeats and incorporates by reference paragraphs 1-10 above.
 
12.
 
IDC has infringed and continues to directly infringe the claims of the ‘468 patent, literally or under the doctrine of equivalents, by making, using, selling, and offering for sale  products that are covered by claims of the ‘468 patent, including its QuoTrek and PrimeTerminal Mobile systems and related hardware and software that provide mobile access to real-time financial data.
 
13.
 
IDC has had actual knowledge of the ‘468 patent since at least December 2008, when its subsidiary Interactive Data Managed Solutions Limited entered into an agreement with WorldLink Information Technology Systems, a prior assignee of the ‘468 patent. That agreement specifically references WorldLink’s “patented technology.”
 
 
 314.
 
IDC obtained further knowledge of the ‘468 patent on March 5, 2012, when it received a letter identifying the ‘468 patent and identifying IDC’s QuoTrek product as using one or more claims of the ‘468 patent.
 
15.
 
IDC’s infringement of the ‘468 patent has damaged Plaintiff.
 
16.
 
IDC’s past infringement has been willful. IDC made, used, sold, or offered for sale its infringing systems under an objectively high likelihood of infringement. It either had subjective knowledge that these systems had an objectively high risk of infringing Plaintiff’s patent, or the risk was so obvious it should have known of it.
 COUNT II – CONTRIBUTORY INFRINGEMENT
17.
 
Plaintiff repeats and incorporates by reference paragraphs 1-16 above.
 
18.
 
Users of QuoTrek and PrimeTerminal Mobile directly infringe claims of the ‘468 Patent.
 
19.
 
IDC has indirectly, through contributory infringement, infringed the ‘468 patent within the United States by knowingly or with willful blindness causing others to infringe the ‘468  patent by selling components for use in performing methods claimed in the ‘468 patent, including its QuoTrek and PrimeTerminal Mobile products. 20.
 
These components are a material part of the ‘468 patent’s claimed methods of operating computers to enable communication with information supplying apparatus. IDC’s marketing materials indicate that the QuoTrek mobile application and system enable users to create a “customizable quote window” with “fields [that] can be easily added, removed or changed.” Based on the fields the user inputs, the QuoTrek supplies from its “sophisticated market data” infrastructure “[s]treaming, [r]eal-[t]ime [q]uotes” to the user. Similarly, IDC’s marketing materials indicate that the PrimeTerminal Mobile application and system includes a “user-friendly interface” that “allows for individual customization of display.” The application and

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