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
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Certified Measurement v. Centerpoint Energy Houston Electric Et. Al.

Certified Measurement v. Centerpoint Energy Houston Electric Et. Al.

Ratings: (0)|Views: 69|Likes:
Published by PatentBlast
Certified Measurement v. Centerpoint Energy Houston Electric et. al.
Certified Measurement v. Centerpoint Energy Houston Electric et. al.

More info:

Published by: PatentBlast on May 16, 2014
Copyright:Traditional Copyright: All rights reserved

Availability:

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

06/26/2014

pdf

text

original

 
 
IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
CERTIFIED MEASUREMENT, LLC, Plaintiff, v. CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC, and ITRON, INC. Defendants. § § § § § § § § § § Civil Action No. 2:14-cv-627
JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Certified Measurement,
LLC (“Plaintiff” or “
Certified Measurement
”) files this
Complaint for Patent Infringement against Defendants CenterPoint Energy Houston Electric, LLC
(“CenterPoint”)
 and Itr 
on, Inc. (“Itron”), and alleges as follows:
 
PARTIES
1.
 
Plaintiff Certified Measurement, LLC is a limited liability company organized under the laws of the State of Delaware, and having its principal place of business at Two High Ridge Park, Stamford, Connecticut 06905. 2.
 
Upon information and belief, Defendant CenterPoint Energy Houston Electric, LLC is a limited liability company organized under the laws of the State of Texas, and having its  principal place of business at 1111 Louisiana Street, Houston, Texas 77002. 3.
 
Upon information and belief, Defendant Itron, Inc. is a corporation organized under the laws of the State of Washington and having its principal place of business at 2111 N Molter Road, Liberty Lake, Washington 99019.
 
 
2
JURISDICTION AND VENUE
4.
 
This is a patent infringement action arising under the patent laws of the United States, 35 U.S.C. §101,
et seq
. 5.
 
This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338. 6.
 
CenterPoint is incorporated in the State of Texas, has conducted and continues to conduct extensive business within the State of Texas, including the Eastern District of Texas. CenterPoint, directly or through intermediaries, ships, distributes, offers for sale, sells, uses, and/or advertises products that infringe the patent claims involved in this action in the State of Texas. 7.
 
Itron has conducted and continues to conduct business within the State of Texas, including the Eastern District of Texas. Itron, directly or through intermediaries, ships, distributes, offers for sale, sells, and/or advertises products that infringe the patent claims involved in this action in the State of Texas. 8.
 
This Court has personal jurisdiction over CenterPoint and Itron. 9.
 
Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) and/or 1400(b)  because each of the Defendants conducts business and is subject to personal jurisdiction in the Eastern District of Texas. 10.
 
Joinder of the Defendants is proper pursuant to 35 U.S.C. § 299(a) because the Defendants make, use, offer for sale, sale, and/or import common products that infringe the  patent claims involved in this action, including, but not limited to, the Itron OpenWay Centron meters and Itron OpenWay architecture.
 
 
3
THE PATENTS-IN-SUIT
11.
 
On October 27, 1998, the U.S. Patent and Trademark Office duly and legally issued
United States Patent No. 5,828,751 (“the ’
751 p
atent”) entitled “Method and Apparatus for Secure Measurement Certification”
 to Jay S. Walker, Bruce Schneier, and James A. Jorash. Certified Measurement
is the owner by assignment of the
751 patent. 12.
 
The ’751 p
atent is valid and enforceable. A tru
e and correct copy of the ’
751  patent is attached hereto as Exhibit A. 13.
 
On August 28, 2001, the U.S. Patent and Trademark Office duly and legally issued United States Patent No.
6,282,648 (“the ’648
 p
atent”) entitled “Method and Apparatus for Secure Measurement Certification” to Jay S. Walker, Bruce Schneier, and James A. Jorash.
Certified Measurement
is the owner by assignment of the ’648
 patent. 14.
 
The
’648
 patent is valid and enforceable.
A true and correct copy of the ’648
  patent is attached hereto as Exhibit B. 15.
 
On September 11, 2001, the U.S. Patent and Trademark Office duly and legally
issued United States Patent No. 6,289,453 (“the ’453
 p
atent”) entitled “Method and Apparatus for Secure Measurement Certification” to Jay S. Walker, Bruce Schneier, and James A. Jorash.
Certified Measurement
is the owner by assignment of the ’453
 patent. 16.
 
The ’453
 patent is valid and enforceable. A true and correct
copy of the ’453
 patent is attached hereto as Exhibit C. 17.
 
On October 1, 2013, the U.S. Patent and Trademark Office duly and legally
issued United States Patent No. 8,549,310 (“the ’310 patent”) entitled “Method and Apparatus
for Secure Measurement Certifica
tion” to Jay S. Walker, Bruce Schneier, and James A. Jorash. Certified Measurement is the owner by assignment of the ’310 patent.

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)//-->