IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. ____________________________ NEOMEDIA TECHNOLOGIES, INC., Plaintiff, v. JUST BORN, INC., Defendant. Judge
Jury Trial Demand COMPLAINT
Plaintiff NeoMedia Technologies, Inc. for its Complaint for patent infringement against Defendant Just Born, Inc., alleges as follows:
Plaintiff NeoMedia Technologies, Inc. (“NeoMedia”) is a Delaware corporation with its principal place of business at 1515 Walnut Avenue, Suite 100, Boulder, Colorado 80302 that provides mobile barcode creation and technology solutions including 2-dimensional (“2D”) products and services. 2.
NeoMedia is the owner of record and assignee of a family of related patents (including US Patent Nos. 5,978,773; 6,199,048; 7,383,209; and 7,765,126), which family includes US Patent 8,131,597 (“the ‘597 Patent”) (the “Asserted Patent”). NeoMedia has and has had the exclusive right to enforce and collect damages for infringement of the Asserted Patent during all relevant time periods.