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Uniloc et. al. v. MeridianEMR et. al.

Uniloc et. al. v. MeridianEMR et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:14-cv-00629: Uniloc USA, Inc. et. al. v. MeridianEMR, Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-laK2 for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:14-cv-00629: Uniloc USA, Inc. et. al. v. MeridianEMR, Inc. et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-laK2 for more info.

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Published by: PriorSmart on Jul 20, 2014
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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION
UNILOC USA, INC. and UNILOC LUXEMBOURG S.A., Plaintiffs, V MERIDIANEMR, INC., HEALTHTRONICS, INC., ENDO HEALTH SOLUTIONS INC., and ALTARIS CAPITAL PARTNERS, LLC, Defendants. § § § § § § § § § § § § CIVIL ACTION NO. 6:14-cv-
JURY TRIAL DEMANDED PLAINTIFFS’ ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs Uniloc USA, Inc. (“Uniloc USA”) and Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) (collectively, “Uniloc”) file this Original Complaint against meridianEMR, Inc., HealthTronics, Inc., Endo Health Solutions, Inc., and Altaris Capital Partners, LLC for infringement of U.S. Patent Nos. 5,682,526 (“the ’526 patent”) and 5,715,451 (“the ’451  patent”).
THE PARTIES
1.
 
Uniloc USA, Inc. (“Uniloc USA”) is a Texas corporation with its principal place of business at Legacy Town Center I, Suite 380, 7160 Dallas Parkway, Plano, Texas 75024. Uniloc USA also maintains a place of business at 102 N. College, Ste. 806, Tyler, Texas 75702. 2.
 
Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) is a Luxembourg public limited liability company, with its principal place of business at 15, Rue Edward Steichen, 4th Floor, L-2540, Luxembourg (R.C.S. Luxembourg B159161).
 
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3.
 
Uniloc Luxembourg and Uniloc USA are collectively referred to as “Uniloc.” Uniloc has researched, developed, manufactured, and licensed information security technology solutions, platforms and frameworks, including solutions for securing software applications and digital content. Uniloc owns and has been awarded a number of patents. Uniloc’s technologies enable, for example, software and content publishers to securely distribute and sell their high-value technology assets with maximum profit to its customers and/or minimum burden to legitimate end-users. Uniloc’s technologies are used in several markets including, for example, electronic health record software, software and game security, identity management, intellectual  property rights management, and critical infrastructure security. 4.
 
meridianEMR, Inc. (“meridianEMR”) is a subsidiary of HealthTronics, Inc. and has its principal place of business at 354 Eisenhower Parkway, Livingston, New Jersey, 07039. meridianEMR may be served with process through its Chief Executive Officer, Michael J. Custode at 354 Eisenhower Parkway, Livingston, New Jersey, 07039. meridianEMR maintains or in the relevant time period maintained a business address at 9825 Spectrum Drive, Building 3, Austin, Texas 78717. Upon information and belief, meridianEMR does business in the State of Texas and in the Eastern District of Texas. 5.
 
HealthTronics, Inc. (“HealthTronics”) is a Georgia corporation with its principal  place of business at 100 Endo Boulevard, Chadds Ford, Pennsylvania. HealthTronics may be served with process through its registered agent, CT Corporation System, 1201 Peachtree Street,  NE, Atlanta, Georgia 30361. HealthTronics may also be served with process through its Texas registered agent, CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201. Upon information and belief, HealthTronics does business in the State of Texas and in the Eastern District of Texas. HealthTronics’ business in the State of Texas is evidenced in part by its maintenance of a registered agent in Texas.
 
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6.
 
Endo Health Solutions Inc. (“Endo Health”) is a Delaware corporation with its  principal place of business at 1400 Atwater Drive, Malvern, Pennsylvania 19355. Endo Health may be served with process through its registered agent, The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801. Upon information and belief, Endo Health does business in the State of Texas and in the Eastern District of Texas. 7.
 
Altaris Capital Partners, LLC (“Altaris Capital”) is a Delaware limited liability company with its principal place of business at 600 Lexington Avenue, 11
th
 Floor, New York,  New York 10022. Altaris Capital may be served with process through its registered agent,  National Registered Agents, Inc., 160 Greentree Drive, Suite 101, Dover, Delaware 19904. Upon information and belief, Altaris Capital does business in the State of Texas and in the Eastern District of Texas through its 2014 acquisition of HealthTronics.
JURISDICTION AND VENUE
8.
 
Uniloc brings this action for patent infringement under the patent laws of the United States, namely 35 U.S.C. §§ 271, 281, and 284-285, among others. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a), and 1367. 9.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(c) and 1400(b). On information and belief, Defendants are deemed to reside in this judicial district, have committed acts of infringement in this judicial district, have purposely transacted business involving their accused products in this judicial district and/or, have regular and established  places of business in this judicial district. 10.
 
Defendants are subject to this Court’s personal jurisdiction pursuant to due  process and/or the Texas Long Arm Statute, due at least to their substantial business in this State and judicial district, including: (A) at least part of their infringing activities alleged herein; and

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