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Gametek v. Playforge et. al.

Gametek v. Playforge et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:12-cv-00502-JAH-NLS: Gametek LLC v. The Playforge, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. John A. Houston presiding. See http://news.priorsmart.com/-l5uD for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:12-cv-00502-JAH-NLS: Gametek LLC v. The Playforge, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. John A. Houston presiding. See http://news.priorsmart.com/-l5uD for more info.

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Published by: PriorSmart on Feb 29, 2012
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02/01/2013

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John J. Edmonds (State Bar No. 274200) jedmonds@cepiplaw.comCOLLINS EDMONDS POGORZELSKISCHLATHER & TOWER, PLLC1851 East First Street, Suite 900Santa Ana, California 92705Telephone: (951) 708-1237Facsimile: (951) 824-7901Attorney for Plaintiff,
GAMETEK LLC
 UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF CALIFORNIAGAMETEK LLC,Plaintiff,v.THE PLAYFORGE, INC. and THEPLAYFORGE, LLC,Defendants.Case No.: ________________
COMPLAINT FOR INFRINGEMNT OFU.S. PATENT NO. 7,076,445DEMAND FOR JURY TRIAL
This is an action for patent infringement in which GAMETEK LLC submits this OriginalComplaint against Defendants named herein, namely THE PLAYFORGE, INC. and THEPLAYFORGE, LLC, as follows:
THE PARTIES
1. GAMETEK LLC (“GAMETEK” or “Plaintiff”) is a California limited liabilitycompany with a place of business at 500 Newport Center Drive, Suite 700, Newport Beach, CA92660.2. On information and belief, PLAYFORGE, INC. is a Nevada Corporation with a placeof business at 1720 S. Amphlett Blvd. Suite 320, San Mateo, CA 94402. Further on information andbelief, THE PLAYFORGE, LLC is a California limited liability company with a place of business at
 
'12
CV0502
NLS
JAH
Case 3:12-cv-00502-JAH-NLS Document 1 Filed 02/28/12 Page 1 of 6
 
 
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1720 S. Amphlett Blvd. Suite 320, San Mateo, CA 94402. THE PLAYFORGE, INC. and THEPLAYFORGE, LLC are collectively referred to as “THE PLAYFORGE” or “Defendants.”
JURISDICTION AND VENUE
3. This action arises under the patent laws of the United States, Title 35 of the UnitedStates Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).4. On information and belief, the Defendants are subject to this Court’s specific and/orgeneral personal jurisdiction, pursuant to due process and/or the California Long Arm Statute, due atleast to its substantial business in California, including related to the infringements alleged herein.Further, on information and belief, Defendants have interactive games comprising infringingmethods which are at least used in and/or accessible in California. Further, on information andbelief, Defendants regularly conduct and/or solicits business, engage in other persistent courses of conduct, and/or derives substantial revenue from goods and services provided to persons and/orentities in California.5. Venue is proper in this district under 28 U.S.C. §§ 1391(b), 1391(c) and 1400(b).Without limitation, on information and belief, Defendants are subject to personal jurisdiction in thisdistrict. On information and belief, Defendants are subject to this Court’s specific and/or generalpersonal jurisdiction, pursuant to due process and/or the California Long Arm Statute, due at least toits substantial business in this district, including related to the infringements alleged herein. Further,on information and belief, Defendants have interactive games comprising infringing methods whichare at least used in and/or accessible in this district. Further, on information and belief, Defendantsregularly conducts and/or solicits business, engages in other persistent courses of conduct, and/orderives substantial revenue from goods and services provided to persons and/or entities in thisdistrict.
Case 3:12-cv-00502-JAH-NLS Document 1 Filed 02/28/12 Page 2 of 6
 
 
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COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,076,445
6. United States Patent No. 7,076,445 (“the ‘445 patent”), entitled “SYSTEM ANDMETHODS FOR OBTAINING ADVANTAGES AND TRANSACTING THE SAME IN ACOMPUTER GAMING ENVIRONMENT,” issued on July 11, 2006.7. GAMETEK is the present assignee of the entire right, title and interest in and to the‘445 patent, including all rights to sue for past and present infringement. Accordingly, GAMETEKhas standing to bring this lawsuit for infringement of the ‘445 patent.8. The various claims of the ‘445 patent cover, inter alia, a method of managing a gamecomprising displaying a plurality of game objects, determining if the user has sufficientconsideration to purchase a game object, presenting an offer to purchase the game object dependentupon parameters comprising the tracked activity of the user and the indication that the user hassufficient consideration, permitting the user to purchase the game object without interrupting thegame, supplying the purchased game object to the user without interrupting the game, andincorporating the game object into the game.9. On information and belief, THE PLAYFORGE has been and now is infringing the‘445 patent by actions comprising the making and/or using methods of managing games comprisingdisplaying a plurality of game objects, determining if the user has sufficient consideration topurchase a game object, presenting an offer to purchase the game object dependent upon parameterscomprising the tracked activity of the user and the indication that the user has sufficientconsideration, permitting the user to purchase the game object without interrupting the game,supplying the purchased game object to the user without interrupting the game, and incorporatingthe game object into the game. On information and belief, such methods comprise Zombie Farm.
Case 3:12-cv-00502-JAH-NLS Document 1 Filed 02/28/12 Page 3 of 6

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