Walker Digital V Google

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WALKER DIGITAL, LLC
Plaintiff,
v. Civil Action No. ___________
GOOGLE INC. JURY TRIAL DEMANDED
Defendant.
COMPLAINT FOR PATENT INFRINGEMENT
1. Plaintiff Walker Digital, LLC, (“Walker Digital”) files this complaint for patent
infringement against defendant Google Inc.
THE PARTIES
2. Walker Digital is a Delaware limited liability company with its principal place of
business located at 2 High Ridge Park, Stamford, CT 06905. Walker Digital is a world-
renowned research and development laboratory responsible for launching several successful
businesses, including Priceline.com and Synapse, Inc.
3. On information and belief, defendant Google Inc. (“Google”) is a Delaware
corporation with its corporate headquarters and principal place of business at 1600 Amphitheater
Parkway, Mountain View, California, 94043.
JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, Title 35 of the
United States Code. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and
1338(a).
5. On information and belief, Google is subject to this Court’s jurisdiction because
Google has transacted business in this district, including, more specifically, directly and/or
through intermediaries, making, using, importing, offering for sale and/or selling products and
services in the State of Delaware (including via the provision of such goods and services over the
Internet). Google, upon information and belief, is doing substantial business in this District, and
has committed acts of patent infringement in this District. In addition, Google is a corporation
organized and existing under the laws of the State of Delaware.
6. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and (c), and 1400(b).
THE ASSERTED PATENTS
7. On June 19, 2001, the United States Patent and Trademark Office (“USPTO”)
duly and legally issued U.S. Patent No. 6,249,772 (the “‘772 patent”), entitled “Systems And
Methods Wherein A Buyer Purchases A Product At A First Price And Acquires The Product
From A Merchant That Offers The Product For Sale At A Second Price” to Jay S. Walker, James
A. Jorasch, and Andrew S. Van Luchene, who assigned their rights and interests in the ‘772
patent to Walker Digital. A true and correct copy of the ‘772 patent is attached as Exhibit A.
8. On June 22, 2004, the USPTO duly and legally issued U.S. Patent No. 6,754,636
(the “‘636 patent”), entitled “Purchasing Systems And Methods Wherein A Buyer Takes
Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.
Walker, Andrew S. Van Luchene, Magdalena Mik, and Daniel E. Tedesco, who assigned their
rights and interests in the ‘636 patent to Walker Digital. A true and correct copy of the ‘636
patent is attached as Exhibit B.
9. On May 2, 2006, the USPTO duly and legally issued U.S. Patent No. 7,039,603
(the “‘603 patent”), entitled “Settlement Systems And Methods Wherein A Buyer Takes
Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.
Walker, Jonothan Otto, Andrew S. Van Luchene, Magdalena Mik, Daniel E. Tedesco, and Ian
-2-
Levitan, who assigned their rights and interests in the ‘603 patent to Walker Digital. A true and
correct copy of the ‘603 patent is attached as Exhibit C.
10. On March 30, 2010, the USPTO duly and legally issued U.S. Patent No.
7,689,468 (the “‘468 patent”), entitled “Purchasing, Redemption And Settlement Systems And
Methods Wherein A Buyer Takes Possession At A Retailer Of A Product Purchased Using A
Communication Network,” to Jay S. Walker, Andrew S. Van Luchne, Magdalena M. Fincham,
and Daniel E. Tedesco, who assigned their rights and interests in the ‘468 patent to Walker
Digital. A true and correct copy of the ‘468 patent is attached as Exhibit D.
11. Walker Digital is the owner of the ‘772, ‘636, ‘603 and ‘468 patents (collectively,
the “Asserted Patents”).
FACTUAL BACKGROUND
12. Walker Digital is a research and development laboratory that has invested many
millions of dollars in its intellectual property. Walker Digital is comprised of a diverse group of
inventors who solve business problems by analyzing human behavior and designing innovative
solutions incorporating modern information technologies. The novel inventions developed by
the Walker Digital team are reflected in a portfolio of more than 200 U.S. and international
patents in a wide range of industries that includes retail, vending, credit cards, security, gaming,
educational testing, and entertainment.
13. Jay S. Walker, the chairman of Walker Digital, is a named inventor of more than
450 issued and pending U.S. and international patents, including each of the Asserted Patents.
Mr. Walker is best known as the founder of Priceline.com, which revolutionized the travel
industry through unprecedented technology, with the end result of bringing huge savings in
airfare, hotel and car rental rates, and other travel related goods and services to every-day
-3-
consumers. The systems at the heart of Priceline.com’s success were developed in the research
and development laboratory of Walker Digital.
14. Development of the inventions conceived by Mr. Walker and the Walker Digital
team of inventors would not have been possible without substantial financial investments made
by Walker Digital. Funds invested by Walker Digital have been used for many things, including
the construction of laboratory facilities utilized to develop and test new inventions. Many of the
inventions developed at the Walker Digital laboratories have led to successful businesses,
including Priceline.com and Synapse, Inc. Revolutionary technologies, including the systems
and methods for purchasing a product online at a first price and acquiring the product from a
merchant that offers the product for sale at a second price, as described and claimed in the
Asserted Patents, were a direct result of investments made by Walker Digital.
15. The Asserted Patents represent breakthroughs in the field of electronic commerce.
COUNT I
(Infringement of the ‘772)
16. Walker Digital incorporates and realleges the allegations of paragraphs 1-15 as
are fully set forth above.
17. Upon information and belief, Google is infringing (literally and/or under the
doctrine of equivalents) the ‘772 patent in this District and throughout the United States by,
among other things, making, using, importing, offering for sale and/or selling products and
services on its Google Offers website located at https://www.google.com/offers, which practices
one or more of the claims of the ‘772 patent. For instance, upon information and belief, Google
offers buyers products and services from retailers at discounted prices and arranges for users to
take possession of the goods or services at the retailers’ locations. An sample of a Google
offering is provided below:

-4-
18. Google committed its acts of infringement without license or authorization.
19. As a result of Google’s infringement of the ‘772 patent, Walker Digital has
suffered monetary damages in an amount not yet determined, and will continue to suffer
damages in the future unless Google’s infringing activities are enjoined by this Court.
20. Walker Digital has suffered and will continue to suffer severe and irreparable
harm unless this Court issues a permanent injunction prohibiting Google, its agents, servants,
employees, representatives, and all others acting in active concert therewith from infringing the
‘772 patent.
COUNT II
(Infringement of the ‘636 Patent)
-5-
one or more of the claims of the ‘636 patent.
‘636 patent.
COUNT III
services on Google Offers website located at https://www.google.com/offers, which practices

-6-
‘603 patent.
COUNT IV
-7-
‘468 patent.
DEMAND FOR JURY TRIAL
Plaintiff Walker Digital, under Rule 38 of the Federal Rules of Civil Procedure, requests
a trial by jury of any issues so triable by right.
PRAYER FOR RELIEF
For the above reasons, Walker Digital respectfully requests that this Court grant the
following relief in favor of Walker Digital and against Google:
(a) A judgment in favor of Walker Digital that Google has directly infringed (either
literally or under the doctrine of equivalents) one or more claims of each of the Asserted Patents;
(b) A permanent injunction enjoining Google and its officers, directors, agents,
servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in
active concert or participation with them, from infringing each of the Asserted Patents;
(c) A judgment and order requiring Google to pay Walker Digital its damages, costs,
expenses, and pre-judgment and post-judgment interest for Google’s infringement of each of the
Asserted Patents;
(d) A judgment and order requiring Google to provide an accounting and to pay
supplemental damages to Walker Digital, including, without limitation, pre-judgment interest;
(e) A judgment and order finding that this is an exceptional case within the meaning
of 35 U.S.C. § 285 and awarding Walker Digital its reasonable attorneys’ fees; and
(f) Any and all such other relief as the Court deems just and proper.
-8-
April 21, 2011 BAYARD, P.A.
/s/ Richard D. Kirk

Of Counsel: Richard D. Kirk (rk0922)
Stephen B. Brauerman (sb4952)
Marc A. Fenster 222 Delaware Avenue, Suite 900
California Bar No. 181067 P.O. Box 25130
Wilmington, DE 19899
RUSS, AUGUST & KABAT
rkirk@bayardlaw.com
12424 Wilshire Boulevard 12th Floor sbrauerman@bayardlaw.com
Los Angeles, California 90025 (302) 655-5000
Telephone: 310/826-7474
Facsimile: 310/826-6991 Attorneys for Plaintiff Walker Digital, LLC
mfenster@raklaw.com
-9-
CIVIL COVER SHEET
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the
use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
I.(a) PLAINTIFF DEFENDANTS
WALKER DIGITAL, LLC GOOGLE, INC.
(b) County Of Residence Of First Listed Plaintiff Fairfield County, Connecticut County Of Residence Of First Listed Defendant New Castle County, Delaware
(c) Attorneys (Firm Name, Address And Telephone Number) Attorneys (If Known)
Richard D. Kirk (No. 0922)

Stephen Brauerman (No. 4952)
Bayard, P.A.
222 Delaware Avenue, Suite 900
Wilmington, DE 19899-5130
(302) 655-5000
II. BASIS OF JURISDICTION (PLACE AN "X" IN ONE BOX III.CITIZENSHIP OF PRINCIPAL PARTIES (Place An 'X' In One Box For Plaintiff
ONLY) And One Box For Defendant)
(For Diversity Cases Only)
PTF DEF PTF DEF
1 U.S. Government 3 Federal Question Incorporated or Principal Place

Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 of Business in this State 4 4
Incorporated and Principal Place
2 U.S. Government 4 Diversity Citizen of Another State 2 2 5 5
of Business in Another State
Defendant (Indicate Citizenship of Parties Citizen or Subject of a 3 3 Foreign Nation 6 6
in Item III) Foreign Country
IV. NATURE OF SUIT PLACE AN "X" IN ONE BOX ONLY)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 610 Agriculture 422 Appeal 28 USC 158 400 State Reapportionment
120 Marine 310 Airplane 362 Personal Injury 620 Other Food & Drug 423 Withdrawal 410 Antitrust
130 Miller Act 315 Airplane Product Med. Malpractice 625 Drug Related Seizure 28 USC 157 420 Banks and Banking
140 Negotiable Instrument Liability 365 Personal Injury of Property 21 USC 881 450 Commerce/ICC Rates/etc.
320 Assault, Libel & Product Liability 630 Liquor Laws PROPERTY RIGHTS
150 Recovery of Overpayment 460 Deportation
& Enforcement of Judgment Slander 368 Asbestos Personal 640 RR & Truck 820 Copyrights 470 Racketeer Influenced and
330 Federal Employers’ Injury Product Liability
151 Medicare Act 650 Airline Regs 830 Patent Corrupt Organizations
Liability PERSONAL PROPERTY
152 Recovery of Defaulted 660 Occupational 840 Trademark 810 Selective Service
340 Marine 370 Other Fraud
Student Loans Safety/Health 850 Securities/Commodities/
(Excl. Veterans) 345 Marine Product 371 Truth in Lending
690 Other Exchange
153 Recovery of Overpayment Liability 380 Other Personal
LABOR SOCIAL SECURITY 875 Customer Challenge
of Veteran’s Benefits 350 Motor Vehicle Property Damage
12 USC 3410
160 Stockholders’ Suits 355 Motor Vehicle 385 Property Damage 710 Fair Labor Standards 861 HIA (1395ff)
891 Agricultural Acts
Product Liability Product Liability Act 862 Black Lung (923)
190 Other Contract 892 Economic Stabilization Act
360 Other Personal Injury 720 Labor/Mgmt Relations 863 DIWC/DIWW
195 Contract Property Liability 893 Environmental Matters
730 Labor/Mgmt Reporting (405(g))
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS & Disclosure Act 894 Energy Allocation Act
864 SSID Title XVI
740 Railway Labor Act 895 Freedom of I
210 Land Condemnation 441 Voting 510 Motions to Vacate 865 RSI (405(g)
Information Act
220 Foreclosure 442 Employment Sentence 790 Other Labor Litigation
HABEUS CORPUS: FEDERAL TAX SUITS 900 Appeal of Fee Determination
230 Rent Lease & Ejectment 443 Housing/ 791 Empl Ref Inc
Under Equal Access to
240 Torts to Land Accommodations 530 General Security Act 870 Taxes (U.S. Plaintiff
Justice
245 Tort Product Liability 444 Welfare 535 Death Penalty or Defendant)
950 Constitutionality of
290 All Other Real Property 440 Other Civil Rights 540 Mandamus & Other State Statutes
550 Civil Rights 871 IRS Third Party
890 Other Statutory Actions
555 Prison Condition 26 USC 7609
V. ORIGIN Appeal to
District
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 7 Judge from
Proceeding State Court State Court Reopened another district Litigation Magistrate
(specify) Judgment
VI. CAUSE OF ACTION (Cite The U.S. Civil Statute Under Which You Are Filing And Write Brief Statement Of Cause.
Do Not Cite Jurisdictional Statutes Unless Diversity)
Action for patent infringement under 35 U.S.C. § 101, et seq. injunctive and declaratory relief and for damages for patent infringement
CHECK IF THIS IS A CLASS
VII. REQUESTED IN DEMAND $ CHECK YES only if demanded in complaint
ACTION
COMPLAINT JURY DEMAND: YES NO
UNDER F.R.C..P. 23
VIII. RELATEDCASE(S) (See instructions) JUDGE DOCKET
Sue L. Robinson NUMBERS 11-317-SLR
DATE SIGNATURE OF ATTORNEY OF RECORD
APRIL 21, 2011 /S/ RICHARD D. KIRK (RK0922)

FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

AO 120 (Rev. 08/10)
Mail Stop 8 REPORT ON THE

TO:
Director of the U.S. Patent and Trademark Office FILING OR DETERMINATION OF AN
P.O. Box 1450 ACTION REGARDING A PATENT OR
Alexandria, VA 22313-1450 TRADEMARK
In Compliance with 35 U.S.C. § 290 and/or 15 U.S.C. § 1116 you are hereby advised that a court action has been
filed in the U.S. District Court for the District of Delaware on the following
G Trademarks or G
✔ Patents. ( G the patent action involves 35 U.S.C. § 292.):
DOCKET NO. DATE FILED U.S. DISTRICT COURT

4/21/2011 for the District of Delaware
PLAINTIFF DEFENDANT
Walker Digital, LLC Google, Inc.
PATENT OR DATE OF PATENT

HOLDER OF PATENT OR TRADEMARK
TRADEMARK NO. OR TRADEMARK
1 6,249,772 6/19/2001 Walker Digital, LLC
In the above—entitled case, the following patent(s)/ trademark(s) have been included:
DATE INCLUDED INCLUDED BY
G
Amendment G Answer G Cross Bill G Other Pleading
PATENT OR DATE OF PATENT
HOLDER OF PATENT OR TRADEMARK
TRADEMARK NO. OR TRADEMARK
1
In the above—entitled case, the following decision has been rendered or judgement issued:
DECISION/JUDGEMENT
CLERK (BY) DEPUTY CLERK DATE
Copy 1—Upon initiation of action, mail this copy to Director Copy 3—Upon termination of action, mail this copy to Director
Copy 2—Upon filing document adding patent(s), mail this copy to Director Copy 4—Case file copy
AO 440 (Rev. 12/09) Summons in a Civil Action
United States District Court

for the
District of Delaware
WALKER DIGITAL, LLC

Plaintiff,
v. Civil Action No.
GOOGLE, INC., TRIAL BY JURY DEMANDED

Defendant.
Summons in a Civil Action
To: Google, Inc.

c/o The Corporation Trust Company
1209 Orange Street
Wilmington, DE 19801
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received
it) — or 60 days if you are the United States or a United States agency, or an officer or employee
of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the
plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of
Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Richard D. Kirk
Stephen B. Brauerman
Bayard, P.A.
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
302-655-5000 (phone)
302-658-6395 (fax)
If you fail to respond, judgment by default will be entered against you for the relief demanded in
the complaint. You also must file your answer or motion with the court.
DATE DEPUTY CLERK’S SIGNATURE

AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4(1))
This summons for (name of individual and title, if any) ______________________________________

was received by me on (date) _________________.
 I personally served the summons on the individual at (place) __________________________

___________________________________________________ on (date) _______________________; or
 I left the summons at the individual’s residence or usual place of abode with (name) ___
_________________________________________________________, a person of suitable age and
discretion who resides there, on (date) ____________________, and mailed a copy to the
individual’s last known address; or
 I served the summons on (name of individual) ___________________________________, who is

designated by law to accept service of process on behalf of (name of organization)
_______________________________________________ on (date) ______________________; or
 I returned the summons unexecuted because _______________________________; or
 Other (specify):
My fees are $ ________ for travel and $ ________ for services, for a total of $ ________.
I declare under penalty of perjury that this information is true.
Date: ___________________ ____________________________________

Server’s signature
____________________________________
Printed name and title
____________________________________
Server’s address
Additional information regarding attempted service, etc:

Complaints
1:99-mc-09999 Plaintiff(s) v. Defendant(s)
U.S. District Court
District of Delaware
Notice of Electronic Filing
The following transaction was entered by Kirk, Richard on 4/21/2011 at 11:46 PM EDT and filed on 4/21/2011
Case Name: Plaintiff(s) v. Defendant(s)
Case Number: 1:99-mc-09999
Filer:
Document Number: 175
Docket Text:
COMPLAINT - Walker Digital, LLC v. Google, Inc.. Filing fee $ 350, receipt number 0311-879254.
(Attachments: # (1) Exhibit A (Part I), # (2) Exhibit A (Part II), # (3) Exhibit B (Part I), # (4) Exhibit B
(Part II), # (5) Exhibit B (Part III), # (6) Exhibit C (Part I), # (7) Exhibit C (Part II), # (8) Exhibit C (Part
III), # (9) Exhibit D (Part I), # (10) Exhibit D (Part II), # (11) Exhibit D (Part III), # (12) Exhibit D (Part
IV), # (13) Exhibit D (Part V), # (14) Exhibit D (Part VI), # (15) Exhibit D (Part VII), # (16) Exhibit D
(Part VIII), # (17) Civil Cover Sheet, # (18) Patent/Trademark Report, # (19) Summons Forms -
Unsigned Google, Inc.)(Kirk, Richard)
1:99-mc-09999 Notice has been electronically mailed to:
1:99-mc-09999 Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
Document description:Main Document

Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1079733196 [Date=4/21/2011] [FileNumber=1187989-0
] [b0dba0fec0a9063c1e24b281851e502e18293e3951f267ea8d51882e6c0740f9a69
12a85c768c856573bb9f5137240a120ae5184d663017220863cf499bbe153]]
Document description:Exhibit A (Part I)
] [2187d0260b2d9276c02a7bb548d1fa15b6eb76ce90ee6f1d5226aa7230d1c1e6808
316affdf8ee3b494e6b009230aa4f4fd6b17edd27dd35f51a7c624b85179a]]
Document description:Exhibit A (Part II)
] [bb431a0bbb765b705a9f28490a993101cf59782e2cea85f980499f2213b8ee7ea09
ab20cafbedb40289ead2fe21ed7f9d87f46c0f789d3a1fd1dc91e97634406]]
Document description:Exhibit B (Part I)
] [945cb301ed645fcc769db9529a964329a5c893c1e52660cfd2eaace3e16dcfcc2d4
cfe8c9c2bb3fd22182aaa8bd613b1a6699f829ab0b55341aaef57aa7c75dd]]
Document description:Exhibit B (Part II)
] [98ef2c8f742814cee3868bcef9a971abb0eea3b704939ccdad383be695527146db8
00c4a729975efee3e2fc978dee3cbd9de194a48709c24f84f7fc9d045981e]]
Document description:Exhibit B (Part III)
] [ae51cc74910efd6733187deb4815cad9d9e757d07cfe8cb3f5ca90eb116beb52bb9
8ec1a10abc0684752b6d5511b4eee26d8778e0501bb7811c4c9bd1daddb24]]
Document description:Exhibit C (Part I)
] [17c78e8833da1c85adeb0636bd11643d00eff01fd62954da2114bd3dfe71b4ea148
652a5ce9194fcc8eae61a4c27497354dbc40d1a6265f75eb20aa183ff3a03]]
Document description:Exhibit C (Part II)
] [172b0ef980d97fec9b20efc93dbc923410f44b76c3453cde4d103f649a3d11c22a6
3c0afbca31352754bfdae88cdc618b24863f6427602fa61cf87d0676bd91c]]
Document description:Exhibit C (Part III)
] [bfdef53a44f52d8d2fd0417bc3756f2bf1981cb71f35c1b6c2bb851debc1959c3f9
746c0b9473ab33ed331b62294acc9016bbcfcd4433059fb0c77cbfd6ec7c7]]
Document description:Exhibit D (Part I)
] [8b6c930ef10cfb646a5773011cc1839e505d8e3fa09b9456f9d178bd3910ae7ffb7
82e0fd008badbdb6a6820f2c2c3b7499609ac522f1820e801ec7c7e99082c]]
Document description:Exhibit D (Part II)
0] [d32dc5cab0b9adad44508df205764d879020cc18c72351633132d58268291a45cc
571a5b57210f613bd76c0cb0321aca156cbd5e36eceecc5f4c6aef6955f6fb]]
Document description:Exhibit D (Part III)
1] [831f1707856d171d0b204bcbe611432bdc21ce11093ddc228faf7e1f05b5f228c2
0f50ba6bf67ab54a07ed66d57ef3544a3b1537fceff25279edaac62783591a]]
Document description:Exhibit D (Part IV)
2] [b00d4d1729d48ab44f6f2199b07925fcaa95023218607cedf26c3d58f40ad6334e
cd39c66d498bf3c0b4e2bbb65b2ead091d9a3b35071ac338a1f28d9bd7175d]]
Document description:Exhibit D (Part V)
3] [63d9af4afe14ac0a6a2e8ab523364c1e30ca92422e4a41483a03969bbecc504b72
4407ca6cbdc0c703d9c6a8f3533f0aae2a8f3045536c41a197d4498b361342]]
Document description:Exhibit D (Part VI)
4] [a87a8b4fec43bb3bc424c4e7ddb81bc466b5b2ca852e2d821b8284f5838242f281
cdb906c7d581df0b8b54a00aaeb4870b79969ae2b9baa5483f4bce3d46a1f9]]
Document description:Exhibit D (Part VII)
5] [bb0b83bcfabd2feaf96cf34761c4371cd48e5991617540bf4fbe34f64d9d21f717
b4226183347e5a5800aedfedf4f8cfb06874593d6863278d137b2ea4e0b4e1]]
Document description:Exhibit D (Part VIII)
[STAMP dcecfStamp_ID=1079733196 [Date=4/21/2011] [FileNumbe r=1187989-1
6] [578502ad92cd82bedf938ddf6b8c49e91a424df68fcc70c4b2bc57147ffe9bbcb3
3b58822b349a5a1166969f9a5939e77bbbe5bcaa6ecb3fe5734128bb6669ea]]
Document description:Civil Cover Sheet
7] [4fb580e6ce8ab5691c40a70e779193668df3177c0dd7a799ff71c145c6b5a4aad6
fb5278e4740d58f81fda9f3e98dfc91d8fece3d2cceab1ee54dc0ae08e1afe]]
Document description:Patent/Trademark Report
8] [7b8700f12fefc3ad7fa1b37e1c37821e4874a7f43ec032b9bdb9f25907bc1f4110
22ccde1baf7fafe65b72367b05a997c369ede026d1ba4dfddfde85f4c08499]]
Document description:Summons Forms - Unsigned Google, Inc.
9] [b2100ca88295eecdb1a8a5d608e4cd8a833d5c67a07a07ff43f16807a4235c8fb2
745a343c6dfa8b9c2c90ab368e4818210a4870c5bfd14a7429de7a3a164d47]]

Walker Digital V Google

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Walker Digital V Google

Uploaded by

Copyright:

Available Formats

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

WALKER DIGITAL, LLC

v. Civil Action No. ___________

GOOGLE INC. JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

infringement against defendant Google Inc.

businesses, including Priceline.com and Synapse, Inc.

3. On information and belief, defendant Google Inc. (“Google”) is a Delaware

Parkway, Mountain View, California, 94043.

JURISDICTION AND VENUE

5. On information and belief, Google is subject to this Court’s jurisdiction because

organized and existing under the laws of the State of Delaware.

THE ASSERTED PATENTS

Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.

patent is attached as Exhibit B.

Possession At A Retailer Of A Product Purchased Using A Communication Network,” to Jay S.

correct copy of the ‘603 patent is attached as Exhibit C.

Methods Wherein A Buyer Takes Possession At A Retailer Of A Product Purchased Using A

Communication Network,” to Jay S. Walker, Andrew S. Van Luchne, Magdalena M. Fincham,

the “Asserted Patents”).

solutions incorporating modern information technologies. The novel inventions developed by

educational testing, and entertainment.

and development laboratory of Walker Digital.

Asserted Patents, were a direct result of investments made by Walker Digital.

(Infringement of the ‘772)

are fully set forth above.

services on its Google Offers website located at https://www.google.com/offers, which practices

offering is provided below:

(Infringement of the ‘636 Patent)

are fully set forth above.

services on its Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘636 patent.

23. Google committed its acts of infringement without license or authorization.

(Infringement of the ‘603 Patent)

are fully set forth above.

services on Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘603 patent.

(Infringement of the ‘468 Patent)

are fully set forth above.

services on its Google Offers website located at https://www.google.com/offers, which practices

one or more of the claims of the ‘468 patent.

33. Google committed its acts of infringement without license or authorization.

DEMAND FOR JURY TRIAL

a trial by jury of any issues so triable by right.

PRAYER FOR RELIEF

following relief in favor of Walker Digital and against Google:

supplemental damages to Walker Digital, including, without limitation, pre-judgment interest;

/s/ Richard D. Kirk

WALKER DIGITAL, LLC GOOGLE, INC.

Richard D. Kirk (No. 0922)

1 U.S. Government 3 Federal Question Incorporated or Principal Place

APRIL 21, 2011 /S/ RICHARD D. KIRK (RK0922)

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Mail Stop 8 REPORT ON THE

DOCKET NO. DATE FILED U.S. DISTRICT COURT

PATENT OR DATE OF PATENT

2 6,754,636 6/22/2004 Walker Digital, LLC

3 7,039,603 5/2/2006 Walker Digital, LLC

4 7,689,468 3/30/2010 Walker Digital, LLC

CLERK (BY) DEPUTY CLERK DATE

United States District Court

WALKER DIGITAL, LLC

Date: _ __________________