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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

Matthew B. Hippler Nevada Bar No. 7015 HOLLAND & HART LLP 5441 Kietzke Lane Second Floor Reno, NV 89511 Phone: 775-327-3000 Fax: 775-786-6179 mhippler@hollandhart.com Donald A. Degnan (pro hac vice application to be submitted) HOLLAND & HART LLP 1800 Broadway, Suite 300 Boulder, CO 80302 Phone: 303-473-2700 Fax: 303-473-2720 ddegnan@hollandhart.com James E. Hartley (pro hac vice application to be submitted) HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202-3979 Phone: 303-295-8000 Fax: 303-975-5486 jhartley@hollandhart.com Attorneys for Plaintiff Server Technology, Inc.

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THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA CASE NO.: COMPLAINT FOR PATENT INFRINGEMENT JURY DEMAND

19 SERVER TECHNOLOGY, INC., (a Nevada Corporation), 20 Plaintiff, 21 v. 22 WESTERN TELEMATIC, INC., 23 (a California Corporation), 24 25 26 27 28 Defendant.

Plaintiff Server Technology, Inc., as and for its Complaint, alleges as follows against Defendant Western Telematic, Inc.

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

PARTIES 1. Plaintiff Server Technology, Inc. (“Server Technology”) is a Nevada corporation

having its principal place of business at 1040 Sandhill Drive, Reno, Nevada, 89521. 2. Defendant Western Telematic, Inc. (“WTI”) is a California corporation having

its principal place of business at 5 Sterling, Irvine, California, 92618. JURISDICTION 3. This is an action for patent infringement arising under the patent laws of the

United States, Title 35 of the United States Code, 35 U.S.C. § 271 et seq. 4. This Court has original jurisdiction over these claims pursuant to 28 U.S.C.

§§ 1331 and 1338(a). 5. This Court has personal jurisdiction over WTI as it transacts business in the

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District of Nevada, it has marketed, manufactured, or sold infringing product within this District, and has caused Server Technology injury within this District. 6. Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c) and/or 1400(b). GENERAL ALLEGATIONS 7. Server Technology is a leader in innovative power management solutions. It

designs and manufactures a number of products, including what are called intelligent power distribution units (or “PDUs”). Although used in many types of applications, a primary

application for PDU products is in data centers. 8. Server Technology is the owner of United States Patent No. 7,702,771 (“the ‘771

patent”) entitled “ELECTRICAL POWER DISTRIBUTION DEVICE HAVING A CURRENT DISPLAY,” which issued on April 20, 2010. A true and correct copy of the ‘771 patent is attached as Exhibit 1 and incorporated by this reference. 9. Server Technology is the owner of United States Patent No. 7,099,934 (“the ‘934

patent”) entitled “NETWORK-CONNECTING POWER MANAGER FOR REMOTE APPLIANCES,” which issued on August 29, 2006. A true and correct copy of the ‘934 patent is attached as Exhibit 2 and incorporated by this reference.

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

10. patent”)

Server Technology is the owner of United States Patent No. 7,043,543 (“the ‘543 entitled “VERTICAL-MOUNT ELECTRICAL POWER DISTRIBUTION

PLUGSTRIP,” which issued on May 9, 2006. A true and correct copy of the ‘543 patent is attached as Exhibit 3 and incorporated by this reference. 11. The ‘771, 934, and ‘543, patents are collectively referred to as the “Server

Technology Patents.” 12. Server Technology marks its products with the numbers of the Server

Technology Patents in accordance with 35 U.S.C. § 287. 13. WTI has made, used, sold, or offered to sell, and continues to make, use, sell,

and/or offer for sale, PDUs that infringe the Server Technology Patents. 14. WTI describes its PDU products as follows: (i) MPC-series PDU Managed

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Power Controllers, including the MPC-20V vertical series PDU; (ii) VMR series PDU Managed Power Controllers; and (iii) IPS Series PDU Internet Power Switches; (collectively referred to as “WTI Accused Products”). 15. WTI has made, used, offered for sale, and has sold in the United States WTI

Accused Products that infringe one or more of the claims of the Server Technology Patents. 16. Specifically, the WTI Accused Products include MPC-series PDU Managed

Power Controllers (including the MPC-20V vertical series PDU) that infringe at least claims 1 and 15 of the ‘771 patent. 17. The WTI Accused Products, specifically the MPC-20V vertical series PDU,

infringe at least claim 1 of the ‘934 patent. 18. The WTI Accused Products, specifically the MPC-20V vertical series PDU,

infringe at least claim 1 of the ‘543 patent. 19. On January 8, 2013, Server Technology provided WTI with express notice of its

acts of infringement. Since that date, WTI has continued to market and sell PDUs that infringe the Server Technology Patents.

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

FIRST CAUSE OF ACTION (Infringement of the ‘771 patent) 20. Server Technology incorporates by reference the allegations contained in the

preceding paragraphs. 21. WTI has infringed and is infringing one or more claims of the ‘771 patent by

manufacturing, using, offering to sell, or selling, within the United States, and/or by importing into the United States, products, including but not limited to the WTI Accused Products, in violation of 35 U.S.C. § 271(a). 22. 23. WTI’s infringing acts have caused damage to Server Technology. WTI will continue to infringe one or more claims of the ‘771 patent unless

preliminarily and permanently enjoined by this Court. As a result of WTI’s infringing conduct, Server Technology has suffered, and will continue to suffer, irreparable harm for which there is no adequate remedy at law. Accordingly, Server Technology is entitled to preliminary and permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 24. WTI’s infringement of the ‘771 patent is willful. SECOND CAUSE OF ACTION (Infringement of the ‘934 patent) 25. Server Technology incorporates by reference the allegations contained in the

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preceding paragraphs. 26. WTI has infringed and is infringing one or more of the claims of the ‘934 patent

by manufacturing, using, offering to sell, or selling, within the United States, and/or by importing into the United States, products, including but not limited to the WTI Accused Products, in violation of 35 U.S.C. § 271(a). 27. 28. WTI’s infringing acts have caused damage to Server Technology. WTI will continue to infringe one or more of the claims of the ‘934 patent unless

preliminarily and permanently enjoined by this Court. As a result of WTI’s infringing conduct, Server Technology has suffered, and will continue to suffer, irreparable harm for which there is

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

no adequate remedy at law. Accordingly, Server Technology is entitled to preliminary and permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 29. WTI’s infringement of the ‘934 patent is willful. THIRD CAUSE OF ACTION (Infringement of the ‘543 patent) 30. Server Technology incorporates by reference the allegations contained in the

preceding paragraphs. 31. WTI has infringed and is infringing one or more of the claims of the ‘543 patent

by manufacturing, using, offering to sell, or selling, within the United States, and/or by importing into the United States, products, including but not limited to the WTI Accused Products, in violation of 35 U.S.C. § 271(a). 32. 33. WTI’s infringing acts have caused damage to Server Technology. WTI will continue to infringe one or more of the claims of the ‘543 patent unless

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preliminarily and permanently enjoined by this Court. As a result of WTI’s infringing conduct, Server Technology has suffered, and will continue to suffer, irreparable harm for which there is no adequate remedy at law. Accordingly, Server Technology is entitled to preliminary and permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 34. WTI’s infringement of the ‘543 patent is willful. PRAYER FOR RELIEF WHEREFORE, Plaintiff Server Technology requests entry of judgment in its favor and against Defendant WTI as follows: A. B. A determination that WTI has infringed each of the Server Technology Patents; A determination that WTI’s infringement of each of the Server Technology

Patents was willful; C. Issuance of a permanent injunction enjoining WTI , its agents, officers, assigns,

and all others acting in concert with WTI from infringing, or inducing or contributing to the infringement of, the Server Technology Patents;

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

D.

An award of damages to compensate Server Technology for WTI’s infringement,

and an award of treble damages pursuant to 35 U.S.C. § 284; E. A finding that this case is exceptional under 35 U.S.C. § 285 and an award of

attorney fees incurred by Server Technology in connection with this action; F. awarded; G. /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// 6 Such other and further relief as the Court deems just and proper. An award of pre-judgment interest and post-judgment interest on the damages

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HOLLAND & HART LLP 5441 Kietzke Lane, Second Floor RENO, NEVADA 89511

JURY DEMAND Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Server Technology hereby demands a trial by jury of all issues so triable. DATED this 11th day of March, 2013 HOLLAND & HART LLP /s/ Donald A. Degnan Donald A. Degnan (pro hac vice application to be submitted) HOLLAND & HART LLP 1800 Broadway, Suite 300 Boulder, CO 80302 Phone: 303-473-2700 Fax: 303-473-2720 ddegnan@hollandhart.com James E. Hartley (pro hac vice application to be submitted) HOLLAND & HART LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202-3979 Phone: 303-295-8000 Fax: 303-975-5486 jhartley@hollandhart.com Matthew B. Hippler Nevada Bar No. 7015 HOLLAND & HART LLP 5441 Kietzke Lane Second Floor Reno, NV 89511 Phone: 775-327-3000 Fax: 775-786-6179 mhippler@hollandhart.com Attorneys for Plaintiff Server Technology, Inc.

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