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d/b/a SCAN SCRIPT, a Michigan corporation Plaintiff Case No.: v. WALGREEN CO., an Illinois corporation Defendant __________________________________________ COMPLAINT & JURY DEMAND NOW COMES Plaintiff PRN Technologies, Inc. (PRN), by and through its attorneys, Carlson, Gaskey & Olds, P.C., and for its Complaint against Defendant Walgreen Co. (Walgreen) states as follows: INTRODUCTION 1. This is an action for patent infringement brought by PRN against Walgreen

pursuant to Title 35 of the Unites States Code. PARTIES 2. PRN is a Michigan corporation having its principal place of business at 6200

Argyle, Dearborn, MI 48126. 3. Walgreen is an Illinois corporation with its primary place of business at 108

Wilmot Road, Deerfield, IL 60015. JURISDICTION AND VENUE 4. This Court has original subject matter jurisdiction over the claims in this action

pursuant to 28 U.S.C. 1331 (federal question) and 1338 (patents).


Walgreen is subject to personal jurisdiction in this Court. In particular, this Court

has personal jurisdiction over Walgreen because Walgreen has engaged in continuous, systematic and substantial activities within this judicial district, including substantial marketing and sales of products in this judicial district. Upon information and belief, Walgreen has approximately 233 store locations in Michigan, including many in this judicial district. Furthermore, upon information and belief, this Court has personal jurisdiction over Walgreen in this case because Walgreen has committed acts giving rise to PRNs claim for patent infringement within and directed to this judicial district. 6. Venue in this Court is proper pursuant to 28 U.S.C. 1391(b) and (c) and 28

U.S.C. 1400(b). PRNS PATENT 7. forth. 8. On March 29, 2005, the United States Patent and Trademark Office duly and PRN incorporates and re-alleges Paragraphs 1 through 6 as each were fully set

lawfully issued United States Letters Patent No. 6,871,783 (the 783 patent), entitled Method of Dispensing Medical Prescriptions. A true and correct copy of the 783 patent is attached hereto as Exhibit 1. 9. 10. 11. The 783 patent names William Kaafarani and Mohamad Bazzi as inventors. PRN is the owner by assignment of all right, title and interest in the 783 patent. The 783 patent generally relates to, inter alia, a novel method of dispensing

medical prescriptions.

COUNT I - WALGREENS DIRECT INFRINGEMENT OF THE 783 PATENT 12. forth. 13. 14. The 783 patent remains valid, enforceable and unexpired. Upon information and belief, Walgreen is directly infringing and has directly PRN incorporates and re-alleges Paragraphs 1 through 11 as each were fully set

infringed the 783 patent, including, without limitation, by making, using, selling, offering for sale, and/or importing, without license or authority, a method and/or system of dispensing medical prescriptions covered by the 783 patent, including but not limited to Walgreens Pharmacy Prescription System including at least Walgreens Phone Applications, and Mobile Connects, which include a system and method for scanning, refilling, monitoring, and notifications related to dispensing medical prescriptions (hereinafter the accused system). 15. The accused system falls within the scope of one or more claims of the 783

patent. Upon information and belief, Walgreen directly infringes at least claims 1 and 2 of the 783 patent. 16. 17. Upon information and belief, Walgreens has actual knowledge of the 783 patent. Upon information and belief, Walgreens infringement has been and continues to

be willful and deliberate. 18. As a result of Walgreens infringement, PRN will suffer severe and irreparable

harm, unless that infringement is enjoined by this Court, and has suffered substantial damages. PRAYER FOR RELIEF WHEREFORE, PRN requests judgment in its favor against Walgreen for the following relief: A. An Order adjudging that Walgreen has infringed the 783 patent;

B. C.

An order adjudging Walgreen to have willfully infringed the 783 patent. A preliminary and permanent injunction enjoining Walgreen, its officers, directors, agents, servants, employees and those persons in active concert or participation with Walgreen, from directly or indirectly infringing the 783 patent in violation of 35 U.S.C. 271;

D. E.

An award of damages adequate to compensate PRN for Walgreens infringement; An order for a trebling of damages and/or exemplary damages because of Walgreens willful infringement pursuant to 35 U.S.C. 284;

F. G.

An Order adjudging that this is an exceptional case; An award to PRN of its attorney fees and its costs and expenses incurred in connection with this action pursuant to 35 U.S.C. 285;

H. I.

An award of prejudgment and post-judgment interest and costs of this action; and Such other and further relief that this Court deems just and proper. JURY DEMAND

Pursuant to Fed R. Civ. P. 38(b) and 5(d), Plaintiff demands a trial by jury for all issues so triable. Dated: May 22, 2013 CARLSON, GASKEY & OLDS, P.C. /s/ Steven Susser John E. Carlson (P51379) Steven Susser (P52940) David L. Atallah (P73403) Carlson Gaskey & Olds, P.C. 400 W. Maple, Suite 350 Birmingham, Michigan 48009 Telephone: (248) 988-8360 Facsimile: (248) 988-8363 Email: 4