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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS PARAGON DATA SYSTEMS INC.

, Plaintiff, vs. GRAND ROUNDS SOFTWARE, LLC, Defendant. Case No.: 14 c 316 DEMAND FOR JURY TRIAL

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Paragon Data Systems Inc. (Paragon or Plaintiff), by and through their undersigned attorneys, for their complaint against defendant Grand Rounds Software, LLC, (Grand Rounds or Defendant) hereby allege as follows: NATURE OF LAWSUIT 1. This action involves claims for patent infringement arising under the patent

laws of the United States, Title 35 of the United States Code. This Court has exclusive jurisdiction over the subject matter of the Complaint under 28 U.S.C. 1338(a). THE PARTIES 2. Paragon is an Ohio corporation with a place of business at 2218 Superior

Avenue, Cleveland, OH 44114. 3. Paragon owns all right, title and interest in, and has standing to sue for

infringement of United States Patent No. 8,172,129 (the 129 patent), entitled Method for Tracking Milk in a Neonatal Care Facility issued May 8, 2012. A copy of the 129 patent is annexed hereto as Exhibit A. 4. Defendant Ground Rounds is a Delaware Limited Liability Company with a

place of business at 404 Valley Glen Drive, Bryn Mawr, PA 19010-2053. On information

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and belief, Ground Rounds transacts business in this judicial district by providing and/or offering to provide products and services that infringe claims of the 129 patent in this judicial district. 5. Venue is proper in this District under 28 U.S.C. 1391 and 1400(b).

DEFENDANT GROUND ROUNDS ACTS OF PATENT INFRINGEMENT 6. Defendant Ground Rounds has infringed, contributed to the infringement, and

induced the infringement of the claims of the 129 patent through, among other activities, the use and sale and distribution of Ground Rounds Crib Notes, electronic medical records software. 7. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to track breast milk in a neonatal facility. 8. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to process identifiers or barcodes that are affixed to a plurality of breast milk feeding and storage instruments and associated with an infant and/or mother of the infant. 9. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to process information obtained from optically scanning an identifier or barcode affixed to a container containing breast milk. 10. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to process information obtained from optically scanning an identifier or barcode affixed to a feeding device containing breast milk. 11. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to record identification information data unique to the infant and/or a mother of the infant in a computer database.

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12.

Ground Rounds Crib Notes, electronic medical records software is

specifically configured to validate that identification information obtained from an optically scanned identifier or barcode is unique to the infant and/or the mother of the infant. 13. Ground Rounds Crib Notes, electronic medical records software is

specifically configured to transmit feeding information over a network to a computer database in response to a scanned identifier or barcode. 14. Defendant Ground Rounds was put on actual notice of the 129 patent at least

as early as July 23, 2012. (Exhibits B-D.) 15. Defendant Ground Rounds developed, marketed, sold, and continues to sell its

infringing Crib Notes, electronic medical records software products with knowledge and willful disregard of Paragons rights in the 129 patent. 16. Defendant Ground Rounds infringement, contributory infringement, and

inducement to infringe has injured and will continue to injure Paragon unless and until this Court enters an injunction prohibiting further infringement and, specifically, enjoining further use and sale of products and systems that come within the scope of the 129 patent. PRAYER FOR RELIEF WHEREFORE, Plaintiff ask this Court to enter judgment against the Defendant, and against their subsidiaries, affiliates, agents, servants, employees and all persons in active concert or participation with them, granting the following relief: A. An award of damages adequate to compensate Paragon for the infringement,

inducement to infringe, and contributory infringement that has occurred, together with prejudgment interest from the date that Defendants infringement of the Paragon 129 patent began; B. Increased damages as permitted under 35 U.S.C. 284;

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C.

A finding that this case is exceptional and an award to Paragon of its

attorneys fees and costs as provided by 35 U.S.C. 285; D. A permanent injunction prohibiting further infringement, inducement and

contributory infringement of the Paragon 129 patent; and E. Such other and further relief as this Court or a jury may deem proper and just. JURY DEMAND Paragon Data Systems Inc. demands a trial by jury on all issues presented in this Complaint. Dated: January 16, 2014 Respectfully submitted, /ss/ Anthony E. Dowell Anthony E. Dowell, Esq. (#6224825) aedowell@taftlaw.com Michael D. Froelich, Esq. (#6281422) mdfroelich@taftlaw.com TAFT STETTINIUS & HOLLISTER LLP 111 E. Wacker Dr., Suite 2800 Chicago, IL 60601 (312) 840-4307 Ryan O. White, Esq. rwhite@taftlaw.com James A. Coles, Esq. jcoles@taftlaw.com M. Zach Gordon, Esq. (#6301683) zgordon@taftlaw.com TAFT STETTINIUS & HOLLISTER LLP One Indiana Square, Suite 3500 Indianapolis, IN 46240 (317) 713-3500 ATTORNEYS FOR PLAINTIFF PARAGON DATA SYSTEMS INC.
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