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, Plaintiff, v. LITTLER MENDELSON, P.C., a California professional corporation, Defendant. § § § § § Civil Action No. 14-cv-1174 § § § § § §
COMPLAINT FOR PATENT INFRINGEMENT Bashen Corporation, by its attorneys, for its Complaint against Littler Mendelson, P.C., alleges as follows: THE PARTIES, JURISDICTION AND VENUE 1. This is an action for patent infringement arising under Title 35 U.S.C. §1 et
seq., of the United States. 2. Plaintiff, Bashen Corporation (“Bashen”) is a Texas corporation with its
principal place of business in Houston, Texas. 3. Defendant, Littler Mendelson, P.C. (“Littler”) is a law firm with its main
office in San Francisco, California and an office in Houston, Texas. 4. This claim arises under the United States Patent laws, 35 U.S.C. §1, et seq.
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§1331, 1332, and 1338(a).
This Court has specific personal jurisdiction over Littler because the
infringing acts conducted by Littler in this State and District are the same infringing acts which constitute the instant cause of action. 6. This Court has general personal jurisdiction over Littler because it has
regularly and systematically conducted business in this State and District and purposefully availed itself of the privilege of conducting business in this State and this District. 7. 1400. FACTS GIVING RISE TO PATENT INFRINGEMENT 8. On January 10, 2006, after a full and extensive examination, the United Venue is proper in this District and Division, under 28 U.S.C. §§1391 and
States Patent and Trademark office duly and legally issued United States Patent No. 6,985,922 (“the ‘922 Patent”) entitled Method, Apparatus And System For Processing Compliance Actions Over A Wide Area Network. A true and correct copy of the ‘922 Patent is attached as Exhibit A. 9. Bashen owns all right, title, and interest to the ‘922 Patent, including the
exclusive right to enforce the ‘922 Patent against past, present and future infringement and resulting damages therefrom. 10. The ‘922 Patent discloses an invention for processing, tracking and
managing compliance actions, such as equal employment opportunity claims, over a wide area network.
Bashen is in the business of processing, tracking and managing compliance
actions for third parties predominantly in the equal employment opportunity area. 12. Littler uses software that organizes, tracks and processes data, and is
marketed under the title CaseSmart®. 13. Littler has infringed and continues to infringe the ‘922 Patent by engaging
in acts including making, using, selling, or offering to sell software solutions associated with its CaseSmart® software, and other software, service and maintenance products sold in conjunction with CaseSmart®. 14. Court. 15. As a result of Littler’s infringing conduct, Bashen has suffered, and will Littler will continue to infringe the ‘922 Patent unless enjoined by this
continue to suffer, irreparable harm for which there is no adequate remedy at law. 16. As a result of the infringement of the ‘922 Patent, Bashen has been
damaged, will be further damaged, and is entitled to be compensated for such damages, pursuant to 35 U.S.C. §284, in an amount to be determined at trial. WILLFUL INFRINGEMENT 17. Littler’s past and continuing infringement of the ‘922 Patent has been
deliberate and willful. Its conduct warrants an award of treble damages, pursuant to 35 U.S.C. §284, and this is an exceptional case justifying an award of attorney fees to Bashen, pursuant to 35 U.S.C. §285.
PRAYER FOR RELIEF Wherefore, upon final hearing or trial, plaintiff Bashen respectfully requests the following relief: a. judgment that Littler Mendelson, P.C. has infringed the ‘922 Patent; b. judgment and order requiring Littler Mendelson, P.C. to pay damages to Bashen adequate to compensate it for Littler Mendelson’s wrongful infringing acts, in accordance with 35 U.S.C. §284; c. judgment requiring Littler Mendelson, P.C. to pay increased damages up to three times for its willful and deliberate infringement of the ‘922 Patent; d. judgment that this is an exceptional case, under 35 U.S.C. §285, and an award to Bashen of its costs, including its reasonable attorney fees and other expenses incurred in connection with this action; e. judgment requiring Littler Mendelson, P.C. to pay prejudgment interest on the amount of the damage award; f. such additional relief the Court deems fair and just.
JURY DEMAND Bashen Corporation requests a trial by jury on all issues so triable. Respectfully Submitted, BASHEN CORPORATION Date: April 29, 2014 By:/s/ Mark M. Grossman Mark M. Grossman email@example.com Nicolas Spear firstname.lastname@example.org Kyle D. Wallenberg email@example.com Grossman Law Offices 225 W. Washington Street, Suite 2200 Chicago, Illinois 60606 (312) 621-9000