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REWARDS NETWORK INC. a/k/a, Defendant. ) ) ) ) ) )


Case No. _________________ DEMAND FOR JURY TRIAL

) ) )

MERIDIAN ENTERPRISES CORPORATIONS COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND Meridian Enterprises Corporation (MERIDIAN) for its Complaint against Defendant, REWARDS NETWORK INC. a/k/a (REWARDS), alleges as follows: Parties 1. Meridian is a corporation organized and existing under the laws of the State of

Missouri, having a principal place of business at 951 Hornet Drive, Hazelwood, Missouri 63042. 2. Rewards Network Inc. is a Delaware corporation and has its principal place of

business at 2 North Riverside Plaza, Suite 950, Chicago, IL 60606. Jurisdiction and Venue 3. The Complaint arises under the patent laws of the United States, Title 35, United

States Code, including, among others, section 271. 4. This Court has jurisdiction over the subject matter of the claims of patent

infringement pursuant to 28 U.S.C. 1331 and 1338(a). 5. This Court has personal jurisdiction over the Defendant because they either have a

regular and established place of business, or conduct business, in this judicial District. In 1

particular, on information and belief, the accused iDine system has been used for participants in this judicial district. 6. Venue in this District is, thus, proper pursuant to 28 U.S.C. 1391(b) and 1400.

Meridians Patent 7. On September 2, 1998, inventor, John L. McMullin, filed a patent application

with the United States Patent and Trademark Office, which application resulted in the granting of United States Patent No. 6,222,914. A copy of that patent is attached as Exhibit A. 8. Meridian is the owner of U.S. Patent No. 6,222,914 (hereinafter, the 914

Patent) by Assignment dated March 16, 2007 and recorded in the Patent and Trademark Office on March 22, 2007, Reel/Frame Nos. 019047/0264. A copy of the Notice of Recordation of Assignment Document and the Assignment are attached as Exhibit B.

Defendants Activities 9. Upon information and belief, REWARDS sponsors and administers an incentive

award program called iDINE, and REWARDS has sold, developed, implemented, and/or performs the processing for such program. 10. In the iDINE program, each participant has a credit card. Those cards have the

name of the participant and an account number on them. 11. participant. 12. In the iDINE program, the participant purchases goods and/or services from The account number on each card is for a credit card account issued to the

participating restaurants, clubs and/or bars and the like by using their credit card.


An award amount is determined in the iDINE program based upon such

purchases. For example, the award can be RARE (5% back), MEDIUM (10% back), and/or WELL DONE (20% back). 14. The iDINE program has a predetermined waiting time between the earning of the

award and the crediting of the award to the credit card account. For example, within 60 days. 15. Upon information and belief, Defendants have known of Meridian and the 914

patent since at least before Defendant began selling, administering, processing, and/or sponsoring their incentive award program. COUNT PATENT INFRINGEMENT The iDINE incentive award program (Accused Card Program) infringes one or


more claims of the 914 patent. 17. The steps outlined in paragraphs 11 through 15 above are covered by at least

claims 1 and 27 of the 914 patent. 18. Court. 19. REWARDS is a willful infringer. REWARDS will continue to infringe the 914 patent unless enjoined by this

WHEREFORE, Meridian prays this Court: A. Permanently enjoin Defendant, and those acting in concert and participation

therewith from infringing, inducing others to infringe, or contributing to the infringement of United States Patent No. 6,222,914; B. Award all monetary damages to Meridian for patent infringement as allowed by

35 U.S.C. 284;

C. D.

Treble the damage award pursuant to 35 U.S.C. 284; Determine that Defendants conduct renders the patent infringement an

exceptional case and award attorneys fees pursuant to 35 U.S.C. 285; E. F. circumstances. Jury Demand Pursuant to Fed. R. Civ. P. 38 and the Seventh Amendment of the Constitution of the United States, Meridian respectfully demands a jury trial on all issues so triable. Respectfully submitted, Award Meridian its costs and expenses; and Grant all other relief that this Court deems necessary, just, and proper under the

/s/ A.J. Bronsky_________________ A. J. Bronsky, Esq., #29686 BROWN & JAMES, P.C. 1010 Market Street, 20th Floor St. Louis, Missouri 63101-2000 (314) 421-3400 Telephone (314) 242-5357 Facsimile Spiro Bereveskos, Esq. Woodard, Emhardt, Moriarty, McNett & Henry, LLP 111 Monument Circle, Suite 3700 Indianapolis, IN 46204-5137 (317) 634-3456 Telephone (317) 637-7561 Facsimile Email Attorneys for Plaintiff, Meridian Enterprises Corporation