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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

WOLF RUN HOLLOW, LLC, Plaintiff, v. SPORTS AUTHORITY, INC., Defendant. Civil Action No. 13-CV-9211 JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement in which Wolf Run Hollow, LLC. (Wolf Run or Plaintiff) makes the following allegations against Sports Authority, Inc., (Sports Authority or Defendant): NATURE OF THE ACTION 1. This is a patent infringement action to stop Defendants infringement of

Plaintiffs United States Patent No. 6,115,817 entitled Methods and Systems for Facilitating Transmission of Secure Messages Across Insecure Networks (the 817 patent; a copy of which is attached hereto as Exhibit A). Plaintiff is the exclusive licensee of the 817 patent with respect to the Defendant. Plaintiff seeks injunctive relief and monetary damages. PARTIES 2. Plaintiff is a limited liability company organized and existing under the laws of

the State of Delaware. Plaintiff maintains its principal place of business at 170 Kinnelon Road, Suite 13, Kinnelon, New Jersey 07405. Plaintiff is the exclusive licensee of the 817 patent with

respect to the Defendants, and possesses the right to sue for infringement and recover past damages. 3. Upon information and belief, Defendant is a corporation organized and existing

under the laws of Colorado and offices and business locations throughout Illinois. JURISDICATION AND VENUE 4. This action arises under the Patent Laws of the United States, 35 U.S.C. 1 et

seq., including 35 U.S.C. 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction over this case for patent infringement under 28 U.S.C. 1331 and 1338(a). 5. The Court has personal jurisdiction over Defendant because: Defendant is present

within or has minimum contacts with the State of Illinois and the Northern District of Illinois; Defendant has purposefully availed itself of the privileges of conducting business in the State of Illinois and in the Northern District of Illinois; Defendant has sought protection and benefit from the laws of the State of Illinois; Defendant regularly conducts business within the State of Illinois and within the Northern District of Illinois; and Plaintiffs causes of action arise directly from Defendants business contacts and other activities in the State of Illinois and in the Northern District of Illinois 6. More specifically, Defendant, directly and/or through authorized intermediaries,

ships, distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web page) its products and services in the United States, the State of Illinois, and the Northern District of Illinois. Upon information and belief, Defendant has committed patent infringement in the State of Illinois and in the Northern District of Illinois, has contributed to patent infringement in the State of Illinois and in the Northern District of Illinois, and/or has induced others to commit patent infringement in the State of Illinois and in the Northern District of

Illinois. Defendant solicits customers in the State of Illinois and in the Northern District of Illinois. Defendant has many paying customers who are residents of the State of Illinois and the Northern District of Illinois and who each use each of the respective Defendants products and services in the State of Illinois and in the Northern District of Illinois. 7. and 1400(b). COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,006,231 8. The 817 patent was duly and legally issued by the United States Patent and Venue is proper in the Northern District of Illinois pursuant to 28 U.S.C. 1391

Trademark Office on September 5, 2000, after full and fair examination for systems and methods for secure messaging on an insecure network. Plaintiff is the exclusive licensee of the 817 patent with respect to the Defendants, and possesses all rights of recovery under the 817 patent with respect to the Defendants, including the right to sue for infringement and recover past damages. 9. Upon information and belief, Defendant has been and is now infringing the 817

Patent in the State of Illinois, in this judicial district, and elsewhere in the United States, by, among other things, directly or through intermediaries, making, using, importing, providing, supplying, distributing, selling, and/or offering for sale apparatuses and systems and providing methods practiced on Defendants various websites (including, without limitation,

http://www.sportsauthority.com/ and related internal systems supporting the operation of said websites) is covered by one or more claims of the 817 Patent to the injury of Wolf Run. Upon information and belief, Defendant directs or requires users to request, utilize, transmit and/or receive secure messages, security procedure, and/or a security software object via the secure

checkout procedures and methods on their website. Upon information and belief, Defendant has also contributed to the infringement of one or more claims of the 817 patent, and/or actively induced others to infringe one or more claims of the 817 patent via their website, in this district and elsewhere in the United State. Defendant directly infringing, literally infringing, and Defendant is thus liable for

infringing the 817 Patent under the doctrine of equivalents. infringement of the 817 Patent pursuant to 35 U.S.C. 271(a). 10. Plaintiff. 11.

Defendants aforesaid activities have been without authority and/or license from

Defendant has also been inducing infringement of the 817 Patent, literally or

under the doctrine of equivalents, under 35 U.S.C. 271(b) by intentionally and knowingly inviting and instructing the users of websites supported by Defendants software to perform the claimed methods and by supplying software modules or components used to directly infringe. 12. Defendant has also been contributing to the infringement of the 817 Patent,

literally or under the doctrine of equivalents, under 35 U.S.C. 271(c) by selling or offering to sell in the United States the software that powers the accused websites with knowledge that the software is especially made or adapted for use in a way that infringes. The software that Defendant provides is a significant part of the inventions of the claims of the 817 Patent and has no significant non-infringing use. 13. On information and belief, to the extent any marking was required by 35 U.S.C.

287, all predecessors in interest to the 817 Patent complied with any such requirements. 14. Defendant is willfully and intentionally infringing the 817 Patent from at least

the date of the filing of this lawsuit. 15.


Plaintiff is entitled to increased damages under 35 U.S.C. 284 and to attorneys fees

and costs incurred in prosecuting this action under 35 U.S.C. 285 with respect to these Defendant.
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16.

Defendant is willfully infringing the 817 Patent at least from the date of the filing

of this Complaint; to the extent that facts learned in discovery show that Defendants infringement of the 817 Patent is, or has been willful, Plaintiff reserves the right to request such a finding at the time of trial. 17. As a result of Defendants infringement of the 817 Patent, Plaintiff has suffered

monetary damages and is entitled to a money judgment in an amount adequate to compensate for Defendants infringement, but in no event less than a reasonable royalty for the use made of the invention by Defendant, together with interest and costs as fixed by the court, and Plaintiff will continue to suffer damages in the future unless Defendants infringing activities are enjoined by this Court. 18. Unless a permanent injunction is issued enjoining Defendant and their agents,

servants, employees, representatives, affiliates, and all others acting on in active concert therewith from infringing the 817 Patent, Plaintiff will be greatly and irreparably harmed. 19. Defendants infringement of Plaintiffs exclusive rights under the 817 p atent will

continue to damage Plaintiff, causing irreparable harm for which there is no adequate remedy at law, unless enjoined by this Court. JURY DEMAND 20. Plaintiff hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of

Civil Procedure. PRAYER FOR RELIEF Plaintiff respectfully requests that the Court find in its favor and against Defendant, and that the Court grant Plaintiff the following relief:

A.

An adjudication that one or more claims of the 817 patent have been infringed, either literally and/or under the doctrine of equivalents, by Defendant and/or by others to whose infringement Defendant has contributed and/or by others whose infringement has been induced by Defendant;

B.

An award to Plaintiff of damages adequate to compensate Plaintiff for the Defendants acts of infringement together with pre-judgment and post-judgment interest;

C.

That, should Defendants acts of infringement be found to be willful from the time that Defendant became aware of the infringing nature of its actions, which is the time of filing of Plaintiffs Original Complaint at the latest, that the Court award treble damages for the period of such willful infringement pursuant to 35 U.S.C. 284;

D.

A grant of permanent injunction pursuant to 35 U.S.C. 283, enjoining the Defendant from further acts of (1) infringement, (2) contributory infringement, and (3) actively inducing infringement with respect to the claims of the 817 patent;

E.

That this Court declare this to be an exceptional case and award Plaintiff its reasonable attorneys fees and costs in accordance with 35 U.S.C. 285; and

F.

Any further relief that this Court deems just and proper.

Dated: December 26, 2013 Respectfully submitted, Parikh Law Group, LLC

s/ Justin Kaplan Justin Kaplan (6298464) Attorney for Plaintiff WOLF RUN HOLLOW, LLC PARIKH LAW GROUP, LLC 150 S. Wacker Drive, Suite 2600 Chicago, IL 60606 (312) 725-3476 (tel.)

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