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Jeffrey I. Kaplan (JK 4706) SORIN ROYER COOPER LLC Two Tower Center Boulevard, 11th Floor East Brunswick, NJ 08816 Telephone: (732) 839-0404 Facsimile: (732) 393-1901 Email: jkaplan@sorinroyercooper.com Attorneys for Plaintiff Centrak, Inc. UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

CENTRAK, INC. and WIRELESS COMMUNICATIONS PRODUCTS, LLC, Plaintiffs, v. EKAHAU, INC., Defendant. DEMAND FOR JURY TRIAL COMPLAINT FOR PATENT INFRINGEMENT

Centrak, Inc. (Centrak) and Wireless Communications Products, LLC (WCP), coplaintiffs, demand a jury trial and complain against the defendant as follows:

THE PARTIES 1. Centrak is a corporation organized and existing under the laws of the State of

Delaware, and having a place of business at 5 Caufield Place, Suite 102, Newtown, Pennsylvania 22 23 24 25 26 27 28
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18940. 2. WCP is a limited liability company organized and existing under the laws of the

State of Delaware, and having a principle place of business in Connecticut.

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3.

Upon information and belief, Defendant Ekahau, Inc. (Ekahau) is a corporation

organized under the laws of the State of Connecticut, having a principle place of business at 55 North Water Street, Norwalk, Connecticut 06854.

JURISDICTION AND VENUE 4. This action arises under the patent laws of the United States of America, Title 35 of

the United States Code. This Court has subject matter jurisdiction of this action under 28 U.S.C. 1331 and 1338(a). 5. Upon information and belief, Ekahau does business and is committing infringements

in this judicial district and is subject to personal jurisdiction in this judicial district by advertising, marketing and selling its services and the infringing services within this judicial district. 6. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 and 1400(b).

THE PATENT 16 7. 17 18 19 20 21 22 23 24 25 26 27 28
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Co-plaintiffs, repeat and incorporate herein the entirety of the allegations contained

in paragraphs 1 through 6 above. 8. On June 29, 1999, U.S. Patent No. 5,917,425 (hereinafter referred to as the 425

patent) was duly and legally issued to Inventors James Crimmins and James Soulnier. Co-Plaintiff Wireless Communications Products, LLC is the owner by assignment of the 425 patent, and CoPlaintiff Centrak is the exclusive licensee with rights to enforce the 425 patent. The 425 patent

relates to methods and systems for locating items within a structure, such as a building, using various combinations of sensors. A copy of the 425 patent is attached hereto as Exhibit 1.

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CLAIM FOR PATENT INFRINGEMENT COUNT ONE Co-Plaintiffs Centrak and WCP repeat and incorporate herein the entirety of the

allegations contained in paragraphs 1 through 7 above. 9. Defendant Ekahau has and still is directly infringing the 425 patent by, among other

things, selling and offering for sale in this judicial district products which practice the location methods and which are used to build the systems claimed in the 425 patent. For example, the

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PRAYER FOR RELIEF WHEREFORE, Centrak and WCP request judgment against Defendant on all the counts and for the following relief: A. B. Declaration that the 425 patent is valid and enforceable; Declaration that defendant Ekahau has infringed the 425 patent, including, but not Ekahau LB1, a product sheet for which is attached here at Ex. 2, when used for its intended purpose, includes all of the features of at least claims 1 and 10, as well as numerous other claims, of the 425 patent. Centrak believes that discovery will reveal that Ekahau is infringing additional claims of the 425 patent. 11. Centrak and WCP have been damaged by Ekahaus infringement of the 425 patent

and will be irreparably harmed unless such infringing activities are enjoined by this Court.

limited to, claims 1 and 10, and other claims which discovery will show are infringed; C. An injunction against Ekahau, each of their officers, agents, servants, employees,

and attorneys, all parent and subsidiary corporations, their assigns and successors in interest, and those persons acting in active concert or participation with them, including distributors and customers, enjoining them from continuing acts of infringement of the 425 patent; D. An accounting for damages under 35 U.S.C. 284 from Ekahau for their respective

infringement of the 425 patent, and the award of damages together with interest as provided by law, such damages to include lost profits and/or reasonable royalties as the Court determines;
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E. F.

An award of all plaintiffs costs and expenses; and Such other and further relief as this Court may deem proper, just and equitable.

DEMAND FOR JURY TRIAL Plaintiff Centrak demands a trial by jury of all issues properly triable by jury in this action.

SORIN ROYER COOPER LLC Attorneys for Plaintiff Source Search Technologies, LLC Two Tower Center Boulevard, 11th Floor East Brunswick, NJ 08816 Telephone: (732) 839-0404 Facsimile: (732) 393-1901 Email: jkaplan@sorinroyercooper.com

Dated: December 13, 2011

By:

s/Jeffrey I. Kaplan/ Jeffrey I. Kaplan (JK 4706)

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