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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALLDIVISIONRPOST HOLDINGS, INC.andRPOSTCOMMUNICATIONSLIMITED,Plaintiffs,v.TREND MICRO INCORPORATED.Defendant.Civil Action No.2:13-cv-1065JURY TRIAL DEMANDED
ORIGINALCOMPLAINT
In this ComplaintagainstDefendantTrend Micro Incorporated,Plaintiffsallege, based ontheirown knowledge with respect to theirown actions and basedoninformation and belief withrespect to all other actions, as follows:
NATUREOF THE ACTION
1.This actionfor willful patent infringementarises under the Patent Laws of theUnited States, namely, 35 U.S.C. §§ 1 et seq.
PARTIES
2.
Plaintiff RPost Communications Limited (“RPC”) is a corporation organized
under the laws of the Nation of Bermuda.It isthe owner of United States Patent No. 8,504,628
(“the ’628patent”)entitled “
System and Method for Verifying Delivery and Integrity of Electronic Messages
.”RPC is also the owner of United States Patent No. 8,484,706 (“the ’706 patent”)entitled “
System for, and Method of, Providing the Transmission, Receipt and Contentof a Reply to an Electronic Message
.”
RPC is also the owner of United States Patent No.
8,468,199 (“the ’199patent”) entitled “System and Method for Verifying Delivery a
nd Integrity
 
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of Electronic Messages.
RPC is also the owner of United States Patent No. 8,224,913
(“
the
’913patent”) entitled “System and Method for Verifying Delivery and Integrity of Electronic
Messages.
RPC is also the owner of United States PatentNo. 8,209,389
(“the ’389patent”)entitled “System and Method for Verifying Delivery and Integrity of Electronic Messages.”
RPC is also the owner of United States Patent No. 7,660,989
(“the ’989patent”) entitled
Systemfor, and Method of, Authenticatingan Electronic Message to a Recipient
.”
The
’628,’706,’199
,
’913,’389, and ’989
patents wereduly and legally issued by the United States Patent andTrademark Office onAugust 6, 2013;July 9, 2013;June 18,2013; July 17, 2012;June 26, 2012;and February10, 2010respectively,after full and fair examination.The
’628,’706, ’199, ’913,’389, and ’989
patentsarevalid and enforceable.True and correct copies of the
’628,’706, ’199,’913,’389, and ’989
patentsareattached as Exhibits A, B,C,D,E, and Frespectively.3.Plaintif
RPost Holdings, Inc. (“RPH”) is a corporation organized under the laws
of the State of Delawarehavingaplace ofbusinessat 555 Republic Drive #200Plano, Texas75074.It isan exclusive licenseefrom RPC of the
’628,’706, ’199, ’913,’389, and ’989
patents.
4.
On informationand belief, DefendantTrend Micro Incorporatedis aCaliforniacorporation having a principal place of business at225 E. John Carpenter Freeway, Suite 1500Irving, Texas 75062.Trendprovidestechnologies that allow users to track, report,analyze, andauthenticatedata regarding electronic messages, including but not limited toInterscan MessagingSecurity Suite, Hosted Email Security, Hosted Email Encryption, ScanMail
TM
, Messaging andCollaboration Security, and Trend Micro SaaS.
 
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5.Trendhas committed acts of infringement and other unlawful acts in this judicialdistrict and does regular business in this judicial district, including providing the technologiesaccused of infringement in this judicial district.6.Oninformation and belief,Trend is aresident of Texas who engages in businessin this state andmaintainsa regular place of business in this state or a designated agent forservice of process in this state.Oninformation and belief,Trendresides in this jurisdictionwithin the meaning of 28 U.S.C. § 1400(b). This proceeding arises, in part, out of business donein this state.Upon information and belief,TrendhasappointedRuth Ann Roman at225 E. JohnCarpenter Freeway, Suite 1500,Irving, Texas 75062as its agent for service of process.
JURISDICTION AND VENUE
7.This Court hassubject matter jurisdiction over this actionunder28 U.S.C. §§1331and1338(a).8.Venue is proper in this district under 28 U.S.C. §§ 1391(b)(2),(c), (d)and/or1400(b). On information and belief,Defendantconductsbusiness in this district, the claimsalleged in this Complaint arise in this district,andthe acts of infringement have taken place andare continuing to take place in this district.9.Oninformation and belief,Defendantis
subject to this Court’s general and
specific personal jurisdiction becauseDefendantshaveminimum contacts within the State of Texas and the Eastern District of Texas, including via thewebsitewww.trendmicro.com, underdue process and/or the Texas Long Arm Statute,Defendanthaspurposefully availed themselvesof the privileges of conducting business in the State of Texas and in theEastern District of Texas;Defendantregularly conductsand solicitsbusiness within the State of Texas and withinthe EasternDistrict of Texas; andPlaintiffs
causes of action arise directly fromDefendant
sbusiness contacts and other activities in the State of Texas and in the Eastern District of Texas.

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