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RUSING LOPEZ & LIZARDI, P.L.L.C. Edward Moomjian II (AZ 016667) Edm@rllaz.com 6363 North Swan Road, Suite 151 Tucson, AZ 85718 (520) 792-4800 Fax: (520) 529-4262 NIRO, HALLER & NIRO Raymond P. Niro, Jr. (IL 6207468) RNiroJr@nshn.com Brian E. Haan (IL 6296654) BHaan@nshn.com Daniel R. Ferri (IL 6303286) DFerri@nshn.com 181 West Madison, Suite 4600 Chicago, IL 60602-4515 (312) 236-0733 Fax: (312) 236-3137 Pro Hac Vice Applications Pending Attorneys for Jedi Technologies, Inc.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1. v. Zoosk, Inc., a Delaware corporation, Defendant. Plaintiff Jedi Technologies, Inc. complains of Defendant Zoosk, Inc. as follows: NATURE OF CASE This is a claim for patent infringement that arises under the patent laws of Jedi Technologies, Inc., an Arizona corporation, Plaintiff, Case No. COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

the United States, Title 35 of the United States Code. This Court has original jurisdiction over the subject matter of this claim under 28 U.S.C. 1331 and 1338(a).

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PARTIES Jedi Technologies, Inc. ("Jedi Technologies") is an Arizona corporation that

has a principal place of business at 11353 East Chuckwagon Circle, Tucson, Arizona, 85749. Jedi Technologies is a privately held technology company that is involved in the research and development of social networking and associated Internet technologies. 3. Jedi Technologies owns and has standing to sue for infringement of United

States Patent No. 8,417,729 B2 (the "'729 Patent"), entitled "System and Method for the Automated Notification of Compatibility Between Real-Time Network Participants," which issued on April 9, 2013. 4. Jedi Technologies also owns and has standing to sue for infringement of

United States Patent No. 7,885,977 B2 (the "'977 Patent"), entitled "System and Method for the Automated Notification of Compatibility Between Real-Time Network Participants," which issued on February 8, 2011. 5. Defendant Zoosk, Inc. ("Zoosk") is a Delaware corporation that has a

principal place of business at 989 Market Street, San Francisco, California 94103. JURISDICTION AND VENUE Zoosk owns and operates an interactive online dating service which it

provides via its website www.zoosk.com and related URLs, as well as via its Zoosk Messenger desktop client and its Zoosk applications for iPhone, iPad, and Android mobile devices. 7. Zoosk provides its interactive online dating service throughout the United

States and conducts substantial business in this judicial district, including providing the interactive online dating services, technologies and methods accused of infringement to residents in this judicial district.

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8.

Zoosk has provided and/or continues to provide its interactive online dating

service to numerous Zoosk members that are residents of Tucson, Arizona, including the following exemplary Zoosk members: Amina, Ekeltra, Vanessa B, Juan, el feo, tuctown bad boy, Cori 32, jwes, Tilis, and others. 9. Zoosk promotes the use of its interactive online dating service for "Online

Dating in Tucson." 10. Zoosk has solicited and/or continues to solicit paid subscriber memberships

to its website members, including residents of Tucson, Arizona, for $12.49 per month, payable by Visa, Mastercard, Amex, or Diners Club, via its www.zoosk.com website. For at least this reason, Zoosk's online interaction with its members, including residents of Tucson, Arizona, is commercial in nature. 11. Zoosk is doing business in this judicial district, has purposefully availed

itself of the privilege of conducting business in this judicial district, thereby invoking its benefits and protections, has established sufficient minimum contacts with the State of Arizona such that it should reasonably and fairly anticipate being brought into court in Arizona, and has purposefully reached out to and directed its activities at residents of Arizona. The patent infringement claims alleged herein arise out of or result from one or more of the foregoing activities. 12. Zoosk has specifically committed acts of infringement in this judicial

district and throughout the State of Arizona. 13. Venue is proper in this district under 28 U.S.C. 1391(b)-(d) and 1400(b). CLAIMS FOR PATENT INFRINGEMENT COUNT I INFRINGEMENT OF U.S. PATENT NO. 8,417,729 B2 14. Paragraphs 1-13 are incorporated by reference.

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15.

Zoosk has infringed and continues to infringe at least claim 26 of the '729

Patent under 35 U.S.C. 271(a) by, among other activities, making, using and/or conducting business through its interactive online dating service website www.zoosk.com and its Zoosk Messenger client. Zoosk has expanded and continues to expand its infringement of claim 26 of the '729 Patent to the mobile market by developing, providing, serving and supporting its Zoosk application for iPhone, iPad, and Android mobile devices. 16. To the extent required by law, Jedi Technologies has complied with the

provisions of 35 U.S.C. 287 with respect to the '729 Patent. 17. The acts of infringement of the '729 Patent by Zoosk have injured Jedi

Technologies, and Jedi Technologies is entitled to recover damages adequate to compensate it for such infringement from Zoosk, but, in no event less than a reasonable royalty. Further, the acts of infringement of the '729 Patent by Zoosk have injured and will continue to injure Jedi Technologies unless and until this Court enters an injunction prohibiting further infringement of the '729 Patent. COUNT II INFRINGEMENT OF U.S. PATENT NO. 7,885,977 B2 18. 19. Paragraphs 1-13 are incorporated by reference. Zoosk has infringed and continues to infringe at least claim 1 of the '977

Patent under 35 U.S.C. 271(a) by, among other activities, making, using and/or conducting business through its interactive online dating service website www.zoosk.com and its Zoosk Messenger client. Zoosk has expanded and continues to expand its infringement of claim 1 of the '977 Patent to the mobile market by developing, providing, serving and supporting its Zoosk application for iPhone, iPad, and Android mobile devices.

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20.

To the extent required by law, Jedi Technologies has complied with the

provisions of 35 U.S.C. 287 with respect to the '977 Patent. 21. The acts of infringement of the '977 Patent by Zoosk have injured Jedi

Technologies, and Jedi Technologies is entitled to recover damages adequate to compensate it for such infringement from Zoosk, but, in no event less than a reasonable royalty. Further, the acts of infringement of the '977 Patent by Zoosk have injured and will continue to injure Jedi Technologies unless and until this Court enters an injunction prohibiting further infringement of the '977 Patent. PRAYER FOR RELIEF WHEREFORE, Plaintiff Jedi Technologies respectfully asks this Court to enter judgment against Defendant Zoosk, Inc. and against its subsidiaries, successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation with them, granting the following relief: a. The entry of judgment in favor of Jedi Technologies and against Zoosk; b. An award of damages adequate to compensate Jedi Technologies for the infringement that has occurred, but in no event less than a reasonable royalty as permitted by 35 U.S.C. 284, together with prejudgment interest from the date the infringement began; c. A finding that this case is exceptional and an award to Jedi Technologies of its reasonable attorneys' fees and costs as provided by 35 U.S.C. 285; d. A permanent injunction prohibiting further infringement of the '729 and '977 Patents; and e. Such other relief that Jedi Technologies is entitled to under law, and any other and further relief that this Court or a jury may deem just and proper.

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JURY DEMAND Jedi Technologies demands a trial by jury on all issues presented in this Complaint. Respectfully submitted this 23rd day of May, 2013. s/ Edward Moomjian II RUSING LOPEZ & LIZARDI, P.L.L.C. Edward Moomjian II (AZ 016667) Edm@rllaz.com NIRO, HALLER & NIRO Raymond P. Niro, Jr. (IL 6207468) RNiroJr@nshn.com Brian E. Haan (IL 6296654) BHaan@nshn.com Daniel R. Ferri (IL 6303286) DFerri@nshn.com Pro Hac Vice Applications Pending Attorneys for Jedi Technologies, Inc.

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