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Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 1 of 152 FILED

2013 Jun-12 PM 02:40


U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF ALABAMA

Intellectual Ventures II LLC, )


a limited liability company, )
)
Plaintiff, )
v. ) Case No. ___________________
)
BBVA Compass Bancshares, Inc., ) (Demand for Jury Trial)
and Compass Bank N.A. d/b/a )
BBVA Compass, )
)
Defendants. )

COMPLAINT FOR PATENT INFRINGEMENT

COMES NOW Plaintiff Intellectual Ventures II LLC and for its complaint

against Defendants BBVA Compass Bancshares, Inc. and Compass Bank N.A.,

doing business as BBVA Compass, hereby alleges as follows:

THE PARTIES

1. Plaintiff Intellectual Ventures II LLC (“Intellectual Ventures II”) is a

Delaware limited liability company having its principal place of business located at

3150 139th Avenue SE, Bellevue, Washington, 98005.

2. Upon information and belief, BBVA Compass Bancshares, Inc.

(“BBVA Compass Bancshares”) is a financial holding company with its principal

place of business at 15 South 20th Street, Birmingham, Alabama 35233.


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3. Upon information and belief, BBVA Compass Bancshares has its

headquarters in this judicial district and transacts substantial business within this

judicial district.

4. Upon information and belief, Compass Bank, N.A., doing business as

BBVA Compass (“BBVA Compass Bank”), is a national banking association with

its principal place of business at 15 South 20th Street, Birmingham, Alabama

35233. Upon information and belief, BBVA Compass Bank is a wholly owned

subsidiary of BBVA Compass Bancshares. BBVA Compass Bancshares and

BBVA Compass Bank will be referred to herein collectively as “BBVA Compass.”

5. Upon information and belief, BBVA Compass Bank has its

headquarters in this judicial district and transacts substantial business within this

judicial district.

6. BBVA Compass offers banking services to individuals and business

in the United States, including Alabama, and particularly within this district.

BBVA Compass provides online banking services via electronic means including,

but not limited to, the web site https://www.bbvacompass.com. In connection

with these online banking services and other systems and services, BBVA

Compass infringes one or more claims of United States Patent No. 5,745,574 (“the

’574 Patent”); United States Patent No. 6,826,694 (“the ’694 Patent””); United

States Patent No. 6,715,084 (“the ’084 Patent); United States Patent No. 6,314,409

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(“the ’409 Patent”); and United States Patent No. 7,634,666 (“the ’666 Patent”)

(collectively the “Patents-in-Suit”).

JURISDICTION AND VENUE

7. This is a civil action for patent infringement under the Patent Laws of

the United States, 35 U.S.C. § 1 et. seq. This Court has subject matter jurisdiction

under 28 U.S.C. §§1331 and 1138(a).

8. This Court has general personal jurisdiction over BBVA Compass

because it has its headquarters and does substantial and continuous business in this

judicial district. This Court has specific jurisdiction over BBVA Compass because

it has committed acts giving rise to this action and has established minimum

contacts within this judicial district such that the exercise of jurisdiction over

BBVA Compass would not offend traditional notions of fair play and substantial

justice.

9. Venue is proper in this judicial district pursuant to 28 U.S.C.

§§1391(b)-(c) and 1400(b) because BBVA Compass has conducted business in this

district and/or provided services to its customers within this judicial district, and

has committed acts of patent infringement within this district giving rise to this

action.

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INTELLECTUAL VENTURES AND THE PATENTS-IN-SUIT

10. Intellectual Ventures Management, LLC (“Intellectual Ventures”) was

founded in 2000. Since its founding, Intellectual Ventures has been deeply

involved in the business of invention. Intellectual Ventures creates inventions and

files patent applications for those inventions; collaborates with others to develop

and patent inventions; and acquires and licenses patents from individual inventors,

universities and other institutions. A significant aspect of Intellectual Ventures’

business is managing the Plaintiff in this case, Intellectual Ventures II.

11. Intellectual Ventures’ business includes purchasing important

inventions from individual inventors and institutions and then licensing the

inventions to those who need them. Through this business, Intellectual Ventures

allows inventors to reap a financial reward from their innovations, which is

frequently difficult for individual inventors to do. To date, Intellectual Ventures

has acquired more than 70,000 IP assets and, in the process, has paid individual

inventors hundreds of millions of dollars for their inventions. Intellectual

Ventures, in turn, has earned more than $3 billion by licensing these patents to

some of the world’s most innovative and successful technology companies who

continue to use them to make computer equipment, software, semiconductor

devices, and a host of other products.

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12. Intellectual Ventures also creates inventions. Intellectual Ventures

has a staff of scientists and engineers who develop ideas in a broad range of fields,

including agriculture, computer hardware, life sciences, medical devices,

semiconductors, and software. Intellectual Ventures has invested millions of

dollars developing such ideas and has filed hundreds of patent applications on its

inventions every year, making it one of the top patent filers in the world.

Intellectual Ventures has also invested in laboratory facilities to assist with the

development and testing of new ideas.

13. Intellectual Ventures also creates inventions by collaborating with

inventors and research institutions around the world. For example, Intellectual

Ventures has developed inventions by selecting a technical challenge, requesting

proposals for inventions to solve the challenge from inventors and institutions,

selecting the most promising ideas, rewarding the inventors and institutions for

their contributions, and filing patent applications on the ideas. Intellectual

Ventures has invested millions of dollars in this way and has created a network of

more than 4,000 inventors worldwide.

14. On April 28, 1998, the ’574 Patent, titled “Security Infrastructure For

Electronic Transactions,” was duly and lawfully issued by the United States patent

and Trademark Office (“PTO”). A copy of the ’574 Patent is attached hereto as

Exhibit A.

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15. On November 30, 2004, the ’694 Patent, titled “High Resolution

Access Control,” was duly and lawfully issued by the PTO. A copy of the ’694

Patent is attached hereto as Exhibit B.

16. On March 30, 2004, the ’084 Patent, titled “Firewall System And

Method Via Feedback From Broad-Scope Monitoring For Intrusion Detection,”

was duly and lawfully issued by the PTO. A copy of the ’084 Patent is attached

hereto as Exhibit C.

17. On November 6, 2001, the ’409 Patent, titled “System For Controlling

Access And Distribution of Digital Property,” was duly and lawfully issued by the

PTO. A copy of the ’409 Patent is attached hereto as Exhibit D.

18. On December 15, 2009, the ’666 Patent, titled “Crypto-Engine For

Cryptographic Processing Of Data,” was duly and lawfully issued by the PTO. A

copy of the ’666 Patent is attached hereto as Exhibit E.

19. Intellectual Ventures II is the owner and assignee of all right, title and

interest in and to the Patents-in-Suit and holds the right to sue and recover damages

for infringement thereof, including past damages.

Count I

INFRINGEMENT OF U.S. PATENT NO. 5,745,574

20. Paragraphs 1-19 are reincorporated by reference as if fully set forth

herein.

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21. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has directly infringed and continues to directly infringe,

literally and/or under the doctrine of equivalents, at least claim 23 of the ’574

Patent by making, using, providing, systems and services that comply with the PCI

Data Security Standard for encrypting data during communication sessions,

including, but not limited to, its website.

22. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass also has and continues to indirectly infringe at least claim 23

of the ’574 Patent by inducing others to infringe and/or contributing to the

infringement of others, including third party users of such systems and services in

this judicial district and elsewhere in the United States. Specifically, Intellectual

Ventures II is informed and believes, and thereon alleges, that BBVA Compass has

actively induced and continues to induce the infringement of at least claim 23 of

the ’574 Patent at least by actively inducing the use of such systems and services

by third party users in the United States. Intellectual Ventures II is informed and

believes, and thereon alleges, that BBVA Compass knew or should have known

that its conduct would induce others to encrypt data during a communication

sessions in a manner that infringes the ’574 Patent. Intellectual Ventures II is

informed and believes, and thereon alleges, that these third parties have infringed

and will continue to infringe the ’574 Patent in violation of 35 U.S.C. § 271(a) by

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using the infringing system. Intellectual Ventures II is informed and believes, and

thereon alleges, that BBVA Compass through at least its website at

https://www.bbvacompass.com actively induced its customers to infringe the ’574

Patent.

23. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has contributorily infringed and continues to contributorily

infringe at least claim 23 of the ’574 Patent by providing within the United States

infringing systems and services that constitute a material part of the claimed

invention and are not staple articles of commerce suitable for substantial non-

infringing use. Intellectual Ventures II is informed and believes, and thereon

alleges, that these third parties have infringed and will infringe the ’574 Patent in

violation of 35 U.S.C. § 271(a) by using the infringing system.

24. Intellectual Ventures II has provided written notice via a letter to

BBVA Compass of its infringement of at least claim 23, and BBVA Compass also

has written notice of its infringement by virtue of the filing and service of this

Complaint.

25. Intellectual Ventures II has suffered damages as a result of BBVA

Compass’ infringement of the ’574 Patent in an amount to be proven at trial.

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Count II

INFRINGEMENT OF U.S. PATENT NO. 6,826,694

26. Paragraphs 1-19 are reincorporated by reference as if fully set forth

herein.

27. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has directly infringed and continues to directly infringe,

literally and/or under the doctrine of equivalents, at least claim 1 of the ’694 Patent

by making, using, providing, offering to sell and/or selling its Small Business

Merchant system/service.

28. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass also has and continues to indirectly infringe at least claim 1

of the ’694 Patent by inducing others to infringe and/or contributing to the

infringement of others, including third party users of its Small Business Merchant

service/system in this judicial district and elsewhere in the United States.

Specifically, Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has actively induced and continues to induce the

infringement of at least claim 1 of the ’694 Patent at least by actively inducing the

use of its Small Business Merchant system/service by third party users in the

United States. Intellectual Ventures II is informed and believes, and thereon

alleges, that BBVA Compass knew or should have known that its conduct would

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induce others to use these systems in a manner that infringes the ’694 Patent.

Intellectual Ventures II is informed and believes, and thereon alleges, that these

third parties have infringed and will infringe the ’694 Patent in violation of 35

U.S.C. § 271(a) by using the infringing system. Intellectual Ventures II is

informed and believes, and thereon alleges, that BBVA Compass through at least

its website at https://bbvacompass.com actively induced its customers to infringe

the ’694 Patent.

29. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has contributorily infringed and continues to contributorily

infringe at least claim 1 of the ’694 Patent by providing, selling and/or offering to

sell within the United States infringing products that constitute a material part of

the claimed invention and are not staple articles of commerce suitable for

substantial non-infringing use. Intellectual Ventures II is informed and believes,

and thereon alleges, that these third parties have infringed and will infringe the

’694 Patent in violation of 35 U.S.C. § 271(a) by using the infringing system.

30. Intellectual Ventures II has provided written notice via a letter to

BBVA Compass of its infringement of at least claim 1, and BBVA Compass also

has written notice of its infringement by virtue of the filing and service of this

Complaint.

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31. Intellectual Ventures II has suffered damages as a result of BBVA

Compass’ infringement of the ’694 Patent in an amount to be proven at trial.

Count III

INFRINGEMENT OF U.S. PATENT NO. 6,715,084

32. Paragraphs 1-19 are reincorporated by reference as if fully set forth

herein.

33. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has directly infringed and continues to directly infringe,

literally and/or under the doctrine of equivalents, at least claim 26 of the ’084

Patent by making, using, offering to sell and/or selling its Small Business

Merchant system/service that uses PCI Data Security Standard compliant intrusion

detection and prevention.

34. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA also has and continues to indirectly infringe at least claim 26 of the

’084 Patent by inducing others to infringe and/or contributing to the infringement

of others, including third party users of its Small Business Merchant

system/service in this judicial district and elsewhere in the United States.

Specifically, Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has actively induced and continues to induce the

infringement of at least claim 26 of the ’084 Patent at least by actively inducing the

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use of its Small Business Merchant system/service by third party users in the

United States. Intellectual Ventures II is informed and believes, and thereon

alleges, that BBVA Compass knew or should have known that its conduct would

induce others to use its Small Business Merchant system/service in a manner that

infringes the ’084 Patent. Intellectual Ventures II is informed and believes, and

thereon alleges, that these third parties have infringed and will infringe the ’084

Patent in violation of 35 U.S.C. § 271(a) by using the infringing system.

Intellectual Ventures II is informed and believes, and thereon alleges, that BBVA

Compass through at least its website https://www.bbvacompass.com actively

induced its customers to infringe the ’084 Patent.

35. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has contributorily infringed and continues to contributorily

infringe at least claim 26 of the ’084 Patent by providing, selling and/or offering to

sell within the United States infringing systems and services that constitute a

material part of the claimed invention and are not staple articles of commerce

suitable for substantial non-infringing use. Intellectual Ventures II is informed and

believes, and thereon alleges, that these third parties have infringed and will

infringe the ’084 Patent in violation of 35 U.S.C. § 271(a) by using the infringing

system.

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36. Intellectual Ventures II has provided written notice via a letter to

BBVA Compass of its infringement of at least claim 26, and BBVA Compass also

has written notice of its infringement by virtue of the filing and service of this

Complaint.

37. Intellectual Ventures II has suffered damages as a result of BBVA

Compass’ infringement of the ’084 Patent in an amount to be proven at trial.

Count IV

INFRINGEMENT OF U.S. PATENT NO. 6,314,409

38. Paragraphs 1-19 are reincorporated by reference as if fully set forth

herein.

39. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has directly infringed and continues to directly infringe,

literally and/or under the doctrine of equivalents, at least claim 38 of the ’409

Patent by making, using, providing, offering to sell and/or selling its Mobility Pack

and services that use PCI Data Security Standard technology for protecting

customer information and account data.

40. Intellectual Ventures II is informed and believes, and thereon alleges,

that First National also has and continues to indirectly infringe at least claim 38 of

the ’409 Patent by inducing others to infringe and/or contributing to the

infringement of others, including third party users of such systems and services in

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this judicial district and elsewhere in the United States. Specifically, Intellectual

Ventures II is informed and believes, and thereon alleges, that BBVA Compass has

actively induced and continues to induce the infringement of at least claim 38 of

the ’409 Patent at least by actively inducing the use of such systems and services in

the United States. Intellectual Ventures II is informed and believes, and thereon

alleges, that BBVA Compass knew or should have known that its conduct would

induce others to use its systems and services in a manner that infringes the ’409

Patent. Intellectual Ventures II is informed and believes, and thereon alleges, that

these third parties have infringed and will infringe the ’409 Patent in violation of

35 U.S.C. § 271(a) by using the infringing system. Intellectual Ventures II is

informed and believes, and thereon alleges, that BBVA Compass through at least

its website https://www.bbvacompass.com actively induced its customers to

infringe the ’409 Patent.

41. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has contributorily infringed and continues to contributorily

infringe at least claim 38 of the ’409 Patent by providing, selling and/or offering to

sell within the United States infringing systems and services that constitute a

material part of the claimed invention and are not staple articles of commerce

suitable for substantial non-infringing use. Intellectual Ventures II is informed and

believes, and thereon alleges, that these third parties have infringed and will

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infringe the ’409 Patent in violation of 35 U.S.C. § 271(a) by using the infringing

system.

42. Intellectual Ventures II has provided written notice via a letter to

BBVA Compass of its infringement of at least claim 38, and BBVA Compass also

has written notice of its infringement by virtue of the filing and service of this

Complaint.

43. Intellectual Ventures II has suffered damages as a result of BBVA

Compass’ infringement of the ’409 Patent in an amount to be proven at trial.

Count V

INFRINGEMENT OF U.S. PATENT NO. 7,634,666

44. Paragraphs 1-19 are reincorporated by reference as if fully set forth

herein.

45. Intellectual Ventures II is informed and believes, and thereon alleges,

that BBVA Compass has directly infringed and continues to directly infringe,

literally and/or under the doctrine of equivalents, at least claim 4 of the ’666 Patent

by using systems or services that use IBM System z mainframes.

46. Intellectual Ventures II has provided written notice via a letter to

BBVA Compass of its infringement of at least claim 4, and BBVA Compass also

has written notice of its infringement by virtue of the filing and service of this

Complaint.

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47. Intellectual Ventures II has suffered damages as a result of BBVA

Compass’ infringement of the ’666 Patent in an amount to be proven at trial.

PRAYER FOR RELIEF

WHEREFORE, Intellectual Ventures II respectfully prays that this Court:

A. Enter judgment in favor of Intellectual Ventures II that BBVA

Compass has infringed the ’574 Patent;

B. Enter judgment in favor of Intellectual Ventures II that BBVA

Compass has infringed the ’694 Patent;

C. Enter judgment in favor of Intellectual Ventures II that BBVA

Compass has infringed the ’084 Patent;

D. Enter judgment in favor of Intellectual Ventures II that BBVA

Compass has infringed the ’409 Patent;

E. Enter judgment in favor of Intellectual Ventures II that BBVA

Compass has infringed the ’666 Patent

F. Enter judgment that Intellectual Ventures II be awarded damages

adequate to compensate it for BBVA Compass’ past infringement and

any continuing or future infringement of the Patents-in-Suit up until

the date such judgment is entered, including pre-judgment and post-

judgment interest, costs and disbursements as justified under 35

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U.S.C. § 284 and, if necessary, to adequately compensate Intellectual

Ventures II for BBVA Compass’ infringement, an accounting;

G. Enter judgment that Intellectual Ventures II be awarded attorney fees,

costs and expenses incurred in prosecuting this action; and

H. Order that Intellectual Ventures II be granted such other, different,

and additional relief as this Court deems equitable and proper under

the circumstances.

DEMAND FOR JURY TRIAL

Plaintiff Intellectual Ventures II hereby demands trial by jury as to all issues

so triable in this civil action.

Dated: June 12, 2013.

Respectfully submitted,

/s/ A.H. “Nick” Gaede, Jr.


A.H. “Nick” Gaede, Jr. (ASB-9661-G64A)

/s/ Jennifer A. Hanson


Jennifer A. Hanson (ASB-2100-E58H)

BAINBRIDGE, MIMS, ROGERS & SMITH, LLP


The Luckie Building, Suite 415
600 Luckie Drive (35223)
Post Office Box 530886
Birmingham, Alabama 35253
Telephone: (205) 879-1100
Facsimile: (205) 879-4300
ngaede@bainbridgemims.com
jhanson@bainbridgemims.com

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OF COUNSEL:

Ian Feinberg
Elizabeth Day
Marc Belloli
FEINBERG DAY ALBERTI & THOMPSON LLP
1600 El Camino Real, Suite 280
Menlo Park, CA 94025
Direct: 650-618-4360
Fax: 650-618-4368
ifeinberg@feinday.com
eday@feinday.com
mbelloli@feinday.com
(pro hac vice applications forthcoming)

Counsel for Plaintiff

DEFENDANTS TO BE PERSONALLY SERVED AT THE BELOW:

BBVA Compass Bancshares, Inc.


B.S. Clanton
15 South 20th Street
Birmingham, Alabama 35296

Compass Bank, N.A. d/b/a BBVA Compass


15 South 20th Street
Birmingham, Alabama 35233

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EXHIBIT A
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EXHIBIT B
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EXHIBIT C
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EXHIBIT D
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EXHIBIT E
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