Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 1 of 6 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE - PDF

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Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 1 of 6 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALARM.COM INCORPORATED, Plaintiff, v. TELULAR CORPORATION, Defendant.
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Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 1 of 6 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALARM.COM INCORPORATED, Plaintiff, v. TELULAR CORPORATION, Defendant. C.A. No. JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT 1. This Complaint arises under the patent laws of the United States, 35 U.S.C. 1, et seq. The Parties 2. Plaintiff Alarm.com Incorporated ( Alarm.com is a Delaware corporation with its principal place of business at 8150 Leesburg Pike, Suite 1400, Vienna, Virginia Defendant Telular Corporation ( Telular is a Delaware corporation with its principal place of business at 311 South Wacker Drive, Suite 4300, Chicago, Illinois Jurisdiction and Venue 4. This Court has subject matter jurisdiction pursuant to 28 U.S.C and 1338(a. 5. This Court has personal jurisdiction over Telular at least because Telular is incorporated under the laws of Delaware. 6. Venue is proper in this District pursuant to 28 U.S.C and 1400(b. Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 2 of 6 PageID #: 2 Background 7. Alarm.com is a pioneer and innovator in the home security industry, introducing the industry s first wireless interactive security solution in Its first-to-market innovations include the use of dedicated wireless signaling that is fully integrated into the security control panel and eliminates the line-cutting vulnerability of landline-based security systems, cellularbased fully integrated two-way voice emergency response capability, alerting via text messages and of non-alarm activity, an ability to report anticipated alarm signals even when the intruder destroys the physical alarm panel that generates the alarm signal, and home security apps for major smartphone platforms that allow remote control of security systems from anywhere. 8. Telular originally focused its business on the development of fixed wireless products that enabled customers to integrate computers and other fixed-location devices with wireless networks. It later expanded into other businesses, including alarm monitoring technology. Telular now offers products and services for residential and commercial security under the Telguard brand. These solutions include Telguard Interactive, a suite of technology for alarm monitoring that includes notification and remote control of monitoring systems, and the recently introduced Telguard HomeControl. 9. In 2009, Alarm.com released native mobile apps for iphone and Blackberry devices to enable users to monitor and control their home security system remotely. These apps built upon Alarm.com s existing suite of services for Internet-based notifications and control of home security systems. Alarm.com later released native mobile apps for Android and Windows Phone devices. 10. Telguard quickly became aware of Alarm.com and its state-of-the-art alarm monitoring technology. In early 2010 a Telular employee, Mr. Shawn Welsh, obtained an Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 3 of 6 PageID #: 3 Alarm.com product and account for Alarm.com s monitoring service. Shortly thereafter, Telular published video footage showing use of Alarm.com s products and services on the Vimeo videosharing web site using the name Telular Marketing. In late 2010, Telular proceeded to release Telguard Interactive, its own Internet-based monitoring service, which included the release of mobile apps for iphone, Android and Blackberry devices ( Telguard Interactive. 11. On April 10, 2013 Telular announced a new monitoring solution, Telguard HomeControl, comprising software components, hardware components, and one or more applications for use on, e.g., smartphones ( Telguard HomeControl. According to Telular s published statements and materials, Telguard HomeControl offers the ability to construct user notifications from all home sensors, allows users to remotely arm and disarm their security systems, turn on and off lights, access locks, adjust thermostats and watch video, and provides for two-way voice communications. Alarm.Com s Patents 12. On December 9, 2003, the United States Patent and Trademark Office issued U.S. Patent No. 6,661,340 ( the 340 Patent entitled System and Method for Connecting Security Systems to a Wireless Device. A copy of the 340 Patent is attached to this Complaint as Exhibit A. The 340 Patent is owned by Alarm.com and has been since its date of issue. 13. On November 15, 2005, the United States Patent and Trademark Office issued U.S. Patent No. 6,965,313 ( the 313 Patent entitled System and Method for Connecting Security Systems to a Wireless Device. A copy of the 313 Patent is attached to this Complaint as Exhibit B. The 313 Patent is owned by Alarm.com and has been since its date of issue. 14. On September 26, 2006, the United States Patent and Trademark Office issued U.S. Patent No. 7,113,090 ( the 090 Patent entitled System and Method for Connecting Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 4 of 6 PageID #: 4 Security Systems to a Wireless Device. A copy of the 090 Patent is attached to this Complaint as Exhibit C. The 090 Patent is owned by Alarm.com and has been since its date of issue. 15. On January 8, 2013, the United States Patent and Trademark Office issued U.S. Patent No. 8,350,694 ( the 694 Patent entitled Monitoring System to Monitor a Property with a Mobile Device with a Monitoring Application. A copy of the 694 Patent is attached to this Complaint as Exhibit D. The 694 Patent is owned by Alarm.com and has been since its date of issue. Claim I: Infringement of U.S. Patent No. 6,661, Alarm.com repeats and realleges the allegations of paragraphs 1 through 15 above 17. Telular has infringed the 340 Patent by making, using, selling and/or offering to sell within the United States products and services for providing user notifications of alarm system events, without authorization from Alarm.com. These infringing products and services include at least Telguard Interactive and Telguard HomeControl. Claim II: Infringement of U.S. Patent No 6,965, Alarm.com repeats and realleges the allegations of paragraphs 1 through 15 above 19. Telular has infringed the 313 Patent by making, using, selling and/or offering to sell within the United States products and services for providing user notifications of alarm system events, without authorization from Alarm.com. These infringing products and services include at least Telguard Interactive and Telguard HomeControl. Claim III: Infringement of U.S. Patent No. 7,113, Alarm.com repeats and realleges the allegations of paragraphs 1 through 15 above Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 5 of 6 PageID #: Telular has infringed the 090 Patent by making, using, selling and/or offering to sell within the United States products and services for providing user notifications of alarm system events, without authorization from Alarm.com. These infringing products and services include at least Telguard Interactive and Telguard HomeControl. Claim IV: Infringement of U.S. Patent No. 8,350, Alarm.com repeats and realleges the allegations of paragraphs 1 through 15 above 23. Telular has infringed the 694 Patent by making, using, selling and/or offering to sell within the United States products and services for monitoring a property using a mobile device, without authorization from Alarm.com. These infringing products and services include at least Telguard Interactive and Telguard HomeControl. Prayer for Relief WHEREFORE, Alarm.com prays for the following relief: 1. Awarding Alarm.com damages for Telular s infringement of the 340, 313, 090 and 694 Patents. 2. Permanently enjoining Telular, its officers, agents, servants, employees, attorneys, successors, assigns, and anyone acting in concert therewith or on its behalf, from infringing the 340, 313, 090 and 694 Patents. 3. Awarding Alarm.com interest, the cost of this action and its reasonable attorney s fees. 4. Granting such other and further relief to Alarm.com as this Court may deem just and equitable. Case 1:13-cv RGA Document 1 Filed 05/20/13 Page 6 of 6 PageID #: 6 JURY DEMAND Alarm.com demands a trial by jury on all issues triable of right by a jury. Respectfully submitted, POTTER ANDERSON & CORROON LLP OF COUNSEL: Roger G. Brooks CRAVATH, SWAINE & MOORE LLP Worldwide Plaza 825 Eighth Avenue New York, NY Tel: ( Dated: May 20, / By: /s/ Richard L. Horwitz Richard L. Horwitz (#2246 David E. Moore (#3983 Bindu A. Palapura (#5370 Hercules Plaza 6 th Floor 1313 N. Market Street Wilmington, DE Tel: ( Attorneys for Plaintiff Alarm.com Incorporated
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