PT Diagnostics v. Hamilton Sundstrand

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Official Complaint for Patent Infringement in Civil Action No. 2:11-cv-00510: PT Diagnostics, LLC v. Hamilton Sundstrand Corporation. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l4WN for more info.
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   1 IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONPT DIAGNOSTICS, LLC, Plaintiff, v.HAMILTON SUNDSTRAND CORPORATION, Defendant.  Civil Action No. ________Jury Trial DemandedCOMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement arising under the Patent Laws of the UnitedStates of America, 35 U.S.C. §1 et seq. in which Plaintiff PT Diagnostics, LLC makes thefollowing allegations against Defendant Hamilton Sundstrand Corporation. PARTIES  1.   Plaintiff PT Diagnostics, LLC (“PT”) is a Texas limited liability company havinga principal place of business at 719 W. Front Street, Suite 242, Tyler, Texas 75702.2.   On information and belief, Defendant Hamilton Sundstrand Corporation(“Hamilton Sundstrand”) is a Delaware corporation with its principal office at One FinancialPlaza, Hartford, Connecticut 06101. Hamilton Sundstrand may be served via its registeredagent, CT Corporation System, 350 N. St. Paul Street, Suite 2900, Dallas, Texas 75201. JURISDICTION AND VENUE 3.   This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has srcinal subject matter jurisdiction pursuant to 28 U.S.C.§§ 1331 and 1338(a).4.   On information and belief, Hamilton Sundstrand is subject to this Court's specificand general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute,   2   due at least to its substantial business in this forum, including: (i) at least a portion of theinfringements alleged herein; and (ii) regularly doing or soliciting business, engaging in otherpersistent courses of conduct, and/or deriving substantial revenue from goods and servicesprovided to individuals in Texas and in this Judicial District.5.   Venue is proper in this district under 28 U.S.C. §§ 1391(c) and 1400(b). Oninformation and belief, Hamilton Sundstrand has transacted business in this district, and hascommitted and/or induced acts of patent infringement in this district. COUNT IINFRINGEMENT OF U.S. PATENT NO. 6,567,729 6.   Plaintiff PT realleges and incorporates by reference paragraphs 1-5 above, as if fully set forth herein.7.   Plaintiff PT is the owner by assignment of United States Patent No. 6,567,729(“the ’729 patent”) entitled “System And Method Of Analyzing Aircraft Removal Data ForPreventative Maintenance.” The ’729 patent was duly and legally issued by the United StatesPatent and Trademark Office on May 20, 2003. A true and correct copy of the ’729 patent isincluded as Exhibit A.8.   On information and belief, Hamilton Sundstrand has infringed and continues toinfringe the ’729 patent in the State of Texas, in this judicial district, and elsewhere in the UnitedStates, by, among other things, making, using, importing, offering for sale, and/or sellingpreventative airplane maintenance products and services that process data gathered from theoperation of airplanes. Such products and services include, by way of example and withoutlimitation, HSPS Customer Web Center, which is covered by one or more claims of the ’729patent, including but not limited to claim 19. By making, using, importing, offering for sale,and/or selling such products and services that are covered by one or more claims of the ’729   3   patent, Hamilton Sundstrand has injured PT and is thus liable to PT for infringement of the ’729patent pursuant to 35 U.S.C. § 271.9.   As a result of Hamilton Sundstrand’s infringement of the ’729 patent, Plaintiff PThas suffered monetary damages in an amount adequate to compensate for Hamilton Sundstrand’sinfringement, but in no event less than a reasonable royalty for the use made of the invention byHamilton Sundstrand together with interest and costs as fixed by the Court, and Plaintiff PT willcontinue to suffer damages in the future unless Hamilton Sundstrand’s infringing activities areenjoined by this Court.10.   Unless a permanent injunction is issued enjoining Hamilton Sundstrand and itsagents, servants, employees, representatives, affiliates, and all others acting or in active concerttherewith from infringing the ’729 patent, Plaintiff PT will be greatly and irreparably harmed.  COUNT IIINFRINGEMENT OF U.S. PATENT NO. 6,732,027 11.   Plaintiff PT realleges and incorporates by reference paragraphs 1-14 above, as if fully set forth herein.12.   Plaintiff PT is the owner by assignment of United States Patent No. 6,732,027(“the ’027 patent”) entitled “System And Method Of Analyzing Operational Source Data.” The’027 patent was duly and legally issued by the United States Patent and Trademark Office onMay 4, 2004. A true and correct copy of the ’027 patent is included as Exhibit B.13.   On information and belief, Hamilton Sundstrand has infringed and continues toinfringe the ’027 patent in the State of Texas, in this judicial district, and elsewhere in the UnitedStates, by, among other things, making, using, importing, offering for sale, and/or sellingpreventative airplane maintenance products and services that process data gathered from the   4   operation of airplanes. Such products and services include, by way of example and withoutlimitation, HSPS Customer Web Center, which is covered by one or more claims of the ’027patent, including but not limited to claim 14. By making, using, importing, offering for sale,and/or selling such products and services that are covered by one or more claims of the ’027patent, Hamilton Sundstrand has injured PT and is thus liable to PT for infringement of the ’027patent pursuant to 35 U.S.C. § 271.14.   As a result of Hamilton Sundstrand’s infringement of the ’027 patent, Plaintiff PThas suffered monetary damages in an amount adequate to compensate for Hamilton Sundstrand’sinfringement, but in no event less than a reasonable royalty for the use made of the invention byHamilton Sundstrand, together with interest and costs as fixed by the Court, and Plaintiff PT willcontinue to suffer damages in the future unless Hamilton Sundstrand’s infringing activities areenjoined by this Court.15.   Unless a permanent injunction is issued enjoining Hamilton Sundstrand and itsagents, servants, employees, representatives, affiliates, and all others acting or in active concerttherewith from infringing the ’027 patent, Plaintiff PT will be greatly and irreparably harmed.  COUNT IIIINFRINGEMENT OF U.S. PATENT NO. 6,959,236 16.   Plaintiff PT realleges and incorporates by reference paragraphs 1-21 above, as if fully set forth herein.17.   Plaintiff PT is the owner by assignment of United States Patent No. 6,959,236(“the ’236 patent”) entitled “System And Method Of Analyzing Operational Source Data.” The’236 patent was duly and legally issued by the United States Patent and Trademark Office onOctober 25, 2005. A true and correct copy of the ’236 patent is included as Exhibit C.
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