Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 1 of 52 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 11 12 13 14 15 16 INTELLICHECK MOBILISA, INC., a Delaware Corporation, v. WIZZ SYSTEMS L.L.C. d/b/a IDSCAN.NET, a Louisiana Limited Liability Company, Plaintiff, Defendants. No. COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED 17 18 19 20 21 22 23 24 Plaintiff Intellicheck Mobilisa, Inc., through its undersigned counsel, K&L Gates LLP, brings this action against Wizz Systems L.L.C. d/b/a IDScan.net. NATURE OF THE ACTION 1. This action arises under the patent laws of the United States, 35 U.S.C. 1 et seq., based on Defendant s infringement of United States Patent No. 5,864,623 ( the 623 patent ), United States Patent No. 6,463,416 ( the 416 patent ), United States Patent No. 6,920,437 ( the 437 patent ), United States Patent No. 7,478,067 ( the 067 patent ) and United States Patent No. 7,899,751 ( the 751 patent ) (collectively, the Patents-in-Suit ). 25 26 COMPLAINT FOR PATENT INFRINGEMENT - 1 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 2 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 PARTIES 2. Plaintiff Intellicheck Mobilisa, Inc. ( Intellicheck Mobilisa or Plaintiff ) is a Delaware corporation with its principal place of business in Port Townsend, Washington. 3. Intellicheck Mobilisa is recognized as a leading technology company providing wireless technology and identity systems for various applications, including patented technology that instantly reads, analyzes, and verifies encoded data in magnetic stripes and barcodes on government-issued IDs. 4. Defendant Wizz Systems, L.L.C. d/b/a IDScan.net ( IDScan or Defendant ) is a Louisiana limited liability company with substantial Washington contacts, as discussed in more detail below, and those contacts include (but are not limited to) advertising specifically directed to Washington and upon information and belief its substantial sales in Washington. JURISDICTION AND VENUE 5. This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. 271. 6. This Court has subject matter jurisdiction over Intellicheck Mobilisa s claim pursuant to 28 U.S.C. 1331 and 1338(a). 7. This Court has personal jurisdiction over Defendant because Defendant regularly conducts business within, and specifically directs its business activities to, the State of Washington and the Western District of Washington ( this District ). Defendant has purposefully availed itself of the opportunity to conduct business in this state through systematic and continuous dealings in Washington. Defendant s actions that give rise to personal jurisdiction include, but are not limited to the following: (1) establishing a direct connection using pingback technology to Q13 Fox News s website (which serves the Seattle-Tacoma, Wash. market ) to promote a story regarding identity theft in Bellevue, Washington and using that direct connection to sell the accused products to Scan IDs to COMPLAINT FOR PATENT INFRINGEMENT - 2 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 3 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 prevent identity theft at your business ; (2) reporting to its Washington customers in its online advertising materials the Washington Department of Licensing s 2014 decision to transition from the typical 5-year driver s license expiration to a 6-year driver s license expiration ; (3) providing accused products to companies with locations in Washington, including, but not limited to, Trader Joe s, AMC Theaters, and BlueCross BlueShield, (4) stating publicly that its accused products will scan any type of ID or driver s license from any state, including Washington, (5) operating a highly interactive website on which customers, including Washington customers, may directly purchase accused products, (6) providing information on its highly interactive website regarding additional Washington State based news stories/marketing materials; (7) upon information and belief, licensing software from Microsoft, a Washington corporation headquartered in Washington, to enable the accused products, and (8) selling and distributing its products via Amazon.com, a corporation headquartered in Washington. Defendant s business activities not only are directed to, and occur within, this District but also knowingly introduce into the stream of commerce products and/or components of products that infringe the claimed apparatuses of the Patents-in-Suit, and are used to infringe the claimed methods of the Patents-in-Suit. Defendants knew and/or intended that such products would be used in Washington. 8. Venue is proper in the Western District of Washington pursuant to 28 U.S.C. 1391(b)-(c), because a substantial part of the events giving rise to the claims pled herein occurred in the District. Venue also is proper under 28 U.S.C. 1400(b) because Defendant has committed, induced others to commit, or contributed to others committing, acts of infringement in this District. COUNT I INFRINGEMENT OF THE 623 PATENT 9. Intellicheck Mobilisa realleges and incorporates by reference paragraphs 1-8 above as if fully set forth herein. 26 COMPLAINT FOR PATENT INFRINGEMENT - 3 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 4 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 10. On January 26, 1999, the United States Patent and Trademark Office ( USPTO ) issued the 623 patent, titled Authentication System for Driver Licenses. A true and correct copy of the 623 patent is provided as Exhibit A. 11. Intellicheck Mobilisa is the owner of the 623 patent by assignment. 12. Defendant is now and has been directly, contributorily, and by inducement, infringing at least one claim of the 623 patent, both literally and under the doctrine of equivalents. Defendant is violating 35 U.S.C. 271 by selling, offering to sell, making, or using the patented invention in the United States, by actively inducing others to sell, offer to sell, make, or use the patented invention in the United States, and by offering to sell or selling within the United States components of a patented machine, manufacture, combination, or composition, or a material or apparatus for use in practicing a patented process, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in an infringement of such patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 13. Defendant s infringing acts include, but are not limited to, its making, using, selling, and offering for sale (and/or inducing or contributing to the making, using, selling, and offering for sale) products such as VeriScan, VeriScan Online, UniScan Mobile, UniScan Web Mobile, ID Parsing SDK, and M-310S Handheld ID Reader with VeriScan. Those products infringe the system claims of the Patents-in-Suit and, when used, infringe the method claims of those patents. Defendant induces and contributes to its customers use of such products through among other things the instructions it provides at (among other places) its website IDScan.net. 14. Defendant is not, and has not been at any time, licensed under the 623 patent. 15. Defendant s acts of infringement have been, and continue to be, willful and deliberate (and Defendant s indirect infringement was knowing and intentional) as shown in part by prior conversations between representatives of Intellicheck Mobilisa and Defendant, COMPLAINT FOR PATENT INFRINGEMENT - 4 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 5 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 in which Defendant s representatives refused to discontinue infringing the 623 patent despite knowledge of that patent gained when Intellicheck Mobilisa notified Defendant of the patent. 16. Intellicheck Mobilisa has been damaged by Defendant s foregoing acts of infringement of the 623 patent, and Intellicheck Mobilisa will continue to be damaged by such infringement unless enjoined by this Court. Intellicheck Mobilisa is entitled to recover damages adequate to compensate for the infringement under 35 U.S.C. 284. COUNT II INFRINGEMENT OF THE 416 PATENT 17. Intellicheck Mobilisa realleges and incorporates by reference paragraphs 1-8 above as if fully set forth herein. 18. On October 8, 2002, the United States Patent and Trademark Office ( USPTO ) issued the 416 patent, titled Authentication System for Identification Documents. A true and correct copy of the 416 patent is provided as Exhibit B. 19. Intellicheck Mobilisa is the owner of the 416 patent by assignment. 20. Defendant is now and has been directly, contributorily, and by inducement, infringing at least one claim of the 416 patent, both literally and under the doctrine of equivalents. Defendant is violating 35 U.S.C. 271 by selling, offering to sell, making, or using the patented invention in the United States, by actively inducing others to sell, offer to sell, make, or use the patented invention in the United States, and by offering to sell or selling within the United States components of a patented machine, manufacture, combination, or composition, or a material or apparatus for use in practicing a patented process, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in an infringement of such patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 21. Defendant s infringing acts include, but are not limited to, its making, using, selling, and offering for sale (and/or inducing or contributing to the making, using, selling, and offering for sale) products such as VeriScan, VeriScan Online, UniScan Mobile, UniScan COMPLAINT FOR PATENT INFRINGEMENT - 5 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 6 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Web Mobile, ID Parsing SDK, and M-310S Handheld ID Reader with VeriScan. Those products infringe the system claims of the Patents-in-Suit and, when used, infringe the method claims of those patents. Defendant induces and contributes to its customers use of such products through among other things the instructions it provides at (among other places) its website IDScan.net. 22. Defendant is not, and has not been at any time, licensed under the 416 patent. 23. Defendant s acts of infringement have been, and continue to be, willful and deliberate (and Defendant s indirect infringement was knowing and intentional) as shown in part by prior conversations between representatives of Intellicheck Mobilisa and Defendant, in which Defendant s representatives refused to discontinue infringing the 416 patent despite knowledge of that patent gained when Intellicheck Mobilisa notified Defendant of the patent. 24. Intellicheck Mobilisa has been damaged by Defendant s foregoing acts of infringement of the 416 patent, and Intellicheck Mobilisa will continue to be damaged by such infringement unless enjoined by this Court. Intellicheck Mobilisa is entitled to recover damages adequate to compensate for the infringement under 35 U.S.C. 284. COUNT III INFRINGEMENT OF THE 437 PATENT 25. Intellicheck Mobilisa realleges and incorporates by reference paragraphs 1-8 above as if fully set forth herein. 26. On July 19, 2005, the United States Patent and Trademark Office ( USPTO ) issued the 437 patent, titled Authentication System for Identification Documents. A true and correct copy of the 437 patent is provided as Exhibit C. 27. Intellicheck Mobilisa is the owner of the 437 patent by assignment. 28. Defendant is now and has been directly, contributorily, and by inducement, infringing at least one claim of the 437 patent, both literally and under the doctrine of equivalents. Defendant is violating 35 U.S.C. 271 by selling, offering to sell, making, or using the patented invention in the United States, by actively inducing others to sell, offer to COMPLAINT FOR PATENT INFRINGEMENT - 6 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 7 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 sell, make, or use the patented invention in the United States, and by offering to sell or selling within the United States components of a patented machine, manufacture, combination, or composition, or a material or apparatus for use in practicing a patented process, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in an infringement of such patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 29. Defendant s infringing acts include, but are not limited to, its making, using, selling, and offering for sale (and/or inducing or contributing to the making, using, selling, and offering for sale) products such as VeriScan, VeriScan Online, UniScan Mobile, UniScan Web Mobile, ID Parsing SDK, and M-310S Handheld ID Reader with VeriScan. Those products infringe the system claims of the Patents-in-Suit and, when used, infringe the method claims of those patents. Defendant induces and contributes to its customers use of such products through among other things the instructions it provides at (among other places) its website IDScan.net. 30. Defendant is not, and has not been at any time, licensed under the 437 patent. 31. Defendant s acts of infringement have been, and continue to be, willful and deliberate (and Defendant s indirect infringement was knowing and intentional) as shown in part by prior conversations between representatives of Intellicheck Mobilisa and Defendant, in which Defendant s representatives refused to discontinue infringing the 437 patent despite knowledge of that patent gained when Intellicheck Mobilisa notified Defendant of the patent. 32. Intellicheck Mobilisa has been damaged by Defendant s foregoing acts of infringement of the 437 patent, and Intellicheck Mobilisa will continue to be damaged by such infringement unless enjoined by this Court. Intellicheck Mobilisa is entitled to recover damages adequate to compensate for the infringement under 35 U.S.C. 284. 25 26 COMPLAINT FOR PATENT INFRINGEMENT - 7 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 8 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 COUNT IV INFRINGEMENT OF THE 067 PATENT 33. Intellicheck Mobilisa realleges and incorporates by reference paragraphs 1-8 above as if fully set forth herein. 34. On January 13, 2009, the United States Patent and Trademark Office ( USPTO ) issued the 067 patent, titled Authentication System for Identification Documents. A true and correct copy of the 067 patent is provided as Exhibit D. 35. Intellicheck Mobilisa is the owner of the 067 patent by assignment. 36. Defendant is now and has been directly, contributorily, and by inducement, infringing at least one claim of the 067 patent, both literally and under the doctrine of equivalents. Defendant is violating 35 U.S.C. 271 by selling, offering to sell, making, or using the patented invention in the United States, by actively inducing others to sell, offer to sell, make, or use the patented invention in the United States, and by offering to sell or selling within the United States components of a patented machine, manufacture, combination, or composition, or a material or apparatus for use in practicing a patented process, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in an infringement of such patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. 37. Defendant s infringing acts include, but are not limited to, its making, using, selling, and offering for sale (and/or inducing or contributing to the making, using, selling, and offering for sale) products such as VeriScan, VeriScan Online, UniScan Mobile, UniScan Web Mobile, ID Parsing SDK, and M-310S Handheld ID Reader with VeriScan. Those products infringe the system claims of the Patents-in-Suit and, when used, infringe the method claims of those patents. Defendant induces and contributes to its customers use of such products through among other things the instructions it provides at (among other places) its website IDScan.net. 38. Defendant is not, and has not been at any time, licensed under the 067 patent. COMPLAINT FOR PATENT INFRINGEMENT - 8 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 9 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 39. Defendant s acts of infringement have been, and continue to be, willful and deliberate (and Defendant s indirect infringement was knowing and intentional) as shown in part by prior conversations between representatives of Intellicheck Mobilisa and Defendant, in which Defendant s representatives refused to discontinue infringing the 067 patent despite knowledge of that patent gained when Intellicheck Mobilisa notified Defendant of the patent. 40. Intellicheck Mobilisa has been damaged by Defendant s foregoing acts of infringement of the 067 patent, and Intellicheck Mobilisa will continue to be damaged by such infringement unless enjoined by this Court. Intellicheck Mobilisa is entitled to recover damages adequate to compensate for the infringement under 35 U.S.C. 284. COUNT V INFRINGEMENT OF THE 751 PATENT 41. Intellicheck Mobilisa realleges and incorporates by reference paragraphs 1-8 above as if fully set forth herein. 42. On March 1, 2011, the United States Patent and Trademark Office ( USPTO ) issued the 751 patent, titled Parsing and Identification Document in Accordance with a Jurisdictional Format. A true and correct copy of the 751 patent is provided as Exhibit E. 43. Intellicheck Mobilisa is the owner of the 751 patent by assignment. 44. Defendant is now and has been directly, contributorily, and by inducement, infringing at least one claim of the 751 patent, both literally and under the doctrine of equivalents. Defendant is violating 35 U.S.C. 271 by selling, offering to sell, making, or using the patented invention in the United States, by actively inducing others to sell, offer to sell, make, or use the patented invention in the United States, and by offering to sell or selling within the United States components of a patented machine, manufacture, combination, or composition, or a material or apparatus for use in practicing a patented process, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in an infringement of such patent, and not a staple article or commodity of commerce suitable for substantial noninfringing use. COMPLAINT FOR PATENT INFRINGEMENT - 9 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 10 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 45. Defendant s infringing acts include, but are not limited to, its making, using, selling, and offering for sale (and/or inducing or contributing to the making, using, selling, and offering for sale) products such as VeriScan, VeriScan Online, UniScan Mobile, UniScan Web Mobile, ID Parsing SDK, and M-310S Handheld ID Reader with VeriScan. Those products infringe the system claims of the Patents-in-Suit and, when used, infringe the method claims of those patents. Defendant induces and contributes to its customers use of such products through among other things the instructions it provides at (among other places) its website IDScan.net. 46. Defendant is not, and has not been at any time, licensed under the 751 patent. 47. Defendant s acts of infringement have been, and continue to be, willful and deliberate (and Defendant s indirect infringement was knowing and intentional) as shown in part by prior conversations between representatives of Intellicheck Mobilisa and Defendant, in which Defendant s representatives refused to discontinue infringing the 751 patent despite knowledge of that patent gained when Intellicheck Mobilisa notified Defendant of the patent. 48. Intellicheck Mobilisa has been damaged by Defendant s foregoing acts of infringement of the 751 patent, and Intellicheck Mobilisa will continue to be damaged by such infringement unless enjoined by this Court. Intellicheck Mobilisa is entitled to recover damages adequate to compensate for the infringement under 35 U.S.C. 284. JURY DEMAND 49. Intellicheck Mobilisa demands a trial by jury. PRAYER FOR RELIEF WHEREFORE, Intellicheck Mobilisa respectfully prays for a judgment against Defendant: A. Finding that the Patents-in-Suit have been infringed by Defendant; B. Finding that the infringement of the Patents-in-Suit has been willful; 26 COMPLAINT FOR PATENT INFRINGEMENT - 10 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
Case 2:15-cv-00366 Document 1 Filed 03/11/15 Page 11 of 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 C. Permanently enjoining Defendants against further infringement of the Patentsin-Suit; D. Awarding Intellicheck Mobilisa damages permitted by 35 U.S.C. 284, including but not limited to pre-judgment interests and costs and increased damages up to three times the amount of compensatory damages; E. Finding that this is an exceptional case and awarding Intellicheck Mobilisa its costs and reasonable attorneys fees incurred in this action as provided by 35 U.S.C. 285; and equitable. F. Awarding Intellicheck Mobilisa such other relief as the Court deems just and DATED this 11th day of March, 2015. Respectfully submitted, K&L Gates LLP By: s/douglas Greenswag Douglas Greenswag, WSBA #37506 By: s/ Theodore J. Angelis Theodore J. Angelis, WSBA #30300 By: s/ Benjamin Hellerstein Benjamin Hellerstein, WSBA #43104 925 Fourth Avenue, Suite 2900 Seattle, WA 98104 Phone: (206) 623-7580 Fax: (206) 623-7022 Email: doug.greenswag@klgates.com theo.angelis@klgates.com ben.hellerstein@klgates.com Attorneys for Plaintiff Intellicheck Mobilisa, Inc. 22 23 24 25 26 COMPLAINT FOR PATENT INFRINGEMENT - 11 K&L GATES LLP 925 FOURTH AVENUE SUITE 2900 SEATTLE, WASHINGTON 98104-1158 TELEPHONE: (206) 623-7580 FACSIMILE: (206) 623-7022
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