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.
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 2 of 152 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 2
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 3 of 152 ( 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. 3
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 4 of 152 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. 4
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 5 of 152 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. 5
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 6 of 152 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. 6
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 7 of 152 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 7
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 8 of 152 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 noninfringing 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. 8
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 9 of 152 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 9
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 10 of 152 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. 10
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 11 of 152 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 11
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 12 of 152 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. 12
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 13 of 152 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 13
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 14 of 152 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 14
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 15 of 152 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. 15
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 16 of 152 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 postjudgment interest, costs and disbursements as justified under 35 16
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 17 of 152 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 17
Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 18 of 152 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 18
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Case 2:13-cv-01106-UNAS-AKK Document 1 Filed 06/12/13 Page 135 of 152 EXHIBIT E
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