Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 1 of 8 Page ID #:1
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`Aaron S. Jacobs (Cal. Bar No. 214953)
`ajacobs@princelobel.com
`James J. Foster
`jfoster@princelobel.com
`Matthew Vella (Cal. Bar No. 314548)
`mvella@princelobel.com
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
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`Attorneys for Plaintiff
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`UNITED STATES DISTRICT COURT
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`CENTRAL DISTRICT OF CALIFORNIA
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`Civil Action No. 8:19-cv-01150
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`COMPLAINT FOR PATENT
`INFRINGEMENT
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`UNILOC 2017 LLC,
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`v.
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`INFOR, INC.,
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`Defendant.
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`Plaintiff, Uniloc 2017 LLC (“Uniloc”), for its complaint against defendant, Infor, Inc.
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`(“Infor”), alleges:
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`1.
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`2.
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`THE PARTIES
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`Uniloc is a Delaware limited liability company.
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`Infor is a Delaware corporation having a regular and established place of business at
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`26250 Enterprise Court in Lake Forest, California, 92630.
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`3.
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`Uniloc brings this action for patent infringement under the patent laws of the United
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`JURISDICTION
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`States, 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331
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`and 1338(a).
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`COUNT I
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`(INFRINGEMENT OF U.S. PATENT NO. 6,324,578)
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`4.
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`Uniloc incorporates paragraphs 1-3 above by reference.
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`3203125.v1
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 2 of 8 Page ID #:2
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`Uniloc is the owner, by assignment, of U.S. Patent No. 6,324,578 (“the ’578
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`Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR
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`MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON A NETWORK,
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`which issued on November 27, 2001 on an application filed on December 14, 1998. A copy of the
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`’578 Patent is attached as Exhibit A.
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`6.
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`The following image from www.infor.com shows that Infor provides numerous
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`solutions over the Internet:
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`The following image from www.infor.com shows that Infor also provides solutions
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`for use on smartphones, such as Workforce mobility:
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`The following image from www.infor.com shows that Infor provides solutions for
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`use on desktop computers, smartphones and tablet devices:
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 3 of 8 Page ID #:3
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`9.
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`The following Infor image shows that one solution provided by Infor and installed
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`on a user’s device is Infor Workplace Management:
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`The following image from www.infor.com shows that Infor provides solutions,
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`such as Workforce Scheduling, that offer users configurable preferences:
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 4 of 8 Page ID #:4
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`The following image from www.infor.com shows that Infor provides solutions,
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`such as Workforce Management, that offer administrators configurable preferences:
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`The following image from www.infor.com also shows that Infor provides solutions,
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`such as Workforce Management, that offer administrators configurable preferences:
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`The following image from Workforce Management also shows that Infor provides
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`solutions, such as Workforce Management, that offer administrators configurable preferences:
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`The following image shows how an unauthorized user is denied access to the
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`Workforce Management product:
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 5 of 8 Page ID #:5
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`15.
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`Infor has infringed at least claim 1 of the ’578 Patent by making, using, offering for
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`sale, and/or selling its software licensing and management system which software and associated
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`backend server architecture allow for installing application programs such as Workforce
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`Management, having configurable preferences and authorized users on a server coupled to a
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`network, distributing an application launcher program to a client, obtaining a user set of the
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`configurable preferences, obtaining an administrator set of configurable preferences, and executing
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`the application program using the user and administrator sets of configurable preferences
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`responsive to a request from a user.
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`Infor has also infringed the ’578 Patent by actively inducing the use of the Infor
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`software licensing and management system. Infor’s customers who used the Infor software
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`licensing and management system in accordance with Infor’s instructions infringed the ’578
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`Patent, as described above. Infor intentionally instructed its customers to infringe through
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`instructions on using the Workforce Management software and Infor system, such as exemplified
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`in the figures above.
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`Infor has also infringed the ’578 Patent by contributing to the infringement by
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`others, including customers using the Infor software licensing and management system, by offering
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`to sell, selling, or otherwise commercially offering use of the system, which was used to infringe
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 6 of 8 Page ID #:6
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`the ’578 Patent, and constituted a material part of the invention. Infor knew portions of the
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`software contained in the accused system were especially written solely for use to implement what
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`Infor knew as infringement of the ’578 Patent. Infor knew those portions had no use, other than
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`for infringement.
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`18.
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`Infor was on notice of the ’578 Patent since, at the latest, the service on Infor on
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`May 12, 2017 of the complaint filed in the previous action between Uniloc and Infor in the Eastern
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`District of Texas. Infor knew and intended (since receiving such notice) that its continued actions
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`actively induced, and contributed to, the infringement of the ’578 Patent.
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`Infor may have infringed the ’578 Patent through other software and architecture
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`utilizing the same or reasonably similar functionality as described above.
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`Uniloc has been damaged by Infor’s infringement of the ’578 Patent.
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`COUNT II
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`(INFRINGEMENT OF U.S. PATENT NO. 7,069,293)
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`Uniloc incorporates by reference paragraphs 1-20 above.
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`Uniloc is the owner, by assignment, of U.S. Patent No. 7,069,293 (“the ’293
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`Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR
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`LICENSING OF APPLICATION PROGRAMS TO A TARGET STATION ON A NETWORK,
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`which issued on June 27, 2006, claiming priority to an application filed on December 14, 1998. A
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`copy of the ’293 Patent is attached as Exhibit B.
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`The following image shows that Infor uses Apache servers for storing and
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`distributing to remote users its software products:
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 7 of 8 Page ID #:7
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`The following image from www.infor.com shows that Infor uses data centers for
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`storing and processing customer data:
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`The following image shows that a user has requested a program from Infor and that
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`Infor has called the Workforce Management software from a source directory and delivered the
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`software to a target directory at the user’s device:
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`Infor has infringed, and continues to infringe, at least claim 1 of the ’293 Patent by
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`making, using, importing, offering for sale, and/or selling the Infor software licensing and
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`management system, which software and associated backend server architecture allow for
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`providing an application program such as Workforce Management for licensing to a network
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`server, specifying source and target directories for the program to be distributed, preparing a file
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`Case 8:19-cv-01150-DOC-KES Document 1 Filed 06/10/19 Page 8 of 8 Page ID #:8
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`packet associated with the program including a segment configured to initiate registration
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`operations for the application program at a target on-demand server and distributing the file packet
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`to the target on-demand server to make the program available for use by a client user.
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`Infor has been on notice of the ’293 Patent since, at the latest, the service on Infor
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`on May 12, 2017 of the complaint in the previous action between Uniloc and Infor in the Eastern
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`District of Texas. Infor knew and intended (since receiving that notice) that its continued actions
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`would infringe the ’293 Patent.
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`Infor may have infringed the ’293 Patent through other software and architecture
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`utilizing the same or reasonably similar functionality as described above.
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`Uniloc has been and is being damaged by Infor’s infringement of the ’293 Patent.
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`PRAYER FOR RELIEF
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`Uniloc requests that the Court enter judgment against Infor as follows:
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`(A)
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`finding that Infor has infringed the ’578 Patent and the ’293 Patent;
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`(B)
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`awarding Uniloc its damages suffered as a result of Infor’s infringement of the ’578
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`Patent and the ’293 Patent;
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`(C)
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`awarding Uniloc its costs, attorneys’ fees, expenses, and interest, and
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`(D)
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`granting Uniloc such other and further relief as the Court may deem just and proper.
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`DEMAND FOR JURY TRIAL
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`Uniloc demands trial by jury on all issues so triable pursuant to Fed. R. Civ. P. 38 and
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`Local Rule 38-1.
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`Dated: June 10, 2019
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`Respectfully submitted,
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`/s/ Aaron S. Jacobs
`Aaron S. Jacobs (Cal. Bar No. 214953)
`ajacobs@princelobel.com
`James J. Foster
`jfoster@princelobel.com
`Matthew Vella (Cal. Bar No. 314548)
`mvella@princelobel.com
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
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