Case 8:19-cv-01150-JLS-ADS Document 30 Filed 10/10/19 Page 1 of 5 Page ID #:279
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`Aaron S. Jacobs (Cal. Bar No. 214953)
`ajacobs@princelobel.com
`James J. Foster
`jfoster@princelobel.com
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`
`Matthew D. Vella (Cal. State Bar No. 314548)
`mvella@princelobel.com
`PRINCE LOBEL TYE LLP
`357 S. Coast Highway, Suite 200
`Laguna Beach, CA 92651
`Tel: (949) 232-6375
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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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`SANTA ANA DIVISION
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`Civil Action No. 8:19-cv-01150-JLS-ADS
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`AMENDED COMPLAINT
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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 2017”), for its Amended Complaint against defendant,
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`Infor, Inc. (“Infor”), alleges:
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`1.
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`THE PARTIES
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`Uniloc 2017 2017 is a Delaware limited liability company.
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`Infor is a Delaware corporation.
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`JURISDICTION
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`3.
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`Uniloc 2017 brings this action for patent infringement under the patent laws of the
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`United States, 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28 U.S.C.
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`§§ 1331 and 1338(a).
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`3307527.v1
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`Case 8:19-cv-01150-JLS-ADS Document 30 Filed 10/10/19 Page 2 of 5 Page ID #:280
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`4.
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`5.
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`COUNT I
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`(INFRINGEMENT OF U.S. PATENT NO. 6,324,578)
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`Uniloc 2017 incorporates paragraphs 1-3 above by reference.
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`Uniloc 2017 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 was attached to the Complaint, Docket No. 1, as Exhibit A.
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`6.
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`Infor infringed claims 1-38 of the ’578 Patent by making, using, offering for sale,
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`and selling its software licensing and management system, which software and associated backend
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`server architecture allowed for installing application programs such as Infor CRM Cloud, having
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`configurable preferences and authorized users on a server coupled to a network, distributing an
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`application launcher program to a client, obtaining a user set of the configurable preferences,
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`obtaining an administrator set of configurable preferences, and executing the application program
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`using the user and administrator sets of configurable preferences responsive to a request from a
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`user.
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`7.
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`As an example, the attached Exhibit C to this Amended Complaint demonstrates
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`that Infor’s implementation of its CRM Cloud application program incorporated each limitation of
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`claims 1-38. Infor’s implementation of other Infor products similarly incorporated each limitation
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`of claims 1-38 of the ’578 patent.
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`8.
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`Infor 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 Infor CRM Cloud software and Infor system.
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`9.
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`Infor also infringed the ’578 Patent by contributing to the infringement by others,
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`including customers using the Infor software licensing and management system, by offering to sell,
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`selling, or otherwise commercially offering use of the system, which was used to infringe the ’578
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`Case 8:19-cv-01150-JLS-ADS Document 30 Filed 10/10/19 Page 3 of 5 Page ID #:281
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`Patent, and constituted a material part of the invention. Infor knew portions of the software
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`contained in the accused system were especially written solely for use to implement what Infor
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`knew as infringement of the ’578 Patent. Infor knew those portions had no use, other than for
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`infringement.
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`10.
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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 USA and Infor in the
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`Eastern District of Texas. Infor knew and intended (since receiving such notice) that its continued
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`actions 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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`12.
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`Uniloc 2017 was 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 2017 incorporates by reference paragraphs 1-12 above.
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`Uniloc 2017 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 was attached as Exhibit B to the Complaint. Docket No. 1.
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`15.
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`Info distributes its application programs to a centralized network management
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`server for further distribution to edge servers.
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`16.
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`Infor specifies to the centralized network management server both where the
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`application programs can be found and where the application programs will be sent.
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`Infor prepares a file package associated with each application program that includes
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`code to cause the edge servers to register the application program on the edge server to make it
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`recognized by and available to users at a client, who can then request execution of the application
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`program.
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`Case 8:19-cv-01150-JLS-ADS Document 30 Filed 10/10/19 Page 4 of 5 Page ID #:282
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`18.
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`Infor infringed, and continues to infringe, claims 1, 3-5, 8, 12, 14, 17, and 19 of the
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`’293 Patent by making, using, importing, offering for sale, and selling the Infor software licensing
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`and management system, which software and associated backend server architecture allow for
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`providing an application program such as Infor CRM Cloud for licensing to a network server,
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`specifying source and target directories for the program to be distributed, preparing a file packet
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`associated with the program including a segment configured to initiate registration operations for
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`the application program at a target on-demand server, and distributing the file packet to the target
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`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 USA and Infor in the
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`Eastern District of Texas. Infor knew and intended (since receiving that notice) that its continued
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`actions would infringe the ’293 Patent.
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`20.
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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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`21.
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`Uniloc 2017 has been and is being damaged by Infor’s infringement of the ’293
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`Patent.
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`PRAYER FOR RELIEF
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`Uniloc 2017 requests that the Court enter judgment against Infor:
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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 2017 its damages suffered as a result of Infor’s infringement of the
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`’578 Patent and the ’293 Patent;
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`(C)
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`awarding Uniloc 2017 its costs, attorneys’ fees, expenses, and interest, and
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`(D)
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`granting Uniloc 2017 such other and further relief as the Court may deem just and
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`proper.
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`Case 8:19-cv-01150-JLS-ADS Document 30 Filed 10/10/19 Page 5 of 5 Page ID #:283
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`Dated: October 10, 2019
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`Respectfully submitted,
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`/s/ James J. Foster
`Aaron S. Jacobs (Cal. Bar No. 214953)
`ajacobs@princelobel.com
`James J. Foster
`jfoster@princelobel.com
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`
`Matthew D. Vella (Cal. State Bar No. 314548)
`mvella@princelobel.com
`PRINCE LOBEL TYE LLP
`357 S. Coast Highway, Suite 200
`Laguna Beach, CA 92651
`Tel: (949) 232-6375
`
`Attorneys for Plaintiff
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