Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 1 of 12
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`DICKINSON WRIGHT PLLC
`MICHAEL N. FEDER (Nevada Bar #7332)
`JOHN L. KRIEGER (Nevada Bar #6023)
`3883 Howard Hughes Parkway, Suite 800
`Las Vegas, Nevada 89169
`Tel: (702) 550-4400
`Fax: (844) 670-6009
`Email: mfeder@dickinson-wright.com
`Email: jkrieger@dickinson-wright.com
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`STANISLAV TORGOVITSKY (Pro hac vice to be submitted)
`1825 Eye Street N.W., Suite 900
`Washington, D.C. 20006
`Tel: (202) 659-6925
`Fax: (844) 670-6009
`Email: storgovitsky@dickinson-wright.com
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`Attorneys for Plaintiff LiveHelpNow, LLC
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`UNITED STATES DISTRICT COURT
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`LIVEHELPNOW, LLC,
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` Plaintiff,
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`vs.
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`TAWK TO INC.,
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`DISTRICT OF NEVADA
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`Case No.
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`COMPLAINT
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`JURY TRIAL DEMANDED
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`Defendants.
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`Plaintiff LiveHelpNow, LLC (“LHN” or “Plaintiff”), by and through its undersigned
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`attorneys, files this complaint for Patent Infringement against Defendant tawk.to, Inc. (“Tawk”)
`and in support thereof alleges as follows:
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`SUMMARY
`This is an action for patent infringement of five separate patents under the patent
`1.
`laws of the United States, 35 U.S.C. § 1, et seq. LHN seeks damages, preliminary and permanent
`injunctive relief, and recovery of its reasonable costs and attorneys’ fees.
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`Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 2 of 12
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`LHN is the leading provider of enterprise-level live chat software servicing more
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`than 6,000 companies with over 22,000 users, and more than 30,000 websites. Collectively, the
`LHN Patents, as defined herein, cover aspects of LHN’s pioneering inventions in the area of
`Internet based applications improving real-time communication between website operators and
`website visitors (“live chatting”) including monitoring, gathering, managing and sharing of
`information by providing whisper technology (“LHN Whisper”), or ability for a website operator
`to communicate a message to another operator directly in the active chat session, while this
`message remains hidden to the website visitors/customers.
`LHN Whisper provides many advantages previously not available to website
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`operators, such as: (a) coaching for training newly hired operators more quickly than traditional
`methods would allow; and (b) ability for expert operators to "chime in" on the chats of less
`experienced operators who, for example, may not have the skills required to answer complex
`visitor/customer inquiries in full detail thus improving customer support.
`Many competitors that provide live chatting, including Defendant, adopted LHN’s
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`inventions and transitioned, at least in part, to the use of technology improperly copying LHN
`Whisper in their live chatting products. During the COVID pandemic, like many of its
`competitors, LHN experienced financial uncertainty, and therefore, had to focus its available
`resources only on a very small fraction of such competitors, those that actually engaged in
`meaningful business discussions with LHN. Unlike its industry peers, Tawk has remained silent,
`electing to continue copying LHN’s technology instead.
`As demonstrated by Defendant’s infringement of the LHN Patents, LHN Whisper
`5.
`is an integral part of Tawk’s live chatting products.
`THE PARTIES
`Plaintiff LHN is a Pennsylvania limited liability company with a principal place
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`of business located at 515 S West End Blvd, Suite 202, Quakertown, Pennsylvania 18951.
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`Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 3 of 12
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`LHN is informed and believes, and thereupon alleges that Defendant Tawk is a
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`corporation organized and existing under the laws of the State of Nevada, with its principal place
`of business at 187 East Warm Springs Road, Suite B298, Las Vegas, Nevada, 89119.
`JURISDICTION AND VENUE
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a) because this Complaint includes a cause of action for patent infringement under the patent
`laws of the United States, including, but not limited to, 35 U.S.C. §§271, 281, 283-285, and 287.
`This case primarily involves a federal question. Complete diversity of citizenship also exists, and
`the amount in controversy exceeds $75,000.
`This Court has personal jurisdiction over Defendant Tawk because it resides in
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`this District, has transacted business in this District, has derived substantial revenue from goods
`and services offered for sale and/or sold in this District, and/or has established sufficient minimum
`contacts with the State of Nevada such that it is subject to the personal jurisdiction of this Court.
`Personal jurisdiction in Nevada over Tawk is also consistent with the requirements of due process.
`Venue is proper because a substantial part of the events or omissions giving rise to LHN’s claims
`occurred in this judicial District, thus, infringement of LHN’s patent is likely to occur in this
`District, Pursuant to LR IA 1-6, venue lies in the unofficial Southern Division of this judicial
`district.
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`BACKGROUND FACTS
`On November 3, 2015, United States Patent No. 9,178,950 (the “’950 patent”) was
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`duly and properly issued to Michael Kansky, for an invention entitled “Method, System And
`Apparatus For Establishing And Monitoring Sessions With Clients Over A Communication
`Network.” A true and correct copy of the ’950 patent is attached to this complaint as Exhibit 1.
`LHN is the owner by assignment of the ‘950 patent.
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`LHN possesses all rights necessary to bring this suit for infringement of the ’950
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`patent.
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`Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 4 of 12
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`On February 28, 2017, United States Patent No. 9,584,375 (the “’375 patent”) was
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`duly and properly issued to Michael Kansky, for an invention entitled “Method, System And
`Apparatus For Establishing And Monitoring Sessions With Clients Over A Communication
`Network.” A true and correct copy of the ’375 patent is attached to this complaint as Exhibit 2.
`LHN is the owner by assignment of the ’375 patent.
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`LHN possesses all rights necessary to bring this suit for infringement of the ’375
`patent.
`On September 17, 2019, United States Patent No. 10,419,372 (the “’372 patent”)
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`was duly and properly issued to Michael Kansky, for an invention entitled “Method, System And
`Apparatus For Establishing And Monitoring Sessions With Clients Over A Communication
`Network.” A true and correct copy of the ’372 patent is attached to this complaint as Exhibit 3.
`LHN is the owner by assignment of the ’372 patent.
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`LHN possesses all rights necessary to bring this suit for infringement of the ’372
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`patent.
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`On March 16, 2021, United States Patent No. 10,951,559 (the “’559 patent”) was
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`duly and properly issued to Michael Kansky, for an invention entitled “Method, System And
`Apparatus For Establishing And Monitoring Sessions With Clients Over A Communication
`Network.” A true and correct copy of the ’559 patent is attached to this complaint as Exhibit 4;
`a Certificate of Correction from the U.S. Patent and Trademark Office for the ’559 patent is
`attached to this complaint as Exhibit 5.
`LHN is the owner by assignment of the ’559 patent.
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`LHN possesses all rights necessary to bring this suit for infringement of the ’559
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`patent.
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`On March 22, 2022, United States Patent No. 11,283,739 (the “’739 patent;”
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`collectively with the 950 patent, the 375 patent, the 372 patent and the 559 patent referred to
`herein as the “LHN Patents”) was duly and properly issued to Michael Kansky, for an invention
`entitled “Method, System And Apparatus For Establishing And Monitoring Sessions With Clients
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`Over A Communication Network.” A true and correct copy of the ’739 patent is attached to this
`complaint as Exhibit 6.
`LHN is the owner by assignment of the ’739 patent.
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`LHN possesses all rights necessary to bring this suit for infringement of the ’739
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`patent.
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`DEFENDANT’S INFRINGEMENT
`Tawk, at least under the brand name “tawk.to” and/or “Tawk.to” makes, uses,
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`imports, sells, and/or offers for sale, and has made, imported, sold, and/or offered for sale, live
`chatting products and services, that practice the technology disclosed and claimed in the LHN
`Patents (collectively the “ Tawk Infringing Products”).
`LHN is informed and believes, and thereupon alleges that Tawk offers the Tawk
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`Infringing Products for sale both alone and in various combinations, arrangements and kits, under
`various designations, and offers them for sale at least on its own website. Tawk encourages,
`assists and instructs customers, affiliates, and partners to use the Tawk Infringing Products in a
`manner that infringes the asserted patents. As a result, Tawk also indirectly infringes the asserted
`patents.
`By making, using, importing, offering for sale, and/or selling the Tawk Infringing
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`Products, Tawk has infringed and continues to infringe on LHN’s valuable intellectual property
`rights.
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`Through its infringement of the LHN Patents, Tawk has caused and continues to
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`cause LHN serious and ongoing harm, including both monetary damages and irreparable harm
`that cannot be compensated with monetary damages and for which LHN has no adequate remedy
`at law.
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`WILLFUL INFRINGEMENT
`Tawk has known of the LHN Patents and of its infringement of the ’950 and ’375
`29.
`patents since at least August 8, 2019, when it received a letter from LHN’s counsel providing it
`with those patents. LHN is informed and believes, and thereupon alleges that: Tawk has known
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`Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 6 of 12
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`of the ’372 patent and its infringement of that patent since the date on which the patent issued,
`September 17, 2019; Tawk has known of the ’559 patent and its infringement of that patent since
`the date on which the patent issued, March 16, 2021; and Tawk has known of the ’739 patent and
`its infringement of that patent since the date on which the patent issued, March 22, 2022.
`After being notified of its continued infringement on January 24, 2020 when it
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`received another letter from LHN’s counsel providing it with LHN’s latest issued ‘372 patent,
`Tawk once again elected to remain silent and continue making, offering for sale, and/or selling
`its Tawk Infringing Products.
`After over two years of the COVID pandemic, Tawk was reminded of its
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`infringement on March 21, 2023 in yet another letter from LHN’s counsel providing Tawk with
`LHN’s two more issued ‘559 and ‘739 patents. Rather than responding, or engaging in any
`discussions with LHN, Tawk continues making, offering for sale, and/or selling its Tawk
`Infringing Products.
`LHN is informed and believes, and thereupon alleges that Tawk’s infringement of
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`the LHN Patents is knowing, willful, intentional, and intended to profit off of LHN’s innovative
`technologies.
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`COUNT ONE
`(Infringement of the ‘950 Patent as to Tawk)
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`LHN incorporates and re-alleges as if fully set forth herein each and every
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`allegation contained in preceding paragraphs of this Complaint.
`Tawk Infringing Products meet each and every limitation of at least claim 5 of the
`34.
`’950 patent. Attached hereto as Exhibit 7 is a claim chart showing how an example of the
`Infringing Products meets these limitations, and thus infringes the ’950 patent for at least this
`reason.
`By making, using, importing, offering to sell, and/or selling the Tawk Infringing
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`Products, Tawk is infringing LHN’s exclusive rights in the ’950 patent in violation of 35 U.S.C.
`§ 271, and will continue to do so unless enjoined by this Court.
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`Tawk has induced, and continues to induce Tawk’s customers, partners, affiliates,
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`and/or end users to infringe the asserted claims. Tawk has taken active steps to encourage and
`facilitate direct infringement by Tawk’s customers, and/or end users of the Tawk Infringing
`Products, with knowledge of that infringement, such as providing the Tawk Infringing Products,
`by contracting for the sale and distribution of the Tawk Infringing Products, by marketing the
`Tawk Infringing Products, and by creating and/or distributing instructional materials, web pages,
`marketing materials, and/or similar materials with instructions for using the Tawk Infringing
`Products in an infringing manner. The use of the Tawk Infringing Products in accordance with
`Tawk’s instructions results in infringement of the asserted claims.
`Tawk has also contributorily infringed, and continues to contributorily infringe,
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`the asserted claims by making, using, offering to sell, selling, and/or contracting for sale of the
`Tawk Infringing Products that perform the patented method, knowing that the Tawk Infringing
`Products are especially made for use in infringing the ’950 patent, and are not staple articles of
`commerce suitable for a substantial non-infringing use.
`Tawk’s infringement is knowing and willful.
`38.
`COUNT TWO
`(Infringement of the ‘375 Patent as to Tawk)
`LHN incorporates and re-alleges as if fully set forth herein each and every
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`allegation contained in the preceding paragraphs of this Complaint.
`Tawk Infringing Products meet each and every limitation of at least claim 1 of the
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`’375 patent. Attached hereto as Exhibit 8 is a claim chart showing how an example of the
`Infringing Products meets these limitations, and thus infringes the ’375 patent for at least this
`reason.
`By making, using, importing, offering to sell, and/or selling the Tawk Infringing
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`Products, Tawk is infringing LHN’s exclusive rights in the ’375 patent in violation of 35 U.S.C.
`§ 271, and will continue to do so unless enjoined by this Court.
`Tawk has induced, and continues to induce Tawk’s customers, partners, affiliates,
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`and/or end users to infringe the asserted claims. Tawk has taken active steps to encourage and
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`facilitate direct infringement by Tawk’s customers, and/or end users of the Tawk Infringing
`Products, with knowledge of that infringement, such as providing the Tawk Infringing Products,
`by contracting for the sale and distribution of the Tawk Infringing Products, by marketing the
`Tawk Infringing Products, and by creating and/or distributing instructional materials, web pages,
`marketing materials, and/or similar materials with instructions for using the Tawk Infringing
`Products in an infringing manner. The use of the Tawk Infringing Products in accordance with
`Tawk’s instructions results in infringement of the asserted claims.
`Tawk has also contributorily infringed, and continues to contributorily infringe,
`43.
`the asserted claims by making, using, offering to sell, selling, and/or contracting for sale of the
`Tawk Infringing Products that perform the patented method, knowing that the Tawk Infringing
`Products are especially made for use in infringing the ’375 patent, and are not staple articles of
`commerce suitable for a substantial non-infringing use.
`Tawk’s infringement is knowing and willful.
`44.
`COUNT THREE
`(Infringement of the ‘372 Patent as to Tawk)
`LHN incorporates and re-alleges as if fully set forth herein each and every
`45.
`allegation contained in preceding paragraphs of this Complaint.
`Tawk Infringing Products meet each and every limitation of at least claim 1 of the
`46.
`’372 patent. Attached hereto as Exhibit 9 is a claim chart showing how an example of the
`Infringing Products meets these limitations, and thus infringes the ’372 patent for at least this
`reason.
`By making, using, importing, offering to sell, and/or selling the Tawk Infringing
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`Products, Tawk is infringing LHN’s exclusive rights in the ’372 patent in violation of 35 U.S.C.
`§ 271, and will continue to do so unless enjoined by this Court.
`Tawk has induced, and continues to induce Tawk’s customers, partners, affiliates,
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`and/or end users to infringe the asserted claims. Tawk has taken active steps to encourage and
`facilitate direct infringement by Tawk’s customers, and/or end users of the Tawk Infringing
`Products, with knowledge of that infringement, such as providing the Tawk Infringing Products,
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`by contracting for the sale and distribution of the Tawk Infringing Products, by marketing the
`Tawk Infringing Products, and by creating and/or distributing instructional materials, web pages,
`marketing materials, and/or similar materials with instructions for using the Tawk Infringing
`Products in an infringing manner. The use of the Tawk Infringing Products in accordance with
`Tawk’s instructions results in infringement of the asserted claims.
`Tawk has also contributorily infringed, and continues to contributorily infringe,
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`the asserted claims by making, using, offering to sell, selling, and/or contracting for sale of the
`Tawk Infringing Products that perform the patented method, knowing that the Tawk Infringing
`Products are especially made for use in infringing the ’372 patent, and are not staple articles of
`commerce suitable for a substantial non-infringing use.
`Tawk’s infringement is knowing and willful.
`50.
`COUNT FOUR
`(Infringement of the ‘559 Patent as to Tawk)
`LHN incorporates and re-alleges as if fully set forth herein each and every
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`allegation contained in preceding paragraphs of this Complaint.
`Tawk Infringing Products meet each and every limitation of at least claim 14 of
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`the ’559 patent. Attached hereto as Exhibit 10 is a claim chart showing how an example of the
`Infringing Products meets these limitations, and thus infringes the ’559 patent for at least this
`reason.
`By making, using, importing, offering to sell, and/or selling the Tawk Infringing
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`Products, Tawk is infringing LHN’s exclusive rights in the ’559 patent in violation of 35 U.S.C.
`§ 271, and will continue to do so unless enjoined by this Court.
`Tawk has induced, and continues to induce Tawk’s customers, partners, affiliates,
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`and/or end users to infringe the asserted claims. Tawk has taken active steps to encourage and
`facilitate direct infringement by Tawk’s customers, and/or end users of the Tawk Infringing
`Products, with knowledge of that infringement, such as providing the Tawk Infringing Products,
`by contracting for the sale and distribution of the Tawk Infringing Products, by marketing the
`Tawk Infringing Products, and by creating and/or distributing instructional materials, web pages,
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`marketing materials, and/or similar materials with instructions for using the Tawk Infringing
`Products in an infringing manner. The use of the Tawk Infringing Products in accordance with
`Tawk’s instructions results in infringement of the asserted claims.
`Tawk has also contributorily infringed, and continues to contributorily infringe,
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`the asserted claims by making, using, offering to sell, selling, and/or contracting for sale of the
`Tawk Infringing Products that perform the patented method, knowing that the Tawk Infringing
`Products are especially made for use in infringing the ’559 patent, and are not staple articles of
`commerce suitable for a substantial non-infringing use.
`Tawk’s infringement is knowing and willful.
`56.
`COUNT FIVE
`(Infringement of the ‘739 Patent as to Tawk)
`LHN incorporates and re-alleges as if fully set forth herein each and every
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`allegation contained in preceding paragraphs of the Complaint.
`Tawk Infringing Products meet each and every limitation of at least claim 15 of
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`the ’739 patent. Attached hereto as Exhibit 11 is a claim chart showing how an example of the
`Infringing Products meets these limitations, and thus infringes the ’739 patent for at least this
`reason.
`By making, using, importing, offering to sell, and/or selling the Tawk Infringing
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`Products, Tawk is infringing LHN’s exclusive rights in the ’739 patent in violation of 35 U.S.C.
`§ 271, and will continue to do so unless enjoined by this Court.
`Tawk has induced, and continues to induce Tawk’s customers, partners, affiliates,
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`and/or end users to infringe the asserted claims. Tawk has taken active steps to encourage and
`facilitate direct infringement by Tawk’s customers, and/or end users of the Tawk Infringing
`Products, with knowledge of that infringement, such as providing the Tawk Infringing Products,
`by contracting for the sale and distribution of the Tawk Infringing Products, by marketing the
`Tawk Infringing Products, and by creating and/or distributing instructional materials, web pages,
`marketing materials, and/or similar materials with instructions for using the Tawk Infringing
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`Products in an infringing manner. The use of the Tawk Infringing Products in accordance with
`Tawk’s instructions results in infringement of the asserted claims.
`Tawk has also contributorily infringed, and continues to contributorily infringe,
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`the asserted claims by making, using, offering to sell, selling, and/or contracting for sale of the
`Tawk Infringing Products that perform the patented method, knowing that the Tawk Infringing
`Products are especially made for use in infringing the ’739 patent, and are not staple articles of
`commerce suitable for a substantial non-infringing use.
`Tawk’s infringement is knowing and willful.
`62.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff LHN respectfully requests that this Court enters judgment in its
`favor against Tawk, as follows:
`1.
`Finding that Tawk has infringed, respectively, the ’950 patent, the ’375 patent,
`the ’372 patent, the ’559 patent, and the ‘739 patent;
`2.
`Awarding to LHN damages for Tawk’s infringement as set forth herein as
`permitted by law and determined at trial;
`3.
`Awarding to LHN exemplary damages as allowed by applicable law;
`4.
`Finding Tawk’s conduct willful and trebling any applicable damages found or
`assessed;
`Finding that this case is exceptional under 35 U.S.C. § 285 and awarding LHN’s
`5.
`attorney fees and costs;
`6.
`Awarding to LHN the costs of this action as allowed by applicable law;
`7.
`Awarding to LHN pre-judgment and post-judgment interest on any monetary
`award according to the maximum allowable legal rate;
`8.
`Entering a permanent injunction under 35 U.S.C. § 283 enjoining each of Tawk,
`its officers, partners, employees, agents, parents, subsidiaries, attorneys, and anyone acting or
`participating with any of them, from manufacturing, making, selling, offering for sale,
`importing, or using the Tawk Infringing Products identified herein or any product that infringes
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`Case 2:23-cv-00667-APG-VCF Document 1 Filed 04/28/23 Page 12 of 12
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`any claim of the ’950 patent, the ’375 patent, the ’372 patent, the ’559 patent, or the ‘739
`patent; and
`9.
`equitable.
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`Awarding LHN such other and further relief as the Court may deem just and
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`JURY DEMAND
`Plaintiff LHN hereby respectfully requests a trial by jury of all issues so triable, pursuant
`to Rule 38 of the Federal Rules of Civil Procedure.
`DATED this 28th day of April, 2023.
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`DICKINSON WRIGHT PLLC
`
`
`/s/ John L. Krieger
`MICHAEL N. FEDER
`Nevada Bar No. 7332
`JOHN L. KRIEGER
`Nevada Bar No. 6023
`3883 Howard Hughes Parkway, Suite 800
`Las Vegas, Nevada 89169
`Tel: (702) 550-4400
`Fax: (844) 670-6009
`Email: mfeder@dickinson-wright.com
`Email: jkrieger@dickinson-wright.com
`
`
`STANISLAV TORGOVITSKY
`(Pro hac vice to be submitted)
`1825 Eye Street N.W., Suite 900
`Washington, D.C. 20006
`Tel: (202) 659-6925
`Fax: (844) 670-6009
`Email: storgovitsky@dickinson-wright.com
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`Attorneys for Plaintiff LiveHelpNow, LLC
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