throbber
Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 1 of 13 PageID #:3573
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`TRADING TECHNOLOGIES
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`INTERNATIONAL, INC.
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`Plaintiff,
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`v.
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`BCG PARTNERS, INC.
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`Defendant.
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`Case No. 10 C 715
`(Consolidated with:
`10 C 716, 10 C 718,
`10 C 720, 10 C 721,
`10 C 726, 10 C 882,
`10 C 883, 10 C 884,
`10 C 885, 10 C 929,
`10 C 931)
`
`Judge Virginia M. Kendall
`
`SECOND AMENDED COMPLAINT
`FOR PATENT INFRINGEMENT AND JURY DEMAND
`
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`Plaintiff Trading Technologies International, Inc. (“Trading Technologies”), for its
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`complaint against Defendant TradeHelm, Inc. (“TradeHelm”), states as follows:
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`PARTIES
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`1.
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`Plaintiff Trading Technologies is a Delaware Corporation with a principal place of
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`business at 222 South Riverside Plaza, Suite 1100, Chicago, Illinois 60606.
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`2.
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`Defendant TradeHelm is a Delaware Corporation with its corporate headquarters at
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`5727 South Lewis Ave., Suite 500, Tulsa, Oklahoma 74105.
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`JURISDICTION AND VENUE
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`3.
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`This is an action for patent infringement arising under the acts of Congress relating
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`to patents, namely the Patent Laws of the United States, 35 U.S.C. §§ 1 et seq. This Court thereby
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`has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`1
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`TS 1014
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`

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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 2 of 13 PageID #:3574
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`4.
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`Defendant TradeHelm regularly conducts business in this district. Defendant’s
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`trading software provides access to exchanges in this district, including the Chicago Board of Trade
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`(“CBOT”). Defendant TradeHelm actively markets, demonstrates, licenses and sells its trading
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`software, including at a minimum the ACTrader product, in this district. See, e.g., Ex. A.
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`Therefore, this Court has jurisdiction generally over Defendant TradeHelm.
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`5.
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` Defendant TradeHelm has committed and continues to commit acts of patent
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`infringement in this district. Therefore, this Court has specific jurisdiction over Defendant
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`TradeHelm.
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`6.
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` Defendant TradeHelm maintains an office in this district at 20 North Wacker Dr.,
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`Suite 3550, Chicago, Illinois 60606, and, as such, it is subject to personal jurisdiction in this district.
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`Therefore, this District is a proper venue pursuant to 28 U.S.C. §§ 1391(b) and 1400(b).
`
`
`COUNT I:
`INFRINGEMENT OF U.S. PATENT NO. 6,766,304
`
`7.
`
`Plaintiff Trading Technologies is the owner of U.S. Patent No. 6,766,304 (“the ‘304
`
`
`
`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which was duly
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`and legally issued on July 20, 2004. A true and correct copy of the ‘304 patent is attached as Exhibit
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`B.
`
`8.
`
`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘304 patent.
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`9.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘304
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘304 patent.
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`10. Defendant TradeHelm has infringed and continues to infringe the ‘304 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘304 patent, including
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`2
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 3 of 13 PageID #:3575
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
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`11. Defendant TradeHelm has in the past and continues to promote, advertise and
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`instruct customers and potential customers about its products and how to use its products, including
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`infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a minimum,
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`maintenance of the website www.TradeHelm.com, and distribution of brochures. See, e.g., Ex. A.
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`12. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`13. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘304 patent in violation of 35 U.S.C. §271(b) and (c).
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`14. Defendant’s infringement of the ‘304 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`
`COUNT II:
`INFRINGEMENT OF U.S. PATENT NO. 6,772,132
`
`Plaintiff Trading Technologies incorporates paragraphs 1-14 as if set forth in full.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 6,772,132 (“the ‘132
`
`
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`15.
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`16.
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`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which was duly
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`and legally issued on August 3, 2004. A true and correct copy of the ‘132 patent is attached as Exhibit
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`C.
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`17.
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`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘132 patent.
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`18.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘132
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘132 patent.
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`3
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 4 of 13 PageID #:3576
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`19. Defendant TradeHelm has infringed and continues to infringe the ‘132 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ’132 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
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`20. Defendant TradeHelm has in the past and continues to promote, advertise and
`
`instruct customers and potential customers about their products and how to use their products,
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`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
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`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
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`e.g., Ex. A.
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`21. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`22. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘132 patent in violation of 35 U.S.C. §271(b) and (c).
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`23. Defendant’s infringement of the ‘132 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`
`COUNT III:
`INFRINGEMENT OF U.S. PATENT NO. 7,212,999
`
`Plaintiff Trading Technologies incorporates paragraphs 1-23 as if set forth in full.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,212,999 (“the ‘999
`
`
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`24.
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`25.
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`patent”), titled “User Interface for an Electronic Trading System,” which was duly and legally issued
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`on May 1, 2007. A true and correct copy of the ‘999 patent is attached as Exhibit D.
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`26.
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`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘999 patent.
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` 3
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`4
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 5 of 13 PageID #:3577
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`27.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘999
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘999 patent.
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`28. Defendant TradeHelm has infringed and continues to infringe the ‘999 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘999 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
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`29. Defendant TradeHelm has in the past and continues to promote, advertise and
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`instruct customers and potential customers about their products and how to use their products,
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`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
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`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
`
`e.g., Ex. A.
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`30. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`31. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘999 patent in violation of 35 U.S.C. §271(b) and (c).
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`32. Defendant’s infringement of the ‘999 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`
`COUNT IV:
`INFRINGEMENT OF U.S. PATENT NO. 7,533,056
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`Plaintiff Trading Technologies incorporates paragraphs 1-32 as if set forth in full.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,533,056 (“the ‘056
`
`
`
`33.
`
`34.
`
`patent”), titled “User Interface for an Electronic Trading System,” which duly and legally issued on
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`May 12, 2009. A true and correct copy of the ‘056 patent is attached as Exhibit E.
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` 4
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`5
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 6 of 13 PageID #:3578
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`35.
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`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘056 patent.
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`36.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘056
`
`patent nor otherwise authorized Defendant TradeHelm to practice the ‘056 patent.
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`37. Defendant TradeHelm has infringed and continues to infringe the ‘056 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘056 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
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`38. Defendant TradeHelm has in the past and continues to promote, advertise and
`
`instruct customers and potential customers about their products and how to use their products,
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`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
`
`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
`
`e.g., Ex. A.
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`39. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`40. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘056 patent in violation of 35 U.S.C. §271(b) and (c).
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`41. Defendant’s infringement of the ‘056 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`COUNT V:
`INFRINGEMENT OF U.S. PATENT NO. 7,676,411
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`42.
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`Plaintiff Trading Technologies incorporates paragraphs 1-41 as if set forth in full.
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` 5
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`6
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 7 of 13 PageID #:3579
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`43.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,676,411 (“the ‘411
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`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which duly and
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`legally issued on March 9, 2010. A true and correct copy of the ‘411 patent is attached as Exhibit F.
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`44.
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`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘411 patent.
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`45.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘411
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘411 patent.
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`46. Defendant TradeHelm has infringed and continues to infringe the ‘411 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘411 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
`
`47. Defendant TradeHelm has in the past and continues to promote, advertise and
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`instruct customers and potential customers about their products and how to use their products,
`
`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
`
`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
`
`e.g., Ex. A.
`
`48. Defendant’s products are not staple articles or commodities of commerce suitable for
`
`substantial non-infringing use.
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`49. Defendant’s actions have in the past and continue to constitute active inducement of
`
`and contributory infringement of the ‘411 patent in violation of 35 U.S.C. §271(b) and (c).
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`50. Defendant’s infringement of the ‘411 patent has caused irreparable harm to Plaintiff
`
`Trading Technologies and will continue to do so unless enjoined.
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`
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` 6
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`7
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 8 of 13 PageID #:3580
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`COUNT VI:
`INFRINGEMENT OF U.S. PATENT NO. 7,693,768
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`Plaintiff Trading Technologies incorporates paragraphs 1-50 as if set forth in full.
`
`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,693,768 (“the ‘768
`
`
`
`51.
`
`52.
`
`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which duly and
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`legally issued on April 6, 2010. A true and correct copy of the ‘768 patent is attached as Exhibit G.
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`53.
`
`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘768 patent.
`
`54.
`
`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘768
`
`patent nor otherwise authorized Defendant TradeHelm to practice the ‘768 patent.
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`55. Defendant TradeHelm has infringed and continues to infringe the ‘768 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘768 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
`
`authorization in violation of 35 U.S.C. § 271(a).
`
`56. Defendant TradeHelm has in the past and continues to promote, advertise and
`
`instruct customers and potential customers about their products and how to use their products,
`
`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
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`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
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`e.g., Ex. A.
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`57. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`58. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘768 patent in violation of 35 U.S.C. §271(b) and (c).
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` 7
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`8
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 9 of 13 PageID #:3581
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`59. Defendant’s infringement of the ‘768 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`60.
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`61.
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`COUNT VII:
`INFRINGEMENT OF U.S. PATENT NO. 7,725,382
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`Plaintiff Trading Technologies incorporates paragraphs 1-59 as if set forth in full.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,725,382 (“the ‘382
`
`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which duly and
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`legally issued on May 25, 2010. A true and correct copy of the ‘382 patent is attached as Exhibit H.
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`62.
`
`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘382 patent.
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`63.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘382
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘382 patent.
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`64. Defendant TradeHelm has infringed and continues to infringe the ‘382 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘382 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
`
`authorization in violation of 35 U.S.C. § 271(a).
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`65. Defendant TradeHelm has in the past and continues to promote, advertise and
`
`instruct customers and potential customers about their products and how to use their products,
`
`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
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`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
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`e.g., Ex. A.
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` 8
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`9
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 10 of 13 PageID #:3582
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`66. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
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`67. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘382 patent in violation of 35 U.S.C. §271(b) and (c).
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`68. Defendant’s infringement of the ‘382 patent has caused irreparable harm to Plaintiff
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`Trading Technologies and will continue to do so unless enjoined.
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`
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`69.
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`70.
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`COUNT VIII:
`INFRINGEMENT OF U.S. PATENT NO. 7,813,996
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`Plaintiff Trading Technologies incorporates paragraphs 1-68 as if set forth in full.
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`Plaintiff Trading Technologies is the owner of U.S. Patent No. 7,813,996 (“the ‘996
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`patent”), titled “Click Based Trading with Intuitive Grid Display of Market Depth,” which duly and
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`legally issued on October 12, 2010. A true and correct copy of the ‘996 patent is attached as Exhibit I.
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`71.
`
`Plaintiff Trading Technologies is in compliance with any applicable marking and notice
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`provisions of 35 U.S.C. § 287, with respect to the ‘996 patent.
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`72.
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`Plaintiff Trading Technologies has never licensed Defendant TradeHelm under the ‘996
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`patent nor otherwise authorized Defendant TradeHelm to practice the ‘996 patent.
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`73. Defendant TradeHelm has infringed and continues to infringe the ‘996 patent by
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`making, using, selling and/or offering for sale products covered by claims of the ‘996 patent, including
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`at a minimum the ACTrader software, see, e.g., Ex. A, without Plaintiff Trading Technologies’
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`authorization in violation of 35 U.S.C. § 271(a).
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`74. Defendant TradeHelm has in the past and continues to promote, advertise and
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`instruct customers and potential customers about their products and how to use their products,
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`
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` 9
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`10
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 11 of 13 PageID #:3583
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`including infringing uses. Defendant’s promotion, advertising, and instruction efforts include, at a
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`minimum, maintenance of the website www.TradeHelm.com, and distribution of brochures. See,
`
`e.g., Ex. A.
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`75. Defendant’s products are not staple articles or commodities of commerce suitable for
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`substantial non-infringing use.
`
`76. Defendant’s actions have in the past and continue to constitute active inducement of
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`and contributory infringement of the ‘996 patent in violation of 35 U.S.C. §271(b) and (c).
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`77. Defendant’s infringement of the ‘996 patent has caused irreparable harm to Plaintiff
`
`Trading Technologies and will continue to do so unless enjoined.
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`RELIEF REQUESTED
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`THEREFORE, Plaintiff Trading Technologies prays for judgment and relief including:
`
`(A)
`
`Judgment that Defendant TradeHelm has been and is infringing one or more of the
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`claims of the ‘304, ‘132, ‘999, ‘056, ‘411, ‘768, ‘382, and ‘996 patents pursuant to 35 U.S.C. §§
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`271(a), (b) and (c);
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`
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`(B)
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`A preliminary and permanent injunction enjoining Defendant TradeHelm and its
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`officers, agents, servants, employees, attorneys, related business entities and those in active concert or
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`participation with it from infringing the ‘304, ‘132, ‘999, ‘056, ‘411, ‘768, ‘382, and ‘996 patents;
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`
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`(C)
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`An award of damages incurred by Plaintiff Trading Technologies as a result of
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`Defendant TradeHelm’s infringement of the ‘304, ‘132, ‘999, ‘056, ‘411, ‘768, ‘382, and ‘996 patents;
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`
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`(D) An assessment of costs, including reasonable attorney fees pursuant to 35 U.S.C. § 285,
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`and prejudgment interest against Defendant TradeHelm; and
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`
`(E)
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`Such other and further relief as this Court may deem just and proper.
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` 10
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`11
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 12 of 13 PageID #:3584
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`JURY DEMAND
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`Plaintiff Trading Technologies demands trial by jury on all issues so triable.
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`Respectfully submitted,
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`By:
`
`
`
` s/ Ann C. Palma__________________
`Leif R. Sigmond, Jr. (ID No. 6204980)
`(sigmond@mbhb.com)
`Matthew J. Sampson (ID No. 6207606)
`(sampson@mbhb.com)
`Michael D. Gannon (ID No. 6206940)
`(gannon@mbhb.com)
`S. Richard Carden (ID No. 6269504)
`
`(carden@mbhb.com)
`
`Jennifer M. Kurcz (ID No. 6279893)
`
`(kurcz@mbhb.com)
`
`Kirsten L. Thomson (ID No. 6293943)
`
`(thomson@mbhb.com)
`
`Ann C. Palma (ID No. 6302703)
`
`(palma@mbhb.com)
`
` McDonnell Boehnen Hulb
`
`300 South Wacker Drive
`
`Chicago, Illinois 60606
`
`Tel.: (312) 913-0001
`Fax: (312) 913-0002
`
`
`ert & Berghoff LLP
`
`Steven F. Borsand (ID No. 6206597)
`(Steve.Borsand@tradingtechnologies.com)
`Trading Technologies International, Inc.
`222 South Riverside
`Suite 1100
`Chicago, IL 60606
`Tel: (312) 476-1000
`Fax: (312) 476-1182
`
`
`
` Attorneys for Plaintiff,
`
`TRADING TECHNOLOGIES
`
`INTERNATIONAL, INC.
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`Date: March 28, 2011
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`12
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`Case: 1:10-cv-00715 Document #: 130 Filed: 03/28/11 Page 13 of 13 PageID #:3585
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`
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`CERTIFICATE OF SERVICE
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`I certify that a copy of the foregoing NOTICE OF MOTION was served on March 28, 2011
`
`as follows:
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`Via Filing with this Court’s CM-ECF System
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`Bradford P. Lyerla
`BLyerla@jenner.com
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`Jenner & Block LLP
`353 N. Clark Street
`Chicago, IL 60654-3456
`Tel.: (312) 923-2613
`Fax.: (312) 527-0484
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`Counsel for Defendant
`TRADEHELM, INC.
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` s/ Ann C. Palma
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` 12
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`13
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