Defendant PayPal Holdings, Inc. is a corporation organized and existing under the laws of Delaware and has a regular and established place of business at 7700 W Palmer Lane, Building D, Austin, Texas 78729 (the “Austin Office”).
On or about March 16, 2016, Fintiv’s Founder and PayPal’s Agent had a phone call that lasted over an hour to discuss Fintiv’s patented technology, a strategic partnership between the two companies, and PayPal’s interest in acquiring Fintiv.
On or about June 13, 2019, the Chairman of Advection Growth Capital LLC (“Advection”), acting on behalf of Fintiv, sent an email to PayPal’s Director of Global Corporate Development (“PayPal’s Director”) specifically identifying the ’845, ’386, and ’488 Patents and
Further, Defendant’s infringement of Fintiv’s rights under the ’413 Patent will continue to damage Fintiv’s business, causing irreparable harm for which there is no adequate remedy at law, unless enjoined by the Court.
Suit; Declare this case exceptional pursuant to 35 U.S.C. § 285; Enter an accounting of all damages not presented at trial; and Award Fintiv its costs, disbursements, attorneys’ fees, and such further and additional relief as is deemed appropriate by this Court.