IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
SIPCO, LLC,
Plaintiff,
vs.
ABB INC.; COULOMB
TECHNOLOGIES, INC.; ECOTALITY,
INC.; ELECTRIC TRANSPORTATION
ENGINEERING CORPORATION dba
ECOTALITY NORTH AMERICA;
ENERGYHUB, INC.; JETLUN
CORPORATION; INGERSOLL-RAND
COMPANY; INGERSOLL-RAND
SCHLAGE LOCK HOLDING
COMPANY LLC; SCHLAGE LOCK
COMPANY; TRANE, INC.; and
SMARTLABS, INC.
Defendants.
)
Civil Action File
No. 6:11cv48
JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff SIPCO, LLC (“SIPCO”) hereby makes this Complaint for patent
infringement against Defendants ABB INC. (“ABB”), COULOMB
TECHNOLOGIES, INC. (“Coulomb Technologies”), ECOTALITY, INC.
(“ECOtality”), ELECTRIC TRANSPORTATION ENGINEERING
CORPORATION dba ECOTALITY NORTH AMERICA (“ECOtality NA”),
ENERGYHUB, INC. (“EnergyHub”), JETLUN CORPORATION (“Jetlun”),
)
G. A preliminary, and thereafter permanent, injunction enjoining and
restraining Defendants, and each of them, and their officers, directors, agents,
servants, employees, attorneys, and all others acting under, by or through them,
from directly infringing, contributorily infringing, and inducing the infringement of
the ‘692 Patent, as set forth herein;
H. A preliminary, and thereafter permanent, injunction enjoining and
restraining Defendants, and each of them, and their officers, directors, agents,
servants, employees, attorneys, and all others acting under, by or through them,
from directly infringing, contributorily infringing, and inducing the infringement of
the ‘492 Patent, as set forth herein;
I. A judgment and order requiring Defendants, and each of them, to pay
SIPCO pre-judgment and post-judgment interest on the full amounts of the
damages awarded;
J. A judgment requiring Defendants, and each of them, to pay the costs
of this action (including all disbursements) and attorneys’ fees as provided by 35
U.S.C. § 285, with prejudgment interest;