TRANSDATA PATENT PRO
(to be admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Attorneys for Plaintiff TransData, Inc. 228559) KIRKLAND & ELLIS LLP 555 California Street San Francisco, California 94104 Telephone: (415) 439-1400 Facsimile: (415) 439-1500 Of Counsel: Paul R. Dated: OctoRespectfully submitted, /s/ Ryan J.
TRANSDATA PATENT TRIAL
TRANSDATA, INC’S COMPLAINT FOR PATENT INFRINGEMENT JURY DEMAND TransData hereby demands a trial by jury on all issues and claims so triable. Such other and further relief as this Court may deem just and proper. § 285 and an award of the reasonable attorneys’ fees, costs, and expenses incurred by TransData in this action and F. A declaration that this case is exceptional under 35 U.S.C. An award of all damages adequate to compensate TransData for SDG&E’s infringement, such damages to be determined by a jury and, if necessary, an accounting of all damages D. § 283 enjoining SDG&E, as well as its officers, directors, servants, consultants, managers, employees, agents, attorneys, successors, assigns, affiliates, subsidiaries, and all persons in active concert or participation with any of them, from infringement of the ‘294 Patent, the ‘713 Patent, and the ‘699 Patent, including but not limited to making, using, offering to sell, selling, or importing any products that infringe or products that perform the patented processes set forth in the ‘294 Patent, the ‘713 Patent, and the ‘699 Patent C. Entry of a permanent injunction pursuant to 35 U.S.C. A judgment that SDG&E has infringed the ‘294 Patent, the ‘713 Patent, and the ‘699 Patent, and continues to infringe the ‘294 Patent, the ‘713 Patent, and the ‘699 Patent B. TRANSDATA, INC’S COMPLAINT FOR PATENT INFRINGEMENT PRAYER FOR RELIEF WHEREFORE, Plaintiff TransData respectfully requests that judgment be entered in favor of TransData and against Defendant SDG&E and further prays that the Court grant the following relief to TransData: A. TransData's Smart Meter Patents are the subject matter of patent enforcement actions currently pending against General Electric, Itron, Landis+Gyr, Oncor Electric Delivery, CenterPoint Energy.
SDG&E has caused TransData substantial damage and irreparable injury by its infringement of the ‘699 Patent, and TransData will continue to suffer damage and irreparable injury unless and until the infringement by SDG&E is enjoined by this Court. SDG&E’s infringement of the ‘699 Patent has injured TransData, and TransData is entitled to recover damages adequate to compensate it for SDG&E’s infringement, which in no event can be less than a reasonable royalty. Although publicly- available information on these additional meters is very limited, TransData believes, on information and belief, that discovery will show that they also infringe one or more claims of the ‘699 Patent.
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