On March 30, 2021, Riggs Technology Holdings, LLC (“Riggs” or “Plaintiff”), represented by William P Ramey, III of Ramey & Browning PLLC, filed an intellectual property lawsuit against Salesforce.com, Inc. (“Salesforce” “Defendant”), seeking Permanent injunctive relief and damages with pre-judgment and post-judgment interests among other reliefs, for the alleged unlawful infringement of technology relating to a novel and improved methods and systems for providing and managing training remotely, owned by Plaintiff. This case was filed in U.S. District Court in the Northern District of Texas with Judge Barbara M. G. Lynn presiding.
The Plaintiff filed this complaint for the alleged infringement of United States Patent No. 7,299,067 (“the ‘067 patent”) (referred to as the “Patent-in-Suit”) entitled “Methods and Systems for Managing the Provision of Training Provided Remotely Through Electronic Data Networks to Users of Remote Electronic Devices” owned by Plaintiff.
The Plaintiff alleged that “Salesforce maintains, operates, and administers online and software-based training platforms, products, and services that facilitate remote training that infringes one or more claims of the ‘067 patent, including one or more of claims 1-18, literally or under the doctrine of equivalents Defendant put the inventions claimed by the ‘067 Patent into service (i.e., used them); but for Defendant’s actions, the claimed-inventions embodiments involving Defendant’s products and services would never have been put into service. Defendant’s acts caused those claimed-invention embodiments as a whole to perform, and Defendant’s procurement of monetary and commercial benefit from it. Salesforce has actively encouraged or instructed others (e.g., its customers and/or the customers of its related companies), and continues to do so, on how to use its products and services (e.g., payment products and services that facilitate purchases from a vendor using a bridge computer) such as to cause an infringement of one or more of claims 1–18 of the ‘067 patent, literally or under the doctrine of equivalents.”
Furthermore, Plaintiff alleged that “upon information and belief that Salesforce has engaged in such actions with specific intent to induce infringement or with willful blindness to the resulting infringement because Salesforce has known or should have known of the ‘067 patent and the technology underlying it from at least the date of issuance of the patent.”
The only claim for relief laid down by the Plaintiff is for the alleged infringement of one or more claims of the ‘067 Patent.
In its prayer for relief, the plaintiff has requested the court to declare that Defendant has infringed the claims of the ‘067 patent, award RIGGS damages in an amount sufficient to compensate it for Defendant’s infringement of the ‘067 patent in an amount no less than a reasonable royalty or lost profits, together with pre-judgment and post-judgment interest and costs. Plaintiff further requested the court to award RIGGS an accounting for acts of infringement, declare Defendant’s infringement to be willful and treble the damages, including attorneys’ fees, expenses, and costs incurred in this action, a decree for future infringement (i) awards a permanent injunction enjoining Defendant from infringing the claims of the Patents-in-Suit, or (ii) awards damages for future infringement in lieu of an injunction in an amount and trebles that amount in view of the fact that the future infringement will be willful as a matter of law.
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Pending - Other Pending
Barbara M. G. Lynn
RIGGS TECHNOLOGY HOLDINGS, LLC
Riggs Technology Holdings LLC
William P Ramey, III
Attorney at Ramey & Browning PLLC
5020 Montrose Blvd, Suite 800
Houston, TX 77006
Docket(#10) ELECTRONIC ORDER granting #9 Motion for Extension of Time to File Answer. The deadline for Defendant Salesforce.com LLC to answer or otherwise respond to Plaintiff's Complaint is June 21, 2021. (Ordered by Chief Judge Barbara M. G. Lynn on 5/24/2021) (chmb) (Entered: 05/24/2021)Read MoreRead Less
Docket(#9) Consent Motion for Extension of Time to File Answer filed by Riggs Technology Holdings LLC (Attachments: #1 Proposed Order) (Ramey, William) (Entered: 05/21/2021)Read MoreRead Less
Docket(#8) ELECTRONIC ORDER granting #7 Motion for Extension of Time to File Answer. The deadline for Defendant Salesforce.com LLC to answer or otherwise respond to Plaintiff's Complaint is May 21, 2021. (Ordered by Chief Judge Barbara M. G. Lynn on 4/20/2021) (chmb) (Entered: 04/20/2021)Read MoreRead Less
Docket(#7) Unopposed Motion for Extension of Time to File Answer filed by Riggs Technology Holdings LLC (Attachments: #1 Proposed Order) (Ramey, William) (Entered: 04/19/2021)Read MoreRead Less
Docket(#6) SUMMONS Returned Executed as to Salesforce.com LLC; served on 3/31/2021. (Ramey, William) (Entered: 04/05/2021)Read MoreRead Less
Docket(#5) Report to Patent/Trademark Office of Initiating Document. Form AO 120 e-mailed to email@example.com. (mjr) (Entered: 03/31/2021)Read MoreRead Less
Docket(#4) Summons Issued as to Salesforce.com LLC. (mjr) (Entered: 03/31/2021)Read MoreRead Less
Docket(#3) New Case Notes: A filing fee has been paid. Pursuant to Misc. Order 6, Plaintiff is provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate Judge (Judge Ramirez). Clerk to provide copy to plaintiff if not received electronically. (mjr) (Entered: 03/31/2021)Read MoreRead Less
Docket(#2) Request for Clerk to issue Summons filed by RIGGS TECHNOLOGY HOLDINGS, LLC. (Ramey, William) (Entered: 03/30/2021)Read MoreRead Less
Docket(#1) COMPLAINT WITH JURY DEMAND against SALESFORCE.COM, INC. filed by RIGGS TECHNOLOGY HOLDINGS, LLC. (Filing fee $402; Receipt number 0539-11748675) Plaintiff will submit summons(es) for issuance. In each Notice of Electronic Filing, the judge assignment is indicated, and a link to the # Judges Copy Requirements and # Judge Specific Requirements is provided. The court reminds the filer that any required copy of this and future documents must be delivered to the judge, in the manner prescribed, within three business days of filing. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: # Attorney Information - Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (Attachments: #1 Exhibit(s) US7299067, #2 Cover Sheet) (Ramey, William) (Entered: 03/30/2021)Read MoreRead Less
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