uniloc luxembourg et. al. v. eclinical works

7/30/2019 Uniloc Luxembourg et. al. v. eClinical Works

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Case 2:13-cv-03244-JFW-VBK Document 1 Filed 05/07/13 Page 1 of 51 Page ID #:31


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-10-COMPLAINT FOR PATENT INFRINGMT

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infringe the 526 patent for the reasons set forth under the Facts Common to Each

Claim for Relief and the allegations regarding direct infringement. eClinicalWorks

customers, who directly infringe the 526 patent include, for example, Grove Medical

Associates and Urban Health Plan.

42. Since at least by May 26, 2011, eClinicalWorks had knowledge of the526 patent. After this date, eClinicalWorks had knowledge that its eClinicalWorks

EMR software software, which are non-staple articles of commerce, was used as a

material part of the claimed invention of the 526 patent.

43. As a direct and proximate result of eClinicalWorkss contributoryinfringement of the 526 patent, Plaintiff has been and continues to be damaged in an

amount yet to be determined.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendant as follows:

1. For a judicial determination and declaration that Defendant has infringedand continues to infringe the 526 patent by making, using, importing, offering for

sale, and/or selling its eClinicalWorks EHR software;

2. For a judicial determination and declaration that Defendant has induced,and continues to induce, the infringement of the 526 patent;

3. For a judicial determination and declaration that Defendant hascontributorily infringed, and continues to contributorily infringe, the 526 patent;

4. For damages resulting from Defendants past and present infringement ofthe 526 patent;

5. For a declaration that this is an exceptional case under 35 U.S.C. 285and for an award of attorneys fees and costs in this action;

6. For an assessment of prejudgment interest; and7. For such other and further relief as the Court may deem just and proper

under the circumstances.



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uniloc luxembourg et. al. v. eclinical works

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