Free Complaint - District Court of Delaware - Delaware

Case 1:05-cv-00816-SLR Document 1 Filed 11/29/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TURN OF THE CENTURY SOLUTION, L.P. )
Plaintiff, g
) C.A. No.
v. )
)
INTERNATIONAL RECTIFIER CORPORATION)
) JURY TRIAL DEMANDED
Defendant. g
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff, by and through its counsel, files this Complaint for patent infringement,
and in support thereof avers the following:
1. Plaintiff Turn of the Century Solution, L.P. ("TOCS") is a limited
partnership organized and existing under the laws of the Commonwealth of Pennsylvania and
having a principal place of business at 1409 Patrick Court, Ambler, Pennsylvania.
2. Defendant Intemational Rectifier Corporation ("IRC") is a corporation
organized and existing under the laws of the State of Delaware and having principal executive
offices at 233 Kansas Street, El Segundo, California.
3. This Court has jurisdiction of this action pursuant to 28 U.S.C. § 1338, as
it arises under the Patent Act, 35 U.S.C. § 1 g gg., as amended, as is hereinafter more fully
described. Venue is proper in this judicial district under 28 U.S.C. § 1391 and 1400(b).
7. On February 4, 1997, United States Letters Patent No. 5,600,836, entitled
"System and Method for Processing Date-Dependent Information Which Spans One or Two
Centuries" (the "'836 Patent"), was duly and legally issued to TOCS, as assignee from the

Case 1:05-cv-00816-SLR Document 1 Filed 11/29/2005 Page 2 of 4
7. On February 4, 1997, United States Letters Patent N0. 5,600,836, entitled
"System and Method for Processing Date-Dependent Infomation Which Spans One or Two
Centuries" (the "'836 Patent"), was duly and legally issued to TOCS, as assignee from the
inventor of the entire right, title and interest in and to the ’836 Patent, and which since that date,
has been and still is the owner of the '836 Patent. A true and correct copy of the '836 Patent is
attached hereto as Exhibit A.
8. On November 10, 1998, United States Letters Patent No. 5,835,909,
entitled "System and Method for Processing Date-Dependent Infomation Which Spans One or
Two Centuries" (the "'909 Patent"), was duly and legally issued to TOCS, as assignee from the
inventor of the entire right, title and interest in and to the '909 Patent, and which since that date,
has been and still is the owner of the '909 Patent. A true and correct copy of the '909 Patent is
attached hereto as Exhibit B.
9. In violation of 35 U.S.C. §27l, IRC has infringed claims of the '836 Patent
and the '909 Patent by using, making, offering to sell and/or selling, or causing others to use,
make, offer to sell or sell systems and methods that are covered by claims of the '836 Patent and
the '909 Patent, without the authority or license of TOCS.
10. TOCS has been damaged by the IRC’s infringement of the '836 Patent and
the '909 Patent, and will continue to be damaged unless such infringement is enjoined by this
Court.
ll. IRC’s infringement has been willful, warranting the assessment of
increased damages pursuant to 35 U.S.C. § 285.
WHEREFORE, Plaintiff respectfully demands judgment that:
2

Case 1:05-cv-00816-SLR Document 1 Filed 11/29/2005 Page 3 of 4
WHEREFORE, Plaintiff respectfully demands judgment that:
A. Pursuant to 35 U.S.C. § 283, IRC, its agents, servants, employees and
attorneys, and those persons in active concert or participation with them, be preliminarily and
permanently enjoined from infringing, inducing infringement of, or contributing to the
infringement of, the '836 Patent and the '909 Patent;
B. Pursuant to 35 U.S.C. § 284, IRC pay to Plaintiff such damages as
Plaintiff has sustained in consequence of IRC’s patent infringement, and to account for and pay
to Plaintiff all damages due to the infringement, including without limitation Plaintiffs lost
profits;
C. Pursuant to 35 U.S.C. § 284, this Court enter judgment for Plaintiff for
three times such damages, together with pre-judgment interest, as a result of IRC’s willful
infringement;
D. Pursuant to 35 U.S.C. § 285, IRC pay to Plaintiff its reasonable attorneys’
fees, as well as the full costs of this action; and
E. Plaintiff have such other and further relief as the Court may deem just and
equitable.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands a jury trial of all issues so triable.
3

Case 1:05-cv-00816-SLR Document 1 Filed 11/29/2005 Page 4 of 4
MORRIS, NICHOLS, ARSHT & TUNNELL
Jgck Blumen§ld (#1014)
Maryellen Noreika (#3208)
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899 ,
(302) 658-9200
Attorneys for Plaintiff
OF COUNSEL:
LAW OFFICES OF GARY A. ROSEN, P.C.
Gary A. Rosen
Patrick Madamba, Jr.
1831 Chestnut Street
Suite 802
Philadelphia, PA 19103
(215) 972-0600
November 29, 2005
4 ‘\
\