UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

MVCONNECT, LLC, an Illinois Limited
Liability Company,

Plaintiff,

v.

RECOVERY DATABASE NETWORK, INC.,
a Delaware corporation, and DIGITAL
RECOGNITION NETWORK, INC., a
Delaware corporation,

Defendants.
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COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff MVCONNECT, LLC (MV) hereby files its Complaint for Patent Infringement
against defendants Recovery Database Network, Inc. (RDN) and Digital Recognition Network,
Inc. (DRN). MV seeks damages, injunctive and other relief for DRNs and RDNs willful
infringement of United States Patent No. 7,579,965 B2.
NATURE OF THE ACTION
1. This is an action for patent infringement under the patent laws of the United
States, 35 U.C.S. 1 et seq.
JURISDICTION AND VENUE
2. The Court has exclusive jurisdiction over the subject matter of this lawsuit
pursuant to 28 U.S.C. 1331 and 1338(a).
3. This Court has personal jurisdiction over defendants RDN and DRN because both
companies transact substantial business in Illinois.
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4. Venue is proper in the Northern District of Illinois pursuant to 28 U.S.C.
1400(b).
THE PATENT IN SUIT
5. On November 18, 2009, United States Patent No. 7,579,965 B2 entitled Vehicle
Data Collection and Processing System (the 965 Patent) was duly and lawfully issued to MV
as assignee of the inventor. MV is the owner of the 965 Patent, including the right to sue and
recover for past, present and future infringement thereof. A true and correct copy of the 965
Patent is attached as Exhibit A.
THE PARTIES
6. Plaintiff MV is an Illinois limited liability company with its principal place of
business in Palatine, Illinois.
7. Recovery Database Network, Inc. is a Delaware Corporation with its principal
place of business at 4100 International Plaza, Suite 2-B10, Fort Worth, Texas, 76109.
8. Defendant Digital Recognition Network, Inc. is a Delaware Corporation with its
principal place of business at 4100 International Plaza, Suite 2-B10, Fort Worth, Texas, 76109.
COUNT I

PATENT INFRINGEMENT AGAINST DRN AND RDN

9. The allegations of paragraphs 1-8 of the Complaint are incorporated herein by this
reference.
10. DRN and RDN have infringed and continue to infringe, have induced and
continue to induce others to infringe, and have committed and continue to commit acts of
contributory infringement of one or more claims of the 965 patent in this district and elsewhere
by making, using, selling, offering for sale and/or importing automated license plate recognition
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technology, which includes the use of mobile camera units and related databases, that is covered
by one or more claims of the 965 patent.
11. DRNs and RDNs acts of infringement are willful and deliberate.
12. DRN and RDN have caused and will continue to cause MV substantial damage
and irreparable injury by virtue of their past dealings and continuing infringement of the 965
patent. MV will suffer further damage and irreparable injury unless and until DRN and RDN are
enjoined by this Court from continuing such infringement.
13. This case is exceptional pursuant to 35 U.S.C. 285.
PRAYER FOR JUDGMENT
WHEREFORE, MV prays for judgment:
a) Entering a preliminary and permanent injunction enjoining DRN and RDN,
their officers, agents, servants, employees and those persons and entities
acting in concert or participation with any of them, from making, using,
offering for sale, selling or importing any product that infringes the 965
patent;
b) Awarding damages for RDNs and DRNs infringement of the 965 patent;
c) Increasing damages, up to three times the amount found, due to RDNs and
DRNs willful infringement;
d) Awarding pre- and post-judgment interest on the damages assessed;
e) Declaring this case exceptional pursuant to 35 U.S.C. 285 and awarding MV
its reasonable attorneys fees and costs of suit; and
f) Awarding to MV such further necessary or proper relief as the Court deems
just.
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DEMAND FOR JURY TRIAL
MV requests a trial by jury.
Date: September 29, 2010
Respectfully submitted,

MVCONNECT, LLC


By: /s/ Peter M. Spingola
One of its Attorneys

Robert A. Chapman (6191210)
Peter M. Spingola (6243942)
Sara Siegall (6297622)
CHAPMAN SPINGOLA, LLP
77 West Wacker Drive Suite 4800
Chicago, Illinois 60601
312/606-8754 (phone)
312/630-9233 (fax)

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