UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION

SCRIPTCHEK VISUAL 

VERIFICATION SYSTEMS, INC., 

Plaintiff, 

v. 

R.R. DONNELLEY & SONS 

COMPANY 

Defendant. 

 CASE NO.: ____________________ 

NOTICE OF REMOVAL 

Pursuant to 28 U.S.C. §§ 1332(a), 1338(a), 1367, 1441, 1446, and 1454, Defendant R.R. 

Donnelley & Sons Company (“R.R. Donnelley”) hereby removes the above-captioned matter from 

the Circuit Court of the Seventeenth Judicial Circuit in and for Broward County, Florida to the 

United States District Court for the Southern District of Florida, Fort Lauderdale Division. R.R. 

Donnelley’s Notice of Removal is based on the following: 

The State Court Action 

1. On or about February 24, 2020, Plaintiff Scriptchek Visual Verification Systems, 

Inc. (“Plaintiff”) filed a complaint against R.R. Donnelley in the Seventeenth Judicial Circuit in 

and for Broward County, Florida, as case number CACE-20-003398 (the “Complaint”). R.R. 

Donnelley was served with a copy of the Complaint on February 27, 2020, via R.R. Donnelley’s 

registered agent. The Complaint is attached as Exhibit 1. (See also Ex. 2 (the civil cover sheet).) 

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2. In the Complaint, Plaintiff asserts claims for breach of contract, specific 

performance, and unjust enrichment. Plaintiff alleges that it and R.R. Donnelley have a 

Manufacture Agreement where Plaintiff granted R.R. Donnelley a limited, non-exclusive right to 

manufacture and sell Plaintiff’s patented Extended Tab Prescription Drug Label to customers 

approved by Plaintiff who have entered into license agreements with Plaintiff. (Compl. ¶ 13.) 

Plaintiff further alleges that R.R. Donnelley has sold – and is still selling – Plaintiff’s “patented” 

Extended Tab Prescription Drug Label to non-approved customers, including CVS Pharmacy, in 

violation of the Manufacture Agreement. (Compl. ¶ 31.) Plaintiff also alleges that R.R. Donnelley 

breached the Manufacture Agreement by failing to keep proper books of account and failing to 

render written reports to Plaintiff as well as failing to include certain markings on Plaintiff’s 

Extended Tab Prescription Drug Label sold by R.R. Donnelley. (Compl. ¶¶ 47, 54.) Plaintiff 

alternatively alleges a count for unjust enrichment. (Compl. ¶¶ 66-88.) Plaintiff’s Complaint 

seeks damages with interest, costs, as well as specific performance to provide books of accounts 

and written reports from 2006 to present and a demand that R.R. Donnelley immediately cease and 

desist from any and all manufacturing of Plaintiff’s patented Extended Tab Prescription Drug 

Label for non-approved customers. (Compl. ¶¶ 49, 55, 65.) Plaintiff alleges that the amount in 

controversy exceeds $30,000, exclusive of interest, costs, and attorney fees (Comp. ¶ 3), which is 

the amount of controversy necessary for circuit court jurisdiction (see Fla. Stat. § 34.01(c)(2)), but 

Plaintiff fails to allege an actual estimated amount in controversy. 

3. With the Complaint, Plaintiff served Plaintiff Scriptchek Visual Verification 

Systems, Inc.’s First Request for Production to Defendant R.R. Donnelley & Sons Company, Inc. 

(“Plaintiff’s First Request for Production”) (see Ex. 3). 

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4. Following an agreed order on the deadline to respond to the Complaint (see Ex. 4), 

R.R. Donnelley filed a Motion to Dismiss, Motion to Strike, Motion in the Alternative for More 

Definite Statement, and Incorporated Memorandum of Law (“Motion to Dismiss”) on May 18, 

2020. (See Ex. 5.) R.R. Donnelley sought dismissal of the Complaint on the grounds that 

Plaintiff’s claims fail to state any claim under Florida law. (Motion to Dismiss at 4.) R.R. 

Donnelley further sought to strike all references to a “Mutual Confidentiality Agreement” in the 

Complaint as it was unclear how it related to Plaintiff’s claims and appeared wholly irrelevant. 

(Motion to Dismiss at 16.) R.R. Donnelley alternatively sought a more definite statement from 

Plaintiff regarding its claims, its anticipated damages, and the relevance of the Mutual 

Confidentiality Agreement. (Motion to Dismiss at 16-21.) 

5. R.R. Donnelley filed a Pro Hac Vice motion, which was granted by agreed order. 

(See Ex. 6 (the motion) and Ex. 7 (the agreed order).) 

6. On May 27, 2020, Plaintiff’s counsel and counsel for R.R. Donnelley held a Zoom 

conference. The purpose of the conference was to serve as an introductory meeting for counsel 

for both parties. During the conference, the counsel for both parties discussed the Motion to 

Dismiss and Plaintiff’s First Request for Production. Plaintiff’s counsel indicated that they 

planned to respond to the Motion to Dismiss during the following week. 

7. On June 1, 2020, R.R. Donnelley served its response to Plaintiff’s First Request for 

Production and filed a corresponding Notice of Service to the court. (See Ex. 8.) 

8. On June 4, 2020, Plaintiff filed its response to the Motion to Dismiss. (See Ex. 9.) 

In its response, similar to Plaintiff counsel’s remarks during the May 27, 2020 conference, Plaintiff 

clarified that its allegations are limited to Plaintiff’s “patented label.” (See generally Plaintiff’s 

Response to Defendant’s Motion to Dismiss Plaintiff’s Complaint, Motion to Strike, Motion in the 

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Alternative for More Definite Statement, and Incorporated Memorandum of Law (“Response to 

Motion to Dismiss”) (noting that Plaintiff no longer refers to its Extended Tab Prescription Drug 

Label as “proprietary and patented” as it did in the Complaint but only as “patented”).) In fact, 

Plaintiff confirmed a definition of the Extended Tab Prescription Drug Label provided by R.R. 

Donnelley in the Motion to Dismiss that indicates that any labels at issue have to relate to certain 

patent applications. (Response to Motion to Dismiss ¶ 16.) Plaintiff also clarified that its breach 

of contract claims are not founded on the Mutual Confidentiality Agreement. (Response to Motion 

to Dismiss ¶ 60.) 

9. On June 8, 2020, R.R. Donnelley filed a Notice of Appearance and Designation of 

E-mail Addresses. (See Ex. 10.) 

10. On June 16, 2020, Plaintiff filed a Notice of Hearing with regards to the Motion to 

Dismiss set for July 7, 2020. (See Ex. 11.) 

Statutory Grounds for Removal 

11. R.R. Donnelley’s removal of this case is based upon 28 U.S.C. §§ 1441(a) and 

1454.1 Section 1441(a) authorizes the removal of any civil actions filed in state court provided 

that the United States District Court has original jurisdiction for such actions. Section 1454(a) 

authorizes the removal of “[a] civil action in which any party asserts a claim for relief arising under 

any Act of Congress relating to patents” to federal district court. This Court has original 

jurisdiction over this action under 28 U.S.C. § 1332(a), which provides such jurisdiction over civil 

1

 Given that the state court action is currently in the Motion to Dismiss stage, R.R. Donnelley has 

yet to raise any counterclaims or affirmative defenses. Were the state court action to proceed to 

that stage, R.R. Donnelley anticipates patent-related counterclaims and affirmative defenses, 

including patent invalidity and non-infringement, which would also provide for removal based 

on 28 U.S.C. § 1454. (See Alexsam, Inc. v. WildCard Sys., Inc., No. 15-CIV-61736, 2015 WL 

13688558 (S.D. Fla. Nov. 20, 2015).) 

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actions in which the parties are diverse and in which the amount in controversy exceeds $75,000, 

exclusive of interest or costs. This Court also has original jurisdiction over Count I of this action 

(the breach of contract claim pertaining to the alleged manufacturing and selling of Plaintiff’s 

patented Extended Tab Prescription Drug Label to non-approved customers) under 28 U.S.C. 

§ 1338(a), which provides such jurisdiction over “any civil action arising under any Act of 

Congress relating to patents[.]” In view of the Court’s federal question jurisdiction under 28 

U.S.C. § 1338(a) over Count I, the Court may exercise supplemental jurisdiction under 28 U.S.C. 

§ 1367(a) over all of Plaintiff’s other claims. 

Diversity of Citizenship 

12. Pursuant to 28 U.S.C. §§ 1332(a) and (c), the diversity required for removal exists 

here because Plaintiff is diverse from R.R. Donnelley. Plaintiff is a Florida Corporation while 

R.R. Donnelley is a Delaware Corporation. (Comp. ¶¶ 4-5.) Moreover, Plaintiff’s principal place 

of business is Florida, while R.R. Donnelley’s principal place of business is Illinois. The 

citizenship of the parties is therefore diverse. 

More than $75,000 in Controversy 

13. The amount in controversy exceeds $75,000. Despite its failure to identify any 

specific patents or bases for damages in its Complaint, Plaintiff’s counsel’s remarks on May 27, 

2020 and its Response to Motion to Dismiss establish that for Plaintiff to prove its breach of 

contract claim in Count I of the Complaint, Plaintiff must establish that the products allegedly sold 

by RR Donnelley to CVS fall within the scope of Plaintiff’s patents licensed under the Manufacture 

Agreement. In other words, Plaintiff must prove that the products at issue infringe Plaintiff’s valid 

patents that were licensed. By clarifying that its claims are focused on Plaintiff’s patents (see, e.g.,

Response to Motion to Dismiss ¶ 16), Plaintiff confirmed that certain tab labels manufactured and 

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sold by R.R. Donnelley—previously and currently—might be at issue. For approximately the last 

five years, R.R. Donnelley’s business records show that R.R. Donnelley generated revenue from 

sales of tab labels at issue to CVS, such that a reasonable royalty2 on those sales and anticipated 

future sales would readily exceed $75,000. 

14. Accordingly, the amount in controversy—based solely on the subject matter of 

Plaintiffs’ claims and without any admission on R.R. Donnelley’s part—exceeds $75,000. Thus, 

the amount-in-controversy requirement of 28 U.S.C. § 1332(a) is satisfied.3

Arising Under Patent Law 

15. “[Section] 1338(a) jurisdiction . . . extend[s] only to those cases in which a wellpleaded complaint establishes either that federal patent law creates the cause of action or that the 

plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal 

patent law, in that patent law is a necessary element of one of the well-pleaded claims.” 

(Christianson v. Colt Industries Operating Corp., 486 U.S. 800, 809 (1988) (emphasis added).) 

16. As clarified by Plaintiff counsel’s remarks on May 27, 2020 and Plaintiff’s 

Response to Motion to Dismiss filed June 4, 2020, Plaintiff’s claim that R.R. Donnelley violated 

the Manufacture Agreement by allegedly manufacturing and selling Plaintiff’s patented Extended 

2

 Patent infringement damages are no less than “a reasonable royalty for the use made of the 

invention by the infringer, together with interest and costs as fixed by the court.” 35 U.S.C. 

§ 284. 

3

 Should the Court deem that more information is necessary to determine whether the amount-incontroversy requirement is satisfied, limited post-removal discovery would be an appropriate 

method to fully resolve this issue. (See Pretka v. Kolter City Plaza II, Inc., 608 F.3d 744, 774 

(11th Cir. 2010) (Pryor, J., concurring) (“Our precedents have taken for granted that a defendant 

who removes a civil action has the same right that plaintiff enjoys to conduct discovery about 

jurisdictional facts.”); Williams v. Best Buy Co., 269 F.3d 1316, 1319 (11th Cir. 2001) (“[A] 

district court may properly consider post-removal evidence in determining whether the 

jurisdictional amount was satisfied at the time of removal.”) (citing Sierminski v. Transouth Fin. 

Corp., 216 F.3d 945, 949 (11th Cir. 2000)).) 

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Tab Prescription Drug Label is directly related to and limited to Plaintiff’s patents. As agreed by 

Plaintiff, the Extended Tab Prescription Drug Label “relates to certain then-pending patent 

applications.” (Response to Motion to Dismiss ¶ 16.) Moreover, as clearly established in its 

Response to Motion to Dismiss, the crux of Plaintiff’s breach of contract claim rests entirely on 

that “patented” Extended Tab Prescription Drug Label. Therefore, in order to prevail on its breach 

of contract claim, Plaintiff would need to demonstrate that any and all tab labels that R.R. 

Donnelley sold to non-approved customers fell under Plaintiff’s patent(s). Put another way, to 

prevail, Plaintiff will have to show that R.R. Donnelley infringed Plaintiff’s patent(s). 

17. With regards to arising under patent law, this is hardly a novel fact pattern. Indeed, 

courts have addressed similar fact patterns in the past, holding that claims such as the one in this 

case do arise under patent law, justifying federal jurisdiction. In Kleinerman v. Luxtron, 107 F. 

Supp. 2d 122 (D. Mass. 2000), the plaintiff entered into a license agreement with the defendant in 

which the plaintiff granted the defendant a license to use, make, or sell products incorporating the 

plaintiff’s patents in consideration for royalty payments based on the defendant’s sales volume. 

(Id. 123.) The plaintiff later alleged that the defendant did not report all sales of products using 

the patented technology in violation of the license agreement, depriving the plaintiff of royalty 

payments. (Id.). The plaintiff filed a breach of contract claim, which the defendant removed to 

federal court. (Id.) On motion to remand, the district court denied the remand motion, noting that 

“an analysis of patent infringement is necessary and subject matter jurisdiction lies in a United 

States District Court” since “[i]f, as [the plaintiff] alleges, [the defendant] used the patented 

technology but failed to pay royalties thereof, it violated the License. To determine if that 

happened, the finder of fact must consider whether the unreported products infringed [the 

plaintiff’s] patents.” (Id. 124.) 

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18. In an analogous case, U.S. Valves, Inc. v. Dray, 190 F.3d 811 (7th Cir. 1999) (“Dray 

I”), a patent licensee brought action against licensor for breach of contract. (Id. 812.) The licensee 

alleged that the licensor had sold valves that were covered by the licensed patents. (Id.) When 

assessing whether this breach of contract claim invoked patent law jurisdiction, the court relied 

upon the second prong of Christianson (emphasized supra). (Id. 813-14.) In doing so, the court 

noted, “[the licensee] claimed that [the licensor] sold valves in contravention of this provision . . . 

If the only way for [the licensee] to establish this claim is for it to show that [the licensor] sold 

valves covered by the patents licensed to [the licensee ], then the court must first examine the 

patent and determine which valves are covered and whether the patent was infringed. Thus patent 

law is a necessary element of [the licensee’s] breach of contract action.” (Id. See also U.S. Valves, 

Inc. v. Dray, 212 F.3d 1368, 1372 (Fed. Cir. 2000) (“Dray II”) (subsequent Federal Circuit decision 

affirming the Seventh Circuit’s conclusion); Berman v. OpenTV Corp., No. C-09-4065 MMC, 

2010 WL 3987448, at *3 (N.D. Cal. Oct. 12, 2010) (relying on Dray II to hold that “[w]here a 

plaintiff asserts that a breach of contract occurs from a defendant’s infringement of the plaintiff’s 

patents, the breach of contract claim necessarily depends on resolution of a substantial question of 

patent law”); Bd. of Regents of Univ. of Texas Sys. V. 3d Sys., Inc., No. A-10-CA-871-SS, 2011 

WL 13324299, at *3 (W.D. Tex. July 12, 2011) (relying on Dray II to find patent law jurisdiction 

in case without diversity jurisdiction where parties were not diverse).) 

19. Even cases following the Supreme Court’s decision in Gunn v. Minton, 568 U.S. 

251 (2013) have continued to recognize the holding in Dray II and have held patent law jurisdiction 

over breach of contract claims. (See Levi Straus & Co. v. Aqua Dynamics Sys., Inc., No. 15-CV04718-WHO, 2016 WL 1365946, at **5-6 (N.D. Cal. Apr. 6, 2016) (citing Dray II and others to 

find patent law jurisdiction over breach of contract claim); Alexsam, Inc. v. Green Dot Corp., No. 

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215CV05742CASPLAX, 2015 WL 6520917, at *3 (C.D. Cal. Sept. 28, 2015); Induction 

Innovations, Inc. v. Pacholok, No. 13 CV 5102, 2014 WL 4922350, at *13 (N.D. Ill. Sept. 30, 

2014) (citing Dray II when ruling that “complaint for breach of contract necessarily contains an 

issue of federal patent law); see also Jang v. Boston Sci. Corp., 767 F.3d 1334, 1336 (Fed. Cir. 

2014) (affirming post-Gunn patent law jurisdiction existed where “[a]lthough this cases arises 

from a [state law breach of contract] claim, rather than directly as a patent infringement claim, [the 

plaintiff’s] right to relief . . . depends on an issue of federal patent law – whether the [products] 

sold by [the defendants] would have infringed [the plaintiff’s patents]”) (internal quotation marks 

omitted).) 

20. R.R. Donnelley notes the decision in MDS (Canada) Inc. v. Rad Source Techs., 

Inc., 720 F.3d 833 (11th Cir. 2013) where the court found no patent law jurisdiction for that 

particular breach of contract action, but as explained in Xitronix Corp. v. KLA-Tencor Corp., 916 

F.3d 429 (5th Cir. 2019), MDS was analogous to Gunn since “like the patent issues in Gunn, [the 

issue in MDS] was backwards-looking and insubstantial because it indisputably concerned a sinceexpired patent.” (Id. 440 (emphasis added).) In contrast, the patents underlying the breach of 

contract cases cited above were deemed either valid or validity was in dispute, and patent law 

jurisdiction was found. Indeed, the Federal Circuit in Jang, which was decided after MDS, noted 

the difference in the Gunn “substantiality” test analyzed therein, which is in contrast to MDS’s 

determination of insubstantiality. Therefore, MDS is distinguishable and the above cited cases 

should govern. (See also Wila B.V. v. Wilson Tool Int’l, Inc., No. CV WDQ-06-2861, 2007 WL 

9780502, at *1 (D. Md. Apr. 2, 2007) (noting that the district court, when considering federal 

question jurisdiction under 28 U.S.C. § 1338, “follow[s] applicable Federal Circuit precedent, if 

such authority is available,” rather than the law of the regional circuit).)

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21. Given the wealth of case law supporting that breach of contract claims such as the 

one at issue in this case arise under patent law, it is clear that this breach of contract claim too 

arises under patent law. Therefore it is proper for this Court to exercise section 1338(a) jurisdiction 

over Plaintiff’s breach of contract claim and, should diversity jurisdiction not apply, section 

1367(a) supplemental jurisdiction over the remaining claims. 

Timeliness of Removal 

22. Pursuant to 28 U.S.C. § 1446(b)(3), “if the case stated by the initial pleading is not 

removable, a notice of removal may be filed within thirty days after receipt by the defendant, 

through service or otherwise, of a copy of an amended pleading, motion, order or other paper from 

which it may first be ascertained that the case is one which is or has become removable.” When 

R.R. Donnelley first received Plaintiff’s Complaint, it was not clear whether this case was 

removable. As discussed in R.R. Donnelley’s Motion to Dismiss, Plaintiff’s Complaint carried 

clear deficiencies as well as contained parts that seemed irrelevant or otherwise confusing. 

However, Plaintiff counsel’s assertions during the May 27, 2020 conference first led R.R. 

Donnelley to ascertain that this case was subject to removal under both diversity jurisdiction as 

well as patent law jurisdiction. Our understanding that this case was subject to removal was 

confirmed via other paper in the form of Plaintiff’s Response to Motion to Dismiss. 

23. Specifically, prior to speaking to Plaintiff’s counsel and receiving Plaintiff’s 

Response to Motion to Dismiss, there was doubt as to whether Plaintiff’s claims were based strictly 

on patents or whether Plaintiff’s claims were also based on some misuse of confidential and 

proprietary information, or some other issue. Plaintiff’s Response to Motion to Dismiss made 

clear that the patents are essential to defining what was licensed under the Manufacture Agreement. 

In particular, throughout its Response to Motion to Dismiss, Plaintiff only referred to the Extended 

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Tab Prescription Drug Label as “patented.” Furthermore, Plaintiff confirmed a definition of the 

Extended Tab Prescription Drug Label indicating that the label at issue has to relate to certain 

patent applications. (Response to Motion to Dismiss ¶ 16.) Moreover, the Plaintiff confirmed that 

the Mutual Confidentiality Agreement, which may have been alleged to be a basis for misuse of 

confidential information claims, is not necessary to any claims. (Response to Motion to Dismiss 

¶¶ 59-63.) Similarly, these clarifications, confirmed by Plaintiff’s Response to Motion to Dismiss, 

permitted R.R. Donnelley to determine that the amount in controversy will exceed $75,000, as 

discussed above, making this case subject to removal under diversity jurisdiction. 

24. This Notice of Removal is filed within 30 days of May 27, 2020, the day of the 

conference with Plaintiff’s counsel in which R.R. Donnelley first ascertained that this case is 

subject to removal. This Notice of Removal is also filed within 30 days of June 4, 2020, the day 

R.R. Donnelley received Plaintiff’s Response to Motion to Dismiss, which was the first paper 

served on R.R. Donnelley after it ascertained that this case is subject to removal and which itself 

further confirmed federal jurisdiction. Either way, the Notice of Removal is timely pursuant to 28 

U.S.C. § 1446(b)(3).4

Written Notice of Removal 

25. As 28 U.S.C. § 1446(d) requires, a copy of this Notice of Removal is being 

submitted to the Clerk of the Seventeenth Judicial Circuit in and for Broward County, Florida, and 

is being served on counsel of record for Plaintiff. 

26. Pursuant to 28 U.S.C. § 1446(d), true and correct copies of all process, pleadings, 

and other documents served on R.R. Donnelley are attached hereto. (See Ex. 12.) 

4

 If R.R. Donnelley’s Notice of Removal is deemed untimely for any reason, 28 U.S.C. 

§ 1454(b)(2) states “the time limitations contained in section 1446(b) may be extended at any 

time for cause shown” so long as “the removal is based solely on [section 1454].” 

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27. A copy of the docket sheet from the Seventeenth Judicial Circuit in and for Broward 

County, Florida is attached hereto. (See Ex. 13.) 

28. R.R. Donnelley reserves the right to amend or supplement this Notice of Removal. 

29. If any questions arise as to the propriety of the removal of this action, R.R. 

Donnelley requests the opportunity to present a brief and requests oral argument in support of 

removal. 

No Waiver 

30. By filing this Notice of Removal, R.R. Donnelley does not waive any defenses 

available to it, does not consent to personal jurisdiction within any Florida state or federal court, 

and does not admit any of Plaintiff’s material allegations, including allegations of wrongdoing by 

R.R. Donnelley or allegations concerning damages. 

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WHEREFORE, for the reasons stated above, R.R. Donnelley hereby removes this action 

to this Court. 

Dated: June 26, 2020 Respectfully submitted, 

R.R. DONNELLEY SONS & COMPANY 

By: /s/ Eugene K. Pettis___________________ 

Eugene K. Pettis 

Debbie P. Klauber 

HALICZER, PETTIS & SCHWAMM, P.A. 

One Financial Plaza 

100 S.E. 3rd Avenue 

Seventh Floor 

Fort Lauderdale, FL 33394 

Telephone: (954) 523-9922 

Fax: (954) 522-2512 

Reginald J. Hill* 

JENNER & BLOCK LLP 

353 N. Clark Street 

Chicago, IL 60654 

Telephone: (312) 222-9350 

Fax: (312) 527-0484 

Attorneys for R.R. Donnelley & Sons Company 

*Not yet admitted in the United States District 

Court for the Southern District of Florida 

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