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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

ARRIVALSTAR S.A. and MELVINO 

TECHNOLOGIES LIMITED, 

Plaintiffs, 

 vs. 

Case No.: 1:12-cv-0773

BRIGHTSKY LLC, XNNOVATION 

CANADA, INC., INTELLIGENTONE 

TECHNOLOGIES, INC., and SECURACOM 

GPS, INC. D/B/A GPS ANYPLACE 

DEMAND FOR JURY TRIAL 

Defendants. 

 

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiffs ArrivalStar S.A. and Melvino Technologies Limited (collectively, 

“ArrivalStar” or “Plaintiffs”), by and through their undersigned attorneys, for their complaint 

against defendants 

BrightSky LLC (“BrightSky”), Xnnovation Canada, Inc. (“Xnnovation”), 

IntelligentOne Technologies, Inc.(“IntelligentOne”), and SecuraCom GPS, Inc. D/B/A GPS 

AnyPlace (“GPS AnyPlace”)(BrightSky, Xnnovation, IntelligentOne, and GPS AnyPlace are 

referred to herein as “Defendants”) hereby allege as follows: 

NATURE OF LAWSUIT

1. This action involves claims for patent infringement arising under the patent 

laws of the United States, Title 35 of the United States Code. This Court has exclusive 

jurisdiction over the subject matter of the Complaint under 28 U.S.C. § 1338(a). 

THE PARTIES

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2. ArrivalStar S.A. is a corporation organized under the laws of Luxembourg and 

having offices at 67 Rue Michel, Welter L-2730, Luxembourg. 

3. Melvino Technologies Limited is a corporation organized under the laws of 

the British Virgin Island of Tortola, having offices at P.O. Box 3152, RG Hodge Building, 

Road Town, Tortola, British Virgin Islands. 

4. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 6,278,936 (“the ‘936 patent”), entitled “System and 

method for an advance notification system for monitoring and reporting proximity of a 

vehicle,” issued August 21, 2001. A copy of the ‘936 is annexed hereto as Exhibit A. 

5. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 6,714,859 (“the ‘859 patent”), entitled “System and 

method for an advance notification system for monitoring and reporting proximity of a 

vehicle,” issued March 30, 2004. A copy of the ‘859 is annexed hereto as Exhibit B. 

6. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 6,741,927 (“the ‘927 patent”), entitled “Userdefinable communications methods and systems,” issued May 25, 2004. A copy of the ‘927 

is annexed hereto as Exhibit C. 

7. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 6,804,606 (“the ‘606 patent”), entitled “Notification 

systems and methods with user-definable notifications based upon vehicle proximities,” 

issued October 12, 2004. A copy of the ‘606 is annexed hereto as Exhibit D. 

8. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 6,904,359 (“the ‘359 patent”), entitled “Notification 

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systems and methods with user-definable notifications based upon occurance of events,” 

issued June 7, 2005. A copy of the ‘359 patent is annexed hereto as Exhibit E. The ‘359 

patent was the subject of an Inter Partes reexamination at the United States Patent and 

Trademark Office. A Reexamination Certificate was issued on May 25, 2010 and is annexed 

hereto as Exhibit F. 

9. ArrivalStar owns all right, title and interest in, and has standing to sue for 

infringement of United States Patent No. 7,191,058 (“the ‘058 patent”), entitled “Notification 

systems and methods enabling user entry of notification trigger information based upon 

monitored mobile vehicle location,” issued March 13, 2007. A copy of the ‘058 patent is 

annexed hereto as Exhibit G. 

10. Defendant BrightSky is a Florida Limited Liability Company having a place 

of business at 557 Bimini Bay Boulevard, Apollo Beach, Florida 33572. BrightSky transacts 

business and has, at a minimum, offered to provide and/or provided in this judicial district 

and throughout the State of Illinois services that infringe claims of the ‘936, ‘859, ‘927, ‘606, 

and ‘359 patents. 

11. Defendant Xnnovation is a Canadian Corporation having a place of business 

at 38 Place du Commerce, #11-280, Ile des Soeurs, Quebec, H3E 1T8, Canada. Xnnovation 

transacts business and has, at a minimum, offered to provide and/or provided in this judicial 

district and throughout the State of Illinois services that infringe claims of the ‘936, ‘859, 

‘927, ‘606, and ‘359 patents. 

12. Defendant IntelligentOne is a Florida Corporation having a place of business 

at 3 Marina Terrace, Treasure Island, Florida 33706. IntelligentOne transacts business and 

has, at a minimum, offered to provide and/or provided in this judicial district and throughout 

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the State of Illinois services that infringe claims of the ‘936, ‘859, ‘927, ‘606, and ‘359 

patents. 

13. Defendant GPS Anyplace is a Florida Corporation having a place of business 

at 34719 Sykes Road, St. Helens Oregon 07051. GPS Anyplace transacts business and has, at 

a minimum, offered to provide and/or provided in this judicial district and throughout the 

State of Illinois services that infringe claims of the ‘936, ‘859, ‘927, ‘606, ‘359, and ‘058 

patents. 

14. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). 

DEFENDANT BRIGHTSKY’S ACTS OF PATENT INFRINGEMENT

15. Defendant BrightSky has infringed claims of the ‘936, ‘859, ‘927, ‘606, and 

‘359 patents through, among other activities, the use and sale of BrightSky’s Tracking Portal 

vehicle tracking system. 

16. Defendant BrightSky’s infringement has injured and will continue to injure 

ArrivalStar unless and until this Court enters an injunction prohibiting further infringement 

and, specifically, enjoining further use of methods and systems that come within the scope of 

the ‘936, ‘859, ‘927, ‘606, and ‘359 patents. 

DEFENDANT XNNOVATION’S ACTS OF PATENT INFRINGEMENT

17. Defendant Xnnovation has infringed claims of the ‘936, ‘859, ‘927, ‘606, and 

‘359 patents through, among other activities, the use and sale of Xnnovation’s GloboTrack 

Cloud Server vehicle tracking system. 

18. The GloboTrack Cloud Server vehicle tracking system was developed by 

BrightSky. 

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19. Defendant Xnnovation’s infringement has injured and will continue to injure 

ArrivalStar unless and until this Court enters an injunction prohibiting further infringement 

and, specifically, enjoining further use of methods and systems that come within the scope of 

the ‘936, ‘859, ‘927, ‘606, and ‘359 patents. 

DEFENDANT INTELLIGENTONE’S ACTS OF PATENT INFRINGEMENT

20. Defendant IntelligentOne has infringed claims of the ‘936, ‘859, ‘927, ‘606, 

and ‘359 patents through, among other activities, the use and sale of IntelligentOne’s 

KnowWhere GPS vehicle tracking system. 

21. The KnowWhere GPS vehicle tracking system was developed by BrightSky. 

22. Defendant IntelligentOne’s infringement has injured and will continue to 

injure ArrivalStar unless and until this Court enters an injunction prohibiting further 

infringement and, specifically, enjoining further use of methods and systems that come 

within the scope of the ‘936, ‘859, ‘927, ‘606, and ‘359 patents. 

DEFENDANT GPS ANYPLACE’S ACTS OF PATENT INFRINGEMENT

23. Defendant GPS Anyplace has infringed claims of the ‘936, ‘859, ‘927, ‘606, 

and ‘359 patents through, among other activities, the use and sale of GPS Anyplace’s 

Personnel tracking system. 

24. GPS Anyplace’s Personnel tracking system was developed by BrightSky. 

25. Defendant GPS Anyplace has also infringed claims of the ‘859, ‘927, ‘359, 

and ‘058 patents through the use and sale of GPS Anyplace’s Fleet Tracking system. 

26. Defendant GPS Anyplace’s infringement has injured and will continue to 

injure ArrivalStar unless and until this Court enters an injunction prohibiting further 

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infringement and, specifically, enjoining further use of methods and systems that come 

within the scope of the ‘936, ‘859, ‘927, ‘606, ‘359, and ‘058 patents. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs ask this Court to enter judgment against the Defendants, 

and against their subsidiaries, affiliates, agents, servants, employees and all persons in active 

concert or participation with them, granting the following relief: 

A. An award of damages adequate to compensate ArrivalStar for the 

infringement that has occurred, together with prejudgment interest from the date that 

Defendant’s infringement of the ArrivalStar patents began; 

B. Increased damages as permitted under 35 U.S.C. § 284; 

C. A finding that this case is exceptional and an award to ArrivalStar of its 

attorneys’ fees and costs as provided by 35 U.S.C. § 285; 

D. A permanent injunction prohibiting further infringement, inducement and 

contributory infringement of the ArrivalStar patents; and 

E. Such other and further relief as this Court or a jury may deem proper and just. 

JURY DEMAND

ArrivalStar demands a trial by jury on all issues presented in this Complaint. 

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Dated: February 3, 2012 Respectfully submitted, 

 /s/ Anthony E. Dowell 

Anthony E. Dowell 

aedowell@dowellbaker.com 

Geoffrey D. Smith 

GSmith@dowellbaker.com 

DOWELL BAKER, P.C. 

201 Main St., Suite 710 

Lafayette, IN 47901 

(765) 429-4004 

(765) 429-4114 (fax) 

ATTORNEYS FOR PLAINTIFFS 

ARRIVALSTAR S.A. and 

MELVINO TECHNOLOGIES 

LIMITED 

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