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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

I2Z TECHNOLOGY, LLC, §

§ Civil Action No. 12-cv-5649

Plaintiff, §

§

v. § COMPLAINT FOR

§ PATENT INFRINGEMENT

ORBITZ WORLDWIDE, INC., §

§ DEMAND FOR JURY TRIAL

Defendant. §

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff I2Z Technology, LLC (“I2Z” or “Plaintiff”), by way of its Complaint against 

Defendant Orbitz Worldwide, Inc. (“Defendant”), demands a jury trial and hereby alleges as 

follows:

NATURE OF THE ACTION

1. This is an action for patent infringement of United States Patent No. 5,345,551 

(the ’551 Patent) arising under the patent laws of the United States, 35 U.S.C § 271 et seq.

THE PARTIES

2. Plaintiff I2Z Technology, LLC is a limited liability company organized under the 

laws of Texas with its principal place of business at 3301 Marshall Avenue, Suite 302, 

Longview, Texas 75604.

3. Defendant is a corporation organized under the laws of Delaware with its 

principal place of business at 500 W. Madison Street, Suite 1000, Chicago, Illinois 60661.

JURISDICTION AND VENUE

4. This is an action for patent infringement arising under the patent laws of the 

United States, Title 35 of the United States Code. 

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5. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. 

§§ 1331 and 1338(a). 

6. This Court has personal jurisdiction over Defendant at least because Defendant

maintains its principal place of business and conducts business within this Judicial District. 

7. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391 and 28 

U.S.C. § 1400.

BACKGROUND

8. On September 6, 1994, United States Patent No. 5,345,551, entitled “METHOD 

AND SYSTEMS FOR SYNCHRONIZATION OF SIMULTANEOUS DISPLAYS OF 

RELATED DATA SOURCES,” was duly and legally issued by the United States Patent and 

Trademark Office. A true and correct copy of the ’551 Patent is attached as Exhibit A to this 

Complaint.

9. I2Z is the assignee and owner of the entire right, title, and interest in and to the 

’551 Patent, including the right to assert all causes of action arising under said patent and the 

right to any remedies for infringement of it.

10. Defendant has made and distributes to customers throughout the United States a 

software application for use on Apple ipads (“the Orbitz app”). 

COUNT I – INFRINGEMENT OF U.S. PATENT NO. 5,345,551

11. I2Z realleges and incorporates by reference the previous paragraphs of this 

complaint as though set forth in full herein.

12. Defendant has infringed and continues to infringe one or more claims of the ’551 

Patent in this Judicial District and elsewhere by making and using infringing products, including 

at least the Orbitz app, which infringes one or more claims of the ’551 Patent. By making and 

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using such an infringing product, Defendant has directly infringed one or more claims of the 

’551 Patent under 35 U.S.C. § 271(a).

13. Because of Defendant’s infringement of the ’551 Patent, I2Z has suffered 

damages and will continue to suffer damages in the future.

14. Defendant has had notice of the ’551 Patent since at least March 7, 2012, when 

I2Z sent a letter informing Defendant of its infringement of the ’551 Patent.

15. Upon information and belief, Defendant’s continued infringement despite its 

knowledge of the ’551 Patent has been objectively reckless and willful.

JURY DEMAND

16. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, I2Z demands a trial 

by jury on all issues triable as such.

PRAYER FOR RELIEF

WHEREFORE, I2Z respectfully demands judgment for itself and against Defendant as 

follows:

A. An adjudication that Defendant has infringed the ’551 Patent;

B. An award of damages to be paid by Defendant adequate to compensate I2Z for its 

past infringement of the ’551 Patent and any continuing or future infringement of the ’551 Patent 

through the date such judgment is entered, together with pre-judgment and post-judgment 

interest;

C. Increased damages pursuant to 35 U.S.C. § 284 for Defendant’s infringement of 

the ’551 Patent after having received notice of such infringement;

D. An accounting of all infringing acts including, but not limited to, those acts not 

presented at trial; 

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E. A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of 

Plaintiff’s reasonable attorneys’ fees, expenses and costs; and

F. Such other and further relief at law or in equity as the Court deems just and 

proper.

Dated: June 18, 2012 Respectfully Submitted,

/s/ Patrick Burns.

Patrick Burns

Illinois State Bar No. 3122589

GREER BURNS & CRAIN LTD.

300 S Wacker Drive, Suite 2500

Chicago, IL 60606

Office: 312-360-0080

Facsimile 312-360-9315

pburns@gbclaw.net

Attorneys for Plaintiff

I2Z TECHNOLOGY, LLC

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