IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Interface IP Holdings LLC, Plaintiff, v. Open Text Corporation, Defendant.

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Civil Action No. _____________

DEMAND FOR JURY TRIAL

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Interface IP Holdings LLC (Interface IP), by and through its undersigned counsel, files this Complaint for Patent Infringement against Defendant Open Text Corporation (Defendant) as follows: The Parties 1. Plaintiff Interface IP is a limited liability company duly organized and existing

under the laws of California, having its principal place of business in Foster City, California. 2. On information and belief, Defendant is a corporation organized and existing

under the laws of Canada, with its principal place of business in Waterloo, Ontario, Canada. Nature of the Action 3. This is a civil action for the infringement of United States Patent No. 7,296,221

(the 221 Patent) (or, the Patent-in-Suit) under the Patent Laws of the United States 35 U.S.C. 1 et seq. Jurisdiction and Venue 4. This Court has jurisdiction over the subject matter of this action pursuant to

28 U.S.C. 1331 and 1338(a) because this action arises under the patent laws of the United

States, including 35 U.S.C. 271 et seq. 5. This Court has personal jurisdiction over Defendant because, on information and

belief, Defendant conducts or has conducted business in Delaware. On information and belief, Defendant has committed and/or participated in the commission of patent infringement in Delaware and elsewhere in the United States, and has harmed and continues to harm Interface IP in Delaware. 6. 1400(b). Patent-in-Suit 7. On November 13, 2007, the 221 Patent, titled System and Method for Remote, Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 and

Automatic Reporting and Verification of Forms, was duly and lawfully issued by the PTO. The 221 Patent is attached hereto as Exhibit A. 8. Interface IP owns the 221 Patent and holds the right to sue and recover damages

for infringement thereof, including past infringement. Count I Infringement of U.S. Patent No. 7,296,221 9. 10. Paragraphs 1-8 are incorporated by reference as if fully restated herein. On information and belief, Defendant, directly and/or through intermediaries, has

acted and is acting to make, use, import, ship, distribute, offer for sale, sell, and/or advertise RightFax Fax Server Products, including, but not limited to, RightFax Fax Server (RightFax). 11. On information and belief, Defendant, alone or in conjunction with others, has

been and is now directly infringing and/or indirectly infringing the 221 Patent by way of inducement and/or contributory infringement, literally and/or under the doctrine of equivalents, in this District, and elsewhere, in violation of 35 U.S.C. 271, including developing, making, using, selling, shipping, distributing, advertising, and/or offering for sale in the United States or importing into the United States products and/or services, including, but not limited to, RightFax, that, alone or in combination with other devices and/or systems, perform each step of at least

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claims 10 and 16 of the 221 Patent. 12. On information and belief, Defendant, alone or in conjunction with others, is

violating of 35 U.S.C. 271, by developing, making, using, selling, shipping, distributing, advertising, and/or offering for sale in the United States or importing into the United States products and/or services, including, but not limited to, RightFax, that, alone or in combination with other devices and/or systems, use software for processing user-specific forms, including the ability to automatically generate and augment a request-specific identifier to a form that uniquely identifies a specific instance of a user-specific form, and stores an association of a requestspecific identifier with a specific instance of a user-specific form. 13. Defendant has been aware of the 221 Patent at least since Interface IP served the

Original Complaint. On information and belief, Defendant may have been aware of the 221 Patent as early as March 2008. 14. On information and belief, Defendant has actively, knowingly, and intentionally

induced, and continues to actively, knowingly, and intentionally induce, infringement of the 221 Patent by others (e.g., Defendants customers, distributors, partners, and/or third parties) by among other things, advertising and promoting the use of RightFax in various websites, including, but not limited to, http://rightfax.com and http://faxsolutions.opentext.com, providing and disseminating instructions on how to use RightFax in an infringing manner, and providing hardware and/or software components required by the claims of the 221 Patent. 15. On information and belief, Defendant has further actively, knowingly, and

intentionally induced, and continues to actively, knowingly, and intentionally induce, infringement of the 221 Patent by encouraging others (e.g., Defendants customers, distributors, partners, and/or third parties) to use RightFax in an infringing manner through the promotion of its Case Studies website located at http://faxsolutions.opentext.com/case-studies.aspx. 16. To date, on information and belief, Defendant continues the relevant operations of

RightFax has not provided its customers, distributors, partners, and/or third parties instructions on how to avoid infringement. Defendant continues to disseminate the same promotional and

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marketing materials, including links to its websites. 17. On information and belief, through Defendants policies and practices of not

investigating whether RightFax infringes the patents of others, Defendant intentionally took steps to avoid learning the extent of its infringement of the 221 Patent. 18. On information and belief, Defendant engages in the foregoing activities because

they specifically intend end users, customers, distributors, partners, and/or third parties to make, use, import, ship, distribute, offer for sale, sell, and/or advertise RightFax. 19. On information and belief, Defendant derives revenue from both their own and/or

third-party infringement of the 221 Patent. 20. On information and belief, Defendant contributorily infringes the 221 Patent

because it sells, imports, or offers to sell components of infringing products, including, for example, components of RightFax, that constitute a material part of the invention of the 221 Patent, knowing the components to be especially made or especially adapted for use in an infringement of the 221 Patent, and knowing the components are not a staple article or commodity of commerce suitable for substantial noninfringing use. Prayer for Relief Wherefore, Plaintiff Interface IP respectfully requests that this Court enter judgment against Defendant as follows: a) adjudging that the Defendant has infringed, literally or under the doctrine of equivalents, the 221 Patent; b) awarding Interface IP the damages to which it is entitled under 35 U.S.C. 284 for Defendants past infringement and any continuing or future infringement up until the date Defendant is finally and permanently enjoined from further infringement, and ordering a full accounting of same; c) awarding Interface IP pre-judgment and post-judgment interest on its damages; and d) awarding Interface IP such other and further relief in law or equity that the Court deems just and proper.

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Demand for Jury Trial Interface IP hereby respectfully demands a trial by jury on all claims and issues so triable.

Dated: March 21, 2014

FARNAN LLP /s/ Brian E. Farnan Brian E. Farnan (Bar No. 4089) 919 North Market Street 12th Floor Wilmington, DE 19801 (302) 777-0300 (302) 777-0301 bfarnan@farnanlaw.com Counsel for Plaintiff

Of Counsel: Bradford J. Black Andrew G. Hamill BLACK & HAMILL LLP 4 Embarcadero Center, Suite 1400 San Francisco, CA 94111 (415) 813-6210 (415) 813-6222 bblack@blackhamill.com ahamill@blackhamill.com

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