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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF TEXASMARSHALL DIVISIONGRQ INVESTMENT MANAGEMENT, LLCPlaintiff,v.FINANCIAL ENGINES, INC. andFINANCIAL ENGINES ADVISORS L.L.C.Defendant.
Case No.
COMPLAINTFOR PATENT INFRINGEMENTDEMAND FOR JURY TRIALORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff GRQ Investment Management, LLC (“GRQ” or “Plaintiff”) hereby alleges for its Complaint for patent infringement against Defendants Financial Engines, Inc., and FinancialEngines Advisors L.L.C. (collectively, “Financial Engines” or “Defendants”) as follows:
PARTIES
1. Plaintiff GRQ Investment Management, LLC is a Texas limited liabilitycompany, having a principal place of business at 7005 Chase Oaks Blvd., Suite 180, Plano, TX75025.2. On information and belief, Defendant Financial Engines, Inc. is a corporationorganized and existing under the laws of the State of Delaware, with its principal place of business located at 1050 Enterprise Way, 3rd Floor, Sunnyvale, California 94089. Oninformation and belief, Financial Engines, Inc. may be served via its registered agent,Corporation Service Company, 2711 Centerville Rd., Ste. 400, Wilmington, DE 19808.3. On information and belief, Defendant Financial Engines Advisors L.L.C. is alimited liability company organized and existing under the laws of the State of Delaware, with its
2 principal place of business located at 1050 Enterprise Way, 3rd Floor, Sunnyvale, California94089. On information and belief, Financial Engines Advisors L.L.C. may be served via itsregistered agent, Corporation Service Company, 2711 Centerville Rd., Ste. 400, Wilmington, DE19808.
JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, Title 35 of theUnited States Code. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331and 1338(a).5. Personal jurisdiction and venue are proper in this district under 28 U.S.C.§§ 1391(b), 1391(c) and 1400(b). On information and belief, Financial Engines has transacted business in this district and/or has committed, contributed to, and/or induced acts of patentinfringement in this district.6. On information and belief, Financial Engines is subject to this Court’s specificand general personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute,due at least to its substantial business in this forum, including: (i) at least a portion of theinfringements alleged herein; and (ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals in Texas and in this judicial district.7. For example, Financial Engines provides advisory services to companies such asJ.C. Penney Company, Inc., and Texas Instruments Incorporated.(http://corp.financialengines.com/about/who-we-work-with.html)
38. For example, from 2007-2011, J.C. Penney Company, Inc. paid Financial Enginesover $15.6 million dollars for its asset management and investment advisory services related toJC Penney’s 401k plans.(http://www.brightscope.com/form-5500/service-providers/55251/J-C-Penney-Corporation-Inc/56193/J-C-Penney-Corporation-Inc-Savings-Profit-Sharing-And-Stock-Ownership-Plan/2011/)9. For example, from 2007-2012, Texas Instruments Incorporated paid FinancialEngines over $5.7 million dollars for its asset management and investment advisory servicesrelated to Texas Instruments’ 401k plans.(http://www.brightscope.com/form-5500/service-providers/349543/Texas-Instruments-Incorporated/354415/Ti-Contribution-And-401k-Savings-Plan/2012/)
U.S. PATENT NOS. 7,120,600 AND 8,229,825
10. GRQ is the owner by assignment of United States Patent No. 7,120,600 (“the ’600Patent”) entitled “Systems and Methods for Improving Investment Performance.” The ’600Patent issued on October 10, 2006. A true and correct copy of the ’600 Patent is attached as
Exhibit A
.11. GRQ is the owner by assignment of United States Patent No. 8,229,825 (“the ’825Patent”) entitled “Systems and Methods for Improving Investment Performance.” The ’825Patent issued on July 24, 2012. A true and correct copy of the ’825 Patent is attached as
ExhibitB
.12. Messrs. Brian C. Tarbox and Mark Greenstein are listed as the inventors on the’600 and ’825 Patents.
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