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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE




QUEST LICENSING CORPORATION

Plaintiff,

v.

INTERACTIVE DATA
CORPORATION

Defendant.






Civil Action No.

Jury Trial Demanded

COMPLAINT

Plaintiff Quest Licensing Corporation (Quest or Plaintiff) hereby alleges patent
infringement of U.S. Patent No. 7,194,468 (the 468 patent) against Interactive Data
Corporation (IDC), as follows:
PARTIES
1. Plaintiff Quest Licensing Corporation is a Delaware corporation with a principal place of
business at 19 Fortune Lane, J ericho, New York 11753.
2. Defendant IDC is a Delaware corporation with its principal place of business at 5 Speen
Street, Framingham, Massachusetts 01701 and has appointed Corporation Trust Company as its
registered agent for service of process.
JURISDICTION AND VENUE
3. This action arises under the Patent Laws of the United States, including 35 U.S.C. 271.
This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a).
4. On information and belief, IDC regularly transacts business in the District of Delaware.
5. IDC has previously admitted that it transacts business in the District of Delaware.
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6. IDC has previously admitted that it is subject to this Courts specific and general personal
jurisdiction and that the District of Delaware is a proper venue in litigation against it under 28
U.S.C. 1391(b)-(c) and 1400(b).
7. IDC is therefore subject to this Courts specific and general personal jurisdiction.
8. Venue is proper pursuant to 28 U.S.C. 1391(b)-(c) and 1400(b).
THE 468 PATENT
9. Quest is the owner of all rights by assignment of the 468 patent, entitled Apparatus and
a Method for Supplying Information, with the right to pursue claims for infringement.
10. The United States Patent and Trademark office issued the 468 patent on March 20,
2007. A true and correct copy of the 468 patent is attached to this Complaint as Exhibit A.
CLAIMS FOR RELIEF
COUNT I DIRECT INFRINGEMENT
11. Plaintiff repeats and incorporates by reference paragraphs 1-10 above.
12. IDC has infringed and continues to directly infringe the claims of the 468 patent,
literally or under the doctrine of equivalents, by making, using, selling, and offering for sale
products that are covered by claims of the 468 patent, including its QuoTrek and PrimeTerminal
Mobile systems and related hardware and software that provide mobile access to real-time
financial data.
13. IDC has had actual knowledge of the 468 patent since at least December 2008, when its
subsidiary Interactive Data Managed Solutions Limited entered into an agreement with
WorldLink Information Technology Systems, a prior assignee of the 468 patent. That
agreement specifically references WorldLinks patented technology.
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14. IDC obtained further knowledge of the 468 patent on March 5, 2012, when it received a
letter identifying the 468 patent and identifying IDCs QuoTrek product as using one or more
claims of the 468 patent.
15. IDCs infringement of the 468 patent has damaged Plaintiff.
16. IDCs past infringement has been willful. IDC made, used, sold, or offered for sale its
infringing systems under an objectively high likelihood of infringement. It either had subjective
knowledge that these systems had an objectively high risk of infringing Plaintiffs patent, or the
risk was so obvious it should have known of it.
COUNT II CONTRIBUTORY INFRINGEMENT
17. Plaintiff repeats and incorporates by reference paragraphs 1-16 above.
18. Users of QuoTrek and PrimeTerminal Mobile directly infringe claims of the 468 Patent.
19. IDC has indirectly, through contributory infringement, infringed the 468 patent within
the United States by knowingly or with willful blindness causing others to infringe the 468
patent by selling components for use in performing methods claimed in the 468 patent,
including its QuoTrek and PrimeTerminal Mobile products.
20. These components are a material part of the 468 patents claimed methods of operating
computers to enable communication with information supplying apparatus. IDCs marketing
materials indicate that the QuoTrek mobile application and system enable users to create a
customizable quote window with fields [that] can be easily added, removed or changed.
Based on the fields the user inputs, the QuoTrek supplies from its sophisticated market data
infrastructure [s]treaming, [r]eal-[t]ime [q]uotes to the user. Similarly, IDCs marketing
materials indicate that the PrimeTerminal Mobile application and system includes a user-
friendly interface that allows for individual customization of display. The application and
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system provide real-time access to a broad range of quotes, which can be easily accessed to
check the performance of individual positions.
21. These components are especially made or adapted for use in an infringing manner, and
they are not staple articles of commerce capable of substantial noninfringing uses. The QuoTrek
application and system are specifically designed to provide real-time information, including
real-time quotes and news, to users. The PrimeTerminal Mobile application and system is
specifically designed to access global real time data.
22. IDC has had actual knowledge of the 468 patent since at least December 2008, when its
subsidiary Interactive Data Managed Solutions Limited entered into an agreement with
WorldLink Information Technology Systems, a prior assignee of the 468 patent. That
agreement specifically references WorldLinks patented technology.
23. IDC obtained further knowledge of the 468 patent on March 5, 2012, when it received a
letter identifying the 468 patent and identifying IDCs QuoTrek product as using one or more
claims of the 468 patent.
24. IDCs infringement of the 468 patent has damaged Plaintiff.
25. IDCs past infringement has been willful. IDC made, used, sold, or offered for sale its
infringing systems under an objectively high likelihood of infringement. It either had subjective
knowledge that these systems had an objectively high risk of infringing Plaintiffs patent, or the
risk was so obvious it should have known of it.
COUNT III INDUCED INFRINGEMENT
26. Plaintiff repeats and incorporates by reference paragraphs 1-25 above.
27. Users of QuoTrek and PrimeTerminal Mobile directly infringe claims of the 468 Patent.
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28. IDC has indirectly, through induced infringement, infringed the 468 patent within the
United States by knowingly or with willful blindness actively inducing others to infringe the
468 Patent.
29. IDC intends for its customers to use QuoTrek and PrimeTerminal Mobile in a manner
that infringes the 468 Patent. In particular, IDCs marketing materials instruct consumers to use
QuoTrek to obtain streaming, realtime quotes, charts and news on their PDAs and smart
phones. IDC provides users instructions on how to install PrimeTerminal Mobile on their
mobile devices. Furthermore, IDCs marketing materials instruct consumers to use
PrimeTerminal Mobile to follow developments in financial markets in real-time and set-up
individual customization of the data displayed.
30. In addition, IDC provides a New User Orientation for its QuoTrek mobile application,
which instructs users how to use QuoTrek to obtain [r]eal-time streaming data. The New User
Orientation instructs users on how to select a Watch List of stock symbols for which, in
response to the users selection, the QuoTrek application and system provide real-time
streaming information.
31. IDC has had actual knowledge of the 468 patent since at least December 2008, when its
subsidiary Interactive Data Managed Solutions Limited entered into an agreement with
WorldLink Information Technology Systems, a prior assignee of the 468 patent. That
agreement specifically references WorldLinks patented technology.
32. IDC obtained further knowledge of the 468 patent on March 5, 2012, when it received a
letter identifying the 468 patent and identifying IDCs QuoTrek product as using one or more
claims of the 468 patent.
33. IDCs infringement of the 468 patent has damaged Plaintiff.
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34. IDCs past infringement has been willful. IDC made, used, sold, or offered for sale its
infringing systems under an objectively high likelihood of infringement. It either had subjective
knowledge that these systems had an objectively high risk of infringing Plaintiffs patent, or the
risk was so obvious it should have known of it.
WHEREFORE, Plaintiff requests that this Court:
(a) enter judgment in favor of Plaintiff that IDC has infringed and continues to infringe
the 468 patent;

(b) award Plaintiff all monetary relief available under the patent laws of the United
States;
(c) declare this case exceptional and award Plaintiff its reasonable attorneys fees
pursuant to 35 U.S.C. 285;
(d) award Plaintiff the costs of this action; and
(e) grant Plaintiff such other and further relief as this Court deems just and proper.
DEMAND FOR A JURY TRIAL

Plaintiff demands a trial by jury on all issues so triable.

April 29, 2014

Of Counsel:

Steven F. Molo
Ben Quarmby
MOLOLAMKEN LLP
540 Madison Avenue
New York, NY
(212) 607-8160 (telephone)
(212) 607-8161 (facsimile)

Andrew R. DeVooght
J ustin B. Weiner
MOLOLAMKEN LLP
300 N. LaSalle Street
Chicago, IL 60622
(312) 450-6700 (telephone)
(312) 450-6701 (facsimile)
SMITH KATZENSTEIN & J ENKINS LLP



/s/ Neal C. Belgam .
Neal C. Belgam (No. 2721)
800 Delaware Avenue, Suite 1000
P.O. Box 410
Wilmington, DE 19899
302-504-1688
nbelgam@skjlaw.com

Attorneys for Quest Licensing Corporation

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