Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 1 of 21
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`MICHAEL PHILIP KAUFMAN,
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`Plaintiff,
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`v.
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`SALESFORCE.COM, INC.,
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`Defendant.
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`
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`No. 1:20-cv-6879
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`COMPLAINT FOR PATENT
`INFRINGEMENT
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`JURY TRIAL DEMANDED
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`Plaintiff MICHAEL PHILIP KAUFMAN (“Plaintiff”), as and for his complaint against
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`the defendant, salesforce.com, inc. (“Salesforce”), alleges as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action against Salesforce for patent infringement. The patents asserted
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`herein concern technology for automatically generating a user interface to work with the data in
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`a relational database and related systems and methods. Plaintiff alleges herein that Salesforce’s
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`online CRM (Customer Relationship Management) services infringe the asserted patents.
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`THE PARTIES
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`Plaintiff is an individual who resides in this District.
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`Upon information and belief, Salesforce is a Delaware corporation with several
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`2.
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`3.
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`offices in this District, including offices at 1095 Avenue of the Americas and 685 Third Avenue
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`in New York, New York.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 2 of 21
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`JURISDICTION AND VENUE
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`Subject Matter Jurisdiction
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`4.
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`This action is for patent infringement and arises under 35 U.S.C. § 271 et seq.
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`This Court has subject matter jurisdiction thereof pursuant to 28 U.S.C. §§ 1331, 1338(a) and
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`1367.
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`Personal Jurisdiction
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`5.
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`This Court has personal jurisdiction over Salesforce under 28 U.S.C. § 1694, Rule
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`4(k)(1)(A) & (C), Fed. R. Civ. P., and the laws of the State of New York, including New York
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`C.P.L.R. §§ 301, 302(a)(1)-(4).
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`6.
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`Jurisdiction over Salesforce exists in this District under 28 U.S.C. § 1694 and
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`Rule 4(k)(1)(C), Fed. R. Civ. P., in that Salesforce is not a resident of this District, but has a
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`regular and established place of business in this District, including without limitation each of
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`Salesforce’s offices in New York City referenced above, at which Salesforce has agents
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`conducting such business. Through those agents in this District, Salesforce is regularly engaged
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`in carrying on a substantial part of its ordinary business on a permanent basis from several
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`physical locations within the District, over which activity Salesforce exercises a substantial
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`measure of control. The leading one of these Salesforce locations within the District is at 1095
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`Avenue of the Americas in New York City, in a building overlooking Bryant Park, the
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`“Salesforce” branding applied to the entire building in giant letters at its top, visible from great
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`distances as part of the New York City Skyline. Other locations at which Salesforce employs
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`agents to conduct its business in this District include (without limitation) its offices at 685 Third
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`Avenue in New York City. Because Salesforce has such a presence in this District, it may be
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`validly served with process in this District, by serving its agents conducting said business, and
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 3 of 21
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`such service establishes personal jurisdiction over Salesforce in this District, pursuant to 28
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`U.S.C. § 1694 (Ruddies v. Auburn Spark Plug Co., 261 F. Supp. 648, 651-52 (S.D.N.Y. 1966)),
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`and Rule 4(k)(1)(C), Fed. R. Civ. P. (“Serving a summons … establishes personal jurisdiction
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`over a defendant … (C) when authorized by a federal statute”).
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`7.
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`In addition, a wholly separate basis for personal jurisdiction over Salesforce also
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`exists under New York CPLR 302(a) and Rule 4(k)(1)(A), Fed. R. Civ. P., in that Salesforce
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`transacts business within New York (e.g., its sales activities within the State), to supply services
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`that Salesforce performs in an infringing manner as hereinafter set forth (e.g., by operating its
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`servers that run the accused Salesforce CRM systems). Salesforce thereby commits tortious acts
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`outside the State causing injury within the State to the person or property of Plaintiff (who
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`resides in this State as stated above).
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`Venue
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`8.
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`Venue is proper in this judicial District pursuant to 28 U.S.C. § 1400(b), in that
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`Salesforce (i) has committed acts of infringement in this District, including without limitation as
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`alleged in paragraph 37 hereof, whereby Salesforce acts through its agents in this District to
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`induce infringement of Plaintiff’s patents, which induced infringement takes place in this
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`District, and (ii) has a regular and established place of business in this District (as alleged in
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`paragraph 6 hereof).
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`The Asserted Patents
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`STATEMENT OF FACTS
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`9.
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`Plaintiff is the first named inventor and assignee of the entire interest of U.S.
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`Patent No. 7,885,981 (the “’981 patent”) (Exhibit A hereto), U.S. Patent No. 10,025,801 (the
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`“’801 patent”) (Exhibit B hereto) and has pending U.S. Patent App. S/N 16/034,696, which was
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 4 of 21
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`published as U.S. Patent Publication No. 2019/0095173 A1 (the ’173 publication) (Exhibit C
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`hereto) and which, when granted, will be added to this complaint by amendment (the foregoing
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`being collectively referred to herein as the “Asserted Patents”). Each of the Asserted Patents is
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`incorporated herein by reference.
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`Salesforce’s CRM Services
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`10.
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`Salesforce sells CRM services over the internet, through server facilities operated
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`by Salesforce and made accessible by it to the public through Salesforce’s website at the Internet
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`address salesforce.com. These CRM services include offerings known as Sales Cloud, Service
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`Cloud, and Marketing Cloud (among others), which are widely used throughout the U.S. and this
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`District.
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`11.
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`Underlying Salesforce’s CRM services are large relational databases, hosted on
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`facilities operated by Salesforce in the U.S., which house end-user CRM data for the Salesforce
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`services. On information and belief, these are “multi-tenant” databases which house data for a
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`large number of unrelated user organizations and end users. Each end-user organization’s CRM
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`data is organized on Salesforce’s multi-tenant database as a relational database (“user database”),
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`within relational database tables (hereinafter, “user tables”) defined within the multi-tenant
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`system. The user databases and their tables are made accessible to and manageable by the end
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`users through web-based applications designed, managed, and operated by Salesforce in the U.S.
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`12.
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`As implemented by Salesforce, user database structures participate in cross-
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`reference and master-detail relationships (the two types of cross-table relationships in relational
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`databases) defined by primary and foreign keys within related tables. Salesforce provides a
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`“Schema Builder” for working with these structures as relational databases:
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 5 of 21
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`13.
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`Salesforce’s CRM services allow end users to modify the structure of the user
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`tables in a user database by adding, removing, or altering fields, tables, and/or relationships
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`between data among tables. The user interface (“UI”) presented by Salesforce’s web
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`applications, having no advance knowledge of any structural changes that a user may make to the
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`database, adapts itself dynamically to the these changes, automatically generating an end-user UI
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`that fits the modified database structure. On information and belief, the entire Salesforce UI for
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`relational CRM data is generated in the same automatic manner as for the user-modified
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`portions, that is, for default and pre-existing user database structures as well as for those
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`modified during the session in which the UI display is generated.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 6 of 21
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`14.
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`As alleged in greater detail below, Salesforce’s CRM UIs provide the ability to
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`create, revise, update and delete relational CRM data, along with mechanisms for representing,
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`managing, and navigating relationships between data records across related database tables. On
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`information and belief, these interface facilities are generated automatically based on a
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`computerized process provided by Salesforce to scan the CRM database structure for the user
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`and determine the tables, constraints, and relationships of the data model.
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`15.
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`Salesforce has operated and continues to operate its servers in the U.S. as alleged
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`herein during the respective terms of the Asserted Patents, without authorization by Plaintiff.
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`Prior Notice
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`16.
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`On August 10, 2020, by letter (a copies of which, along with a confirming email,
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`are attached as Exhibit D hereto) Plaintiff gave written notice to Salesforce of the Asserted
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`Patents, including without limitation the ’981 patent, the ’801 patent, and the ‘173 publication, of
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`the manner in which Plaintiff alleges that Salesforce is infringing and inducing infringement
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`thereof, and that Plaintiff is claiming provisional patent rights under 35 U.S.C. § 154(d) with
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`respect to the ’173 publication. Salesforce did not respond to Plaintiff’s letter.
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`COUNT I
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`(DIRECT INFRINGEMENT OF U.S. PATENT NO. 7,885,981)
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`Plaintiff realleges and incorporates paragraphs 1-16 above by reference.
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`By operating its servers in the U.S. as alleged herein during the term of the ’981
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`17.
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`18.
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`patent, without authorization by Plaintiff, Salesforce directly infringes at least claim 1 of the ’981
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`patent, literally and/or under the doctrine of equivalents, under 35 U.S.C. § 271(a).
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`19.
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`In the case of claim 1 of the ’981 patent, Salesforce performs as recited in the
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`claim preamble, “automatically generating an end-user interface for working with the data within
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 7 of 21
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`a relational database defined within a relational DBMS … wherein [the] relational database may
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`be of any arbitrary size or complexity,” and meets the claim limitations by performing the steps
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`of the claim, literally, and/or under the doctrine of equivalents, as follows:
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`(a) providing an output stream from said server, for user display and input devices,
`defining a user interface paradigm comprising a set of modes for interacting with a
`given database table, said modes comprising create, retrieve, update and delete, and
`a corresponding display format for each mode
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`Salesforce provides an output stream from its servers (http protocol stream), for user display and
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`input devices (the user’s screen, keyboard, mouse, etc.). The http protocol stream defines, for the
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`user’s web browser, a user interface paradigm providing create, retrieve, update, and delete
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`modes for interacting with CRM database tables, with corresponding UI display formats.
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`A “create” mode is reflected in Salesforce screens such as the following:
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 8 of 21
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`A “retrieve” mode is reflected in Salesforce screens such as the following:
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`An “update” mode is reflected in Salesforce screens such as the following:
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 9 of 21
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`A “delete” mode is reflected in Salesforce screens such as the following:
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`(b) causing said server to scan said database and apply a body of rules to determine
`the table structures, constraints and relationships of said data model, and store
`representations thereof in machine-readable media accessible to said server
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`To determine the elements to be represented in the user interface, Salesforce’s server scans the
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`user’s CRM database and applies a body of rules to determine its table structures, constraints,
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`and relationships, and stores a representation thereof in the server’s machine-readable storage.
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`While this step is internal to Salesforce’s operations, Plaintiff alleges on information and belief
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`that it is plausible that this step takes place because the various Salesforce CRMs all allow the
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`users to alter the table structures, constraints and relationships and the Salesforce CRM
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`dynamically adapts to such changes. For example, in a user-level database having Account and
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`Opportunity tables, a user can add a Department table, wherein each Opportunity is assigned to a
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`Department:
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 10 of 21
`Case 5:21-cv-04491-BLF Document1 Filed 08/25/20 Page 10 of 21
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`
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`Before:
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 11 of 21
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`After:
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`The Salesforce CRM applications automatically render the corresponding displays after this new
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`table is added, reflecting that the applications re-scan the user database upon re-rendering the
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`user display screens, evidencing performance of this claim step.
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`(c) causing said server to use said representations to construct a corresponding
`client application for access through said user display and input devices
`
`Salesforce’s servers use the representations they have stored pursuant to step (b) to construct a
`
`client application corresponding to the database, for access through the user display and input
`
`devices in communication with the server. This may be seen, for example, where screens of a
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`user-modified database are rendered, as above.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 12 of 21
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`wherein said client application provides a connection to said database
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`It is apparent from the fact that user changes to the database data are persistent across repeated
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`accesses that the generated client application provides a connection to the database.
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`provides displays of the table contents of said database for each of said modes in
`accordance with the display formats of said paradigm
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`As illustrated with respect to step (b) above, the client application UI provides displays of the
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`user-level tables for performing create, retrieve, update, and delete modes, in accordance with the
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`display formats of the generated UI paradigm.
`
`integrates into each said mode display processes for representing, navigating, and
`managing said relationships across tables, for selecting among said modes, and for
`navigating across said tables and interacting in accordance the selected mode with
`the data in the tables that are reached by said navigation
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`Each mode display integrates a number of processes, which include processes for representing,
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`navigating, and managing said relationships across tables, for selecting among the create,
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`retrieve, update, and delete operations, and for interacting in accordance the selected mode with
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`the data in the tables that are reached by said navigation. For example,
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 13 of 21
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`“Representing”:
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`The display above integrates a process for “representing” a relationship across tables, in this
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`example by replacing actual the foreign key for an Opportunity’s Account with the Account
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`name.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 14 of 21
`Case 5:21-cv-04491-BLF Document1 Filed 08/25/20 Page 14 of 21
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`
`
`
`Opportunities
`
`Departments
`
`Files w
`
`Contacts ~
`
`Campaigns w
`
`Dashboards ~
`
`Perception Analysis
`New Opportunity
`
`“Navigating”:
`“Navigating”:
`
`All
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`Search Opportunities and more...
`Her>sea@yay
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`Leads
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`Sales
`
`Home
`
`Accounts w
`
`
`
`Opportunity
`Express Logistics SLA
`Account Name
`Express Logistics and Transport
`
`Close Date
`5/16/2020
`
`Amount
`$120,000.00
`
`Opportunity Owner
`
`+ Follow
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`New Case
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`Opportunity Name
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`Account Name
`Express Logistics and Transport.
`Type
`Existing Customer - Upgrade
`Lead Source
`External Referral
`
`eartment
`Order Number
`Current Generator(s)
`
`Tracking Number
`
`Created By
`ea 8/24/2020, 3:47 PM
`Description
`
`Delivery Status
`
`Amount
`$120,000.00
`Expected Revenue
`$84,000.00
`Close Date
`5/16/2020
`Next Step
`
`Stage
`Perception Analysis
`Probability (%)
`70%
`Primary Campaign Source
`
`Main Competitor(s)
`
`Delivery/Installation Status
`In progress
`
`Last Modified By
`ea 8/24/2020, 5:47 PM
`
`Related
`
`(7) Products (0)
`
`Notes & Attachments (0)
`
`it Upload Files
`Ordropfiles
`
`(3) contact Roles (0)
`
`Partners (0)
`
`Stage History (2)
`
`Stage:
`Amount:
`Probability (%)
`Expected Reve...
`Close Date:
`Last Modified By:
`Last Modified:
`Stage:
`Amount:
`Prabability (%)
`Expected Reve...
`Close Date:
`
`Perception Analysis
`$120,000.00
`TO%
`$84,000.00
`7/29/2015
`8/24/2020, 3:47 PM
`
`$120,000.00
`TO%
`$84,000.00
`5/16/2020
`
`
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`or,
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`Related
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`United Oil & Gas Corp.
`8/12/2020
`
`© Opportunities (6)
`United Oi! SLA
`Account Name:
`Close Date:
`Edge SLA lame:
`Edge Communications
`5/7/2020
`Close Date:
`University of AZ SLA
`Account Name:
`University of Arizona
`Close Date:
`5/25/2020
`
`GenePoint SLA
`Account Name:
`GenePoint
`Close Date:
`8/17/2020
`Express Logistics SLA
`Account Name:
`Close Date:
`Grand Hotels SLA
`Account Name:
`Close Date:
`
`Grand Hotels & Resorts Ltd
`5/14/2020
`
`‘View All
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`Edit
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 15 of 21
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`The displays above integrate a process for “navigating” a relationship across tables, in these
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`examples by providing navigational links to data in a related table.
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`“Managing”:
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`The display above integrates a process for “managing” a relationship across tables, in this
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`example by providing dropdown control to constrain permissible inputs to valid data as provided
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`in the corresponding column of the related table.
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`while observing and enforcing relational interdependencies among data across
`tables
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`Salesforce’s end-user applications provide all of the above features that are operable in a manner
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`that consistently observes and enforces relational interdependencies among data across tables.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 16 of 21
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`20.
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`In performing as described in paragraph 19, Salesforce also directly infringes
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`claim 2 of the ’981 patent, under 35 U.S.C. § 271(a), literally, and/or under the doctrine of
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`equivalents, by providing through its generated user applications the additional feature of user
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`interface components for revealing and enforcing non-relational constraints (e.g., restricting user
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`input to conform with applicable data types such as numbers, alphabetical input, and dates, etc.).
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`21.
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`In performing as described in paragraph 19, Salesforce also directly infringes
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`claim 3 of the ’981 patent, under 35 U.S.C. § 271(a), literally, and/or under the doctrine of
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`equivalents, in that Salesforce’s CRM databases provide the database feature known as
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`“referential integrity constraints,” as recited in claim 3.
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`22.
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`Claim 4 of the ’981 patent is an independent “system” claim corresponding to
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`claim 1, claiming a computer system that Salesforce runs to perform the process recited in claim
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`1. Salesforce directly infringes claim 4, under 35 U.S.C. § 271(a), literally, and/or under the
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`doctrine of equivalents, by making and using it servers, which constitute the claimed system, in
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`the U.S., during the term of the ’981 patent, without authority from Plaintiff.
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`23.
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`Claim 5 of the ’981 patent is an independent “computer-readable media” claim
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`corresponding to claim 1, claiming a machine-readable medium containing software that
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`Salesforce runs to perform the process recited in claim 1. Salesforce directly infringes claim 5,
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`under 35 U.S.C. § 271(a), literally, and/or under the doctrine of equivalents, by making and using
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`the claimed computer-recorded medium, for example, the computer-readable media on
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`Salesforce’s servers that a contains recorded copy of the computer programs that run Salesforce’s
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`servers, in the U.S., during the term of the ’981 patent, without authority from Plaintiff, as well
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`as any other copies of these computer programs stored on computer-readable media.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 17 of 21
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`24.
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`Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to compensation for said
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`infringements, in no event less than a reasonable royalty, for the use made of the invention by
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`Salesforce as herein alleged, together with pre- and post-judgment interest and costs as fixed by
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`the Court.
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`25.
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`The foregoing also reflects infringement of at least claims 1, 5, and 8 published in
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`the ’173 publication, pursuant to which Salesforce will likewise be liable for damages under 35
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`U.S.C. 154(d) when a patent issues upon the patent application so published, which will be
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`added to this complaint by amendment.
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`COUNT II
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`(DIRECT INFRINGEMENT OF U.S. PATENT NO. 10,025,801)
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`Plaintiff realleges and incorporates paragraphs 1-25 above by reference.
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`On information and belief, when a first user-level table is related to a second user-
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`26.
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`27.
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`level table through a foreign key, Salesforce’s servers, in rendering the first user-level table in the
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`CRM UI, automatically supplant the foreign key in the representation of the first user-level table
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`with a description derived from the column having the name “Name” in the second table, thereby
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`enhancing the “raw” representation of the data of the first table by replacing what would have
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`been a numeric value in the display of the first table with a more human-friendly description
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`derived from the second table. This functionality, separately claimed in the ’801 patent, may be
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`seen, for example, in the “representing” feature illustrated in ¶ 19 above, with regard to step (c)
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`of claim 1 of the ’981 patent.
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`28.
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`Salesforce derives the data and description for use in the display of foreign
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`references in primary user-level tables in the Salesforce CRM, in the manner specified in at least
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`claim 1 of the ’801 patent, literally and/or under the doctrine of equivalents. By using its servers
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 18 of 21
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`in the U.S. in such manner and otherwise as alleged in paragraph 27, during the term of the ’801
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`patent, without authorization by Plaintiff, Salesforce has directly infringed and continues to
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`directly infringe claim 1 of the ’801 patent, under 35 U.S.C. § 271(a).
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`29.
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`Claim 5 of the ’801 patent is an independent “computer-readable media” claim
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`corresponding to claim 1, claiming a machine-readable medium containing software that
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`Salesforce runs to perform the process recited in claim 1. Salesforce directly infringes claim 5,
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`under 35 U.S.C. § 271(a), literally, and/or under the doctrine of equivalents, by making and using
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`the claimed computer-recorded medium, for example, the computer-readable media on
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`Salesforce’s servers that a contains recorded copy of the computer programs that run Salesforce’s
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`servers, in the U.S., during the term of the ’801 patent, without authority from Plaintiff, as well
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`as any other copies of these computer programs stored on computer-readable media.
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`30.
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`The manner in which Salesforce derives and describes foreign key fields in the
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`representation of its CRM databases further directly infringes at least claims 9, 11, 16, and 18 of
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`the ’801 patent, under 35 U.S.C. § 271(a) literally, and/or under the doctrine of equivalents.
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`31.
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`Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to compensation for said
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`infringements, in no event less than a reasonable royalty, for the use made of the invention by
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`Salesforce as herein alleged, together with pre- and post-judgment interest and costs as fixed by
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`the court.
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`COUNT III
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`(INDUCED INFRINGEMENT OF THE ’981 PATENT)
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`32.
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`Plaintiff realleges and incorporates paragraphs 1-31 above by reference.
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 19 of 21
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`33.
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`There exist numerous persons in the U.S. and in this District (“Salesforce CRM
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`Users”) who have used and continue to use the infringing features of the Salesforce CRM as
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`alleged in Counts I and II herein.
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`34.
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`Salesforce CRM users necessarily directly infringe at least claims 4 and 5 of the
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`’981 patent, and at least claim 5 of the ’801 patent, literally, and/or under the doctrine of
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`equivalents, by using the system as alleged in paragraph 22, and the media as alleged in
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`paragraphs 23 and 29, without authorization by Plaintiff, in the U.S., during the terms of the ’981
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`patent and ’801 patent, constituting direct infringement of at least claims 4 and 5 of the ’981
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`patent, and claim 5 of the ’801 patent, under 35 U.S.C. § 217(a).
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`35.
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`Through its sales and marketing efforts, and user instructions, in this District and
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`elsewhere in the U.S., Salesforce induces Salesforce CRM Users to use the Salesforce CRM and
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`thereby directly infringe the ’981 and ’801 patents as alleged in paragraph 34, under 35 U.S.C.
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`§ 271(a).
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`36.
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`Salesforce has been on notice of the ’981 and ’801 patents and of the direct and
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`induced infringement alleged herein, at least by reason of the written notice given to Salesforce
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`as set forth in paragraph 16, as well as the filing of this complaint.
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`37.
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`Notwithstanding such notice, Salesforce continues its own infringement, and by
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`its acts of sales, marketing, and instruction, which take place at locations in the U.S. including
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`without limitation Salesforce’s offices in this District, continues its inducement of the Salesforce
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`CRM Users, including a substantial number of Salesforce CRM Users in this District, to directly
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`infringe by using the infringing Salesforce CRM, as hereinabove alleged, knowing that the
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`Salesforce CRM users are thereby directly infringing the ’981 and ’801 patents and intending
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 20 of 21
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`Salesforce’s acts to cause such infringement, constituting induced infringement, in this District
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`and elsewhere in the U.S., under 35 U.S.C. § 271(b).
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`38.
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`Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to compensation for said
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`infringements, in no event less than a reasonable royalty, for said inducement as herein alleged,
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`together with pre- and post-judgment interest and costs as fixed by the court.
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`39.
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`The foregoing also reflects induced infringement of at least claim 5 published in
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`the ’173 publication, pursuant to which Salesforce will likewise be liable for damages under 35
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`U.S.C. 154(d) when a patent issues upon the patent application so published, which will be
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`added to this complaint by amendment.
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`COUNT IV
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`(WILLFUL INFRINGEMENT)
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`40.
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`41.
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`Plaintiff realleges and incorporates paragraphs 1-39 above by reference.
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`Salesforce knew of the Asserted Patents since at least the date of the notice set
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`forth in paragraph 16 (the “Notice Date”).
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`42.
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`On information and belief, since the Notice Date, and with knowledge of the
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`Asserted Patents and of the manner in which it was being accused of infringing the Asserted
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`Patents, Salesforce has continued its direct and induced infringement thereof. Salesforce has
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`done so intentionally, and is accordingly a willful infringer.
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`43.
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`For reasons including without limitation the foregoing, Plaintiff is entitled to
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`enhanced damages under 35 U.S.C. § 284.
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`PRAYER FOR RELIEF
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`Plaintiff requests that the Court enter judgment against Salesforce as follows:
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`(A) that Salesforce has infringed the Asserted Patents;
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`Case 5:21-cv-04491-BLF Document 1 Filed 08/25/20 Page 21 of 21
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`(B) awarding Plaintiff its damages suffered as a result of Salesforce’s infringement of the
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`Asserted Patents pursuant to 35 U.S.C. § 284;
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`(C) awarding Plaintiff enhanced damages pursuant to 35 U.S.C. § 284;
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`(D) permanently enjoining Salesforce, its officers, directors, agents, servants, affiliates,
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`employees, divisions, branches, subsidiaries and parents, and all others acting in concert or
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`privity with them, from infringing the Asserted Patents;
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`(E) awarding Plaintiff its costs, attorneys’ fees, expenses, and interest (including without
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`limitation pre-judgment interest); and
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`(F) granting Plaintiff such other and further relief as the Court may deem just and proper.
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`DEMAND FOR JURY TRIAL
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`Plaintiff hereby demands trial by jury on all issues so triable pursuant to Rule 38, Fed. R.
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`Civ. P.
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`Dated: August 25, 2020
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`/s Ronald Abramson
`Ronald Abramson
`David G. Liston
`Ari J. Jaffess
`Alex G. Patchen
`M. Michael Lewis
`Rebecca Rothkopf
`LISTON ABRAMSON LLP
`Attorneys for Plaintiff
`The Chrysler Building
`405 Lexington Avenue, 46th Floor
`New York, NY 10174
`(212) 257-1630
`docket@listonabramson.com
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