Case 2:15-cv-03240-PSG-SS Document 1 Filed 04/30/15 Page 1 of 9 Page ID #:1
`
`
`Courtney A. Hasselberg (SBN 291189)
`(chasselberg@shb.com)
`SHOOK, HARDY & BACON L.L.P.
`Jamboree Center
`5 Park Plaza, Suite 1600
`Irvine, California 92614
`Telephone: 949.475.1500
`Facsimile: 949.475.0016
`
`Attorney for Plaintiff
`TELESIGN CORPORATION.
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`
`
`Case No.
`
`
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`
`JURY TRIAL DEMANDED
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`
`
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` PLAINTIFF,
`
`TELESIGN CORPORATION,
`
`
`v.
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`
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`TWILIO, INC.,
`
` DEFENDANT.
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`TELESIGN CORPORATION’S
`COMPLAINT FOR PATENT INFRINGEMENT
`Plaintiff TeleSign Corporation (“TeleSign”) for this Complaint against
`Defendant Twilio, Inc. (“Twilio”) and on information and belief alleges as follows:
`Introduction
`1.
`TeleSign is an industry leader in internet security and user authentication.
`TeleSign is one of the fastest-growing technology companies in North America, sells
`to some of the top websites in the world, and is a market leader in two-step-
`verification technology.
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`1
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`COMPLAINT
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`TWILIO INC., Ex 2030, Page 1
`TELESIGN CORPORATION v. TWILIO INC.
`IPR2017-01977
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`

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`Case 2:15-cv-03240-PSG-SS Document 1 Filed 04/30/15 Page 2 of 9 Page ID #:2
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`2.
`TeleSign helps its customers secure billions of end-user accounts
`worldwide and prevent registration fraud.
`3.
`The technology offered by TeleSign gives businesses the ability to
`connect a unique identity with every account to verify new registrations and
`authenticate users. TeleSign helps businesses detect suspicious users and better
`protect their existing user base from account compromise. TeleSign is trusted by
`some of the world’s largest companies to help prevent fraudulent accounts and stop
`account takeovers.
`4.
`TeleSign owns United States Patent No. 7,945,034 (the “‘034 Patent”),
`entitled “Process for determining characteristics of a telephone number,” and Nos.
`8,462,920 (the “‘920 Patent”) and 8,687,038 (the “‘038 Patent”), both entitled
`“Registration, verification and notification system” (collectively, the “Asserted
`Patents”).
`5.
`Twilio competes directly with TeleSign.
`6.
`Twilio has used, and continues to use, TeleSign’s patented technology in
`connection with products and services that Twilio makes, sells, offers for sell and/or
`uses without TeleSign’s permission, causing TeleSign irreparable harm.
`7.
`In this suit, TeleSign asks the Court to enjoin Twilio from making, using,
`selling or offering to sell products and services claimed by the Asserted Patents and to
`award monetary relief for Twilio’s past violations.
`Jurisdiction and Venue
`8.
`This is an action for patent infringement arising under the patent laws of
`the United States, 35 U.S.C. § 1 et seq., including §§ 271 and 281. This Court has
`original jurisdiction over this patent-infringement action under 28 U.S.C. § 1338(a).
`9.
`Venue is proper in this Court at least because Twilio is responsible for
`acts of infringement occurring in the Central District of California, as alleged in this
`Complaint, and has delivered or caused to be delivered infringing products or services
`
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`COMPLAINT
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`TWILIO INC., Ex 2030, Page 2
`TELESIGN CORPORATION v. TWILIO INC.
`IPR2017-01977
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`Case 2:15-cv-03240-PSG-SS Document 1 Filed 04/30/15 Page 3 of 9 Page ID #:3
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`in the Central District of California. Moreover, TeleSign is headquartered in the
`Central District of California, where the harm from Twilio’s infringement has been
`and is being felt.
`
`Plaintiff TeleSign
`10. Plaintiff TeleSign is a California corporation, duly authorized to do
`business in the State of California, with its principal place of business in Marina Del
`Rey, California.
`
`Defendant Twilio
`11. Defendant Twilio is a Delaware corporation with its principal place of
`business in San Francisco, California. Twilio maintains its principal place of business
`at 645 Harrison Street, San Francisco, California 94107 and can be served at 548
`Market Street #14510, San Francisco, California 94104
`The Asserted Patents
`12.
` The United States Patent and Trademark Office issued the ‘034 Patent
`(attached as Exhibit A) on May 17, 2011, the ‘920 Patent (attached as Exhibit B) on
`June 11, 2013, and the ‘038 Patent (attached as Exhibit C) on April 1, 2014.
`13. TeleSign is the owner of all right, title and interest in the Asserted
`Patents, including all rights to pursue and collect damages for past, present, and future
`infringement of the Asserted Patents.
`FIRST CLAIM FOR PATENT INFRINGEMENT (‘034 PATENT)
`14. TeleSign repeats and realleges each of the allegations contained in the
`paragraphs above.
`15. On May 17, 2011, United States Patent No. 7,945,034, entitled “Process
`for determining characteristics of a telephone number,” was duly and legally issued by
`the United States Patent and Trademark Office.
`
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`TWILIO INC., Ex 2030, Page 3
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`Case 2:15-cv-03240-PSG-SS Document 1 Filed 04/30/15 Page 4 of 9 Page ID #:4
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`16. Plaintiff TeleSign is the owner of the ‘034 Patent with full rights to
`pursue recovery of royalties or damages for infringement of the ‘034 Patent, including
`full rights to recover past and future damages.
`17. Each claim of the ‘034 Patent is valid and enforceable.
`18. On March 31, 2015, Twilio posted a blog entry stating “Today we’re
`happy to introduce you to a new product called Lookup, an API that will retrieve
`detailed information about a phone number.”
`https://www.twilio.com/blog/2015/03/introducing-twilio-lookup.html.
`19. Defendant Twilio has infringed the ‘034 Patent and, unless enjoined, will
`continue to do so, by using, offering for sale and selling services claimed by the ‘034
`Patent.
`20. Twilio makes, sells, offers for sale and/or uses, in the United States its
`“lookup” technology, including through its website at www.twilio.com, as indicated
`by, for example, https://www.twilio.com/lookup and as shown below (hereafter
`referred as “Twilio Lookup”).
`
`
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`21. The ’034 patent relates to, among other things, using “characteristics of a
`telephone number” in a registration process. These characteristics could include for
`example, whether a telephone number is a landline (claim 4), the phone carrier (claim
`1), and geographic characteristics such as a country (claim 6).
`22. By way of example only, the screen capture below from
`https://www.twilio.com/lookup indicates that Twilio Lookup technology determines at
`least these characteristics.
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`23. On information and belief, Twilio Lookup includes the performance of
`each step of the methods claimed by the ‘034 Patent.
`24. TeleSign has been damaged by Twilio’s infringement of the ‘034 Patent
`and will suffer additional irreparable damage unless Twilio is enjoined from
`continuing to infringe the ‘034 Patent.
`25. TeleSign demands trial by jury for all issues relating to this claim.
`26. On information and belief, Twilio’s infringement has been willful and
`continues to be, at least since notice of this Complaint.
`SECOND CLAIM FOR PATENT INFRINGEMENT (‘920 PATENT)
`27. TeleSign repeats and realleges each of the allegations contained in the
`paragraphs above.
`28. On June 11, 2013, United States Patent No. 8,462,920, entitled
`“Registration, verification and notification system,” was duly and legally issued by the
`United States Patent and Trademark Office.
`29. Plaintiff TeleSign is the owner of the ‘920 Patent with full rights to
`pursue recovery of royalties or damages for infringement of the ‘920 Patent, including
`full rights to recover past and future damages.
`30. Each claim of the ‘920 Patent is valid and enforceable.
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`31. Defendant Twilio has infringed the ‘920 Patent and, unless enjoined, will
`continue to do so, by making, using, offering for sale and/or selling services claimed
`by the ‘920 Patent.
`32. Twilio makes, sells, offers for sale and/or uses, in the United States its
`“two-factor authentication” technology, including through its website at
`www.twilio.com, (via http://www.twilio.com/use-cases/two-factor-authentication, for
`example, as illustratively shown below) (hereafter referred as “Twilio Two-Factor
`Authentication”).
`
`
`
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`33. TeleSign’s ‘920 patent is directed to, among other things, verifying a
`contact by using a “verification code.”
`34. As illustratively shown at http://www.twilio.com/help/faq/twilio-
`basics/what-do-i-do-if-i-lose-my-phone-or-cant-sign-in-with-two-factor-
`authentication-enabled-on-my-account/screenshot_6_26_13_2_08_pm-2, Twilio’s
`Two-Factor Authentication uses such a “verification code.”
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`35. Twilio Two-Factor Authentication comprises the performance of each
`element of the methods claimed by the ‘920 Patent.
`36. TeleSign has been damaged by Twilio’s infringement of the ‘920 Patent
`and will suffer additional irreparable damage unless Twilio is enjoined from
`continuing to infringe the ‘920 Patent.
`37. TeleSign demands trial by jury for all issues relating to this claim.
`38. On information and belief, Twilio’s infringement has been willful and
`continues to be, at least since notice of this Complaint.
`THIRD CLAIM FOR PATENT INFRINGEMENT (‘038 PATENT)
`39. TeleSign repeats and realleges each of the allegations contained in the
`paragraphs above.
`40. On April 1, 2014, United States Patent No. 8,687,038, entitled
`“Registration, verification and notification system,” was duly and legally issued by the
`United States Patent and Trademark Office.
`41. Plaintiff TeleSign is the owner of the ‘038 Patent with full rights to
`pursue recovery of royalties or damages for infringement of the ‘038 Patent, including
`full rights to recover past and future damages.
`42. Each claim of the ‘038 Patent is valid and enforceable.
`43. Defendant Twilio has infringed the ‘038 Patent and, unless enjoined, will
`continue to do so, by making, using, offering for sale and/or selling products and
`services claimed by the ‘038 Patent.
`44. Defendant Twilio has infringed the ‘038 Patent and, unless enjoined, will
`continue to do so, by making, using, offering for sale and/or selling services claimed
`by the ‘038 Patent.
`45. Twilio makes, sells, offers for sale and/or uses, in the United States its
`“two-factor authentication” technology, including through its website at
`www.twilio.com, (via http://www.twilio.com/use-cases/two-factor-authentication, for
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`example, as illustratively shown below) (hereafter referred as “Twilio Two-Factor
`Authentication”).
`
`
`
`
`46. TeleSign’s ‘038 patent is directed to, among other things, verifying a
`contact by using a “verification code.”
`47. As illustratively shown at http://www.twilio.com/help/faq/twilio-
`basics/what-do-i-do-if-i-lose-my-phone-or-cant-sign-in-with-two-factor-
`authentication-enabled-on-my-account/screenshot_6_26_13_2_08_pm-2, Twilio’s
`Two-Factor Authentication uses such a “verification code.”
`
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`48. Twilio Two-Factor Authentication comprises the performance of each
`element of the methods claimed by the ‘038 Patent.
`49. TeleSign has been damaged by Twilio’s infringement of the ‘038 Patent
`and will suffer additional irreparable damage unless Twilio is enjoined from
`continuing to infringe the ‘920 Patent.
`50. TeleSign demands trial by jury for all issues relating to this claim.
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`51. On information and belief, Twilio’s infringement has been willful and
`continues to be, at least since notice of this Complaint.
` PRAYER FOR RELIEF
`WHEREFORE, TeleSign respectfully requests this Court to:
`A.
`Enter judgment for TeleSign that Twilio has willfully infringed, and is
`willfully infringing one or more claims of each of the Asserted Patents;
`Issue a preliminarily injunction enjoining Twilio (including its officers,
`directors, employees, agents, and all persons acting in concert with them)
`from infringing any of the Asserted Patents;
`Issue a permanent injunction enjoining Twilio (including its officers,
`directors, employees, agents, and all persons acting in concert with them)
`from infringing any of the Asserted Patents;
`D. Order that Twilio pay compensatory damages to TeleSign for Twilio’s
`infringement of the Asserted Patents, including but not limited to,
`damages for lost profits and in no event less than a reasonable royalty,
`together with interest and costs under 35 U.S.C. § 284;
`Find this to be an exceptional case, award TeleSign treble damages due
`to Twilio’s deliberate and willful conduct, and order Twilio to pay
`TeleSign’s costs of suit and attorneys’ fees;
`Aware TeleSign pre-judgment interest; and
`For such other relief as the Court deems appropriate.
`
`B.
`
`C.
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`E.
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`F.
`G.
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`Dated: April 30, 2015
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`Respectfully Submitted,
`
`SHOOK, HARDY & BACON L.L.P.
`
`By: /s/ Courtney A. Hasselberg
`Courtney A. Hasselberg
`Attorney for Plaintiff
`TELESIGN CORPORATION
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`TWILIO INC., Ex 2030, Page 9
`TELESIGN CORPORATION v. TWILIO INC.
`IPR2017-01977
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