Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 1 of 14
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`PAYRANGE INC.,
`
`Plaintiff,
`
`v.
`
`KIOSOFT TECHNOLOGIES, LLC and
`TECHTREX, INC.,
`
`Defendants.
`
`CASE NO.: 1:20-cv-24342-RNS
`
`FIRST AMENDED COMPLAINT
`FOR PATENT INFRINGEMENT
`
`JURY TRIAL DEMANDED
`
`Founded in 2013, Plaintiff PayRange Inc. (“PayRange” or “Plaintiff”) developed
`1.
`the original mobile payment systems for non-networked unattended retail machines based on its
`patented technology. PayRange’s innovations were widely acclaimed and accepted by
`customers. Unfortunately, TechTrex, Inc. (“TechTrex”) and KioSoft Technologies, LLC
`(“KioSoft”) (collectively, “Defendants”) have blatantly disregarded PayRange’s patent rights by
`attempting to poach PayRange’s customers with a copycat product and solicit new business with
`copycat product. PayRange seeks recovery of its damages based on lost profits, royalties and/or
`price erosion, as well as a permanent injunction to prevent Defendants’ continued and future
`infringement by selling, maintaining, and supporting copycat products (e.g., mobile apps).
`PayRange, through their undersigned counsel, therefore, brings this action against Defendants,
`alleging as follows:
`
`NATURE OF ACTION
`This is a civil action for patent infringement arising under the patent laws of the
`2.
`United States, Title 35 of the United States Code.
`3.
`As set forth in more detail below, Defendants have been infringing PayRange’s
`patents, namely, United States Patent Nos. 10,719,833; 10,891,608; and 10,891,614 (the
`“’833 Patent,” “’608 Patent,” and “’614 Patent” respectively or, collectively the “patents-in-
`suit”), and continue to do so through the present date.
`
`-1-
`
`Petitioner Kiosoft Exhibit 1022
`Page 1
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 2 of 14
`
`In a related case in this District, PayRange Inc. v. KioSoft Technologies, LLC and
`4.
`TechTrex, Inc., No. 1:20-cv-20970-RS, PayRange filed a patent infringement lawsuit against
`Defendants asserting infringement of PayRange’s United States Patent Nos. 9,659,296 and
`9,134,994.
`
`THE PARTIES
`PayRange is a Tennessee corporation with its principal place of business at 9600
`5.
`NE Cascades Pkwy, Suite 280, Portland, OR 97220.
`6.
`TechTrex is a Canadian corporation with its principal place of business at 3610
`Nashua Drive, Suite 5, Mississauga, Ontario L4V1L2, Canada.
`7.
`KioSoft is a Florida limited liability company with its principal place of business
`at 3600 S. Congress Avenue, Suite O, Boynton Beach, FL 33426. Upon information and belief,
`KioSoft is a wholly owned subsidiary of TechTrex.
`JURISDICTION AND VENUE
`This Court has subject matter jurisdiction over this patent infringement action
`8.
`pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`9.
`This Court has personal jurisdiction over Defendants because, upon information
`and belief, each Defendant conducts business in this District, and KioSoft distributes products
`within this State. TechTrex has directed and controlled such conduct. Defendants have further
`purposefully availed themselves of the opportunity to conduct commercial activities in this
`forum and have committed acts of patent infringement in this District as alleged in this
`Complaint.
`This Court also has personal jurisdiction over KioSoft because, upon information
`10.
`and belief, KioSoft has a principal place of business in this District.
`11.
`Venue is proper in this District pursuant to 28 U.S.C. § 1400(b) because, upon
`information and belief, this is a judicial district where KioSoft has committed acts of patent
`infringement as alleged in this Complaint, and this is a judicial district where KioSoft has a
`
`-2-
`
`Petitioner Kiosoft Exhibit 1022
`Page 2
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 3 of 14
`
`
`
`regular and established place of business. Further, Kiosoft is incorporated in this state with its
`principal place of business in this District.
`12.
`Venue is proper in this District against TechTrex pursuant to 28 U.S.C. §
`1391(c)(3), because the entity is foreign and therefore may be sued in any judicial district.
`13.
`Defendants, upon information and belief, have used, sold, imported and/or offered
`for sale products, including at least the “CleanPay Mobile” and “CleanReader Solutions”
`products, that infringe the patents-in-suit in this District.
`14.
`Defendants disputed neither jurisdiction nor venue in PayRange Inc. v. KioSoft
`Technologies, LLC and TechTrex, Inc., No. 1:20-cv-20970-RS, thereby waiving such arguments
`in this action.
`
`BACKGROUND
`A.
`PayRange’s Products and Intellectual Property
`15.
`Founded in 2013, PayRange is a technology company offering innovative mobile
`payment solutions for various self-help retail industries.
`16.
`PayRange’s innovative technology allows customers to pay by phone when using
`self-help retail machines. For example, while a traditional laundry machine requires customers
`to insert coins to use the machine, PayRange offers smart solutions to enable customers to make
`a cashless purchase using apps on their cell phones.
`17.
`PayRange provides quick and inexpensive solutions to vendors (called
`“operators” in the industry). Operators only need to install a small device manufactured by
`PayRange on their existing machines or kiosks. The PayRange device communicates wirelessly
`with the customer’s cell phone running the app to complete the transaction. For example,
`PayRange’s BluKey mobile payment device is designed to work with laundry machines and
`other types of machines that accept payments and allows consumers to conveniently use a mobile
`app to pay in seconds any coin operated machine or in-person merchant accepting payment via
`PayRange’s technology. The BluKey laundry products are among PayRange’s most sought after
`and sold products.
`
`
`
`-3-
`
`Petitioner Kiosoft Exhibit 1022
`Page 3
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 4 of 14
`
`
`
`18.
`To protect its unique and innovative technologies and intellectual property rights,
`PayRange filed for patents.
`19.
`On July 21, 2020, the United States Patent and Trademark Office (“USPTO”)
`issued the ’833 Patent, titled “Method and System For Performing Mobile Device-To-Machine
`Payments.” A true and correct copy of the ’833 Patent is attached hereto as Exhibit 1.
`20.
`On January 12, 2021, the United States Patent and Trademark Office (“USPTO”)
`issued the ’608 Patent, titled “Method and system for an offline-payment operated machine to
`accept electronic payments.” A true and correct copy of the '608 Patent is attached hereto as
`Exhibit 2.
`21.
`On January 12, 2021, the United States Patent and Trademark Office (“USPTO”)
`issued the ’614 Patent, titled “Method and system for presenting representations of payment
`accepting unit events.” A true and correct copy of the ’614 Patent is attached hereto as Exhibit 3.
`B.
`Defendants’ Infringing Products
`22.
`Defendants directly compete with PayRange. In particular, Defendants offer a so-
`called “single-source” solution, i.e., they manufacture and sell the payment-collecting kiosks or
`terminals in which the mobile payment functionalities are built-in. For example, Defendants’
`laundry solution includes its CleanPayMobile cell phone app, its CleanPay Kiosks, and/or its
`CleanReader Solutions terminals.
`23.
`On or about February 12, 2019, senior executives of PayRange and Defendants
`had business meetings in Portland, Oregon, during which the parties discussed a potential
`business and licensing relationship. On information and belief, Defendants have had knowledge
`of PayRange and PayRange’s products embodying the inventions claimed in the patents-in-suit
`since at least February 12, 2019.
`24.
`Upon information and belief, by making and selling kiosks with built-in mobile
`payment functionalities, Defendants directly or indirectly infringe the patents-in-suit.
`
`
`
`-4-
`
`Petitioner Kiosoft Exhibit 1022
`Page 4
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 5 of 14
`
`
`
`25.
`As a result of Defendants’ infringement of the patents-in-suit, PayRange has
`suffered monetary damages and is entitled to a money judgment in an amount adequate to
`compensate for Defendants’ infringement, together with interest and costs as fixed by the Court.
`26.
`Defendants’ infringement has been and is willful and, pursuant to 35 U.S.C. §
`284, PayRange is entitled to treble damages. Defendants’ willful infringement is based at least
`on its knowledge of PayRange, its products, and the ’833 Patent since at least September 10,
`2020, when PayRange’s counsel notified Defendants’ counsel of its intent to assert the ’833
`Patent against Defendants. Defendants’ counsel did not provide any non-infringement and/or
`invalidity defenses in response. Defendants have either willfully and wantonly infringed the
`’833 Patent or have recklessly avoided knowledge of their own infringement.
`COUNT I
`INFRINGEMENT OF THE ’833 PATENT
`27.
`Plaintiff realleges and incorporates the allegations of the preceding paragraphs of
`this complaint as if fully set forth herein.
`28.
`PayRange is the assignee and owner of all right, title, and interest in and to the
`’833 Patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`embodying the ’833 Patent throughout the United States, and to import any product embodying
`the ’833 Patent into the United States.
`29.
`The ’833 Patent is an invention of systems and methods for identifying an
`automatic retail machine at a mobile device and requesting authorization from a server to
`complete a cashless transaction with the automatic retail machine.
`30.
`Upon information and belief, Defendants have been and are now infringing at
`least claim 1 of the ’833 Patent in this State, in this District, and elsewhere in the United States,
`by, among other things, directly or through intermediaries, making, using, selling and/or offering
`for sale products with built-in mobile payment functionalities, covered by one or more claims of
`the ’833 Patent to the injury of PayRange. Defendants are directly infringing, literally
`
`
`
`-5-
`
`Petitioner Kiosoft Exhibit 1022
`Page 5
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 6 of 14
`
`
`
`infringing, and/or infringing the ’833 Patent under the doctrine of equivalents. Defendants are
`thus liable for infringement of the ’833 Patent pursuant to 35 U.S.C. § 271(a).
`31. When placed into operation by Defendants or users of Defendants’ Infringing
`Products, the Infringing Products claim 1 of the ’833 Patent as they perform a method of
`payment processing prior to user selection of any items or services provided by an automatic
`retail machine. Such method comprises: at a mobile device with one or more processors,
`memory, and a communications unit (e.g., an iPhone): identifying the automatic retail machine
`based at least in part on a transmission received from an electronic payment device of the
`automatic retail machine, e.g., by the CSCPayMobile app powered by Defendants; in response to
`identifying the automatic retail machine, obtaining, from the electronic payment device, a
`request, via the communications unit of the mobile device, to preemptively obtain authorization
`to make funds available for a cashless transaction with the automatic retail machine; sending, to
`a server, the request via the communications unit of the mobile device; in response to sending the
`request to the server, obtaining from the server an authorization grant of an amount of funds for
`use in conjunction with the cashless transaction with the automatic retail machine; detecting, by
`an application executing on the mobile device (e.g., by the CSCPayMobile app powered by
`Defendants), a trigger condition to perform the cashless transaction with the automatic retail
`machine; and in response to detecting the trigger condition, sending to the electronic payment
`device the authorization grant to enable completion of the cashless transaction at the automatic
`retail machine.
`32.
`Upon information and belief, Defendants will continue to directly infringe the
`’833 Patent unless enjoined.
`33.
`To the extent Defendants’ Infringing Products, without more, do not directly
`infringe at least claim 1 of the ’833 Patent, Defendants contribute to infringement of the same
`under 35 U.S.C. § 271(c) inasmuch as the Infringing Products offered for sale and sold by
`Defendants are each a component of a patented machine or an apparatus used in practicing a
`
`
`
`-6-
`
`Petitioner Kiosoft Exhibit 1022
`Page 6
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 7 of 14
`
`
`
`patented process, constituting a material part of PayRange’s invention, knowing the same to be
`especially made or especially adapted for use in infringement of the ’833 Patent.
`34.
`For example, upon information and belief, the core software module of
`Defendants’ CleanPayMobile app, which directly infringes the ’833 Patent, is being provided by
`Defendants’ to other service providers to incorporate into their own apps, such as
`CSCPayMobile app or Wash Connect app.
`35.
`Upon information and belief, Defendants will continue to contribute to
`infringement of the ’833 Patent unless enjoined.
`36.
`Defendants actively encourage their business partners and/or customers to use
`Defendants’ Infringing Products or their equivalents in an infringing manner. Defendants and
`Plaintiff had a business meeting in early 2019 where aspects of the now-patented technology was
`discussed. Moreover, Defendants have known about the ’833 Patent’s issuance since at least
`September 10, 2020. Despite such knowledge, Defendants have actively induced its business
`partners and/or customers to use Defendants’ products in a way that now constitutes
`infringement. Defendants have encouraged this infringement with a specific intent to cause its
`business partners and customers to infringe. Defendants’ acts thus constitute active inducement
`of patent infringement in violation of 35 U.S.C. § 271(b).
`37.
`Upon information and belief, Defendants will continue to induce infringement of
`the ’833 Patent unless enjoined.
`38.
`Defendants’ direct infringement, contributory infringement, and inducement of
`infringement have irreparably harmed PayRange.
`39.
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`compensate for the infringement.
`40.
`Defendants’ infringement has been and is willful and, pursuant to 35 U.S.C. §
`284, PayRange is entitled to treble damages. Defendants’ willful infringement is based at least
`on Defendants’ knowledge of PayRange, its products, and its patents. Defendants’ conduct is
`egregious as it continued offering, selling, making and using the Infringing Products despite
`
`
`
`-7-
`
`Petitioner Kiosoft Exhibit 1022
`Page 7
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 8 of 14
`
`
`
`knowledge of the infringement. Defendants have either willfully and wantonly infringed the
`’833 Patent or have recklessly avoided knowledge of its own infringement, even when faced
`with knowledge of PayRange’s own products and patents.
`41.
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`is entitled to an award of attorneys’ fees.
`
`COUNT II
`INFRINGEMENT OF THE ’608 PATENT
`42.
`Plaintiff realleges and incorporates the allegations of the preceding paragraphs of
`this complaint as if fully set forth herein.
`43.
`PayRange is the assignee and owner of all right, title, and interest in and to the
`’608 Patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`embodying the ’608 Patent throughout the United States, and to import any product embodying
`the ’608 Patent into the United States.
`44.
`Upon information and belief, Defendants have been and are now infringing at
`least claim 1 of the ’608 Patent in this State, in this District, and elsewhere in the United States,
`by, among other things, directly or through intermediaries, making, using, selling and/or offering
`for sale products with built-in mobile payment functionalities, covered by one or more claims of
`the ’608 Patent to the injury of PayRange. Defendants are directly infringing, literally
`infringing, and/or infringing the ’608 Patent under the doctrine of equivalents. Defendants are
`thus liable for infringement of the ’608 Patent pursuant to 35 U.S.C. § 271(a).
`45. When placed into operation by Defendants or users of Defendants’ infringe at
`least claim 1 of the ’608 Patent. They includes a payment module (e.g., CleanReader) for an
`offline payment-operated machine including a coin receiving switch, the payment module
`comprising: a short-range wireless transceiver (e.g., Bluetooth) configured to communicate with
`one or more mobile devices; one or more processors; a first interface module configured to
`output to a control unit of the offline payment-operated machine one or more electrical pulses,
`each of the one or more electrical pulses emulating an analog signal generated by the coin
`
`
`
`-8-
`
`Petitioner Kiosoft Exhibit 1022
`Page 8
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 9 of 14
`
`
`
`receiving switch of the offline payment-operated machine in response to insertion of a single
`coin of a predetermined type in the offline payment-operated machine; and memory (e.g., Flash
`memory) with one or more programs for execution by the one or more processors, the one or
`more programs including instructions for: storing, in the memory of the payment module, a
`number of the electrical pulses that must be received by the control unit to initiate an operation
`of the offline payment operating machine; receiving a wireless request via the short-range
`wireless transceiver from a respective mobile device of the one or more mobile devices to initiate
`a cashless operation of the offline-payment operated machine; and in response to the wireless
`request: determining a first number of electrical pulses to output via the first interface module to
`the control unit of the offline payment-operated machine in order to initiate the requested
`cashless operation of the offline payment-operated machine; causing the offline payment-
`operated machine to initiate the requested cashless operation by issuing the first number of
`electrical pulses to the control unit via the first interface module; and sending operation
`information corresponding to the initiated operation of the offline payment-operated machine to
`the respective mobile device via the short-range wireless transceiver.
`46.
`To the extent Defendants’ Infringing Products, without more, do not directly
`infringe at least claim 1 of the ’608 Patent, Defendants contribute to infringement of the same
`under 35 U.S.C. § 271(c) inasmuch as the Infringing Products offered for sale and sold by
`Defendants are each a component of a patented machine or an apparatus used in practicing a
`patented process, constituting a material part of PayRange’s invention, knowing the same to be
`especially made or especially adapted for use in infringement of the ’608 Patent.
`47.
`Defendants actively encourage their business partners and/or customers to use
`Defendants’ Infringing Products or their equivalents in an infringing manner. Defendants and
`Plaintiff had a business meeting in early 2019 where aspects of the now-patented technology was
`discussed. Despite such knowledge, Defendants have actively induced its business partners
`and/or customers to use Defendants’ products in a way that now constitutes infringement.
`Defendants have encouraged this infringement with a specific intent to cause its business
`
`
`
`-9-
`
`Petitioner Kiosoft Exhibit 1022
`Page 9
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 10 of 14
`
`
`
`partners and customers to infringe. Defendants’ acts thus constitute active inducement of patent
`infringement in violation of 35 U.S.C. § 271(b).
`48.
`Defendants’ direct infringement, contributory infringement, and inducement of
`infringement have irreparably harmed PayRange.
`49.
`Upon information and belief, Defendants will continue to infringe the ’608 Patent
`unless enjoined.
`50.
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`compensate for the infringement.
`51.
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`is entitled to an award of attorneys’ fees.
`
`COUNT III
`INFRINGEMENT OF THE ’614 PATENT
`52.
`Plaintiff realleges and incorporates the allegations of the preceding paragraphs of
`this complaint as if fully set forth herein.
`53.
`PayRange is the assignee and owner of all right, title, and interest in and to the
`’614 Patent. PayRange has the exclusive right to make, use, sell, and offer to sell any product
`embodying the ’614 Patent throughout the United States, and to import any product embodying
`the ’614 Patent into the United States.
`54.
`Upon information and belief, Defendants have been and are now infringing at
`least claim 1 of the ’614 Patent in this State, in this District, and elsewhere in the United States,
`by, among other things, directly or through intermediaries, making, using, selling and/or offering
`for sale products with built-in mobile payment functionalities, covered by one or more claims of
`the ’614 Patent to the injury of PayRange. Defendants are directly infringing, literally
`infringing, and/or infringing the ’614 Patent under the doctrine of equivalents. Defendants are
`thus liable for infringement of the ’614 Patent pursuant to 35 U.S.C. § 271(a).
`55. When placed into operation by Defendants or users of Defendants’ infringe at
`least claim 1 of the ’614 Patent. When, for example, CleanPay Mobile is installed on a mobile
`
`
`
`-10-
`
`Petitioner Kiosoft Exhibit 1022
`Page 10
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 11 of 14
`
`
`
`phone it performs a method of presenting representations of payment accepting unit events,
`comprising: at a mobile device with one or more processors, memory, one or more output
`devices including a display, and one or more radio transceivers: identifying one or more payment
`accepting units (e.g., CleanReaders) in proximity to the mobile device that are available to accept
`payment from a mobile payment application executing on the mobile device, the identifying
`including detecting predefined radio messages broadcast (e.g., by Bluetooth) by the one or more
`payment accepting units, wherein the one or more payment accepting units are vending machines
`(e.g., laundry machines) that accept payment for dispensing of products and/or services;
`displaying a user interface of the mobile payment application on the display of the mobile
`device, the user interface being configured to display a visual indication of the one or more
`payment accepting units and accept user input to (i) receive selection by a user of the mobile
`device of an available payment accepting unit of the one or more payment accepting units and
`(ii) trigger payment by the mobile payment application for a vending transaction initiated by the
`user of the mobile device with the available payment accepting unit of the one or more payment
`accepting units; establishing via the one or more radio transceivers a wireless connection
`between the mobile device and the available payment accepting unit of the one or more payment
`accepting units; after establishing the wireless connection, presenting the user interface of the
`mobile payment application and enabling user interaction with the user interface of the mobile
`payment application to complete the vending transaction; exchanging information with the
`available payment accepting unit via the one or more radio transceivers, in conjunction with the
`vending transaction; and in response to receiving the information, displaying, on the display, an
`updated user interface of the mobile payment application to the user of the mobile device.
`56.
`To the extent Defendants’ Infringing Products, without more, do not directly
`infringe at least claim 1 of the ’614 Patent, Defendants contribute to infringement of the same
`under 35 U.S.C. § 271(c) inasmuch as the Infringing Products offered for sale and sold by
`Defendants are each a component of a patented machine or an apparatus used in practicing a
`
`
`
`-11-
`
`Petitioner Kiosoft Exhibit 1022
`Page 11
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 12 of 14
`
`
`
`patented process, constituting a material part of PayRange’s invention, knowing the same to be
`especially made or especially adapted for use in infringement of the ’614 Patent.
`57.
`Defendants actively encourage their business partners and/or customers to use
`Defendants’ Infringing Products or their equivalents in an infringing manner. Defendants and
`Plaintiff had a business meeting in early 2019 where aspects of the now-patented technology was
`discussed. Despite such knowledge, Defendants have actively induced its business partners
`and/or customers to use Defendants’ products in a way that now constitutes infringement.
`Defendants have encouraged this infringement with a specific intent to cause its business
`partners and customers to infringe. Defendants’ acts thus constitute active inducement of patent
`infringement in violation of 35 U.S.C. § 271(b).
`58.
`Defendants’ direct infringement, contributory infringement, and inducement of
`infringement have irreparably harmed PayRange.
`59.
`Upon information and belief, Defendants will continue to infringe the ’614 Patent
`unless enjoined.
`60.
`Pursuant to 35 U.S.C. § 284, PayRange is entitled to damages adequate to
`compensate for the infringement.
`61.
`This case is “exceptional” within the meaning of 35 U.S.C. § 285, and PayRange
`is entitled to an award of attorneys’ fees.
`REQUEST FOR RELIEF
`WHEREFORE, Plaintiff requests that the Court find in its favor and against Defendants,
`and that the Court grant PayRange the following relief:
`a. Judgment that Defendants infringe the patents-in-suit;
`b. Judgment that Defendants are jointly and severally liable for infringement of the
`patents-in-suit.
`c. That PayRange be granted with injunctive relief against Defendants and its officers,
`employees, agents, servants, attorneys, instrumentalities, and/or those in privity with
`them, to prevent the recurrence of the infringing activities complained of herein,
`
`
`
`-12-
`
`Petitioner Kiosoft Exhibit 1022
`Page 12
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 13 of 14
`
`
`
`
`
`
`
`including removing all infringing mobile apps from all third party app stores such as
`the Google Play Store and Apple App Store, and for all further proper injunctive relief
`pursuant to 35 U.S.C. § 283;
`d. Judgment that Defendants account for and pay to PayRange all damages and costs
`incurred by PayRange, caused by Defendants’ infringing activities complained of
`herein;
`e. Judgment that Defendants have willfully infringed and increase the damages award to
`PayRange up to three times the amount assessed, pursuant to 35 U.S.C. § 284;
`f. That PayRange be granted pre-judgment and post-judgment interest on the damages;
`g. That this Court declare this an exceptional case and award PayRange reasonable
`attorneys’ fees and costs in accordance with 35 U.S.C. § 285; and
`h. That PayRange be granted such other and further relief as the Court may deem just and
`proper under the circumstances.
`
`-13-
`
`Petitioner Kiosoft Exhibit 1022
`Page 13
`
`

`

`Case 1:20-cv-24342-RNS Document 17 Entered on FLSD Docket 01/15/2021 Page 14 of 14
`
`
`
`Dated: January 15, 2021
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`By: /s/joseph r. englander
`Joseph R. Englander
`
`
`Joseph R. Englander
`FOWLER WHITE BURNETT
`1395 Brickell Avenue, 14th Floor
`Miami, Florida 33131
`Telephone: (305) 789-9200
`Facsimile: (305) 728-7559
`Email: JEnglander@fowler-white.com
`
`James C. Yoon (PHV pending)
`Ryan R. Smith (PHV pending)
`Jamie Y. Otto (PHV pending)
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 565-5100
`Email: jyoon@wsgr.com, rsmith@wsgr.com,
`jotto@wsgr.com
`
`ATTORNEYS FOR PLAINTIFF
`PAYRANGE INC.
`
`-14-
`
`Petitioner Kiosoft Exhibit 1022
`Page 14
`
`