Case 6:21-cv-00007 Document 1 Filed 01/06/21 Page 1 of 42
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:21-cv-_________
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`JURY TRIAL DEMANDED
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`CASELAS, LLC,
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`Plaintiff
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` v.
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`VOLUSION LLC,
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`Defendant
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Caselas, LLC (“Plaintiff”) hereby files this Original Complaint for Patent Infringement against
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`Volusion LLC (“Volusion” or “Defendant”), and alleges, upon information and belief, as follows:
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`THE PARTIES
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`1.
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`Caselas, LLC is a limited liability company organized and existing under the laws of the State of
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`Florida with its principal place of business at 600 S. Dixie Highway, Suite 605, West Palm Beach,
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`Florida 33401.
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`2.
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`Upon information and belief, Defendant is a foreign limited liability company organized and
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`existing under the laws of the State of Delaware, with a principal place of business located at
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`1835A Kramer Lane #100, Austin, Texas 78731. Defendant may be served through its registered
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`agent in the State of Texas at National Registered Agents, Inc., 1999 Bryan Street, Suite 900,
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`Dallas, Texas 75201. On information and belief, Volusion sells, offers to sell, and otherwise
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`provides payment processing and/or merchant account services throughout the State of Texas,
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`including in this judicial District, and introduces payment processing and/or merchant account
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`3.
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`4.
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`services via its infringing systems into the stream of commerce knowing and intending that they
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`would be extensively used in the State of Texas and in this judicial District. On information and
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`belief, Volusion specifically targets customers in the State of Texas and in this judicial District.
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`JURISDICTION AND VENUE
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`This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331 and 1338.
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`This Court has personal jurisdiction over Defendant. Defendant has continuous and systematic
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`business contacts with the State of Texas. Defendant directly conducts business extensively
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`throughout the State of Texas, by distributing, making, using, offering for sale, selling, and
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`advertising (including the provision of interactive web pages and providing payment processing
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`and/or merchant account services; and further including maintaining physical facilities) its services
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`in the State of Texas and in this District. Defendant has purposefully and voluntarily made its
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`business services, including the infringing systems, available to residents of this District and into
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`the stream of commerce with the intention and expectation that they will be purchased and/or used
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`by consumers in this District. On information and belief, Volusion is a provider of financial
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`services throughout the United States, and is a registered Visa Service Provider (or ISO), and/or is
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`a
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`registered MasterCard
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`Service
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`Provider
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`(or MSP).
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`See,
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`e.g.,
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`https://www.visa.com/splisting/searchGrsp.do (Visa Registered Service Providers List); see also
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`https://www.mastercard.us/content/mccom/en-us/merchants/safety-security/security-
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`recommendations/service-providers-need-to-know.html/
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`(MasterCard Registered
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`Service
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`Providers List).
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`5.
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`On information and belief, Defendant maintains physical brick-and-mortar business locations in
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`the State of Texas and within this District, retains employees specifically in this District for the
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`purpose of servicing customers in this District, and generates substantial revenues from its business
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`activities in this District.
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`See https://www.volusion.com/.
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`See https://www.volusion.com/careers.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`6.
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`See https://www.volusion.com/careers.
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`On information and belief, Volusion has a substantial presence in the State of Texas and within
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`this District, as exemplified by the LinkedIn Profile Page for Volusion, which indicates there are
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`173 employees of Volusion residing in the Austin area.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`See Volusion LinkedIn Profile Page, at https://www.linkedin.com/company/volusion/people/.
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`On information and belief, Volusion provides financial services, including but not limited to
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`7.
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`payment processing and/or merchant account services, to businesses located in the State of Texas
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`and within this District. On information and belief, Volusion further provides specific hardware
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`(such as, for example, credit card terminals) to its customers in the State of Texas and within this
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`District, and provides technical support for such hardware. On information and belief, Volusion
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`further exercises ownership control over such hardware via contractual licensing and/or lease
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`agreements with its customers.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`8.
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`Venue is proper in the Western District of Texas as to Defendant pursuant to at least 28 U.S.C. §§
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`1391(c)(2) and 1400(b). As noted above, Defendant maintains a regular and established business
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`presence in this District.
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`PATENTS-IN-SUIT
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`9.
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`Plaintiff is the sole and exclusive owner, by assignment, of U.S. Patent Nos. 7,529,698 (“the ’698
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`Patent”); 7,661,585 (“the ’585 Patent”); 9,117,206 (“the ’206 Patent”); 9,117,230 (“the ’230
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`Patent”); and 9,715,691 (“the ’691 Patent”) (hereinafter collectively referred to as “the Caselas
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`Patents”).
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`10.
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`By operation of law, the Caselas Patents were originally issued and exclusively vested to the sole
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`named inventor, Raymond Anthony Joao, as of the date of their respective issuances. See 35
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`U.S.C. § 261; Schwendimann v. Arkwright Advanced Coating, Inc., 959 F.3d 1065, 1072 (Fed.
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`Cir. 2020); Suppes v. Katti, 710 Fed. Appx. 883, 887 (Fed. Cir. 2017); Taylor v. Taylor Made
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`Plastics, Inc., 565 Fed. Appx. 888, 889 (Fed. Cir. 2014). Mr. Joao, in a written instrument dated
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`March 6, 2012, and filed with the United States Patent and Trademark Office on May 7, 2015 at
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`Reel 035604 and Frames 0126-0132, assigned all rights, title, and interest in the Caselas Patents
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`to GTJ Ventures, LLC. Thereafter, in a written instrument dated October 23, 2020, GTJ Ventures
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`assigned all rights, title, and interest in the Caselas Patents to the Plaintiff, Caselas LLC. As such,
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`Plaintiff Caselas LLC has sole and exclusive standing to assert the Caselas Patents and to bring
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`these causes of action.
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`11.
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`The Caselas Patents are valid, enforceable, and were duly issued in full compliance with Title 35
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`of the United States Code.
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`12.
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`The inventions described and claimed in the Caselas Patents were invented individually and
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`independently by Raymond Anthony Joao.
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`13.
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`14.
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`The Caselas Patents each include numerous claims defining distinct inventions.
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`The priority date of each of the Caselas Patents is at least as early as January 16, 2001. As of the
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`priority date, the inventions as claimed were novel, non-obvious, unconventional, and non-routine.
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`15.
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`For example, and as evidence of the stated non-routine aspects of the inventions, during
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`prosecution of the ’206 Patent, Primary Examiner Andrew Joseph Rudy specifically and expressly
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`considered whether the claims of the ’206 Patent were eligible under 35 USC §101 in view of the
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`United States Supreme Court’s decision in Alice. Examiner Rudy affirmatively and expressly
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`found that the claims are in fact patent eligible under 35 USC §101 because: (i) all claims are
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`directed to patent-eligible subject matter; (ii) none of the claims are directed to an abstract idea;
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`(iii) each of the claims contains an inventive concept; and (iv) there is no preemption of any
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`abstract idea or the field of the abstract idea (if any). See Corrected Notice of Allowability, dated
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`July 9, 2015.
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`16.
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`As further evidence of the stated non-routine aspects of the inventions, during prosecution of the
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`’230 Patent, Primary Examiner Andrew Joseph Rudy specifically and expressly considered
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`whether the claims of the ’230 Patent were eligible under 35 USC §101 in view of the United
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`States Supreme Court’s decision in Alice. Examiner Rudy affirmatively and expressly found that
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`the claims are in fact patent eligible under 35 USC §101 because: (i) all claims are directed to
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`patent-eligible subject matter; (ii) none of the claims are directed to an abstract idea; (iii) each of
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`the claims contains an inventive concept; and (iv) there is no preemption of any abstract idea or
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`the field of the abstract idea (if any). See Corrected Notice of Allowability, dated July 9, 2015.
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`17.
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`As further evidence of the stated non-routine aspects of the inventions, during prosecution of the
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`’691 Patent, Primary Examiner Andrew Joseph Rudy specifically and expressly considered
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`whether the claims of the ’691 Patent were eligible under 35 USC §101 in view of the United
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`States Supreme Court’s decision in Alice. Examiner Rudy affirmatively and expressly found that
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`the claims are in fact patent eligible under 35 USC §101 because: (i) all claims are directed to
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`patent-eligible subject matter; (ii) none of the claims are directed to an abstract idea; (iii) each of
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`the claims contains an inventive concept; and (iv) there is no preemption of any abstract idea or
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`the field of the abstract idea (if any). See Notice of Allowability, dated April 10, 2017.
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`18.
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`Plaintiff alleges infringement on the part of Defendant of the ’698 Patent, the ’585 Patent, the ’206
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`Patent, the ’230 Patent, and the ’691 Patent (collectively as the “Asserted Patents”).
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`19.
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`The ’698 Patent relates generally to methods which include receiving information regarding a
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`transaction involving an account, wherein the information regarding the transaction is received by
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`a receiver prior to a processing, a completion, a consummation, or a cancellation, of the transaction,
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`processing the information regarding the transaction with a processing device using information
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`regarding the account, generating a report or a message in response to the processing of the
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`information regarding the transaction, wherein the report or the message contains information
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`regarding a charge-back regarding a previous transaction involving the account, and transmitting
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`the information report to a communication device associated with a merchant, vendor, or provider,
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`of a good, product, or service. See Abstract, ’698 Patent.
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`20.
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`The ’585 Patent relates generally to apparatuses and methods, which include receiving information
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`regarding a transaction involving an individual and involving an account, wherein the information
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`regarding the transaction is received by a receiver prior to a processing, a completion, a
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`consummation, or a cancellation, of the transaction, processing the information regarding the
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`transaction with a processing device, generating a report or a message in response to the processing
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`of the information regarding the transaction, wherein the report or the message contains
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`information regarding a charge-back regarding a previous transaction involving the individual, and
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`transmitting the report or the message to a communication device associated with a merchant,
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`vendor, or provider, of a good, product, or service. See Abstract, ’585 Patent.
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`21.
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`The ’206 Patent relates generally to apparatuses and methods, which include receiving information
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`regarding an individual and information involving an account involved in a transaction, wherein
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`the information regarding the individual is received by a receiver prior to a processing, a
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`completion, a consummation, or a cancellation, of the transaction, processing the information
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`regarding the individual with a processing device, generating a report or a message in response to
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`the processing of the information regarding the individual, wherein the report or the message
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`contains information regarding a charge-back regarding a previous transaction involving the
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`individual, and transmitting the report or the message to a communication device associated with
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`a merchant, vendor, or provider, of a good, product, or service. See Abstract, ’206 Patent.
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`22.
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`The ’230 Patent relates generally to apparatuses and methods, which include receiving information
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`regarding a transaction involving an individual and involving an account, wherein the information
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`regarding the transaction is received by a receiver prior to a processing, a completion, a
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`consummation, or a cancellation, of the transaction, processing the information regarding the
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`transaction with a processing device, generating a report or a message in response to the processing
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`of the information regarding the transaction, wherein the report or the message contains
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`information regarding a charge-back regarding a previous transaction involving the individual, and
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`transmitting the report or the message to a communication device associated with a merchant,
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`vendor, or provider, of a good, product, or service. See Abstract, ’230 Patent.
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`23.
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`The ’691 Patent relates generally to apparatuses and methods, which include processing, with a
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`processing device, information regarding an account involved in a transaction involving an
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`individual, wherein the information regarding the account is received by a receiver, and further
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`wherein the information regarding the account is processed prior to a processing, a completion, a
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`consummation, or a cancellation, of the transaction, generating, with the processing device, a
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`report or a message in response to the processing of the information regarding the account, wherein
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`the report or the message contains information regarding a charge-back regarding a previous
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`transaction involving the account, and transmitting, with or from a transmitter, the report or the
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`message to a communication device associated with a merchant, vendor, or provider, of a good,
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`product, or service. See Abstract, ’691 Patent.
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`24.
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`As noted, the claims of the Asserted Patents have priority to at least January 16, 2001. At that
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`time, the use of chargeback data as an integral data point in payment processing was still many
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`years away. For example, Visa did not recognize and implement chargeback data into individual
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`real-time transaction risk assessments until 2010. Similarly, MasterCard did not recognize and
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`implement chargeback data into individual real-time transaction risk assessments until 2015. The
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`same is true of payment technology companies such as Intuit and Square, which did not implement
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`chargeback data into individual real-time transaction risk assessments until 2009 and 2015,
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`respectively. As such, the technological solutions of the Caselas Patents were not well-understood,
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`routine, or conventional as of January 2001.
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`25.
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`As noted, the claims of the Asserted Patents have priority to at least January 16, 2001. Only years
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`later would credit card issuers and payment processors begin to recognize the importance of
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`chargebacks in the real-time processing of individual transactions. For example, the Payment Card
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`Industry Data Security Standard (“PCI DSS”) was not developed until December 2004. Further,
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`the Secure POS Vendor Alliance (“SPVA”) was not created until 2009 by VeriFone, Hypercom,
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`and Ingenico. As such, the technological solutions of the Caselas Patents were not well-
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`understood, routine, or conventional as of January 2001.
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`26.
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`The claims of the Asserted Patents are not drawn to laws of nature, natural phenomena, or abstract
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`ideas. Although the systems and methods claimed in the Asserted Patents are ubiquitous now
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`(and, as a result, are widely infringed), the specific combinations of elements, as recited in the
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`claims, were not conventional or routine at the time of the invention.
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`27.
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`Further, the claims of the Asserted Patents contain inventive concepts which transform the
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`underlying non-abstract aspects of the claims into patent-eligible subject matter.
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`28.
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`Consequently, the claims of the Asserted Patents recite apparatuses and methods resulting in
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`improved functionality of the claimed systems and represent technological improvements to the
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`operation of computers. The claims of the Asserted Patents provide for more secure transaction
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`processing, reduced fraud, reduced chargeback exposure to merchants, reduced costs to merchants
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`(including as a result of lower chargeback ratios), reduced opportunity-cost losses to merchants,
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`reduced costs of goods for consumers, and more secure transactions involving merchants and non-
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`present consumers (such as, for example, online merchants). See, e.g., ’698 Patent at 1:33-2:38.
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`29.
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`The claims of the Asserted Patents overcome deficiencies existing in the art as of the date of
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`invention, and comprise non-conventional approaches that transform the inventions as claimed
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`into substantially more than mere abstract ideas. For example, as of the date of invention,
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`“[m]erchants, vendors, or providers, of goods, products, or services, lo[se] millions of dollars each
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`year as the result of non-payment of their receivables. Non-payment of receivables can result from
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`credit card fraud, charge card fraud, debit card fraud, cyber-shoplifting, charge-backs, bank fraud,
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`check fraud, the stopping of issued checks, checks returned for insufficient funds, and other causes
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`or activities.” ’698 Patent at 1:33-39. The inventions as claimed overcome these deficiencies in
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`the state of the art, and provide substantial cost savings and protections to all parties. As explained,
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`as of the date of invention, “many merchants, vendors, or providers, are having their charges or
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`receivables challenged, disputed, and/or denied, by dishonest individuals. This has resulted in
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`charge-backs to the merchants, vendors, or providers, which entail having a bank or issuer
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`associated with the account holder’s or the account owner’s account impose a return of funds.
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`Other fees may also be imposed on the respective merchants, vendors, or providers.” Id. at 1:62-
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`2:2. Likewise, as of the date of invention, “the respective merchants, vendors, or providers, can
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`lose in a number of ways. They lose the funds received, they may not have the goods, products,
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`or services, returned, they may be charged charge-back fees, and/or they can experience
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`opportunity costs (i.e. expended employee time and/or company resources) in dealing with the
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`disputed charges.” Id. at 2:3-9. As such, the inventions as claimed provide non-conventional
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`solutions to the conventional problems of the day because the likelihood of chargeback, and the
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`resulting costs and business disruptions to the merchant, are reduced. Id. at 2:35-39.
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`30.
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`The inventions as claimed further overcome the deficiencies existing in the art as of the date of
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`invention by “prevent[ing] and/or … reduc[ing] the incidence of any one or more of credit card
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`fraud, credit account fraud, charge card fraud, charge account fraud, debit card fraud, debit account
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`fraud, check fraud, checking account fraud, and/or cyber-shoplifting.” As explained, the
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`inventions as claimed overcome these deficiencies by “provid[ing] an apparatus and method for
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`providing transaction history information, account history information, and/or charge-back
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`information which can be utilized by a merchant, vendor, or other entity, in processing, and/or in
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`assessing the processing of, a transaction.” Id. at 2:39-48. As such, the inventions as claimed
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`provide non-conventional solutions to the conventional problems of the day because the incidents
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`of fraud are reduced by the use of chargeback information in the processing of transactions.
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`31.
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`The inventions as claimed further overcome the deficiencies existing in the art as of the date of
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`invention by providing methods and apparatuses for processing entities to assess “whether or not
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`it should fulfill an order relating to a transaction.” As explained, the inventions as claimed
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`overcome prior deficiencies in this regard by “process[ing] information regarding past denials of
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`liability or responsibility regarding a transaction, past charge-back activity involving any one or
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`more of a credit card, a credit account, a charge card, a charge account, a debit card, a debit account,
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`or a checking account.” Id. at 2:61-3:3. As such, the inventions as claimed provide non-
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`conventional solutions to the conventional problems of the day because the incidents of fulfilling
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`fraudulent or potential chargeback transactions are reduced on the front end, based on past
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`chargeback activity (among others).
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`32.
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`The inventions as claimed further overcome the deficiencies existing in the art as of the date of
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`invention by providing methods and apparatuses for use in all types of transactions, including
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`“face-to-face
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`transactions, non-face-to-face
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`transactions,
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`telephone
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`transactions, on-line
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`transactions, mail order transactions, and/or in any other non-cash transactions.” Id. at 3:4-12. As
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`such, the inventions as claimed provide non-conventional solutions to the conventional problems
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`of the day by providing a solution for non-cash and non-face-to-face transactions (including online
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`transactions), among others. Among other advancements, the inventions as claimed provided
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`nonconventional solutions to online transaction processing, which was deficient at the time.
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`33.
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`The inventions as claimed further overcome the deficiencies existing in the art as of the date of
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`invention by providing methods and apparatuses useful by “a merchant, vendor, or other entity, in
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`order to assess an individual's or an entity's past transaction history, account history, or charge-
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`back history, in order to determine if the individual or entity has had a history of, or could be a risk
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`in, denying being party to a transaction involving a credit card, a credit account, a charge card, a
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`charge account, a debit card, a debit account, or a checking account, disputing a transaction a
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`involving credit card, a credit account, a charge card, a charge account, a debit card, a debit
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`account, passing or attempting to pass a bad check, stopping payment of an issued check, and/or
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`in other ways attempting to defraud or otherwise obtain goods, products, or services, without
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`paying for same, shopping same, and/or cyber-shoplifting same.” Id. at 3:13-35. As such, the
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`inventions as claimed provide non-conventional solutions to the conventional problems of the day
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`by providing a solution for payment processors as a safeguard against future or potential
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`chargebacks. Among other advancements, the inventions as claimed provided nonconventional
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`solutions, which included a consideration of historical chargebacks or fraud by the individual
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`associated with the transaction. The inventive solution further provides for fraud and chargeback
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`assessment “during a transaction authorization process,” which was unconventional at the time.
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`Id. at 3:35-42.
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`34.
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`The inventions as claimed further overcome the deficiencies existing in the art as of the date of
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`invention by providing for an unconventional “central processing computer,” which performs a
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`number of specific inventive aspects of the solution. As such, the claimed “central processing
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`computer” does not merely comprise standard conventional hardware and software; rather, as
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`claimed, it advances the functionality of the computer as a useful tool in the electronic processing
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`of payments and the prevention of fraud.
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`35.
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`The inventions as claimed provide multiple inventive technical solutions to the technological
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`problems of the time associated with chargeback and electronic payment fraud. Among those
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`technological solutions are: (i) providing transaction history information, account history
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`information, and/or charge-back information, which can be utilized by a merchant, vendor, or other
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`entity, in processing, and/or in assessing the processing of, a transaction; (ii) providing transaction
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`history information, account history information, and/or charge-back information, which can be
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`utilized in order to prevent and/or in order to reduce the incidence of any one or more of credit
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`card fraud, credit account fraud, charge card fraud, charge account fraud, debit card fraud, debit
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`account fraud, check fraud, checking account fraud, or cyber-shoplifting; (iii) providing
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`transaction history information, account history information, and/or charge-back information,
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`which can be utilized in order to process information regarding fraudulent use of any one or more
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`of credit cards, credit accounts, charge cards, charge accounts, debit cards, debit accounts,
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`electronic money accounts, automated teller machines, checks, or checking accounts; (iv)
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`providing transaction history information, account history information, and/or charge-back
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`information, which can be utilized in order to process information regarding checks returned due
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`to insufficient funds and checks for which stop payment orders have been made; (v) providing
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`transaction history information, account history information, and/or charge-back information
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`which can be utilized to process information regarding disputes and/or denial of payment
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`assertions made in conjunction with any one or more of credit cards, credit accounts, charge cards,
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`charge accounts, debit cards, debit accounts, electronic money accounts, checks, or checking
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`accounts; (vi) providing transaction history information, account history information, and/or
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`charge-back information, which can be utilized in order to process information regarding past
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`denials of liability or responsibility regarding a transaction; (vii) providing transaction history
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`information, account history information, and/or charge-back information, which can be utilized
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`in order to perform risk management assessments regarding a transaction; (viii) providing
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`transaction history information, account history information, and/or charge-back information,
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`which can be utilized in face-to-face transactions, non-face-to-face transactions, telephone
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`transactions, on-line transactions, mail order transactions, or in any other transactions; (ix)
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`providing transaction history information, account history information, and/or charge-back
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`information, which can provide information at any time during, prior to, and/or subsequent to, a
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:21-cv-00007 Document 1 Filed 01/06/21 Page 16 of 42
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`transaction; (x) providing transaction history information, account history information, and/or
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`charge-back information, which can be utilized to allow a merchant, vendor, or provider, of goods,
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`products, and/or services, to process information regarding a counterpart or counterparty to a
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`transaction in order to determine if the counterpart or counterparty could be a risk, could be a credit
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`risk, or might not fulfill payment obligations relating to a transaction; (xi) providing transaction
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`history information, account history information, and/or charge-back information, which can be
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`utilized during a transaction, during a transaction authorization process, subsequent to a
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`transaction, subsequent to a transaction authorization process, prior to an order fulfillment process,
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`or during an order fulfillment process; (xi) providing transaction history information, account
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`history information, and/or charge-back information, which can be utilized on, over, or on
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`conjunction with, any communication network or system; (xii) providing transaction history
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`information, account history information, and/or charge-back information, which can be utilized
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`on, over, or in conjunction with, any one or more of a telephone network, a telecommunication
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`network, a digital communication network, a satellite communication network, a wireless
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`communication network, a personal communication services network, a broadband
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`communication network, or a bluetooth communication network; (xiii) providing transaction
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`history information, account history information, and/or charge-back information, which can be
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`utilized on, over, or in conjunction with the Internet and/or the World Wide Web; (xiv) providing
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`transaction history information, account history information, and/or charge-back information,
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`which can be utilized on, over, or in conjunction with a wireless communication network; (xv)
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`providing transaction history information, account history information, and/or charge-back
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`information, which can be utilized in order to provide information to a merchant, vendor, or
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`provider, regarding charge-backs, stopping of payments, and/or failures to make payments, which
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:21-cv-00007 Document 1 Filed 01/06/21 Page 17 of 42
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`have occurred in an account of an individual or entity; (xvi) providing transaction history
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`information, account history information, and/or charge-back information, which can provide
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`detailed information to a merchant regarding an account transaction or subsequent activities; (xvii)
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`providing transaction history information, account history information, and/or charge-back
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`information, which can be utilized in order to provide transaction history information, account
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`history information, and/or charge-back information, during a transaction authorization process,
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`prior to an transaction authorization process, subsequent to transaction authorization process, or
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`prior to a goods, products, and/or services, shipment or delivery; (xviii) providing transaction
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`history information, account history information, and/or charge-back information, which can
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`utilize intelligent agents, software agents, or mobile agents; and (xix) providing transaction history
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`information, account history information, and/or charge-back information, which can be
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`programmed to be self-activating or activated automatically. Id. at 5:52-7:61. Each of the
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`foregoing represent non-routine and unconventional technological solutions to the deficiencies in
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`the art relating to chargeback and electronic payment fraud; thus, the inventions as claimed capture
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`inventive concepts that transform the inventions into substantially more than the mere practice of
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`electronic payment processing.
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`36.
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`As noted above, during prosecution of each of the ’206 Patent, the ’230 Patent, and the ’691 Patent,
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`the Primary Patent Examiner specifically considered whether the claims at issue were eligible
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`under 35 USC §101 in view of the United States Supreme Court’s decision in Alice. In each
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`instance, after due consideration, the Primary Patent Examiner expressly found that the claims are
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`in fact patent eligible under 35 USC §101 because: (i) all claims are directed to patent-eligible
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`subject matter; (ii) none of the claims are directed to an abstract idea; (iii) each of the claims
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`contains an inventive concept; and (iv) there is no preemption of any abstract idea or the field of
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`ORIGINAL COMPLAINT FOR PATENT INFRING