1 KEKER & VAN NEST, LLP
JOHN W. KEKER - #49092
2 HENRY C. BUNSOW - #60707
JON B. STREETER - #101970
3 MICHAEL H. PAGE - #154913
RAGESH K. TANGRI - #159477
4 710 Sansome Street
San Francisco, CA 94111-1704
5 Telephone: (415) 391-5400
Facsimile: (415) 397-7188
6 FINNEGAN, HENDERSON, FARABOW,
7 GARRETT & DUNNER, LLP
CHRISTOPHER P. ISAAC
8 1300 I Street, N.W.
Washington, D.C. 20005-3314
9 Telephone: (202) 408-4000
Facsimile: (202) 408-4400
10 Attorneys for Plaintiff
11 INTERTRUST TECHNOLOGIES CORPORATION
12
13
14 UNITED STATES DISTRICT COURT
15 NORTHERN DISTRICT OF CALIFORNIA
16
17 INTERTRUST TECHNOLOGIES Case No. C 01 1640 JL
CORPORATION,
18 a Delaware corporation, FIRST AMENDED COMPLAINT FOR
INFRINGEMENT OF U.S. PATENT NOS.
19 Plaintiff, 6,185,683 B1 AND 6,253,193 B1
20 v. DEMAND FOR JURY TRIAL
21 MICROSOFT CORPORATION, a
Washington corporation,
22
Defendant.
23
24
25 Plaintiff INTERTRUST TECHNOLOGIES CORPORATION (hereafter "InterTrust")
26 hereby complains of Defendant MICROSOFT CORPORATION (hereafter "Microsoft"), and
27 alleges as follows:
28
SNIPPETS:
KEKER & VAN NEST, LLP
Washington, D.C. 20005-3314
Title 35, United States Code, more particularly 35 U.S.C. §§ 271 and 281.
10 Microsoft is a Washington Corporation with its principal place of business at One Microsoft
13 Microsoft does business in this judicial district and has committed and is continuing to
14 acts of infringement in this judicial district.
17 `683 patent"), duly and lawfully issued on February 6, 2001.
18 attached hereto as Exhibit A.
27 been and is infringing the `683 patent under § 271by making, using, selling, and offering
28 sale digital rights management software incorporating inventions claimed in the `683
FIRST AMENDED COMPLAINT FOR INFRINGEMENT OF U.S. PATENT NOS.
InterTrust is further informed and believes, and on that basis alleges, that Microsoft's
infringement of the `683 patent under §271will continue unless enjoined by this Court.
been and is knowingly and intentionally inducing others to infringe directly the `683 patent
thereby inducing infringement of the `683 patent under § 271.
By reason of the aforesaid acts of infringement,
19 infringement, as well as enhanced damages, pursuant to 35 U.S.C. § 284;
I am employed in the City and County of San Francisco, State of California in the office of a
Suite 275, San Francisco, CA 94102, with instructions to hand-carry the above and make
I am readily familiar with the practice of Keker & Van Nest,
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