IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WEB NAVIGATION TECHNOLOGIES, LLC, Plaintiff, v.

LINKEDIN CORPORATION AND ALPHONSO LABS INC. D/B/A PULSE Defendants.

Civil Action No. ______ JURY TRIAL DEMANDED

PLAINTIFFS COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Web Navigation Technologies, LLC (WNT) files this Complaint against LinkedIn Corporation (LinkedIn) and Alphonso Labs Inc. d/b/a Pulse (Pulse) (collectively Defendants) and alleges as follows: PARTIES 1. Plaintiff WNT is a Delaware corporation with its principal place of business at

One Commerce Center 1201 Orange St., #600, Wilmington, DE 19899. 2. Upon information and belief, Defendant LinkedIn is a corporation organized and

existing under the laws of the State of Delaware, with its principal place of business located at 2029 Stierlin Ct., Mountain View, CA 94043. LinkedIn may be served with process through its registered agent Corporation Service Company dba CSC Lawyers Incorporating Service at 2710 Gateway Oaks Dr., Suite 150N, Sacramento, California 95833 3. Upon information and belief, Defendant Pulse is a corporation organized and

existing under the laws of the State of Delaware, with its principal place of business located at

320 High St., Palo Alto, CA 94301. Pulse may be served with process through its registered agent Akshay Kothari at 320 High St., Palo Alto, CA 94301. BACKGROUND 4. On information and belief, Defendant LinkedIn is the owner of a professional

social network on the Internet, with users worldwide. 5. On information and belief, Defendant LinkedIn owns, operates, and/or is doing

business as Pulse. 6. On information and belief, Defendant Pulse makes, imports, sells, and/or offers

for sale the Pulse System (as defined below), which provides a system for navigating through a plurality of user specified web pages (Pulse System) within the United States, including this District, that infringes one or more claims of United States Patent No. 6,993,531 (the 531 Patent) entitled System and Method of Routine Navigation. The 531 Patent was duly and legally issued by the United States Patent and Trademark Office on January 31, 2006. A true and correct copy of the 531 Patent is attached hereto as Exhibit A. 7. On information and belief, the Pulse System provides a system for navigating

through a list of user specified web pages with a browser that allows a user to sequentially move through such web pages. Because this system for navigating through a list of user specified web pages is an essential part of the functionality of the Pulse System, the Pulse System does not have any substantial uses that do not infringe the 531 Patent. 8. Defendants have provided and continue to provide to internet users access to a

system for navigating through a plurality of user specified web pages, including through use of the Pulse System. On information and belief, Defendants intend on making the Pulse System available in the future.

9.

Defendants direct end users to operate the websites Pulse System, for example,

by providing instructions on proper use and operation of the Pulse System. JURISDICTION AND VENUE 10. This is an action for patent infringement arising under the patent laws of the

United States of America, Title 35, United States Code. 11. This Court has original jurisdiction over the subject matter of this action pursuant

to 28 U.S.C. 1331 and 1338(a). 12. Upon information and belief, Defendants are subject to this Courts general and/or

specific personal jurisdiction because they (a) are residents of the State of Delaware; (b) have designated an agent for service of process in the State of Delaware; (c) have committed acts of infringement in the State of Delaware as alleged below; and/or (d) are engaged in continuous and systematic activities in the State of Delaware. 13. Venue is proper in this district under 28 U.S.C. 1391(c) and 1400(b). On

information and belief, Defendants have a regular and established place of business in this district, and/or have transacted business in this district, and/or have committed, contributed to the commitment of, and/or induced acts of patent infringement in this district. THE PATENT-IN-SUIT 14. WNT is the owner by assignment of the 531 Patent and owns all right, title and

interest in the 531 Patent, including the right to sue for and recover all past, present and future damages for infringement of the 531 Patent. 15. Defendants have been aware of the 531 Patent, at a minimum, as of the date of

the filing of this suit.

CLAIM 1 INFRINGEMENT OF U.S. PATENT NO. 6,993,531 16. 17. WNT incorporates paragraphs 1 through 15 as though fully set forth herein. Upon information and belief, Defendants have been and are now directly

infringing one or more claims of the 531 Patent in violation of 35 U.S.C. 271(a), by making, using, selling, offering for sale or importing in the United States the computer-implemented website www.pulse.me, which provides a system for navigating through a plurality of user specified web pages. On information and belief, Defendants intend to continue offering a system for navigating through a plurality of user specified web pages in the future. 18. In addition and/or in the alternative, Defendants have been and/or are now

indirectly infringing one or more claims of the 531 Patent and are continuing to engage in such indirect infringement in violation of 35 U.S.C. 271(b) by inducing visitors to the www.pulse.me website and to use the Pulse System to directly infringe the 531 Patent through their use of the infringing instrumentalities with the knowledge that end users will use the Pulse System and with the knowledge and the specific intent to encourage and facilitate the infringing uses by at least making their www.pulse.me website available to end users and providing access to the Pulse System and the necessary software and instructional materials to operate the same. Defendants are aware that the Pulse System provides a system for navigating through a plurality of user specified web pages and, therefore, that Defendants end users will infringe the 531 Patent by using the Pulse System. On information and belief, end users of the www.pulse.me website use the Pulse System to navigate through a plurality of user specified web pages and, therefore, directly infringe one or more claims of the 531 Patent. On information and belief, Defendants have intended, and continue to intend, to induce patent infringement by end users,

with knowledge that the inducing acts would cause infringement, or have been willfully blind to the possibility that the inducing acts would cause infringement. 19. As a direct and proximate consequence of the acts and practices of Defendants in

infringing, directly and/or indirectly, one or more claims of the 531 Patent, WNT has suffered, is suffering, and will continue to suffer injury and damages for which it is entitled to relief under 35 U.S.C. 284 in an amount to be determined at trial. 20. WNT. DEMAND FOR JURY TRIAL 21. WNT, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by The limitation of damages provision of 35 U.S.C. 287(a) is not applicable to

jury of any issues so triable. PRAYER FOR RELIEF WHEREFORE, Web Navigation Technologies, LLC requests entry of judgment that: 1. 2. Defendants have infringed the patent-in-suit; Defendants account for and pay to Plaintiff all damages caused by their

infringement of the patent-in-suit; 3. Plaintiff be granted pre-judgment and post-judgment interest on the damages

caused to it by reason of one or more of Defendants patent infringement; 4. The Court declare this an exceptional case and that Plaintiff be granted reasonable

attorneys fees in accordance with 35 U.S.C. 285; 5. 6. Costs be awarded to Plaintiff; and Plaintiff be granted such other and further relief as the Court may deem just and

proper under the circumstances.

July 10, 2013 OF COUNSEL:

BAYARD, P.A. /s/ Richard D. Kirk Richard D. Kirk (No. 922) Stephen B. Brauerman (No. 4952) Vanessa R. Tiradentes (No. 5398) 222 Delaware Avenue, Suite 900 P.O. Box 25130 Wilmington, DE 19899 (302) 655-5000 rkirk@bayardlaw.com sbrauerman@bayardlaw.com vtiradentes@bayardlaw.com Attorneys for Plaintiff Web Navigation Technologies, LLC