IN THE UNITED STATES DISTRICT FOR THE SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION BASHEN COPORATION, § a Texas corporation, § § Plaintiff, § § Civil Action No. 14-cv-1174 v. § § LITTLER MENDELSON, P.C., § a California professional corporation, § § Defendant. §

COMPLAINT FOR PATENT INFRINGEMENT

Bashen Corporation, by its attorneys, for its Complaint against Littler Mendelson,

P.C., alleges as follows:

THE PARTIES, JURISDICTION AND VENUE

1. This is an action for patent infringement arising under Title 35 U.S.C. §1 et

seq., of the United States.

2. Plaintiff, Bashen Corporation (“Bashen”) is a Texas corporation with its

principal place of business in Houston, Texas.

3. Defendant, Littler Mendelson, P.C. (“Littler”) is a law firm with its main

office in San Francisco, California and an office in Houston, Texas.

4. This claim arises under the United States Patent laws, 35 U.S.C. §1, et seq.

This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§1331,

1332, and 1338(a).

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5. This Court has specific personal jurisdiction over Littler because the

infringing acts conducted by Littler in this State and District are the same infringing acts

which constitute the instant cause of action.

6. This Court has general personal jurisdiction over Littler because it has

regularly and systematically conducted business in this State and District and

purposefully availed itself of the privilege of conducting business in this State and this

District.

7. Venue is proper in this District and Division, under 28 U.S.C. §§1391 and

1400.

FACTS GIVING RISE TO PATENT INFRINGEMENT

8. On January 10, 2006, after a full and extensive examination, the United

States Patent and Trademark office duly and legally issued United States Patent No.

6,985,922 (“the ‘922 Patent”) entitled Method, Apparatus And System For Processing

Compliance Actions Over A Wide Area Network. A true and correct copy of the ‘922

Patent is attached as Exhibit A.

9. Bashen owns all right, title, and interest to the ‘922 Patent, including the

exclusive right to enforce the ‘922 Patent against past, present and future infringement

and resulting damages therefrom.

10. The ‘922 Patent discloses an invention for processing, tracking and

managing compliance actions, such as equal employment opportunity claims, over a wide

area network.

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11. Bashen is in the business of processing, tracking and managing compliance

actions for third parties predominantly in the equal employment opportunity area.

12. Littler uses software that organizes, tracks and processes data, and is

marketed under the title CaseSmart®.

13. Littler has infringed and continues to infringe the ‘922 Patent by engaging

in acts including making, using, selling, or offering to sell software solutions associated

with its CaseSmart® software, and other software, service and maintenance products sold

in conjunction with CaseSmart®.

14. Littler will continue to infringe the ‘922 Patent unless enjoined by this

Court.

15. As a result of Littler’s infringing conduct, Bashen has suffered, and will

continue to suffer, irreparable harm for which there is no adequate remedy at law.

16. As a result of the infringement of the ‘922 Patent, Bashen has been

damaged, will be further damaged, and is entitled to be compensated for such damages,

pursuant to 35 U.S.C. §284, in an amount to be determined at trial.

WILLFUL INFRINGEMENT

17. Littler’s past and continuing infringement of the ‘922 Patent has been

deliberate and willful. Its conduct warrants an award of treble damages, pursuant to 35

U.S.C. §284, and this is an exceptional case justifying an award of attorney fees to

Bashen, pursuant to 35 U.S.C. §285.

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PRAYER FOR RELIEF

Wherefore, upon final hearing or trial, plaintiff Bashen respectfully requests the

following relief:

a. judgment that Littler Mendelson, P.C. has infringed the ‘922 Patent;

b. judgment and order requiring Littler Mendelson, P.C. to pay damages to Bashen adequate to compensate it for Littler Mendelson’s wrongful infringing acts, in accordance with 35 U.S.C. §284;

c. judgment requiring Littler Mendelson, P.C. to pay increased damages up to three times for its willful and deliberate infringement of the ‘922 Patent;

d. judgment that this is an exceptional case, under 35 U.S.C. §285, and an award to Bashen of its costs, including its reasonable attorney fees and other expenses incurred in connection with this action;

e. judgment requiring Littler Mendelson, P.C. to pay prejudgment interest on the amount of the damage award;

f. such additional relief the Court deems fair and just.

JURY DEMAND

Bashen Corporation requests a trial by jury on all issues so triable.

Respectfully Submitted,

BASHEN CORPORATION

Date: April 29, 2014 By:/s/ Mark M. Grossman

Mark M. Grossman mgrossman@grossmanlegal.com Nicolas Spear nspear@grossmanlegal.com Kyle D. Wallenberg kwallenberg@grossmanlegal.com Grossman Law Offices 225 W. Washington Street, Suite 2200 Chicago, Illinois 60606 (312) 621-9000

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