Complaint Against Egnyte, Inc. Filed by Ubqs-ip, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Civil Cover Sheet) (Ramey, William)

Document #1 Filed 03/27/2026 · 8 pages · District Court, D. Utah · View original PDF

1Plaintiff UBQS-IP LLC is a Texas limited liability company having an address located at 5900 Balcones Dr., Suite 100, Austin, Texas 78731.

2On information and belief, Defendant is a Delaware corporation with a principal office in California and a regular and established place of business at 13937 Sprague Lane, Suite 150, Draper, Utah, 84020. On information and belief, Defendant sells and offers to sell products and services throughout Utah, including in this judicial district, and introduces products and services that perform infringing methods or processes into the stream of commerce knowing that they would be sold in Utah and this judicial district. Defendant can be served with process through their registered agent, Northwest Registered Agent, LLC, 7533 S Center View Court, Suite N, West Jordan, Utah 84084, at its place of business, or anywhere else it may be found.

3The defendant operates, manufactures, and sells foods products in the State of Utah and throughout the United States. The defendant is, upon information and belief, licensed to do business and does business in the State of Utah.

II.

JURISDICTION AND VENUE

4This Court has original subject-matter jurisdiction over the entire action pursuant to 28 U.S.C. §§ 1331 and 1338(a) because Plaintiff’s claim arises under an Act of Congress relating to patents, namely, 35 U.S.C. § 271.

5This Court has personal jurisdiction over Defendant because: (i) Defendant is present within or has minimum contacts within the State of Utah and this judicial district; (ii) Defendant has purposefully availed itself of the privileges of conducting business in the State of Utah and in this judicial district; and (iii) Plaintiff’s cause of action arises directly from Defendant’s business contacts and other activities in the State of Utah and in this judicial district.

6Venue is proper in this district under 28 U.S.C. § 1400(b). Defendant has committed acts of infringement and has a regular and established place of business in this District. Further, venue is proper because Defendant conducts substantial business in this forum, directly or through intermediaries, including: (i) at least a portion of the infringements alleged herein; and (ii) regularly doing or soliciting business, engaging in other persistent courses of conduct and/or deriving substantial revenue from goods and services provided to individuals in Utah and this District. Furthermore, Defendant resides in Utah.

III. INFRINGEMENT OF THE ’580 PATENT

7On December 25, 2007, the ’580 patent”, (attached as Exhibit A) entitled “Systems and Methods for Sharing Information between a User Group and Associated Document” was duly and legally issued by the U.S. Patent and Trademark Office. Plaintiff owns the ’580 patent by assignment, reel/frame 073448/0258, recorded January 23, 2026. The ‘580 patent expires on March 26, 2026 and therefore Plaintiff is not seeking indirect infringement claims after March 25, 2026.

8The ’580 patent relates to novel and improved systems and methods for provide for sharing information between a user group and an associated document and, more particularly, provide for making use of a distributed information framework without the need for a project management server, offering a common document to all participants in the project

9Defendant maintains, operates, and administers a system with methods and user interface that allow collaborative editing for multiple people to concurrently edit a single page or blog post that infringes one or more of claims of the ’580 patent, including one or more of claims 1-20, literally or under the doctrine of equivalents. Defendant puts the inventions claimed by the ’580 patent into service (i.e., used them) but for Defendant’s actions, the claimed inventions embodiments involving Defendant’s products and services would never have been put into service. Defendant’s acts complained of herein caused those claimed-invention embodiments to perform, and enabled Defendant’s procurement of monetary and commercial benefit therefrom.

10Support for the allegations of infringement may be found in the preliminary exemplary table attached as Exhibit B. These allegations of infringement are preliminary and are therefore subject to change.

11Defendant has and continues to induce infringement.1 Defendant has actively encouraged or instructed others (e.g., its customers and/or the customers of its related companies), and continues to do so, on how to use its products and services (e.g., for collaborative editing that allows multiple people to concurrently edit a single page) such as to cause infringement of one or more of claims 1-20 of the ’580 patent, literally or under the doctrine of equivalents. Moreover, Defendant has known of the ’580 patent and the technology underlying it from at least the filing date of the lawsuit.2 For clarity, direct infringement is previously alleged in this complaint.

12Defendant has and continues to contributorily infringe.3 Defendant has actively encouraged or instructed others (e.g., its customers and/or the customers of its related companies), and continues to do so, on how to use its products and services (e.g., https://www.egnyte.com/file- server/cloud-based-server) such as to cause infringement of one or more of claims 1-20 of the ’580 patent, literally or under the doctrine of equivalents. Moreover, Defendant has known of the ’580 patent and the technology underlying it from at least the filing date of the lawsuit.4 For clarity, direct infringement is previously alleged in this complaint. The only reasonable use for the infringing products and services is an infringing use, and there is no evidence to the contrary. The product and service is not a staple commercial product and Defendant had reason to believe that the customer’s use of the product and/or service would be an infringing use. As shown on Defendant’s websites, such as https://www.egnyte.com/file-server/cloud-based-server. Defendant offers the products and/or service with instruction or advertisement that suggests an infringing use.

13Defendant has caused Plaintiff damage by direct infringement of the claims of the ’580 patent. 1 Only sought through March 25, 2026. 2 Plaintiff reserves the right to amend if discovery reveals an earlier date of knowledge. 3 Only sought through March 25, 2026. 4 Plaintiff reserves the right to amend if discovery reveals an earlier date of knowledge.

IV.

CONDITIONS PRECEDENT

14Plaintiff has never sold a product. Upon information and belief, Plaintiff predecessor-in- interest has never sold a product. Plaintiff is a non-practicing entity, with no products to mark. Plaintiff has pled all statutory requirements to obtain pre-suit damages. Further, all conditions precedent to recovery are met. Under the rule of reason analysis, Plaintiff has taken reasonable steps to ensure marking by any licensee producing a patented article.

15Plaintiff and its predecessors-in-interest have entered settlement licenses with several defendant entities, but none of the settlement licenses were to produce a patented article, for or under the Plaintiff’s patents. Duties of confidentiality prevent disclosure of settlement licenses and their terms in this pleading but discovery will show that Plaintiff and its predecessors-in-interest have substantially complied with Section 287(a). Furthermore, each of the defendant entities in the settlement licenses did not agree that they were infringing any of Plaintiff’s patents, including the Patent-in-Suit, and thus were not entering into the settlement license to produce a patented article for Plaintiff or under its patents. Further, to the extent necessary, Plaintiff will limit its claims of infringement to method claims and thereby remove any requirement for marking.

16To the extent Defendant identifies an alleged unmarked product produced for Plaintiff or under Plaintiff’s patents, Plaintiff will develop evidence in discovery to either show that the alleged unmarked product does not practice the Patent-in-suit and that Plaintiff has substantially complied with the marking statute. Defendant has failed to identify any alleged patented article for which Section 287(a) would apply. Further, Defendant has failed to allege any defendant entity produce a patented article.

17The policy of § 287 serves three related purposes: (1) helping to avoid innocent infringement; (2) encouraging patentees to give public notice that the article is patented; and (3)

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Public U.S. federal court record (district court docket 73106235, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.