Complaint Filed by Combined Public Communications, LLC and Prodigy Solutions Inc. Against Grissom Commissary Supply, Inc. and Joint Accounts, LLC. Filing Fee $405, Receipt Number AKYWDC-4481147. (Attachments: # 1 Exhibit a - U.S. Patent, # 2 Exhibit B - Claim Chart, # 3 Cover Sheet, # 4 Summons Tendered, # 5 Summons Tendered)
1This is an action for patent infringement arising under the patent laws of the United
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Defendants for, inter alia, making, using, offering to sell, selling, and/or importing products,
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2Plaintiff CPC is a Delaware limited liability company with its principal place of business at 100 Aqua Drive, Cold Spring, Kentucky 41076.
3Plaintiff Prodigy is a Delaware corporation with its principal place of business at 6000 Midlantic Drive, Suite 415N, Mount Laurel, New Jersey 08054.
4Upon information and belief, Defendant Care A Cell is a Kentucky corporation with its principal office address at 1613 Moscow Avenue, Hickman, Kentucky, 42050.
5Upon information and belief, Defendant JointAccounts is a Tennessee limited liability company that is registered to do business in Kentucky, with its principal office address at 209 N Lindell Street, Martin, Tennessee, 38237.
6This court has original jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
7Upon information and belief, Defendant Care A Cell uses at least the following publicly available website to transact business: https://careacell.jointaccounts.com, which is linked with and is a subdomain of Defendant JointAccounts’ website, https://jointaccounts.com. Care A Cell’s website states that it is “powered by JointAccounts” and directs users to call “JointAccounts automated phone line.” With respect to the communications system and/or services that are the subject of this Complaint, Care A Cell’s website also identifies JointAccounts (“JointAccounts is here to make sure distance doesn’t keep you apart from your loved ones. Our dedicated communication services for correctional institutions ensure that you can always share moments, big or small, with family and friends.”).
8Upon information and belief, Defendant Care A Cell is an agent and/or alter ego of Defendant JointAccounts, which acts in concert with JointAccounts and at its direction to provide commissary services, including inmate care packages and/or communications services, to at least the detention centers located in the following counties in Kentucky: Webster County, Fulton County, Hopkins County, and Taylor County. Upon information and belief, JointAccounts has the right and ability to direct or control Care A Cell’s actions, and Care A Cell is authorized to act on behalf of JointAccounts to provide services in Kentucky.
9Upon information and belief, the president of Defendant Care A Cell is Michael Lynn Grissom. Upon information and belief, Michael Lynn Grissom resides at the same address as the registered address of Defendant Care A Cell, 1613 Moscow Avenue, Hickman, Kentucky, 42050. Upon information and belief, Michael Lynn Grissom is also a member of JointAccounts, LLC. Upon information and belief, Defendant JointAccounts resides in the states of its members, including Kentucky.
10This Court has personal jurisdiction over Defendant Care A Cell at least because Care A Cell is incorporated and registered to do business in Kentucky and has its principal office in this District. Furthermore, this Court has personal jurisdiction over Care A Cell because, among other things, Care A Cell has transacted business, contracted to supply services or goods, has caused and continues to cause tortious injury, and has committed and continues to commit acts of patent infringement in Kentucky, including in this District.
11This Court has personal jurisdiction over Defendant JointAccounts at least because, on information and belief, JointAccounts resides in, has registered to do business, has transacted business, has contracted to supply services or goods, has caused and continues to cause tortious injury, and has committed and continues to commit acts of patent infringement in Kentucky, including in this District. JointAccounts has thereby engaged in continuous, systematic, and substantial activities within the Commonwealth of Kentucky and has thereby established at least minimum contacts with the Commonwealth of Kentucky. Pursuant to KRS 454.210(2), this Court may exercise personal jurisdiction over JointAccounts consistent with the Constitution of Kentucky and the Constitution of the United States.
12Venue is proper in this District under 28 U.S.C. § 1400(b) at least because, among other things, on information and belief, each Defendant resides in this District, each Defendant is subject to personal jurisdiction in this District, each Defendant or its agent has a regular and established place of business in this District, each Defendant has caused and continues to cause tortious injury, and each Defendant has committed and continues to commit acts of patent infringement in this District.
STATEMENT OF FACTS Plaintiffs
13Plaintiff CPC is a leader in connecting friends, families, and others to individuals incarcerated in several jails, prisons, and detention centers around the country. Among other services, CPC provides communication services that allow inmates (or “residents”) to communicate with outside parties in a convenient, efficient, and secure manner, including CPC’s proprietary “Chirping” service that enables real-time text messaging between inmates and their loved ones.
14In July 2023, CPC entered into a license agreement with Prodigy, wherein CPC
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least via its Chirping service.
15Plaintiff Prodigy is the U.S. corrections industry’s only single-source provider of inmate communications and commissary technology. Among other services, CPC provides Secure Two-Way Communication technology, including associated software and devices, comprising an integrated platform that manages essential secure facility communications technology and data,
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16CPC and Prodigy each contract with governmental entities responsible for operating correctional facilities in the U.S. to provide telecommunications services to inmates. In accordance with such contracts, Plaintiffs provide and/or install respective software, hardware, devices, and/or other equipment that enable inmates to engage in secure communications with outside parties. The governmental entities and Plaintiffs, respectively, typically receive a percentage of revenues collected based on fees charged for inmate communications with outside parties enabled by Plaintiffs’ respective services. CPC, for example, entered into an agreement with the Webster County Detention Center to be the exclusive provider of, among other things, all inmate communications and communication devices, including but not limited to phone calls and messaging communications.
17Inmate communications from U.S. correctional facilities to outside parties may be performed in conjunction with one or more of tablets, kiosks, wall-mounted devices, or other telecommunications devices that are accessible to inmates for securely communicating with
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Public U.S. federal court record (district court docket 73114369, document 1). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.