Unified Messaging Solutions, LLC v. Groupon, Inc.
Filing
1
COMPLAINT against Groupon, Inc. filed by Unified Messaging Solutions, LLC; Jury Demand. Filing fee $ 350, receipt number 0752-6896971. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Simon, Anthony)
CIVIL COVER SHEET
JS 44 (Rev. 09/11)
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet.
I. (a) PLAINTIFFS
DEFENDANTS
Unified Messaging Solutions, LLC
Groupon, Inc.
(b) County of Residence of First Listed Plaintiff Collin County, TX
County of Residence of First Listed Defendant
Cook Co., IL
NOTE: In land condemnation cases, use the location of the tract of land involved.
(EXCEPT IN U.S. PLAINTIFF CASES)
(c) Attorneys (Firm Name, Address, and Telephone Number)
Attorneys (If Known)
Anthony G. Simon, The Simon Law Firm, PC, 800 Market St., Suite 1700, St.
Louis, MO 63101 - 314-241-2929
II. BASIS OF JURISDICTION
1
U.S. Government
Plaintiff
2
U.S. Government
Defendant
s
(Place an “X” in One Box Only)
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)
(For Diversity Cases Only)
PTF
Citizen of This State
1
3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of Parties in Item III)
Citizen of Another State
CONTRACT
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excl. Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
V. ORIGIN
s
1 Original
Proceeding
(Place an “X” in One Box Only)
TORTS
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers’
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Med. Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
3
2
Incorporated and Principal Place
of Business In Another State
5
5
3
Foreign Nation
6
6
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
510 Motions to Vacate
Sentence
Habeas Corpus:
530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
Remanded from
Appellate Court
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
s
LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt. Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc.
Security Act
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRS—Third Party
26 USC 7609
OTHER STATUTES
375 False Claims Act
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
IMMIGRATION
462 Naturalization Application
463 Habeas Corpus Alien Detainee
(Prisoner Petition)
465 Other Immigration
Actions
4 Reinstated or
Reopened
VI. CAUSE OF ACTION (Enter U.S. Civil Statute under which you are filing and
write a brief statement of cause.)
BANKRUPTCY
625 Drug Related Seizure
of Property 21 USC 881
690 Other
(Place an “X” in One Box Only)
2 Removed from
State Court
2
3
s
Citizen or Subject of a
Foreign Country
IV. NATURE OF SUIT
and One Box for Defendant)
PTF
DEF
s 4
Incorporated or Principal Place
4
of Business In This State
DEF
1
Transferred from
5 another district
(specify)
6 Multidistrict
Litigation
VII. PREVIOUS BANKRUPTCY MATTERS (For nature of suit 422 and
423, enter the case number and judge for any associated bankruptcy matter previously
adjudicated by a judge of this Court. Use a separate attachment if necessary.)
35 U.S.C. §§ 271-Patent Infringement
VIII. REQUESTED IN
COMPLAINT:
IX. This case (check one box)
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
s
DEMAND $
CHECK YES only if demanded in complaint:
s Yes
No
JURY DEMAND:
is not a refiling of a previously dismissed action
is a refiling of case number ______________ previously dismissed by Judge ___________________
Date
Signature of Attorney of Record
March 1, 2012
s/ Anthony G. Simon
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