IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION VirtualOne, LLC A Florida

corporation, Plaintiff, v. William M. Ringbom d.b.a. PhytoTrak Development Company An individual, Defendant. Jury trial demanded. Injunctive Relief Demanded. Case No. ___________________________

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, VirtualOne, LLC., brings this action for patent infringement against Defendant William M. Ringborn, d.b.a PhytoTrak Development Company, and alleges: THE PARTIES 1. Plaintiff VirtualOne is a limited liability company organized under the laws of the State

of Florida and has its principal place of business in Plant City, Florida. 2. On information and belief, Defendant William M. Ringbom is an individual residing in

Arroyo Grande, CA, d.b.a. the PhytoTrak Development Company. JURISDICTION AND VENUE 3. This is an action for direct patent infringement arising under the provisions of the

Patent Laws of the United States of America, Title 35, United States Code.

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Subject-matter jurisdiction over Plaintiffs claims is conferred upon this Court by 28

U.S.C. 1331 and 1338(a). 5. On information and belief, Defendant has offered to sell an infringing article, solicited

business in the State of Florida, transacted business within the State of Florida, and attempted to derive financial benefit from residents of the state of Florida. 6. Defendant, directly or through his business, is subject to personal jurisdiction in this

judicial district, and/or is doing business in this judicial district in connection with the patent infringement alleged herein. 7. Venue is proper in this judicial district under 28 U.S.C. 1391(b) and/or 1400(b). CLAIMS FOR RELIEF CLAIM 1 Patent infringement of U.S. Patent No. 7,878,396 8. On February 1, 2011, U.S. Patent No. 7,878,396 (the 396 patent), entitled System

and Method for Tracking Origins of Produce, was duly and legally issued by the United States Patent and Trademark Office. Exhibit A. VirtualOne is the owner by assignment of all right, title, and interest in and to the 396 patent, including the right to sue for and recover all past, present, and future damages for infringement of the 396 patent. 9. Upon information and belief, Defendant, directly or through his business, has infringed

and continues to directly infringe the 396 patent by making, using, selling, and/or offering to sell, in the United States, Florida, and/or this judicial district, goods, systems, methods, and/or services that are covered by the one or more claims of the 396 patent. This includes, but is not limited to claims 1, 4, 5, 10, 13, 14, and 19. Defendant is liable for direct patent infringement of

the 396 patent pursuant to 35 U.S.C. 271. 10. Defendant advertises his infringing product through his website,

http://www.phytotrak.com/. Specifically, but not limited to, the Traceability Initiative Update present at: http://www.phytotrak.com/Documents/Traceability%20Initiative%20Update.doc. Exhibit B. 11. Defendants acts of direct patent infringement have caused damage to VirtualOne, and

VirtualOne is entitled to recover from Defendant the damages sustained by VirtualOne as a result of the wrongful acts of Defendant, in an amount subject to proof at trial. 12. As a consequence of the infringement complained of herein, VirtualOne has been

irreparably damaged to an extent not yet determined, and will continued to be irreparably damaged by such acts in the future unless Defendant is enjoined by this Court from committing further acts of infringement. WHEREFORE, Plaintiff demands judgment against Defendant as follows: A. B. Defendant has infringed the 396 patent; Defendant accounts for and pays to VirtualOne all damages caused by his infringement

of the 396 patent; C. Defendant pays to VirtualOne all attorney fees and costs caused by his infringement of

the 396 patent; D. VirtualOne be granted permanent injunctive relief pursuant to 35 U.S.C. 283

enjoining Defendant, his business, officers, agents, servants, employees, and those persons in active concert or participation with him, from further acts of patent infringement; E. VirtualOne be granted pre-judgment and post-judgment interest on the damages cause

to it by reason of Defendants patent infringement; and F. VirtualOne be granted such other and further relief as the Court may deem just and

proper under the circumstances. F. Plaintiff demands a trial by jury. s/ H. William Larson H. William Larson, Esq. Fla. Bar # 969930 bill@larsonpatentlaw.com Nathan P. Suedmeyer, Esq. Fla. Bar # 70787 nathan@larsonpatentlaw.com Justin P. Miller, Esq. Fla. Bar # 84495 justin@larsonpatentlaw.com Larson & Larson, P.A. 11199 69th Street Largo, FL 33773 (727)-546-0660 tele (727) 213-6922 fax Trial Counsel for Plaintiff