ING Bank filed an action for declaratory judgment against LBS Innovations [NPE], seeking declaration that its website does not infringe a patent related to providing location-based offers to mobile devices.  ING Bank had previously filed this same action for declaratory judgment in Delaware on June 6, but voluntarily dismissed that case and re-filed in New Jersey.  LBS has filed four prior suits since March 2011 against over 30 defendants including 7-Eleven, Barnes & Noble, BP, Chick-fil-a, Choice Hotels, Citgo Petroleum, CompUSA, Conn’s, ConocoPhillips, Costco, Dave & Buster’s, GameStop, Hyatt, Keycorp, Marriott, McDonald’s, Merrill Lynch, and Sally Beauty Supply.  Microsoft previously filed an action for declaratory judgment against LBS in February 2012.  Dennis Hollenberg is the named inventor on the patent-in-suit, which was assigned to LBS in November 2010.  LBS Innovations is one of 14 portfolios controlled by Empire IP, a patent monetization entity managed by Daniel Mitry and Timothy Salmon.  Other notable Empire IP licensing programs include Cuozzo Speed Technologies, PanoMap, PotterVoice, Rotatable Technologies, and Secor View Technologies.  6/21, District of New Jersey, assigned to Judge Claire C. Cecchi and referred to Magistrate Judge Joseph A. Dickson, 2:2012cv03809.