within this forum such that the exercise of jurisdiction over Expedia, Hotels.com LP,Hotels.com GP, and Hotwire would not offend the traditional notions of fair play andsubstantial justice.8.
For example, Expedia, Hotels.com, L.P., Hotels.com GP, and Hotwire havecommitted acts of infringement in this District, by offering combined flight, hotel, and/orcar travel booking services on its website that infringe claims of United States PatentNos. 8,239,451, 8,171,079, 8,073,904, 7,490,091, 7,421,468, and 7,277,918.9.
Joinder of the Defendants in this action is proper under 35 U.S.C. § 299.Upon information and belief, Defendant Expedia, as the parent company, is responsiblefor the operations of Defendant Hotwire, Defendant Hotels.com, L.P., and DefendantHotels.com GP. Metasearch Systems seeks relief against the Defendants jointly,severally, or in the alternative with respect to the same transactions, occurrences, or seriesof transactions or occurrences relating to the Defendants’ patent infringement. Inaddition, questions of fact common to all Defendants will arise in this action.10.
On information and belief, at least some of the IP addresses used byHotels.com’s metasearch engine trace back to IP addresses belonging to Expedia.11.
Expedia markets a network of sites, including Hotels.com and Hotwire, forconsolidated advertising. For example, Expedia states:“Get the word out—Expedia, Inc.’s network of sites, which includes Expedia.com,Hotels.com and Hotwire.com, has the largest global footprint of any online travelsite. Our travel lifestyle media platform provides you with unprecedented visibilityand connects you with active, in-market consumers, no matter where they are.”