INFRINGEMENT OF THE ’
NPT incorporates paragraphs 1 through 9 by reference as if fully stated herein.11.
617 patent is valid and enforceable.12.
Ford has directly infringed, and continues to directly infringe, one or more claims
of the ’
617 patent under 35 U.S.C. § 271(a), either literally and/or under the doctrine of equivalents, by making, using, selling, offering for sale, and/or importing products and/ormethods encompassed by those claims.13.
d parties, including Ford’s affiliates, dealers, and
customers, have infringed,and continue to infringe
, one or more claims of the ’617
patent under 35 U.S.C. § 271(a), eitherliterally and/or under the doctrine of equivalents, by using, selling, and/or offering for sale in theUnited States, and/or importing into the United States, products supplied by Defendants.14.
Upon information and belief, based on the information presently available toNPT, absent discovery, and in the alternative to direct infringement, NPT contends that Ford hasinduced infringement, and continues to induce infringement, o
f one or more claims of the ’617
patent under 35 U.S.C. § 271(b). Ford has actively, knowingly, and intentionally induced, and
continues to actively, knowingly, and intentionally induce, infringement of the ’
617 patent bymaking, using, importing, and selling or otherwise supplying products to third parties, includingat a minimum its affiliates, dealers, and customers, with the knowledge and intent that such thirdparties will use, sell, offer for sale, and/or import, products supplied by Ford
to infringe the ’
617patent; and with the knowledge and intent to encourage and facilitate the infringement throughthe dissemination of the products and/or the creation and dissemination of promotional andmarketing materials, supporting materials, instructions, product manuals, and/or technicalinformation related to such products.
Case 6:12-cv-00832 Document 1 Filed 10/31/12 Page 3 of 7 PageID #: 3