This Court has personal jurisdiction over Defendant at least because Defendanthas ongoing and systematic contacts with this District, including being incorporated in this stateand operating businesses in this state that, on information and belief, infringe the patents-in-suit.6.
Venue is proper in this District under 28 U.S.C. §§ 1400(b) and 1391.
COUNT IINFRINGEMENT OF U.S. PATENT NOS. 6,384,736 and 7,369,058
Plaintiff repeats and realleges the allegations of paragraphs 1 through 6 as thoughfully set forth herein.8.
On May 7, 2002, United States Patent No. 6,384,736 ("the '736 Patent"), entitled"REMOTE CONTROL ELECTRONIC DISPLAY SYSTEM," was duly and legally issued bythe United States Patent and Trademark Office. A true and correct copy of the '736 Patent isattached as Exhibit A to this Complaint.9.
On May 6, 2008, United States Patent No. 7,369,058 ("the '058 Patent," or,collectively with the '736 Patent, the "Activision Patents"), entitled "REMOTE CONTROLELECTRONIC DISPLAY SYSTEM," was duly and legally issued by the United States Patentand Trademark Office. A true and correct copy of the '058 Patent is attached as Exhibit B to thisComplaint.10.
Plaintiff, as the assignee and owner of all right, title, and interest in and to theActivision Patents, has the right to assert causes of action arising under the Activision Patentsand the right to any remedies for infringement thereof.11.
Defendant is and has been directly and indirectly infringing one or more claims of the Activision Patents in the United States by selling, offering for sale, and using digital displaysystems, including but not limited to the "SoloHealth Station," and by performing methods thatinfringe one or more claims of the Activision Patents, in violation of 35 U.S.C. § 271.