Defendants have conducted and do conduct business within Puerto Rico, directlyor through intermediaries, resellers, agents, or offers for sale, sells, and/or advertises (includingthe use of interactive web pages with promotional material) products in Puerto Rico that infringethe Asserted Patents.10.
In addition to Defendants
continuously and systematically conducting business inPuerto Rico, the causes of action against Defendants are connected (but not limited) to
Defendant’s purposeful acts committed in P
uerto Rico, including Defendants
making, using,importing, offering for sale, or selling products which include features that fall within the scopeof at least one claim of each of the Asserted Patents.11.
At the time of the invention, all three inventors of the Asserted Patents wereresiding in Puerto Rico. Thus, the Asserted Patents grew out of invention and innovation thattook place in Puerto Rico.12.
Moreover, Canatelo is owned by a local Puerto Rico entrepreneur, who acquiredthe Asserted Patents as a way to further incentivize local innovation. Thus, the current owner of the Asserted Patents has availed itself of legal rights, duties and obligations within the district.13.
Venue lies in this District under 28 U.S.C. §§1391 and 1400(a) because, amongother reasons, Defendants are subject to personal jurisdiction in this District, and have committedand continue to commit acts of patent infringement in this District. For example, Defendantshave used, sold, offered for sale, and/or imported infringing products in this District.
Defendants are properly joined under 35 U.S.C. §299(a)(1) because a right torelief is asserted against the parties jointly, severally and in the alternative with respect to thesame transactions, occurrences, or series of transactions or occurrences relating to the making,