Upon information and belief, Defendant Land O’Frost, Inc. is a corporationorganized and existing under the laws of the State of Illinois, having its principal place of business in Lansing, Illinois.
JURISDICTION AND VENUE
This civil action for patent infringement arises under the patent laws of the UnitedStates, Title 35 of the United States Code.6.
This Court has jurisdiction over the subject matter of this action pursuant toTitle 28 of the United States Code, Sections 1331 and 1338(a).7.
Land O’Frost is subject to personal jurisdiction in this Court because it doesbusiness in Wisconsin, including but not limited to, systematic and not isolated offering andproviding of goods and services in this judicial district.8.
Venue is proper in this district under Title 28 of the United States Code, Sections1391(b) and 1400(b).
COUNT I: INFRINGEMENT OF U.S. PATENT NO. 7,172,779
Kraft incorporates the foregoing Paragraphs 1 through 8 as though fully set forthherein.10.
Plaintiff Kraft Foods Group Brands LLC is the owner by assignment of all right,title, and interest in the ’779 patent, entitled “Container For Sliced And Fluffed Food Products,”which was duly and properly issued by the United States Patent & Trademark Office onFebruary 6, 2007. A true and correct copy of the ’779 patent is attached as Exhibit A.11.
Plaintiff Kraft Foods Group, Inc. is a licensee of the ’779 patent and makes andsells sliced food products in a package embodying the patented invention throughout the UnitedStates.