1234567 891011121314151617 18192021222324
Pro Performance Sports, LLC alleges:
JURISDICTION AND VENUE
1. This is an action for patent infringement under Title 35 of theUnited States Code. The Court has federal-question jurisdiction under 28U.S.C § 1331, and exclusive original jurisdiction under 28 U.S.C. §1338(a).2. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and1400 (a).
3. Pro Performance is a limited-liability corporation organizedand existing under the laws of the State of California with its principalplace of business in Carlsbad, California. Pro Performance is a leadingprovider of sports training aids and sports-related products.4. Pro Performance is informed and believes and thereon allegesthat Defendant Russell Brands LLC is a Delaware entity with its principalplace of business in Kentucky. Pro Performance is further informed and believes and thereon alleges that Defendant Spalding Holdings LLC is a Kentucky limited-liability company with its principal place of business inKentucky. Russell and Spalding are collectively referred to as “Russell.”
FIRST CLAIM FOR RELIEF
Infringement of U.S. Patent No. 8,371,965
5. Pro Performance incorporates paragraphs 1 through 4, above.6. U.S. Patent No. 8,371,965 (the “’965 patent”), entitledMiniature Door-Mounted Basketball Hoop, issued on February 12, 2013.