3Sugimoto, Koshiro Yamaguchi, Takashi Horiuchi, and Yutaka Sugiyama as inventors. A truecopy of the ‘542 patent is attached hereto as Exhibit 3.
CW Media Pro’s Infringing Activities
9. On information and belief, CW Media Pro is engaged in the business of offeringto sell and selling compatible label cartridges for use in Brother P-Touch labeling machines,which compatible label cartridges are covered by one or more claims of each of the ‘796 patent,the ‘539 patent, and the ‘542 patent.
First Cause of Action: Infringement of U.S. Patent No. 6,116,796
10. Each and every allegation of paragraphs 1 through 9 of this Complaint areincorporated by reference, as though set forth here in their entirety.11. CW Media Pro has and continues to directly infringe one or more claims of the‘796 patent, in violation of 35 USC §271(a), by selling and/or offering to sell ‘796 AccusedLabel Cartridges, including, without limitation, models with the following designations: PT-S121, PT-S131, PT-S211, PT-S221, PT-S231, TZ-125, TZ-135, TZ-212, Pro tape for Brother TZe221 3/8” 9mm P-touch black on white label TZ221 TZe-221, Pro tape for Brother TZe2311/2” 12mm P-touch black on white label TZ231 TZe-231, Pro tape for Brother TZe315 1/4”6mm P-touch white on black label TZ315 TZe-315, Pro tape for Brother TZe325 3/8” 9mm P-touch white on black label TZ325 TZe-325, Pro tape for Brother TZe335 1/2” 12mm P-touchwhite on black label TZ335 TZe-335, Pro tape for Brother TZe631 1/2” 12mm P-touch black onyellow label TZ631 TZe-631, PT tape for Brother TZe111 1/4" 6mm P-touch black on clear label TZ111 TZe-111, PT tape for Brother TZe115 1/4" 6mm P-touch white on clear labelTZ115 TZe-115, PT tape for Brother TZe121 3/8" 9mm P-touch black on clear label TZ121TZe-121, PT tape for Brother TZe125 3/8" 9mm P-touch white on clear label TZ125 TZe-125,