products and services; and/or induces others to make and use its products and services in aninfringing manner; and/or contributes to the making and use of infringing products and servicesby others, including their customers, who directly infringe the Patents.4.
Plaintiff Norman seeks injunctive relief to prevent Defendant from continuinginfringement of Plaintiff’s valuable patent rights. Plaintiff Norman further seeks monetarydamages and prejudgment interest for Defendant’s past infringement of the Patents.5.
This is an exceptional case, and Norman is entitled to damages, enhanceddamages, attorneys’ fees, costs, and expenses.
II. THE PARTIES
Plaintiff Norman is a corporation organized and existing under the laws of theState of Texas, with its principal place of business located at 100 E. Ferguson, Suite 816, Tyler, Texas 75702.7.
Upon information and belief, Defendant Volvo Cars of North America, LLC is aDelaware corporation with its principal place of business located at 1 Volvo Dr., Rockleigh, New Jersey, 07647. Upon information and belief, Volvo Cars of North America, LLC is authorized todo business in Texas and has appointed CT Corporation System, 350 N. St. Paul Street, Suite2900, Dallas, Texas 75201 as its agent for service of process.
III. JURISDICTION AND VENUE
This is an action for patent infringement which arises under the Patent Laws of the United States, in particular, 35 U.S.C. §§271, 281, 283, 284, and 285. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. §§1331 and 1338(a).9.
This Court has personal jurisdiction over Defendant, and venue is proper in thisCourt pursuant to 28 U.S.C. §§1391(b), (c), and 1400.