1UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MASSACHUSETTSANGEL GUARD PRODUCTS, INC., )Plaintiff, ))v. ))SEWELL DEVELOPMENT CORP., )Defendant. )CIVIL ACTION NO.
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Angel Guard Products, Inc. (“Angel Guard”), through its attorneys, brings thisaction against Defendant Sewell Development Corp. (“Sewell”) as follows:
JURISDICTION AND VENUE
1. This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. §§ 271 et seq. This Court has subject matter jurisdiction under 28U.S.C. §§ 1331 and 1338(a).2. This Court has personal jurisdiction over Sewell because Sewell is committingacts of infringement in this District.3. Venue is proper in this District under 28 U.S.C. §§ 1391(b) and 1400(b).
4. Angel Guard is a corporation organized and existing under the laws of theCommonwealth of Massachusetts with a principal place of business in Worcester,Massachusetts.5. Upon information and belief, Sewell is a corporation organized and existing underthe laws of the State of Utah, having a principal place of business at 3877 N. 200 E, Provo, Utah84604.