PLAINTIFF’S ORIGINAL COMPLAINT Page 2
JURISDICTION AND VENUE
3. This is an action for patent infringement arising under the patent laws of the United States, Title 35, United States Code. This Court has exclusive subject matter jurisdiction over this case for patent infringement under 28 U.S.C. § 1338(a).4. This Court has personal jurisdiction over the Defendant Catalyst.Catalyst conducts business within the State of Texas and within the Eastern District of Texas. Catalyst, directly or through intermediaries (including distributors, retailers, andothers) ships, distributes, offers for sale, sells, and advertises its products in the UnitedStates, the State of Texas, and the Eastern District of Texas. Catalyst has purposefullyand voluntarily placed infringing products in the stream of commerce with theexpectation that its products will be purchased by end users in the Eastern District of Texas. For example, Catalyst maintains an interactive internet web site with the domainname, www.catalystsecure.com. Catalyst has committed the tort of patent infringementwithin the State of Texas and this District.5. Venue is proper in the Eastern District of Texas under 28 U.S.C.§§ 1391(b) and 1400. Venue is also proper in the Eastern District of Texas since similarfactual and legal issues are currently pending before the Eastern District of Texas
andPlaintiff wishes to prevent overlapping issues being simultaneously adjudicated in differentdistricts.
See In re Vistaprint Ltd.
, 628 F.3d 1342, 1345 (Fed. Cir. 2010);
InternetMachines LLC v. Alienware Corp
., 2011 WL 2292961 (E.D. Tex. June 7, 2011).
U.S. PATENT NO. 6,918,082
6. On or about December 17, 1998, Jeffrey M. Gross and Matthew H. Parkerfiled patent application number 09/215,593. This application issued as United StatesPatent No. 6,918,082 (“the ‘082 Patent”), Ex. A, entitled “Electronic Document Proofing
Case 6:12-cv-00164-LED Document 1 Filed 03/19/12 Page 2 of 6 PageID #: 2