system allows touch screen control of a schedule log to arrange and edit a schedule of audio orvideo events for playback.4.
Pursuant to 35 U.S.C.
282, the ‘324 patent is presumed valid.5.
By assignment, Plaintiff is the owner of the ‘324 patent and at all relevant timeshas had the right to enforce the ‘324 patent.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, Title 35 of theUnited States Code, particularly §§ 271 and 281. This Court has jurisdiction over the claim forpatent infringement under 28 U.S.C. § 1338(a).7.
Venue is proper in this Court under 28 U.S.C. §§ 1391(b) and (c) and 1400(b).8.
Defendant, upon information and belief, transacts business in this district bymaking, using, selling or offering to sell methods and systems as described and claimed in the‘324 patent and/or conducting other business in this judicial district sufficient to render it subjectto jurisdiction in this district.
CLAIM FOR PATENT INFRINGEMENT
Upon information and belief, Defendant manufactures, makes, has made, markets,sells and/or uses products that infringe one or more claims in the ‘324 patent.10.
On information and belief, Defendant has directly infringed at least claim 1 of the‘324 patent and continues to infringe the ‘324 patent by its manufacture, use, sale, importationand/or offer for sale of its touch-screen controlled tablets that include a media player and theability to update a playlist of music, including but not limited to the ViewPad E72, ViewPadE100, ViewPad 10e, and ViewPad 10pi models of touchscreen tablets.