IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK ARROW ELECTRONICS, INC., and TRANSIM TECHNOLOGY CORP; Plaintiffs, Civil Case No. -against- JURY TRIAL DEMANDED ISCHEMATICS.com LLC SP, 7 Defendant, TT, J, COMPLAINT Arrow Electroni , Inc, and Transim Technology Corp. (collectively "Plaintiffs"), for its Complaint against iSchematics.com LLC ("Defendant"), hereby alleges as follows: NATURE OF THE ACTION 1 This is a civil action for the infringement of United States Patent No. 6,530,065 ("the '065 Patent") under the Patent Laws of the United States, 35 U.S.C. §1 et seq. This action relates to Defendant's systems, apparatuses, computer readable media, and methods used to make, use, sell, offer for sale, and/or export computer-based programs that simulate elegtrical circuits that infringe one or more claims of the '065 Patent. PLAINTIFFS 2. Amow Electronics, Ine. ("Arrow") is a New York limited liability company having a corporate office located within this judicial district at 70 Maxess Road, Melville, NY 11747 and a components office located within this judicial district at 3001 Expressway Drive North, Suite 100, Islandia, NY 11749.3. Transim Technology Corp. ("‘Transim") is a wholly-owned subsidiary of Arrow Electronics, Inc. and is a leader in developing and hosting innovative cloud-based design centers for online design support and engineering solutions. 4, Transim has undertaken substantial efforts to protect its proprietary rights by obtaining protection in the U.S. Patent & Trademarks Office for its web-based circuit simulator. As evidence of its innovative and inventive efforts, on March 14, 2000, Transim filed U.S. Provisional Application No. 60/189,627, entitled "Client Server Circuit Simulator" and, on March 14, 2001, filed U.S. Non-Provisional Application No. 09/811,371 ("the §'371 Application”), entitled "Client-Server Simulator, Such As An Electrical Circuit Simulator Provided By A Web Server Over The Internet.” 5 Transim operates an online electrical circuit simulator accessible over the internet in this judicial district under the trade name WEBSIM® at www transim.com, Transim provides online electrical circuit simulation solutions covered by the ‘065 Patent to many leading semiconductor manufacturers and distributors, including Arrow. All of these licensed solutions are accessible over the internet in this judicial district. Transim and its WEBSIM product are an important part of Arrow"s eCommerce business, DEFENDANT. 7. Upon information and belief, iSchematics.com LLC is a Minnesota limited li lity company having a principal place of business at 801 University Avenue SE #21, Minneapolis, Minnesota 55414,JURISDICTION AND VENUE 8. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338(a) because this action arises under the Patent Laws of the United States, 35 U.S.C. § 271 et seq 9. This Court has personal jurisdiction over Defendant at least under N.Y.C.P.LR. 302(a) because Defendant has sufficient minimum contacts with the forum as a result of business conducted within the State of New York and within the Eastern District of New York. Personal jurisdiction also exists specifically over Defendant because, it makes, uses, offers for sale, sells, imports, advertises, makes available and/or markets one or more products and/or services within the State of New York, and more particularly, within the Eastern District of New York, and have purposely availed themselves of the privileges and benefits of the laws of the State of New York. 10. Upon information and belief, Defendant, directly and/or through authorized intermediaries, ships, distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web page) its products and services in the United States and the State of New York. 11. Upon information and belief, Defendant has committed patent infringement in the State of New York. Defendant solicits customers in the State of New York, Defendant has paying customers who are residents of the State of New York and who each use Defendant's products and services in the State of New York. 12. Venue is proper in this judicial district as to Defendant pursuant to 28 U.S.C. §§ 1391 and 1400(b), because Defendant has committed acts of infringement in the Eastern District of New York and has transacted business in the Eastern District of New York.