3within this judicial district. The exercise of jurisdiction over each Defendant would not offendtraditional notions of fair play and substantial justice.
Defendants do business in this district, including providing fibrin sealant patches,which are used, offered for sale, sold, imported into and have been purchased in Texas, includingin this judicial district. Venue is proper in this district pursuant to 28 U.S.C. §§ 1331, 1338(a),1391(b), (c) and (d) and 1400(b).
INFRINGEMENT OF U.S. PATENT NO. 7,189,410
On March 13, 2007, United States Letters Patent No. 7,189,410
patent”) for “Supplemented and Unsupplemented
Tissue Sealants, Methods of Their Productionand Use
” was duly and legally issued to
William N. Drohan, Martin J. MacPhee, Wilson H.Burgess, Hernan Nunez, Manish Singh, Gene Liau and Thomas Maciag. All rights and interest
in the ‘
410 patent have been assigned to Plaintiff ARC and, for the field of unsupplementedfibrin patches, exclusively licensed to Plaintiff STB.
A true and correct copy of the ‘
410 patentis attached hereto as Exhibit A.
Upon information and belief, Defendants have infringed and continue to infringethe
patent. The infringing acts include at least the manufacture, sale, offer for sale and/or importation of unsupplemented fibrin sealant patches (including, for example and withoutlimitation,
), and/or inducing and contributing to the manufacture, use, sale, offer for sale and/or importation of unsupplemented fibrin sealant patches (including, for example and
without limitation, EVARREST™
), that are covered by
one or more claims of the ‘410 patent
.Defendants are liable for infringement of the
patent pursuant to 35 U.S.C. § 271