Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
STB, Ltd. d/b/a STB Lifesaving Technologies et. al. v. Johnson & Johnson et. al.

STB, Ltd. d/b/a STB Lifesaving Technologies et. al. v. Johnson & Johnson et. al.

Ratings: (0)|Views: 141|Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00277: STB, Ltd. d/b/a STB Lifesaving Technologies, Inc. et. al. v. Johnson & Johnson et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l82U for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00277: STB, Ltd. d/b/a STB Lifesaving Technologies, Inc. et. al. v. Johnson & Johnson et. al. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l82U for more info.

More info:

Published by: PriorSmart on Apr 17, 2013
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

04/17/2013

pdf

text

original

 
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISIONSTB, LTD. AND THE AMERICANNATIONAL RED CROSS,Plaintiffs,v.JOHNSON & JOHNSON, ETHICON, INC.,OMRIX BIOPHARMACEUTICALS, LTD.AND OMRIX BIOPHARMACEUTICALS, INC. Defendants.§§§§§§§§§§§Civil Action No. 2:13-cv-277JURY TRIAL DEMANDEDCOMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs STB, Ltd. d/b/a STB Lifesaving Technologies, Inc.
(“
STB
”)
and the American
 National Red Cross (“ARC”)
for their Complaint against Defendants Johnson & Johnson,Ethicon, Inc., Omrix Biopharmaceuticals, Ltd. and Omrix Biopharmaceuticals, Inc. (collectively
Defendants
”), hereby allege
as follows:
THE PARTIES
1.
 
Plaintiff STB is a corporation duly organized and existing under the laws of thestate of Washington with a principal place of business at 13212 NE 16
th
Street, Suite 312,Bellevue, Washington 98005.
2.
 
Plaintiff ARC is a nonprofit, charitable corporation chartered by an act of theUnited States Congress of January 5, 1905, as amended, and codified at 36 U.S.C. § 300101
et  seq.
, also known as the American Red Cross, with an office located at 15601 Crabbs BranchWay, Rockville, Maryland 20855.
 
2
3.
 
Upon information and belief, Defendant Johnson & Johnson is a corporation dulyorganized and existing under the laws of the state of New Jersey with a principal place of  business at One Johnson & Johnson Plaza, New Brunswick, NJ 08933.
4.
 
Upon information and belief, Defendant Ethicon, Inc. is a corporation dulyorganized and existing under the laws of the state of New Jersey with a principal place of  business at Route 22 West, Somerville, NJ 08876.
5.
 
Upon information and belief, Defendant Omrix Biopharmaceuticals, Ltd. is acorporation duly organized and existing under the laws of Israel with a principal place of  business at 14 Einstein Street, Weizmann Science Park, P.O. Box 619, Rehovot, 76106 Israel.
6.
 
Upon information and belief, Defendant Omrix Biopharmaceuticals, Inc. is acorporation duly organized and existing under the laws of the state of Delaware with a principal place of business at Route 22 West, Somerville, NJ 08876.
JURISDICTION
7.
 
This Court has jurisdiction over the subject matter of this action pursuant to 28U.S.C. §§ 1331 and 1338(a) because this action arises under the patent laws of the United States,including 35 U.S.C. § 271
et seq
.
8.
 
This Court has personal jurisdiction over each Defendant in that each Defendanthas made, sold, offered for sale and/or imported, and/or aided and abetted others in making,selling and/or offering for sale, fibrin sealant patches for hemostasis (including, for example andwithout limitation, EVARR 
EST™
), which are used, offered for sale, sold, imported into andhave been purchased in Texas, including in this judicial district. This Court also has personal jurisdiction over each Defendant in that each Defendant has established sufficient minimumcontacts with this judicial district as a result of business conducted within the State of Texas and
 
3within this judicial district. The exercise of jurisdiction over each Defendant would not offendtraditional notions of fair play and substantial justice.
VENUE
9.
 
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
10.
 
On March 13, 2007, United States Letters Patent No. 7,189,410
(“the ‘
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.
11.
 
Upon information and belief, Defendants have infringed and continue to infringethe
‘410
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,
EVARREST™
), 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
‘410
patent pursuant to 35 U.S.C. § 271
et seq
.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->