Venue is proper in this district, pursuant to 28 U.S.C. § 1391(b) and (c), becauseDefendant is subject to personal jurisdiction in the District, and because a substantial part of theevents giving rise to this claim for declaratory relief and the subject matter thereof occurred withinthe District, including, without limitation, that Plaintiff received a patent infringement demand letterfrom Defendant in this District, and that Plaintiff’s principal place of business is located in thisDistrict.
Plaintiff is a Florida corporation having its principal place of business at 4761 AnchorAvenue, Port Salerno, Florida 34992. Plaintiff is an industry-leading manufacturer of a wide varietyof sportfishing equipment and accessories.6.
Defendant is a Missouri corporation having its principal place of business at 4262 DHighway, Bolivar, Missouri 65613. Defendant is the owner of the Patent-in-Suit and, uponinformation and belief, is the manufacturer of an outrigger pulley product sold under the brand “Hal-Lock”.
Defendant is the owner by assignment of U.S. Patent No. 6,129,033, entitled “Pulleyor Roller-Type Block with Lock Arrangement” and issued on October 10, 2000 (“the ‘033 Patent”).A copy of the ‘033 Patent is attached as Exhibit “A” hereto.8.
On April 8, 2013 Defendant sent a letter to Plaintiff, accusing Defendant of “making,having, made, using, selling and/or offering for sale halyard line locks that infringe [the ‘033Patent].” The letter also claims that any and all use or re-sale by purchasers of Plaintiff’s product