or claims of the '841 Patent are performed by Thanks Again directly, through the operation of Thanks Again’s rewards program.
Thanks Again’s infringement will continue unless enjoined by this Court.11.
Thanks Again has caused Rewards Network to suffer, and unless enjoined by thisCourt, will cause Rewards Network to continue to suffer substantial injury, including lost profits,for which Rewards Network is entitled to damages adequate to compensate it for Thanks Again’sinfringement.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Rewards Network respectfully requests judgment and relief against Thanks Again as follows:A.
A judgment that Thanks Again has infringed the '841 Patent;B.
An injunction against Thanks Again, its subsidiaries, affiliates, parents,successors, assignees, officers, agents, servants, employees, and all persons acting in concert or in participation with them, or any of them, permanently enjoining each of them from infringing,contributing to, or inducing the infringement of the '841 Patent;C.
Awarding Rewards Network damages adequate to compensate for ThanksAgain’s infringement of the '841 Patent, but in no event less than a reasonable royalty on ThanksAgain’s use of Rewards Network’s invention;D.
Awarding pre-judgment interest on any damages award;E.
Increasing Thanks Again's liability for damages up to three times the amountfound or assessed, in the event that Thanks Again's infringement of the '841 Patent is adjudged to be willful;
Case: 1:13-cv-03107 Document #: 1 Filed: 04/25/13 Page 3 of 4 PageID #:3