transactions in the State of New York that it reasonably knew and/or expected that it could behaled into a New York court as a consequence of such activity.5.
Upon information and belief, Defendant makes, uses, and/or sells, and/or inducesothers to make and/or use infringing products within the Eastern District of New York; andDefendant has a continuing presence and has the requisite minimum contacts with the EasternDistrict of New York such that this venue is a fair and reasonable one. Upon information and belief, Defendant has transacted and, at the time of the filing of this Complaint, is continuing totransact business within the Eastern District of New York.6.
For these reasons, personal jurisdiction exists and venue is proper in this Courtunder 28 U.S.C. §§ 1391(b) and (c) and 28 U.S.C. § 1400(b).
On February 15, 2005, United States Patent No. 6,856,686 B2
(“the ’686 Patent”)was duly and legally issued for “Method
and Apparatus for Securing E-Mail Attachments.
” Atrue and correct copy of the ‘
686 Patent is attached hereto as Exhibit A and made a part hereof.8.
On February 15, 2005, United States Patent No. 6,856,687 B2
Patent”)was duly and legally issued for “
Portable Telecommunication Security Device
.” A true andcorrect copy of the ‘
687 Patent is attached hereto as Exhibit B and made a part hereof.9.
Patents are collectively referred to as the “Pate
Plaintiff is the owner of all right, title and interest in and to the Patents-in-Suit,with the exclusive right to enforce said Patents against infringers and the exclusive right tocollect damages for all relevant times, including the right to prosecute this action.11.
The Patents-in-Suit, generally speaking, relate to secure web-based peer-to-peer
communications. Specifically, the ’
686 Patent discloses a method of using microprocessor-based