2 benefits of this District by conducting business in this jurisdiction, including by promoting products for sale via the internet, which are accessible to and accessed by residents of thisDistrict.5.
Venue is proper in this District pursuant to 28 U.S.C. §§1391(b)-(c) and §1400(b), because Defendant resides in this District and substantial acts of infringement have occurred inthis District.
COUNT ONEINFRINGEMENT OF U.S. PATENT NO. 5,331,637
On July 19, 1994, U.S. Patent No. 5,331,637 (the “’637 Patent”) entitled“Multicast Routing Using Core Based Trees” was duly and legally issued by the United StatesPatent and Trademark Office. A true and correct copy of the ’637 Patent is attached as Exhibit Ahereto.7.
Plaintiff Relay IP is the sole and exclusive owner of all right, title, and interest inthe ’637 Patent and holds the exclusive right to take all actions, including the filing of this patentinfringement lawsuit, necessary to enforce its rights to the ’637 Patent. Relay IP also has theright to recover all damages for past, present, and future infringement of the ’637 Patent and toseek injunctive relief as appropriate under the law.8.
Defendant has infringed and continues to directly infringe one or more claims of the ’637 Patent, including at least Claim 1, by using the method claimed in testing equipmentthat it sells and has sold for use by its customers to also practice the method of at least Claim 1of the ’637 Patent. Such equipment includes, for example and without limitation, equipmentfrom the following product lines and all other routing platforms that support/enable the practiceof the PIM-SM standard: NetVanta 1335 PoE Multiservice Access Router, NetVanta 1335 Wi-Fi & PoE Multiservice Access Router, NetVanta 3448 Multiservice Access Router, NetVanta