COUNT I - WALGREEN’S DIRECT INFRINGEMENT OF THE ‘783 PATENT
PRN incorporates and re-alleges Paragraphs 1 through 11 as each were fully setforth.13.
The ‘783 patent remains valid, enforceable and unexpired.14.
Upon information and belief, Walgreen is directly infringing and has directlyinfringed the ‘783 patent, including, without limitation, by making, using, selling, offering forsale, and/or importing, without license or authority, a method and/or system of dispensingmedical prescriptions covered by the ‘783 patent, including but not limited to Walgreen’sPharmacy Prescription System including at least Walgreen’s Phone Applications, and MobileConnects, which include a system and method for scanning, refilling, monitoring, andnotifications related to dispensing medical prescriptions (hereinafter the “accused system”).15.
The accused system falls within the scope of one or more claims of the ‘783patent. Upon information and belief, Walgreen directly infringes at least claims 1 and 2 of the‘783 patent.16.
Upon information and belief, Walgreen’s has actual knowledge of the ‘783 patent.17.
Upon information and belief, Walgreen’s infringement has been and continues tobe willful and deliberate.18.
As a result of Walgreen’s infringement, PRN will suffer severe and irreparableharm, unless that infringement is enjoined by this Court, and has suffered substantial damages.
PRAYER FOR RELIEF
WHEREFORE, PRN requests judgment in its favor against Walgreen for the followingrelief:A.
An Order adjudging that Walgreen has infringed the ‘783 patent;