business in Texas and may be served with process by serving its registered agent CapitolServices, Inc., 1675 S. State St., Suite B, Dover, Delaware 19901.3. Defendant regularly conduct and transact business in Texas, throughout theUnited States, and within the Eastern District of Texas, itself and/or through one or more subsidiaries, affiliates, business divisions, or business units. Defendant can beserved with process through any of its registered agents including officers or directors.
JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, Title 35 of theUnited Stated Code. The Court’s jurisdiction over this action is proper under the above statutes,including 35 U.S.C. § 271
, and 28 U.S.C. §§ 1331 and 1338(a).5. Personal jurisdiction exists generally over each Defendant because eachDefendant has sufficient minimum contacts with the forum as a result of business regularlyconducted within the State of Texas and within the Eastern District of Texas. Indeed, Defendant,directly or through subsidiaries or intermediaries, make, use, sell and offer for sale, the productsthat are the subject of this Complaint in the United States, the State of Texas,and the Eastern District of Texas. Personal jurisdiction also exists specifically over Defendantas a result of, at least, Defendant’s distribution network wherein Defendant, individually andcollectively, placed instrumentalities and provided services and applications that practice theclaimed inventions within the stream of commerce, which stream is directed at this district, and by committing the tort of patent infringement within the Eastern District of Texas.6. Venue is proper in this Court under 28 U.S.C. §§ 1391 (b)(2), (c), and 28 U.S.C. §1400(b).