Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(c) and1400(b).
Camco is the exclusive licensee of two U.S. Patents (Asserted Patents”),both entitled Drain Pan for Mounted Water Equipment: 8,104,634 B2 (the “’634 Patent”)and D653,745 S (the “’745 Patent”). True and correct copies of the ‘634 Patent(Exhibit A) and ‘745 Patent (Exhibit B) are attached.8.
Camco received all substantial rights to the Asserted Patents in Septemberof 2012, through a License Agreement with the owner of the patents. In particular, theLicense Agreement provides Camco with the “exclusive right” to seek abatement of patent infringement for the entire term of the Asserted Patents and otherwise to sue forpatent infringement and all recoveries therefrom.9.
Seisco sells both tankless water heaters and drain pans therefor and knowsand intends that such products will be put together and otherwise used in combination bythose purchasing or utilizing such products.10.
Seisco commits, induces and contributes to acts of infringement by making,using, offering to sell, and/or selling in the United States, and/or importing into theUnited States tankless water heaters and drain pans that practice one or more claims ineach of the Asserted Patents. True and correct images of one such drain pan are attachedas Exhibit C.