3Telecommunications Public Limited Company. A true and correct copy of the ’548patent is attached as Exhibit A.8.
GlobeTecTrust is the exclusive licensee of the ’548 patent and has the legalright to enforce rights under the ’548 patent, sue for infringement, and seek all availablerelief and damages.9.
Upon information and belief, Defendant is infringing (literally and/or underthe doctrine of equivalents) the ’548 patent in this District and throughout the UnitedStates by, among other things, making, using, importing, offering for sale and/or selling acommunications network that includes nodes as claimed in the ’548 patent that routenetwork traffic according to the method claimed in the ’548 patent. Defendant’sinfringing networks include, without limitation, networks utilizing a Multiprotocol LabelSwitching (MPLS) architecture, which allows Defendant to sell MPLS-based productsand services, such as Vantage Point. (See
: “VantagePoint is a fully redundant,always-on network through which we offer a suite of economical, reliable high-bandwidth services. Our state-of-the-art fiber-based core network is the largest IP/MPLSbased network in northern New England.”)10.
Defendant committed these acts of infringement without license orauthorization.11.
As a result of Defendant’s infringement of the ’548 patent, GlobeTecTrust hassuffered monetary damages in an amount not yet determined, and will continue to sufferdamages in the future unless Defendant’s infringing activities are enjoined by this Court.