Defendant has conducted and does conduct business within Puerto Rico, directly or through intermediaries, resellers or agents, or offers for sale, sells, advertises (including, but notlimited to, the use of interactive web pages with promotional material) products or services, or uses services or products in Puerto Rico or elsewhere
that infringe the ‘
In addition to Defendant’
s continuously and systematically conducting business inPuerto Rico
, the causes of action against Defendant are connected (but not limited) to Defendant’
s purposeful acts committed in Puerto Rico, including Defendant
making, using, offering for sale,or selling a service that includes a computer-implemented method for rating-based sorting anddisplaying of reviews, which include features that fall within the scope of at least one claim of the
Venue lies in this judicial district pursuant to 28 U.S.C. §§1391 and 1400(b).
V. FACTUAL ALLEGATIONS
The ‘127 patent
On February 22, 2011
, the United States Patent and Trademark Office (“USPTO”)
duly and legally
issued the ‘
patent, entitled “
Rating-based Sorting and Displaying of Reviews
after a full and fair examination.13.
Ingeniador is presently the owner of all right, title and interest in and to the ‘
127 patent. Ingeniador possesses all rights of recovery
under the ‘
127 patent, including the exclusiveright to recover for past infringement.14.
127 patent is valid and enforceable.15.
127 patent contains four independent claims and thirteen dependent claims.Defendants commercialize methods that perform all the steps recited in one or more claims of the
127 patent. Defendant employs a computer-implemented method that sorts and displays reviews