Case 2:13-cv-00142-WCO Document 1 Filed 06/27/13 Page 3 of 10
district, has committed and continue to commit acts
patentinfringementin this judicial district, and has harmed and continues to harm IBC in thisjudicial district by,among otherthings,selling and offeringtosell
infringing articles covered under one or more
the above patents.8.Venue
proper pursuant to 28 U.S.C.
1391 and 1400because,amongother reasons, Defendants are subject to personal jurisdiction and havecommitted acts
patent infringement in this judicial district.9. Joinder
the Defendants is proper under
U.S.C. §299in asmuchas
Plaintiff's right to relief is asserted against the Defendants with respect toor arising out
the same series
occurrences relating tothe making, using, importing into the United States, offering for sale,
the same accused product and questions
fact common to alldefendants will arise in the action.
FACTS COMMON TO ALL COUNT
10.The allegations ofParagraphs 1 to 9 are incorporated by reference
fully set forth herein.11. IBC is the owner
Patent No. D588,419S
'419 Patent") acopy
which is attached as Exhibit
12. The Patent is directedtoa unique ornamental design for a Barbeque MeatSkewer.