practice putting from any direction.
an action for patent infringement arising under the patent laws
theUnited States, Title 35
the United States Code. Jurisdiction as to these claims is conferred onthis Court by 35 U.S.C.
This Court has personal jurisdiction over Defendant because Defendant advertisesits products in this District. Specifically, Defendant advertises its Putt-A-RoundTM practicetarget through SkyMall® Magazine, which is made available on flights to and from this Districtoperated by, among others, United Airlines and American Airlines. Copies
excerpts fromSkyMall® Magazine for Late Spring 2013 for United Airlines and American Airlines areattached as Exhibits
On information and belief, Defendant Anne Stone purchased advertising inSkyMall® Magazine with the knowledge and intent that the advetiising would reach consumersin this District and with the intent to sell its Putt-A-RoundTM product in this District.
Venue is proper in this district under 28 U.S.C.
1391(b) and 1400(b).
Roger Young incorporates by reference paragraphs 1-7 as fully set forth herein.
On May 22, 2001, United States Patent No. D442,661 ("the '661 patent") entitled
Putting Practice Hole Simulator" was duly and legally issued
the United States Patentand Trademark Office. Roger Young is the owner
all right, title, and interest in and to the '661patent, with full right to bring suit to enforce the patent, including the right to recover for pastinfringement damages. A copy
the '661 patent is attached hereto as Exhibit
Anne Stone has known
the '661 patent since at least as early as May 29, 2013,