This Court has jurisdiction over the subject matter of this actionas to the Defendant pursuant to 28 U.S.C. §§ 1331 and 1338(a).4.
This Court has
jurisdiction as to 13th Floor because, upon information and belief, 13th Floor is subject to both generaland specific jurisdiction in this State. More particularly, upon informationand belief, 13th Floor regularly conducts business activity in the State of Florida, whether directly or through authorized dealers by selling and offering to sell products that infringe one or more claims of Correct Craft’s patents in Florida.5.
Venue properly lies within this judicial district and division, pursuant to 28 U.S.C. §§1391(c) and 1400(b).STATEMENT OF FACTS6.
Correct Craft is the sole and exclusive owner of the followingvalid and enforceable United States Patents (collectively, the “Patents-in-Suit”):PATENT NO. TITLERE37,823 (the ‘823 Patent’) Water Sport Towing Apparatus and Method 6,666,159 (the ‘159 Patent’) Water Sport Towing Apparatus7,299,761 (the ‘761 Patent’) Water Sport Towing Apparatus