AutoZone is a Nevada corporation with its principal place of business at 123South Front Street, Dept. 8088, Memphis, Tennessee 38103.
The allegations set forth in the foregoing paragraphs 1 through 3 are herebyrealleged and incorporated herein by reference.5.
The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338(a).6.
AutoZone is a citizen of Nevada because AutoZone was incorporated in the stateof Nevada.7.
On February 11, 1997, United States Patent No. 5,603,054 (the “‘054 Patent”),entitled “Method For Triggering Selected Machine Event When The Triggering Properties Of The System Are Met And The Triggering Conditions Of An Identified User Are Perceived,” wasduly and legally issued by the United States Patent and Trademark Office. A true and correctcopy of the ‘054 Patent is attached as Exhibit 1 to this Complaint.8.
UbiComm is the assignee and owner of all rights, titles and interests in and to the‘054 Patent, including, but not limited to, the right to assert all causes of action arising under the‘054 Patent and the right to any remedies for infringement.9.
Without license or authorization, AutoZone has directly infringed and continuesto directly infringe one or more claims of the ‘054 Patent in this Judicial District and elsewherein the United States at least by making and/or using one or more websites, including, but notlimited to,http://www.autozone.com/autozone/ (the “Websites”).10.
AutoZone has continuously and systematically conducted business in this JudicialDistrict.11.
AutoZone has purposefully availed itself of the privilege of conducting businesswithin this Judicial District.12.
AutoZone has established sufficient minimum contacts with this Judicial Districtsuch that it should reasonably and fairly anticipate being haled into court in this Judicial District.13.
AutoZone has purposefully directed activities at residents of Nevada.