THE HARM TO 3M
12.Faréclahas, by its infringing conduct, caused 3M irreparable harm for which thereis no adequate remedy at law.13.3M has suffered damage as a result ofFarécla
’s infringement to date.
14.This is an exceptional case under 35 U.S.C. § 285.
COUNT I: INFRINGEMENT OF THE ‘
15.3M incorporates the allegations contained in the above paragraphs as though fullyset forth herein.16.Faréclahas been and now is directly infringing, actively inducing others to
infringe and/or contributing to the infringement of the ‘
231patent by making, using, sellingand/or offering for sale products, including at least the G3 Ultra Compound, in violation of 35U.S.C. § 271.17.Faréclawill continue to directly infringe, actively induce others to infringe and/or
contribute to the infringement of the ‘
231patent unless and untilFaréclais enjoined by thisCourt.18.On information and belief,Faréclahas been and now is contributing to and
inducing infringement of the ‘
231patent by offering to sell and selling products intended to
practice one or more claims of the ‘
231patent, including at leastthe G3 Ultra Compound. Oninformation and belief, the infringing products are intended to be made or adapted for use in
practicing one or more claims of the ‘
231patent, and the infringing products are not staplearticles orcommodities of commerce suitable for substantial non-infringing use. On informationand belief,Faréclais and has been aware, through actual knowledge or willful blindness, that theinfringing products would be used to practice one or more claims of the