Complaint for Patent Infringement
12345678910111213141516171819202122232425262728Plaintiff CEATS, Inc. (“CEATS”) for its Complaint against Defendant AmericanAirlines, Inc. (“American”), alleges as follows:
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, Title 35 of theUnited States Code.2.
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).3.
Upon information and belief, American conducts business throughout theUnited States, including in this Judicial District, and has committed the acts complained of inthis Judicial District and elsewhere. Venue is proper in this Judicial District pursuant to 28U.S.C. §§ 1391(b)–(d) and 1400(b).4.
Upon information and belief, American is subject to this Court’s specific and general personal jurisdiction, due at least to its substantial business in this forum, includingcommitting at least a portion of the infringements alleged herein, regularly doing or soliciting business, engaging in other persistent course of conduct, and deriving substantial revenuefrom goods and services provided to individuals in this Judicial District.
Plaintiff CEATS is a Nevada corporation with its principal place of business at800 E. Charleston Boulevard, Las Vegas, Nevada.6.
Upon information and belief, Defendant American is a Delaware corporationwith its principal place of business at 4333 Amon Carter Boulevard, Fort Worth, TX 76155.
FIRST CAUSE OF ACTION(Infringement of U.S. Patent No. 7,548,867)
CEATS incorporates by reference and realleges each of the allegations of Paragraphs 1–6.8.
On June 16, 2009, the United States Patent and Trademark Office duly and lawfully issued U.S. Patent No. 7,548,867 (“the ’867 patent”), entitled “System and Method for Maintaining Coherency of Data Entries.” A true and correct copy of the ’867 patent is