prototype of their invention. On November 9, 1993, the team filed an application for patent onthe invention, and on February 2, 1999, the U.S. Patent and Trademark Office issued U.S. Patent No. 5,867,686 (the “Conner Patent”).
Plaintiff Data Speed Technology LLC (“Data Speed Tech”) is a Delaware limitedliability company.3.
On information and belief, Defendant Blackboard, Inc. (“Defendant”) is aDelaware corporation with its principal office at 650 Massachusetts Avenue NW, Washington,District of Columbia 20001. On information and belief, Defendant has appointed CorporationService Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808, as its agentfor service of process.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, 35 U.S.C. § 1,
., including § 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331and 1338(a).5.
This Court has specific and general personal jurisdiction over Defendant because,among other reasons, Defendant has availed itself of the rights and benefits of Delaware byincorporating under Delaware law, Defendant has done business in this District, has committedand continues to commit acts of patent infringement in this District, and has harmed andcontinues to harm Data Speed Tech in this District, by, among other things, using, selling,offering for sale, and importing infringing products and services in this District.6.
Venue is proper in this district under 28 U.S.C. §§ 1391(b)-(d) and 1400(b) because, among other reasons, Defendant is incorporated in this district, Defendant is subject to personal jurisdiction in this District, and Defendant has committed and continues to commit acts