3States Patent and Trademark Office. A true and correct copy of the ’058 Patent is attached asExhibit A to this Complaint.9.
On December 11, 2012, United States Patent No. 8,330,613 (collectively with the’058 Patent, the “Activision Patents”), titled “REMOTE CONTROL ELECTRONIC DISPLAYSYSTEM,” was duly and legally issued by the United States Patent and Trademark Office. Atrue and correct copy of the ’613 Patent is attached as Exhibit B to this Complaint.10.
Plaintiff is the assignee and owner of all right, title, and interest in and to theActivision Patents, and has the right to assert causes of action arising under the ActivisionPatents and the right to any remedies for infringement thereof.11.
On information and belief, Defendant operates the Inverness Hotel and Conference Center.12.
Defendant is and has been directly infringing one or more claims of each of theActivision Patents in the United States by using digital signage in at least the Inverness Hotel and Conference Center in violation of 35 U.S.C. § 271.13.
Because of Defendant’s infringement of the Activision Patents, Plaintiff hassuffered damages and will continue to suffer damages in the future.14.
Plaintiff has suffered irreparable injury due to the acts of infringement byDefendant and will continue to suffer irreparable injury unless Defendant’s infringing activitiesare enjoined.15.
Defendant has had notice of its infringement of the Activision Patents at leastsince March 18, 2013, when Defendant was notified of its infringement in a letter sent bycertified mail.