26. This Court has personal jurisdiction over PNC and venue is proper in this district because PNC has committed, and continues to commit, acts of infringement in the State of Illinois, including in this district and has engaged in continuous and systematic activities in theState of Illinois, including in this district. For example, PNC regularly conducts business in thisdistrict as shown by at least 30 PNC locations in the City of Chicago. Therefore, PNC hasengaged in continuous and systematic activities in this district and has purposefully availed itself of the privileges of conducting business in this district.
(INFRINGEMENT OF U.S. PATENT NO. 5,826,245)
7. CVS incorporates paragraphs 1 through 6 herein by reference.8. This cause of action arises under the patent laws of the United States, and in particular, 35 U.S.C. §§ 271,
Providing Verification Information for aTransaction.
CVS is the owner
of the ‘245
patent with ownership of all substantial rights in the
45 patent, including the right to exclude others and to enforce, sue, and recover damages for past and future infringement. A t
rue and correct copy of the ‘245
patent is attached as Exhibit 1.10.
patent is valid, enforceable and was duly issued in full compliance withTitle 35 of the United States Code.
11. PNC has and continues to directly infring
e one or more claims of the ‘245
patentin this judicial district and/or elsewhere in Illinois and the United States, including at least claim22 by, among other things, practicing methods that
infringe the ‘245
patent including, but not