Plaintiff is the owner the Patent-in-Suit with respect to the Defendant, and possesses all right to enforce the Patent-in-Suit, including the right to sue the Defendant for infringement and recover past damages.4.
Upon information and belief, Defendant is a Limited Liability Company dulyorganized and existing under the laws of the State of Delaware, having a place of businesslocated at 1209 N. Orange Street, Wilmington, Delaware 19801-1120. Upon information and belief, Defendant does business through its website, www.moosejaw.com, which is accused of infringing the Patent-in-Suit. Defendant can be served via its registered agent, The CorporationTrust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801.
JURISDICTION AND VENUE
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
. This Court has subject matter jurisdiction over this case for patent infringement under 28U.S.C. §§ 1331 and 1338(a).6.
On information and belief, Defendant is subject to this Court’s specific andgeneral personal jurisdiction pursuant to due process and/or the Delaware Long Arm Statute, dueto having availed itself of the rights and benefits of the state of Delaware by engaging inactivities including (i) forming its corporate entity under Delaware law; (ii) conductingsubstantial business in this forum; and (iii) engaging in other persistent courses of conduct,and/or deriving substantial revenue from services provided to individuals in Delaware, and thisJudicial District.7.
More specifically, Defendant, directly and/or through its intermediaries,distributes, offers for sale, sells, and/or advertises (including the provision of an interactive web page) its services in the United States, the State of Delaware, and this Judicial District. Upon