26. This Court has personal jurisdiction over Citigroup and venue is proper in thisdistrict because Citigroup has committed, and continues to commit, acts of infringement in theState of Illinois, including in this district and has engaged in continuous and systematic activitiesin the State of Illinois, including in this district. For example, Citigroup regularly conducts business in this district as shown by at least 30 Citigroup locations in the City of Chicago.Therefore, Citigroup has engaged 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
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. Citigroup has and continues to directly infring
e one or more claims of the ‘245
patent in this judicial district and/or elsewhere in Illinois and the United States, including at leastclaim 22 by, among other things, practicing methods that
infringe the ‘245
patent including, but