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 corporation duly organized andexisting under the laws of the State of Delaware, having a place of business located at 1600Amphitheatre Parkway, Mountain View, California 94043. Upon information and belief,Defendant does business through its website, play.google.com, which is accused of infringing thePatent-in-Suit. Defendant can be served via its registered agent, The Corporation TrustCompany, 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) incorporating under Delaware law; (ii) conducting substantial business inthis forum; and (iii) engaging in other persistent courses of conduct, and/or deriving substantialrevenue from services provided to individuals in Delaware, and this Judicial 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. Uponinformation and belief, Defendant has committed patent infringement in the State of Delaware