3other persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals in Texas and in this district.
Plaintiff’s rights to relief are asserted against all named defendants jointly,severally, or in the alternative, with respect to or arising out of the same transaction,occurrence, or series of transactions or occurrences relating to the making, using,importing into the United States, offering for sale, or selling of the same accused productor process; and questions of fact common to all defendants will arise in this action.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 5,379,421
On January 3, 1995, United States Patent No. 5,379,421 (“the 421 patent”)was duly and legally issued by the United States Patent and Trademark Office for aninvention titled “Interactive Terminal For The Access Of Remote Database Information.”On October 10, 1995, a certificate of correction of the 421 patent was duly and legallyissued by the Patent Office.10.
Garnet is the owner of the 421 patent with all substantive rights in and tothat patent, including the sole and exclusive right to prosecute this action and enforce the421 patent against infringers, and to collect damages for all relevant times.11.
D&M, Denon, and Marantz, either alone and/or in conjunction with others,including their customers and/or suppliers, made, had made, used, imported, provided,supplied, distributed, sold, and/or offered for sale products and/or systems responsive tooutput signals from a telephone (including at least the following models: Denon AVR1912,Marantz SR7005) that infringed one or more claims of the 421 patent.