(c), as Defendants reside in this judicial district, a substantial part of the events,omissions and acts which are the subject matter of this action occurred within theCentral District of California, and a substantial part of the property that is thesubject of the action is located in the Central District of California.
Aspen Medical Holdings, LLC is a California Limited LiabilityCompany with a principal place of business at 6481 Oak Canyon, Irvine, California.
Aspen Medical Products is a California corporation with its principal
place of business at 6481 Oak Canyon, Irvine, California.
On information and belief, Orthomerica is a Florida corporation, whichhas or used to have a principal place of business at 505 31st Street, Newport Beach,
California 92663. On information and belief, Orthomerica also has a place ofbusiness at 6333 N Orange Blossom Trail, Orlando, Florida 32810. On information
and belief, Orthomerica has made, used, sold and/or offered to sell in this Judicial
District the products that are alleged to infringe Plaintiffs' design patent discussedbelow. Orthomerica also operates a website at www.orthomerica.comat which it
advertises the products that are alleged to infringe Plaintiffs' design patent.
The true names and capacities, whether individual, corporate, associateor otherwise, of defendants DOES 1 through 10, inclusive, are unknown to
Plaintiffs, which therefore sues said defendants by such fictitious names. Plaintiffs
will seek leave of this Court to amend this Complaint to include their proper names
and capacities when they have been ascertained. Plaintiffs are informed and believe,
and based thereon allege, that each of the fictitiously named defendants participatedin and is in some manner responsible for the acts described in this Complaint and
the damage resulting therefrom.
Plaintiffs allege on information and belief that each of the defendantsnamed herein as Does 1 through 10, inclusive, performed, participated in, or abettedin some manner, the acts alleged herein, proximately caused the damages alleged
COMPLAINT FOR PATENT
Case 8:13-cv-01461-AG-DFM Document 1 Filed 09/18/13 Page 2 of 11 Page ID #:2