3others to infringe the ’811 patent within the United States.10.
For example, Defendant sells, offers for sale, and/or uses at least Pro EvolutionSoccer 2013, thereby infringing at least claim 7 of the ’811 patent. Defendant induces the use of Pro Evolution Soccer 2013 by others, such as its customers, who also directly infringe the ’811 patent. Defendant has actively and knowingly aided and abetted that direct infringement. De-fendant actually intended to cause the acts that constitute direct infringement, knows of the ’811 patent at least as early as the filing date of this Complaint, and knew its actions would lead toactual infringement and/or was recklessly indifferent with respect thereto. Further, Defendantsold, offered for sale, and/or imported a material component of the patented invention that is nota staple article of commerce capable of substantial non-infringing use, with knowledge of the’811 patent, and knowledge that the component was especially made or adapted for use in an in-fringing manner.
Babbage hereby demands a trial by jury on all issues so triable.
Babbage requests the following relief:A.
A judgment that Defendant has directly infringed the ’811 patent, contrib-utorily infringed the ’811 patent, and induced infringement of the ’811 pa-tent;B.
An injunction preventing Defendant and its officers, directors, agents,servants, employees, attorneys, licensees, successors, and assigns, and those in active concert or participation with any of them, from directly in-fringing, contributorily infringing, and inducing the infringement of the’811 patent;