3contributing to the infringement of the ’811 patent by others in the United States; and/or (c)inducing others to infringe the ’811 patent within the United States.10.
For example, Defendant sells, offers for sale, and/or uses at least League of Legends, thereby infringing at least claim 7 of the ’811 patent. Defendant induces the use of League of Legends by others, such as its customers, who also directly infringe the ’811 patent.Defendant has actively and knowingly aided and abetted that direct infringement. Defendantactually intended to cause the acts that constitute direct infringement, knows of the ’811 patent atleast as early as the filing date of this Complaint, and knew its actions would lead to actualinfringement and/or was recklessly indifferent with respect thereto. Further, Defendant sold,offered for sale, and/or imported a material component of the patented invention that is not astaple 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 aninfringing 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,contributorily infringed the ’811 patent, and induced infringement of the’811 patent;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 directlyinfringing, contributorily infringing, and inducing the infringement of the