making, using, selling, offering to sell or importing in this district and elsewhere into the United States the patented invention(s) of the Patent-in-Suit, the right to license the Patent-in-Suit, and to sue the Defendant for infringement and recover past damages.3.
Upon information and belief, Sensus is a corporation duly organized and existingunder the laws of the State of Delaware since January 22, 1992 and having its principal place of business located at 8601 Six Forks Road, Suites 300 & 700 (Wake County), Raleigh, NorthCarolina, 27615. Defendant may be served through its registered agent, The Corporation TrustCompany, Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware, 19801.4.
Upon information and belief, Sensus ships, distributes, makes, uses, offers for sale, sells, and/or advertises its products under its FlexNet™ brand name.
JURISDICTION AND VENUE
This action arises under the Patent Laws of the United States, 35 U.S.C. § 1
, including 35 U.S.C. §§ 271, 281, 283, 284, and 285. This Court has subject matter jurisdiction over this case for patent infringement under 28 U.S.C. §§ 1331 and 1338(a).6.
The Court has personal jurisdiction over Defendant because: Defendant hasminimum contacts within the State of Delaware and in the District of Delaware; Defendant has purposefully availed itself of the privileges of conducting business in the State of Delaware and in the District of Delaware; Defendant has sought protection and benefit from the laws of theState of Delaware; Defendant regularly conducts business within the State of Delaware and within the District of Delaware, and Plaintiff’s causes of action arise directly from Defendant’s business contacts and other activities in the State of Delaware and in the District of Delaware.
Endeavor MeshTech, Inc. v. Sensus USA Inc.
Page |C-2ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT