-2-States, including 35 U.S.C. § 271
This Court has personal jurisdiction over Defendant because, among other things,Defendant is incorporated in Delaware and conducts or has conducted business in Delaware. Oninformation and belief, Defendant has committed and/or participated in the commission of patentinfringement in Delaware and elsewhere in the United States, and has harmed and continues toharm Interface IP in Delaware.6.
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and 1400(b).
On July 29, 2008, the ’663 patent, titled “Graphical Input Device With DynamicField Width Adjustment For Input Of Variable Data Via A Browser-Based Display,” was dulyand lawfully issued by the United States Patent and Trademark Office (“PTO”). The ’663 patentis attached hereto as Exhibit A.8.
Interface IP owns the ’663 patent and holds the right to sue and recover damagesfor infringement thereof, including past infringement.
CountInfringement of U.S. Patent No. 7,406,663
Paragraphs 1-8 are incorporated by reference as if fully restated herein.10.
Defendant has directly infringed, and continues to directly infringe, at least claim1 of the ’663 patent under 35 U.S.C. § 271, literally and/or under the doctrine of equivalents, byusing and/or operating websites that practice at least claim 1 including, for example,http://www.redroof.com.11.
Interface IP has been and continues to be damaged by Defendant’s infringementof the ’663 patent.