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Nalco Company v. Ashland

Nalco Company v. Ashland

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-07332: Nalco Company v. Ashland Inc. Filed in U.S. District Court for the Northern District of Illinois, no judge yet assigned. See http://news.priorsmart.com/-l9hz for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-07332: Nalco Company v. Ashland Inc. Filed in U.S. District Court for the Northern District of Illinois, no judge yet assigned. See http://news.priorsmart.com/-l9hz for more info.

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Published by: PriorSmart on Oct 12, 2013
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11/06/2013

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IN THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISEASTERN DIVISION
) NALCO COMPANY, )) Civil Action No. _____________ )Plaintiff, ))v. ))ASHLAND INC., ))Defendant. ))
COMPLAINT FOR PATENT INFRINGEMENT
 Nalco Company (“Nalco”), for its Complaint, states and alleges as follows:
THE PARTIES
 1.
 
Plaintiff, Nalco, is a corporation duly organized and existing under the laws of theState of Delaware and has a principal place of business at 1601 W. Diehl Road, Naperville,Illinois 60563-1198.2.
 
Defendant, Ashland Inc. (“Ashland”), is a corporation existing under the laws of the State of Kentucky, and has a principal place of business at 50 E. RiverCenter Blvd.,Covington, KY 41012. Ashland Inc. is registered to do business in the State of Illinois with anagent for service of process at 208 South LaSalle St., Suite 814, Chicago, Illinois 60604.3.
 
 Nalco and Ashland are both involved and active in the sale of chemicals andchemical mixing technology for industrial processes such as papermaking. Ashland has made,sold, used and is currently selling for use by its papermaking customers chemical mixing
 
technology called PerForm™ Vmax chemical mixers through its commercial division AshlandHercules Water Technology.
JURISDICTION AND VENUE
 4.
 
This is a claim of patent infringement arising under the Acts of Congress relatingto patents, 35 U.S.C. §§ 271; 281-285.5.
 
This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).6.
 
Personal jurisdiction and venue in this District are proper under 28 U.S.C. § 1391and 1400(b). Ashland Inc. has systematic and continuous contacts with the State of Illinois andthis District. It is registered to do business in the State of Illinois with an agent for service of  process at 208 South LaSalle St., Suite 814, Chicago, Illinois 60604.
Count IDirect Patent Infringement of U.S. Patent No. 7,981,251
 7.
 
On July 19, 2011, United States Patent No. 7,981,251 entitled Method AndArrangement For Feeding Chemicals Into A Process Stream (“the ’251 patent”) was duly andlegally issued to Plaintiff as assignee of the inventors Tommy Jacobson, Mika Salonen, andMartti Latva. Plaintiff is the owner of the entire right, title and interest in and to the ’251 patentand has been the owner of the patent throughout the period of Defendant’s infringement and stillis the owner thereof. The ’251 patent is attached as Exhibit A.8.
 
Defendant’s making, selling, offering for sale, using or importing in the UnitedStates the PerForm™ Vmax chemical mixers, including the PerForm™ Vmax 1000, directlyinfringes one or more claims of the ’251 patent.9.
 
Plaintiff has complied with the statutory notice requirement by marking its products or by at least the filing of this Complaint.
 
10.
 
Plaintiff has been damaged by Defendant's infringement of the ’251 patent andwill continue to be damaged in the future unless Defendant is permanently enjoined frominfringing said patent.
Count IIDirect Patent Infringement of U.S. Patent No. 7,550,060
 11.
 
On June 23, 2009, United States Patent No. 7,550,060 entitled Method AndArrangement For Feeding Chemicals Into A Process Stream (“the ’060 patent”) was duly andlegally issued to Plaintiff as assignee of the inventors Tommy Jacobson, Mika Salonen, andMartti Latva. Plaintiff is the owner of the entire right, title and interest in and to the ’060 patentand has been the owner of the patent throughout the period of Defendant’s infringement and stillis the owner thereof. The ’060 patent is attached as Exhibit B.12.
 
Defendant’s use of the PerForm™ Vmax chemical mixers, including thePerForm™ Vmax 1000, directly infringes the ’060 patent. Defendant has used and continues touse the PerForm™ Vmax chemical mixers, including the PerForm™ Vmax 1000, in a processthat infringes the ’060 patent in at least one pulp processing plant.13.
 
Plaintiff has provided Defendant notice by at least the filing of this Complaint.14.
 
Plaintiff has been damaged by Defendant's infringement of the ’060 patent andwill continue to be damaged in the future unless Defendant is permanently enjoined frominfringing said patent.
 

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