technology called PerForm™ Vmax chemical mixers through its commercial division AshlandHercules Water Technology.
JURISDICTION AND VENUE
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
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.