On information and belief, Weebly
is subject to this Court’s specific and general
personal jurisdiction pursuant to due process and/or the Texas Long Arm Statute, due at least toits substantial business in this forum, including: (i) at least a portion of the infringement allegedherein; and (ii) regularly doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving substantial revenue from goods and services provided to individuals inTexas and in this Judicial District.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,353,199
Quxuz is the sole owner by assignment of the entire right, title, and interested inUnited States Patent No. 7,353,199
patent”) entitled “Method of Moderating External
Access to an Electronic Document Authoring Development and Distribution.
” The ’199
patentissued on April 1, 2008
. A true and correct copy of the ’
199 patent is included as Exhibit A.7.
Upon information and belief, Weebly has been and now is infringing, both
literally and/or under the doctrine or equivalents, the claims of the ‘199
patent in the State of Texas, in this judicial district, and elsewhere in the United States, by, among other things,making, using, importing, offering for sale, and/or selling one or more document authoring,development and distribution systems covered
by one or more claims of the ‘199
. By making, using, importing, offering for sale, and/or selling theAccused Products, for example www.weebly.com, that are covered by one or more claims of the
patent, Weebly has injured Quxuz and is thus liable to
Quxuz for infringement of the ‘199
patent pursuant to 35 U.S.C. §271.