COUNT I(Infringement of the ‘113 Patent)
9. Leseman realleges and incorporates herein the allegations set forth inParagraphs 1-8.10. Stratasys has directly infringed at least claim 1 of the ‘113 Patent pursuantto 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using,selling, and/or offering for sale in the United States and without authority products thatinfringe such claims. In particular, Stratasys has used, in Minnesota, extrusion diescovered by at least Claim 1 of the ‘113 Patent, to manufacture extruded filament used incartridges for Stratasys 3-D printers.11. Leseman has suffered damages as a result of Stratasys’s infringement of the‘113 Patent. In addition, Leseman will continue to suffer irreparable harm unless thisCourt enjoins Stratasys from infringing the ‘113 Patent.
PRAYER FOR RELIEF
For the above reasons, Leseman respectfully requests that this Court grant thefollowing relief in its favor and against Stratasys:(a) A judgment in favor of Leseman that Stratasys has infringed (either literallyor under the doctrine of equivalents) one or more claims of the ‘113 Patent;(b) A preliminary and/or permanent injunction enjoining Stratasys and itsofficers, directors, agents, servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in active concert or participation with it, from infringing the ‘113 Patent;