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Leseman v. Stratasys

Leseman v. Stratasys

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 0:14-cv-00363-SRN-SER: Leseman, LLC v. Stratasys, Inc. Filed in U.S. District Court for the District of Minnesota, the Hon. Susan Richard Nelson presiding. See http://news.priorsmart.com/-l9Th for more info.
Official Complaint for Patent Infringement in Civil Action No. 0:14-cv-00363-SRN-SER: Leseman, LLC v. Stratasys, Inc. Filed in U.S. District Court for the District of Minnesota, the Hon. Susan Richard Nelson presiding. See http://news.priorsmart.com/-l9Th for more info.

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Published by: PriorSmart on Feb 11, 2014
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02/11/2014

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UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTA)LESEMAN, LLC ))))Plaintiff,v.STRATASYS, INC.,Defendant.))))))))Civil Action No. _____________ 
JURY TRIAL DEMANDEDCOMPLAINT
Plaintiff Leseman, LLC (“Leseman”), for its Complaint against Stratasys, Inc.(“Stratasys”), alleges as follows.
THE PARTIES
1. Leseman is a limited liability company organized under the laws of theState of Minnesota, with a principal place of business in Maple Grove, Minnesota.2. On information and belief, Stratasys is a corporation organized under thelaws of the state of Delaware with its principal place of business located at 7665Commerce Way, Eden Prairie, Minnesota.
JURISDICTION AND VENUE
3. This is a civil action for patent infringement arises under the patent laws of the United States, Title 35 of the United States Code Section 1
 et. seq
.
 
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4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331and 1338(a).5. This Court has personal jurisdiction over Stratasys because Stratasysconducts substantial and continuous business in this judicial district, including businessconducted at its facility located at 7665 Commerce Way, Eden Prairie, Minnesota. ThisCourt has personal jurisdiction over Stratasys because it has committed acts of infringement giving rise to this action in this District and has established minimumcontacts within this District such that the exercise of jurisdiction over Stratasys would notoffend traditional notions of fair play and justice.6. Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c) and1400(b) because Stratasys resides in this District and has committed acts of infringementin this District and has a regular and established place of business in this District.
BACKGROUND
7. On February 12, 2008, the United States Patent Office issued Patent No.7,329,113 (“the ‘113 Patent”), entitled, “Adjustable Extrusion Die.” A true and correctcopy of the ‘113 Patent is attached hereto as
 Exhibit A
.8. Leseman is the owner by assignment of all right, title in interest in the ‘113Patent, which is valid, subsisting and in full force and effect.
 
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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;

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