2 Mart Plaza, 12
Floor, Chicago, Illinois 60654. Defendant WhyTeeZee, LLC is a limited liability company organized under the laws of the State of Delaware with its principal place of business, on information and belief, at 222 West Merchandise Mart Plaza, 12
Floor, Chicago, Illinois 60654. Defendant BitBend, LLC is a limited liability company organized under the laws of the State of Illinois with its principal place of business at 201 South Taylor Street, Oak Park, Illinois 60302. Defendant Robert Brown is an individual and the Chief Executive Officer of OptionsAway; Mr. Brown is a resident of Oak Park, Illinois. Defendant Heidi Brown is an individual and is the Chief Marketing Officer of OptionAway; Mrs. Brown is a resident of Oak Park, Illinois.
III. JURISDICTION AND VENUE
4. This Court has subject matter jurisdiction under the provisions of 28 U.S.C. §§ 1331 and 1338(a), in that this action for patent infringement arises under the laws of the United States, including 35 U.S.C. §§ 271 and 281-285. This Court has jurisdiction over the remaining non-patent claims pursuant to 28 U.S.C. § 1367. 5. Personal jurisdiction over Defendants comports with 735 ILCS 5/2-209 and the United States Constitution because Defendants do business in this judicial district, have committed and continue to commit, or have contributed and/or induced and continue to contribute to and/or to induce, acts of patent infringement in this judicial district as alleged in this Complaint, or otherwise have sufficient contacts with the state. 6. Venue is proper in this judicial district under the provisions of 28 U.S.C. §§ 1391(b), (c), and § 1400(b).
IV. FACTUAL BACKGROUND
7. Smart Options is the owner of United S
tates Patent Nos. 7,313,539 (“539 patent”) and United States Patent No. 8,301,550 (“550 patent”). Smart Options also owns