- 2 -
Nalco is a leading provider of air protection technologies, and, in particular, technologies for removing hazardous mercury from flue gases evolved during combustion of coal, delivering environmental, social and economic benefits to its customers. 7.
Nalco is the exclusive licensee of U.S. Patent No. 6,808,692 and the Inter Partes Reexamination Certificate related thereto (the “’692 Patent”), entitled “Enhanced Mercury Control in Coal-Fired Power Plants.” 8.
The ’692 Patent teaches and claims,
, methods of treating coal combustion flue gas with a bromide compound so as to reduce mercury emissions at coal-fired power plants. 9.
The ’692 Patent was duly and legally issued by the United States Patent and Trademark Office on October 26, 2004, reexamined by the United States Patent and Trademark Office, and subject to an Inter Partes Reexamination Certificate duly and legally issued by the United States Patent and Trademark Office on April 7, 2014. A copy of the ’692 Patent and Inter Partes Reexamination Certificate are attached hereto as Exhibit A and are made a part of this Complaint. 10.
As the exclusive licensee of the ’692 Patent, Nalco possesses the right to sue for infringement and recover damages resulting from such infringement.
COUNT I - INFRINGEMENT OF THE ’692 PATENT
Nalco incorporates by reference the allegations of Paragraphs 1 through 10. 12.
Chem-Mod has infringed and is now infringing the ’692 Patent through, among other activities, the use and licensing of its “Chem-Mod™ Solution” in the United States. On