FactSet has previously admitted that it transacts business in the District of Delaware. 6.
FactSet has previously admitted that it is subject to this Court’s specific and general personal jurisdiction and that the District of Delaware is a proper venue in litigation against it under 28 U.S.C. §§ 1391(b)-(c) and 1400(b). 7.
FactSet is therefore subject to this Court’s specific and general personal jurisdiction. 8.
Venue is proper pursuant to 28 U.S.C. §§ 1391(b)-(c) and 1400(b).
THE ‘468 PATENT
Quest is the owner of all rights by assignment of the ‘468 patent, entitled “Apparatus and a Method for Supplying Information,” with the right to pursue claims for infringement. 10.
The United States Patent and Trademark office issued the ‘468 patent on March 20, 2007. A true and correct copy of the ‘468 patent is attached to this Complaint as Exhibit A.
CLAIM FOR RELIEF COUNT I
Plaintiff repeats and incorporates by reference paragraphs 1-10 above.
FactSet has infringed and continues to directly infringe the claims of the ‘468 patent, literally or under the doctrine of equivalents, by making, using, selling, and offering for sale products that are covered by claims of the ‘468 patent, including its Mobile Solutions system and related hardware and software that provide mobile access to real-time financial data.
FactSet’s infringement of the ‘468 patent has damaged Plaintiff.
To the extent that facts uncovered in discovery show that FactSet’s past infringement has been willful, Plaintiff reserves the right to seek enhanced damages and attorney fees for such past infringement.