IDC 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.
IDC 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.
CLAIMS FOR RELIEF COUNT I – DIRECT INFRINGEMENT
Plaintiff repeats and incorporates by reference paragraphs 1-10 above.
IDC 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 QuoTrek and PrimeTerminal Mobile systems and related hardware and software that provide mobile access to real-time financial data.
IDC has had actual knowledge of the ‘468 patent since at least December 2008, when its subsidiary Interactive Data Managed Solutions Limited entered into an agreement with WorldLink Information Technology Systems, a prior assignee of the ‘468 patent. That agreement specifically references WorldLink’s “patented technology.”