JURISDICTION AND VENUE
4. This action arises under the Patent Act, 35 U.S.C. § 101
.5. This Court has jurisdiction over Plaintiff’s claims under at least 28 U.S.C.§§ 1331 and 1338.6. This Court has personal jurisdiction over Defendant as, upon informationand belief, Defendant has engaged in acts of infringement complained of herein in NorthCarolina, including sales, offers for sale, and/or distribution of infringing products.Further, upon information and belief, Defendant does systematic and continuous businessin North Carolina and in this judicial district by, among other things, routinely selling anddistributing its products in North Carolina to North Carolina consumers in this judicialdistrict. Further, upon information and belief, Defendant has purposefully advertised,sold and distributed infringing product into the stream of commerce in the United Stateswith the reasonable belief and expectation that such product would periodically flow into North Carolina.7. The United States District Court for the Middle District of North Carolinais the appropriate venue for this action, pursuant to at least 28 U.S.C. §§ 1391 and1400(b).
8. Plaintiffs own all right, title and interest to United States Patent No.8,429,844 (“the ‘844 Patent”), including all rights to bring actions and recover damagesfor infringement thereof. The ‘844 Patent issued on April 30, 2013, is entitled “Modular