3 throughout the United States including in Delaware, through various directly- or indirectly-owned operating subsidiaries, including its wholly-owned subsidiary Ascend Laboratories, LLC. 9.
On information and belief, defendant Ascend Laboratories, LLC is a corporation organized and existing under the laws of the State of New Jersey, having its principal place of business at 180 Summit Ave., Suite 200, Montvale, New Jersey 07645. On information and belief, Ascend Laboratories, LLC is a wholly-owned subsidiary of Alkem Laboratories Ltd. 10.
On information and belief, Ascend Laboratories, LLC is in the business of, among other things, formulating, developing, manufacturing, marketing, and selling generic copies of branded pharmaceutical products for the United States market, including in Delaware.
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, Title 35, United States Code. The Court has subject matter jurisdiction over this action pursuant to the provisions of 28 U.S.C. §§ 1331, 1338(a), 2201, and 2202. 12.
Based on the facts and causes alleged herein, and for additional reasons to be further developed through discovery, this Court has personal jurisdiction over the Defendants. 13.
This Court has personal jurisdiction over Defendants by virtue of the fact that,
, they have committed — or aided, abetted, induced, contributed to, or participated in the commission of — the tortious act of patent infringement that has led and/or will lead to foreseeable harm and injury to Acorda, a Delaware corporation, and to Alkermes. 14.
This Court has personal jurisdiction over Alkem Laboratories Ltd. On information and belief Alkem Laboratories Ltd. regularly does or solicits business in Delaware, engages in other persistent courses of systematic conduct in Delaware, and/or derives substantial revenue from services or things used or consumed by Alkem Laboratories Ltd. or its affiliates