2systems, such as Redbox kiosks, installed in numerous retail locations. On information and belief, Defendant does business on a regular basis in Illinois and in this District, including making, using, selling and/or offering for sale its wireless interactive consumer video systems in Illinois and this District which infringe RTC’s rights under the patent asserted herein.
JURISDICTION AND VENUE
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 1
., and particularly 35 U.S.C. §§ 271 and 281. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). Personal jurisdiction over Defendants is proper in this Court. 4.
Venue is proper in this District in accordance with 28 U.S.C. §§ 1391(b)-(c) and § 1400(b).
INFRINGEMENT OF U.S. PATENT NO. 5,608,449
On March 4, 1997, the United States Patent and Trademark Office duly and legally issued United States Patent No. 5,608,449 (“the ‘449 patent”) entitled “Wireless Interactive Consumer Video System.” RTC is the owner of the ‘449 patent, by virtue of assignment of all rights, title and interest to the ‘449 patent. A true and correct copy of the ‘449 patent is attached to this Complaint as Exhibit A. 6.
Defendant has been and still is infringing and inducing infringement of the ‘449 patent by making, using, offering to sell, selling, and/or importing wireless interactive consumer video systems, including, but not limited to its self-service kiosk systems depicted at http://www.flextronics.com/business_groups/selfservice/default.aspx and Redbox kiosks, and/or engaging in activities related to wireless interactive consumer video systems that are covered by one or more claims of the ‘449 patent, and/or inducing others to make, use, offer to sell and/or sell such systems and/or engage in such activities.