3the laws of the State of Delaware, with its principal place of business at 12920 SE 38
Street,Bellevue, Washington. Defendant and/or one or more of its affiliates provides VoIP Services(“the VoIP Services”) as described below to subscribers, which VoIP Services, on informationand belief, may or may not be marketed or provided under a specific name or trade name. TheVoIP Services include but are not limited to the T-Mobile@Home service.
JURISDICTION AND VENUE
This Court has exclusive original jurisdiction of the subject matter of this actionunder 28 U.S.C. § 1338(a).
This Court has personal jurisdiction over Defendant. Defendant is incorporatedunder the laws of the State of Delaware. In addition, Defendant has conducted and does conductregular and ongoing business in Delaware. Upon information and belief, Defendant, directly orthrough intermediaries (including distributors, agents, retailers, subsidiaries, affiliates, andothers) ships, distributes offers for sale, sells, advertises, operates and/or uses its VoIP productsand services in the United States and in Delaware. On information and belief, Defendant hascommitted acts of patent infringement in Delaware, including, making, using, offering for sale,and/or selling infringing VoIP products or services in Delaware. These products or services havebeen used and continued to be used and/or purchased by consumers in Delaware and consumersin Delaware benefit from these products and services.
Venue is proper under 28 U.S.C. §§ 1391 and 1400(b) because both BCT andDefendants are incorporated under the laws of the State of Delaware. In addition, uponinformation and belief, Defendant regularly conducts business in Delaware and has made, used,offered to sell, and sold, and/or continue to make, use, offer to sell, and/or sell products and/orservices within Delaware, including without limitation, VoIP products and services which, upon