2.On information and belief, PSKW is a New Jersey limited liability companyhaving a principal place of business at 1 Crossroads Drive, Third Floor, Bedminster, New Jersey07921.3.On information and belief, Triple I is a New Jersey corporation having a principal place of business at 350 Starke Road, Carlstadt, New Jersey 07072.
JURISDICTION AND VENUE
4.This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§ 1331 and 1338(a) because this action arises under the patent laws of the United States, 35U.S.C. § 101,
5.Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b)(c) and1400(b).
6.On April 12, 2011, United States Patent No. 7,925,531 (“the ’531 patent”) entitled“Method of Delivering Goods and Services Via Media,” was duly and legally issued by theUnited States Patent and Trademark Office. A true and accurate copy of the ’531 patent isattached hereto as Exhibit A.7.TrialCard is the owner by assignment of all right, title and interest in and to the’531 patent.
COUNT I –PATENT INFRINGEMENT BY PSKW
8.The averments of paragraphs 1 through 7 above are incorporated herein byreference.9.On information and belief, PSKW has infringed and continues to infringe the ’531 patent in violation of 35 U.S.C. §271 by its marketing of programs promoting pharmaceutical