NSJ's Infringement of the
9. On July 29, 2003, the '008 Patent was duly and legally issued for aninvention entitled "Static Mixer." The '008 Patent is assigned to Sulzer Mixpac AG. A copyof the '008 patent is attached as Exhibit A.10. Defendant NSJ
the '008 Patent either directly, contributorily, orby inducing infringement by making, using, offering for sale, or importing industrial staticmixers in the United States.11. Defendant has imported, sold, offered for sale or delivered into thisjudicial district static mixers that
the '008 patent.
COUNTIINFRINGEMENT OF U.S. PATENT NO. 6,599,008
12. Plaintiffs reallege and incorporate herein by reference the allegations inparagraphs
of its complaint.13. By using, importing, selling, or offering to sell their static mixers,Defendant has infringed one or more claims of the '008 Patent directly, contributorily, orthrough inducement. Defendant has engaged in the foregoing conduct with respect to thepatented invention in the United States without authority from Mixpac during the term of the'008 Patent.14. Defendant will not stop using, selling, and/or offering for sale theproducts at issue to avoid infringing the '008 Patent.15. Defendant's infringement has been deliberate, willful, and wanton, andwith
knowledge of the '008 Patent.