. Before Amazon “de-listed” M-Edge from Amazon.com, M-Edge’s productsroutinely constituted at least 20 of the top 25 most popular products in Amazon’s “Kindle Store”.One such product was M-Edge’s innovative lighted jacket which M-Edge patented.3.AmazonServices LLC is a Nevada limited liability company with its corporateheadquarters and principal place of business at 1200 12
Avenue Street, Suite 1200, Seattle,Washington 98114-2734. Amazon Services LLC has appointed as its registered agentCorporation Service Company, 300 Deschutes Way SW, Suite 304, Tumwater, Washington08501.4.Defendant Amazon.com Inc. is a Delaware corporation with its corporateheadquarters and principal place of business at1200 12
Avenue South, Suite 1200, Seattle,Washington 98114-2734. Amazon.com, Inc.has appointed as its registered agent CorporationService Company, 300 Deschutes Way SW, Suite 304, Tumwater, Washington 08501.Amazon Services LLC and Amazon.com, Inc. are collectively referenced as “Amazon.”
JURSIDICTION AND VENUE
5.This Court has jurisdiction over the subject matter of this action pursuant to 28U.S.C.§§1331 and 1367(a).6.Amazontransactssubstantial business in this judicial district and hascommittedacts of infringement in this judicial district, at least by soliciting advertising from Marylandcompanies and by operating Internet websites and conducting business over those Internetwebsites that are accessible to residents of Maryland, includingwww.amazon.com,which offersfor sale products which infringe the patent-in-suit. Amazon also has directed its tortious activityagainst a Maryland company, resulting in injury within Maryland.7.Venue is proper in this district under 28 U.S.C. §§ 1391 and 1400(b).
Case 1:11-cv-03332-MJG Document 10 Filed 12/22/11 Page 2 of 15