Subject matter jurisdiction is conferred upon this Court by 28 U.S.C. §§ 1331 and1338(a).6.
Personal jurisdiction exists generally over Defendants because Defendants havesufficient minimum contacts with this forum as a result of business conducted in the State of Connecticut. Defendants have sold and continue to sell their infringing products in the District of Connecticut.7.
Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b).
United States Patent Number 7,611,270, entitled “Lighthead Mounting Structure,” acopy of which is attached hereto as Exhibit A (hereinafter “the ‘270 Patent”), was duly and legallyissued by the U.S. Patent and Trademark Office on November 3, 2009 and named as inventors JonH. Lyons and Richard H. Morrow, both residents of Connecticut.9.
Plaintiff is, and at all times relevant has been, the lawful owner of all right, title andinterest in and to the ‘270 Patent, including all rights to recover for past infringement thereof byvirtue of an assignment from inventors Jon H. Lyons and Richard H. Morrow, duly executed onSeptember 4, 2007 and recorded in the Assignment Division of the United States Patent andTrademark Office at reel/frame 019836/0918.10.
The ‘270 patent is valid and enforceable.11.
Plaintiff has marked its products embodying the invention claimed in the ‘270 patentin accordance with 35 U.S.C. § 287.12.
Defendant’s have been infringing and are continuing to infringe, directly andindirectly by way of inducement and/or contributory infringement, literally and/or under the doctrineof equivalents, the ‘270 Patent under 35 U.S.C. § 271 by manufacturing, using, offering to sell,