La Cruz Boulevard, Santa Clara, California 95050.4.
On information and belief, Defendant Appthority, Inc. (“Defendant” or“Appthority”) is a corporation organized and existing under the laws of the State of Delaware,conducts business throughout the United States, including in this judicial district, and has itsprincipal place of business at 1200 Seaport Boulevard, Redwood City, California 94063.
JURISDICTION AND VENUE
This is an action for patent infringement arising under the patent laws of theUnited States, including 35 U.S.C. §§ 271 and 281-285. This Court has exclusive jurisdictionover the subject matter of this action under 28 U.S.C. § 1331 and § 1338(a).6.
Venue is proper in the United States District Court for the District of Massachusetts, pursuant to at least 28 U.S.C. §§ 1391(b) and (c), and 1400(b).7.
This Court has personal jurisdiction over Defendant for reasons including that, oninformation and belief, Defendant regularly does business and sells infringing products tocustomers, including technology partners, in Massachusetts, both directly and indirectly, andsuch sales constitute continuous and systematic contacts with Massachusetts.
FIRST CLAIM FOR RELIEF(Patent Infringement of U.S. Patent No. 5,854,924)
Plaintiffs incorporate by reference the allegations contained in paragraphs 1through 7 above as though set forth fully herein.9.
On December 29, 1998, United States Patent No. 5,854,924 (“the ‘924 patent”)entitled “Static Debugging Tool and Method” was duly and legally issued. A true and correctcopy of the ‘924 patent is attached hereto as Exhibit A.10.
Rovi is the lawful owner of the ‘924 patent, by assignment.