3of Google Storage and all reasonably similar products. On information and belief, DefendantGoogle indirectly infringes by actively inducing its customers to use Google Storage and allreasonably similar products. On information and belief, Defendant Google knew or should haveknown its actions would induce and/or contribute to infringement of the ’968 patent.10.
On information and belief, Defendant Google will continue to infringe the ’968patent unless enjoined by this Court.11.
Defendant Google’s acts of infringement have damaged Titanide in an amount tobe proven at trial, but in no event less than a reasonable royalty. Defendant Google’sinfringement of Titanide’s rights under the ’968 patent will continue to damage Titanide causingirreparable harm, for which there is no adequate remedy at law, unless enjoined by this Court.
CLAIM 2INFRINGEMENT OF U.S. PATENT 6,735,623
Titanide re-alleges and incorporates by reference the allegations set forth in theParagraphs above as if fully set forth herein.13.
On May 11, 2004, United States Patent Number 6,735,623 (“the ’623 patent”)entitled “Method and System for Accessing a Remote Storage Area” was duly and lawfullyissued by the United States Patent and Trademark Office. A true and correct copy of the ’623patent is attached hereto as
Titanide is the owner and assignee of all right, title, and interest in and to the ’623patent, including the right to assert all causes of action arising under said patent and the right toany remedies for infringement of it.15.
On information and belief, Defendant Google has been and now is infringing the’623 patent in the State of Texas, in this judicial district, and elsewhere in the United States by,among other things, making, using, importing, offering to sell, and/or selling in the United Statesdata storage products and/or services that embody the inventions claimed in the ’623 patent,including but not limited to Google Storage and all reasonably similar products. On informationand belief, Defendant Google indirectly infringes by contributing to its customers’ infringement