Plaintiff has been damaged by Defendant’s infringement of the ‘210 patent in an amountto be determined at trial, and has suffered and will continue to suffer irreparable loss andinjury unless Defendant is permanently enjoined from infringing the ‘210 patent.
B. Infringement of the ‘515 Patent
Plaintiff incorporates the foregoing paragraphs as if fully set forth here.16.
Defendant has been, and is now, directly infringing and indirectly infringing by way of inducing infringement and/or contributing to the infringement of the ‘515 patent in theState of Texas, in this judicial district, and elsewhere within the United States by, amongother things, selling, offering for sale, or importing products and services covered by oneor more claims of the ‘515 patent, all to the injury of Plaintiff.17.
Defendant’s acts of infringement have been willful, deliberate, and in reckless disregardof Plaintiff’s patent rights, and will continue unless permanently enjoined by this Court.18.
Plaintiff has been damaged by Defendant’s infringement of the ‘515 patent in an amountto be determined at trial, and has suffered and will continue to suffer irreparable loss andinjury unless Aluratek is permanently enjoined from infringing the ‘515 patent.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Anu IP LLC respectfully prays for the following relief againstDefendant General Imaging Company.A. A judgment in favor of Plaintiff that Defendant has infringed the ‘210 and ‘515 patents;B. A permanent injunction, enjoining Defendant, along with its officers, directors,agents, servants, employees, affiliates, divisions, branches, subsidiaries, and parents from