Defendant has infringed and continue to directly infringe one or more claims of the ’111 patent in this judicial district and elsewhere in Illinois and the United States by orthrough the testing, making, using, offering for sale, selling, and/or importing of certain printingdevices, a list of which is attached as Exhibit B. Defendant has been, and now is, directlyinfringing claims of the ’111 patent, including (for example, and without limitation) at leastclaims 17 and 18 of the ’111 patent, by or through the testing, making, using, offering for sale,selling, and/or importing of printing devices that are sold with,
, an internal printercontroller, an external data stream input port operative to receive an external data streamincluding automatic document selection data, a document construction module in communicationwith the internal printer controller, and a document data printing mechanism that printsdocument data in a designated document format.11.
APS has been damaged as a result of Defendant’s infringing conduct describedherein. Defendant is, thus, liable to APS in an amount that adequately compensates it forDefendants’ infringements, which, by law, cannot be less than a reasonable royalty, togetherwith interest and costs as fixed by this Court under 35 U.S.C. § 284.
APS hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules of CivilProcedure.
PRAYER FOR RELIEF
APS requests that the Court find in its favor and against Defendant, and that the Courtgrant APS the following relief:a. Judgment that one or more claims of the ’111 Patent have been infringed, eitherliterally and/or under the doctrine of equivalents, by Defendant;