practices one or more of the claims of the ‘371 Patent, all without Kittrich’s consent.
As adirect and proximate result of Defendant’s infringement of the ‘371 Patent, Plaintiff issuffering damages and irreparable injury for which it has no adequate remedy at law.10.
As a direct and proximate result of Defendant’s infringement of the ‘371patent, Kittrich has been and continues to be damaged in an amount to be proven at trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Kittrich prays for judgment against Defendant FriedlandBros. as follows:
for a judicial determination and declaration that Defendant has infringed U.S.Letters Patent No. 5,874,371;
for a judicial determination and decree that Defendant’s infringement of U.S.Letters Patent No. 5,874,371 is and has been willful;
for damages resulting from Defendant’s past and present infringement of U.S.Letters Patent No. 5,874,371 and the trebling of such damages because of thewillful and deliberate nature of Defendant’s infringement;
for a temporary restraining order, preliminary injunction and/or permanentinjunction ordering Defendant, its officers, directors, shareholders, agents,servants, employees and all other entities and individuals acting in concert withthem or on their behalf:1. to refrain from directly or indirectly making or causing to be made, orselling or causing to be sold, or importing, or offering for sale, fulfillingorders for, or using or causing to be used, displaying or causing to bedisplayed at a store, on television or on an internet website, any ZipGrip Products embodying any of the claims of the ’371 patent;2. to refrain from directly or indirectly printing, distributing, posting, ordisplaying on the internet or television, or causing to be printed,distributed or posted, any printed material or computer readable