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Plaintiff, v. STRATASYS, INC., Defendant.
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Civil Action No. _____________ JURY TRIAL DEMANDED
COMPLAINT Plaintiff Leseman, LLC (“Leseman”), for its Complaint against Stratasys, Inc. (“Stratasys”), alleges as follows. THE PARTIES 1. Leseman is a limited liability company organized under the laws of the
State of Minnesota, with a principal place of business in Maple Grove, Minnesota. 2. On information and belief, Stratasys is a corporation organized under the
laws of the state of Delaware with its principal place of business located at 7665 Commerce Way, Eden Prairie, Minnesota. JURISDICTION AND VENUE 3. This is a civil action for patent infringement arises under the patent laws of
the United States, Title 35 of the United States Code Section 1 et. seq.
4. and 1338(a). 5.
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
This Court has personal jurisdiction over Stratasys because Stratasys
conducts substantial and continuous business in this judicial district, including business conducted at its facility located at 7665 Commerce Way, Eden Prairie, Minnesota. This Court has personal jurisdiction over Stratasys because it has committed acts of infringement giving rise to this action in this District and has established minimum contacts within this District such that the exercise of jurisdiction over Stratasys would not offend traditional notions of fair play and justice. 6. Venue is proper in this District under 28 U.S.C. §§ 1391(b) and (c) and
1400(b) because Stratasys resides in this District and has committed acts of infringement in this District and has a regular and established place of business in this District. BACKGROUND 7. On February 12, 2008, the United States Patent Office issued Patent No.
7,329,113 (“the ‘113 Patent”), entitled, “Adjustable Extrusion Die.” A true and correct copy of the ‘113 Patent is attached hereto as Exhibit A. 8. Leseman is the owner by assignment of all right, title in interest in the ‘113
Patent, which is valid, subsisting and in full force and effect.
COUNT I (Infringement of the ‘113 Patent) 9. Leseman realleges and incorporates herein the allegations set forth in
Paragraphs 1-8. 10. Stratasys has directly infringed at least claim 1 of the ‘113 Patent pursuant
to 35 U.S.C. § 271(a), literally or under the doctrine of equivalents, by making, using, selling, and/or offering for sale in the United States and without authority products that infringe such claims. In particular, Stratasys has used, in Minnesota, extrusion dies covered by at least Claim 1 of the ‘113 Patent, to manufacture extruded filament used in cartridges for Stratasys 3-D printers. 11. Leseman has suffered damages as a result of Stratasys’s infringement of the
‘113 Patent. In addition, Leseman will continue to suffer irreparable harm unless this Court enjoins Stratasys from infringing the ‘113 Patent. PRAYER FOR RELIEF For the above reasons, Leseman respectfully requests that this Court grant the following relief in its favor and against Stratasys: (a) A judgment in favor of Leseman that Stratasys has infringed (either literally or under the doctrine of equivalents) one or more claims of the ‘113 Patent; (b) A preliminary and/or permanent injunction enjoining Stratasys and its officers, directors, agents, servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in active concert or participation with it, from infringing the ‘113 Patent;
A judgment and order requiring Stratasys to pay to Leseman its damages, costs, expenses, and pre-judgment and post-judgment interest for Stratasys’s infringement of the ‘113 Patent; and
Such other and further relief as the Court deems just and proper.
DEMAND FOR JURY TRIAL Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Leseman demands a trial by jury of all issues so triable.
Dated: February 10, 2014
WINTHROP & WEINSTINE, P.A.
By s/Devan V. Padmanabhan Devan V. Padmanabhan (240126) Sri K. Sankaran (204304) WINTHROP & WEINSTINE 225 South Sixth Street, Suite 3500 Minneapolis, MN 55402 Telephone: (612) 604-6400 Facsimile: (612) 604-6800 firstname.lastname@example.org
Attorneys for Plaintiff Leseman, LLC