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Case 1:99-mc-09999 Document 92

Filed 03/02/10 Page 5 of 16

covered by one or more claims of the ‘331 Patent, including but not limited to the Accused

Products.

18.

Defendants have contributed to and/or induced and will continue to contribute to

and/or induce the infringement of the ‘331 Patent by others in this District and elsewhere in the

United States, with the direct infringement being accomplished by end users of at least the

Accused Products.

19.

Apple has been and continues to be damaged by Defendants’ infringement of the

‘331 Patent, in an amount to be determined at trial.

20.

Apple has suffered irreparable injury for which there is no adequate remedy at

law and will continue to suffer such irreparable injury unless Defendants’ infringement of the

‘331 Patent is enjoined by this Court.

21.

Defendants’ infringement of the ‘331 Patent is exceptional and entitles Apple to

attorneys’ fees and costs incurred in prosecuting this action under 35 U.S.C. § 285.

COUNT II - INFRINGEMENT OF U.S. PATENT NO. 7,479,949

  • 22.

    Paragraphs 1 through 21 are incorporated by reference as if fully stated herein.

  • 23.

    The ‘949 Patent, entitled “Touch Screen Device, Method, And Graphical User

Interface For Determining Commands By Applying Heuristics,” was duly and legally issued on

January 20, 2009 by the United States Patent and Trademark Office. A copy of the ‘949 Patent

is attached hereto as Exhibit B.

24.

Apple is the exclusive and current owner of all rights, title, and interest in the

‘949 Patent, including the right to bring this suit for injunctive relief and damages.

25.

Defendants have infringed and are infringing the ‘949 Patent by making, using,

selling, offering for sale, and/or importing, without authority, products and services that are

5

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