Appendix 4

• Author: Kenneth Dorsney
• Pages: 575-579

575

A–4

COM PL AI NT

IN THE UNITED STATES DISTRICT COURT

[Name of District]

[DISTRICT COURT CAPTION]

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiffs [Name of Plaintiffs] (collectively, “Plaintiff”), for their complaint

against Defendant [Name of Defendant], hereby alleges as follows:

THE PARTIES

1. Plaintiff is a limited partnership organized under the laws of _____,

having its principal place of business at [Address].

2. Plaintiff 2 [Name of Plaintiff 2] is a company incorporated under the Laws

of _____ and _____, having a registered office at [Address].

3. Upon information and belief, Defendant 1 [Name of Defendant 1]is a

corporation organized under the laws of _____, having a place of business at

[Address].

4. Upon information and belief, Defendant 1a [Name of Defendant 1a] a

corporation organized under the laws of _____, having its principal place of business at

[Address].

5. Upon information and belief, Defendant 1b [Name of Defendant 1b] is a

company organized under the laws of_____, having a place of business at [Address].

6. Upon information and belief, Defendant 1c [Name of Defendant 1c] is a

company organized under the laws of_____, having a place of business at [Address].

Upon information and belief, Defendant 1b is a wholly-owned subsidiary of

Defendant 1c.

7. Upon information and belief, Defendant 1 is a wholly-owned subsidiary

of Defendant 1c.

7. Upon information and belief, Defendant 1a is a subsidiary of

Defendant 1c.

8. Upon information and belief, Defendant 1b is the marketing arm of

Defendant 1c and is engaged on behalf of Defendant 1c in the marketing and sales of

pharmaceutical products in the United States and elsewhere.

9. Upon information and belief, the acts of Defendant 1 complained of herein

were done at the direction of, with the authorization of, and with the cooperation,

participation and assistance of, Defendant 1c, Defendant 1b and/or Defendant 1a.

JURISDICTION AND VENUE

10. Upon information and belief, Defendants sell various products and do

business throughout the United States, including within this District.