36. Philips incorporates by reference each and every allegation set forth in this Complaint.
37. United States Letters Patent No. 8,537,231 (“the ’231 patent”
issued on September 17, 2013 to Gerhardus Engbertus Mekenkamp and Tim Dekker. A copy of the ’231 patent, entitled “User Interface System Based on Pointing Device” is attached hereto as Exhibit B.
38. Koninklijke Philips N.V. is the owner by assignment of the ’231 patent.
39.
Philips provided actual notice of the ’231 patent to Nintendo
no later than the filing date of this Complaint.
40.
Nintendo has had actual knowledge of the ’231 patent
no later than the filing date of this Complaint.
41.
Nintendo has had actual knowledge of its infringement of the ’231 patent
no later than the filing date of this Complaint.
42. Upon information and belief, Nintendo has directly infringed, induced infringement of, and contributed to infringement of one or more claims of the ’231 patent, both literally and under the doctrine of equivalents, by making, using, selling, offering for sale, and importing HCI products within the United States.
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Dated: May 14, 2014