In the United States District Court for the District of Delaware
Case 1:17-cv-00595-LPS-CJB Document 18 Filed 08/23/17 Page 1 of 50 PageID #: 98 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE HANESBRANDS INC., Plaintiff, C.A. No. 1:17-595-LPS-CJB v. JURY TRIAL DEMANDED JACQUES MORET, INC., Defendant. FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT AND ANSWER TO DEFENDANT’S AMENDED COUNTERCLAIMS Plaintiff Hanesbrands Inc. (“Hanesbrands”) for its Complaint against Jacques Moret, Inc. (“Jacques Moret”), and its answer to Defendant Jacques Moret’s Amended Counterclaims, states as follows: The Nature of the Action 1. This is an action for infringement of United States Patent Nos. 6,125,664; 6,685,534; 7,163,432; 6,790,122; and 7,169,011 (collectively, “the Asserted Patents”) under 35 U.S.C. § 271. The Parties 2. Hanesbrands is a Maryland corporation, with a principal place of business at 1000 East Hanes Mill Road, Winston-Salem, North Carolina 27105. 3. On information and belief, Jacques Moret is a Delaware corporation, with a principal place of business at 1411 Broadway, 8th Floor, New York, NY 10018. Service upon Jacques Moret may be made by serving its registered agent for service of process, The Corporation Trust Company, 1209 Orange Street, Wilmington, DE 19801. Case 1:17-cv-00595-LPS-CJB Document 18 Filed 08/23/17 Page 2 of 50 PageID #: 99 4. On information and belief, Jacques Moret is in the business of selling basic and fashion apparel for men, women and children, and derives revenue from sales and distribution of the products at issue in the District.
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