Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 1 of 20 PageID #: 1
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`INNOVAMED HEALTH LLC and
`PRECISION HOLDINGS USA INC.,
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`v.
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`MANAMED INC.,
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`Plaintiffs,
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`Defendant.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`§
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`Case No. 4:22-cv-359
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR PATENT INFRINGEMENT
`Plaintiffs Innovamed Health LLC (“Innovamed”) and Precision Holdings USA Inc.
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`(“Precision”) (collectively, “Plaintiffs”) for its Complaint against Defendant ManaMed Inc.
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`(“ManaMed” or “Defendant”) alleges as follows:
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`THE PARTIES
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`Innovamed is a limited liability company organized and existing under the laws of
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`1.
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`Texas with a principal place of business at 10 Westelm Garden, San Antonio, Texas 78230-2632.
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`2.
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`Precision is a corporation organized and existing under the laws of California with
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`a principal place of business at 2217 Plaza Dr. Rocklin, California 95765.
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`3.
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`Upon information and belief, ManaMed is a corporation organized and existing
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`under the laws of Nevada with a principal place of business at 5240 W Charleston Blvd, Las
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`Vegas, Nevada 89146. Upon information and belief, ManaMed has a place of business in this
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`District at 2612 Sirius Dr., Denton, Texas 76208.
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`1
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 2 of 20 PageID #: 2
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`JURISDICTION AND VENUE
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`This is an action for patent infringement arising under the patent laws of the
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`4.
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`United States, 35 U.S.C. §§ 1, et seq. This Court has jurisdiction over this action pursuant to 28
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`U.S.C. §§ 1331 and 1338(a).
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`5.
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`Venue is proper in this Judicial District pursuant to 28 U.S.C. §§ 1391 and
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`1400(b). Upon information and belief, ManaMed maintains a regular and established physical
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`place of business in this District including, at least, a distribution center located at 2612 Sirius
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`Dr., Denton, Texas 76208. Upon information and belief, ManaMed employs full-time personnel
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`in this District, at least at this location. Furthermore, upon information and belief, ManaMed is
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`registered to conduct business in the state of Texas and has a Texas Taxpayer Number of
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`32079024744. ManaMed has conducted and continues to conduct business in this District, and
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`has committed and continues to commit acts of patent infringement in this District.
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`6.
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`This Court has personal jurisdiction over ManaMed. Upon information and
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`belief, ManaMed regularly conducts business and has committed acts of patent infringement
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`and/or has induced acts of patent infringement by others in this District and/or has contributed to
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`patent infringement by others in this District, the state of Texas, and elsewhere in the United
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`States, including with respect to its products discussed below.
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`7.
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`ManaMed is subject to this Court’s jurisdiction pursuant to due process and/or the
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`Texas Long Arm Statute due at least to its substantial business in this State and District,
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`including (a) at least part of its past infringing activities, (b) regularly doing or soliciting business
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`in Texas, and/or (c) engaging in persistent conduct and/or deriving substantial revenue from
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`goods and services provided to customers in Texas.
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`2
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 3 of 20 PageID #: 3
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`PATENTS-IN-SUIT
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`8.
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`On August 28, 2018, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent 10,058,475 (“the ’475 Patent”) entitled “Portable Intermittent
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`Pneumatic Compression System.” A true and correct copy of the ’475 Patent is attached hereto
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`as Exhibit A.
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`9.
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`On February 9, 2021, the United States Patent and Trademark Office duly and
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`legally issued U.S. Patent 10,912,704 (“the ’704 Patent”) entitled “Portable Intermittent
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`Pneumatic Compression System.” A true and correct copy of the ’704 Patent is attached hereto
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`as Exhibit B.
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`10.
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`Innovamed is the sole and exclusive owner of all right, title, and interest to and in
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`the ’704 Patent and the ’475 Patent (collectively, the “Patents-in-Suit”), and holds the exclusive
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`right to take all actions necessary to enforce its rights to the Patents-in-Suit, including the filing
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`of this patent infringement lawsuit. Innovamed also has the right to recover all damages for past,
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`present, and future infringement of the Patents-in-Suit and to seek injunctive relief as appropriate
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`under the law.
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`11.
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`Precision is an exclusive licensee of the Patents-in-Suit, with the license running
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`to Precision’s wholly owned subsidiaries.
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`FACTUAL ALLEGATIONS
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`12.
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`The technology of the Patents-in-Suit was developed at Innovamed. Innovamed’s
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`founders recognized the need for a portable compression device that could help alleviate deep
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`vein thrombosis.
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`3
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 4 of 20 PageID #: 4
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`13.
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`Innovamed filed Provisional Application No. 61/794,235 on March 15, 2013. On
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`March 17, 2014, Innovamed then filed Utility Application No. 14/217,213 therefrom, which
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`issued as the ’475 Patent on August 28, 2018.
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`14.
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`Innovamed filed Utility Application No. 16/045,870 on July 26, 2018, which was
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`a continuation of Utility Application No. 14/217,213, and issued as the ’704 Patent on February
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`9, 2021.
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`15.
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`The ’475 Patent is generally directed to an intermittent pneumatic compression
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`system that is wrapped around a patient’s extremity, such as a leg, for prophylactic compression
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`of the leg to avoid deep vein thrombosis. The compression system of the ’475 Patent generally
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`provides for a portable battery-operated system that avoids tubes that create a tripping hazard for
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`the patient. The compression system is generally arranged with an inflatable bladder having a
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`divider creating at least two sections and having a pressure sensor for measuring air pressure.
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`16.
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`The ’704 Patent is generally directed to an intermittent pneumatic compression
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`system that is wrapped around a patient’s extremity, such as a leg, for prophylactic compression
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`of the leg to avoid deep vein thrombosis. The compression system of the ’704 Patent generally
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`provides for a portable battery-operated system that avoids tubes that create a tripping hazard for
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`the patient. The compression system is generally arranged with an inflatable bladder having a
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`divider creating at least two sections and having a pressure sensor for measuring air pressure, and
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`where the system module for controlling the system is mounted onto the bladder.
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`17.
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`In or about January 2014, Innovamed licensed its portable compression device
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`technology to DJO, LLC (“DJO”), a global medical device company. Upon information and
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`belief, incorporating the innovations of the ’475 Patent, DJO marketed and sold the VenaPro®, a
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`portable compression device for post-operative deep vein thrombosis.
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`4
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`18.
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`Upon information and belief, ManaMed was incorporated in California on
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`February 6, 2015, four months after the application leading to the ’475 Patent was first
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`published, on October 9, 2014, and a year after Innovamed first licensed DJO to distribute
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`Innovamed’s portable compression device technology under the VenaPro® label.
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`19.
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`Upon information and belief, Trevor Theriot (“Theriot”), John Lasso (“Lasso”),
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`and Joseph Horton (“Horton”) are the principals, officers, and/or directors of ManaMed. Upon
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`information and belief, Theriot, Lasso, and Horton previously were distributors of DJO’s
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`VenaPro® product line, which incorporates the innovations described in the ’475 Patent and
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`’704 Patent.
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`20.
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`Upon information and belief, from 2007 to 2015, DJO employed Horton as a
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`Vascular Sales Specialist. Upon information and belief, in his role as DJO salesman, Horton was
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`responsible for selling the VenaPro® product line. Furthermore, upon information and belief,
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`Theriot and Lasso were outside sales representatives who both sold the VenaPro® product line.
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`Upon information and belief, Horton, Theriot, and Lasso were also familiar with the structure
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`and benefits of the VenaPro® product line.
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`21.
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`Upon information and belief, ManaMed began manufacturing, distributing, and
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`selling its competing product in 2016 called the “PlasmaFlow.”
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`22.
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`Upon information and belief, Grandway Healthcare Limited is a manufacturer for
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`ManaMed.
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`23.
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`Upon information and belief, Medline Industries, Inc. is a distributor for
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`ManaMed. Upon information and belief, ManaMed also distributes in the United States its
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`PlasmaFlow product under the label “Hemo-Force Mobile” by Medline Industries, Inc.
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`24. ManaMed has manufactured, used, marketed, distributed, sold, offered for sale,
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`5
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 6 of 20 PageID #: 6
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`exported from, and/or imported into the United States, products that infringe the Patents-in-Suit.
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`For example, portable deep vein thrombosis compression products such as the PlasmaFlow and
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`PlasmaFlight, upon information and belief, infringe the Patents-in-Suit.
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`1
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`2
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`25. ManaMed has infringed and is continuing to infringe the Patents-in-Suit by
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`making, using, selling, offering to sell, importing, and/or by actively inducing others to make,
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`use, sell, offer to sell and/or import, accused products that comprise and utilize portable deep
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`vein thrombosis compression technology. The accused products include, but are not limited to,
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`the PlasmaFlow and the PlasmaFlight (“the Accused Products”).
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`26.
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`Upon information and belief, ManaMed had knowledge of the ’475 Patent,
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`because Theriot, Lasso, and Horton each sold DJO’s VenaPro® product line in 2014 and were
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`aware of “patents pending” on those devices. On further information and belief, ManaMed had
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`knowledge of the patent application that led to the ’475 Patent, which published on October 9,
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`2014, four months before Theriot, Lasso, and Horton formed ManaMed to compete with the
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`VenaPro® product line. On further information and belief, ManaMed had knowledge of the
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`1 https://www.manamed.com/products/plasmaflow-compression-device
`2 https://www.manamed.com/products/plasmaflight
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`6
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 7 of 20 PageID #: 7
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`’475 Patent at least in 2018 and had knowledge that the ’475 Patent protected the VenaPro®
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`product line. ManaMed also had knowledge of the ’475 Patent as a result of the filing of this
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`Complaint.
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`27.
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`Upon information and belief, ManaMed also had knowledge of the ’704 Patent,
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`which is a continuation of the patent application that issued as the ’475 Patent. On further
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`information and belief, ManaMed had knowledge of the ’704 Patent at least in 2021 and had
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`knowledge that the ’704 Patent protected the VenaPro® product line. ManaMed also had
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`knowledge of the ’704 Patent as a result of the filing of this Complaint.
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`28. ManaMed’s infringement of the Patents-in-Suit is willful. ManaMed continues to
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`commit acts of infringement despite a high likelihood that its actions constitute infringement, and
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`ManaMed knew or should have known that its actions constituted an unjustifiably high risk of
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`infringement.
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`COUNT I
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`(Infringement of the ’475 Patent)
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`29.
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`Plaintiffs reallege and incorporate by reference the foregoing paragraphs as if
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`fully set forth herein.
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`30.
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`Plaintiffs’ have not licensed or otherwise authorized ManaMed to make, use, offer
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`for sale, sell, or import any product(s) that embody the inventions of the ’475 Patent.
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`31. ManaMed has and continues to directly infringe the ’475 Patent, either literally or
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`under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by
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`making, using, offering to sell, selling, and/or importing into the United States products that
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`satisfy each and every limitation of one or more claims of the ’475 Patent. Upon information
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`7
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`and belief, these products include at least the Accused Products, such as those which comprise
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`portable deep vein thrombosis compression technology.
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`32.
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`For example, ManaMed has and continues to directly infringe at least claim 16 of
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`the ’475 Patent by making, using, offering to sell, selling, and/or importing into the United States
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`products that comprise a portable intermittent pneumatic compression system comprising: an air
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`pumping module comprising a power supply, an electronic control unit, and a valve with an
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`inflation port, wherein said electronic control unit is adapted to control said valve; and a flexible
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`inflatable wrap comprising an inflatable bladder with a first end and a second end that is coupled
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`to said inflation port, and a surface that is adapted to contact a user, wherein said flexible
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`inflatable wrap is directly coupled to said air pumping module; wherein said inflatable bladder
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`comprises a first section and a second section separated by a divider that provides a passageway
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`from said first section to said second section, wherein said inflation port is connected within said
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`first section adjacent to said first end of said inflatable bladder and near a surface of said divider,
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`and a pressure sensor that is adapted to measure an air pressure of said inflatable bladder is
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`connected within said second section adjacent to said first end of said inflatable bladder and near
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`an opposite surface of said divider, wherein said air flows from said inflation port to said
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`pressure sensor through said first section; and wherein said valve is adapted to enable air to flow
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`only from said inflation port to said inflatable bladder through a first connection line to said first
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`section to inflate said inflatable bladder, wherein said pressure sensor measures said air pressure
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`of said inflatable bladder through a second connection line to said second section, wherein the
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`second connection line is only used for measuring the air pressure of said inflatable bladder.
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`33. ManaMed’s PlasmaFlow is an exemplary product that infringes at least claim 16
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`of the ’475 Patent. Upon information and belief, other products provided by ManaMed infringe
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`the ’475 Patent.
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`34.
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`The Accused Products are portable intermittent compression systems comprising
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`an air pumping module comprising a power supply, an electronic control unit, and a valve with
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`an inflation port. For example, upon information and belief, the ManaMed PlasmaFlow is a
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`portable intermittent pneumatic compression system that comprises an air pumping module
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`comprising a power supply, an electronic control unit, and a valve with an inflation port.
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`35.
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`The Accused Products comprise an electronic control unit that is adapted to
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`control the valve. For example, upon information and belief, the ManaMed PlasmaFlow has an
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`electronic control unit that is adapted to control the valve.
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`36.
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`The Accused Products comprise a flexible inflatable wrap comprising an
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`inflatable bladder with a first end and a second end that is coupled to the inflation port, and a
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`surface that is adapted to contact a user. For example, upon information and belief, the
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`ManaMed PlasmaFlow has a flexible inflatable wrap comprising an inflatable bladder with a first
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`end and a second end that is coupled to the inflation port, and a surface that is adapted to contact
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`a user.
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`37.
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`The Accused Products comprise a flexible inflatable wrap that is directly coupled
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`to the air pumping module. For example, upon information and belief, the ManaMed
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`PlasmaFlow has a flexible inflatable wrap that is directly coupled to the air pumping module.
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`38.
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`The Accused Products comprise an inflatable bladder with a first section and a
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`second section separated by a divider that provides a passageway from the first section to the
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`second section. For example, upon information and belief, the ManaMed PlasmaFlow has an
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`9
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`inflatable bladder with a first section and a second section separated by a divider that provides a
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`passageway from the first section to the second section.
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`39.
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`The Accused Products comprise an inflation port that is connected within the first
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`section adjacent to the first end of the inflatable bladder and near a surface of the divider. For
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`example, upon information and belief, the ManaMed PlasmaFlow has an inflation port that is
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`connected within the first section adjacent to the first end of the inflatable bladder and near a
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`surface of the divider.
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`40.
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`The Accused Products comprise a pressure sensor that is adapted to measure an
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`air pressure of the inflatable bladder and is connected within the second section adjacent to the
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`first end of the inflatable bladder and near an opposite surface of the divider. For example, upon
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`information and belief, the ManaMed PlasmaFlow has a pressure sensor that is adapted to
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`measure an air pressure of the inflatable bladder and is connected within the second section
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`adjacent to the first end of the inflatable bladder and near an opposite surface of the divider.
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`41.
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`The Accused Products comprise a system wherein air flows from the inflation
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`port to the pressure sensor through the first section. For example, upon information and belief,
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`the ManaMed PlasmaFlow comprises a system wherein air flows from the inflation port to the
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`pressure sensor through the first section.
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`42.
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`The Accused Products comprise a valve that is adapted to enable air to flow only
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`from the inflation port to the inflatable bladder through a first connection line to the first section
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`to inflate the inflatable bladder. For example, upon information and belief, the ManaMed
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`PlasmaFlow has a valve that is adapted to enable air to flow only from the inflation port to the
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`inflatable bladder through a first connection line to the first section to inflate the inflatable
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`bladder.
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`10
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`43.
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`The Accused Products comprise a pressure sensor that measures the air pressure
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`of the inflatable bladder through a second connection line to the second section. For example,
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`upon information and belief, the ManaMed PlasmaFlow has a pressure sensor that measures the
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`air pressure of the inflatable bladder through a second connection line to the second section.
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`44.
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`The Accused Products comprise a second connection line that is only used for
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`measuring the air pressure of the inflatable bladder. For example, upon information and belief,
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`the ManaMed PlasmaFlow has a second connection line that is only used for measuring the air
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`pressure of the inflatable bladder.
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`45.
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`Upon information and belief, ManaMed had knowledge of the ’475 Patent and
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`notice of their infringement of the ’475 Patent no later than August 28, 2018. ManaMed also had
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`knowledge of the ’475 Patent and notice of their infringement of the ’475 Patent as a result of the
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`filing of this Complaint.
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`46.
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`Upon information and belief, ManaMed has indirectly infringed and continues to
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`indirectly infringe the ’475 Patent by actively inducing and contributing to the infringement of
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`the ’475 Patent by others, such as ManaMed’s customers and end-users of the Accused Products
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`in this District and elsewhere in the United States.
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`47.
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`For example, upon information and belief, ManaMed’s customers and end-users
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`directly infringe, either literally or under the doctrine of equivalents, through their use,
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`manufacture, importation, sell, and/or offer for sale the inventions claimed in the ’475 Patent.
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`Upon information and belief, ManaMed induces this direct infringement through its affirmative
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`acts of manufacturing, importing, selling, distributing, and/or otherwise making available the
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`Accused Products, and providing instructions, documentation, and other information to
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`customers and end-users suggesting that they make, import, sell, offer for sale, and/or use the
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`11
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`Accused Products in an infringing manner, including technical support, marketing, product
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`manuals, advertisements, and online documentation.3 Upon information and belief, because of
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`ManaMed’s inducement, ManaMed’s customers and end-users make, import, sell, offer for sale,
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`and/or use the Accused Products in a way ManaMed intends and directly infringe the ’475
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`Patent. Upon information and belief, ManaMed performs these affirmative acts with knowledge
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`of the ’475 Patent and with the intent, or willful blindness, that the induced acts directly infringe
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`the ’475 Patent.
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`48.
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`Upon information and belief, ManaMed’s affirmative acts of manufacturing,
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`importing, selling, and/or offering to sell the Accused Products in this District and elsewhere in
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`the United States and causing the Accused Products to be manufactured, imported, used, sold,
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`and/or offered for sale contributes to the direct infringement of the ’475 Patent by others. Upon
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`information and belief, the Accused Products are material to the invention of the ’475 Patent, are
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`not staple articles or commodities of commerce, have no substantial non-infringing uses, and are
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`known by ManaMed to be especially made or adapted for use in the infringement of the ’475
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`Patent. Upon information and belief, ManaMed performs these affirmative acts with knowledge
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`of the ’475 Patent and with intent, or willful blindness, that they cause the direct infringement of
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`the ’475 Patent.
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`49.
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`Plaintiffs have suffered damages, and will continue to suffer damages, as a result
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`of ManaMed’s direct and indirect infringement of the ’475 Patent in an amount to be proved at
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`trial.
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`50.
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`Plaintiffs have suffered, and will continue to suffer, irreparable harm as a result of
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`ManaMed’s infringement of the ’475 Patent, for which there is no adequate remedy at law,
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`3 https://www.manamed.com/products/plasmaflow-compression-device
`12
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 13 of 20 PageID #: 13
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`unless ManaMed’s infringement is enjoined by this Court. Accordingly, Plaintiffs seek a
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`permanent injunction enjoining ManaMed from making, using, importing, offering to sell, and/or
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`selling the Accused Products, including at least all versions and variants of the ManaMed
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`PlasmaFlow and PlasmaFlight.
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`51. ManaMed has, within the meaning of 35 U.S.C. § 284, committed and continues
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`to commit acts of infringement that ManaMed actually knew or should have known constituted
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`an unjustifiably high risk of infringement of at least one valid and enforceable claim of the ʼ475
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`Patent. ManaMed’s direct and indirect infringement of the ʼ475 Patent has been and continues to
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`be willful, intentional, deliberate, and/or in conscious disregard of Plaintiffs’ rights under the
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`patent. Plaintiffs are entitled to an award of treble damages, reasonable attorney fees, and costs
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`in bringing this action.
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`COUNT II
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`(Infringement of the ’704 Patent)
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`52.
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`Plaintiffs reallege and incorporate by reference the foregoing paragraphs as if
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`fully set forth herein.
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`53.
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`Plaintiffs have not licensed or otherwise authorized ManaMed to make, use, offer
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`for sale, sell, or import any products that embody the inventions of the ’704 Patent.
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`54. ManaMed has and continues to directly infringe the ’704 Patent, either literally or
`
`under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by
`
`making, using, offering to sell, selling, and/or importing into the United States products that
`
`satisfy each and every limitation of one or more claims of the ’704 Patent. Upon information
`
`and belief, these products include at least the Accused Products, such as those which comprise
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`portable deep vein thrombosis compression technology.
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`13
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`55.
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`For example, ManaMed has and continues to directly infringe at least claim 1 of
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`the ’704 Patent by making, using, offering to sell, selling, and/or importing into the United States
`
`products that comprise a portable intermittent pneumatic compression system comprising: an air
`
`pumping module comprising a power supply, an electronic control unit, a first pressure port, and
`
`a valve with at least an inflation port, wherein said electronic control unit is adapted to control
`
`said valve; a flexible wrap comprising an inflatable bladder with a first section and a second
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`section that is connected to said first section through a passageway, with said inflation port
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`coupled to said first section of said inflatable bladder through a first line that is connected to a
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`first portion of said air pumping module; and a pressure sensor for measuring an air pressure of
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`said inflatable bladder through said first pressure port that is coupled to said second section of
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`said inflatable bladder through a second line that is connected to a second portion of said air
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`pumping module, wherein said first pressure port is the only pressure sensing port coupled to
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`said air pumping module; wherein said flexible wrap is adapted to be worn by a user and said air
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`pumping module is mounted on said inflatable bladder, wherein said first portion of said air
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`pumping module is mounted to said first section of said inflatable bladder through said flexible
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`wrap and said second portion of said air pumping module is mounted to said second section of
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`said inflatable bladder through said flexible wrap; and wherein said valve enables air to flow
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`from said inflation port to said first section through said first line to inflate said inflatable bladder
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`and said air pressure is measured by said pressure sensor through said second line that does not
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`provide air to inflate said inflatable bladder.
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`56. ManaMed’s PlasmaFlow is an exemplary product covered by at least claim 1 of
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`the ’704 Patent. Upon information and belief, other products provided by ManaMed infringe the
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`’704 Patent.
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 15 of 20 PageID #: 15
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`57.
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`The Accused Products are portable intermittent pneumatic compression systems
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`comprising an air pumping module comprising a power supply, an electronic control unit, a first
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`pressure port, and a valve with at least an inflation port. For example, upon information and
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`belief, the ManaMed PlasmaFlow has an air pumping module comprising a power supply, an
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`electronic control unit, a first pressure port, and a valve with at least an inflation port.
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`58.
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`The Accused Products comprise an electronic control unit that is adapted to
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`control the valve. For example, upon information and belief, the ManaMed PlasmaFlow has an
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`electronic control unit that is adapted to control the valve.
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`59.
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`The Accused Products comprise a flexible wrap comprising an inflatable bladder
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`with a first section and a second section that is connected to the first section through a
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`passageway, with the inflation port coupled to the first section of the inflatable bladder through a
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`first line that is connected to a first portion of the air pumping module. For example, upon
`
`information and belief, the ManaMed PlasmaFlow has a flexible wrap comprising an inflatable
`
`bladder with a first section and a second section that is connected to the first section through a
`
`passageway, with the inflation port coupled to the first section of the inflatable bladder through a
`
`first line that is connected to a first portion of the air pumping module.
`
`60.
`
`The Accused Products comprise a pressure sensor for measuring an air pressure of
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`the inflatable bladder through the first pressure port that is coupled to the second section of the
`
`inflatable bladder through a second line that is connected to a second portion of the air pumping
`
`module. For example, upon information and belief, the ManaMed PlasmaFlow has a pressure
`
`sensor for measuring an air pressure of the inflatable bladder through the first pressure port that
`
`is coupled to the second section of the inflatable bladder through a second line that is connected
`
`to a second portion of the air pumping module.
`
`15
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 16 of 20 PageID #: 16
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`61.
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`The Accused Products comprise a first pressure port that is the only pressure
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`sensing port coupled to the air pumping module. For example, upon information and belief, the
`
`ManaMed PlasmaFlow has a first pressure port that is the only pressure sensing port coupled to
`
`the air pumping module.
`
`62.
`
`The Accused Products comprise a flexible wrap that is adapted to be worn by a
`
`user and the air pumping module is mounted on the inflatable bladder. For example, upon
`
`information and belief, the ManaMed PlasmaFlow has a flexible wrap that is adapted to be worn
`
`by a user and the air pumping module is mounted on the inflatable bladder.
`
`63.
`
`The Accused Products comprise a first portion of the air pumping module that is
`
`mounted to the first section of the inflatable bladder through the flexible wrap and the second
`
`portion of the air pumping module is mounted to the second section of the inflatable bladder
`
`through the flexible wrap. For example, upon information and belief, the ManaMed PlasmaFlow
`
`has a first portion of the air pumping module that is mounted to the first section of the inflatable
`
`bladder through the flexible wrap and the second portion of the air pumping module is mounted
`
`to the second section of the inflatable bladder through the flexible wrap.
`
`64.
`
`The Accused Products comprise a valve that enables air to flow from the inflation
`
`port to the first section through the first line to inflate the inflatable bladder and the air pressure
`
`is measured by the pressure sensor through the second line that does not provide air to inflate the
`
`inflatable bladder. For example, upon information and belief, the ManaMed PlasmaFlow has a
`
`valve that enables air to flow from the inflation port to the first section through the first line to
`
`inflate the inflatable bladder and the air pressure is measured by the pressure sensor through the
`
`second line that does not provide air to inflate the inflatable bladder.
`
`16
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`Case 4:22-cv-00359-ALM Document 1 Filed 04/29/22 Page 17 of 20 PageID #: 17
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`65.
`
`Upon information and belief, ManaMed had knowledge of the ’704 Patent and
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`notice of their infringement of the ’704 Patent no later than February 9, 2021. ManaMed also
`
`had knowledge of the ’704 Patent and notice of their infringement of the ’704 Patent as a result
`
`of the filing of this Complaint.
`
`66.
`
`Upon information and belief, ManaMed has indirectly infringed and continues to
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`indirectly infringe the ’704 Patent by actively inducing and contributing to the infringement of
`
`the ’704 Patent by others, such as ManaMed’s customers and end-users of the Accused Products
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`in this District and elsewhere in the United States.
`
`67.
`
`For example, upon information and belief, ManaMed’s customers and end-users
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`directly infringe, either literally or under the doctrine of equivalents, through their use,
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`manufacture, importation, sale, and/or offer to sell the inventions claimed in the ’704 Patent.
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`Upon information and belief, ManaMed induces this direct infringement through its affirmative
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`acts of manufacturing, importing, selling, distributing, and/or otherwise making available the
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`Accused Products, and providing instructions, documentation, and other information to
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`customers and end-users suggesting that they make, import, sell, offer for sale, and/or use the
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`Accused Products in an infringing manner, including technical support, marketing, product
`
`manuals, advertisements, and online documentation.4 Upon information and belief, because of
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`ManaMed’s inducement, ManaMed’s customers and end-users make, import, sell, offer for sale,
`
`and/or use the Accused Products in a way ManaMed intends and directly infringe the ’704
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`Patent. Upon information and belief, ManaMed performs these affirmative acts with knowledge
`
`of the ’70