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This suffices to allow a reasonable reasoning that Plaintiff has a "possible claim for relief" with regard to its claim for joint violation. See Iqbal, 556 U.S. 678-79. Hence, I will deny Accused's demand that I dismiss this claim. 3. Induced Infringement The Complaint plausibly states a claim for caused infringement.

271(b)," [w] hoever actively induces violation of a patent will be liable as an infringer." "To show induced infringement, the patentee must show direct infringement, and that the alleged infringer intentionally caused infringement and has particular intent to motivate another's violation."  Reference . v. Imation Corp., 681 F. 3d 1358, 1363 (Fed.

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2012) (internal quote marks left out). Pre-suit knowledge is not needed to plead a claim of induced infringement. See Walker Digital, LLC v. Facebook, Inc., 852 F.Supp. 2d 559, 565 (D. Del. 2012). To plausibly plead intent, a problem needs to consist of realities "revealing that [the supposed indirect infringer] specifically meant [the direct infringers] to infringe [the patent]" In re Expense of Lading Transmission & Processing Sys.

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Cir. 2012 ). Plaintiff's filing of the Grievance suffices to develop the requisite understanding for post-filing indirect violation liability. Furthermore, the Grievance includes enough factual accusations to support an inference of particular intent. (See e. g., D.I. 1 at 21 ("Jam City motivates continued direct violation of the.

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Hence, Complainant's accusations suffice to support a claim of induced violation. 4. Contributory Infringement The Complaint plausibly mentions a claim for contributing infringement. A complainant adequately pleads contributing infringement when it asserts that a defendant: "( 1) knew the patent; (2) sold products specifically made for infringing use; (3) understood the infringing usage; (4) offered items without any significant noninfringing usage; and (5) [others] directly infringed." Walker Digital, LLC, 852 F.

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2d at 567. Plaintiff's claims of contributory infringement reads: Jam City contributes to direct violation of the asserted claims of the '762 Patent by providing video game players with the necessary software and instructions to operate the Charged Products, consisting of the downloading of applet applications for the delivery and screen of browser-independent content.