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Pro Marketing Sales, Inc. v. Cyber Solutions International, Llc et al

REPLY BRIEF re MOTION to Dismiss

20 Cited authorities

  1. Diamond Crystal Brands v. Food Movers Intern

    593 F.3d 1249 (11th Cir. 2010)   Cited 438 times   3 Legal Analyses
    Finding specific jurisdiction when the non-forum defendant "purposefully engag[ed] in fourteen such transactions in just six months," thus establishing "a substantial and ongoing relationship with a Georgia manufacturer"

  2. Ethicon, Inc. v. U.S. Surgical Corp.

    135 F.3d 1456 (Fed. Cir. 1998)   Cited 338 times   14 Legal Analyses
    Holding "as a matter of substantive patent law, all co-owners must ordinarily consent to join as plaintiffs in an infringement suit"

  3. Innovative Clinical v. First National Bank

    279 Ga. 672 (Ga. 2005)   Cited 165 times   1 Legal Analyses
    Holding that subsection must be read and applied literally

  4. Hess v. Advanced Cardiovascular Systems, Inc.

    106 F.3d 976 (Fed. Cir. 1997)   Cited 159 times   5 Legal Analyses
    Holding that explaining the state of the art and providing well-known information found in textbooks was insufficient for joint inventorship

  5. Israel v. Amgen

    475 F.3d 1256 (Fed. Cir. 2007)   Cited 91 times   1 Legal Analyses
    Explaining that “issues of patent ownership are distinct from questions of inventorship”

  6. Bard Peripheral Vascular, Inc. v. W.L. Gore & Assocs., Inc.

    670 F.3d 1171 (Fed. Cir. 2012)   Cited 39 times   9 Legal Analyses
    Denying permanent injunction for patent covering prosthetic vascular grafts used to bypass or replace blood vessels because "it was in the public interest to allow competition in the medical device arena"

  7. Nartron v. Schukra U.S.A

    558 F.3d 1352 (Fed. Cir. 2009)   Cited 38 times   3 Legal Analyses
    Holding for purposes of a correction of inventorship claim that an alleged co-inventor's contribution must be "not insignificant in quality"

  8. Jordan Outdoor Enterprises, Ltd. v. That 70's Store, LLC

    819 F. Supp. 2d 1338 (M.D. Ga. 2011)   Cited 14 times
    Rejecting the argument that a defendant regularly solicits business in Georgia by operating websites that are accessible in Georgia as well as everywhere else

  9. Kason Indus., Inc. v. Dent Design Hardware, Ltd.

    952 F. Supp. 2d 1334 (N.D. Ga. 2013)   Cited 12 times
    Denying jurisdictional discovery “on a mere ‘hunch that there may be facts—or a desire to find out if there are any facts—that justify the exercise of personal jurisdiction.’ ” (quoting Atlantis Hydroponics, 915 F.Supp.2d at 1379–80)

  10. RMS Titanic, Inc. v. Zaller

    978 F. Supp. 2d 1275 (N.D. Ga. 2013)   Cited 10 times   1 Legal Analyses

    No. 1:13–cv–0625–WSD. 2013-10-17 RMS TITANIC, INC. and Premier Exhibitions, Inc., Plaintiffs, v. Thomas ZALLER, Imagine Exhibitions, Inc., a Nevada Corporation, Imagine Exhibitions, PTE, LTD, Imagine Exhibitions, Inc., a Georgia Corporation, and TZ, Inc., a Georgia Corporation, Defendants. Brian D. Wainger, In–House Legal Services, PLLC, Virginia Beach, VA, Robert William McFarland, Sarah Kate McConaughy, McGuire Woods, LLP, Norfolk, VA, Robert J. Waddell, Jr., McGuire Woods LLP, Atlanta, GA, for

  11. Rule 12 - Defenses and Objections: When and How Presented; Motion for Judgment on the Pleadings; Consolidating Motions; Waiving Defenses; Pretrial Hearing

    Fed. R. Civ. P. 12   Cited 351,086 times   937 Legal Analyses
    Granting the court discretion to exclude matters outside the pleadings presented to the court in defense of a motion to dismiss

  12. Rule 9 - Pleading Special Matters

    Fed. R. Civ. P. 9   Cited 39,307 times   323 Legal Analyses
    Requiring that fraud be pleaded with particularity

  13. Rule 5 - Serving and Filing Pleadings and Other Papers

    Fed. R. Civ. P. 5   Cited 22,480 times   16 Legal Analyses
    Allowing service by filing papers with the court's electronic-filing system

  14. Section 262 - Joint owners

    35 U.S.C. § 262   Cited 100 times   21 Legal Analyses
    Providing for joint ownership of patents

  15. Section 9-1-1 - Uniform Unsworn Declarations Act

    Ga. Code § 9-1-1   Cited 9 times

    (a) This Code section shall be known and may be cited as the "Uniform Unsworn Declarations Act." (b) As used in this Code section, the term: (1) "Law" includes a statute, judicial decision or order, rule of court, executive order, and administrative rule, regulation, or order. (2) "Record" means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form. (3) "Sign" means, with present intent to authenticate or adopt

  16. Section 18-2-80 - Venue

    Ga. Code § 18-2-80   Cited 8 times

    (a) In this Code section, the following rules determine a debtor's location: (1) A debtor who is an individual is located at the individual's principal residence; (2) A debtor that is an organization and has only one place of business is located at its place of business; and (3) A debtor that is an organization and has more than one place of business is located at its chief executive office. (b) A cause of action in the nature of a claim for relief under this article is governed by the law of the