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infringe the 526 patent for the reasons set forth under the Facts Common to Each Claim for Relief and the allegations regarding direct infringement. eClinicalWorks customers, who directly infringe the 526 patent include, for example, Grove Medical Associates and Urban Health Plan. 42. Since at least by May 26, 2011, eClinicalWorks had knowledge of the
526 patent. After this date, eClinicalWorks had knowledge that its eClinicalWorks EMR software software, which are non-staple articles of commerce, was used as a material part of the claimed invention of the 526 patent. 43. As a direct and proximate result of eClinicalWorkss contributory
infringement of the 526 patent, Plaintiff has been and continues to be damaged in an amount yet to be determined. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendant as follows: 1. For a judicial determination and declaration that Defendant has infringed
and continues to infringe the 526 patent by making, using, importing, offering for sale, and/or selling its eClinicalWorks EHR software; 2. For a judicial determination and declaration that Defendant has induced,
and continues to induce, the infringement of the 526 patent; 3. For a judicial determination and declaration that Defendant has
contributorily infringed, and continues to contributorily infringe, the 526 patent; 4. For damages resulting from Defendants past and present infringement of
the 526 patent; 5. For a declaration that this is an exceptional case under 35 U.S.C. 285
and for an award of attorneys fees and costs in this action; 6. 7. For an assessment of prejudgment interest; and For such other and further relief as the Court may deem just and proper
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