ICM sold the equipment to Guardian to be used in their infringing oil recovery process. Mr. Vander Griend personally decided to indemnify ICM’s customers against CleanTech’s patent infringement claims. CleanTech respectfully requests permission to add a count to the Complaint that alleges infringement of the ‘037 Patent and to add claims that ICM and Mr. Vander Griend contributed to and/or actively induced infringement of the patents-in-suit.
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