Law to Add ICM

Similarly, the determination of WNYE’s direct infringement is a necessary predicate to finding ICM liable for indirect infringement. ICM is already a party in this MDL and is indemnifying a number of the ethanol plants named as WNYE in this MDL. Accordingly, ICM will not be prejudiced by being added to the Complaint against WNYE because it is already heavily involved in a number of the associated cases in this matter and shares the same litigation counsel representing WNYE.

CleanTech respectfully requests that the Court allow the proposed amendment because there is no reason to deny the requested amendment.

See Here

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40. Defendants infringe and will continue to infringe one or more of the claims of the ‘516 patent, by, among other activities, practicing the claimed methods and/or processes, and/or by knowingly and actively inducing others to infringe, and/or by contributing to the infringement of others.
41. Defendants’ infringement, contributory infringement and/or inducement to infringe has injured GS CleanTech, and GS CleanTech is entitled to recover damages adequate to compensate it for such infringement.
42. Defendants’ infringement, contributory infringement and/or inducement to infringe has been willful, deliberate, and objectively reckless.
43. Defendants’ infringing activities have injured and will continue to injure GS CleanTech, unless and until this Court enters an injunction prohibiting further infringement and, specifically, enjoining further manufacture, use, sale, importation, and/or offer for sale of products or practice of any methods and/or processes that come within the scope of the claims of the ‘516 patent.

Exhibit A HERE

SkunK