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It structures essential sections including the caption, the nature of the action, parties, subject-matter and personal jurisdiction, venue, factual background of intellectual property rights, and detailed infringement allegations. It also provides placeholders for numbered paragraphs and multiple claims for relief, supporting FRCP-style pleading and referencing governing statutes.","[Your name, Esq.]\n[Firm name]\n[Firm address line 1]\n[Firm address line 2]\nAttorney for Plaintiff [or Plaintiffs]\n[Name(s) of plaintiff(s)]\nU.S. district court\n[DISTRICT AND DIVISION]\n[INSTRUCTIONS: the bracketed material is guidance and is to be removed. Look to other complaints both for language that might be useful as well as for examples. Each paragraph should be numbered. Maintain the spacing.]\n[Prior to the “Nature of the Action,” you may provide a short introductory paragraph here, a couple lines, similar to that in the amended Apple v. Samsung I complaint. See \u0013 HYPERLINK \"http://www.patentprogress.org/wp-content/uploads/2012/11/Filing-75-Amended-Complaint-Apple-Samsung-I-18462.pdf\" \u0014http://www.patentprogress.org/wp-content/uploads/2012/11/Filing-75-Amended-Complaint-Apple-Samsung-I-18462.pdf\u0015 for the complaint.]\nTHE NATURE OF THE ACTION\n[Use one or more paragraphs to explain, in “short and plain” terms, the nature of the dispute. It is appropriate to be persuasive here.]\n[You may use additional paragraphs here. Hit enter to add paragraphs and update the numbering.]\nTHE PARTIES\n[Allegations regarding the plaintiff and its domicile.]\n[Allegations regarding defendant 1 and its domicile, including address and other contact info.]\n[Add additional paragraphs regarding any other defendants.]\nJURISDICTION AND VENUE\n[Allegations regarding subject matter jurisdiction. Bases may include 28 U.S.C. §§ 1331, 1332, 1338, and for supplemental claims, 1367. Do not be conclusory. Tie the facts briefly into the law.]\n[Allegations regarding personal jurisdiction, including Constitutional bases as well as the applicable state’s long-arm statute. Do not be conclusory. Tie the facts briefly into the law.]\n[Allegations regarding venue. For patent or copyright venue, because of the TC Heartland case, you cannot use 28 U.S.C. § 1391. Instead, rely on 28 U.S.C. § 1400 for both patent and copyright claims. For trademark, unfair competition, or state-law claims, you can and should rely on 28 U.S.C. § 1391 for venue. Do not be conclusory. Tie the facts briefly into the law.]\nBACKGROUND\n[In this section, provide allegations regarding the plaintiff’s intellectual property rights, such as nature of ownership (by invention or assignment), nature of rights (including copyright registration, trademark registration, and/or patent issuance, as the case may be. After Iqbal and Twombly, facts matter, so do not skimp on details. (Thus, the Apple v. Samsung II complaint is too bare-bones in my opinion. See \u0013 HYPERLINK \"https://insight.rpxcorp.com/litigation_documents/9581880\" \u0014https://insight.rpxcorp.com/litigation_documents/9581880\u0015). Another reason to be persuasive because that may help urge the defendant to settle. IP owners will sometimes file a complaint and send a courtesy copy via mail (prior to service) as a prompt towards settling. So be persuasive so long as you are also being legally and factually truthful pursuant to FRCP 11. You can use subheadings such as the example shown below, similar to the Apple v. Samsung I complaint.]\nSubheading example: Plaintiff’s rights\n[More detailed allegations regarding the plaintiff’s rights. For copyrights, give examples of the relevant rights, etc.. For patents, include claims and patent number, etc. Images can be pasted in. See the Apple v. Samsung I complaint.]\n[Additional paragaphs. Add or delete paragraphs as needed.]\n[Additional paragaphs. Add or delete paragraphs as needed.]\n[Additional paragaphs. Add or delete paragraphs as needed.]\n[Additional paragaphs. Add or delete paragraphs as needed.]\nSubheading example: Defendant’s infringement\n[More detailed allegations regarding the defendant’s infringement, along with what happened during enforcement, if any. Show what the infringement was. You can cite language from the website and any C&D letters or responses. Images can be pasted in.]\n[Additional paragraphs. Add or delete paragraphs as needed.]\n[Additional paragraphs. Add or delete paragraphs as needed.]\n[Addi","cbCaicP38nOHlVIo","https://ap.wps.com/l/cbCaicP38nOHlVIo","docx",31467,6,"English","en",105,"# THE NATURE OF THE ACTION\n# THE PARTIES\n# JURISDICTION AND VENUE\n# BACKGROUND\n# FIRST CLAIM FOR RELIEF\n# SECOND CLAIM FOR RELIEF","[{\"question\":\"What is the purpose of the “Nature of the Action” section in this complaint template?\",\"answer\":\"It explains the dispute in short and plain terms, using one or more persuasive paragraphs to describe what is happening and why it matters legally.\"},{\"question\":\"Which allegations are required for “Jurisdiction and Venue” in the template?\",\"answer\":\"It calls for non-conclusory allegations for subject-matter jurisdiction, personal jurisdiction (including constitutional and state long-arm basis), and venue, with statute selection guidance for patent/copyright versus trademark/state-law claims.\"},{\"question\":\"How should the “Background” section describe intellectual property rights?\",\"answer\":\"It should include allegations about ownership and the nature of the rights, such as invention or assignment, copyright registration, trademark registration, or patent issuance, with sufficiently detailed facts to support the claims.\"}]","Complaint Template - 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