11. Defendant has infringed and continues to infringe one or more claims of the‘750 patent by making, using, providing, offering to sell, and selling (directly or through intermediaries), in this district and elsewhere in the United States, systems and methods for accessing electronic data. Particularly, Defendant requires and/or directs users to access and/or use Quick Response Codes (“QR Codes”) printed on Defendant’s commercial advertisements, in a manner claimed in the ’750 patent. Defendant infringe the ‘750 patent by providing printed commercial documents that have at least one machine recognizable feature aka a QR Code. 12.Defendant infringe ‘750 patent by providing QR Codes on printed commercial advertisements to be used by viewers for accessing programmed material. QR Codes are features recognized by the mobile smartphone device when the device, controlled by the user, scans the QR Code, in a manner claimed by the ‘750 patent. The mobile smartphone device uses a barcode scanner application to communicate with the QR Code, featured within the Defendant’s printed advertisement, to obtain programmed information relating to the advertisement. 13. After the mobile device scans the QR Code, a ommunication link is established and the content is displayed on the screen of the mobile device. Accessed content relates to the commercial advertisement and is programmed by the Defendant to relate to the printed commercial document. The Defendant infringes the ‘750 patent when the scanned QR Code provides programmed content to the user of the mobile device relat ing to the commercial document featuring the QR Code. 14. Defendant is a company that specializes in mortgages and roll out of their QR Code advertising program has garnered significant attention in the Internet community. Executives of the company are quoted on several websites as endorsing the QR campaign as a means of competing with online lenders and expanding their market potential. The Defendant uses the QR Codes in their advertising campaigns to connect the Defendant’s loan officers with clients. The clients scan the QR Codes to access Defendant’s mobile website. On the website the clients access through scanning the QR Code, clients can find more information on mortgage loan products offered by the Defendant. 15.When the mobile device scans the QR Code, a command sequence is initiated to access material programmed by the Defendant to relate to the advertisement, as illustrated in the above. The user’s device then downloads, via the Internet, the programmed data indicative of the QR Code (for example, data indicative of mortgage loan products). On information and belief, this data is programmed and stored on Defendant’s remote servers for access by devices that have scanned corresponding QR Codes.