Judge Andrews recently denied defendants’ motions to dismiss plaintiff’s amended complaint in Select Retrieval LLC v. Amerimark Direct LLC, et al., C.A. No. 11-812-RGA (D. Del. June 18, 2012), because the complaint’s “minimal allegations” stating a claim for direct infringement satisifed Rule 18. Id. at 1. Judge Andrews also found plaintiff’s willfulness allegations sufficient because the complaint alleged that shortly before the complaint was filed “the defendant was notified by letter of the existance of its patent, that the defendant infringed the patent, and that the plaintiff was offering a license agreement.” Id. at 2.