Upon information and belief in violation of35 U.S.C. § 271, Facebook is and has been directly infringing the '111 patent by making, using, selling, and/or offering to sell in the United States, or importing into the United States, products or processes that practice the inventions claimed in the '111 patent, including without limitation, Facebook Ads. Facebook has had knowledge of the' 111 patent from at least February 27, 2012, when Yahoo! Notified Facebook of its infringement, and its infringement since at least that date has been willful.