One of the first questions that a patent plaintiff faces in bringing suit is "what do we have to include in the complaint?"
It's common in the District of Delaware for a patent plaintiff to list only a small number of asserted claims from each asserted patent, against a small number of accused products—often just one claim against one product.
Of course, listing more asserted claims may increase the chances that a court finds that the plaintiff stated a plausible claim of infringement in the event of a motion to dismiss. But many plaintiffs are fine with that risk, knowing that they can amend to avoid any motion to dismiss (usually) .
The Court normally permits parties to later add or remove asserted claims or accused products as ...