IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION Carolina Waterworks, Inc.

, Plaintiff, v. Taylor Made Group, LLC and Taylor Made Products, Defendants. ) ) ) ) ) ) ) ) 2:12-cv-02568-RMG Civil Action No. ________________

COMPLAINT JURY TRIAL DEMANDED

Carolina Waterworks, Inc. (CWI), by and through its attorneys, files this Complaint for patent infringement against Taylor Made Group, LLC and Taylor Made Products (Taylor Made) and in support thereof, states as follows: The Parties, Jurisdiction and Venue 1. CWI is a corporation having its principle place of business at 211 Eagle Road,

Goose Creek, South Carolina 29445. 2. Upon information and belief, Taylor Made is a corporation having a principal

place of business located in Gloversville, New York, which produces recreational marine products for distribution throughout the United States, including this district. 3. 4. Jurisdiction is proper under 28 U.S.C. 1331, 1332(a)(1), and 1338(a). Venue is proper pursuant to 28 U.S.C. 1391(c) and 1400(b).

Facts Giving Rise To Patent Infringement 5. CWI hereby restates and realleges the allegations set forth in paragraphs 1

through 4, not inconsistent herewith. 6. U.S. Patent No. 6,955,574 B2 (the 574 Patent), entitled Shackle Pocket

Buoy, forms the basis for this action. 7. The claims of the 574 patent cover buoys and methods for making buoys. A true

and complete copy of the 574 Patent is attached as Exhibit A. 8. Mr. L. Keith Rogerson, resident of Isle of Palms, South Carolina, is the inventor

of the 574 Patent. 9. CWI, by assignment recorded in the United States Patent Office, is the legal

owner of the 574 Patent. 10. Taylor Made does not have permission to practice the claims of the 574 Patent.

Taylor Made infringes the 574 Patent by making, using, selling and offering for sale, for example, buoys that are covered by one or more claims of the 574 Patent. 11. Taylor Made has sold in this district buoys that are covered by one or more claims

of the 574 Patent. WHEREFORE, CWI prays for judgment and relief as follows: (1) That the defendant Taylor Made has infringed United States Letters Patent 6,955,574 B2; (2) That the defendant Taylor Made and its agents, servants, officers, directors, employees, joint venturers and all persons acting in concert with them, directly or indirectly, be enjoined from infringing, inducing others

to infringe, or contributing to the infringement of United States Letters Patent 6,955,574 B2; (3) That the defendant Taylor Made be ordered to account for and pay to Plaintiff CWI the damages adequate to compensate it for the infringement pursuant to 35 USC 284. (4) That plaintiff CWI be awarded prejudgment interest, and its costs, disbursements and attorneys fees herein pursuant to 35 USC 285; and (5) Such other further relief as this Court deems just, equitable and appropriate. Respectfully submitted, TURNER PADGET GRAHAM & LANEY P.A. September 6, 2012 s/Bernard S. Klosowski, Jr. Bernard S. Klosowski, Jr. (Fed. ID # 9251) 200 East Broad Street, Suite 250 (29601) P.O. Box 1509 Greenville, South Carolina 29602 (864) 552-4622 Email: bklosowski@turnerpadget.com ATTORNEYS FOR PLAINTIFF