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Case 2:07-cv-00887-TSZ Document 1 Filed 06/08/2007 Page 1 of 5
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UNITED STATES DISTRICT COURT
8 FOR THE WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
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Plaintiff High Maintenance Bitch, LLC (“HMB”) complains against
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defendant Innovative Spotlight, Inc. (“Innovative”), and for causes of action
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alleges as follows
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THE PARTIES
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1. Plaintiff HMB is a Washington State limited liability company,
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with its principal place of business at 10015 Lake City Way, NE, Box 315,
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Seattle, Washington, 98125.
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2. HMB is the owner of United States Patent No. D475,163
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(“HMB Patent 1”), reproduced as Exhibit A hereto.
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3. HMB is the owner of United States Patent No. D468,491
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(“HMB Patent 2”), reproduced as Exhibit B hereto.
Complaint VeriTrademark
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Case 2:07-cv-00887-TSZ Document 1 Filed 06/08/2007 Page 2 of 5
6 Jurisdiction
8 Innovative.
10 claims for relief, which arise under the laws of the United States and more
13 Claims for relief, which arise under act of Congress relating to patents,
15 Factual Background
17 products that are within the scope of the claims of HMB Patent 1, HMB Patent
19 10. HMB has not licensed or assigned Innovative HMB Patent 1, HMB
21 Causes of Action
22 COUNT I
(Direct Infringement of HMB Patent 1)
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11. By this reference HMB incorporates and re-alleges, as though
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fully set forth herein, paragraphs 1 through 10 above.
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12. Innovative, without authority has made, used, sold, and/or
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Complaint VeriTrademark
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Seattle, WA 98104
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Case 2:07-cv-00887-TSZ Document 1 Filed 06/08/2007 Page 3 of 5
1 offered for sale goods within the scope of the claims of HMB Patent 1, HMB
4 a cause of action for direct infringement of HMB patent 1, HMB patent 2, and
6 14. HMB alleges that Innovative will continue to infringe HMB Patent
11 COUNT II
(Direct Infringement of HMB Patent 2)
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16. By this reference HMB incorporates and re-alleges, as though
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fully set forth herein, paragraphs 1 through 15 above.
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17. Innovative, without authority has made, used, sold, and/or
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offered for sale goods within the scope of the claims of HMB Patent 2.
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18. The conduct of Innovative as set forth above gives rise to
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a cause of action for direct infringement of HMB Patent 2, pursuant to 35 USC
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§§ 271(a), 281, and 289.
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19. HMB alleges that Innovative will continue to infringe HMB Patent
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2 unless enjoined by the court.
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20. By reason of the foregoing HMB is entitled to injunctive and
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monetary relief against Innovative, pursuant to 35 USC §§ 283-285, as more
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fully set forth below.
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COUNT III
25 (Direct Infringement of HMB Patent 3)
2 offered for sale goods within the scope of the claims of HMB Patent 3.
6 24. HMB alleges that Innovative will continue to infringe HMB Patent
14 enjoining Innovative Spotlight, Inc., its agents, and any and all parties
16 any manner HMB Patent 1, HMB Patent 2, and HMB Patent 3, whether by making,
24 E. For such other and further relief as the court deems just, proper
25 and equitable.
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Complaint VeriTrademark
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Seattle, WA 98104
(206)281-0795
Case 2:07-cv-00887-TSZ Document 1 Filed 06/08/2007 Page 5 of 5
3 causes so triable.
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Dated this June 8, 2007
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/Daniel M Bronski/
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VeriTrademark
9 216 First Ave S #210
Seattle, WA 98104
10 (206) 219-0515
11 Daniel M. Bronski
12 James J. Ruttler, of
Counsel (US Patent Reg. No.
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Complaint VeriTrademark
Page 5 of 5 216 First Ave S #210
Seattle, WA 98104
(206)281-0795