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Case No.:
COMPLAINT FOR
INFRINGEMENT OF PATENT
Plaintiffs,
vs.
NINGBO A-ONE INDUSTRIAL CO.,
LTD.,
Defendant.
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FIRST COUNT
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1.
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company organized and existing under the laws of the Peoples Republic of China
and is the holder and owner of U.S. Design Patent No. D704,908 (Patent-in-
Suit).
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2.
existing under the laws of the State of California and holds an exclusive license to
the Patent-in-Suit and the product line of air mover devices covered by the Patent-
in-Suit.
3.
(Defendant) is a company organized and existing under the laws of the Peoples
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Republic of China with its principal business office at 598 JiangNan Road, Room
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4.
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and (c)(3).
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other parts of the United States of America by marketing products and services
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that infringe the Patent-in-Suit causing injury to Plaintiffs, and there is no district
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in which the action may otherwise be brought. 28 U.S.C. 1391(b)(3) and (c)(3).
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6.
The Patent-in-Suit was filed June 8, 2011 and was issued by the
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United States Patent and Trademark Office on May 13, 2014. Attached hereto
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develops, manufactures and sells various air mover devices, including Model
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a true and correct photo of Model No. P-230AT air mover device.
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No. AP11003, and exports and sells Model No. AP11003 air mover device to
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manufactured, and offered for sale Model No. AP11003 air mover device.
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in-Suit.
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A.
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D704,908;
B.
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D.
case and that Plaintiffs be awarded attorneys fees, costs of suit, and expenses in
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G.
For such other and further relief as this Court may deem just and
proper.
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By:
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Plaintiffs hereby waive the right to trial by jury and request for a court trial.
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By:
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