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Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 1 of 50

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF CONNECTICUT

KX TECHNOLOGIES, LLC
Plaintiff
v.
ZUMA WATER FILTERS, INC.
d/b/a ZUMA FILTERS,
U.S. WATER FILTERS, INC.
WATER FILTERS DIRECT, LLC
d/b/a TIER1,
CLEARWATER FILTERS
d/b/a MIST BY CLEARWATER,
WATERFALL FILTER COMPANY
d/b/a WATERFALL FILTER,
BLUESKY
d/b/a ICEPURE,
BEST FILTERS
d/b/a BEST,
DISTA FILTER
d/b/a DISTA,
SHOPSTIC, INC.
d/b/a ALPINE WATER,
and
ETERNAWATER
d/b/a Eternawater
Defendants

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Complaint for Damages and Injunctive


Relief for Patent Infringement, False
Advertising, Unfair Competition, and
Unfair Trade Practices

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 2 of 50

COMPLAINT
Plaintiff KX Technologies, LLC ("KXT") alleges as follows:
I. NATURE OF THE ACTION
1. This is a civil action seeking damages and injunctive relief for patent infringement under
the patent laws of the United States, Title 35 of the United States Code 1, et seq., false
advertising and unfair competition under the Lanham Act, section 43 (15 U.S.C. 1125), and
unfair trade practices under the Connecticut Unfair Trade Practices Act (CUTPA), C.G.S. 42110a, et seq.
II. JURISDICTION AND VENUE
2. Jurisdiction of this Court is proper pursuant to Title 28 U.S.C. 1331 and 1338(a).
3. This cause of action arises in part under the Lanham Act, section 43 (15 U.S.C. 1125).
Subject matter jurisdiction for the Lanham Act claim is conferred on this Court by the Lanham
Act, section 39 (15 U.S.C. 1121).
4. This cause of action also arises in part under the Connecticut Unfair Trade Practices Act
(CUTPA), C.G.S. 42-110a, et seq. Subject matter jurisdiction for the CUTPA claim is
conferred on this Court by 28 U.S.C. 1338(b).
5. Supplemental jurisdiction for the CUTPA claim is conferred on this Court by 28 U.S.C.
1367(a).
6. Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c), and 1400(b).

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III. PARTIES
7. Plaintiff KX Technologies, LLC ("KXT") is a Delaware limited liability company
authorized to do business in the State of Connecticut, having a principal place of business at 55
Railroad Avenue, West Haven, Connecticut 06516.
8. Plaintiff KXT is informed and believes that defendant Zuma Water Filters, Inc. d/b/a
Zuma Filters is a corporation organized and existing under the laws of the state of California. It is
assigned Entity Number C3397335 by the California Secretary of State, and has a principal place
of business at 556 South Fair Oaks Ave, Suite 504, Pasadena, CA 91105. Exhibit A.
9. Plaintiff KXT is informed and believes that defendant Zuma Water Filters, Inc. d/b/a
Zuma Filters transacts business in this district and has repeatedly solicited business in this district
through an interactive website, including but not limited to zumafilters.com, houseoffilters.com,
and Amazon.com, and has sold infringing water filter cartridges in this district. Exhibit A.
10. Plaintiff KXT is informed and believes that defendant Water Filters Direct LLC d/b/a
Tier1 is a domestic limited liability company organized and existing under the laws of the state of
Minnesota. Water Filters Direct LLC is assigned Entity Number 33592-LLC by the Minnesota
Secretary of State, and has a principal place of business at 560 22nd Street, Zumbrota, MN 55992.
Exhibit B.
11. Plaintiff KXT is informed and believes that defendant Water Filters Direct LLC d/b/a
Tier1 transacts business in this district and has repeatedly solicited business in this district through
an interactive website, including but not limited to fridgefilters.com, and waterfilters.net, and has
sold infringing water filter cartridges in this district. Exhibit B.

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12. Plaintiff KXT is informed and believes that defendant U.S. Water Filters Inc. d/b/a Tier1
is a corporation organized and existing under the laws of the state of Delaware. U.S. Water Filters
Inc., has a principal place of business at 560 22nd Street, Zumbrota, MN 55992. Exhibit C.
13. Plaintiff KXT is informed and believes that defendant U.S. Water Filters, Inc., is the sole
owner of the United States Trademark Registration No. 4,709,090 for selling product in interstate
commerce under the mark "TIER1", including water filtration and purification units and
replacement cartridges and filters thereof. Exhibit C.
14. Plaintiff KXT is informed and believes that defendant U.S. Water Filters, Inc., transacts
business in this district and has repeatedly solicited business in this district through an interactive
website, and has sold infringing water filter cartridges in this district. Exhibit C.
15. Plaintiff KXT is informed and believes that defendant Clearwater Filters d/b/a Mist by
Clearwater is a domestic corporation with an as yet unknown business address selling products in
interstate commerce, including water filtration and purification units and replacement cartridges
and filters thereof, including the infringing device as alleged herein.
16. Plaintiff KXT is informed and believes that defendant Clearwater Filters d/b/a Mist by
Clearwater transacts business in this district and has repeatedly solicited business in this district
through various interactive websites, including Amazon.com. Exhibit D.
17. Defendant Clearwater Filters d/b/a Mist by Clearwater remains evasive in providing any
business address to the public. Plaintiff KXT anticipates the filing of a third party subpoena upon
Amazon.com at the onset of this litigation to determine the business address of the defendant.

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18. Plaintiff KXT is informed and believes that defendant Waterfall Filter Company d/b/a
Waterfall Filter is a domestic limited liability company organized and existing under the laws of
the state of Nevada. Waterfall Filter Company is assigned entity number E0354842014-7 by the
Nevada Secretary of State, and has a principal place of business at 100-126 8020 S. Rainbow
Blvd, Las Vegas, Nevada 89139. Exhibit E.
19. Plaintiff KXT is informed and believes that defendant Waterfall Filter Company d/b/a
Waterfall Filter is the sole owner of the United States Trademark Registration No. 4763656 for
selling product in interstate commerce under the mark "Waterfall Filter", including water filtration
and purification units and replacement cartridges and filters thereof. Exhibit E.
20. Plaintiff KXT is informed and believes that defendant Waterfall Filter Company d/b/a
Waterfall Filter transacts business in this district and has repeatedly solicited business in this
district through various interactive websites, including Amazon.com. Exhibit E.
21. Plaintiff KXT is informed and believes that defendant Bluesky d/b/a IcePure is a domestic
corporation with an as yet unknown business address selling products in interstate commerce,
including water filtration and purification units and replacement cartridges and filters thereof,
including the infringing device as alleged herein. Exhibit F.
22. Plaintiff KXT is informed and believes that defendant Bluesky d/b/a IcePure transacts
business in this district and has repeatedly solicited business in this district through various
interactive websites, including Amazon.com. Exhibit F.

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23. Defendant Bluesky d/b/a IcePure remains evasive in providing any business address to the
public. Plaintiff KXT anticipates the filing of a third party subpoena upon Amazon.com at the
onset of this litigation to determine the business address of the defendant.
24. Plaintiff KXT is informed and believes that defendant Best Filters d/b/a Best is a domestic
corporation with an as yet unknown business address selling products in interstate commerce,
including water filtration and purification units and replacement cartridges and filters thereof,
including the infringing device as alleged herein. Exhibit G.
25. Plaintiff KXT is informed and believes that defendant Best Filters d/b/a Best transacts
business in this district and has repeatedly solicited business in this district through various
interactive websites, including Amazon.com. Exhibit G.
26. Defendant Best Filters d/b/a Best remains evasive in providing any business address to the
public. Plaintiff KXT anticipates the filing of a third party subpoena upon Amazon.com at the
onset of this ligation to determine the business address of the defendant.
27. Plaintiff KXT is informed and believes that defendant Shopstic, Inc. d/b/a Alpine Water, is
a domestic corporation existing under the laws of Florida, having a business at 6586 Waters Edge
Way, Lakewood Ranch, Florida 34202. Exhibit H.
28. Plaintiff KXT is informed and believes that defendant Shopstic, Inc. d/b/a Alpine Water is
the sole owner of the United States Trademark Application No. 87077359 for selling product in
interstate commerce under the mark "Alpine Water", including refrigerator water filters and
replacement cartridges thereof, including the infringing device as alleged herein. Exhibit H.

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29. Plaintiff KXT is informed and believes that defendant Shopstic, Inc. d/b/a Alpine Water
transacts business in this district and has repeatedly solicited business in this district through
various interactive websites, including Amazon.com. Exhibit H.
30. Plaintiff KXT is informed and believes that defendant Dista Filter d/b/a Dista is a
domestic corporation with an as yet unknown business address selling products in interstate
commerce, including water filtration and purification units and replacement cartridges and filters
thereof, including the infringing device as alleged herein. Exhibit I.
31. Plaintiff KXT is informed and believes that defendant Dista Filter d/b/a Dista transacts
business in this district and has repeatedly solicited business in this district through various
interactive websites, including Amazon.com. Exhibit I.
32. Defendant Dista Filter d/b/a Dista remains evasive in providing any business address to the
public. Plaintiff KXT anticipates the filing of a third party subpoena upon Amazon.com at the
onset of this litigation to determine the business address of the defendant.
33. Plaintiff KXT is informed and believes that defendant Eternawater d/b/a Eternawater is a
domestic corporation with an as yet unknown business address selling products in interstate
commerce, including water filtration and purification units and replacement cartridges and filters
thereof, including the infringing device as alleged herein. Exhibit J.
34. Plaintiff KXT is informed and believes that defendant Eternawater d/b/a Eternawater
transacts business in this district and has repeatedly solicited business in this district through
various interactive websites, including Amazon.com. Exhibit J.

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35. Defendant Eternawater d/b/a Eternawater remains evasive in providing any business
address to the public. Plaintiff KXT anticipates the filing of a third party subpoena upon
Amazon.com at the onset of this litigation to determine the business address of the defendant.
IV. FACTUAL BACKGROUND
36. Plaintiff KXT is the assignee and rightful owner of the following United States Patent,
which was duly and legally issued by the United States Patent and Trademark Office: U.S. Patent
No. 8,673,146, issued on March 18, 2014, titled "PUSH FILTER WITH FLOATING KEY
LOCK," (the "'146 Patent"). Exhibit K.
37. Relevant independent claims of the '146 Patent include Claims 1 and 15. Claim 1 of the
'146 Patent is directed to a filter housing assembly:
1. A filter housing assembly comprising:
a filter housing for enclosing a filter media, said filter housing having a body
and a top portion for forming a fluid-tight seal with said body, said filter
housing top portion including:
an ingress port;
an egress port;
a filter key located on said top portion and having a top surface, longitudinal
sides, and lateral sides, each of said filter key longitudinal sides including a
plurality of spaced protrusions or fingers extending laterally from said top
surface, wherein said fingers include winged extensions having slanted or
angled faces for mating attachment to a filter base or manifold.
'146 Patent, Claim 1, Exhibit K.
38. Claim 15 of the '146 Patent is directed to a method for extracting a filter housing assembly
from a filter base:
15. A method for extracting a filter housing assembly from a filter base comprising:
applying an axial insertion force to said filter housing assembly already
connected to said filter base towards said filter base thereby inserting a
filter key on said filter housing assembly further into a slidable floating

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lock of said filter base, said filter key having longitudinal sides with a
plurality of fingers or spaced protrusions on each of said longitudinal sides;
releasing said slidable floating lock, such that said floating lock moves relative
to said filter key under a resilient retraction force;
aligning said plurality of fingers on each longitudinal side of said filter key
between fingers or drive keys on said floating lock; and
applying an axial extraction force to said filter housing assembly to remove
said filter housing assembly from said filter base.
'146 Patent, Claim 15, Exhibit K.
39. Plaintiff KXT is the assignee and rightful owner of the following United States Patents,
which were duly and legally issued by the United States Patent and Trademark Office: a) U.S.
Patent No. D656,578, issued on March 27, 2012, titled "CASSETTE FILTER," (the "'578 Patent";
Exhibit L); b) U.S. Patent No. D656,579, issued on March 27, 2012, titled "CASSETTE FILTER
AND COVER PLATE" (the "579 Patent"; Exhibit M); c) U.S. Patent No. D656,580, issued on
March 27, 2012, titled "CASSETTE FILTER MANIFOLD" (the "580 Patent"; Exhibit N) (the
design patents collectively referred to herein as the "CASSETTE FILTER Design Patents"); and
d) U.S. Patent No. 9,061,225 issued on June 23, 2015, titled "REINFORCED RECEIVER FOR
CASSETTE FILTER LOCKING CLIP" (the "225 Patent"; Exhibit O); (the design patents and the
Reinforced Receiver utility patent are collectively referred to herein as the "CASSETTE FILTER
Technology Patents").
40. Relevant independent claims of the '225 Patent include Claims 1 and 11. Claim 1 of the
'225 Patent is directed to a receiver for a cassette filter:
1. A receiver for a cassette filter housing having an upper housing surface the
receiver comprising:
an arrow shaped elongated member parallel with an upper surface of the
cassette, the elongated member having ends and including a base portion
attached to the upper housing surface the cross-section of which is a

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substantially planer segment extending to the upper surface, and an upper


receiver portion having at least one cavaliered retaining surface; and
a first reinforcement member extending outward from the base portion
adjacent one of the ends of the elongated member and perpendicular to the
elongated member, and a second reinforcement member extending
outward from the base portion adjacent the opposite end of the elongated
member and perpendicular to the elongated member the reinforcement
members affixed to the base portion and the upper housing surface;
whereby the elongated member is engagable with a locking clip having at least
one foot engagable with the at least one retaining surface when the
receiver and locking clip are in the locked position and the reinforcement
member provides support for the receiver.
'225 Patent, Claim 1; Exhibit O.
41. Claim 11 of the '225 Patent is directed to a cassette filter housing:
11. A receiver for a cassette filter housing having an upper housing surface the
receiver comprising:
a fixed, immobile elongated member parallel with an upper surface of the
cassette, the elongated member including a base portion attached to the
upper housing surface and an upper receiver portion having at least one
retaining surface, said base portion being substantially centered on the
elongated member and retains the elongated member in a fixed position;
and
at least one triangular reinforced end member integrally formed with the
elongated member and the upper housing surface;
whereby the elongated member is engagable with a slidably engaging
manifold locking clip having at least one foot engagable with the at least
one retaining surface when the receiver and locking clip are in the locked
position and the at least one triangular reinforced end member provides
support for the receiver.
'225 Patent, Claim 11; Exhibit O.
V. CLAIMS FOR RELIEF
FIRST COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Zuma Water Filters, Inc. d/b/a Zuma Filters)
42. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.

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43. Plaintiff KXT is informed and believes that defendant Zuma Water Filters, Inc. d/b/a
Zuma Filters ("Zuma") has infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C.
271(a) by making, using, offering for sale and/or selling in this district and elsewhere in the
United States a filter housing assembly identified by the invention disclosed and claimed in the
'146 Patent. Such infringing device includes the replacement filter by Zuma Filters for the
Frigidaire PureSource ULTRAWF filter cartridge, Model No. OPFE1-RF300 ("Defendants'
ULTRAWF Replacement Cartridge"). Exhibit A.
44. Photographs of defendant Zuma's ULTRAWF Replacement Cartridge and its packaging,
and photographs depicting the salient features of the filter key, are attached in Exhibit A.
45. Defendant Zuma's' ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of Exhibit
A, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.

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46. Plaintiff KXT is informed and believes that defendant Zuma has infringed Claim 15 of the
'146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
47. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of defendant
Zuma through interactive websites on the Internet and through other means.
48. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by defendant Zuma by making, using, offering for sale and selling
said infringing device has been repeated with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
49. As a direct and proximate result of defendant Zuma's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
50. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Zuma is preliminarily and permanently enjoined from their unlawful and willful
infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
SECOND COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to U.S. Water Filters, Inc. d/b/a Tier1 and Water Filters Direct LLC d/b/a Tier1)
51. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.

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52. Plaintiff KXT is informed and believes that defendants U.S. Water Filters, Inc. d/b/a Tier1
and Water Filters Direct LLC d/b/a Tier1 (collectively, "Tier1") have infringed Claims 1, 2, 3, 6,
and 7 of the '146 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or
selling in this district and elsewhere in the United States a filter housing assembly identified by
the invention disclosed and claimed in the '146 Patent. Such infringing device includes the
replacement filter by U.S. Water Filters, Inc. d/b/a Tier1 and Water Filters Direct LLC d/b/a Tier1
for the Frigidaire PureSource ULTRAWF filter cartridge, Model No. RWF1180 ("Defendants'
ULTRAWF Replacement Cartridge"). Exhibits B & C.
53. On January 19, 2016, Defendants Water Filters Direct LLC and U.S. Water Filters, Inc.,
both doing business under the umbrella entity and/or brand name of "Tier1" were notified by
United States Certified Mail (No. 7009 2250 0002 0062 6786) that they were offering for sale
and/or selling water filters that infringed the " '146 Patent", and were requested by Plaintiff KXT
to cease and desist the infringing activities. Exhibit B.
54. Photographs of Defendants' Tier1 ULTRAWF Replacement Cartridge and its packaging,
and photographs depicting the salient features of the filter key, are attached in Exhibit B.
55. Defendants' Tier1 ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of Exhibit
B, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced

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protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
56. Plaintiff KXT is informed and believes that Defendants Tier1 have infringed Claim 15 of
the '146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
57. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendants
Tier1 through interactive websites on the Internet and through other means. Exhibits B & C.
58. Plaintiff KXT is informed and believes that Defendants knew of the '146 Patent, and knew
that their activities would lead to direct infringement of the filter housing assembly claims, and
inducing infringement of the method claim for extracting a filter housing assembly, identified by
the '146 Patent.
59. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendants Tier1 by making, using, offering for sale and
selling said infringing device, and by continuing to do so has been repeated and willful with

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conscious disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this
Court.
60. As a direct and proximate result of Defendants Tier1 acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
61. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendants Tier1 are preliminarily and permanently enjoined from their unlawful and
willful infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
THIRD COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Clearwater Filters d/b/a Mist by Clearwater)
62. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
63. Plaintiff KXT is informed and believes that defendant Clearwater Filters d/b/a Mist by
Clearwater ("Mist") have infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C.
271(a) by making, using, offering for sale and/or selling in this district and elsewhere in the
United States a filter housing assembly identified by the invention disclosed and claimed in the
'146 Patent. Such infringing device includes the replacement filter by Clearwater Filters d/b/a Mist
by Clearwater for the Frigidaire PureSource ULTRAWF filter cartridge, Model No. CWMF011
("Defendants' ULTRAWF Replacement Cartridge"). Exhibit D.
64. Photographs of Defendant Mist's ULTRAWF Replacement Cartridge and its packaging,
and photographs depicting the salient features of the filter key, are depicted in Exhibit D.

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65. Defendant Mist's ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of Exhibit
D, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
66. Plaintiff KXT is informed and believes that defendant Mist has infringed Claim 15 of the
'146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
67. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of defendant
Mist through interactive websites on the Internet and through other means.
68. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by defendant Mist by making, using, offering for sale and selling

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said infringing device has been repeated with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
69. As a direct and proximate result of defendant Mists acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
70. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Mist is preliminarily and permanently enjoined from their unlawful
infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
FOURTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Waterfall Filter Company d/b/a Waterfall Filter)
71. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
72. Plaintiff KXT is informed and believes that defendant Waterfall Filter Company d/b/a
Waterfall Filter ("Waterfall") has infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35
U.S.C. 271(a) by making, using, offering for sale and/or selling in this district and elsewhere in
the United States a filter housing assembly identified by the invention disclosed and claimed in
the '146 Patent. Such infringing device includes the replacement filter by Waterfall Filter
Company d/b/a Waterfall Filter for the Frigidaire PureSource ULTRAWF filter cartridge, Model
No. WFC4401 ("Defendants' ULTRAWF Replacement Cartridge"). Exhibit E.
73. Photographs of Defendant Waterfall's ULTRAWF Replacement Cartridge and its
packaging, and photographs depicting the salient features of the filter key, are depicted in Exhibit
E.

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74. Defendant Waterfall's ULTRAWF Replacement Cartridge embodies all of the limitations
and features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of
Exhibit E, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
75. Plaintiff KXT is informed and believes that defendant Waterfall has infringed Claim 15 of
the '146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
76. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Waterfall through interactive websites on the Internet and through other means.
77. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant Waterfall by making, using, offering for sale and

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selling said infringing device has been repeated with conscious disregard for the rights of Plaintiff
KXT, and will continue unless enjoined by this Court.
78. As a direct and proximate result of defendant Waterfall's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
79. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Waterfall is preliminarily and permanently enjoined from their unlawful and
willful infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
FIFTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Bluesky d/b/a IcePure)
80. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
81. Plaintiff KXT is informed and believes that defendant Bluesky d/b/a IcePure ("IcePure")
has infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C. 271(a) by making,
using, offering for sale and/or selling in this district and elsewhere in the United States a filter
housing assembly identified by the invention disclosed and claimed in the '146 Patent. Such
infringing device includes the replacement filter by Bluesky d/b/a IcePure for the Frigidaire
PureSource ULTRAWF filter cartridge, Model No. RFC2200A ("Defendants' ULTRAWF
Replacement Cartridge"). Exhibit F.
82. Photographs of defendant IcePure's ULTRAWF Replacement Cartridge and its packaging,
and photographs depicting the salient features of the filter key, are depicted in Exhibit F.

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83. Defendant IcePure's ULTRAWF Replacement Cartridge embodies all of the limitations
and features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of
Exhibit F, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
84. Plaintiff KXT is informed and believes that Defendant IcePure has infringed Claim 15 of
the '146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
85. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
IcePure through interactive websites on the Internet and through other means.
86. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant IcePure by making, using, offering for sale and

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21

selling said infringing device has been repeated with conscious disregard for the rights of Plaintiff
KXT, and will continue unless enjoined by this Court.
87. As a direct and proximate result of Defendant IcePure's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
88. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant IcePure is preliminarily and permanently enjoined from their unlawful and
willful infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
SIXTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Best Filters d/b/a Best)
89. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
90. Plaintiff KXT is informed and believes that Defendant Best Filters d/b/a Best ("Best")
have infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C. 271(a) by making,
using, offering for sale and/or selling in this district and elsewhere in the United States a filter
housing assembly identified by the invention disclosed and claimed in the '146 Patent. Such
infringing device includes the replacement filter by Best for the Frigidaire PureSource
ULTRAWF filter cartridge, Model No. ULTRA WF ("Defendant Best's ULTRAWF Replacement
Cartridge"). Exhibit G.
91. Photographs of Defendant Best's ULTRAWF Replacement Cartridge and its packaging,
and photographs depicting the salient features of the filter key, are attached in Exhibit G.

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92. Defendant Best's ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of Exhibit
G, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
93. Plaintiff KXT is informed and believes that Defendant Best has infringed Claim 15 of the
'146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
94. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Best through interactive websites on the Internet and through other means.
95. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant Best by making, using, offering for sale and selling

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23

said infringing device has been repeated with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
96. As a direct and proximate result of Defendant Best's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
97. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Best is preliminarily and permanently enjoined from their unlawful and willful
infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
SEVENTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Shopstic, Inc. d/b/a Alpine Water)
98. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
99. Plaintiff KXT is informed and believes that Defendant Shopstic, Inc. d/b/a Alpine Water
("Alpine") have infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C. 271(a) by
making, using, offering for sale and/or selling in this district and elsewhere in the United States a
filter housing assembly identified by the invention disclosed and claimed in the '146 Patent. Such
infringing device includes the replacement filter by Shopstic, Inc. d/b/a Alpine Water for the
Frigidaire PureSource ULTRAWF filter cartridge ("Defendant Alpine's ULTRAWF Replacement
Cartridge"). Exhibit H.
100. Photographs of Defendant Alpine's ULTRAWF Replacement Cartridge and its
packaging, and photographs depicting the salient features of the filter key, are depicted in Exhibit
H.

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24

101. Defendant Alpine's ULTRAWF Replacement Cartridge embodies all of the limitations
and features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of
Exhibit H, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key, where
the fingers include winged extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter
housing; and
e) the spaced protrusions or fingers being integrally formed with the filter key.
102. Plaintiff KXT is informed and believes that Defendant has infringed Claim 15 of the
'146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
103. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Alpine through interactive websites on the Internet and through other means.
104. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant Alpine by making, using, offering for sale and

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25

selling said infringing device has been repeated with conscious disregard for the rights of Plaintiff
KXT, and will continue unless enjoined by this Court.
105. As a direct and proximate result of Defendant Alpine's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
106. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Alpine is preliminarily and permanently enjoined from their unlawful and
willful infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
EIGHTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Dista Filter d/b/a Dista)
107. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
108. Plaintiff KXT is informed and believes that Defendant Dista Filter d/b/a Dista ("Dista")
has infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C. 271(a) by making,
using, offering for sale and/or selling in this district and elsewhere in the United States a filter
housing assembly identified by the invention disclosed and claimed in the '146 Patent. Such
infringing device includes the replacement filter by Dista Filter d/b/a Dista for the Frigidaire
PureSource ULTRAWF filter cartridge, Model No. DWF-22 ("Defendant Dista's ULTRAWF
Replacement Cartridge"). Exhibit I.
109. Photographs of Defendant Dista's ULTRAWF Replacement Cartridge and its packaging
and photographs depicting the salient features of the filter key, are attached as Exhibit I.

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26

110. Defendant Dista's ULTRAWF Replacement Cartridge embodies all of the limitations
and features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of
Exhibit I, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having longitudinal
sides 18 and lateral sides 20 including a plurality of spaced protrusions or fingers 22
extending from the top surface of the filter key, where the fingers include winged
extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit, friction
fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing; and
e) the spaced protrusions or fingers being integrally formed with the filter key.
111. Plaintiff KXT is informed and believes that Defendant Dista has infringed Claim 15 of
the '146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
112. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Dista through interactive websites on the Internet and through other means.
113. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant Dista by making, using, offering for sale and selling
said infringing device has been repeated with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.

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114. As a direct and proximate result of Defendant Dista's acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
115. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Dista is preliminarily and permanently enjoined from their unlawful and willful
infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
NINTH COUNT
Patent Infringement of U.S. Patent No. 8,673,146
(as to Eternawater d/b/a Eternawater)
116. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 inclusive.
117. Plaintiff KXT is informed and believes that Defendant Eternawater d/b/a Eternawater
("Eternawater") has infringed Claims 1, 2, 3, 6, and 7 of the '146 Patent under 35 U.S.C. 271(a)
by making, using, offering for sale and/or selling in this district and elsewhere in the United States
a filter housing assembly identified by the invention disclosed and claimed in the '146 Patent.
Such infringing device includes the replacement filter by Eternawater for the Frigidaire
PureSource ULTRAWF filter cartridge, Model No. EWRF1022 ("Defendants' ULTRAWF
Replacement Cartridge"). Exhibit J.
118. Photographs of Defendant Eternawater's ULTRAWF Replacement Cartridge and its
packaging, and photographs depicting the salient features of the filter key, are depicted in Exhibit
J.

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28

119. Defendant Eternawater's ULTRAWF Replacement Cartridge embodies all of the


limitations and features of Claims 1, 2, 3, 6, and 7 of the '146 Patent as shown in the annotated
photos of Exhibit J, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having longitudinal
sides 18 and lateral sides 20 including a plurality of spaced protrusions or fingers 22
extending from the top surface of the filter key, where the fingers include winged
extensions having slanted or angled faces 24;
c) the filter key being attached to the filter housing top portion by a snap fit, friction
fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing; and
e) the spaced protrusions or fingers being integrally formed with the filter key.
120. Plaintiff KXT is informed and believes that Defendant Eternawater has infringed Claim
15 of the '146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method
for extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
121. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Eternawater through interactive websites on the Internet and through other means.
122. Plaintiff KXT is informed and believes that the direct infringement and inducement of
infringement of the '146 Patent by Defendant Eternawater by making, using, offering for sale and
selling said infringing device, and by continuing to do so has been repeated and willful with

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29

conscious disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this
Court.
123. As a direct and proximate result of Defendant Eternawater's acts of patent infringement
and inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
124. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Eternawater is preliminarily and permanently enjoined from their unlawful and
willful infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
TENTH COUNT
Patent Infringement of the CASSETTE FILTER Technology Patents
(as to Waterfall Filter Company d/b/a Waterfall Filter)
125. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 and 72-79
inclusive.
126. Plaintiff KXT is informed and believes that Defendant Waterfall has infringed Claims 15 and 11-17 of the '225 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or
selling in this district and elsewhere in the United States a filter housing assembly identified by
the invention disclosed and claimed in the '225 Patent. Such infringing device includes the
replacement filter by Waterfall for the Frigidaire PureSource WF2CB filter cartridge, Model No.
WFC6601. Exhibit E.
127. Photographs of Defendant Waterfall's replacement filter and its packaging are attached
in Exhibit E.

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30

128. Defendant Waterfall's replacement filter embodies all of the limitations and features of
Claims 1-5 and 11-15 of the '225 Patent as shown in the annotated photos of Exhibit E, including:
a) an arrow shaped elongated member 100 parallel with an upper surface 105 of the cassette
110;
b) the elongated member having ends 112, 114 and including a base portion 116 attached to
the upper housing surface 105 the cross-section of which is a substantially planer segment
extending to the upper surface;
c) an upper receiver portion 120 having at least one retaining surface 122;
d) a first reinforcement member 124 extending outward from the base portion adjacent one of
the ends of the elongated member and perpendicular to the elongated member; and
e) a second reinforcement member 126 extending outward from the base portion adjacent the
opposite end of the elongated member and perpendicular to the elongated member the
reinforcement members affixed to the base portion and the upper housing surface.
129. Plaintiff KXT is informed and believes that Defendant Waterfall has infringed the
CASSETTE FILTER Design Patents by making, using, offering for sale and/or selling in this
district and elsewhere in the United States a cassette filter assembly incorporating the patented
ornamental design features disclosed and claimed in the CASSETTE FILTER Design Patents.
130. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Waterfall through interactive websites on the Internet and through other means. Exhibit E.

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131. Plaintiff KXT is informed and believes that Defendant Waterfall knew or should have
known of the CASSETTE FILTER Technology Patents, and that their activities would lead to
direct infringement thereof.
132. Plaintiff KXT is informed and believes that the infringement of the CASSETTE FILTER
Technology Patents by Defendant Waterfall by making, using, offering for sale and selling said
infringing device, and by continuing to do so has been repeated and willful with conscious
disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this Court.
133. As a direct and proximate result of Defendant Waterfall's acts of patent infringement,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
substantial damages in an amount not presently known.
134. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Waterfall is preliminarily and permanently enjoined from their unlawful and
willful infringement of the CASSETTE FILTER Technology Patents, Plaintiff KXT will suffer
irreparable harm.
ELEVENTH COUNT
Patent Infringement of the CASSETTE FILTER Technology Patents
(as to Bluesky d/b/a IcePure)
135. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 and 81-88
inclusive.
136. Plaintiff KXT is informed and believes that Defendant IcePure has infringed Claims 1-5
and 11-17 of the '225 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or
selling in this district and elsewhere in the United States a filter housing assembly identified by

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32

the invention disclosed and claimed in the '225 Patent. Such infringing device includes the
replacement filter by IcePure for the Frigidaire PureSource WF2CB filter cartridge, Model No.
RWF3300A. Exhibit F.
137. Photographs of Defendant IcePure's replacement filter and its packaging are attached in
Exhibit F.
138. Defendant IcePure's replacement filter embodies all of the limitations and features of
Claims 1-5 and 11-15 of the '225 Patent as shown in the annotated photos of Exhibit F, including:
a)

an arrow shaped elongated member 100 parallel with an upper surface 105 of the
cassette 110;

b)

the elongated member having ends 112, 114 and including a base portion 116 attached to

the upper housing surface 105 the cross-section of which is a substantially planer segment
extending to the upper surface;
c)

an upper receiver portion 120 having at least one retaining surface 122;

d)

a first reinforcement member 124 extending outward from the base portion adjacent one

of the ends of the elongated member and perpendicular to the elongated member; and
e)

a second reinforcement member 126 extending outward from the base portion adjacent

the opposite end of the elongated member and perpendicular to the elongated member the
reinforcement members affixed to the base portion and the upper housing surface.
139. Plaintiff KXT is informed and believes that Defendant IcePure has infringed the
CASSETTE FILTER Design Patents by making, using, offering for sale and/or selling in this

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33

district and elsewhere in the United States a cassette filter assembly incorporating the patented
ornamental design features disclosed and claimed in the CASSETTE FILTER Design Patents.
140. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
IcePure through interactive websites on the Internet and through other means. Exhibit F.
141. Plaintiff KXT is informed and believes that Defendant IcePure knew or should have
known of the CASSETTE FILTER Technology Patents, and that their activities would lead to
direct infringement thereof.
142. Plaintiff KXT is informed and believes that the infringement of the CASSETTE FILTER
Technology Patents by Defendant IcePure by making, using, offering for sale and selling said
infringing device, and by continuing to do so has been repeated and willful with conscious
disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this Court.
143. As a direct and proximate result of Defendant IcePure's acts of patent infringement,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
substantial damages in an amount not presently known.
144. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant IcePure is preliminarily and permanently enjoined from their unlawful and
willful infringement of the CASSETTE FILTER Technology Patents, Plaintiff KXT will suffer
irreparable harm.

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34

TWELFTH COUNT
Patent Infringement of the CASSETTE FILTER Technology Patents
(as to Dista Filter d/b/a Dista)
145. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 and 108115 inclusive.
146. Plaintiff KXT is informed and believes that Defendant Dista has infringed Claims 1-5
and 11-17 of the '225 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or
selling in this district and elsewhere in the United States a filter housing assembly identified by
the invention disclosed and claimed in the '225 Patent. Such infringing device includes the
replacement filter by Dista for the Frigidaire PureSource WF2CB filter cartridge, Model No.
DWF-33. Exhibit I.
147. Photographs of Defendant Dista's replacement filter and its packaging are attached in
Exhibit I.
148. Defendant Dista's replacement filter embodies all of the limitations and features of
Claims 1-5 and 11-15 of the '225 Patent as shown in the annotated photos of Exhibit I, including:
a) an arrow shaped elongated member 100 parallel with an upper surface 105 of the cassette
110;
b) the elongated member having ends 112, 114 and including a base portion 116 attached to
the upper housing surface 105 the cross-section of which is a substantially planer segment
extending to the upper surface;
c) an upper receiver portion 120 having at least one retaining surface 122;

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35

d) a first reinforcement member 124 extending outward from the base portion adjacent one of
the ends of the elongated member and perpendicular to the elongated member; and
e) a second reinforcement member 126 extending outward from the base portion adjacent the
opposite end of the elongated member and perpendicular to the elongated member the
reinforcement members affixed to the base portion and the upper housing surface.
149. Plaintiff KXT is informed and believes that Defendant Dista has infringed the
CASSETTE FILTER Design Patents by making, using, offering for sale and/or selling in this
district and elsewhere in the United States a cassette filter assembly incorporating the patented
ornamental design features disclosed and claimed in the CASSETTE FILTER Design Patents.
150. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Dista through interactive websites on the Internet and through other means. Exhibit I.
151. Plaintiff KXT is informed and believes that Defendant Dista knew or should have
known of the CASSETTE FILTER Technology Patents, and that their activities would lead to
direct infringement thereof.
152. Plaintiff KXT is informed and believes that the infringement of the CASSETTE FILTER
Technology Patents by Defendant Dista by making, using, offering for sale and selling said
infringing device, and by continuing to do so has been repeated and willful with conscious
disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this Court.

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153. As a direct and proximate result of Defendant Dista's acts of patent infringement,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
substantial damages in an amount not presently known.
154. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Dista is preliminarily and permanently enjoined from their unlawful and willful
infringement of the CASSETTE FILTER Technology Patents, Plaintiff KXT will suffer
irreparable harm.
THIRTEENTH COUNT
Patent Infringement of the CASSETTE FILTER Technology Patents
(as to Eternawater)
155. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41 and 117124 inclusive.
156. Plaintiff KXT is informed and believes that Defendant Eternawater has infringed Claims
1-5 and 11-17 of the '225 Patent under 35 U.S.C. 271(a) by making, using, offering for sale
and/or selling in this district and elsewhere in the United States a filter housing assembly
identified by the invention disclosed and claimed in the '225 Patent. Such infringing device
includes the replacement filter by Eternawater for the Frigidaire PureSource WF2CB filter
cartridge, Model No. EWRF1016. Exhibit J.
157. Photographs of Defendant Eternawater's replacement filter and its packaging are
attached in Exhibit J.

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158. Defendant Eternawater's replacement filter embodies all of the limitations and features
of Claims 1-5 and 11-15 of the '225 Patent as shown in the annotated photos of Exhibit J,
including:
a) an arrow shaped elongated member 100 parallel with an upper surface 105 of the cassette
110;
b) the elongated member having ends 112, 114 and including a base portion 116 attached to
the upper housing surface 105 the cross-section of which is a substantially planer segment
extending to the upper surface;
c) an upper receiver portion 120 having at least one retaining surface 122;
d) a first reinforcement member 124 extending outward from the base portion adjacent one of
the ends of the elongated member and perpendicular to the elongated member; and
e) a second reinforcement member 126 extending outward from the base portion adjacent the
opposite end of the elongated member and perpendicular to the elongated member the
reinforcement members affixed to the base portion and the upper housing surface.
159. Plaintiff KXT is informed and believes that Defendant Eternawater has infringed the
CASSETTE FILTER Design Patents by making, using, offering for sale and/or selling in this
district and elsewhere in the United States a cassette filter assembly incorporating the patented
ornamental design features disclosed and claimed in the CASSETTE FILTER Design Patents.
160. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of Defendant
Eternawater through interactive websites on the Internet and through other means. Exhibit J.

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161. Plaintiff KXT is informed and believes that Defendant Eternawater knew or should have
known of the CASSETTE FILTER Technology Patents, and that their activities would lead to
direct infringement thereof.
162. Plaintiff KXT is informed and believes that the infringement of the CASSETTE FILTER
Technology Patents by Defendant Eternawater by making, using, offering for sale and selling said
infringing device, and by continuing to do so has been repeated and willful with conscious
disregard for the rights of Plaintiff KXT, and will continue unless enjoined by this Court.
163. As a direct and proximate result of Defendant Eternawater's acts of patent infringement,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
substantial damages in an amount not presently known.
164. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendant Eternawater is preliminarily and permanently enjoined from their unlawful and
willful infringement of the CASSETTE FILTER Technology Patents, Plaintiff KXT will suffer
irreparable harm.
FOURTEENTH COUNT
UNFAIR COMPETITION IN VIOLATION OF THE LANHAM ACT
(15 U.S.C. 1125, Et Seq.)
(as to Zuma Water Filters, Inc. d/b/a Zuma Filters)
165. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-50 inclusive.
166. This is an action for unfair competition in the conduct of the Defendant Zuma's trade in
violation of the Lanham Act, Section 43 (15 U.S.C. 1125(a)).

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 39 of 50

39

167. Plaintiff KXT is informed and believes that Defendant Zuma has sold, advertised,
promoted and continues to sell, advertise, and promote competing goods and services offered by
KXT in this district and in the same channels of interstate commerce as Plaintiff, which falsely
bear the certified mark of the Water Quality Association ("WQA"). Exhibit A.
168. The WQA is a not-for-profit association for the residential, commercial, and
industrial water treatment industry.
169. The WQA certifies products for the water treatment industry. As stated on the WQA
website (www.wqa.org/product-cert):
Certified Products Have a "Leg Up" in the Marketplace
Finding quality products in a marketplace flooded with options can be
challenging. How can you tell if a product is safe, reliable, durable and capable
of meeting the claims made on its packaging and literature?
WQA's Certified Product Listings are available to help connect consumers
with water treatment products that have been tested and certified to industry
standards.
WQA's Gold Seal Product Certification Program ensures that the product is
constructed or formulated from safe materials, the claims listed on the packaging
are backed by test data, and the product will hold up under normal usage
conditions.
WQA maintains a complete listing of all products and components that have
earned the Gold Seal and Sustainability Marks. Only products that pass the
rigorous testing requirements of industry standards, pass annual manufacturing
facility audits, and comply with WQA's Certification Schemes can be found in
this listing.
www.wqa.org/product-cert (emphasis added); Exhibit P.
170. Some of the benefits of a WQA certification include, inter alia: a) certified products
bearing a distinguished WQA Mark indicate that the product has undergone evaluation and
testing to verify that the product will perform as the certified claims indicate, which provides
consumers a very simple way to recognize products that will perform the way the packaging

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 40 of 50

40

indicates it will; b) WQA certified products allow for consumers to target the specific
contaminant issues with confidence that the product does what it claims it will do; c) WQA
certified products are demonstrated to pass some states or local city specific regulations (e.g.,
California has passed new legislation that will require an ANSI accredited certifier to issue
certification to products making health claims before they can be legally sold in California.
Products certified by WQA are demonstrated to be safe for purchase in California.). Exhibit
P.
171. Section 43 of the Lanham Act states in pertinent part:
(1) Any person who, on or in connection with any goods or services, or any
container for goods, uses in commerce any word, term, name, symbol, or device, or
any combination thereof, or any false designation of origin, false or misleading
description of fact, or false or misleading representation of fact, which
(A) is likely to cause confusion, or to cause mistake, or to deceive as to the
affiliation, connection, or association of such person with another person, or as to
the origin, sponsorship, or approval of his or her goods, services, or commercial
activities by another person, or
(B) in commercial advertising or promotion, misrepresents the nature,
characteristics, qualities, or geographic origin of his or her or another person's
goods, services, or commercial activities,
shall be liable in a civil action by any person who believes that he or she is or is
likely to be damaged by such act.
15 U.S.C. 1125 (emphasis added).
172. On information and belief, Defendant Zuma's use of the WQA mark in this district is
likely to deceive purchasers and potential customers as to the sponsorship or approval of
Defendant Zuma's goods, and misrepresents the nature, characteristic, and quality of its goods.

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 41 of 50

41

173. As a direct and proximate result of Defendant Zuma's acts of unfair competition,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
damages in an amount not presently known.
174. Defendant Zuma's unfair competition will continue unless enjoined by this Court.
FIFTEENTH COUNT
UNFAIR COMPETITION IN VIOLATION OF THE LANHAM ACT
(15 U.S.C. 1125, Et Seq.)
(as to Waterfall Filter Company d/b/a Waterfall Filter)
175. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41, 72-79, and
126-134 inclusive.
176. This is an action for unfair competition in the conduct of the Defendant Waterfall's trade
in violation of the Lanham Act, Section 43 (15 U.S.C. 1125(a)).
177. Plaintiff KXT is informed and believes that Defendant Waterfall has sold, advertised,
promoted and continues to sell, advertise, and promote competing goods and services offered by
KXT in this district and in the same channels of interstate commerce as Plaintiff, which falsely
bear the certified mark of the Water Quality Association ("WQA"). Exhibit E.
178. The WQA is a not-for-profit association for the residential, commercial, and
industrial water treatment industry.
179. The WQA certifies products for the water treatment industry. As stated on the WQA
website (www.wqa.org/product-cert):
Certified Products Have a "Leg Up" in the Marketplace
Finding quality products in a marketplace flooded with options can be
challenging. How can you tell if a product is safe, reliable, durable and capable
of meeting the claims made on its packaging and literature?

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 42 of 50

42

WQA's Certified Product Listings are available to help connect consumers


with water treatment products that have been tested and certified to industry
standards.
WQA's Gold Seal Product Certification Program ensures that the product is
constructed or formulated from safe materials, the claims listed on the packaging
are backed by test data, and the product will hold up under normal usage
conditions.
WQA maintains a complete listing of all products and components that have
earned the Gold Seal and Sustainability Marks. Only products that pass the
rigorous testing requirements of industry standards, pass annual manufacturing
facility audits, and comply with WQA's Certification Schemes can be found in
this listing.
www.wqa.org/product-cert (emphasis added); Exhibit P.
180. Some of the benefits of a WQA certification include, inter alia: a) certified products
bearing a distinguished WQA Mark indicate that the product has undergone evaluation and
testing to verify that the product will perform as the certified claims indicate, which provides
consumers a very simple way to recognize products that will perform the way the packaging
indicates it will; b) WQA certified products allow for consumers to target the specific
contaminant issues with confidence that the product does what it claims it will do; c) WQA
certified products are demonstrated to pass some states or local city specific regulations (e.g.,
California has passed new legislation that will require an ANSI accredited certifier to issue
certification to products making health claims before they can be legally sold in California.
Products certified by WQA are demonstrated to be safe for purchase in California.). Exhibit
P.
181. Section 43 of the Lanham Act states in pertinent part:
(1) Any person who, on or in connection with any goods or services, or any
container for goods, uses in commerce any word, term, name, symbol, or device, or

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 43 of 50

43

any combination thereof, or any false designation of origin, false or misleading


description of fact, or false or misleading representation of fact, which
(A) is likely to cause confusion, or to cause mistake, or to deceive as to the
affiliation, connection, or association of such person with another person, or as to
the origin, sponsorship, or approval of his or her goods, services, or commercial
activities by another person, or
(B) in commercial advertising or promotion, misrepresents the nature,
characteristics, qualities, or geographic origin of his or her or another person's
goods, services, or commercial activities,
shall be liable in a civil action by any person who believes that he or she is or is
likely to be damaged by such act.
15 U.S.C. 1125 (emphasis added).
182. On information and belief, Defendant Waterfall's use of the WQA mark in this district is
likely to deceive purchasers and potential customers as to the sponsorship or approval of
Defendant Waterfall's goods, and misrepresents the nature, characteristic, and quality of its goods.
183. As a direct and proximate result of Defendant Waterfall's acts of unfair competition,
Plaintiff KXT has been and continues to be injured, and has sustained and will continue to sustain
damages in an amount not presently known.
184. Defendant Waterfall's unfair competition will continue unless enjoined by this Court.
SIXTEENTH COUNT
UNFAIR COMPETITION IN VIOLATION OF THE LANHAM ACT
(15 U.S.C. 1125, Et Seq.)
(as to Dista Filter d/b/a Dista)
185. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-41, 108-115,
and 146-154 inclusive.
186. This is an action for unfair competition in the conduct of the Defendant Dista's trade in
violation of the Lanham Act, Section 43 (15 U.S.C. 1125(a)).

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 44 of 50

44

187. Plaintiff KXT is informed and believes that Defendant Dista has sold, advertised,
promoted and continues to sell, advertise, and promote competing goods and services offered by
KXT in this district and in the same channels of interstate commerce as Plaintiff, which falsely
bear the certified mark of the Water Quality Association ("WQA"). Exhibit I.
188. The WQA is a not-for-profit association for the residential, commercial, and
industrial water treatment industry.
189. The WQA certifies products for the water treatment industry. As stated on the WQA
website (www.wqa.org/product-cert):
Certified Products Have a "Leg Up" in the Marketplace
Finding quality products in a marketplace flooded with options can be
challenging. How can you tell if a product is safe, reliable, durable and capable
of meeting the claims made on its packaging and literature?
WQA's Certified Product Listings are available to help connect consumers
with water treatment products that have been tested and certified to industry
standards.
WQA's Gold Seal Product Certification Program ensures that the product is
constructed or formulated from safe materials, the claims listed on the packaging
are backed by test data, and the product will hold up under normal usage
conditions.
WQA maintains a complete listing of all products and components that have
earned the Gold Seal and Sustainability Marks. Only products that pass the
rigorous testing requirements of industry standards, pass annual manufacturing
facility audits, and comply with WQA's Certification Schemes can be found in
this listing.
www.wqa.org/product-cert (emphasis added); Exhibit P.
190. Some of the benefits of a WQA certification include, inter alia: a) certified products
bearing a distinguished WQA Mark indicate that the product has undergone evaluation and
testing to verify that the product will perform as the certified claims indicate, which provides
consumers a very simple way to recognize products that will perform the way the packaging

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 45 of 50

45

indicates it will; b) WQA certified products allow for consumers to target the specific
contaminant issues with confidence that the product does what it claims it will do; c) WQA
certified products are demonstrated to pass some states or local city specific regulations (e.g.,
California has passed new legislation that will require an ANSI accredited certifier to issue
certification to products making health claims before they can be legally sold in California.
Products certified by WQA are demonstrated to be safe for purchase in California.). Exhibit
P.
191. Section 43 of the Lanham Act states in pertinent part:
(1) Any person who, on or in connection with any goods or services, or any
container for goods, uses in commerce any word, term, name, symbol, or device, or
any combination thereof, or any false designation of origin, false or misleading
description of fact, or false or misleading representation of fact, which
(A) is likely to cause confusion, or to cause mistake, or to deceive as to the
affiliation, connection, or association of such person with another person, or as to
the origin, sponsorship, or approval of his or her goods, services, or commercial
activities by another person, or
(B) in commercial advertising or promotion, misrepresents the nature,
characteristics, qualities, or geographic origin of his or her or another person's
goods, services, or commercial activities,
shall be liable in a civil action by any person who believes that he or she is or is
likely to be damaged by such act.
15 U.S.C. 1125 (emphasis added).
192. On information and belief, Defendant Dista's use of the WQA mark in this district is
likely to deceive purchasers and potential customers as to the sponsorship or approval of
Defendant Dista's goods, and misrepresents the nature, characteristic, and quality of its goods.

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 46 of 50

46

193. As a direct and proximate result of Defendant Dista's acts of unfair competition, Plaintiff
KXT has been and continues to be injured, and has sustained and will continue to sustain damages
in an amount not presently known.
194. Defendant Dista's unfair competition will continue unless enjoined by this Court.
SEVENTEENTH COUNT
VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT UNDER
CONNECTICUT GENERAL STATUTES 42-110a, ET SEQ.
(as to Zuma Water Filters, Inc. d/b/a Zuma Filters)
195. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-50 and 166174 inclusive.
196. This is an action for unfair methods of competition, and unfair and deceptive acts and
practices in the conduct of the Defendant Zuma's trade in violation of the Connecticut Unfair
Trade Practices Act ("CUTPA"), pursuant to C.G.S. 42-11Oa, et seq.
197. This Court has pendent jurisdiction under 28 U.S.C. 1367(a). Venue is proper under 28
U.S.C. 1391.
198. By committing the acts herein alleged, Defendant Zuma has engaged in unfair methods
of competition and unfair and deceptive acts and practice in the conduct of trade within the State
of Connecticut in violation of C.G.S. 42-110a, et seq., causing confusion to consumers in the
trade, damage and loss profits to Plaintiff.
199. Defendant Zuma knew or should have known that the aforementioned acts are in
violation of C.G.S. 42-110a, et seq.

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 47 of 50

47

200. Plaintiff KXT has suffered an ascertainable loss of money and property as a result of
Defendant Zuma's acts or practices in this district prohibited by C.G.S. 42-110a, et seq.
EIGHTEENTH COUNT
VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT UNDER
CONNECTICUT GENERAL STATUTES 42-110a, ET SEQ.
(as to Waterfall Filter Company d/b/a Waterfall Filter)
201. Plaintiff re-alleges and incorporates herein the allegations of paragraphs 1-41, 72-79,
126-134, and 176-184 inclusive.
202. This is an action for unfair methods of competition, and unfair and deceptive acts and
practices in the conduct of the Defendant Waterfall's trade in violation of the Connecticut Unfair
Trade Practices Act ("CUTPA"), pursuant to C.G.S. 42-11Oa, et seq.
203. This Court has pendent jurisdiction under 28 U.S.C. 1367(a). Venue is proper under 28
U.S.C. 1391.
204. By committing the acts herein alleged, Defendant Waterfall has engaged in unfair
methods of competition and unfair and deceptive acts and practice in the conduct of trade within
the State of Connecticut in violation of C.G.S. 42-110a, et seq., causing confusion to
consumers in the trade, damage and loss profits to Plaintiff.
205. Defendant Waterfall knew or should have known that the aforementioned acts are in
violation of C.G.S. 42-110a, et seq.
206. Plaintiff KXT has suffered an ascertainable loss of money and property as a result of
Defendant Waterfall's acts or practices in this district prohibited by C.G.S. 42-110a, et seq.

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 48 of 50

48

NINETEENTH COUNT
VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT UNDER
CONNECTICUT GENERAL STATUTES 42-110a, ET SEQ.
(as to Dista Filter d/b/a Dista)
207. Plaintiff re-alleges and incorporates herein the allegations of paragraphs 1-41, 108-115,
146-154, and 186-194 inclusive.
208. This is an action for unfair methods of competition, and unfair and deceptive acts and
practices in the conduct of the Defendant Dista's trade in violation of the Connecticut Unfair
Trade Practices Act ("CUTPA"), pursuant to C.G.S. 42-11Oa, et seq.
209. This Court has pendent jurisdiction under 28 U.S.C. 1367(a). Venue is proper under 28
U.S.C. 1391.
210. By committing the acts herein alleged, Defendant Dista has engaged in unfair methods
of competition and unfair and deceptive acts and practice in the conduct of trade within the State
of Connecticut in violation of C.G.S. 42-110a, et seq., causing confusion to consumers in the
trade, damage and loss profits to Plaintiff.
211. Defendant Dista knew or should have known that the aforementioned acts are in
violation of C.G.S. 42-110a, et seq.
212. Plaintiff KXT has suffered an ascertainable loss of money and property as a result of
Defendant Dista's acts or practices in this district prohibited by C.G.S. 42-110a, et seq.

VI. PRAYER FOR RELIEF


WHEREFORE, Plaintiff KX Technologies, LLC prays for relief as follows:

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 49 of 50

49

1. That each respective Defendant, its respective officers, agents, servants, employees and
attorneys, and all other persons, firms, or corporations acting in concert or participation with it, be
enjoined and restrained, during the pendency of this action and permanently thereafter, from
making, using, offering for sale or selling any and all goods which infringe the aforementioned
United States patents;
2. That Plaintiff KXT recover its damages sustained as a result of each respective
Defendant's infringement pursuant to 35 U.S.C. 284;
3. That each respective Defendant's infringement be independently adjudged to be willful and
this case declared exceptional, and that Plaintiff's damages be trebled, pursuant to 35 U.S.C.
284;
4. That Plaintiff recover its reasonable costs, expenses, and attorney fees, pursuant to 35
U.S.C. 285;
5. That each Defendant, its respective officers, agents, servants, employees, and attorneys,
and all other persons, firms, or corporations acting in concert or participation with it, be ordered to
vacate or otherwise destroy infringing products, advertisements, catalogs, brochures, and alter all
internet sites that promote the infringing goods to remove any and all reference to the infringing
products, including implementing the remedies pursuant to 15 U.S.C. 1118;
6. That each respective Defendant account for (a) all gains, profits, and advantages derived
by said trade practices and unfair competition, and (b) all gains, profits, and advantages derived by
each Defendant's respective infringement of Plaintiffs intellectual property; and
7. That Plaintiff granted such other and further relief as the Court deems just and proper.

Case 3:16-cv-01433-SRU Document 1 Filed 08/23/16 Page 50 of 50

50

VII. DEMAND FOR JURY TRIAL


Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff KX Technologies,
LLC hereby demands a jury trial on all issues raised by the claims herein and triable of right by a
jury.

Respectfully submitted,
KX TECHNOLOGIES, LLC

Date: August 23, 2016

By: /s/ Robert Curcio


Robert Curcio
Fed. Bar No. CT18791

By: /s/ David R. Pegnataro


David R. Pegnataro
Fed. Bar No. CT28854
DELIO, PETERSON & CURCIO, LLC
700 State Street, Suite 402
New Haven, CT 06511
Tel: 203-787-0595
Fax: 203-787-5818
Email: efilings@delpet.com
Attorneys for Plaintiff
KXIN908_Complaint.doc

Case 3:16-cv-01433-SRU Document 1-1 Filed 08/23/16 Page 1 of 2

CIVIL COVER SHEET

JS 44 (Rev. 11/15)

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

KX Technologies, LLC

Zuma Water Filters, Inc. d/b/a Zuma Filters, et al.

New Haven, CT

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)


NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)

Pasadena, CA

(IN U.S. PLAINTIFF CASES ONLY)


IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

DeLio, Peterson & Curcio LLC


700 State Street, Suite 402
New Haven, CT 06511 - Phone: 203-787-0595

II. BASIS OF JURISDICTION (Place an X in One Box Only)


1

U.S. Government
Plaintiff

Federal Question
(U.S. Government Not a Party)

U.S. Government
Defendant

Diversity
(Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff


(For Diversity Cases Only)
PTF
Citizen of This State
1

DEF
1

and One Box for Defendant)


PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State

Citizen of Another State

Incorporated and Principal Place


of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

IV. NATURE OF SUIT (Place an X in One Box Only)


CONTRACT

TORTS

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

FORFEITURE/PENALTY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

625 Drug Related Seizure


of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS


870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions

OTHER STATUTES
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes

V. ORIGIN (Place an X in One Box Only)


1 Original
Proceeding

2 Removed from
State Court

Remanded from
Appellate Court

4 Reinstated or
Reopened

5 Transferred from
Another District
(specify)

6 Multidistrict
Litigation

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

35 USC 271, 15 USC 1125, CGS 42-110a

VI. CAUSE OF ACTION Brief description of cause:

Patent Infringement, Unfair Competition under Lanham Act, and violation of CUTPA

CHECK IF THIS IS A CLASS ACTION


VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE

CHECK YES only if demanded in complaint:


Yes
No
JURY DEMAND:

DEMAND $

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

/s/ Robert Curcio

08/23/2016
FOR OFFICE USE ONLY
RECEIPT #

AMOUNT

Print

APPLYING IFP

Save As...

JUDGE

MAG. JUDGE

Reset

JS 44 Reverse (Rev. 11/15)

Case 3:16-cv-01433-SRU Document 1-1 Filed 08/23/16 Page 2 of 2

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44


Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)

(b)

(c)

Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II.

Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III.

Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV.

Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.

V.

Origin. Place an "X" in one of the six boxes.


Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
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Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 1 of 24

EXHIBIT A

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 2 of 24

Corporate Registration

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 3 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 4 of 24

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 5 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 6 of 24

Frigidaire
Case 3:16-cv-01433-SRU Document
1-2 Ultrawf
Filed 08/23/16 Page 7 of 24

7/26/2016

Home / Appliances / Appliance Accessories / Results For: "frigidaire ultrawf'

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1/3

Frigidaire
Case 3:16-cv-01433-SRU Document
1-2 Ultrawf
Filed 08/23/16 Page 8 of 24

7/26/2016

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213

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Case 3:16-cv-01433-SRU Document
1-2 Ultrawf
Filed 08/23/16 Page 9 of 24

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Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 10 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 11 of 24

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 12 of 24


Discount Refrigerator Water and Ice Filters - FREE SHIPPING

Page 1 of3

Click here for Wholesale Quantity Pricing (http://zumafilters.com/index.php?


main_page=create_account)

CONFIRMATION PAGE
Payment Method:
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Cardholder First Name:


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https:llwww.houseoffilters.comlindex.php?main-.page=fec_ confirmation&fecaction=...

7/13/2016

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 13 of 24


Discount Refrigerator Water and Ice Filters - FREE SHIPPING

Page 2 of3

Shopping Cart Contents


(https://www.houseoffiLters.com/shopping_cart.htmL)
Qty.ltem Name
1 x Frigidaire WF3CB CompatibLe Refrigerator Water and Ice FiLter (4 Pack) OPFE2-RF300

Total

$74.95

Sub-Total:

$74.95

FREE USPS Priority Shipping (1-3 days Transit Time):

$0.00

TotaL:

$74.95

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711312016

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 14 of 24

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 15 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 16 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 17 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 18 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 19 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 20 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 21 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 22 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 23 of 24

Case 3:16-cv-01433-SRU Document 1-2 Filed 08/23/16 Page 24 of 24

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 1 of 25

EXHIBIT B

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 2 of 25

Corporate Registration

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 3 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 4 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 5 of 25

Cease and Desist Letter

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 6 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 7 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 8 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 9 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 10 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 11 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 12 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 13 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 14 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 15 of 25

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 16 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 17 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 18 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 19 of 25

Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 20 of 25

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Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 22 of 25

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Case 3:16-cv-01433-SRU Document 1-3 Filed 08/23/16 Page 25 of 25

Case 3:16-cv-01433-SRU Document 1-4 Filed 08/23/16 Page 1 of 3

EXHIBIT C

Case 3:16-cv-01433-SRU Document 1-4 Filed 08/23/16 Page 2 of 3

Case 3:16-cv-01433-SRU Document 1-4 Filed 08/23/16 Page 3 of 3

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 1 of 15

EXHIBIT D

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 2 of 15

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 3 of 15

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 4 of 15

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 5 of 15

Case 3:16-cv-01433-SRU Document


1-5 Filed
08/23/16 Page 6 of 15
ultrawf replacement
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7/26/2016
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ULTRAWF Kenmore 24201780146-9999


PS2364646 Compatible Filter Frigidaire
Replace

$20.86
Buy It Now
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Replacement for Frigidaire Water Filter


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1/14

7/26/2016

Case 3:16-cv-01433-SRU Document


1-5 Filed
08/23/16 Page 7 of 15
ultrawf replacement
filter I eBay
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wiltec

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5/14

7/26/2016

ultrawf replacement
filter I e8ay
Case 3:16-cv-01433-SRU Document
1-5 Filed
08/23/16 Page 8 of 15

It

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6/14

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 9 of 15

Internet Order(s) and


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Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 10 of 15


Order Details

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Helio, John

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HAMDEN, CT06518-2738
United Stales

Order Summary
lIem(s) Sublolal:
Shipping & Handling:

$181.86
$10.44

Tolal before tax:


Estimaled lax 10 be
collecled:

$192.30
$1.63

Grand Total:

$193.93

Transactions

2 SHIPMENTS

Delivered Jun 21, 2016


Your package was left In the mailbox.
Misl Frigidaire Waler Filler - UL TRAWF Compatible for Frigidaire refrigeralors
Sold by: ClearWaler Fillers
S10.99
Condition: New

BU~ it Again

CORAL FILTER ULTRAWF Frigidaire Pure source WF3CBIKENMORE 46-9999 Refrigeralor


Compatible Waler Filler
Sold by: Amazon.com LLC

Relurn or replace

il~

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Condition: New
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Frigidaire ULTRAWF compatible Premium Replacemenl Refrigerator Waler Filler By


ElemaWaler Model EWRF1022
Soid by: ProActive Producls
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$22.77

Condition: New
[ BU'y tt Again

Besl Frigidaire Waler Fiiter - ULTRAWF Compalible Cartridge For Frigidaire Refrigeralors &
Ice Makers - Compatible wtth Pure source. Gallery. Professio
Sold by: Besl Filler
510.99
Condition: New
[ BUyit'"Again

2Pack Frigidaire ULTRAWF Compalible Waler Filler - 2-Pack


Sold by: Founlain Disl
$39.99

Condition: New
[ BU; it Again

Frigidaire ULTRAWF Compalible Waler Filler - Refrigeralor

https:/Iwww.amazon.com/gp/your-account/order-detailslref=oh_ aui_01'_000_sOO?ie=UTF8 .. , 8/22/2016

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 11 of 15


Order Details

Page 2 of3

Sold by: Walerfall Filler Company


S 19.99
Condition: New

[flu;it

Again ~l

Filter Replacement Cartridge for Ultrawf,kenmore

[i

469999,242017800,2420 1780 1,ps2364646,a0094e28261


Sold by: Excellen-Shop

$17.58
Condition: New

I B~y

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Delivered Jun 23, 2016


Your package was delivered .
Replacement Cartridge for Frigidaire ULTRAINF Refrigerator Water Filter

.' .'

Relurn or replace Items

Sold by: FrsmorllGoods


$ Hj'.14

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Condition : New

Buy

~ Again

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2 Replacemenl Frig idaire

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https:/Iwww.amazon.com/gp/your-account/order-details/ref=oh_aui_01'_000_sOO?ie=UTF8... 8/2212016

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 12 of 15

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 13 of 15

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 14 of 15

Case 3:16-cv-01433-SRU Document 1-5 Filed 08/23/16 Page 15 of 15

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 1 of 26

EXHIBIT E

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 2 of 26

Corporate Registration

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 3 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 4 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 5 of 26

Trademark Registration

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 6 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 7 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 8 of 26

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 9 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 10 of 26

Case 3:16-cv-01433-SRU Document


1-6 Filed
08/23/16 Page 11 of 26
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ULTRAWF Kenmore 24201780146-9999


PS2364646 Compatible Filter Frigidaire
Replace

$20.86
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Replacement for Frigidaire Water Filter


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Replacement Water Filter Kenmore Frigidaire


Crucial Fridge Genuine Eco Aqua

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$34.99

19 sold

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$20.50

GE SmartWater MWF
MWFP 46-9991 GWF

$23.99
Buy It Now or Best oFfer
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2-Pack Frigidaire
ULTRAWFCompatible ...

$45.93
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1/14

7126/2016

ultrawf replacement
filter I eBay
Case 3:16-cv-01433-SRU Document
1-6 Filed
08/23/16 Page 12 of 26
Amana Clean N Clear
12527304 WF401 WF. ..

$19.99
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BEST FRIGIDAIRE
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Filter Replacement Cartridge for Ultrawf,kenmore

$21.90
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YOLO 2-Pack Water Filter Replacement


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Whirlpool Icemaker Fill


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Frigidaire LGUB2642LF2 single pack

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GE SmartWater GSWF
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$8.50
Refrigerator Water Filter Replace Fridigaire
ULTRAWF Kenmore Healthy Drinking

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$27.51
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Samsung Da29-00020b
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$46.74
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Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter 2 Pack

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EAF1 CB Genuine
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Frigidaire PureSource Ultra Refrigerator Fridge Water Ice Filter


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7/26/2016

Case 3:16-cv-01433-SRU Document


1-6 Filed
08/23/16 Page 13 of 26
ultrawf replacement
filter I eBay
ecoFresca wat. ..

--

By: deals-ouUets

l~~" \

Replacement Water Filter Kenmore Frigidaire Crucial Fridge Genuine


Eco Aqua

$34.99

-;.

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12 items

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter new

$23.90

Refrigerator W ...
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2 watching

Frigidaire ULTRAWF Compatible Water Filter


Replacement for Refrigerator .

$25.08
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15 items

wiltec

By: 2014dkille

Frigidaire ULTRAWF Compatible Water Filter


Replacement for Refrigerator NEW

$25.80
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/
Replacement Water Filter for Kenmore
Frigidaire 46-9999, 46-9916, ULTRAWF, 2 ...

$46.65

2Ommloz(200g)

75 items

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2013 jeep

Only 1 left!

By: forcerecon1 0

19 sold

90 DAV WARRANTY
..,....

Frigidaire ULTRAWF Compatible Water Filter Replacement for


Refrigerator NEW

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7/26/2016

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filter I e8ay
Case 3:16-cv-01433-SRU Document
1-6 Filed
08/23/16 Page 14 of 26

$42.99
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ULTRAWF Kenmore 24201780146-9999


PS2364646 Replace Compatible Filter
Frigidaire

$27.99
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Filter Replacement Cartridge for


Ultrawf,kenmore 469999,2420178
00,242017801,ps23

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16 sold

Replacement Water Fi lter Cartridge For


Frigidaire FGHS2655KE1 2 pack

$91.99
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Replacement Water Filter Cartridge For


Frigidaire DGHS2634KP1 single pack

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Replacement Water Filter Cartridge For


Frigidaire FGHS2665KF2 2 pack

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Replacement Water Fi lter Cartridge For Frigidaire FPHB2899LF single


pack

http://www.ebay.com/sch/i .html?_from=R40&_sacat=0&ykw=ultrawf+replacement+filter&jpg=100&rt=nc

10/14

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 15 of 26

Website Listings WF2CB Cassette Replacement


Cartridge

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 16 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 17 of 26

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 18 of 26


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Ordered on June 17, 2016

Order# 115-2467364-4001806

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5836

Order Summary
Item(s) Subtotal:

$161 .86

Shipping & Handling:


HAMDEN, CT06518-2738

Total before tax:

United States

$10.44
5192 _30
$1 _63

Eslimaled tax to be
collected:

$193.93

Grand Total:

Trensactions

2 SHIPMENTS

Delivered Jun 21, 2016


Your package was len In the mailbox.

Sotd by: ClearWaler Fillers

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Mist Frigidaire Water Filler - ULTRAWF Compatible for Frig idaire refrigerators

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il~

r-----------

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[ Buylt Again 1
CORAL FILTER ULTRA1M' Frigidaire Puresource WF3CB/KENMORE 46-9999 Refrigerator
Compatible Water Filler

C __

-_. .l.

A_rch
_ lv_e_o_r_de_r_ _ _

Sold by: Amazon.com LLC


S24.43
Condition : New

I BUy it Aga~ I
Frigidaire ULTRAWF compatible Premium Repl acement Refrigerator Water Filter By
EtemaWater Model EWRF1022
Sold by: ProActive Products

Product question? Ask Seller

522.77
Condition: New
[

BU'~ tt Again

Best Frigidaire Water Filler - ULTRAWF Compatible Cartridg e For Frigidaire Refrigerators &
Ice Makers - Compatible with Puresouree. Gallery, Professio
Sold by: Best Filler

$10.99
Condition: New

Buy -tt- Again

2-Pack Frigidaire ULTRAWF Compatibte Water Filter - 2-Pack


Sold by: f ountain Dist
$39.99
Condition: NeVI
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Frigidaire ULTRAWF Compa tible Water Filler - Refrigerator

https:llwww.amazon.comlgp/your-account/orde1.-detailslref=oh_ aui_ 01'_000_sOO?ie=UTF8... 8122/2016

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 19 of 26


Order Details

Page 2 of3
Sold by: Walerfall Filler Company
$ 19.99
Condition: New

Filter Replacement Cartridge for Ullrawf,kenmore


469999,242017800,242017801,ps2364646,ao094e28261
Sold by: E>ccellanShop
$ 17.56
Condttlon: New

I B~Y n

Again

Delivered Jun 23, 2016


Your package Vias delivered.
Replacement Cartridge for Frigidaire ULTRA1M' Refrtgeralor Water Filler
Sold by: FremontGoods
$19.14
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~ I.

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2 Replacement Frigidaire
Pure Air Ullra Refrigerator

2 Pack - Frigidaire
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Electrotux,...

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207

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Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 20 of 26

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 21 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 22 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 23 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 24 of 26

Photos WF2CB Cassette Replacement


Cartridge

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 25 of 26

Case 3:16-cv-01433-SRU Document 1-6 Filed 08/23/16 Page 26 of 26

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 1 of 32

EXHIBIT F

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 2 of 32

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 3 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 4 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 5 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 6 of 32

Case 3:16-cv-01433-SRU Document


1-7 Filed
08/23/16 Page 7 of 32
ultrawf replacement
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. 1.

ULTRAWF Kenmore 24201780146-9999


PS2364646 Compatible Filter Frigidaire
Replace

$20.86
Buy It Now
Free shipping

Price
$

c:=J $ =:=J
to

Only 1 left!
Format

see all

7 sold

see all

Replacement for Frigidaire Water Filter


ULTRAWF SND

@ All Listings (71 )

Auction (0)
Buy It Now

(71)

Item Location
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$24.99

Within

Trending at
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Buy it Now
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1100 miles" 1 of 106511

o
o
o

US Only
North America
Worldwide

Delivery Options

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o

Free shipping
Free In-store pickup

Show only

o
o
o

see all

Frigidaire ULTRAWF compatible Premium


Replacement Refrigerator Water Filter B ...

$26.46
see all

Buy it Now
Free shipping

Popular on eBay

Returns accepted
Completed listings
Sold listings

More refinements ...

Replacement Water Filter Kenmore Frigidaire


Crucial Fridge Genuine Eco Aqua

Recently viewed items

Buy It Now
Free shipping

$34.99

19 sold

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$20.50

GE SmartWater MWF
MWFP 46-9991 GWF

$23.99
Buy It Now or Best oFfer
Free shipping

Buy It Now
Only 1 left!
2-Pack Frigidaire
ULTRAWFCompatible ...

$45.93
Buy It Now
Free shi ppi ng

http://www.ebay.com/schli.htrnl?_from=R40&_sacat=0&_nkw=ultrawf+replacement+filter&jpg=100&rt=nc

1/14

7/26/2016

Case 3:16-cv-01433-SRU Document


1-7 Filed
08/23/16 Page 8 of 32
ultrawf replacement
filter I eBay
ecoFresca wat. ..

--

By: deals-ouUets

l~~" \

Replacement Water Filter Kenmore Frigidaire Crucial Fridge Genuine


Eco Aqua

$34.99

-;.

k'

,4 '

;;:.,

.~

:~'--"':"""---

Buy It Now
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19 sold
12 items

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter new

$23.90

Refrigerator W ...
By: parts-bay

Buy It Now
Free shipping
Only 1 leftl
2 watching

Frigidaire ULTRAWF Compatible Water Filter


Replacement for Refrigerator .

$25.08
Buy It Now
Free shipping
15 items

wiltec

By: 2014dkille

Frigidaire ULTRAWF Compatible Water Filter


Replacement for Refrigerator NEW

$25.80
Buy It Now
Free shipping

/
Replacement Water Filter for Kenmore
Frigidaire 46-9999, 46-9916, ULTRAWF, 2 ...

$46.65

2Ommloz(200g)

75 items

Buy It Now
Free shipping

2013 jeep

Only 1 left!

By: forcerecon1 0

19 sold

90 DAV WARRANTY
..,....

Frigidaire ULTRAWF Compatible Water Filter Replacement for


Refrigerator NEW

,~ ,,~ ~ .
J

. - ,-

See more collections

http://www.ebay.com/schli.html?_from=R40&_sacat=0&_nkw=ultrawf+replacement+filter&_ipg=100&rt=nc

5/14

7/26/2016

ultrawf replacement
filter I e8ay
Case 3:16-cv-01433-SRU Document
1-7 Filed
08/23/16 Page 9 of 32

It

$20.88
Was: $24
Buy It Now
Free shipping
Only 1 left!

15% off

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$23.72
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NEW REPLACEMENT CARTRIDGE


FRIGIDAIRE ULTRAWF REFRIGERATOR
WATER FILTER ICEPURE

$41.50
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9 sold

ULTRAWF Kenmore 242017801 46-9999


Replace Compatible Filter Frigidaire 2 Pack

$45.99
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2 watching

Replacement Water Fi lter for Kenmore


Frigidaire 46-9999, 46-9916, ULTRAWF, 2420

$94.05
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ULTRAWF Kenmore 242017801 46-9999


PS2364646 Compatible Filter Frigidaire
Replace

$23.99
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Frigidaire ULTRAWF Refrigerator Water Filter VOC Reduction


Replacement Part New

http://www.ebay.com/schli .html?_from=R40&_sacat=0&_nkw=ultrawf+replacement+filter&_ipg=100&rt=nc

6/14

7/26/2016

ultrawf replacement
filter I eBay
Case 3:16-cv-01433-SRU Document
1-7 Filed
08/23/16 Page 10 of 32

YOLO 2-Pack Water Filter Replacement Cartridge for


ULTRAWF,WF3CB,kENMORE

$46.46
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37 sold

ULTRAWF Kenmore Replace 242017801 469999 Compatible Filter Frigidaire NSF OEM

$48.99

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?I1
-- --

Replacement Water Filter Cartridge For


Frigidaire BGHS2634KE1 single pack

$42.99
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Replacement Water Filter Cartridge For


Frigidaire FGHS2667KPO single pack

$42.99
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;r~

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-- --

Replace 2-Pack Water Filter Replacement


Cartridge for ULTRAWF,KENMORE

$46.71
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Replacement Water Filter Cartridge For


Frigidaire FGHF2366PF 2 pack

$91.99
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Filter Replacement Cartridge for Ultrawf,kenmore 469999,2420178


00,242017801,ps23

http://www.ebay.com/schli.html?_from = R40&_sacat=0&_nkw=ultrawf+repl acement+filter&jpg=100&rt=nc

8/14

7/26/2016

ultrawf replacement
filter I eBay
Case 3:16-cv-01433-SRU Document
1-7 Filed
08/23/16 Page 11 of 32

$100.44
Buy It Now
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Only 1 left!

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$26.35
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Replacement Water Filter Cartridge For


Frigidaire FGHS2644KF1 2 pack

$91.99
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Replacement Water Filter Cartridge For


Frigidaire DGHS2634KB2 2 pack

$91.99
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-- -.

Replacement Water Filter Cartridge For


Frigidaire BGHS2634KE2 2 pack

$91.99
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Replacement Water Filter Cartridge For


Frigidaire FGHS2365KF2 3 pack

$130.99
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Replacement Water Filter Cartridge For Frigidaire LGUB2642LF1 single


pack

http://www.ebay.com/schli .html?_from=R40&_sacat=0&_nkw=ultrawf+replacement+filter&jpg=100&rt=nc

9/14

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 12 of 32

Website Listings WF2CB Cassette Replacement


Cartridge

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 13 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 14 of 32

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 15 of 32


Order Details

Page 1 of3

Browsing Hislory

Departme nts

John's Ama zon.com

Today's Deals

Hello, John
Your Account '

Try Prime

Lists ,

Cart

Your Account) Your Orders) Order Delails

Order Details
Ordered on June 17, 2016

Order# 115-2467364-4001806

ShIppIng Address

View or Print Invoice I

Payment Method
VISA ..

5836

HAMDEN, CT06518-2738
United Slates

Order Summary
Item(s) Subtotal:
Shipping & Handling:

S181.86

Tolat before lax:


Eslimated lax 10 be

$192.30

$10.44

$1.63

collected:
Grand Tolal:

$193.93

Transaclions

2 SHIPMENTS

Delivered Jun 21,2016


Your package was left In Ihe mailbox.

I"

Mist Frigidaire Water Filter - ULTRAWF Compatible for Frigidaire refrigerators


Sold by: ClearWaler Fillers
S10.99
Condition: New
[ Buy it

Agal~

I
[

Return or replace

it~

Leave seller feedback

I -~odu~e-w---I

CORAL FILTER ULTRAWF Frigidaire Puresource WF3CB/KENMORE 46-9999 Refrigeralor


Compalible Water Filler

Archtve order

Sold by: Amazon.com LLC

<'24.43
Condition : New

Buy

it A~,;j~ I

Frigidaire ULTRAWF compallble Premium Replacement Refrigerator Waler Filler By


ElemaWaler Model EWRF1022
Sold by: ProActive Producls
Product queslion? Ask Seller
S22.77
Condition: New
[ B'uy ~ Again I
Best Frigidaire Water Filler - ULTRAWF Compalible Cartridge For Frigidaire Refrige ralors &
Ice Makers - Compatible w~ Puresource , Gallery, Professio
Sold by: Best f iller
$ 18.99
ConditIon: New

[ - Buy ~ Again

2-Pack Frigidaire ULTRAWF Compalible Water Filler - 2-Pack


Sold by: Foontain Disl

0.39.99
Condition: New
[ BU; it Again

Frigidaire UL TRAWF Compatible Water Filter - Refrigerator

htlps:llwww.amazon.com/gp/your-account/order-details/ref=oh_ aui_01-_000_sOO?ie=UTF8 ,. , 8/22/2016

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 16 of 32


Order Details

Page 2 of3

Sold by: Walerfall Filler Company

$ 19.99
Condition : New

[~gainJ
Filter Replacemenl Cartridge for Ullrawl,kenmore

469999,2420 178oo,2420 1780I ,ps2364646,aoo94e28261

fi

Sold by: ExcellenShop

$ 17.56
Condttlon: New

I B~YHAgaln
Delivered Jun 23, 2016
Your package Vias delivered.
Replacemen t Cartridge for Frigidaire UlTRA'M' Refrlgeralor Waler Filler
Sold by: FremonlGoods

Return or replace lIems

$19.14

Leave seller feedback

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Buy

~Again

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Archive order

Customers Who Bought Items in Your Order Also Bought

Page 1 of 13

'I

LJ

2 Replacemenl Frigidaire

2 Pack - Frig idaire

Frigidaire PAUlTRA,

Frigidaire SCPUREAIR2PK

Pure Air Ullra Refrig eralor

PAULTRA Relrlgerator

Electro lux EAFCBF

Air Filler, 2-Pack

Atr Filers, Also F~s

Compatible Air Filter -

compatible air filte r -

EleCiroluK" ..

PureAir Universal Air.. .

VNF02

105
$1 0.93

161
5 14.99

207

$ 13.H)
45

$6.39

Your Recently Viewed Items and Featured Recommendations


Inspired by your purchases

Page 1 of6

II

u
Frigidaire PAULTRA

Frigidaire SCPUREAIRU

Coral Filter CPAUL TRA

Frigidaire SCPUREAI R2PK

Eleclrolux

Refrigerator Ai r Filler

PureAir Universal

Frigidaire PaullJ'a I

Air Filter, 2,Pack

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Eleclrolux EAFCBF

366

64

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Refrigerator Air Filter

207
513.68

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https ://www.amazon.com/gp/your-account/order-details/ref=oh_aui_01'_000_sOO?ie=UTF8... 8/2212016

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 17 of 32

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 18 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 19 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 20 of 32

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Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 25 of 32

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Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 29 of 32

Case 3:16-cv-01433-SRU Document 1-7 Filed 08/23/16 Page 30 of 32

Photos WF2CB Cassette Replacement


Cartridge

01433-SRU Document 1-7 Filed 08/23/16

01433-SRU Document 1-7 Filed 08/23/16

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 1 of 15

EXHIBIT G

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 2 of 15

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 3 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 4 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 5 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 6 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 7 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 8 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 9 of 15

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 10 of 15


Order Details

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Browsing History ,

Departments -

John's Amazon.com

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Hello, John
Your Account '.

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Cart

Lists

Your Account' Your Orders} Order Detail;

Order Details
Ordered on June 17, 2016

Order# 115-2467364-4001806

Shipping Address

Payment Method
VISA .. 5836

HAMDEN, CT06518-2738
United States

View or Print Invoice

Order Summary
flem(s) Subtotal:
Shipping & Handling:

$181.86
$10.44

Total before tax:


Estimated tax to be

$192.30
$1 .63

collected:
Grand Total:

$193.93

Transactions

2 SHIPMENTS

Delivered Jun 21, 2016


Your package was left in Ihe mailbox.

lot

Mist Frigidaire Water Filter - ULTRA~ Compatible for Frigidaire refrigerators


Sold by: ClearWater Filters
S18 .99
Condition: New

B~y it Again

I
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CORAL FILTER ULTRA~ Frigidaire Pure source WF3CB/KENMORE 46-9999 Refrigerator


Compatible Water Filter

Return or replace

it~

Leave seller feedback

._------'iVrite a product review

Archive order

Sold by: Amazon.com LLC


~24 .43

Condition: Nel'l
[ Buy \tAga!.; \
Frigidaire ULTRAWF compatible Pre mium Replacement Refrtgerator Water Filter By
EtemaWater Model EWRF1022
Sold by: ProActive Products

Product question? Ask Seller

$22.77
Condition: Nel'l

[ BU'y it Again

Best Frigidaire Water Filter - ULTRAWF Compatible Cartridge For Frlgldaire Refrigerators &
Ice Makers - Compatible with Puresouree, Gallery. Professio
Sold by: Best Filler
$ 18.99

Condition: New
[ Buy -;;-Again

2Pack Frigidaire ULTRA~ Compatible Water FlIter - 2-Pack


Sold by: Fountain Dist
S39.99
Condillon : New
[ -BUY it Again

Frigida ire ULTRAWF Compatible Water Filler - Refrigerator

htlps:llwww.amazon.com/gp/your-account/o1.de1.-detailslref=oh_ aui_01'_000_sOO?ie=UTF8... 8/22/2016

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 11 of 15


Order Details

Page 2 of3

Sold by: Walerfall Filler Company


S19.99
Condition: New

[Bu;iIAgain]
Filter Replacement Cartridge for Ultrawf,kenmore

If

469999,242017600,2420 1760 l ,ps2364646,ao094e28261


Sold by: Excellen-Shop
$ 17.56
Condition: New

I B~Y

UAgaln

Delivered Jun 23, 2016


Your package was delivered.
Replacement Carl ridg e for Frigidaire ULTRAWF Refrtgerator Waler Filler
Sold by: FremorilGoods

Return or replace items

S19,14

r-

Condition: New

BU~ RAgain

Leave sellerfeedback

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Customers Who Bought Items in Your Order Also Bought

Page 10[,13

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2 Replacement Frigidaire

2 Pack - Frigidaire

Frigidaire PAULTRA,

Frigidaire SCPUREAIR2PK

Pure Air Ultra Refrigerator

PAULTRA Refrigerator

Eleclrolux EAFCBF

Air Filler, 2-Pack

Air Filers , Al so Ftts

Compatible Air Filter -

compatible air filter -

Electrolux,,, ,

PureAir Universal Air

VNF02

105
$10.93

161
$14,99

207
$13,19

45
$6,39

Your Recently Viewed Items and Featured Recommendations


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Page 1 or6

II

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Frigidaire PAUlTRA

F rigidaire SCPUREAIRU

Coral Filler CPAULTRA

Frigidaire SCPUREAIR2PK

Eleclrolux

Refrigerator Air Filler

PureAir Universa l

Frigidaire Paullra I
Eleclrolux EAFCBF

Air Filter, 2,Pack

Replacem

Refrigeralor Air Filter

$ 13,19

366

Refrigerator Air Filler Kit


64

SI 1.52
$7,65

207

S13,68

Compatible Coral",
29

You
viewed

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View or edit
your brow5ing
history

https:llwww.amazon.com/gp/your-account/order-detailslref=oh_aui_01'_000_sOO?ie=UTF8... 8/2212016

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 12 of 15

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 13 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 14 of 15

Case 3:16-cv-01433-SRU Document 1-8 Filed 08/23/16 Page 15 of 15

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 1 of 18

EXHIBIT H

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 2 of 18

Corporate Registration

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 3 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 4 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 5 of 18

Trademark Application

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 6 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 7 of 18

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 8 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 9 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 10 of 18

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 11 of 18


Order Details

Page 1 of3

Browsing History .

Departments .

John's AmalOn.cam

Today's Deals

Hello, John
YOllr Account

Try Prime

Cart

Lists '

Your Account ) Your Orders) Order Details

Order Details
Ordered on June 17, 2016

View or Print Invoice

Ordertlll5-24673644001806

Shipping Address

Payment Method

~ISA

....

5836

HAMDEN, CT065182738
United States

Order Summary
Item(s) Sublolal:
Shipping & Handling:

$181.86

Tolal before tax:


Estimated tax to be

$192.30

$10.44

$1.63

collecled:
Grand Total:

$193.93

Transaction s

2 SHIPMENTS

Delivered Jun 21, 2016


Your package was left in the mailbox.
Mist Frigidaire Water Filler ULTRAWF Compatible lor Frigidaire refrigerators

Return or replace

Sotd by: ClearWater Fillers

S1 0.99
Condition: New
[ Buy il Again

il~

Leave seller feedback

CORAL FI LTER ULTRAWF Frigidaire Puresource WF3CB/KENMORE 469999 Refrigerator


Compatible Waler Filler
Sold by: Amazon.com LLC
$24.43
Condlllon : New

Buy

it Agal;;' I

Frigidaire ULTRAWF compatible Premium Replacement Refrigeralor Water Filter By


EtemaWater Model EWRF1022
Sold by: ProActive Products

Product question? ASK Seller

S22.77
Condition: New
[.

Buy~Agaln

Best Frigidaire Water Filter - ULTRAWF Compatible Cartridge For Frigidaire Refrigerators &
Ice Makers - Compatible with Puresource, Gallery. Professio
Sold by: Best Filter
$t8.99
Condition: New
[- Buy -;;-Again

2Pack Frigidaire ULTRAWF Compatible Water Filter - 2Pack


Sold by: Fountain Dist
$39.99
Condition: New

raUY II Again I
Frigidaire ULTRAWF Compatible Water Filler - Refrigerator

https:llwww.amazon.comlgp/your-account/order-detailslref=oh_ aui_01'_000 _sOO?ie=UTF8 .. , 8/22/2016

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 12 of 18


Order Details

Page 2 of3

Sold by: Watertall Filter Company


S l999
Condition: New
E

gain]

Filter Reptacement Cart ridge for Ullrawf,kenmore


469999,24 2017800.2420 1780 t ,ps 2364646 ,a0094e28261
Sold by: Excelle n-Shop
$ 17.56
Condition: New

I B~y ~ Agaln
Delivered Jun 23, 2016
Your package was delivered.
Replacement Cartridge for Frigidaire ULTRAI,M= Refrlgeralor Water Filler

Return or replace items

Sold by: FremonlGoods

$19.14

Leave seller feedback

Condition: New
Buy

~Again

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Archive order

Customers Who Bought Items in Your Order Also Bought

Page 1 of 13

.;:.11

LJ

2 Replacement Frigidaire

2 Pack - Frigidaire

Frigidaire PAUL TRA,

Frigidaire SCPUREAIR2PK

Pure Air Ultra Refngerator

PAULTRA Refrigerator

Electrolux EAFCBF

Air Filter, 2-Pack

Air FIRers , Also FHs

Compatible Air Filler -

compatible air filter -

Electrolux,.. .

PureAir Universal Air .. .

VNF02

105

161

S10.93

207

S13.19
45

$6.39

S14.99

Your Recently Viewed Items and Featured Recommendations


Inspired by your purchases

Page 1 of6

-.
_.II

u
Frigidaire PAULTRA

Frigidaire SCPUREAIRU

Coral Filler CPAULTRA

Frigidaire SCPUREAIR2PK

Refrigerator Air Filter

PureAir Universal

Frigidaire Paullra I

Air Filter, 2,Pack

Refrigerator Air Filler

366

64

SI I .52
$7.G5

K~

Electrolux EAFCBF
Refrigerator Air Filter

Electrolux
Replacem

207

$ 13.19

S13.68

Compatible Coral .. .

29

You
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. ,

) View o r e dit
your brow sing

history

https:llwww.amazon.com/gp/your-accountlorder-details/ref=oh_aui_01'_000_sOO?ie=UTF8... 8/22/2016

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 13 of 18

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 14 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 15 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 16 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 17 of 18

Case 3:16-cv-01433-SRU Document 1-9 Filed 08/23/16 Page 18 of 18

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 1 of 19

EXHIBIT I

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 2 of 19

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 3 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 4 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 5 of 19

Case 3:16-cv-01433-SRU Document


1-10 filter
Filed
08/23/16 Page 6 of 19
I e8ay
ultrawf replacement

7/26/2016
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ultrawf replacement filter

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. 1.

ULTRAWF Kenmore 24201780146-9999


PS2364646 Compatible Filter Frigidaire
Replace

$20.86
Buy It Now
Free shipping

Price
$

c:=J $ =:=J
to

Only 1 left!
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7 sold

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Replacement for Frigidaire Water Filter


ULTRAWF SND

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Crucial Fridge Genuine Eco Aqua

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$34.99

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Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$20.50

GE SmartWater MWF
MWFP 46-9991 GWF

$23.99
Buy It Now or Best oFfer
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2-Pack Frigidaire
ULTRAWFCompatible ...

$45.93
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1/14

7/26/2016

ultrawf replacement
I e8ay
Case 3:16-cv-01433-SRU Document
1-10 filter
Filed
08/23/16 Page 7 of 19

It

$20.88
Was: $24
Buy It Now
Free shipping
Only 1 left!

15% off

Replacement Cartridge for Frigidaire


ULTRAWF Refrigerator Water Filter

$23.72
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NEW REPLACEMENT CARTRIDGE


FRIGIDAIRE ULTRAWF REFRIGERATOR
WATER FILTER ICEPURE

$41.50
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9 sold

ULTRAWF Kenmore 242017801 46-9999


Replace Compatible Filter Frigidaire 2 Pack

$45.99
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2 watching

Replacement Water Fi lter for Kenmore


Frigidaire 46-9999, 46-9916, ULTRAWF, 2420

$94.05
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Only 1 left!

ULTRAWF Kenmore 242017801 46-9999


PS2364646 Compatible Filter Frigidaire
Replace

$23.99
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Frigidaire ULTRAWF Refrigerator Water Filter VOC Reduction


Replacement Part New

http://www.ebay.com/schli .html?_from=R40&_sacat=0&_nkw=ultrawf+replacement+filter&_ipg=100&rt=nc

6/14

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 8 of 19

Website Listings WF2CB Cassette Replacement


Cartridge

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 9 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 10 of 19

Internet Order(s) and


Receipt(s)

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 11 of 19


Order Details

Page 1 of3

All

II

Browsing History .,

Departments .

John's Amazon.com

Today' s Deals

Hello, John
Your Account '.

Try Prime

Lists

Cart

Your Account) Your Orders l arder Details

Order Details
Ordered on June 17, 2016

OrderIl115-24673644001806

Shipping Address

Payment Method
WSII .. 5836

View or Print Invoice

Order Summary
Item(s) Subtotal:

5181.86

Shipping & Handling:


HAMDEN, CT06518-2738

Total before tax:

United States

$10.44
5192.30

Eslimaled tax to be

$1.63

collected:
$193.93

Grand Total :

Transactions

2 SHIPMENTS

Delivered Jun 21, 2016


Your package was left In Ihe mailbox.

1,1

Mist Frigidaire Water Filter - ULTRAVVF Compatible for Frigidaire refrigerators


Sold by: CtearWa ter Fillers

510.99
Condition: New
[

B~y i t Again

CORAL FILTER ULTRAVVF Frigidaire Puresource VVF3CB/KENMORE 469999 Refrigerator

I
I

[[

Return or replace Items

Leave seller feedback


Write

a product review

Archive order

Compatible Water Filter


Sold by: Amazon.com LLC
<>24.43
Condition: New

I Buy it Aga~~ 1
Frigidaire UL TRAVVF compatible Premium Replacement Refrigerator Water Filter By
EtemaWater Model EWRF1022
Sold by: ProActive Products

Product question? Ask Seller

$22.77
Condition: New
[ - Buy nAgain

Best Frigidaire Water Filter - ULTRAVVF Compatible Cartridge For Frigidaire Refrigerators &
Ice Makers - Compatible with Puresouree , Gallery, Prolessio
Sold by: Best Filter
$'18.99

Condttlon : New
[ Buy- n- Again

2-Pack Frigidaire ULTRAVVF Compatible Water Filter - 2-Pack


Sold by: Fountain D15t
S39.99
Condition: New
[ Bu;it Again

Frigidaire ULTRAVVF Compatible Water Filter - Refrigerator

https:1Iwww.amazon.com/gp/your-account/order-detailslref=oh_aui_or_000_sOO?ie=UTF8... 8/22/2016

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 12 of 19


Order Details

Page 2 of3

Sold by: WalBrfall FillBr Company

S19.99
Condition: New

[8UYY

Again

"

Filter Replacement Cartridge for Ullrawf,kenmore


469999,242017800,242017801 ,ps2364646,aOO94e28261
Sold by: EKcelien-Shop
S I7.56
Condition: New

I B~y ~Agaln
Delivered Jun 23, 2016
Your package was delivered.
Replacement Cartridge for Frigidaire UlTRAINF Refrigerator Water Filter
Sold by: FremoritGoods

$ 19.14

Cqnditlon: New
Buy

~Again

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leave seller feedback

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pr';;;ct~

Page 1 of 13

Fir.

Archive order

Customers Who Bought Items in YOUI' Order Also Bought

.. ..
~

';'11

~~.;: 1

LJ

2 Replacement Frigidaire

2 Pack - Frigidaire

Frigidaire PAUL TRA,

Frigidaire SCPUREAIR2PK .

Pure Air Ultra Refrigerator

PAULTRA Refrigerator

Electrolux EAFCBF

Air Filler, 2-Pack

Air Fil ers, Also F~s

Compatible Air Filler -

compatible air filter -

Electrolu x,...

PureAir Universal Air .. .

VNF02

207

S 13.19

161

105
!)1 0 .93

I
I
--I

45
$6.39

514.99

Your Recently Viewed Items and Featured Recommendations


Inspired by your purchases

Page 1 of6

.:.11

u
Frigidaire PAUlTRA

Frigidaire SCPUREAIRU

Coral Filter CPAUl TRA

Frigidaire SCPUREAIR2PK

Electrolux

Refrigerator Ai r Filter

PureAir Universal

Frigidaire Paultra I

Air Filler, 2,Pack

Replacem

Refrigerator Air Filler Kit

Eleclrolux EAFCBF

366

64

51 1.52
$7.65

Re frigeralor Air Filler

207

513.6B

S 13.19

Compalible COfal...

29

You
viewed

.t!l'1'

Viewo r edit
your broVising
history

https:/Iwww.amazon.com/gp/your-account/order-details/ref=oh_aui_01'_000_sOO?ie=UTF8... 8/2212016

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 13 of 19

Photos ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 14 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 15 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 16 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 17 of 19

Photos WF2CB Cassette Replacement


Cartridge

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 18 of 19

Case 3:16-cv-01433-SRU Document 1-10 Filed 08/23/16 Page 19 of 19

Case 3:16-cv-01433-SRU Document 1-11 Filed 08/23/16 Page 1 of 18

EXHIBIT J

Case 3:16-cv-01433-SRU Document 1-11 Filed 08/23/16 Page 2 of 18

Website Listings ULTRAWF Replacement Cartridge

Case 3:16-cv-01433-SRU Document 1-11 Filed 08/23/16 Page 3 of 18

Case 3:16-cv-01433-SRU Document 1-11 Filed 08/23/16 Page 4 of 18

Case 3:16-cv-01433-SRU Document


1-11 filter
Filed
08/23/16 Page 5 of 18
I e8ay
ultrawf replacement

7/26/2016
Hi! Sign in

Sell

eb

~I
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ultrawf replacement filter

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II

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It Now

ultrawf replacement filter 71 listings

Water Filters

..

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<D

I .. I

Follow this search

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See all categories

Condition

New

see all

(71)

~.

. 1.

ULTRAWF Kenmore 24201780146-9999


PS2364646 Compatible Filter Frigidaire
Replace

$20.86
Buy It Now
Free shipping

Price
$

c:=J $ =:=J
to

Only 1 left!
Format

see all

7 sold

see all

Replacement for Frigidaire Water Filter


ULTRAWF SND

@ All Listings (71 )

Auction (0)
Buy It Now

(71)

Item Location
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$24.99

Within

Trending at
$29.99
Buy it Now
Free shipping

1100 miles" 1 of 106511

o
o
o

US Only
North America
Worldwide

Delivery Options

o
o

Free shipping
Free In-store pickup

Show only

o
o
o

see all

Frigidaire ULTRAWF compatible Premium


Replacement Refrigerator Water Filter B ...

$26.46
see all

Buy it Now
Free shipping

Popular on eBay

Returns accepted
Completed listings
Sold listings

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 1 of 23

EXHIBIT K

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 2 of 23

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 4 of 23

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 7 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 8 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 9 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 10 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 11 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 12 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 13 of 23

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 14 of 23


US 8,673,146 B2
1

PUSH FILTER WITH FLOATING KEY LOCK

5,147,722, and are incorporated herein by reference thereto.


One of the uses of the instant filter apparatus is as a water
filtration apparatus for a refrigerator. Refrigerators are appliances with an outer cabinet, a refrigeration compartment disposed within the outer cabinet and having a rear wall, a pair of
opposing side walls, at least one door disposed opposite the
rear wall, a top and a bottom and a freezer compartment
disposed in the outer cabinet and adjacent to the refrigeration
compartment. It is common for refrigerators to have a water
dispenser disposed in the door and in fluid communication
with a source of water and a filter for filtering the water.
Further, it is common for refrigerators to have an ice dispenser
in the door and be in fluid communication with a source of
water and a filter for filtering the water. It has been found that
the filter assembly of the instant invention is useful as a filter
for a refrigerator having a water dispenser and/or an ice
dispenser.

This invention relates to a filtering apparatus, specifically a


filter housing apparatus to facilitate easy removal and
replacement of a filter housing from a mechanical support,
and more specifically, to a push filter design that activates a
floating key lock, where the key may be used simultaneously
as a lock and as an identifier for particular filter attributes. The
mechanical support may be situated inline, and in fluid communication, with influent and effluent piping, such as within
a refrigerator. More specifically, the invention relates to a
filter housing and mount, whereby the filter housing may be
attached to, and removed from, the mount by a push-actuated
release. A controlled attachment or detachment of the filter
sump, containing the filter media, is activated by the axial
push of the sump towards the mechanical support. The specific key lock design allows a user to identify and match
certain filter configurations received by the mechanical support, and reject other filter configurations. An internal shutoff,
activated by the push-actuated release, blocks spillage during
filter housing removal and replacement.

10

15

SUMMARY OF THE INVENTION


20

BACKGROUND OF THE INVENTION


The invention relates to a water filtration system having a
locking and unlocking mechanism for changing the filter
when the filter media has served its useful life. The use of
liquid filtration devices is well known in the art as shown in
U.S. Pat. Nos. 5,135,645, 5,914,037 and 6,632,355.Although
these patents show filters for water filtration, the filters are
difficult to replace owing to their design and placement. For
example, U.S. Pat. No. 5,135,645 discloses a filter cartridge
as a plug-in cartridge with a series of switches to prevent the
flow of water when the filter cartridge is removed for replacement. The filter must be manually inserted and removed and
have a switch activated to activate valve mechanisms so as to
prevent the flow of water when the filter is removed. The
coverofthe filter is placed in the sidewall ofa refrigerator and
is employed to activate the switches that activate the valves.
The filter access is coplanar with the refrigerator wall and
forces an awkward access to the filter cartridge.
In U.S. patent application Ser. No. 11/511,599 filed on
Aug. 28, 2006, for Huda, entitled "FILTER HOUSING
APPARATUS WITH ROTATING FILTER REPLACEMENT MECHANISM," a filter assembly having a rotator
actuating mechanism including a first internal rotator and a
second internal rotator is taught as an efficient way to insert,
lock, and remove the filter housing from its base. A simple
push mechanism actuates the self-driving release and change
over means that hold and release the filter housing sump, and
provide influent shutoff to prevent leaking and spillage. Rotational shutoff and locking mechanisms are activated and
released by axial force on the filter housing at the commencement of the filter changing procedure.
The instant invention is particularly useful as the water
filtering system for a refrigerator having water dispensing
means and, optionally, an ice dispensing means. The water
used in the refrigerator or water and ice may contain contaminants from municipal water sources or from underground
well or aquifers. Accordingly, it is advantageous to provide a
water filtration system to remove rust, sand, silt, dirt, sediment, heavy metals, microbiological contaminants, such as
Giardia cysts, chlorine, pesticides, mercury, benzene, toluene, MTBE, Cadmium bacteria, viruses, and other know contaminants. Particularly useful water filter media for microbiological contaminants include those found in U.S. Pat. Nos.
6,872,311, 6,835,311, 6,797,167, 6,630,016, 6,331,037, and

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65

The present invention is directed to, in a first aspect, a filter


housing assembly comprising: a filter housing for enclosing a
filter media, the filter housing having a body and a top portion
for forming a fluid-tight seal with the body, the filter housing
top portion including: an ingress port; an egress port; and a
filter key located on the top portion and having a top surface,
longitudinal sides, and lateral sides, the filter key including
spaced protrusions or fingers on the longitudinal sides of the
filter key extending laterally from the top surface. The fingers
include winged extensions having slanted or angled faces,
and may include a diamond shaped cross-section.
The filter key may include a boss extending in an axial
direction above the top surface of the filter key, the boss
having an angled face of predetermined width ramping
upwards from the filter key top surface and lateral segments or
wings extending beyond the boss width. The filter housing
assembly may include a filter manifold attached to the filter
housing top portion, the filter manifold comprising an attachment structure for fixably receiving the filter key. One of the
ingress or egress ports may be located on the filter manifold.
The spaced protrusions or fingers on the filter key may form
a predetermined pattern for identifying different filter
attributes unique to a filter encased within the filter housing.
The filter key may also be color-coded, transparent, translucent, mirrored, textured, materially modified, or having a
conductive signature for identifying different filter attributes
specific to a filter encased within the filter housing. The filter
key may include a locking nub or tab for attachment to the top
portion. The top portion may include a filter key location boss
or support member extending axially upwards from the top
portion at a distance away from an axial center point, and filter
key lateral support members located opposite the filter key
location boss on the other side of the axial center point and
extending axially upwards from the top portion, the filter key
lateral support members having a separation approximately
equal to the filter key width, the filter key location boss and the
filter key lateral support members forming a structural support with exposed surfaces for attaching the filter key to the
top portion.
In a second aspect, the present invention is directed to a
filter housing assembly comprising: a filter housing for
enclosing a filter media, the filter housing having a body and
a top portion for forming a fluid-tight seal with the body, the
filter housing top portion including: an ingress port; an egress
port; a filter manifold attached to the filter housing top portion, the filter manifold comprising an attachment structure
for receiving the filter key; the filter key located on the top

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 15 of 23


US 8,673,146 B2
3

portion and having a top surface, longitudinal sides, and


lateral sides, the filter key including spaced protrusions, drive
keys, or fingers on the longitudinal sides of the filter key
extending laterally from the top surface, and having winged
extensions with slanted or angled faces, wherein the winged
extensions have a diamond shaped cross-section.
In a third aspect, the present invention is directed to a filter
housing assembly comprising: a filter housing for enclosing a
filter media; a filter head having at least one port in fluid
communication with the filter media, the filter head forming
a fluid-tight seal with the filter housing; a filter manifold
comprising: a base portion axially centered about the filter
head; a port in fluid communication with the filter media; and
a first attachment structure located on the base portion for
receiving a filter key; and the filter key having a top surface, a
bottom, longitudinal sides, and lateral sides, the filter key
including: spaced protrusions or fingers on the longitudinal
sides of the filter key extending laterally from the top surface
and having winged extensions; and a second attachment
structure located on the filter key bottom for attaching the
filter key to the first attachment structure on the filter manifold. The filter key fingers may include slanted or angled faces
on the winged extensions. The winged extensions may have a
diamond shaped cross-section.
The filter head may include a filter key location boss or
support member extending axially upwards from the filter
head top surface at a distance away from the filter head axial
center point, and filter key lateral support members located
opposite the filter key location boss on the other side of the
axial center point and extending axially upwards from the
filter head top surface, the filter key lateral support members
having a separation approximately equal to the filter key
width, the filter key location boss and the filter key lateral
support members forming a structural support with exposed
surfaces for attaching the filter key to the filter head. The filter
key location boss may include an aperture for receiving a
locking nub or tab from the filter key. The filter key second
attachment structure may comprise a complementary groove
or slot on the filter key bottom to attach with the axially
extending protrusion of the filter manifold. The filter manifold may also include radially extending arms about the base
portion, providing structural support for a shroud. The filter
key may include a boss extending in an axial direction above
the top surface of the filter key, the boss having an angled face
of predetermined width ramping upwards from the filter key
top surface and lateral segments or wings extending beyond
the boss width.
In a fourth aspect, the present invention is directed to a filter
base for releasably connecting to a complementary mating
filter housing assembly comprising: a base platform having
fluid ingress and egress ports; and a floating lock in sliding
communication with the base platform, having a bottom surface, a top surface, and longitudinal and lateral sides, the
floating lock including: spaced protrusions, drive keys, or
fingers on the longitudinal sides extending laterally inwards,
including at least one shaped protrusion, finger, or drive key
for slidably contacting the complementary mating filter housing assembly, the at least one shaped protrusion, finger, or
drive key including an angled face exposed towards the bottom surface, and an edge or wedge opposite the angled face
for releasably securing the complementary mating filter housing assembly.
The floating lock includes a position stop centered about
the lateral sides, and located above the at least one drive key
to provide a physical stop during insertion of the complementary mating filter key. The position key includes a track structure longitudinally across the floating lock. The filter base

includes an enclosure for receiving the floating lock, the


enclosure allowing the floating lock to slidably move therein.
A rear plate may be attached to the base platform for at least
partially housing the floating lock. At least one resilient member may be in contact with the floating lock to provide a
retraction force when the floating lock is acted upon by the
filter housing assembly during insertion or extraction of the
filter housing assembly.
In a fifth aspect, the present invention is directed to a filter
base for releasably receiving a complementary mating filter
housing assembly comprising: a base platform having a top
surface; a port for fluid ingress; a port for fluid egress; an
upper ingress stanchion in fluid communication with the
ingress port, the upper ingress stanchion extending upwards
from the base platform top surface, the upper ingress stanchion including a first shutoff plug and a resilient member to
apply axial or vertical force to the first shutoff plug to block
fluid flow from the ingress port during extraction of the filter
housing assembly; an upper egress stanchion in fluid communication with the egress port, the upper egress stanchion
extending upwards from the base platform top surface, the
upper egress stanchion including a second shutoff plug and a
resilient member to apply axial or vertical force to the second
shutoff plug to block fluid flow from the egress port during
extraction of the filter housing assembly; a lower ingress
stanchion in fluid communication with the upper ingress stanchion and the ingress port, the lower ingress stanchion
extending axially downwards from the base platform for
receiving an ingress port from the filter housing assembly; a
lower egress stanchion in fluid communication with the upper
egress stanchion and the egress port, the lower egress stanchion extending axially downwards from the base platform
for receiving an egress port from the filter housing assembly;
an enclosure for at least partially receiving a floating lock, the
enclosure allowing the floating lock to slidably move therein;
the floating lock having longitudinal sides and lateral sides,
including: spaced fingers, drive keys, or protrusions located
on at least one of the longitudinal sides for releasably mating
with fingers of a complementary mating filter key, at least one
of the fingers, drive keys, or protrusions located on an inside
face of the floating lock longitudinal side, and having an
angled surface for slidably contacting fingers on the complementary mating filter housing assembly, such that when the
fingers of the complementary mating filter housing assembly
are inserted within the floating lock, the angled surface slidably contacts the filter housing assembly finger, shifting the
floating lock in a longitudinal direction, the at least one of the
fingers, drive keys, or protrusions including a wedge portion
on one end for releasably securing the filter housing assembly
fingers; a position key centered about the floating block,
above and adjacent the at least one drive key for providing a
physical stop for the filter housing assembly fingers during
insertion or extraction of the filter housing assembly; a rear
plate attached to the base platform for housing the floating
lock; and at least one resilient member attached to the floating
lock to provide a retraction force when the floating lock is
slidably acted upon by the filter housing assembly during
insertion or extraction.
In a sixth aspect, the present invention is directed to a filter
base for releasably receiving a complementary mating filter
housing assembly comprising: a non-floating port including:
a fluid ingress port; a fluid egress port; an ingress stanchion in
fluid communication with the ingress port; an egress stanchion in fluid communication with the egress port; and a
formed recess for receiving a floating lock, the recess at least
partially enclosing the floating lock and having a width and
length that allows the floating lock to shift longitudinally

10

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55

60

65

Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 16 of 23


US 8,673,146 B2
5

therein; the floating lock having a bottom surface, a top surface, and longitudinal and lateral sides, and seated within the
non-floating port formed recess, the floating lock including:
at least one drive key on the longitudinal side extending
laterally inwards at the bottom surface for slidably receiving
an angled boss or winged extension from a complementary
mating filter housing assembly, the at least one drive key
including an angled portion exposed towards the bottom surface, and an edge or wedge on each of the drive key bottom for
releasably contacting with a portion of the complementary
mating filter housing assembly boss or winged extension; a
position key centered about lateral sides of the floating lock,
and located above the at least one drive key to provide a
physical stop during insertion of the complementary mating
filter housing assembly; at least one resilient member in contact with the floating lock for applying a longitudinal retraction force in a direction that tends to push or pull the floating
lock back to an original position; a rear plate for slidably
securing the floating lock within the non-floating port; shutoff
plugs in each of the stanchions forterminating fluid flow from
the ingress and egress ports when the complementary mating
filter housing assembly is removed from the filter base; a
resilient member within each of the stanchions for applying
an axial extraction force to the complementary mating filter
housing assembly, and simultaneously move the shutoff
plugs into position to cease fluid flow when the complementary mating filter housing assembly is extracted.
In a seventh aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the
combination comprising: a filter base having an ingress port
and an egress port on a base platform; a slidable floating lock
in slidable contact of the filter base, the floating lock having a
plurality of drive keys or lateral extensions separated by gaps;
a resilient member in contact with the floating lock, providing
a retraction force for the floating lock; and a filter housing
assembly including: a filter key having a plurality of lateral
extensions separated by gaps, such that when the filter housing assembly is inserted into the filter base, the fingers of the
filter key slidably contact the lateral extensions of the floating
lock to shift the floating lock relative to the base platform,
allowing the fingers on the filter key to traverse between the
lateral extensions on the floating lock, and upon retraction of
the floating lock by the resilient member, the fingers on the
filter key align with the lateral extensions on the floating lock
to prevent extraction of the filter housing assembly.
The floating lock includes a bottom surface, a top surface,
and longitudinal and lateral sides, and wherein the lateral
extensions include drive keys on the longitudinal sides
extending laterally inwards at the bottom surface for slidably
receiving the filter key, each of the drive keys including an
angled portion exposed towards the bottom surface, and an
edge or wedge on each of the drive key bottom for releasably
contacting with a portion of the filter key; and a position key
centered about the floating lock, and located above the drive
keys to provide a physical stop during insertion of the filter
housing assembly.
The combination may also include a rear plate for securing
the floating lock within the filter base; shutoff plugs in each of
the stanchions for terminating fluid flow from the ingress and
egress ports when the filter housing assembly is extracted
from the filter base; and a resilient member within each of the
stanchions for applying an axial extraction force to the filter
housing assembly, and simultaneously moving the shutoff
plugs into position to cease fluid flow when the filter housing
assembly is extracted.
In an eight aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the

combination comprising: a base platform having fluid ingress


and egress ports; an ingress stanchion in fluid communication
with the ingress port; an egress stanchion in fluid communication with the egress port; a floating lock in sliding communication with the base platform, having a bottom surface, a
top surface, and longitudinal and lateral sides, the floating
lock including: spaced protrusions or fingers on the longitudinal sides extending laterally inwards; at least one drive key
for slidably contacting a boss of a filter key of the filter
housing assembly, the at least one drive key including an
angled face exposed towards the filter housing assembly, and
an edge or lip adjacent the angled face for releasably securing
the boss of the filter key upon insertion of the filter housing
assembly; at least one resilient member in contact with the
floating lock for applying a longitudinal retraction force in a
direction that tends to push or pull the floating lock back to an
original position; a filter housing for enclosing a filter media,
the filter housing having a body and a top portion for forming
a fluid-tight seal with the body, the filter housing top portion
including: a filter housing ingress port; a filter housing egress
port; and a filter key located on the top portion and having a
top surface, longitudinal sides, and lateral sides, the filter key
including: spaced protrusions or fingers on the longitudinal
sides of the filter key extending laterally from the top surface;
and a boss extending in an axial direction above the top
surface of the filter key, the boss having an angled face of
predetermined width ramping upwards from the filter key top
surface and laterally extending segments or wings extending
beyond the boss width; such that, when the filter housing
assembly is attached to the filter base, the angled face of the
boss of the filter key slidably contacts the angled face of the at
least one drive key of the floating lock to shift the floating lock
relative to the base platform, allowing the fingers on the filter
key to traverse between the fingers on the floating lock, and
upon retraction of the floating lock by the at least one resilient
member, the fingers on the filter key align with the fingers on
the floating lock to prevent extraction of the filter housing
assembly.
In a ninth aspect, the present invention is directed to a
method for attaching a filter housing assembly to a filter base
comprising: inserting ingress and egress ports of the filter
housing assembly into ingress and egress stanchions of the
filter base; inserting a filter key of the filter housing assembly
having lateral fingers with winged extensions into a slidable
floating lock having lateral fingers or drive keys by using the
filter key to shift the slidable floating lock longitudinally,
whereby the lateral fingers of the filter key transverse the
lateral fingers or drive keys of the floating lock; and releasing
the filter housing assembly so that resilient members in the
filter base apply an extraction force to the filter housing,
moving the filter housing assembly slightly in an axial extraction direction; and providing a retraction force to the floating
lock during the releasing to align the floating lock fingers or
drive keys with the filter key fingers, such that extraction of
the filter housing assembly is prohibited.
In a tenth aspect, the present invention is directed to a
method for extracting a filter housing assembly from a filter
base comprising: applying an axial insertion force to the filter
housing assembly already connected to the filter base towards
the filter base thereby inserting a filter key on the filter housing assembly further into a slidable floating lock of the filter
base; releasing the slidable floating lock, such that the floating
lock moves relative to the filter key under a resilient retraction
force; aligning fingers on the filter key between fingers or
drive keys on the floating lock; and applying an axial extraction force to the filter housing assembly to remove the filter
housing assembly from the filter base.

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 17 of 23


US 8,673,146 B2

In an eleventh aspect, the present invention is directed to a


refrigerator in combination with a filter assembly comprising:
an outer cabinet; a refrigeration compartment disposed within
the outer cabinet and having a rear wall, a pair of opposing
side walls, at least one door disposed opposite the rear wall, a
top and a bottom; a freezer compartment disposed in the outer
cabinet and adjacent to the refrigeration compartment; a
water dispenser disposed in the door and in fluid communication with the filter assembly with automated assembly for
changing a sump and filter media from the refrigerator; the
filter assembly comprising: a filter housing for enclosing a
filter media, the filter housing having a body and a top portion
for forming a fluid-tight seal with the body, the filter housing
top portion including: an ingress port; an egress port; and a
filter key located attached to the filter housing and having a
top surface, longitudinal sides, and lateral sides, the filter key
including spaced protrusions or fingers on the longitudinal
sides of the filter key extending laterally from the top surface.
It is an object of this invention to provide a filter housing
apparatus mounted to a base and having an automatic locking
mechanism for simple replacement and removal.
It is an object of this invention to provide a filter housing
apparatus and base attached by a push activated, slideably
moveable, floating lock.
It is another object of this invention to provide a filter
housing apparatus mounted on a surface having non-rotating
locking means with pressure activation for replacement and
removal.
It is another object of the present invention to provide a
filter housing apparatus that allows for a keyed identification
of the filter.
It is a further object of this invention to provide a filter
housing apparatus for use with water dispensing and\or ice
dispensing apparatus whereby filtered water is provided to the
water dispensing and/or ice dispensing apparatus.

FIG. 3C is a lateral side view of the floating lock of FIG.


3A.
FIG. 3D depicts a top view of the floating lock of FIG. 3A.
FIG. 3E depicts cross-sectional longitudinal side view of
the floating lock of FIG. 3A.
FIG. 4A is a perspective view of one embodiment of the
filter manifold.
FIG. 4B is a top plan view of a second embodiment of the
filter manifold with an extension support member.
FIG. 4C is a perspective view of a second embodiment of
the filter manifold.
FIG. SA is a side view ofone embodiment of the filter head
of the present invention.
FIG. SB is a bottom perspective view of the filter head of
FIG. SA.
FIG. SC is a top perspective view of the filter head of FIG.
SA.
FIG. SD is another embodiment of the filter head with a
snap fit lock for the filter key.
FIG. SE is a bottom perspective view of the filter head of
FIG. SD.
FIG. SF is a top perspective view of the filter head depicting
the aperture for receiving the filter key.
FIGS. 6A and 6B are exploded views of a second embodiment of the filter assembly of the present invention, showing
a filter key having an extended boss.
FIG. 7A is a top perspective view of an embodiment of the
filter key of the present invention having an extended boss.
FIG. 7B is a bottom perspective view of the filter key of
FIG. 7A.
FIG. 7C depicts a top plan view of the filter key of FIG. 7A.
FIG. 7D depicts a side plan view of the filter key of FIG.
7A.
FIG. 7E depicts an end or lateral side view of the embodiment of the filter key of FIG. 7A, showing the boss rising
above the plane created by the fingers, and two wings extending laterally outwards from the boss.
FIG. 7F is a perspective view of a another embodiment of
the filter key of the present invention showing a locking nub
located on the bottom portion on a lateral side.
FIG. SA depicts a perspective view of an embodiment of
the floating lock of the present invention.
FIG. SB is a top view of the floating lock of FIG. SA.
FIG. SC is a cross-sectional view of the floating lock of
FIG. SA depicting a drive key located at one end of the
floating lock on the longitudinal or side panel.
FIG. SD depicts an exploded view of the drive key of FIG.
SC showing the edge angle and face.
FIG. SE depicts a perspective view ofa floating lock having
an extension member.
FIG.SFisasideviewofthefloatinglockofFIG.SEhaving
an extension member.
FIG. SG is a lateral or cross-sectional view of the floating
lock of FIG. SE with an extension member.
FIG. 9A is a perspective view of a non-floating port of the
present invention.
FIG. 9B is a top plan view of the non-floating port of FIG.
9A.
FIG. lOA is a top plan view of one embodiment of the rear
plate of the present invention.
FIG. lOB is a bottom perspective view of the rear plate of
FIG. lOA.
FIG. lOC is a top plan view ofa second embodiment of the
rear plate of the present invention.
FIG. 11 is an exploded view of a filter assembly of the
present invention, showing a filter key having a boss, connected to a filter manifold having extension supports.

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BRIEF DESCRIPTION OF THE DRAWINGS


The features of the invention believed to be novel and the
elements characteristic of the invention are set forth with
particularity in the appended claims. The figures are for illustration purposes only and are not drawn to scale. The invention itself, however, both as to organization and method of
operation, may best be understood by reference to the
description of the preferred embodiment( s), which follows,
taken in conjunction with the accompanying drawings in
which:
FIG. lA is a top exploded view ofone embodiment of the
filter assembly of the present invention.
FIG. lB is a side plan view the embodiment of the filter
housing assembly of FIG. lA.
FIG. 2A is a perspective view of one embodiment of the
filter key of the present invention.
FIG. 2B is a lateral side view of the filter key of FIG. 2A.
FIG. 2C depicts a bottom plan view of the filter key of FIG.
2A showing a groove and a locking nub or tab for attachments.
FIG. 2D depicts a perspective view from the opposite side
of the filter key of FIG. 2C.
FIG. 2E depicts a bottom view of the filter key of FIG. 2A.
FIG. 2F is a longitudinal side view of the filter key of FIG.
2A.
FIG. 3A depicts a perspective view of one embodiment of
the floating lock or sliding lock of the present invention.
FIG. 3B is a perspective view from the opposite side of the
floating lock of FIG. 3A.

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DETAILED DESCRIPTION OF THE PREFERRED


EMBODIMENT(S)

manly used in the art for sealing adjoining components, typically adjoining plastic components. As discussed in further
detail below, filter key 5 is connected to filter manifold 3.
Filter key 5 may be formed as one piece with filter manifold
3, or may be securely attached by other methods, such as
bonding, welding, press fit, friction fit, or the like. Filter key
5 may also be removably attached for replacement by an end
user. Filter manifold 3 is attached to filter head 2. Filter
manifold 2 may be removably attached as well for replacement by an end user. Filter media 8 is located in filter housing
1. Each end of filter media 8 is secured by a cap that facilitates
the direction of the fluid being treated by the filter. At one end,
filter media 8 is secured by a closed end cap 7, and at the other
end by open end cap 6. Filter media 8 may be any filter media
known in the art, and preferably, is a carbon block filter. It is
typically shaped in a similar fashion as filter housing 1, which
in the preferred embodiment is cylindrical. Open end cap 6 is
designed to interface and be in fluid communication with
filter head 2. Filter housing assembly 200 is a finished assembly including filter housing 1, which encompasses filter
media 8 by closed end cap 7 at one end, and open end cap 6 at
the other. Generally, a-ring seals, such as a-ring seal 9, are
used to prevent water leakage where different components are
expected to mate. Filter manifold 3 and filter key 5 are joined
with filter head 2, and secured to filter housing 1 to form the
assembled filter housing apparatus 200. These components
may be integral, permanently secured, or removably attached
to one another, and to filter head 2. FIG. lB is a side plan view
of the preferred embodiment of the filter assembly of the
present invention.
FIG. 2A is a perspective view of filter key 5. FIG. 2B is a
lateral side view of filter key 5. As previously noted, the
bottom of filter key 5 is attached to filter manifold 3 by any
number of fastening schemes, or may be integrally formed
with filter manifold 3. FIG. 2C depicts a groove 51 that is
preferably shaped to receive a complementary protrusion on
filter manifold 3, and is preferably shaped to receive a dovetail protrusion; however, other connecting, complementary
shapes are not excluded. The connection of filter key 5 with
filter manifold 3 may be bonded, sonic welded, press fitted,
friction fitted, or the like. As depicted in the illustrative
embodiment, groove 51 is shaped to accept a snap feature for
a press or snap fit located on filter manifold 3. In this manner
filter key 5 may be removably attached to filter manifold 3.
Similarly, filter manifold 3 may be designed to be removably
attached to filter head 2. Thus, the design has more flexibility
to introduce and accommodate different key configurations,
which can be used to designate specific filter types, and purposely reject other filter types.
FIG. 4A depicts a perspective view of the one embodiment
of filter manifold 300. Port 310 is shown off center of filter
manifold 300. FIG. 4A depicts the filter manifold without
extension support members. Preferably, port 310 is an outlet
port; however, the present invention is not limited to a specific
ingress and egress location, and may have these ports interchanged. When port 310 is used as an egress or outlet port,
filter manifold 300 takes fluid from filter media 8 through the
center port of open cap 6, and directs fluid flow radially
outwards from the axial center to port 310. In this embodiment, the ingress port is located on filter head 2. By locating
the ingress and egress ports off axis, filter housing assembly
200 has a more robust design, with enhanced structural integrity for mounting to the filter base, and for remaining fixably
in place during attachment. Referring to FIGS. 4A-4C, in a
preferred attachment scheme for filter key 5, a protrusion 32
or 320 is formed on or nearthe center line of filter manifold 3
or 300. Protrusion 32 or 320 is preferably a rectangular

In describing the preferred embodiment of the present


invention, reference will be made herein to FIGS. 1to11 of
the drawings in which like numerals refer to like features of
the invention. Features of the invention are not necessarily
shown to scale.
The present invention is directed to a filter housing assembly for filtration of liquids, including the interception of
chemical, particulate, and/or microbiological contaminants.
The use of the mechanical locking assembly of the filter
housing without the need for excess force and tight tolerances
essential in prior art filter housings makes for easy and frequent filter changes and optimal filter performance. The filter
housing assembly of the present invention provides simplified filter changes to minimize process downtime and without
recourse to tools. A simple push mechanism actuates the
self-driving release and change over means that hold and
release the filter housing sump or filter cartridge, and provides
influent shutoff means to prevent leaking and spillage. A
floating lock or sliding lock responsive to an axial insertion
force from the filter cartridge moves perpendicular or radially
to the axial motion of the sump, and allows a specific filter key
to insert within the floating lock. Once inserted, the floating
lock retracts towards its original position under a resilient
force, such as two springs in tandem, or other complementary
resilient mechanism keeping the floating lock under retraction tension when moved from its initial position. The filter
key and floating lock combination allows for the identification of specific filter models and may be configured to reject
all but specific filter types.
Removal of the filter cartridge is performed in the same
manner. An axial insertion force causes the floating lock to
move radially, which allows the filter key to be removed from
the floating lock. An extraction force provided by spring
tension, or the like, helps push the filter cartridge out of its
base. Fluid shutoff and locking mechanisms are initiated by
the axial force on the filter cartridge at the commencement of
the filter changing procedure.
The present invention is described below in reference to its
application in connection with, and operation of, a water
treatment system. However, it should be apparent to those
having ordinary skill in the art that the invention may be
applicable to any device having a need for filtering liquid.
FIG. lA is a top exploded view of the preferred embodiment of the filter assembly of the present invention. The filter
assembly is fixably secured in a position within an operating
environment requiring fluid filtration, such as attached to an
internal sidewall of a refrigerator, although certainly other
operating environments may be envisioned, and the filter
assembly may be used in any number of environments where
the filter assembly has access to, and can be placed in fluid
communication with, influent and effluent fluid access ports.
For illustrative purposes only, application to the filtering of
water being piped into a refrigerator is discussed.
A filter housing assembly 200 comprises the removable,
detachable filter cartridge or sump of the filter assembly from
a filter base 100. Filter housing assembly 200 includes a filter
housing 1, which encloses filter media 8, a filter head 2 that
attaches at one end to filter housing 1, and attaches at the other
end to a filter manifold 3 and non-floating port 11. A filter key
5 is attached to filter manifold 3. Filter base 100 includes
non-floating port 11, floating lock 12, and rear plate 13. Filter
head 2 secures in a water-tight fit to filter housing 1. The
attachment scheme may be made by a water-tight screw fit,
bond, weld, or other water-tight fastening mechanism com-

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 19 of 23


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12

shaped segment extending above circular center portion 33 or


330. Protrusion 32 allows for precise alignment of filter key S,
while providing a robust connection. A dovetail shape, press
fit, or friction fit interconnection between protrusion 32 and
groove Sl of filter key S permits the user to remove and
replace filter key S. This allows for the designation of specific
filter keys, and correspondingly, specific filter cartridges. Protrusion 32 or 320 may be integrally formed with filter manifold 3 or 300, respectively, or may be separately fabricated
and attached by bond, weld, press fit, friction fit, or other
suitable means known in the art. Preferably, protrusion 32 or
320 has a dovetail shaped surface for mating with complementary groove Sl of filter key S.
In the embodiment depicted by FIGS. 4B and 4C, protrusion 32 may be on an extension support 34. FIG. 4B depicts a
top level view of filter manifold 3, showing extension support
34 extending longitudinally or radially outward from center
portion 33, along a radius. Extension support 34 supports
optional shroud 4 that covers and protects filter head 2.
Filter manifold 3 or 300 seats within, and attaches to, filter
head 2. FIG. SA depicts a side view of one embodiment of
filter head 2. Filter head 2 is shown with off-center port 21. In
this manner, port 21 of filter head 2 and port 31 of filter
manifold 3 are both off-center and parallel to one another
about a plane that approximately intersects the center point of
filter head 2. As shown in FIGS. 1, 4, and S, a recessed portion
22 formed about the center point of filter head 2 receives
center portion 33 of filter manifold 3. If extension support 34
is used with filter manifold 3, when filter manifold 3 is
inserted within filter head 2, extension support 34 is situated
approximately perpendicular to the plane formed by ports 21
and 31. Extension support 34 provides at each end a snap fit
design for shroud 4. FIG. SB is a bottom perspective view of
the filter head. FIG. SC is a top perspective view of filter head
2 depicting recess portion 22.
Filter head 210 depicts another embodiment as shown in
FIGS. SD-SF. In this embodiment, as depicted in the top
perspective view of FIG. SF, on the top surface of filter head
210 is a curved receiving boss or support member 23 0 located
on one side of the center point, and two parallel, lateral
support members 240a,b located opposite curved boss 230 on
the other side of the center point of filter head 210. These
structural support members are used to align filter key S to
filter head 210, and help secure filter key S. This filter head
may be used in conjunction with the filter manifold 300
without extension supports, as depicted in FIG. 4A. Structural
support member 230 provides a physical stop for filter key S,
which typically slides on protrusion 32 provided by filter
manifold 300. Lateral support members 240a,b are used to
align filter key S, and prevent it from inadvertent shifting.
FIG. SE is a bottom perspective view of filter head 210. FIG.
SD is a side view of filter head 210.
Filter manifold 300 includes an off-center port 310, as well
as a center portion 330 that fits securely within recess 220 of
filter head 210. Protrusion 320 receives the groove from filter
key S. In this embodiment, when filter key S is slidably
inserted within protrusion 320, structural support member
230 and lateral structural support members 240a,b secure
filter key S. The curved portion of structural support member
230 forces filter key S to be inserted in one direction only. An
added boss 232, located on the top of filter head 210 and
centered between lateral support members 240a,b may be
employed to serve as a lock or snap fit for filter key S. Additionally, in another embodiment, structural support member
230 may be formed with a small aperture 23S located directly
away from the center point of filter head 210 at its base where
support member 230 meets the top portion of filter head 210.

This small aperture 23S is designed to receive a protruding


material or locking nub or tabe S3 placed at, or formed with,
the corresponding end portion of filter key S on the lower end
of a lateral side. Locking nub or tab S3 on filter key S is
inserted within small aperture 23S on the curved portion of
structural support member 230 and prevents axial removal of
filter key S away from filter head 210. FIGS. 2A-2F show
locking nub S3 located on the bottom portion of a lateral side
of filter key S. FIG. SD is a side view of filter head 210
depicting aperture 23S for receiving filter key S.
Filter key S includes at least one laterally extending finger
S2, and preferably a plurality of extending fingers, as depicted
in FIGS. 2A-2F. FIG. 2C is a bottom perspective view of filter
key S. In a first illustrative embodiment, filter key Sis shown
with ten laterally extending fingers S2. Fingers S2 are preferably constructed of the same material as, and integrally
formed with, base SS of filter key S. However, the fingers may
also be removably attached, and the filter key design is not
limited to an integrally formed construction. The laterally
extending fingers S2 may form a number of different configurations. In the illustrative embodiment, there is a uniform gap
S4 between each finger S2. In other configurations, a finger
may be missing on one or both sides of filter key S, and gap S4
may be wider in some places than in others. Using a digital 1,
0 designation to indicate a finger (1) or a gap (0), it is possible
to have many different configuration for a filter key. The
configuration as shown in FIG. 2E would be designated on
each side as 101010101. As a separate example, for a designation of100010101, this would represent a lateral finger (1)
followed by a wide gap (000), and then a finger (1) followed
by a gap (0) and a finger (1) followed by another gap (0), and
one last finger (1 ). The present invention is not limited to any
particular finger/gap order. Additionally, it is not necessary
for the finger/ gap configuration on one side of filter key S to be
symmetric with the finger/gap configuration on the opposite
side. By having different finger/gap configurations, it is possible to make a mechanical key identifier for the specific filter
housing assembly being employed. Filter key S may also be
color-coded to facilitate identification for different filter cartridges or housing assemblies. It may also be textured, mirrored, transparent, translucent, materially modified, or having
a conductively signature, or any combination thereof, for
identification purposes. More importantly, aside from identification of the filter housing assembly, a particular filter key
finger/gap configuration will only allow for the use of a specific filter housing assembly in a given system.
Fingers S2 of filter key S are strength bearing members,
used to mate with, or interlock with, corresponding drive keys
l23a,b located on longitudinal sides of floating lock 12 as
depicted in FIG. 3. There must be at least one drive key on
floating lock 12 that corresponds to, and lines up with, at least
one finger on filter key S, so that when filter key S is inserted
to mate with floating lock 12, the drive keys slidably contact
the fingers and floating lock 12 is shifted longitudinally an
incremental amount to allow fingers S2 on filter key S to
traverse between the gaps 122 on floating lock 12. Once
fingers S2 have passed between the corresponding gaps on
floating lock 12, which is slidably restrained under tensional
forces, floating lock 12 is partially returned towards its original position by the tensional retraction forces so that at least
one finger on filter key S aligns or interlocks with at least one
drive key on floating lock 12, and the alignment resists any
direct outward, axial extraction forces.
Each finger S2 of filter key S includes a slanted face SS as
depicted in FIGS. 2A and 2F. These angled features are made
to slidably contact complementary slanted edge or angled
features l2la,b of drive keys 123a,b of floating lock 12

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shown in FIGS. 3A and 3E. During insertion of filter key 5,


the sliding contact of the angled feature of the filter key's
fingers transversely shifts floating lock 12 off of its initial
position, and allows the fingers of filter key 5 to be inserted
within gaps 122 between the drive keys 123a,b.
A perspective view of floating lock 12 is depicted in FIGS.
3A and 3B. Floating lock 12 has angled-faced fingers, protrusions, or drive keys 123a,b and gaps 122 that may reciprocally correspond to fingers 52 and gaps 54 located on filter
key 5. It is not necessary for the drive keyI gap configuration of
floating lock 12 to be exactly complementary to the finger/gap
configuration of filter key 5. It is only necessary that floating
lock 12 is able to fully receive the inserting filter key 5 when
filter housing assembly 200 is axially inserted into filter base
100. Each drive key 123a,b offloating lock 12 is shaped with
a receiving wedge 129a, b, respectively, opposite slanted edge
l2la,b to capture fingers 52 of filter key 5. Fingers 52 may
have a cross-sectional diamond shape to facilitate the capture
by the drive key receiving wedge l29a,b. Drive keys 123a,b
are placed on at least one longitudinal side of floating lock 12,
as depicted in FIGS. 3D and 3E. Underneath and centered
between drive keys 123a,b is a row of position stops 125.
Position stops 125 preclude fingers 52 from extending any
further during insertion. There need not be a position stop 125
for each drive key 123a,b, provided there is at least one
position stop 125 to prohibit over insertion of filter key 5.
Position stops 125 also include a slanted or angled face 126
for slidable contact with slanted face 58 of fingers 52 on filter
key 5. Position stops 125 are shown as a row of jagged edges,
but do not have to correspond one-for-one with drive keys
l23a,b.
Upon insertion, when fingers 52 of filter key 5 contact drive
keys 123a,b, floating lock 12 shifts away from its initial
position, against retraction forces, and moves according to the
contacting angled edges 58 and 121. Once wings 56a,b of
fingers 52 clear lip l27a,b of drive keys 123a,b, floating lock
12 is not prohibited from reacting to the retraction forces, and
moves slightly back, towards its original position where diamond shaped wings 56a,b are then trapped by receiving
wedges l29a,b. This position locks filter key 5 to floating lock
12 resisting any a direct axial extraction force.
There is a gap or space 124 between the bottom most
portion of drive key 123a,b and top most portion of position
stop 125. Upon extraction, when wings 56a,b of fingers 52 are
pushed within this gap or space, there is no structure preventing floating lock 12 from responding to the tensional retraction forces acting on it. Thus, floating lock 12 is free to
respond to the retraction forces, and will tend to move
towards its initial position. This will align fingers 52 of filter
key 5 within gaps 122 of floating lock 12 and allow for easy
extraction of filter housing 200.
In order to extract filter housing assembly 200, a user again
pushes axially inwards on the filter housing assembly, which
releases wings 56a,b on filter key 5 from drive keys 123a,b.
This frees floating lock 12 to return to towards its original
position, and locates fingers 52 on filter key 5 at gaps 122 of
floating lock 12. Filter housing assembly 200 can now be
freely extracted from filter base 100. Resilient members 1110
within shut-off stanchions llOla,b of non-floating port 11
assist in pushing or extracting filter housing assembly 200
away from filter base 100.
FIG. 9A is a perspective view of non-floating port 11,
which works in tandem with rear plate 13 or rear plate 1300 to
hold floating or sliding lock 12 in place while allowing it to
freely move longitudinally off its center position and back to
its center position during the insertion and extraction of filter
housing assembly 200. As discussed further herein, non-

floating port 11 will also hold floating lock 1200 and floating
lock 1212 of FIG. 8. For simplicity, reference is made chiefly
to the interaction of non-floating port 11 with floating lock 12,
although the applicability of non-floating port 11 includes
usage with floating lock 1200and1212 as well. Non-floating
port 11 includes a protruding encasement 1102, larger than
floating lock 12, and made to enclose floating lock 12 therein.
Encasement 1102 prevents over-travel of floating lock 12, and
protects it when installed from extraneous, unintended movement. FIG. 9B is a top plan view of non-floating port 11.
Stanchions llOla,b are located on opposite sides of encasement 1102. Ports 1103 represent the ingress and egress ports
for the fluid. Shut-off stanchions llOla,b include shutoff
plugs 14, which act as valve seals to stop fluid flow when the
filter cartridge is being removed. Shut-off stanchions llOla,b
are preferably cylindrical in shape, containing spring activated, a-ring sealed plugs for sealing the ingress and egress
lines during filter cartridge removal. In a preferred embodiment, rear plate 13 is snap fitted into non-floating port 11. In
order to accommodate this, snap fittings 1105 are shown on
non-floating port 11 that receive a corresponding fitting 135
on rear plate 13.
Referring to FIG. 1, floating lock 12 is supported by nonfloating port 11 and rear plate 13. FIG. lOA is a top plan view
of one embodiment of rear plate 13 of the present invention.
FIG. lOB depicts a bottom perspective view ofrear plate 13.
Rear plate 13 secures floating lock 12 within a support structure in non-floating port 11. Rear plate 13 is preferably
attached by snap fit to non-floating port 11, although other
attachment schemes known in the art may be easily
employed, such as bonding, welding, and assorted mechanical fasteners. Rear plate 13 is formed with extensions 132 on
each end, and shaped gaps 133 therebetween. Gaps 133 are
shaped to go around shut-off stanchions llOla,b of nonfloating port 11. In this embodiment, rear plate 13 includes a
center aperture 131 that allows for longitudinal movement of
floating lock 12. Floating lock 12 may include an extension
member opposite the face configured with fingers and gaps, in
order to permit resilient components, such as helical or torsion springs to act upon it. FIGS. 3C and 3E are side views of
the floating lock showing extension member 128. FIG. 3B is
a perspective view of the floating lock 12 with extension
member 128. FIG. SE depicts floating lock 1212 with extension member 1280. In these embodiments, the extension
member is acted upon by resilient devices held by the rear
plate.
FIG. lOC is a top plan view of another embodiment of the
rear plate 1300 of the present invention. In this embodiment,
the topside of rear plate 1300 includes a domed, slotted cover
1302 over the center aperture. Cover 1302 is formed to encase
springs or other resilient members about the extension member 128 extending from floating lock 12. Dome 1302 includes
a slot 1304 that is made to receive the extension member 128
from floating lock 12. Slot 1304 helps retain linear movement
offloating lock 12 inside dome 1302. In this embodiment, two
complementary resilient members, such as springs, would
reside on each side of the extension member 128 of floating
lock 12. One resilient member preferably applies force on the
floating lock extension member in one direction, while the
other resilient member applies force to the floating lock
extension member in the opposite direction. In this manner,
no matter which way floating lock 12 is moved or shifted, a
retraction force presents itself to return floating lock 12 to its
original, centered position.
At all times during insertion, the filter housing assembly is
under extraction forces that tend to push the housing out of the
filter base. These extraction forces result from resilient mem-

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bers in each shut-off stanchion llOla,b of non-floating port


11 (shown in FIG. 9B) that force shutoff plugs 14 into position in order to block the ingress and egress ports. Preferably,
the extraction forces on shutoff plugs 14 are provided by a
spring 1110 in each port, although other resilient members
may be used to provide a similar result. Inserting the filter
housing assembly into the filter base works against these
extraction forces, and pushes shutoff plugs 14 further up each
shut-off stanchion llOla,b of non-floating port 11. This
allows for fluid ingress, while keeping the filter housing
assembly under the constant extraction force.
Protective port shroud 4 may be placed over filter head 2, to
protect the floating lock 12 and filter key 5 mechanism from
damage and debris. Shroud 4 is preferably supported by the
extension supports on the filter manifold.
FIGS. 6A and 6B are exploded views of another embodiment of the filter assembly of the present invention, showing
the combination of filter manifold 300, filter key 500, and
filter head 210. Filter key 500 is depicted without a locking
nub or tab; however it may included a locking nub to facilitate
attachment to the filter head. FIG. 7F depicts filter key 590
with locking nub or tab 501. Locking nub 501 is located at the
base of filter key 590. In this embodiment, filter key 500 or
590 and filter manifold 300 are modified such that floating
lock 1200 or 1212 of FIG.Sis slidably shifted by the interaction wings 560a,b of an extended boss 550 on filter key 500
or 590 with drive keys 1210a,b of floating lock 1200.
Filter key 500 or 590 is inserted within floating lock 1200
through the axial insertion of the filter housing assembly into
the filter base. Hammerhead shaped wings 560a,b on fingers
520 of filter key 500 and drive keys l210a,b on floating lock
1200 or 1212 slidably contact one another, causing a transverse motion of floating lock 1200 or 1212 perpendicular to
the axial motion of insertion. In this manner, floating lock
1200 or 1212 is shifted longitudinally, in a direction radially
relative to the filter housing assembly axis. Fingers 520 of
filter key 500 are positioned within the gaps 1220 on floating
lock 1200 or 1212. Once filter key 500 or 590 is inserted,
floating lock 1200 or 1212 is returned partially towards its
original position by retracting tensional forces, preferably by
complementary spring forces, so that the fingers on floating
lock 1200 or 1212 align directly with fingers 520 on filter key
500 or 590, thus preventing a direct extraction force from
removing the filter housing assembly from the filter base.
FIG. 7F depicts a top perspective view of filter key 590. At
one end of filter key 590 is an upwardly extended angled boss
550. Boss 550 rises above horizontal plane 570 created by the
top portion of fingers 520, and is angled toward fingers 520,
with its highest point at one end of filter key 500. Boss 550
angles downward from its highest point towards fingers 520.
Preferably, boss 550 is an upwardly facing triangular or
wedge shaped design having wings 560a,b for interaction
with drive keys l210a,b, respectively, on floating lock 1200.
FIG. 7E depicts an end view of filter key 500 showing a
hammerhead shaped boss 550 rising above plane 570 created
by fingers 520, and wings 560a,b extending laterally from
boss 550 resembling what may be considered a hanimerhead
shape. The purpose of wings 560a, bis to contact corresponding angled drive keys l210a,b on floating key 1200.
A perspective view of the complementary floating lock
1200 is depicted in FIG. SA. The only difference between
floating lock 1200 of FIG. SA and floating lock 1212 of FIG.
SE is the addition of an extension member 12SO on floating
lock 1212. Floating lock 1200 has fingers 1230a,b and gaps
1220 that may reciprocally correspond to fingers 520 and
gaps 540 located on filter key 500 or 590. It is not necessary
for the finger/gap configuration of floating lock 1200 to be

exactly complementary to the finger/gap configuration of


filter key 500 or 590. It is only necessary that floating lock
1200 is able to fully receive the inserting filter key 500 when
the filter housing assembly is axially inserted into the filter
base. Furthermore, once floating lock 1200 is subjected to
retraction forces acting to return it partially towards its original position, it is necessary that at least one finger on filter key
500 or 590 vertically align with at least one finger on floating
lock 1200 or 1212 preventing any extraction without further
shifting of floating lock 1200or1212.
Using floating lock 1200 and filter key 500 as illustrative
examples, upon slidable contact of wings 560a, b on filter key
500 and drive keys 1210a,b on floating lock 1200, floating
lock 1200 moves in a transverse motion, perpendicular to the
axial motion ofinsertion. In this manner, floating lock 1200 is
shifted longitudinally, in a direction radially relative to the
filter housing assembly axis. Fingers 520 of filter key 500 are
positioned within the gaps 1220 on floating lock 1200. Once
filter key 500 is inserted, floating lock 1200 is returned partially towards its original position by retracting tensional
forces, preferably by complementary spring forces, so that
the fingers on floating lock 1200 align directly with fingers
520 on filter key 500, thus preventing a direct extraction force
from removing the filter housing assembly from the filter
base.
Fingers 1230a,b are preferably constructed of the same
material as floating lock 1200 and integrally formed therewith. However, fingers 1230 may also be removably attached,
and the floating lock design is not limited to an integrally
formed construction. Additionally, the present invention is
not limited to any particular finger/gap order. It is not necessary for the finger/gap configuration on one side of floating
lock 1200 to be symmetric with the finger/gap configuration
on the opposite side. Floating lock 1200 is responsive to
tensional forces, such as complementary springs acting on it
from two separate directions to provide resistance longitudinally. Floating lock 1200 effectively moves longitudinally
when acted upon by filter key 500, and is forced to return
partially towards its original position after fingers 520 of filter
key 500 have traversed through gaps 1220. Upon partial
retraction, fingers 520 are aligned behind or underneath fingers 1230 of floating lock 1200. FIG. SB is a top view of
floating lock 1200 showing laterally extending fingers
1230a,b and adjacent gaps 1220 between the fingers.
FIG. SC is a cross-sectional view of floating lock 1200,
depicting drive key 1210a, which is located at one end of
floating lock 1200 on longitudinal or side panel 1240. Drive
key 1210a is opposite a similar drive key 1210b (not shown),
which is located on the opposite longitudinal panel of floating
lock 1200. Both drive keys are designed to have an angled
face for slidably interacting with wings 560a, b of boss 550 on
filter key 500. Each drive key is preferably integrally fabricated with floating lock 1200; however, the drive keys may be
fabricated separately and attached to the longitudinal panels
of floating lock 1200 by attachment means known in the art.
As shown in FIG. SC, below drive key 1210a is a position key
or physical stop 1250, preferably formed with the supporting
lateral wall 1260 of floating lock 1200. As shown in FIG. SB,
position key 1250 is situated between drive keys l210a,b.
Position key 1250 may be integrally formed with lateral wall
1260, or may be separately attached thereto by any acceptable
means in the prior art, such as bonding, welding, gluing, press
fitting, and the like. Position key 1250 acts as a physical stop
to ensure against over travel of floating lock 1200. Position
key 1250 is situated below drive keys 1210a,b by a distance
designed to accommodate the insertion of boss 550 of filter
key 500. Upon insertion of filter key 500 into floating lock

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Case 3:16-cv-01433-SRU Document 1-12 Filed 08/23/16 Page 22 of 23


US 8,673,146 B2
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1200, boss 550 traverses through gap 1270 in floating lock


preferably in close proximity to the use of the filtered water
produced by the filter housing apparatus.
1200 formed by the space between drive keys 1210a,b. Wings
While the present invention has been particularly
560a,b of boss 550 extend outward relative to the width of
described, in conjunction with a specific preferred embodiboss 550, traversing between lateral wall 1260 and drive keys
l210a,b. In this manner, wings 560a,b retain floating lock 5 ment, it is evident that many alternatives, modifications and
variations will be apparent to those skilled in the art in light of
1200 from retracting back to its original position while boss
the foregoing description. It is therefore contemplated that the
550 is being inserted. At all times, floating lock 1200 is under
appended claims will embrace any such alternatives, modifithe retraction force of resilient members, such as tandem
cations and variations as falling within the true scope and
springs, or the like, tending to keep floating lock 1200 its
10 spirit of the present invention.
original position, which is preferably a centered position.
During insertion of filter key 500, wings 560a,b interact with
The invention claimed is:
drive keys 1210a,b to shift floating lock 1200 longitudinally
1. A filter housing assembly comprising:
off-center while under the resilient retraction forces. Upon
a filter housing for enclosing a filter media, said filter
full insertion, when boss 550 reaches and contacts position 15
housing having a body and a top portion for forming a
key 1250, wings 560a,b are no longer held by drive keys
fluid-tight seal with said body, said filter housing top
l210a,b because the length of drive keys 1210a,b is shorter
portion including:
than the length of boss 550. At this point in the insertion
an ingress port;
process, the tensional retraction forces shift floating lock
an egress port;
1200 towards its original position.
a filter key located on said top portion and having a top
20
Once wings 560a,b reach position key 1250, and the user
surface, longitudinal sides, and lateral sides, each of said
filter key longitudinal sides including a plurality of
releases the insertion force initially applied on the filter housing assembly, the extraction forces from shutoff plug springs
spaced protrusions or fingers extending laterally from
said top surface, wherein said fingers include winged
1110 dominate. These forces push the filter housing assembly
extensions having slanted or angled faces for mating
axially outwards, away from floating lock 1200. Since wings 25
attachment to a filter base or manifold.
560a,b are no longer bound between drive keys 1210a,b and
lateral wall 1260, floating lock 1200 will tend to shift longi2. The filter housing assembly of claim 1 wherein said
tudinally, partially towards its original position as filter key
fingers include a diamond shaped cross-section.
500 moves slightly axially outwards. At this point, wings
3. The filter housing assembly of claim 1 including having
560a,b interact with edge angles l280a,b to push away from 30 said filter key attached to said filter housing top portion by
snap fit, friction fit, welding, or bonding.
the center position, shifting filter key 500, and combining or
contacting with face l300a,b to keep the filter housing from
4. The filter housing assembly of claim 1 including a filter
retracting. FIG. SD depicts an exploded view of drive key
manifold or base attached to said filter housing top portion,
said filter manifold or base comprising an attachment struc1210a with edge angle 1290a and face 1300a.
Fingers 520 of filter key 500 are now aligned with fingers 35 ture for fixably receiving said spaced protrusions or fingers on
said longitudinal sides of said filter key.
1230 of floating lock 1200 and remain in contact in a vertical
plane in the axial direction, prohibiting extraction of the filter
5. The filter housing assembly of claim 4 wherein one of
housing assembly from the filter base.
said ingress or egress ports is located on said filter manifold.
It is envisioned that the preferred embodiment of the
6. The filter housing assembly of claim 1 wherein said
present invention would be disposed in a refrigerator, most 40 ingress port and said egress port are off axial center of said
likely within the door. The output of the filter assembly may
filter housing.
be selectively coupled to a water dispenser or an ice dispenser.
7. The filter housing assembly of claim 1 wherein said
The water source to the refrigerator would be in fluid comspaced protrusions or fingers are integrally formed with said
munication with filter base 100, and prohibited from flowing
filter key.
when filter housing assembly 200 is removed from filter base 45
8. The filter housing assembly of claim 1 including having
said spaced protrusions or fingers forming a predetermined
100. Shutoff plugs 14 in stanchions llOla,b seal fluid flow
until filter housing assembly 200 is inserted in filter base 100.
pattern for identifying different filter attributes unique to a
filter encased within said filter housing.
Upon insertion, fluid would flow to the filter housing assembly and filter water would be returned from the filter housing
9. The filter housing assembly of claim 1 including having
assembly.
50 said filter key color-coded, transparent, translucent, mirrored,
All parts of the filter housing assembly 200 and filter base
textured, materially modified, or having a conductively signature for identifying different filter attributes specific to a
100 may be made using molded plastic parts according to
filter encased within said filter housing.
processes known in the art. The filter media may be made
from known filter materials such as carbon, activated carbons,
10. A filter housing assembly comprising:
malodorous carbon, porous ceramics and the like. The filter 55
a filter housing for enclosing a filter media, said filter
housing having a body and a top portion for forming a
media, which may be employed in the filter housing of the
fluid-tight seal with said body, said filter housing top
instant invention, includes a wide variety of filter media
portion including:
capable of removing one or more harmful contaminants from
an ingress port;
water entering the filter housing apparatus. Representative of
an egress port;
the filter media employable in the filter housing include those 60
a filter manifold attached to said filter housing top portion,
found in U.S. Pat. Nos. 6,872,311, 6,835,311, 6,797,167,
said filter manifold comprising an attachment structure
6,630,016, 6,331,037, and 5,147,722. In addition, the filter
for receiving a filter key, said filter key located on said
composition disclosed in the following Published Applications may be employed as the filter media: US 2005/0051487
top portion and having a top surface, longitudinal sides,
and lateral sides, each of said filter key longitudinal sides
and US 2005/00111827.
65
including a plurality of spaced protrusions, drive keys,
The filter assembly is preferably mounted on a surface in
proximity to a source of water. The mounting means are also
or fingers extending laterally from said top surface, and

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US 8,673,146 B2
19

20

having winged extensions with slanted or angled faces,


wherein said winged extensions have a diamond shaped
cross-section.
11. A filter housing assembly comprising:
a filter housing for enclosing a filter media;
a filter head having at least one port in fluid communication
with said filter media, said filter head forming a fluidtight seal with said filter housing;
a filter manifold comprising:
a base portion axially centered about said filter head;
a port in fluid communication with said filter media; and
a first attachment structure located on said base portion
for receiving a filter key;
wherein said filter manifold is formed integrally with
said filter head, and
said filter key having a top surface, a bottom, longitudinal sides, and lateral sides, said filter key including:
two opposing longitudinal sides having a plurality of
spaced protrusions or fingers on each longitudinal
side extending laterally from said top surface and
having winged extensions; and
a second attachment structure located on said filter
key bottom for attaching said filter key to said first
attachment structure on said filter manifold.
12. The filter housing assembly of claim 11 wherein said
filter key is fixably or removably attached to said filter manifold.
13. The filter housing assembly of claim 11 wherein said
filter key fingers include slanted or angled faces on said
winged extensions.
14. The filter housing assembly of claim 13 wherein said
winged extensions have a diamond shaped cross-section.
15. A method for extracting a filter housing assembly from
a filter base comprising:
applying an axial insertion force to said filter housing
assembly already connected to said filter base towards
said filter base thereby inserting a filter key on said filter
housing assembly further into a slidable floating lock of
said filter base, said filter key having longitudinal sides
with a plurality of fingers or spaced protrusions on each
of said longitudinal sides;
releasing said slidable floating lock, such that said floating
lock moves relative to said filter key under a resilient
retraction force;

aligning said plurality of fingers on each longitudinal side


of said filter key between fingers or drive keys on said
floating lock; and
applying an axial extraction force to said filter housing
assembly to remove said filter housing assembly from
said filter base.
16. A refrigerator in combination with a filter assembly
comprising:
an outer cabinet;
a refrigeration compartment disposed within said outer
cabinet and having a rear wall, a pair of opposing side
walls, at least one door disposed opposite said rear wall,
a top and a bottom;
a freezer compartment disposed in said outer cabinet and
adjacent to said refrigeration compartment;
a water dispenser disposed in said door and in fluid communication with said filter assembly with automated
assembly for changing a sump and filter media from said
refrigerator;
said filter assembly comprising:
a filter housing for enclosing a filter media, said filter
housing having a body and a top portion for forming a
fluid-tight seal with said body, said filter housing top
portion including:
an ingress port;
an egress port; and
a filter key located attached to said filter housing and having a top surface, longitudinal sides, and lateral sides,
each of said filter key longitudinal sides including a
plurality of spaced protrusions or fingers extending laterally from said top surface.
17. The combination according to claim 16 including having said filter key formed integrally with said filter housing
top portion.
18. The filter housing assembly of claim 16 including having said filter key removably attached to said top portion.
19. The filter housing assembly of claim 16 including a
filter manifold attached to said filter housing top portion, said
filter manifold comprising an attachment structure for fixably
receiving said filter key.

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