FNA Group v. Jiangsu Longteng-Pengda - Complaint

Case 2:18-cv-00812-RFB-VCF Document 1 Filed 05/07/18 Page 1 of 24
1 NICHOLAS J. SANTORO (NBN 532)

JASON D. SMITH (NBN 9691)
2 SANTORO WHITMIRE
10100 W. Charleston Blvd., Suite 250
3
Las Vegas, Nevada 89135
4 Tel.: (702) 948-8771 / Fax: (702) 948-8773
Email: nsantoro@santoronevada.com
5 jsmith@santoronevada.com
6 STEVEN E. JEDLINSKI (pro hac vice forthcoming)

7 ANTHONY J. FUGA (pro hac vice forthcoming)
HOLLAND & KNIGHT LLP
8 131 S. Dearborn, 30th Fl.
Chicago, Illinois 60603
9 Tel.: (312) 263-3600 / Fax: (312) 578-6666
Email: steven.jedlinski@hklaw.com
10
anthony.fuga@hklaw.com
11
Attorneys for Plaintiff
12 FNA Group, Inc.
13 UNITED STATES DISTRICT COURT

14 DISTRICT OF NEVADA
15 FNA GROUP, INC. Civil Case No.: 2:18-cv-00812
16 COMPLAINT
Plaintiff,
17 JURY TRIAL DEMANDED
vs.
18
JIANGSU LONGTENG-PENGDA ELECTRIC
19 MECHANICAL CO., LTD.
20
Defendant.
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22
23
24
25
26
27
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1 Plaintiff FNA Group, Inc. (“FNA”) states the following as its Complaint against
2 Defendant Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd. (“LT”):
3 INTRODUCTION
4 1. FNA seeks relief from LT’s (i) breaches of contracts, (ii) trade secret violations,
5 (iii) patent infringement, (iv) tortious interference, (v) unfair competition, and (vi) unjust
6 enrichment. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
7 1338(a) because Counts IV through VII arise under federal law and relates to the Patent Act,
8 Lanham Act and the Defend Trade Secrets Act. This Court has supplemental jurisdiction over
9 the remaining contract and state law claims pursuant to 28 U.S.C. § 1367 because the claims
10 form part of the same case or controversy. This Court further has diversity jurisdiction over this
11 action pursuant to 28 U.S.C. § 1332 because there is complete diversity between FNA and LT
12 and the amount in controversy exceeds $75,000.
13 2. In 2012, FNA entered into multiple agreements with LT whereby FNA agreed to
14 license its technology and know-how information to LT solely for LT’s manufacturing of
15 products for FNA products. See Exhibits 1 and 2. After the relationship between the parties
16 broke down, LT breached those agreements by misappropriating and utilizing FNA trade secrets,
17 know-how and confidential information. Using this information, LT “developed” its own
18 competing products to compete with FNA.
19 3. LT has also infringed and continues to infringe FNA patents through LT’s
20 manufacturing activities regarding virtually identical products. LT has interfered with FNA’s
21 business and has been unjustly enriched by these actions. FNA brings this suit as a result.
22 PARTIES
23 4. Plaintiff FNA Group, Inc. is an Illinois corporation with its principal place of
24 business located at 7152 99th Street, Pleasant Prairie, Wisconsin.
25 5. In addition to its headquarters and manufacturing facility in Pleasant Prairie,
26 Plaintiff FNA Group, Inc. maintains a sales and marketing presence in Elk Grove Village,
27 Illinois, where it used to have its principal place of business.
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1 6. Defendant Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd. is a company

2 with its principal place of business located at No. 88 Zhao Min Industry Zone, Lu Si Gang Town,
3 Qing Dong City, Jiang Su Province, P.R. China.
4 7. The Chinese name for Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd. is
5 江苏龙腾鹏达机电有限公司.
6 8. Defendant Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd is also known
7 as Jiang Su Long Term Products Co. Ltd. Upon information and belief, the latter name was
8 created by the company based on the similar meaning between “Long Term” in English and
9 “Longteng” in Chinese.
10 JURISDICTION AND VENUE
11 9. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
12 1338(a) because Counts IV through VII arise under federal law and relates to the Patent Act,
13 Lanham Act and the Defend Trade Secrets Act. This Court has supplemental jurisdiction over
14 the remaining contract and state law claims pursuant to 28 U.S.C. § 1367 because the claims
15 form part of the same case or controversy.
16 10. This Court further has diversity jurisdiction over this action pursuant to 28 U.S.C.
17 § 1332 because there is complete diversity between FNA and LT and the amount in controversy
18 exceeds $75,000.
19 11. This Court has personal jurisdiction over LT because LT has, directly or through
20 intermediaries (e.g. distributors, retailers and others) committed acts within Nevada, and/or LT
21 maintains minimum contacts with the state of Nevada such that the exercise of jurisdiction would
22 not offend traditional notions of fair play and substantial justice. Upon information and belief,
23 representatives of LT have attended or are attending the National Hardware Show in Las Vegas,
24 Nevada as an exhibitor of household pressure washers, pumps and related products. In doing so,
25 LT is believed to be offering products that either infringe FNA’s patents or improperly use
26 FNA’s confidential information and trade secrets.
27
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1 12. If LT contends that it cannot be sued in the forum state and refuses to identify any
2 other state where suit is possible, then the federal court is entitled to use Rule 4(k)(2) against it.
3 13. Alternatively, to the extent the above facts do not establish personal jurisdiction
4 over LT, this Court has jurisdiction over LT pursuant to Rule 4(k)(2) of the Federal Rules of
5 Civil Procedure: (i) FNA’s claims arise, in part, under federal law; (ii) LT has sufficient contacts
6 with the United States as a whole, in part, because LT works as a supplier from China and
7 imports its products for sale in the United States and representatives of LT attend U.S. based
8 trade shows; and (iii) exercising jurisdiction over LT is consistent with due process.
9 14. Venue is proper in this District pursuant to 28 U.S.C. § 1391 (b) and (c), and §
10 1400.
11 FACTUAL BACKGROUND
12 FNA is an Industry Leader in Pressure Washers and Related Components
13 15. FNA is a privately held company that develops, manufacturers and markets
14 commercial and industrial pressure washers, pressure washer pumps, high pressure hoses, as well
15 as accessories and replacement parts for those units.
16 16. FNA’s products are sold in major home-improvement retail chains across the
17 United States.
18 17. FNA is a recognized industry leader in the pressure washer market and has
19 received numerous awards for its work in the field of pressure washers.
20 18. FNA has distinguished itself from competitors by, for example, its innovative
21 proprietary product lines and the attention that FNA devotes to ensuring consistently high-quality
22 products. FNA has numerous patents around the world covering many of these products.
23 19. The market for FNA’s products is competitive. FNA competes in the marketplace
24 on the basis of, in part, the innovative nature of its products, the product features and the precise
25 care FNA takes in the manufacture and quality control of its products. There are other
26 companies developing and selling their own line of products, competing for the same customers
27 and market share that FNA services.
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1 20. Additionally, FNA’s success is and has been dependent upon its ability to protect
2 its confidential information and trade secrets, including, by way of example, its product design,
3 its product testing specifications and results, development specifications, manufacturing process
4 and modifications, assembly techniques, efficiency enhancements, design and manufacturing
5 processes, manufacturing specifications, quality control techniques, product performance
6 information, business strategies, forecasting information, supply chain structure, pricing, margin
7 analysis, customer information (current and prospective), and sales and marketing plans.
8 21. FNA has expended significant amount of money to research, design and develop
9 products and systems and to educate, train and familiarize employees and contractors (including
10 manufacturers) in the proper development, design, manufacturing and sales of its products.
11 22. If FNA’s confidential information and/or the trade secrets referenced in the
12 preceding paragraphs were to become available to a competitor, FNA’s competitive advantage
13 and substantial investment in its design, engineering, and manufacturing technology over the last
14 few decades would be irreparably harmed or destroyed.
15 23. FNA takes extensive precautions to protect its confidential information and trade
16 secrets. All FNA employees are obligated to use confidential information and trade secrets only
17 in connection with their employment at FNA. All FNA employees have a duty not to disclose
18 the confidential information and trade secrets. FNA maintains a locked door policy, requiring all
19 visitors to sign into the building, limiting entry of visitors to certain locations, and requiring
20 visitors to be accompanied by a FNA employee when touring the FNA facility. Not all
21 employees have access to FNA’s confidential information and trade secrets. Instead, the
22 company’s confidential information is disseminated on a “need to know basis.” FNA’s computer
23 systems are password protected, further limiting access to confidential information.
24 24. FNA requires third parties enter into non-disclosure agreements with FNA when
25 the relationship could involve the exchange of confidential information and trade secrets of FNA.
26
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1 FNA’s Relationship with LT
2 25. While FNA manufactures many of its products in the United States, given its
3 range of products, FNA outsources some of its manufacturing to China.
4 26. LT was one of FNA’s manufacturers.
5 27. Upon information and belief, LT was formed in China in 2011 as a limited
6 company specializing in producing household pressure washers, gasoline pumps and related
7 products.
8 28. In 2012, FNA entered into agreements with LT whereby FNA agreed to license
9 certain technology and know-how information to LT for LT’s manufacture and service of pumps
10 and other related licensed products (the “Products”).
11 29. The agreements between the Parties include: (1) a Nondisclosure, Noncompetition
12 and Nonsolicitation Agreement (the “NDA”) (attached as Exhibit 1), and (2) a Technology and
13 Know-how License Contract (the “License Contract”) (attached as Exhibit 2).
14 30. Upon execution of, and reliance on the NDA and License Contract, FNA provided
15 various items of confidential information, know-how and trade secrets to LT. In the absence of
16 the agreements, FNA would never have provided its confidential information, know-how or trade
17 secrets to LT.
18 31. FNA provided LT with information and data concerning its products and/or
19 services, including, by way of example, formulas, designs, drawings, pricing and costing,
20 marketing plans, sketches, models, product configurations, design or performance specifications
21 and proprietary information relating to the manufacture, assembly, use, sale, consumer feedback,
22 market research, and marketing or other disposition of FNA licensed products.
23 32. FNA and LT established and maintained a good working relationship for years.
24 During those years, LT manufactured over 30 variety of pumps for FNA including the following:
25 FNA No. Description

26 510001 PUMP, 2400@2.0 P/BOOST LONG EXT. AL HEAD
27
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1 520002 PUMP, 3100@2.4 HORIZ-AXIAL P/BOOST BRASS

2 530006 PUMP, C45 SERIES, HORZ TRIPLEX, 13X13
3 530008 C31 SERIES PUMP, 3400PSI @ 2.3 GPM HORIZ
4
5 33. Eventually, however, a breakdown in the relationship caused FNA to stop

6 utilizing LT to manufacture its Products in 2016.
7 LT’s Improper Filing of Chinese Patents
8 34. Unbeknownst to FNA, during FNA’s business relationship with LT, a number of
9 Chinese patents regarding FNA’s Products were obtained by LT.
10 35. Pursuant to Section 4.4 of the Licensing Contract, LT was not allowed to apply
11 for those patents. Instead, those inventions and any intellectual property rights associated with
12 the inventions belong to—and only to—FNA.
13 36. In 2017, LT filed a lawsuit in China against FNA’s new Chinese manufacturer,
14 Suzhou DanNio for patent infringement based upon one of those improperly obtained patents.
15 37. After FNA notified LT that the patent filings were improper under the parties’
16 agreements, LT withdrew its improperly obtained Chinese patents regarding FNA technology
17 thereby abandoning any rights and dropped the lawsuit.
18 LT’s Recent Inappropriate Activities
19 38. Upon information and belief, LT has recently been manufacturing Products based
20 on FNA’s confidential information, know-how and trade secrets and selling and shipping them to
21 companies based in the United States.
22 39. In doing so, LT has wrongfully misappropriated FNA confidential information,
23 know-how and trade secrets and provided such information to third parties in violation of the
24 Parties’ agreements and Illinois and federal law.
25 40. Upon information and belief, LT has been utilizing FNA trade secrets, know-how
26 and confidential information to manufacture, offer to sell, and sell Products virtually identical to
27 FNA’s directly to third parties.
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1 41. Specifically, on its website LT is currently offering products that LT previously

2 manufactured for FNA under the agreements. Attached as Exhibit 3 is a compilation exhibit of a
3 screenshot of LT’s product offerings on its website, along with specifics regarding each product.
4 42. LT’s product, LT901/LT902 (vertical axial pump) is actually FNA’s pump model
5 number 510001. FNA provided the confidential engineering drawings and specifications for the
6 pump during the Parties’ relationship.
7 43. In addition, FNA has patent protection on the ornamental design of the 510001
8 pump including U.S. Patent No. D691,638.
9 LT901/LT902 Product FNA 510001 Pump ‘638 Patent Figure
10
11
12
13
14
15
16 44. LT’s product, LT921/LT922 (horizontal axial pump) is actually FNA’s pump
17 model number 520002. FNA provided the confidential engineering drawings and specifications
18 for the pump during the Parties’ relationship.
19 45. In addition, FNA has patent protection on this ornamental design of the 520002
22
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25
26
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1 46. LT’s product, LT931/LT932 (forged brass pump head), is actually FNA’s pump
2 model number 530008. FNA provided the confidential engineering drawings and specifications
3 for the pump during the Parties’ relationship.
7
10
11
12
13
14 48. LT’s product, LT951/LT952 (forged brass pump head) is actually FNA’s pump
15 model 530006. FNA provided the confidential engineering drawings and specifications for the
16 pump during the Parties’ relationship.
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23
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25
26
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1 50. Upon information and belief, LT has used FNA’s trade secrets and confidential
2 information to manufacture axial pumps virtually identical to those of FNA for FNA’s direct
3 competitors, including at least Karcher North America and Nilfisk Pressure Pro, Inc.
4 51. For example, upon information and belief, LT manufacturers and imports into the
5 United States pumps for Nilfisk Pressure Pro’s Dirt Laser pressure washers. These pressure
6 washers are offered for sale on Power Equipment Direct’s website.
7 52. Upon information and belief, Nilfisk Pressure Pro’s Dirt Laser model PP3425H
8 incorporates a knock-off of FNA’s pump 530008 – shown below in paragraph 53. FNA
9 provided the confidential engineering drawings and specifications for this pump during the
10 Parties’ relationship.
11 53. In addition, FNA has patent protection on the ornamental design of the 530008
13 LT Product FNA 530008 Pump ‘211 Patent Figure
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15
16
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21 54. Upon information and belief, Nilfisk Pressure Pro’s Dirt Laser models PP3225H
22 and PP3225K also incorporate a knock-off of FNA’s patented pump 520002 – shown below.
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1 LT Product FNA 520002 Pump ‘762 Patent Figure

2
8 55. Upon information and belief, LT manufactures the LT921/LT922 (horizontal
9 axial pump) and imports those pumps into the United States to Karcher North America.
10 56. Upon information and belief, LT manufactures the LT921/LT922 (horizontal
11 axial pump) and imports the pump into the United States to Nilfisk Pressure Pro LLC through
12 agent companies authorized to act on LT’s behalf.
13 57. Pursuant to the Parties’ agreements, LT is not allowed to sell, transfer, license, or
14 otherwise provide any of FNA’s technology and know-how to any third person in any manner
15 whatsoever.
16 58. Pursuant to the Parties’ agreements, LT should have returned to FNA all tangible
17 forms of the confidential information and technology and know-how that it received by FNA
18 once it stopped manufacturing products for the company.
19 59. LT has clearly not returned FNA’s confidential information and technology
20 know-how, but has instead been using it and indirectly disclosing FNA’s protected information
21 and know-how to third parties.
22 60. Upon information and belief, LT is providing pumps currently used on Nilfisk
23 Pressure Pro units.
24 COUNT I
Breach of the Non-Disclosure Agreement
25 (Illinois Law)
26 61. FNA incorporates and restates paragraphs 1 through 60 as if fully set forth herein.
27
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1 62. The Parties entered into the NDA on March 27, 2012 in relation to the License
2 Contract, in order to facilitate the licensing of FNA trade secrets and confidential information to
3 LT for LT’s manufacture of FNA Products. A breach of the NDA is governed by Illinois law –
4 the law which the parties agreed the NDA would be governed.
5 63. The NDA is a valid and enforceable contract.
6 64. Under the NDA, FNA is the Licensor; LT is the Licensee and Restricted Party.
7 65. As signatories to the NDA, FNA and LT have an obligation to comply with the
8 terms of the NDA for the duration of the agreement’s term.
9 66. The term of the NDA that applies to its Confidentiality provision (“Article 5”) is
10 ten years from the Effective Date of March 27, 2012.
11 67. FNA has complied with the NDA.
12 68. Pursuant to Article 5 of the NDA, LT “acknowledges and agrees that … [LT] has
13 been given access and exposure to trade secrets and confidential information … regarding [FNA]
14 or its Affiliates and their respective businesses, equipment, products and employees
15 (“Confidential Information”), including but not limited to…”
16 69. Pursuant to Article 5 of the NDA, that “Confidential Information” includes
17 research, technology, intellectual property, technical information, methods, ideas, and “all other
18 information [FNA] tries to keep confidential and that has commercial value or is of such a nature
19 that its unauthorized disclosure would be detrimental to Licensor’s interest.”
20 70. Pursuant to Article 5(c), LT agreed :
21 (i) to receive and keep all Confidential Information in confidence and
not disclose any Confidential Information to any Person (including
22 the Restricted Party or its Affiliates) …
23 (ii) not to use or permit the use of any Confidential Information
without first obtaining Licensor’s written consent to such use …
24
25 (iii) except as required by law or directed by Licensor, not [to] disclose

or distribute or permit the disclosure or distribution of any
26 Confidential Information, directly or indirectly, to any other Person
(including any Restricted Party or any of its Affiliates); and
27
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1 (iv) to take or cause to be taken all other necessary and appropriate

actions to preserve the confidentiality of the Confidential
2 Information.
3 71. LT breached each of the sections of Article 5 of the NDA by:
4 (a) failing to keep Confidential Information in confidence;
5 (b) using or permitting the use of Confidential Information without
first obtaining FNA’s written consent to do so; and
6
(c) disclosing or distributing Confidential Information to third parties.
7
8 72. Pursuant to the NDA, LT is not to use or permit to be used FNA’s confidential
9 information to any third person in any manner whatsoever.
10 73. Upon information and belief, LT is presenting at the 2018 National Hardware
11 Show taking place in Las Vegas, Nevada from May 8, 2018 to May 10, 2018. According to the
12 show’s website, LT will be at booth 1011 and will be offering its high pressure washers, which
13 include a pump.
14 74. The National Hardware Show allows thousands of exhibitors representing 15
15 major product categories to show off their products and connect with consumers and businesses.
16 75. 86% of attendees at the National Hardware Show plan on purchasing and sourcing
17 new products when they attend.
18 76. As a result of LT’s breaches, FNA has been harmed, including by a loss of
19 customers, orders, and market share; price erosion of its Products and patents; a loss of business
20 opportunities; and a loss of goodwill and damage to its reputation.
21 77. Article 6 of the NDA states:
22 The Restricted Party acknowledges and agrees that any breach of the
restrictive covenants set forth in Articles 3, 4 or 5 hereof will result in
23 irreparable damage to Licensor … for which there will be no adequate
remedy at law, and the Restricted Party consents to equitable relief …
24
[and] other rights and remedies includ[ing], without limitations, monetary
25 damages and payment of all costs incurred by the Company in
enforcement against the Restricted Party of any provision of this
26 Agreement at law or in equity, including reasonable attorneys’ fees.
27
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1 78. LT has acknowledged that its breach of Article 5 has resulted in irreparable harm
2 to FNA.
3 COUNT II
Breach of the Technology and Know-How License Contract
4 (Illinois Law)
6 80. The Parties entered into the License Contract on March 27, 2012 so that FNA
7 could grant to LT a non-exclusive, non-transferable, non-sublicensable and royalty license to use
8 FNA’s technology and know-how “solely for (a) manufacturing Licensed Products in the
9 Territory and for (b) providing after-sale and other ancillary services in relation to any Licensed
10 Product.” A breach of the License Contract is governed by Illinois law – the law which the
11 parties agreed the NDA would be governed.
12 81. The License Contract is a valid and enforceable contract.
13 82. Under the License Contract, FNA is the Licensor; LT is the Licensee.
14 83. The License Contract incorporates the NDA and must be interpreted consistently
15 with that agreement.
16 84. As signatories to the License Contract, FNA and LT have an obligation to comply
17 with the terms of the License Contract.
18 85. FNA has complied with the License Contract.
19 86. By means of the License Contract, FNA granted LT a license to use “certain
20 technology and know-how … for the manufacture of Licensed Products (as defined below) and
21 the provision of after-sale service[.]”
22 87. Pursuant to Article 1.7, “Technology and Know-how” was defined as:
23 (a) with respect to “Technology”, the proprietary technology (whether or

not patented, including formula, method, process, technique, invention and
24 industrial design) in relation to the manufacture, assembly, use, sale,
marketing or other disposition of any Licensed Product, and (b) with
25
respect to “Know-how”, technical knowledge, experience, skills,
26 commercial secrets, special techniques (including product quality control)
and proprietary information in relation to the manufacture, assembly, use,
27 sale, marketing or other disposition of any Licensed Product, and (c) all
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1 Technical Improvements thereto; in each case, which will be provided or

furnished from time to time by or on behalf of the Licensor to the Licensee
2 or any of its Affiliates or any Guarantor pursuant to this Contract or which
has been provided or furnished to the Licensee and/or any of its Affiliate
3
or any Guarantor prior to the date hereof.
4
88. The License Contract was terminated between the parties when FNA stopped
5
utilizing LT as its manufacturer in China.
6
7 89. However, Section 9.3 of the License Contract provides:
8 Effect of Termination. In the event this Contract expires or is terminated

pursuant to this Article 9, the Licensee covenants that it
9
(a) shall not sell, transfer, license, dispose of, or otherwise provide all
10 or any part of the Technology and Know-how to any third Person
(or any Affiliate of Licensee), in any manner whatsoever;
11
(b) shall immediately cease, or cause to be [ceased], the manufacture
12 of the Licensed Products and stop using the Technology and
13 Know-how;
14 (c) shall cease (or cause to be ceased) the using or disclosing any
Confidential Information; and
15
(d) shall immediately return (or caused to be returned) to Licensor all
16 tangible forms of the Confidential Information and the Technology
and Know-how (including, without limitation, the Technical
17 Documentation), whether in written or other form, and all copies
thereof.
18
19 90. LT breached Section 9.3 of the License Contract by:
20 (a) selling, transferring, licensing, disposing of, or otherwise providing

parts of FNA’s Technology and Know-how to third persons;
21
(b) continuing to manufacture and use the Licensed Products and
22 FNA’s Technology and Know-how;
23
(c) continuing to use or disclose Confidential Information; and
24
(d) not returning or causing to be returned to FNA all tangible forms
25 of the Confidential Information and Technology Know-how
provided to LT in written or other form.
26
27
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1 91. Pursuant to the License Contract, LT is not allowed to sell, transfer, license, or
2 otherwise provide any of FNA’s technology and know-how to any third person in any manner
3 whatsoever.
4 92. Upon information and belief, LT is presenting at the 2018 National Hardware
5 Show taking place in Las Vegas, Nevada from May 8, 2018 to May 10, 2018. According to the
6 show’s website, LT will be at booth 1011 and will be offering its high pressure washers, which
7 include a pump.
8 93. The National Hardware Show allows thousands of exhibitors representing 15
9 major product categories to show off their products and connect with consumers and businesses.
10 94. 86% of attendees at the National Hardware Show plan on purchasing and sourcing
11 new products when they attend.
12 95. As a result of LT’s breaches, FNA has been harmed, including by a loss of
13 customers, orders, and market share; price erosion of its Products and patents; a loss of business
14 opportunities; and a loss of goodwill and damage to reputation.
15
COUNT III
16 Violation of the Nevada Deceptive Trade Practices statute, NRS 598.0915
18 97. In the course of its business, LT has misrepresented and passed off FNA Products,
19 designs, and patents as its own.
20 98. LT intentionally, willfully and unlawfully simulated and misappropriated FNA
21 pumps and patents by advertising, promoting, and selling its virtually identical products.
22 99. LT’s actions have caused confusion or misunderstanding regarding the source of,
23 and FNA’s affiliation with, LT’s products.
24 100. LT’s acts have unfairly deceived the public, and will continue to cause confusion
25 and mistake as to the proper origin of LT’s products in violation of the Nevada Deceptive Trade
26 Practices statute, NRS 598.0915.
27
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1 101. LT’s actions constitute oppression, fraud and malice in that LT has intentionally
2 engaged in activities designed to confuse the public and divert sales to itself that would - and
3 should - have been enjoyed by FNA.
4 102. As a result of LT’s actions, FNA has suffered and will suffer damages and
5 irreparable injury to its property and goodwill, including destruction of the business value of its
6 proprietary pumps and patents, and LT will be unjustly enriched thereby in such sum as may be
7 proved at the time of trial.
8
COUNT IV
9 False Designation of Origin and False Descriptions, 15 U.S. Code § 1125
11 104. In the course of its business, LT has misrepresented and passed off FNA Products,
12 designs, and patents as its own.
13 105. LT intentionally, willfully and unlawfully simulated and misappropriated FNA
14 pumps and patents by advertising, promoting, and selling its virtually identical products.
15 106. LT’s actions have caused confusion or misunderstanding regarding the source of,
16 and FNA’s affiliation with, LT’s products.
17 107. LT’s actions are likely to cause confusion, mistake, and to deceive as to the
18 affiliation, connection, or association of FNA with the origin, sponsorship or approval of LT’s
19 goods and commercial activities, in violation of 15 U.S.C. §1125(a).
20 108. LT’s actions have caused and continue to cause FNA irreparable harm for which
21 there is no adequate remedy at law. Such irreparable harm will continue until LT’s unlawful
22 activities are enjoined.
23 COUNT V
Misappropriation of Trade Secrets in Violation of the Defend Trade Secrets Act,
24 18 U.S.C. § 1836, et seq.
26 110. FNA’s confidential information and technology and know-how (including the
27 designs, technology, engineering and research pertaining to its Products) constitute a trade secret.
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1 111. FNA entered into agreements with confidentiality provisions with LT in order to
2 protect its trade secrets from disclosure or use by LT or any third parties without FNA’s written
3 consent.
4 112. LT knew or had reason to know that FNA’s trade secrets were trade secrets based
5 on the agreements between the Parties, which clearly delineated the proprietary and confidential
6 nature of the information and technology and know-how.
7 113. FNA’s trade secrets derive their value from not being generally known and are
8 not readily ascertainable through proper means.
9 114. Pursuant to the agreements between the Parties, LT obtained knowledge of FNA
10 trade secrets for manufacturing purposes, and has disclosed and used those trade secrets without
11 FNA’s implied or express consent.
12 115. Upon information and belief, LT has manufactured, offered to sell and sold
13 products containing stolen FNA trade secrets to at least two different companies in the United
14 States.
15 116. The FNA trade secrets misappropriated by LT relate to products used in, or
16 intended for use in, interstate or foreign commerce.
17 117. LT knows or has reason to know that its maintenance and sale of FNA trade
18 secrets occurred by improper means.
19 118. LT knows or has reason to know that its disclosure and/or use of FNA trade
20 secrets has been done without the implied or express consent of FNA.
21 119. Therefore, LT willfully and maliciously misappropriated FNA trade secrets in
22 violation of the Defend Trade Secrets Act, 18 U.S.C. § 1836, et seq.
23 120. FNA has been harmed by LT’s use and disclosure of its trade secrets.
24
25
26
27
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1 COUNT VI
Patent Infringement, U.S. Patent No. D699,762
2
4 122. On February 18, 2014, United States Patent No. D699,762 (“the ‘762 patent”)
5 entitled “Pump” duly and legal issued. A true and correct copy of the ‘762 patent is attached
6 hereto as Exhibit 4.
7 123. FNA owns all rights, title, and interest in and to the ‘762 patent and has the right
8 to sue and recover for past, present, and future infringement.
9 124. LT has manufactured, used, imported, offered for sale, or sold pumps or pressures
10 washers including pumps that directly or indirectly infringe, either literally or under the doctrine
11 of equivalents, at least the claim of the ‘762 patent in violation of 35 U.S.C. § 271.
12 125. For example, LT’s LT921/LT922 horizontal axial pump and LT’s Terminator
13 branded pump on Nilfisk Pressure Pro’s Dirt Laser models PP3225H and PP3225K infringe the
14 ‘762 patent inasmuch as it has an overall visual appearance that, to an ordinary observer
15 conversant in the prior art, is substantially the same as the overall visual appearance of the design
16 claimed in the ‘762 patent.
17 LT Pump on Nilfisk PW LT Pump FNA Patent Figure
18
19
20
21
22
23
24 126. LT has engaged and is engaging in willful and deliberate infringement of the ‘762
25 patent. LT has been aware or the application that resulted in the ‘762 patent since its filing. One
26 of the listed inventors of the ‘762 patent is Wang Xu Dong – an employee of LT. Such willful
27 and deliberate infringement justifies an increase of three times the damages to be assessed
28 - 18 -
1 pursuant to 35 U.S.C. § 284 and further qualifies this action as an exceptional case supporting an
2 award of reasonable attorneys’ fees pursuant to 35 U.S.C. § 285.
3 127. Upon information and belief, LT will continue to infringe FNA’s rights in the
4 ‘762 patent unless restrained by this Court.
5 128. FNA has suffered and continues to suffer irreparable injury, for which it has no
6 adequate remedy at law.
7 129. As a result of LT’s infringement of the ‘762 patent, FNA has suffered damages in
8 an amount to be determined at trial, which includes disgorgement of LT’s total profits, lost
9 profits, but in no event less than a reasonable royalty for the use made of the invention by LT,
10 together with interest and costs as fixed by the Court.
11
COUNT VII
12 Patent Infringement, U.S. Patent No. D700,211
14 131. On October 22, 2013, United States Patent No. D700,211 (“the ‘211 patent”)
15 entitled “Pump” duly and legal issued. A true and correct copy of the ‘211 patent is attached
16 hereto as Exhibit 5.
17 132. FNA owns all rights, title, and interest in and to the ‘211 patent and has the right
18 to sue and recover for past, present, and future infringement.
19 133. LT has manufactured, used, imported, offered for sale, or sold pumps or pressures
20 washers including pumps that directly or indirectly infringe, either literally or under the doctrine
21 of equivalents, at least the claim of the ‘211 patent in violation of 35 U.S.C. § 271.
22 134. For example, LT’s Terminator branded pump on Nilfisk Pressure Pro’s Dirt Laser
23 model PP3425H infringes the ‘211 patent inasmuch as it has an overall visual appearance that, to
24 an ordinary observer conversant in the prior art, is substantially the same as the overall visual
25 appearance of the design claimed in the ‘211 patent.
26
27
28 - 19 -
1 LT Pump on Nilfisk PW ‘211 Patent Figure

2
10 135. LT has engaged and is engaging in willful and deliberate infringement of the ‘211
11 patent. LT has been aware or the application that resulted in the ‘211 patent since its filing. One
12 of the listed inventors of the ‘211 patent is Wang Xu Dong – an employee of LT. Such willful
13 and deliberate infringement justifies an increase of three times the damages to be assessed
14 pursuant to 35 U.S.C. § 284 and further qualifies this action as an exceptional case supporting an
15 award of reasonable attorneys’ fees pursuant to 35 U.S.C. § 285.
16 136. Upon information and belief, LT will continue to infringe FNA’s rights in the
17 ‘211 patent unless restrained by this Court.
18 137. FNA has suffered and continues to suffer irreparable injury, for which it has no
19 adequate remedy at law.
20 138. As a result of LT’s infringement of the ‘211 patent, FNA has suffered damages in
21 an amount to be determined at trial, which includes disgorgement of LT’s total profits, lost
22 profits, but in no event less than a reasonable royalty for the use made of the invention by LT,
23 together with interest and costs as fixed by the Court.
24 COUNT VIII
25 Tortious Interference with Prospective Economic Advantage
27
28 - 20 -
1 140. FNA had a reasonable expectation of entering into valid business relationships
2 with Karcher, Pressure-Pro or any other companies in need of its Products or technology.
3 141. LT knew of FNA’s expectancy when it bypassed FNA and sold virtually identical
4 products based on FNA technology directly to companies like Karcher and Nilfisk Pressure-Pro.
5 142. LT’s interference was purposeful and prevented FNA’s legitimate expectancy
6 from ripening into a valid business relationship with these companies.
7 143. As such, LT’s misappropriation and use of FNA confidential information and
8 trade secrets has interfered with FNA’s prospective economic advantage and has harmed FNA.
9
COUNT IX
10 Common Law Unjust Enrichment
12 145. LT has intentionally engaged in wrongful activities designed to divert sales to
13 itself that would have otherwise been enjoyed by FNA.
14 146. In particular, LT has been unjustly enriched by its misappropriation of FNA
15 confidential information and trade secrets and by its infringement of FNA patents.
16 147. Any profits or benefits incurred by LT as a result of its actions rightfully belong
17 to FNA, the legal owner of FNA trade secrets and patents.
18
COUNT X
19 Common Law Unfair Competition
21 149. LT, by careful and considered planning, intentionally promoted its products to
22 consumers so as to confuse and deceive consumers and obtain the acceptance of LT’s goods
23 based on the merit, reputation and goodwill of FNA and its high-quality products.
24 150. LT’s actions constitute oppression, fraud and malice in that it has intentionally
25 engaged in activities designed to confuse the public and divert sales to itself that would have
26 otherwise been enjoyed by FNA.
27
28 - 21 -
1 151. LT misappropriated and unlawfully exploited the valuable property rights and
2 goodwill of FNA through its use of confusingly similar products and pumps.
3 152. As a result of LT’s actions, FNA has suffered and will suffer damages and
4 irreparable injury to its property and goodwill, including destruction of the business value of its
5 Products, and LT will be unjustly enriched thereby.
6 PRAYER FOR RELIEF
7 WHEREFORE, Plaintiff FNA Group, Inc. respectfully requests the following relief:
8 i. Enter Judgment in favor of FNA Group, Inc. and against Defendant Jiangsu
9 Longteng-Pengda Electric Mechanical Co., Ltd. as to Counts I-X based on

10
LT’s: (a) breaches of the NDA and License Contract, (b) trade secret
11
violations, (c) patent infringement, (d) tortious interference with FNA’s
12
economic advantage and business relations, (e) use of unfair competition
13
methods, and (f) unjust enrichment;
14
15 ii. Award actual, consequential, and compensatory damages suffered by FNA,
16 including but not limited to the total profits from LT’s infringing activities
17 pursuant to 35 U.S.C. § 289, by reason of LT’s infringement of the U.S.
18
Patent Nos. D699,762 and D700,211;
19
iii. Award exemplary damages;
20
iv. Award enhanced damages;
21
22 v. Declare this case exceptional under 35 U.S.C. § 285;
23 vi. Award attorneys’ fees and costs;
24 vii. Award pre-judgment and post-judgment interest at the highest rates allowed
25 by law;
26
27
28 - 22 -
1 viii. Enter an order preliminarily and permanently enjoining LT and all other
2 persons or entities acting in concert with LT from using and disclosing FNA’s
3
confidential information, trade secrets, technology, and from infringing the
4
U.S. Patent Nos. D699,762 and D700,211;
5
ix. Enter an order requiring the impounding and destruction of all products
6
infringing U.S. Patent Nos. D699,762 and D700,211; and
7
8 x. Grant any such other and further relief as it deems proper and just.
9 JURY DEMAND
10 FNA Group, Inc. demands a trial by jury on all issues so triable.
11 Dated: May 7, 2018
/s/ Jason D. Smith
13 JASON D. SMITH (NBN 9691)
SANTORO WHITMIRE
14 10100 W. Charleston Blvd., Suite 250
15 Tel.: (702) 948-8771 / Fax: (702) 948-8773
E-mail: nsantoro@santoronevada.com
17
Steven E. Jedlinski (pro hac vice forthcoming)
18 Anthony J. Fuga (pro hac vice forthcoming)
20 Tel.: (312) 263-3600 / Fax: (312) 578-6666
21 Email: steven.jedlinski@hklaw.com
22
Attorneys for Plaintiff FNA Group, Inc.
23
24
25
26
27
28 - 23 -
Case 2:18-cv-00812-RFB-VCF Document 1-1 Filed 05/07/18 Page 1 of 1

JASON D. SMITH (NBN 9691)
2 SANTORO WHITMIRE
3 10100 W. Charleston Blvd., Suite 250
4 Tel.: (702) 948-8771 / Fax: (702) 948-8773
Email: nsantoro@santoronevada.com
6
STEVEN E. JEDLINSKI (pro hac vice forthcoming)
7 ANTHONY J. FUGA (pro hac vice forthcoming)
9 Tel.: (312) 263-3600 / Fax: (312) 578-6666
E-Mail: steven.jedlinski@hklaw.com
10
11
Attorneys for Plaintiff
12 FNA Group, Inc.
13 UNITED STATES DISTRICT COURT
14
DISTRICT OF NEVADA
15
FNA GROUP, INC., Case No.: 2:18-cv-00812
16
Plaintiff,
17
18 v. INDEX OF EXHIBITS TO COMPLAINT
19 JIANGSU LONGTENG-PENGDA ELECTRIC

MECHANICAL CO., LTD.,
20
Defendants.
21
22 Exhibit 1: Nondisclosure Agreement

23 Exhibit 2: Technology and Know-How License Contract
24 Exhibit 3: Screenshots of LT Website
25 Exhibit 4: U.S. Design Patent US D699, 762 S
26 Exhibit 5: U.S. Design Patent US D700,211 S
27
28
EXHIBIT 1
Nondisclosure Agreement
'
NONDISCLOSURE, NONCOMPETITION AND

NONSOLICITATION AGREEMENT
THIS NONDISCLOSURE, NONCOMPETITION AND NONSOLICITATION

AGREEMENT (the "Agreement") is made and entered into this 27 day of March, 2012
("Effective Date"), by and among:
(1) liang Su Long Term Products Co .. Ltd. located No.88 Zhao Min industry
zone. Lu Si Gang town. Oing Dong citv. liang Su province. P.R.China ("Licensee");
(2) FNA GROUP, INC., a company duly organized and existing under the laws of
the State of [Illinois], the United States of America ("USA") with its principal address at
1825 Greenleaf Ave., Elk Grove Village, IL 60007, USA ("Licensor").
(Licensee is hereinafter referred to collectively as "Restricted Parties" and individually

a "Restricted Party". Restricted Parties and Licensor are hereinafter referred to collectively as
the "Parties" and individually as a "Party".)
RECITALS
WHEREAS, in order to induce Licensor to enter into the Technology and Know-how
License Contract, dated as of March 27. 2012, by and among Restricted Parties and Licensor, as
the same may be supplemented and amended from time to time in accordance with the terms
thereof (the "License Contract"), the Restricted Party has agreed to execute and deliver to
Licensor this Agreement;
WHEREAS, the Restricted Party will benefit, directly or indirectly, from the
consummation of the transactions contemplated by the License Contract;
WHEREAS, in relation to the licensing arrangement contemplated by the License

Contract, Restricted Party and Licensor have entered into a certain Confidentiality Agreement
dated March 27, 2012 (the "Confidentiality Agreement");
WHEREAS, each capitalized term defined in the License Contract and not otherwise
defined herein shall have the meaning ascribed thereto in the License Contract when used herein;
NOW THEREFORE, for good and valuable consideration, including the inducement of
Licensor to consummate the transactions contemplated by the License Contract, and other
consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto
agree as follows:
1. Defined Terms. For purposes of this Agreement, in addition to terms defined

elsewhere in this Agreement, the following terms will have the following meanings when used
with initial capital letters:
"Business" means the manufacture, assembly, use, sale, marketing, after-sale

service or other disposition of any Licensed Product, any related ancillary activities and
1
any other business Licensor may license (or co-operate with) the Licensee or consider
licensing (or co-operating with) the Licensee during the Term;
"Customer" means any customer of Licensor or any Person to whom or with

whom Licensor or any agent, distributor or independent sales representative of Licensor
(a) has provided or provides any Licensed Products prior to the termination or expiration
of the License Contract, (b) has actively pursued for Business purposes prior to the
termination or expiration of the License Contract, or (c) has otherwise engaged m
Business activities prior to the termination or expiration of the License Contract; and
"Territory" means any area throughout the world or, with respect to a Restricted
Party, the maximum geographical areas within which the obligations of Article 3 are
valid or permitted by applicable law in respect of the Restricted Party.
2. Term. The term of this Agreement shall be:
(a) as applicable to Article 3, from the Effective Date to a date which is the
longer of (I) three (3) years following the termination or expiration of the License
Contract and (ii) the maximum period legally permitted by applicable law following the
termination or expiration of the License Contract; and
(b) as applicable to Articles 4 and 5, from the Effective Date to a date which
is ten (I 0) year following the termination or expiration of the License Contract (the
"Term").
3. Noncompetition. During the Term (as applicable to this Article 3) the Restricted
Party shall not: '
(a) within the applicable Territory, directly or indirectly engage in any of the
Business activities, whether as an advisor, principal, owner, director, officer, agent,
employee, partner, consultant, investor, lender, stockholder, associate, or otherwise; or
(b) be the record or beneficial, direct or indirect, owner of any outstanding

capital stock or voting securities (or obligations or securities convertible into capital stock
or voting securities) of any Person which
(i) is engaged, directly or indirectly, in any business activities

encompassed by the Business (A) with respect to any Customer, or (B) within the
applicable Territory, or
(ii) within the applicable Territory, owns, directly or indirectly, any

interest in any other business which is engaged, directly or indirectly, in any
business activities encompassed by the Business.
4. Non-solicitation. During the Term (as applicable to this Article 4) the Restricted
Party shall not:
NONDISCLOSURE NONCOMPETITION AND jiangsulongterm prod®ts 2.doc
2
(a) directly or indirectly solicit, or attempt to persuade, any Customer or

supplier of Licensor to cease doing business with Licensor or to reduce the amount of
business it does with Licensor. The Restricted Party acknowledges and agrees that this
covenant is necessary to enable Licensor to maintain a stable Customer and supplier base
in order to remain in business, and that it would disrupt, damage, impair and interfere
with the Business if the Restricted Party were to engage in such solicitation.
(b) directly or indirectly solicit, or attempt to persuade, influence or induce, or

assist any other Person in so persuading or inducing, any employee of Licensor or any of
its Affiliates to leave the employ of Licensor or any of its Affiliates, or to accept any
other employment or position unless (in each case prior to any such inducement or
attempted inducement) such employee is no longer employed by Licensor or any of its
Affiliates or has given written notice of his intention to terminate employment with
Licensor or any of its Affiliates. The Restricted Party acknowledges and agrees that the
purpose of this covenant is to enable Licensor to maintain a stable workforce in order to
remain in business, and that it would disrupt, damage, impair and interfere with
Licensor's business if the Restricted Party were to engage in such solicitation.
5. Confidentiality.
(a) The Restricted Party acknowledges and agrees that prior to and during the
consummation of the transactions contemplated by the License Contract, the Restricted
Party has been given access and exposure to trade secrets and confidential information in
written, oral, ele.ctronic and other form regarding Licensor or its Affiliates and their
respective businesses, equipment, products and employees ("Confidential
Information"), including but not limited to:
(i) the identities of Licensor's or its Affiliates' Customers and key

accounts and potential customers, including, without limitation, the identity of
Customers and key accounts and potential customers, cultivated or maintained by
the Restricted Party prior to the termination or expiration of the License Contract
and the identities of contact persons at those Customers and key accounts and
potential customers;
(ii) the particular preferences, likes, dislikes and needs of those

Customers and key accounts and potential customers; and contact persons with
respect to product types, pricing, sales calls, timing, sales terms, rental terms,
lease terms, service plans, and other marketing terms and techniques;
(iii) the business methods, practices, strategies, forecasts, pricing, and

marketing techniques;
(iv) the identities of licensors, vendors, and other suppliers and the
identities of contact persons at such licensors, vendors, and other suppliers; ·
(v) the identities of key sales representatives and personnel and other
employees;
NONDISCLOSURE NONCOMPETITION AND jiangsulongterm prod®ts 2.doc
3
(vi) advertising and sales materials, research, technology, intellectual

property, training materials and techniques, computer software and related
materials;
(vii) technical information, including without limitation, analysis,

research, processes, computer programs, algorithms, methods, ideas, source codes
and object codes;
(viii) other facts and financial and other business information concerning
or relating to such Persons and their business, operations, financial condition,
results of operating and prospects;
(ix) the facts, information or data as defined in the term "Confidential

information" in Confidentiality Agr~ement, or in the term "Confidential
Information" in the License Contract; and
(x) all other information Licensor tries to keep confidential and that
has commercial value or is of such a nature that its unauthorized disclosure would
be detrimental to Licensor's interest.
(b) "Confidential Information" will not include information, which is

already in the public domain at the time of disclosure through no violation of any
confidentiality obligation, other than as a result of any direct or indirect action or inaction
by the Restricted Party and information, which is approved for public release by Licensor
or its Affiliates.
For the avoidance of doubt, information shall not be construed to be within one of
the above exceptions merely because it may be referred to or otherwise generally
included in disclosures of a broad nature or represents a technological advance or
improvement of any Confidential Information or because constituent elements or
combinations thereof fall within the above exception.
(c) During the Term (as applicable to this Article 5), the Restricted Party
agrees as follows:
(i) to receive and keep all Confidential Information in confidence and

not disclose any Confidential Information to any Person (including the Restricted
Party or any of its Affiliates), except to its respective officers or employees who
have a need to know such Confidential Information for the purposes of the
Business and use thereof, and who have been informed of its obligations under
this Agreement and have undertaken a similar written obligation to those ·
contained in this Agreement which extends to the benefit of and is enforceable by
Licensor;
(ii) not to use or permit the use of any Confidential Information

without first obtaining Licensor's written consent to such use except for the
Purposes of the Business and use thereof, or for any purpose detrimental to
Licensor or its Affiliates;
NONDISCLOSURE NONCOMPETITION AND jiangsulongterm prodi¢ts 2.doc
4
(iii) except as required by law or directed by Licensor, not disclose or

distribute or permit the disclosure or distribution of any Confidential Information,
directly or indirectly, to any other Person (including any Restricted Party or any
of its Affiliates); and
(iv) to take or cause to be taken all other necessary and appropriate

actions to preserve the confidentiality of the Confidential Information.
(d) All physical property and all notes, memoranda, files, records, writings,
documents and other materials of any and every nature, written or electronic, which the
Restricted Party has or will prepare, develop or receive in the course of its association
with Licensor or its Affiliates and which relate to or are useful in any manner to the
Business or any other business now or hereafter conducted by Licensor or its Affiliates,
are and will remain the sole and exclusive property of such Persons, the Restricted Party
will
(i) not sell, transfer, license, or remove from such Person's premises,
any such physical property, the original, "soft copy" or any reproduction of any
such materials nor the information contained therein, and
(ii) on the date of termination or expiration of the License Contract,

not use or disclose, cause any use or disclosure to be ceased, and immediately tum
over to Licensor or any of its Affiliates, immediately turned over to Licensor or
its Affiliates all such physical property, materials and information in the
Restricted Party's possession or under the Restricted Party's custody or control.
6. Specific Performance, Remedies and Modification.
(a) The Restricted Party acknowledges and agrees that any breach of the
restrictive covenants set forth in Articles 3, 4 or 5 hereof will result in irreparable damage
to Licensor or any of its Affiliates for which there will be no adequate remedy at law, and
the Restricted Party consents to equitable relief, including without limitations an
injunction in favor of Licensor or any of its Affiliates, as the case may be, without proof
of actual damages and without the requirement of posting bond, enjoining any breach of
such covenant by any court of competent jurisdiction, without prejudice to any other
rights or remedies to which Licensor or any such Affiliates may be entitled. Such other
rights and remedies include, without limitations, monetary damages and payment of all
costs incurred by the Company in enforcement against the Restricted Party of any
provision of this Agreement at law or in equity, including reasonable attorneys' fees.
(b) In the event that any provision of Article 3, 4 or 5 or the application of any
such provision to any Person or circumstance shall be determined by any court of
competent jurisdiction to be unenforceable by reason of its being extend eo for too great a
period of time or too large a geographic area or over too great a range of activities, it
should be interpreted to extend only over the maximum period of time, geographic area,
or range of activities as to which such court would find it enforceable, and such
determination of unenforceability will not affect any other provision of this Agreement.
NONDISCLOSURE NONCOMPETITION AND jiangsulongtenn prodl$:ts 2.doc
5
7. Language. The Contract shall be written in English. A Chinese text may be

prepared for reference only. In case of any discrepancy between the two language versions, the
English version shall prevail.
8. Waiver. Failure by Licensor to insist upon strict compliance with any of the
terms, covenants, or conditions hereof shall not be deemed to be a waiver of such term, covenant,
or condition, nor shall any relinquishment of any right or power hereunder by Licensor at any
one or more times be deemed a waiver or relinquishment of such right or power by Licensor at
any other time or times.
9. Modification and Amendment. This Contract and the Appendices hereto may
only be modified or amended in writing signed by authorized representatives of the Parties, or
otherwise in accordance with the terms and conditions of this Contract.
10. Applicable Law. This Agreement will be deemed to be a contract made under the
laws of the State of Illinois and for all purposes will be governed by and interpreted in
accordance with the laws prevailing in the State of Illinois, without regard to principles of
conflict of laws.
II. Counterparts. This Agreement may be executed in several counterparts, each of

which when so executed will be deemed to be an original and all of which will together
constitute one and the same agreement.
12. Inurement. The obligations of the Restricted PartY under this Agreement are of a
personal nature and the Restricted Party may not assign such obligations. This Agreement will
inure to the benefit of the heirs, administrators, successors and assigns of Licensor.
13. Severability. Any term or provision deemed by a court of competent jurisdiction

to be unenforceable and invalid for any other reason will be severed from this Agreement, and
the remainder of this Agreement will continue in full force and effect.
14. Headings. The headings contained in this Agreement are inserted for convenience
only and do not constitute a part of this Agreement.
[Remainder of the Page Intentionally Left Blank]
NONDISCLOSURE NONCOMPETITION AND jiangsulongtenn prodl(S:ts 2.doc
6
J '~ • l
IN WITNESS WHEREOF, the. parties hereto have executed this Agreem~nt on the day
and year first above written. ,...
Name: Gus Alexander
Title: Chief Executive Officer
NONDISCLOSURE NONCOMPETITION AND jiangsulongterm prodqtts 2.doc
7
EXHIBIT 2
Technology and Know-How License Contract
. -JI·
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT
THIS TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT (this "Contract") is

made and entered into in Jiangsu on this 27 the day of March ,2012 ("Effective
Date"), by and among:
(1) FNA GROUP INC.~ a company duly organized and existing under the laws of the
State of [Illinois), the United States of America ("USA,) with Its principal
address at 1825 Greenleaf Ave.; Elk Grove Village, IL 60007, USA ("Licensor");
(2) Jiang Su .Long Term Products Co .. Ltd

a company duly organized and existing under the laws of the J;>eople's Republic of China
("PRC" or "China") wlth its registered address at Headquarters located:
No.88 Zhao Min industry zone, Lu Si Gang town, Oing Dong citv, liang
Su province. P.R.China ("Licensee");
Licensor and Licensee are hereinafter referre.d to collectively as the "Parties" and
individually as a "Party")
PREAMBLE
(1) WHEREAS, Licensor agrees to license certain technology and know-how to
Licensee for the manufacture of Licensed Products (as defined below) and the
provision of after-sale service;
(2) WHEREAS, · Licensor and Licensee ·have entered into a Manufacturing

Agreement dated March 27,2012 , (the "Manufacturing Agreement");
(3) WHEREAS, in c.onnection with this · licensing arrangement, Licensor and

Licensee have also entered into a certain Confidentiality Agreement dated_
March 27. 2012 , as the same may be supplemented and amended
from time to time in accordance with the terms thereof (the "Confidentiality
Agreement"); and
(4) WHEREAS, as a further inducement for the Licensor to enter into this Contract,
each Licensee has also agreed to undertake certain confidentiality, non-compete
and non-solicitation obligations by executing and delivering a Nondisclosure,
Non~competition and Non-solicitati~n Agreement ("Restriction Agreement");
NOW, THEREFORE, after friendly consultation and negotiation, for good and valuable
consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties
hereby agree as follows: ·
'
1
ARTICLE 1 DEFINITIONS
Unless context otherwise· requires,· the following terms shall have the meanings set forth
below: ·
1.1 "Affiliate" means, with respect to a Person, any other Person which directly or
-indirectly through one or more intermediaries controls, is controlled by, or is
under common control with the Person; the term "control" (including the terms
"controlled by" and "under common control with") means, in respect of a Person,
direct or indirect ownership of any voting stock, ownership interest or securities
of such Person, or the power to elect or appoint directors or senior management,
al}d/or the ability to determine and enforce the strategic, business or operations
policies of such Person.
1.2 "FNA CONFIDENTIAL INFORMATION" is understood to mean (a) technical

information and d·ata concerning the PRODUCT and/or SERVICES made
available by FNA in written, machine recognizable, graphic, or sample form
including, without limitation, formulas, drawings, materials and formulations,
documents, pricing and costing, intra-company memoranda, marketing plans and
surveys, plans for new pr9duct(s) or product improvement, photographs, sketches,
models, mockups, product configurations, design or performance specifications,
and test data, provided such information is labeled "CONFIDENTIAL" or other
equivalent legend; or under all of the circumstances, would be reasonably
understood to be confidential or proprietary; (b) information and data disclosed
orally or visually provided it is identified at the time of disclosure or a reasonable
time thereafter as confidential or proprietary; and, (c) the existence of the
PRODUCT, and the terms and existence of this Agreement, and the discussions
between the parties.
1.3 "Term" means the term of this Contract, and any extensions thereof, as provided
for in Article 9.1.
1.4 "Licensed Products" means products which are set out in Appendix 2) as the same
may be supplemented and amended from time to time by the Licensor in its sole
discretion. ·
1.5 "Person" includes any individual, company~ legal person enterprise, non-legal
person enterprise, joint venture, partnership, wholly owned entity, unit, trust or
other entity or organization; Person also includes that Person's legal
representative, successor or heir.
1.6 "Technical Documentation" means the technical documentation in connection

with the Technology and Know-how, which has been provided or furnished to
Licensee or any of its Affiliates or before the Effective Date or which will be
provided or furnished by or on behalf of Licensor to Licensee pursuant to this
Contract in any tangible form, including but not limited to, research report,
documents, letters, forms, product or design drawings, lay-out drawings, data,
TECHNOLOGY AND ~OW-HOW LICENSE CON1RACT 2Jiang SR Long Term Products .doc
2
handbooks, lists, manuals, reports, video and audio tapes, instructional

information, or computer programs and files, the details of which are specified in
Appendix 1 attached hereto, as the same may be supplemented and amended from
time to time by the Licensor in its sole discretion.
1. 7 "Technology and Know-how" means (a) with respect to "Technology", the

proprietary technology (whether or not patented, including formula, method,
process, technique, invention and industrial design) in relation to the manufacture,
assembly, use, sale, marketing or other disposition of any Licensed Product, and
(b) with respect to "Know-how", technical knowledge, experience, skills,
commercial secrets, special techniques (including product quality control) and
proprietary information in relation to the manufacture, assembly, use, sale,
marketing or other disposition of any Licensed Product, and (c) all Technical
Improvements thereto; in each case, which will be provided or furnished from
time to time by or· on behalf of the Licensor to the Licensee or any of its Affiliates
pursuant to this Contract or which has been provided or furnished to the Licensee
and/or any of its Affiliate prior to the date hereof.
1.8 "Technical Improvements" means any technical improvements developed from

and jn connection with the Technology and Know-how, including but not limited
to, new design drawings, new technfcal documents, and/or new process methods
technology, new materials and application technology, new equipment application
technology, and/or new computer software programs.
1.9 "Territory" means mainland China, excluding Hong Kong, Macao and Taiwan.
ARTICLE 2 SCOPE OF LICENSE; MANUFACTURE AND SALE
2.1 Subject to the terms and conditions of this Contract and except as otherwise
provided for herein~ Licensor hereby grants to Licensee, and Licensee hereby
accepts the grant of, a non-exclusive, non-transferable, non-sublicensable and
royalty license to use the· Technology and Know-how solely for (a) manufacturing
Licensed Products in the Territory and for (b) providing after-sale and other
ancillary services in relation to any Licensed Product.
2.2 The Parties hereby acknowledge and agree that no other rights whatsoever are
granted to Licensee in respect of the Technology and Know-how except those
expressly provided for herein. The Licensee specifically recognizes the validity
of, and the sole right, title, and interest of Licensor in and as the sole owner ofthe
Technology and Know-how (including Technical Improvements), and agrees that
the rights granted to the Licensee under this Contract are subject to and
conditional upon Licensee's full, complete, and continuing performance of their
respective obligations hereunder.
2.3 Licensee shall not transfer or sublicense all or any portion of the Technology and
Know-how to any Person (including without limitation, or any Affiliate of the
Licensee).
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang S!J Long Tenn Products .doc
3
2.4 At any time after the execution of this Contract , if in the Licensor's sole
discretion it is deemed to be necessary or appropriate, Licensor may apply with
the relevant PRC authorities to register this Contract and obtain a Registration
Certificate of Technology Import Contract Licensee shall use its best efforts to
assist with such application process.
2.5 The Licensee agrees and covenants that the Technology and ;Know-how will be
used solely for manufacturing the Licensed Products in quantities and in
accordance with the specifications as expressly provided by the Licensor from
time to time. Licensee shall not manufacture, any Licensed Product for any
Person (including without limitations~ any Affiliate of the Licensee) without the
express written consent of the Licensor, or other than in accordance with the
preceding sentence or in accordance with this Contract.
2.6 The Licensee agre.es and covenants that any Licensed Product will be sold only to
the Licensor in quantities and ptices to be agreed by Licensor and Licensee.
Licensee shall not sell any Licensed Product to any other Person (including
without limitations, any Affiliate of the Licensee) without the express written
consent of the Licensor.
2.7 For Products covered in this contract, the Licensee shall not, without prior written
consent of FNA~ sell to any customer other than FNA in the North American
market. For customers in other markets, the Licensee shall discuss the
opportunities with FNA before selling. The Licensee shall use its best effort to
prevent the Products from entering the North American market directly or
indirectly without FNA's prior consent.
ARTICLE 3 TECHNICAL IMPROVEMENTS
3.1 Subject to Article 3.2, Licensee shall promptly communicate to the Licensor any
improvements or modifications which Licensee makes to Technology and Know-
how during the Term of this Contract and hereby makes available and grants to
the Licensor during the Term of the Contract, free of charge, an exclusive and
unrestricted license to all such improvements or modifications, with the right to
sub-license. Licensee shall not license any such improvements or modifications to
any third Person (including without limitation, any Guarantor or any Affiliate. of
the Licensee).
3.2 To ensure the quality of the Licensed Products, Licensee shall not introduce or
use any technology, production process or know-how which could conflict with
and/or affect the proper use or application of the Technology and Know-how for
the manufacture of any Licensed Products or could have adverse impact ·on the
quality of the Licensed Product. Iti the event that Licensee wishes to modify the
Technology and Know-how , Licensee shall inform Licensor and request for the
advice and consent of Licensor prior to making any modification or applying any
such modification to its manufacture of any Licensed Products. Licensee may
make no modification or applying such modification to the manufacture of any
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang S4 Long Tenn Products .doc
4
Licensed Product unless Licensor has expressly approved such .modification or

application in writing.
ARTICLE 4 WARRANTY, INDEMNITY AND INFRINGEMENT
4·.1 Licensor represents and warrants:
(a) Licensor has the right to license the Technology and Know-how to
Licensee in accordance with the terms and conditions of this Contract; and
(b) The Technology and Know-how, when provided by Licensor to Licensee

pursuant to this Contract, can be capable of satisfying the goals
contemplated herein or otherwise can be suitable for manufacturing the
Licensed Products in China.
4.2 The Licensee represents that it has not, and warrants covenants that it shall not,
and shall procure all of their respective employees, agents, consultants, advisors,
partners, associates, directors, officers and contractors to be contractually bound
not to, disclose or provide to any third Person, or any Affiliate of the Licensee, in
any manner, the Technology and Know-how. In addition, Licensee shall use, the
Technology and Know-how only solely for the purpose of manufacturing
Licensed Products and otherwise in accordance with this Contract.
4.3 In the event of any third Person's claim against Licensee for infringement of the
third Perspn's rights arising from Licensee's use of the Technology and Know-
how in accordance with this Contract, Licensee shall immediately inform
Licensor and assist Licensor in opposing such claim.
4.4 Licensee shall not ·at any time apply for any patent or copyright or other
intellectual property rights relating to the Technology or Know How or Licensed
Products in China or in any other country.
ARTICLE 5 CONFIDENTIALITY
5.1 The Licensee hereby represents that it has kept strictly confidential the
Confidential Information, and has not disclosed or used, or permitted to be
disclosed or used, directly or indirectly, any Confidential Information, in whole or
in part, to or by any third Person (or any Affiliate Licensee) in any manner.
The Licensee hereby warrants and covenants that it shall keep strictly confidential
the Confidential Information , and shall not disclose or use, or permit to be
disclosed or used, directly or indirectly, any Confidential Information, in whole or
in part, to or by any third Person (or any Affiliate of the Licensee) in any manner
except to authorized officers, employees ot agents of the Licensee; provided that
(a) the disclosure is necessary for the performance of their respective duties, and
is provided on a need-to-know basis; and (b) such officers, employees or agents
have been informed of the disclosing Party's confidentiality obligations under this
Contract or any other related agreements and have undertaken a similar written
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang S~ Long Tenn Products .doc
5
obligations of confidentiality which extends to the benefit of and is enforceable by

the Licensor.
5.2 The Licensee shall take, or cause to be taken, all necessary and appropriate
actions to preserve the confidentiality of the Confidential Information (including
the Technology and Know-how), including without limitation requiring, as a
condition to employment or entering into any business relationship, any and all of
their respective employees (including seconded employees), agents, consultants,
advisors, partner, associate, directors, officers and contractors, to sign the
requisite non-disclosure contracts and non-competition contracts whose form and
substance shall be pre-approved by the Licensor.
5.3 The obligations of this Article 5 shall survive, for a period often (10) years, after
the latter of (a) the date of the termination or expiration of this Contract or (b) the
date of termination, dissolution and liquidation of the Licensee.
ARTICLE 6 FORCE MAJEURE
6.1 Events of force majeure include, but are not limited to acts qf God, war, civil
commotion, riot, delays of carriers, fire, explosion, earthquake, epidemic, flood,
wip.dstorm, or any substantial change in law~ regulation, or any act of
governmental authority, or any other cause which is beyond the reasonable
control of the affected Party.
6.2 Should any Party be materially and adversely prevented from performing its
obligations· under this Contract due to the occurrence of any event of force
majeure, the affected Party shall promptly send notice to the other Party
describing the nature of the event of force majeure and, upon request of the non-
affected Party, shall provide evidence of such event of force majeure reasonably
acceptable to the non-:;tffected Party.
6.3 Any delay or failure in performance of this Contract directly caused by an event
of force majeure shall not constitute default by the affected Party or give rise to
any claim for damage, losses or penalties. Under such circumstances, both Parties
are required to continue to substantially perform their obligations which are not
materially affected by the event of force majeure to the maximum extent possible.
The affected Party shall notify the other Party immediately of the elimination of
the event of force majeure.
ARTICLE 7 BREACH OF CONTRACT
7.1 If Licensee fails to perform, in the time and manner herein provided, any
obligation or condition, or breaches any representation, guaranty, covenant or any
other obligation stipulated in this Contract, Licensee shall bear all the liabilities
(to be determined in accordance with the laws of the State of Illinois) arising from
such failure or breach.
1ECHNOLOGY AND KNOWMHOW LICENSE CONTRACT 2Jiang s~ Long Tenn Products .doc
6
7.2 Should Licensee breach or fail to perform under this Contract, in addition to any
other rights, Licensor shall have the right to terminate this Contract in accordance
with the provisions of Article 9.2. Licensor shall also be entitled to claim for
compensation (to be. determined in accordance with the laws of the State of
illinois) for its losses resulted from the failure or breach.
ARTICLE 8 APPLICABLE LAW
The conclusion, validity, interpretation and performance of, and the settlement of
disputes in connection with, this Contract, shall be governed by the laws of the State of
Illinois.
ARTICLE 9 DURATION AND TERMINATION
9.1 Effective Date and Term. This Contract shall become effective on the Effective
Date and shall, unless earlier terminated in accordance with the terms herein,
remain in effect for as long as Licensee is manufacturing Products for Licensor.
9.2 Termination.
(a) Notwithstanding Article 9.1, the Licensor shall have the right (but not
obligation) to terminate this Contract, effective immediately upon notice
and without any further acts, if any of the following events occurs:
(i) the Licensee's breach of any obligations under this Contract, as

determined by the Licensor in its sole discretion;
(ii) bankruptcy or insolvency, dissolution or liquidation of the

Licensee or cessation of any such Party's business as. conducted as
of the date hereof;
(iii) with respect to any Party, the continuation of any event of force
majeure for more than three (3) consecutive months and lack of
prospect of an equitable solution, resulting in an inability for any
other Party to operate effectively;
(iv) the Licensee's breach of any obligation under the Confidentiality

Agreement or the Restriction Agreement, as determined by the
Licensor in its sole discretion;
(v) the Licensor's economic benefits are, in the Licensor's sole

determination, adversely affected by the promulgation of any PRC
laws, rules or regulations or the amendment or interpretation of
any existing PRC laws, rules or regulations after the Effective
·Date; or
(vi) consent of the Licensor to the early termination of this Contract.
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang SI,TLong Term Products .doc
7
9.3 Effect of Termination. In the event this Contract expires or is terminated

pursuant to this Article 9, the Licensee covenants that it
(a) shall not sell, transfer, license, dispose of, or otherwise provide all or any
part of the Technology and Know-how to any third Person (or any
Affiliate of Licensee), in any manner whatsoever;
(b) shall ·immediately cease, or cause to be caused, the manufacture of the

Licensed Products and stop using the Technology and· Know-how;
(c) shall cease (or cause to be ceased) the using or disclosing any Confidential
Information; and
(d) shall immediately return (or caused to be returned) to Licensor all tangible
forms of the Confidential Information and the Technology and Know-how
(including, without limitation, the Technical Documentation), whether in
written or other form, and all copies thereof.
ARTICLE 10 EFFECTIVENESS AND MISCELLANEOUS PROVISIONS
10.1 Language. The Contract shall be written in English. A Chinese text may be
prepared for reference only. In case of any discrepancy between the two language
versions, the English version shall prevail,
10.2 Waiver. The failure to exercise or delay in exercising a right or remedy under this
Contract shall not constitute a waiver of the right or remedy or a waiver of any
other rights or remedies and no single or partial exercise of any right or remedy
under this Contract shall prevent any further exercise o~ the right or remedy or the
exercise of any other right or remedy.
10.3 Notice. Any notice or other communication required or permitted to be given

hereunder by one Party shall be in writing and delivered via overnight courier or
facsimile or electronic mail to the persons addressed below and shall be deemed
received by the other Party within two (2) days of such delivery:
To Licensee:
Managing Director Telephone: - - - - - - -

Fax Number:
Email: .
To Licensor:
Gus Alexander
Chief Executive Officer Telephone: --~-
Fax Number:
Email:
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang SS Long Tenn Products .doc
8
10.4 Severability and Entire Contract Should any provision of this Contract be held
legal, invalid or unenforceable for any reason, it is the intention of the Parties that
such provision shall be modified to the minimum extent to eliminate such illegality,
invalidity or unenforceability and to accomplish to the maximum extent the
intentions of ·the Parties. This Contract and the Appendices hereto constitute the
entire agreement of the Parties with respect to its subject matters.
10.5 Modification and Amendment This Contract and the Appendices hereto may only
be modified or amended in writing signed by authorized representatives· of the
Parties, or otherwise in accordance with the terms and conditions of this Contract.
10.6 Assignment. During the Term, the Licensee shall not assign any of its rights or
obligations under· this Contract to any third Person without the prior written
consent of the Licensor which may be refused for any reason or for no reason. Any
assignment permitted under this Article 10.6 shall only be effective upon the
assignee's agreement in writing to become a party to and be bound by the terms
and conditions of this Contract, the Restriction Agreement, or Confidentiality
Agreement and assume the Licensee's rights and obligations hereunder and
thereunder.
10.7 Counterparts. This Agreement may be executed in several counterparts, each of

which when so executed will be deemed to be an original and all of which will
together constitute one and the same agreement.
10.8 Successors. This Contract shall inure to the benefit of and be binding upon each of
the Parties and theirrespective permitted successors and assigns.
10.9 Appendices. The Appendices hereto shall constitute an integral part of.this Contract.
IN WITNESS WHEREOF, each of the Parties has executed this Contract or has caused
this Contract to be executed by its duly authorized officer or officers as of the date first
above written. ·
FNAGROUP
By:~.·~~~~~----~~-----
Name:_~~::....__~~.--------
Title:_-~-~~=-=-----~----
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang S9 Long Tenn Products .doc
9
Licensee:
By: kz.J5, ,;.I?~"'~~~~ t{).J,,-:;;j

~\;¥_
Name:
Title: ¥ ..Jt 1k
r ~~~ "''J ·,_f,o
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang ~ong Term Products .doc
10
• J
' ,
Appendix 1
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang ~lLong Tenn Products .doc
11
Appendix 2
Licensed Products
TECHNOLOGY AND KNOW-HOW LICENSE CONTRACT 2Jiang fitQLong Term Products .doc
12
JIANG SU LT LICENSED PRODUCTS (APRIL 2017)
ITEM# & Description

510001 PUMP, 2400@2.0 P/BOOST LONG EXT. AL
HEAD
510003 PUMP, 3000@2.4 P/BOOST LONG EXT. AL
HEAD
510005 PUMP, 3100@2.5 P/BOOST BRASS HEAD
510011 PUMP, 2700@ 2.3 LONG EXT. AL HEAD NO
PB
510013 PUMP, 3000@2.4 P/BOOST LONG EXT,
ADAPTER
510014 PUMP, 3000@2.4 W/0 PB LONG EXT. AL
HEAD
510015 PUMP, 3000@2.4 W/0 PB 11 DEG WOBBLE
PLAT
510016 VERTICAL PONY PUMP, 2400PSI@ 2.0GPM
510017 PUMP, VERT 11rnmx12DEG, NO P/B, AL
HEAD
510019 VERTICAL RECONDITIONED PUMP
I
·.
510020 PUMP, VERT 12rnmx12DEG,P/B, 3 LEG

UNIHEAD
510021 PUMP, VERT 11mmx12DEG, P/B, AL
UNIHEAD
520002 PUMP, HORZ, 12mmx12DEG, P/B, BRASS
HEAD
520004 PUMP, HORZ, 12mmx12DEG, P/B, AL
UNIHEAD
520006 PUMP, HORZ, 12mm X 12DEG, ALUM
UNIHEAD
520011 PUMP, 3000PSI@2.4GPM HORIZ-AX AL NO
P-B
530001 PUMP,3000PSI@ 2.3GPM HORIZONTAL-
TRIPLEX
530002 PUMP ,3200PSI @ 2.5GPM HORIZONTAL-
TRIPLEX
530003 PUMP,~800PSI@ 3.5GPM HORIZONTAL-
TRIPLEX
530004 PUMP,4000PSI@ 3.3GPMHORIZONTAL-
TRIPLEX
530006 PUMP, C45 SERIES, HORZ TRIPLEX, 13X13
1
13
530007 PUMP, 4700PSI@ 4.0 GPM, 3400 RPM BELT

D
530008 PUMP, C31 SERIES, HORZ TRIPLEX, 12X8.7
530009 C31 SERIES PUMP, 3200PSI@ 2.5GPM
HORIZ
530010 PUMP, C41 SERIES, HORZ TRIPLEX, 13X10
530011 PUMP, 3400PSI @ 2.3GPM W/1.5MM INJ.
530012 C41 SERIES PUMP, 4000PSI@ 3.3GPM
HORIZ
530013 PUMP,3200PSI@ 2.5GPM W/1.5mm
INJECTOR
530016 PUMP, C31 SERIES, HORZ TRIPLEX, 12X8.2
530017 PUMP, CY SERIES, HORIZ TRIPLEX, 12x8.2
530019 PUMP, C3X SERIES, HORIZ TRIPLX,
12x9.6BD
530021 PUMP, C4X SERIES, HORIZ TRIPLEX,
13x13BD
14
EXHIBIT 3
Screenshots of LT Website
Pengda Group Page 1 of 2
Product Display
Location：Home > Product Display
Pressure Washer／
All 20 A info
Gasoline Pump
Motor
Enameled Wire
Company Profile
LT201C LT202C Series LT203C Series LT205C Series
Products
Factory Tour
Showroom
Laboratory
Contact Us
LT501C Series LT502C Series LT503C Series LT701C Series
LT702C Series LT703C Series LT705C Series LT706C Series
LT707C Series LT703I Series LT706I Series LT707I Series
LT901/LT902 LT921/LT922 LT931/LT932 LT951/LT952
Home Previous Next End Page：1/1page 20A info / page Turn： in1 page 
1
http://www.pengda-group.com/En/Product1.asp?EnBigClassName=Pressure+Washer%2F... 4/19/2018
Copyright © 2013-2016 Jiangsu Longteng-pengda Electric Mechanical Co.,Ltd

Tel：+86 513 6869 6668 Fax：+86 513 6869 3300 E-mail：Jeff@pengda-group.com
2
http://www.pengda-group.com/En/Product1.asp?EnBigClassName=Pressure+Washer%2F... 4/19/2018
Product Display
Pressure Washer／
Gasoline Pump Model：LT951/LT952
Motor LT951/LT952
Features
Enameled Wire
◎ Forged Brass Pump Head
◎ Dark Anodized Crank Case
◎ Pressure Adjustable
◎ Site Glass for Easy Control of Oil Level
Company Profile
◎ Ceramic Plungers
Products
◎ German Parker Sealing Set
Factory Tour ◎ Water Outlet QC Coupling
Showroom ◎ With Thermal Relief Valve
Laboratory
Contact Us Model LT951 LT952

Rated Pressure(bar/PSI) 260/3800 280/4000
Rated Flow(LPM/GPM) 13.2/3.5 12.5/3.3
Rotate(RPM) 3450-3550 3450-3550
Bore(mm) 13 13
Stroke(mm) 10 9.4
Reference Engine Honda GX270 Honda GX2700
Packing Dim.(mm) 295*275*170 295*275*170
N.G.(kg) 6.50 6.50
【Return】

3
http://www.pengda-group.com/En/productsShow.asp?ArticleID=28 4/19/2018
Product Display
Pressure Washer／
Motor LT931/LT932
Features
Enameled Wire
◎ Forged Brass Pump Head
◎ Pressure Adjustable
◎ Site Glass for Easy Control of Oil Level
Company Profile
◎ Ceramic Coated Stainless Steel Plungers
Products
◎ German Parker Sealing Set
Factory Tour ◎ With Thermal Relief Valve
Showroom
Laboratory Model LT931 LT932
Contact Us Rated Pressure(bar/PSI) 210/3000 220/3200
Rotate(RPM) 3450-3550 3450-3550
Bore(mm) 12 12
Stroke(mm) 8.7 9.6
Reference Engine Honda GX160 Honda GX200
Packing Dim.(mm) 220*250*84 220*250*84
N.G.(kg) 3.66 3.66
【Return】

4
Product Display
Pressure Washer／
Motor LT921/LT922
Horizontal Axial Pump
Enameled Wire
Features
◎ Forged Brass Pump Head and Aluminum
Manifold
◎ Zink-coated Water Inlet Connector
Company Profile
Products
◎ 3 Copper Sealing Sets Prevent Water Leak
Factory Tour ◎ Stainless Steel Piston
Showroom ◎ Pressure Adjustable
Laboratory ◎ With Thermal Relief Valve
Contact Us
Model LT921 LT922
Rated Pressure(bar/PSI) 210/3000 215/3100

Rotate(RPM) 3450-3550 3450-3550
Bore(mm) 12 12
Stroke(mm) 8.6 8.6
Reference Engine Honda GCV190 Honda GCV190
Packing Dim.(mm) 200*150*201 200*150*201
N.G.(kg) 2.86 2.86
【Return】

5
Product Display
Pressure Washer／
Motor LT901/LT902
Vertical Axial Pump
Enameled Wire
Features
◎ Die Cast Aluminum Pump Head and
Manifold
◎ Zink-coated Water Inlet Connector
Company Profile
◎ 3 Copper Sealing Sets Prevent Water Leak
Products
◎ Stainless Steel Piston
Factory Tour ◎ Pressure Adjustable
Showroom ◎ 6-hole Flange Fit for Different Mounting
Laboratory Position and Direction
Contact Us ◎ With Thermal Relief Valve
Model LT901 LT902

Rated Pressure
165/2400 210/3000
(bar/PSI)
Rotate(RPM) 3450-3550 3450-3550
Bore(mm) 11 12
Stroke(mm) 8.6 8.6
Ducar 140cc Honda Honda
Reference Engine
GCV160 GCV160/190
Packing Dim.(mm) 165*215*180 165*215*180
N.G.(kg) 2.97 2.55
【Return】

6
EXHIBIT 4
U.S. Design Patent
US D699,762 S
111111 1111111111111111111111111111111111111111111111111111111111111
USOOD699762S
c12) United States Design Patent (10) Patent No.: US D699,762 S

Alexander et al. (45) Date of Patent: ** Feb. 18, 2014
(54) PUMP (56) References Cited
U.S. PATENT DOCUMENTS

(71) Applicants:GusAlexander, Inverness, IL (US);
James E. Welch, Bentonville, AR (US); D354,495 s * 111995 Tojo ................................. D15/7
Wang Xu Dong, Shenyang (CN) D538,824 S * 3/2007 Tojo ................................. D15/7
D538,826 S * 3/2007 Kienzle ............................ D15/9
D633,406 S * 3/2011 Magri .............................. D15/7
(72) Inventors: Gus Alexander, Inverness, IL (US); D670,312 S * 1112012 Alexander et al ................ D15/7
James E. Welch, Bentonville, AR (US);
* cited by examiner
Wang Xu Dong, Shenyang (CN)
Primary Examiner- Ralf Seifert
(73) Assignee: FNA IP Holdings, Inc., Elk Grove (74) Attorney, Agent, or Firm- Steven E. Jedlinski;
Village, IL (US) Holland & Knight LLP
(57) CLAIM
(**) Term: 14 Years The ornamental design for a pump, as shown and described.
DESCRIPTION
(21) Appl. No.: 29/434,059
FIG. 1 is a perspective view of a pump as viewed from the
(22) Filed: Oct. 9, 2012 front right side;
FIG. 2 is a perspective view of a pump as viewed from the rear
(51) LOC (10) Cl. 15-02 left side;
(52) U.S. Cl. FIG. 3 is a left side elevation view thereof;
USPC ............................................................. Dl5/7 FIG. 4 is a right side elevation view thereof;
FIG. 5 is a front elevation view thereof;
(58) Field of Classification Search FIG. 6 is a rear elevation view thereof;
USPC ........... D15/7-9; D23/231, 232, 225; 417/60, FIG. 7 is a top plan view thereof; and,
417/235,265,321,355,358,363,359, FIG. 8 is a bottom plan view thereof.
417/410.1,415-416,405, 900; 60/408, The broken lines in FIGS. 2, 4, and 8 are included for the
purpose of illustrating portions of the pump that form no part
60/412; 184/26-37; 415/140-147;
of the claimed design.
123/495, 509; D24/111
See application file for complete search history. 1 Claim, 8 Drawing Sheets
1
U.S. Patent Feb.18,2014 Sheet 1 of8 US D699,762 S
FIG.1
2
-us D699,'762 s
Sneet 2 ofS
Feb. 18,2014
U.S. }latent
f\G. 2
3
FIG. 3
4
FIG. 4
5
U.S. Patent Feb. 18, 2014 Sheet 5 of 8 US D699,762 S
FIG. 5
6
FIG. 6
7
II
FIG. 7
8
FIG. 8
9
EXHIBIT 5
U.S. Design Patent
US D700,211 S
111111 1111111111111111111111111111111111111111111111111111111111111
USOOD700211S
c12) United States Design Patent (10) Patent No.: US D700,211 S

Alexander et al. (45) Date of Patent: ** Feb. 25, 2014
(54) PUMP D633,101 s * 212011 Magri .............................. D15/7

D633,102 S * 212011 Magri .............................. D15/7
D633,103 S * 212011 Magri .............................. D15/7
(75) Inventors: Gus Alexander, Inverness, IL (US); D633,104 S 212011 Magri .............................. D15/7
James E. Welch, Jr., Bentonville, AR
*
D633,105 S * 212011 Magri .............................. D15/7
(US); Wang Xu Dong, Shenyang (CN) D633,406 S * 3/2011 Magri .............................. D15/7
D642,594 S 8/2011 Mattson et al.
(73) Assignee: FNA IP Holdings, Inc., Elk Grove D644,252 S 8/2011 Kojima
D648,353 S 1112011 Mattson et al.
Village, IL (US) D652,844 S 112012 Hanitsch et a!.
D654,095 S 2/2012 Mattson et al.
(**) Term: 14 Years D656,962 S 4/2012 Boldsen
D670,312 S * 1112012 Alexander et al . ............... D15/7
(21) Appl. No.: 29/429,403 * cited by examiner
(22) Filed: Aug. 10, 2012 Primary Examiner- Ralf Seifert
(51) LOC (10) Cl. ................................................ 15-02 (74) Attorney, Agent, or Firm- Steven E. Jedlinski;
(52) U.S. Cl. Holland & Knight LLP
USPC ............................................................. Dl5/7
(57) CLAIM
(58) Field of Classification Search
USPC ........... D15/7-9; D23/231, 232, 225; 417/60, The ornamental design for a pump, as shown and described.
417/235,265,321,355,358,363,359, DESCRIPTION
417/410.1,415-416,405, 900; 60/408,
60/412; 184/26-37; 415/140-147; FIG. 1 is a perspective view of a pump as viewed from the
123/495, 509 front left side;
See application file for complete search history. FIG. 2 is a perspective view of a pump as viewed from the rear
right side;
(56) References Cited FIG. 3 is a front elevation view thereof;
U.S. PATENT DOCUMENTS FIG. 4 is a rear elevation view thereof;
FIG. 5 is a right side elevation view thereof;
5,494,414 A 211996 Steinhart et a!. FIG. 6 is a left side elevation view thereof;
D538,824 S * 3/2007 Tojo ................................. D15/7 FIG. 7 is a top plan view thereof; and,
D538,826 S * 3/2007 Kienzle ............................ D15/9 FIG. 8 is a bottom plan view thereof.
D553,157 S 10/2007 Busschaert The broken lines are included for the purpose of illustrating
D589,983 S * 4/2009 Sinico .............................. D15/7
D591,311 S * 4/2009 Tojo ................................. D15/7 portions of the pump that form no part of the claimed design.
D616,467 S * 5/20 10 Reverberi et al. .. .. .. .. .. .. .. .. D15/5
D617,814 S 6/2010 Dreifert 1 Claim, 7 Drawing Sheets
1
FIG. 1
2
FIG. 2
3
--
-----
FIG. 3
4
FIG. 4
5
FIG. 5
6
FIG. 6
7
FIG. 7
FIG. 8
8
JS 44 (Rev. 06/17) CIVIL COVER SHEET
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

FNA Group, Inc. Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd.
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Nicholas J. Santoro and Jason D. Smith, SANTORO WHITMIRE, LTD.
10100 W. Charleston Blvd., Suite 250, Las Vegas, NV 89135
Tel. (702) 948-8771 Fax (702) 948-8773
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State
u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 490 Cable/Sat TV
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 891 Agricultural Acts
u 362 Personal Injury - Product Liability u 751 Family and Medical u 893 Environmental Matters
Medical Malpractice Leave Act u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. 271 et seq. and 18 U.S.C. § 1836, et seq.
VI. CAUSE OF ACTION Brief description of cause:
Patent infringement and trade secret violation
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
05/07/2018 /s/ Jason D. Smith
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT

for the
District
__________ of Nevada
District of __________
FNA GROUP, INC. )

)
)
)
Plaintiff(s) )
)
v. Civil Action No. 2:18-cv-00812
)
JIANGSU LONGTENG-PENGDA ELECTRIC )
MECHANICAL CO., LTD. )
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) JIANGSU LONGTENG-PENGDA ELECTRIC MECHANICAL CO., LTD.
No. 88 Zhao Min Industry Zone
Lu Si Gang Town, Qing Dong City
Jiang Su Province
P.R. China
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
Nicholas J. Santoro (Nev. Bar No. 532)
Jason D. Smith (Nev. Bar No. 9691)
SANTORO WHITMIRE, LTD.
10100 W. Charleston Blvd., Suite 250
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 2:18-cv-00812
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)

was received by me on (date) .
u I personally served the summons on the individual at (place)

on (date) ; or
u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
u I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
u I returned the summons unexecuted because ; or
u Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:

FNA Group v. Jiangsu Longteng-Pengda - Complaint

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FNA Group v. Jiangsu Longteng-Pengda - Complaint

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Case 2:18-cv-00812-RFB-VCF Document 1 Filed 05/07/18 Page 1 of 24

1 NICHOLAS J. SANTORO (NBN 532)

6 STEVEN E. JEDLINSKI (pro hac vice forthcoming)

13 UNITED STATES DISTRICT COURT

1 6. Defendant Jiangsu Longteng-Pengda Electric Mechanical Co., Ltd. is a company

12 FNA is an Industry Leader in Pressure Washers and Related Components

1 FNA’s Relationship with LT

3 range of products, FNA outsources some of its manufacturing to China.

4 26. LT was one of FNA’s manufacturers.

10 and other related licensed products (the “Products”).

13 Know-how License Contract (the “License Contract”) (attached as Exhibit 2).

20 marketing plans, sketches, models, product configurations, design or performance specifications

22 market research, and marketing or other disposition of FNA licensed products.

25 FNA No. Description

1 520002 PUMP, 3100@2.4 HORIZ-AXIAL P/BOOST BRASS

5 33. Eventually, however, a breakdown in the relationship caused FNA to stop

1 41. Specifically, on its website LT is currently offering products that LT previously

18 for the pump during the Parties’ relationship.

20 pump including U.S. Patent No. D699,762.

21 LT921/LT922 Product FNA 520002 Pump ‘762 Patent Figure

1 LT Product FNA 520002 Pump ‘762 Patent Figure

8 55. Upon information and belief, LT manufactures the LT921/LT922 (horizontal

10 56. Upon information and belief, LT manufactures the LT921/LT922 (horizontal

12 agent companies authorized to act on LT’s behalf.

18 once it stopped manufacturing products for the company.

21 and know-how to third parties.

23 Pressure Pro units.

25 (iii) except as required by law or directed by Licensor, not [to] disclose

1 (iv) to take or cause to be taken all other necessary and appropriate

7 could grant to LT a non-exclusive, non-transferable, non-sublicensable and royalty license to use

11 parties agreed the NDA would be governed.

12 81. The License Contract is a valid and enforceable contract.

15 with that agreement.

17 with the terms of the License Contract.

18 85. FNA has complied with the License Contract.

21 the provision of after-sale service[.]”

23 (a) with respect to “Technology”, the proprietary technology (whether or

1 Technical Improvements thereto; in each case, which will be provided or

7 89. However, Section 9.3 of the License Contract provides:

8 Effect of Termination. In the event this Contract expires or is terminated

19 90. LT breached Section 9.3 of the License Contract by:

20 (a) selling, transferring, licensing, disposing of, or otherwise providing

19 designs, and patents as its own.

20 98. LT intentionally, willfully and unlawfully simulated and misappropriated FNA

23 and FNA’s affiliation with, LT’s products.

26 Practices statute, NRS 598.0915.

12 designs, and patents as its own.

13 105. LT intentionally, willfully and unlawfully simulated and misappropriated FNA

16 and FNA’s affiliation with, LT’s products.

19 goods and commercial activities, in violation of 15 U.S.C. §1125(a).

22 activities are enjoined.

8 to sue and recover for past, present, and future infringement.

16 claimed in the ‘762 patent.

17 LT Pump on Nilfisk PW LT Pump FNA Patent Figure

18 to sue and recover for past, present, and future infringement.

25 appearance of the design claimed in the ‘211 patent.

1 LT Pump on Nilfisk PW ‘211 Patent Figure

15 award of reasonable attorneys’ fees pursuant to 35 U.S.C. § 285.

17 ‘211 patent unless restrained by this Court.

19 adequate remedy at law.

23 together with interest and costs as fixed by the Court.

12 145. LT has intentionally engaged in wrongful activities designed to divert sales to

13 itself that would have otherwise been enjoyed by FNA.

14 146. In particular, LT has been unjustly enriched by its misappropriation of FNA