1 Mark D. Kremer (SB# 100978) m.kremer@conklelaw.

com 2 CONKLE, KREMER & ENGEL Professional Law Corporation 3 3130 Wilshire Boulevard, Suite 500 Santa Monica, California 90403-2351 4 Phone: (310) 998-9100 Fax: (310) 998-9109 5 Steven Stern sstern@grr.com 6 Richard S. Schurin rschurin@grr.com 7 GOTTLIEB, RACKMAN & REISMAN, P.C. 270 Madison Avenue 8 New York, New York 10016 Telephone: (212) 684-3900 9 Facsimile: (212) 684-3999 10 Attorneys for Plaintiff Acolyte Technologies Corporation 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1317.010\9998

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ACOLYTE TECHNOLOGIES CORPORATION, a New York corporation, Plaintiff, v. JEJA INTERNATIONAL CORPORATION LIMITED, a foreign corporation; EVELYN KIM, an individual; INHO KIM, an individual; CHOONG BIN LIM, an individual; SOOK JA LIM, an individual; CEONG LIM an individual; and DOES 1-10, Defendants. CIVIL ACTION NO. '11CV2012 MMA CAB COMPLAINT FOR INFRINGEMENT OF U.S. PATENT NOS. D633,232 & D642,299 AND UNFAIR COMPETITION

Complaint

Plaintiff, Acolyte Technologies Corporation, (hereinafter plaintiff and/or

2 Acolyte), by way of its Complaint against the corporate defendant Jeja 3 International Corporation, Limited (Jeja), and individual defendants Evelyn Kim, 4 Inho Kim, Choong Bin Lim, Sook Ja Lim and Ceong Lim, all d/b/a La Bonita 5 (hereinafter collectively the individual defendants), and Does 1-10, alleges as 6 follows: 7 8 9 10 1. Through the design of innovative LED lighting products, Acolyte 11 created and established a market for lighting products that are used to adorn and 12 lighten dcor and floral arrangements. Plaintiff is the recognized leader in this new 13 industry. As alleged herein, the defendants have slavishly copied and sold 14 plaintiffs original and protected product designs and engaged in acts of unfair 15 competition. 16 17 2. Through this action and the accompanying documents, plaintiff seeks a Plaintiff also seeks 18 preliminary and permanent injunction against defendants. NATURE OF ACTION

19 damages for the willful, malicious and deliberate design patent infringement, unfair 20 competition and related wrongful activities. Plaintiffs claims arise and are asserted 21 under the patent laws of the United States, 35 U.S.C. 100 et seq., and the common 22 law. 23 24 25 26 3. Acolyte is a New York corporation, with an office and place of 27 business located at 44 East 32nd Street, New York, New York 10016. 28
1317.010\9998

THE PARTIES

Complaint

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4.

Acolyte creates, designs, imports, and distributes LED lighting Acolytes LED lighting

2 products throughout the United States and the world. 4 and by the purchasing public. 5 6 5.

3 products are protected by patents and are well-known and recognized in the industry

Upon information and belief, defendant Jeja is a foreign corporation,

7 incorporated in Hong Kong and located at Flat/Rm 611 6/F Ricky CTR 36 Chong 8 Yip Street, Kwun Tong Kowloon, Hong Kong. As an integral part of its business, 9 Jeja markets and sells LED lighting products for event and floral design to 10 importers, suppliers and also directly to wholesale customers throughout the United 11 States. 12 13 6. Upon information and belief, the individual defendants together do 14 business under the name La Bonita. Together, the individual defendants own and 15 operate a store that sells LED lighting products for event and floral design to local 16 customers. La Bonita is located at 693 Palomar Street, Chula Vista, California 17 91911. 18 19 7. Upon information and belief, defendants Does 1-10 are individuals 20 and/or business entities whose identities are presently unknown to plaintiff. To the 21 extent their identities become known to plaintiff, the Doe defendants will be joined 22 and the activities in which they engaged will be further pleaded in an Amended 23 Complaint. 24 25 8. Upon information and belief, Does 1-10 are engaged in the business of 26 importing and distributing LED lighting products for event and floral design which 27 are alleged herein to infringe Acolytes rights. 28
1317.010\9998

Complaint

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9.

Upon information and belief, Does 1-10 purchase infringing LED

2 lighting products from Jeja and sell those products to the individual defendants and 3 other individuals or entities in the United States. Accordingly, the identities of 4 Does 1-10 are known to Jeja, and one or more of Does 1-10 are known to the 5 individual defendants. 6 7 8 9 10. Upon information and belief, Jeja and the individual defendants do 10 business in the State of California and in the United States by selling LED lighting 11 products and other merchandise to customers in California and in the United States. 12 13 11. Upon information and belief, Jeja also does business in the State of 14 California by virtue of the interactive and non-passive website owned and operated 15 by it which is accessible and accessed by customers in the State of California, and 16 through which the products at issue herein are advertised, marketed and sold to 17 customers in California. 18 www.jejahk.com. 19 20 12. Upon information and belief, all of the defendants reside and/or 21 transact business in this judicial district, and this Court therefore has personal 22 jurisdiction over defendants. 23 24 13. This Court has jurisdiction over the subject matter of this action 25 pursuant to 28 U.S.C. 1331 and 1338(a) and (b). 26 27 14. This Court has diversity jurisdiction over this dispute under 28 U.S.C. 28 1332 since this dispute exceeds $75,000 and is between citizens of different states.
1317.010\9998

JURISDICTION AND VENUE

The website owned and operated by Jeja is

Complaint

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15.

This Court has supplemental jurisdiction over the state law causes of

2 action pursuant to 28 U.S.C. 1367. 3 4 16. Venue is proper in this district under 28 U.S.C. 1391(b) and (c), 5 and/or 28 U.S.C. 1400(b). 6 7 8 9 A. 10 11 17. Prior to Acolytes entry into the marketplace, there were an extremely 12 limited number of products available that were effective in visually enhancing an 13 event or floral arrangement for a reasonable cost. The dearth of desirable products 14 led to a need for elegant and innovative lighting products that could be used to adorn 15 and lighten the environment, dcor and floral arrangements. 16 17 18. After its inception in 2002, Acolyte addressed this need by creating, 18 designing, manufacturing, marketing and selling its new and original wireless LED 19 lighting products. 20 21 19. Acolytes products were and continue to be meticulously designed and 22 engineered according to Acolytes product specifications, using Acolytes own 23 product molds. The design and engineering process was and continues to be a 24 painstaking process that often takes about year to conclude from the time of 25 conception through to completion, with multiple revisions along the way. Acolytes 26 products are constructed using high-quality materials and electronic components 27 that meet Acolytes specifications and demands for quality and excellence that are 28 only found in authentic Acolyte products.
1317.010\9998

FACTS COMMON TO ALL COUNTS

ACOLYTES INTELLECTUAL PROPERTY RIGHTS

Complaint

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20.

Through the hard work of its management and dedicated employees,

2 Acolyte developed an extremely successful business designing, manufacturing, 3 marketing, and selling many different types of LED lighting products on a 4 wholesale basis throughout the United States and in various markets around the 5 world. 6 7 21. As a result, many LED lighting products sold by Acolyte have enjoyed 8 tremendous success and notoriety with its customers. Among Acolytes greatest 9 successes is its original waterproof LED lighting device marketed under the 10 trademark SUBMERSIBLE since 2005. 11 12 22. Acolyte regularly markets, advertises and promotes its 13 SUBMERSIBLE products in industry publications such as Flowers &, Florists 14 Review and other print publications. Acolyte also attends and participates in 15 various trade shows throughout the United States. 16 17 23. In addition to Acolytes own advertising in industry and trade 18 magazines and at trade shows throughout the United States, Acolyte also utilizes a 19 group of independent sales representatives that market and promote Acolytes 20 SUBMERSIBLE product line to customers across the United States on behalf of 21 and for the benefit of Acolyte. 22 23 24. As a result of its own advertising and promotional activities and those 24 of its sales representatives, as well as its own commercial success, Acolyte has built 25 up a significant amount of goodwill under its SUBMERSIBLE product line in the 26 industry and with its customers. 27 28
1317.010\9998

Complaint

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1 2 3 25.

Acolytes Design Patent Rights In recent years, Acolyte has expanded its SUBMERSIBLE product

4 line and sought to protect a number of its newer designs via design patents. In 5 particular, since 2009, Acolyte has filed numerous applications for design protection 6 in the United States and in a number of countries throughout the world, including 7 China, Japan, Europe and Canada. 8 9 26. As a result of Acolytes design application filing program, many of 10 Acolytes newer LED lighting products are already protected by design patents (or 11 analogous forms of protection) in the United States, Europe, China, Canada and 12 Japan. 13 14 27. For example, one of Acolytes designs is covered by U.S. Design On 15 Patent No. D 633,232 and is entitled Lighting Device (the 232 patent). The 16 application for the 232 design patent was filed on November 10, 2009. 17 February 22, 2011, the U.S. Patent Office issued the 232 patent which claimed the 18 ornamental design for a lighting device as shown and described. A copy of this 19 patent is attached hereto as Exhibit A. An illustration of the lighting device that is 20 shown and protected by the 232 patent is presented below: 21 22 23 24 25 26 27 28
1317.010\9998

Complaint

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28.

Another related Acolyte design is covered by U.S. Design Patent No.

2 D 642,299 and is entitled Lighting Device (the 299 patent). The application for 3 the 299 design patent was filed on April 30, 2010. On July 26, 2011, the U.S. 4 Patent Office issued the 299 patent which claimed the ornamental design for a 5 lighting device as shown and described. A copy of this patent is attached hereto as 6 Exhibit B. An illustration of the lighting device that is shown and protected by the 7 299 patent is presented below: 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1317.010\9998

Complaint

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29.

One of the Acolyte products that embodies the designs shown and

2 claimed in the 232 patent and the 299 patent is the Acolyte SUB-9 lighting 3 device which is shown below: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 30. The SUB-9 is a waterproof lighting device having an array of LEDs 19 disposed within a translucent, plastic housing. The SUB-9 lighting device 20 represents one of a number of LED lighting products added to Acolytes 21 SUBMERSIBLE product line. 22 23 24 25 26 27 28
1317.010\9998

Complaint

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1 B. 2 3 4

DEFENDANT JEJA INFRINGES ACOLYTES DESIGN PATENT RIGHTS 31. Upon information and belief, the corporate defendant Jeja International

5 Corp. manufactures, advertises and sells LED lighting devices to supplier(s) and 6 customers located in the United States that infringe the 232 patent and the 299 7 patent. 8 9 32. Jejas infringing products are advertised on its website located at 10 www.jejahk.com. A copy of Jejas website showing the infringing products is 11 attached hereto as Exhibit C. 12 13 33. The infringing lighting devices advertised and sold by Jeja are a virtual 14 copy of the designs that are protected by Acolytes 232 patent and the 299 patent 15 (Copycat SUB-9 Lighting Device). 16 17 18 19 20 21 22 23 24 25 26 27 28
1317.010\9998

Complaint

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34.

For comparison, a photograph of the Copycat SUB-9 Lighting Device

2 as advertised and sold by Jeja through its website is shown beside the designs 3 protected by the 232 patent and the 299 patent: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1317.010\9998

COPYCAT SUB-9

232 DESIGN PATENT

Complaint

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 35. Moreover, a true and accurate electronic copy of Jejas quotation sheet 17 with prices and minimum order quantities (MOQ) depicting the Copycat SUB18 9 Lighting Device and a 14-LED version thereof is attached hereto as Exhibit D. 19 20 36. A photograph of the Copycat SUB-9 Lighting Device as depicted in the 21 Jeja quotation sheet is depicted below: 22 23 24 25 26 27 28
1317.010\9998

COPYCAT SUB-9

299 DESIGN PATENT

Complaint

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1 2 3 4 5 6 7 8 9 10 11 12 37. Jejas Copycat SUB-9 Lighting Device and the infringing 14-LED

13 version thereof are available for viewing on the web on Jejas website at 14 http://www.jejahk.com/en/pro.asp?action=overmore. 15 16 38. Upon information and belief, Jeja manufactures markets and sells

17 infringing lighting devices, such as the Copycat SUB-9 Lighting Device and the 1418 LED version thereof, to U.S. importers and U.S. wholesale distributors directly, via 19 email and through its website www.jejahk.com. 20 21 39. As readily apparent from the illustrations and pictures shown herein,

22 the Copycat SUB-9 Lighting Device and the 14-LED version thereof, which are 23 marketed and sold by Jeja, share the same design features claimed in the 232 patent 24 and the 299 patent. 25 26 40. Upon information and belief, based on the similarities between the

27 Copycat SUB-9 Lighting Device and the 14-LED version thereof, which are 28
1317.010\9998

Complaint

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1 marketed and sold by Jeja, and the designs shown in the 232 patent and the 299 2 patent, an ordinary observer would be deceived into believing that the Copycat 3 SUB-9 Lighting Device and the 14-LED version thereof are the patented product 4 shown in these patents. 5 6 41. Upon information and belief, Jeja is presently shipping a significant 7 amount of infringing products into the United States. 8 9 42. Upon information and belief, a specific shipment of infringing products 10 believed to be originating from Jeja is currently on a ship scheduled to arrive in the 11 United States in September 2011. This particular shipment is more fully discussed 12 in Plaintiffs motion for expedited relief which is filed concurrently with this 13 Complaint. 14 15 C. 16 17 18 43. The individual defendants, through their business La Bonita, market, 19 promote and sell the lighting devices manufactured by Jeja described herein. 20 21 44. For comparison, a photograph of the Copycat SUB-9 Lighting Device 22 as sold by the individual defendants is shown beside the designs protected by the 23 232 patent and the 299 patent: 24 25 26 27 28
1317.010\9998

THE INDIVIDUAL DEFENDANTS INFRINGE ACOLYTES DESIGN PATENT RIGHTS

Complaint

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1 COPYCAT SUB-9 2 3 4 5 6 7 8 9 10 11 12 13 14 15 COPYCAT SUB-9 16 17 18 19 20 21 22 23 24 25 26 27 28

1317.010\9998

232 DESIGN PATENT

299 DESIGN PATENT

Complaint

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45.

Upon information and belief, the individual defendants, through their

2 business La Bonita, purchased the Copycat SUB-9 Lighting Device from a supplier 3 of Jejas products who is currently unidentified but who is known to the individual 4 defendants. 5 6 D. 7 8 46. Upon information and belief, all of the defendants identified herein 9 directly compete with Acolyte in connection with the sale of LED lighting devices 10 for event design. 11 12 47. Upon information and belief, defendants have sold and offered for sale 13 the Copycat SUB-9 Lighting Device to companies and individuals that would 14 otherwise have purchased authentic SUB-9, SUBMERSIBLE and other related 15 products from Acolyte or an authorized distributor of Acolyte. 16 17 48. Upon information and belief, the importation, sale and offer for sale by 18 defendants of infringing LED lighting products is with full knowledge of Acolytes 19 patent rights and business operations. 20 21 49. Upon information and belief, the importation, sale and offer for sale by 22 defendants of infringing LED lighting products is done with intent to unfairly 23 compete with Acolyte. 24 25 50. Acolyte and defendants are direct competitors vying for the business of 26 the same or substantially the same group of customers. 27 28
1317.010\9998

ACOLYTE WILL SUFFER IRREPARABLE HARM

Complaint

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51.

By their infringing acts, defendants have irreparably harmed Acolyte

2 and such injury will continue and grow unless defendants are enjoined by this Court. 3 4 52. Acolyte has built its reputation on the quality and the uniqueness of its 5 products. 6 7 53. The infringing products accused herein are more cheaply constructed 8 and more cheaply priced than the authentic products manufactured and sold by 9 Acolyte. 10 11 54. Defendants importation, distribution, sale and offer for sale of the 12 infringing products accused herein, as well as other copycat products, have created 13 and will continue to create confusion, irreparably damaging Acolytes reputation 14 and goodwill. 15 16 55. Defendants importation, distribution, sale and offer for sale of the 17 infringing products accused herein, as well as other copycat products, has 18 irreparably decreased and will continue to irreparably decrease the size of Acolytes 19 market share and, if not enjoined, will cost Acolyte its position as the market leader. 20 21 56. Defendants importation, distribution, sale and offer for sale of the 22 infringing products accused herein, as well as other copycat products, will result in 23 reduced cash flow to Acolyte and irreparable price erosion of Acolytes patented 24 products in that Acolyte will be forced to drastically change its pricing structure in 25 order to compete with lower-priced, knock-off products. 26 27 57. If defendants are not enjoined from infringing the 232 patent and the 28 299 patent, other potential competitors will be encouraged to distribute knock-off
1317.010\9998

Complaint

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1 products resembling those in the asserted patents, and will flood the market with 2 even more cheaply-made and cheaply-priced copycat products. Some of these 3 potential competitors are Acolytes own current customers. 4 5 58. If defendants are enjoined from infringing the 232 patent and the 299 6 patent, other infringing competitors will be deterred from continuing to infringe 7 Acolytes patents and will be deterred from doing so in the future. 8 9 59. If defendants are not enjoined from infringing the 232 patent and the 10 299 patent, Acolyte will lose sales of related products that are not protected by 11 Acolytes patents and/or other forms of intellectual property. 12 13 60. Due to defendants actions, Acolyte is deeply concerned that it will lose 14 a number of customers. 15 16 61. Because of Acolytes business and reputation, as well as the value of its 17 patents, Acolyte will be irreparably harmed if defendants are not enjoined, and 18 money damages cannot sufficiently compensate Acolyte for the damage caused by 19 defendants infringing acts. 20 21 62. In contrast, none of the defendants will suffer any recognizable 22 irreparable harm if they are enjoined. 23 24 25 26 27 63. Acolyte hereby repeats and re-alleges paragraphs 1 through 63 above as 28 if fully set forth herein.
1317.010\9998

COUNT I (Patent Infringement of U.S. Patent D 633,232)

Complaint

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64.

The 232 patent, was legally issued on February 22, 2011 and is

2 entitled Lighting Device. 3 4 65. Acolyte is the owner, by assignment, of all right, title and interest in 5 and to the 232 patent. 6 7 66. Upon information and belief, defendants have manufactured, imported, 8 distributed offered for sale and/or sold, and continue to manufacture, import, 9 distribute, offer for sale and/or sell LED lighting devices that infringe the 232 10 patent. 11 12 67. Defendants have been and continue to infringe the 232 patent by 13 manufacturing, importing, distributing, offering for sale and/or selling lighting 14 devices embodying the patented invention claimed in the 232 patent and/or will 15 continue to do so unless enjoined by this Court. 16 17 68. The infringement by defendants of the 232 patent is in direct violation 18 of Acolytes right under 35 U.S.C. 271 to exclude others from making, using, 19 selling and/or offering for sale products embodying the invention of the 299 patent. 20 21 69. Upon information and belief, each infringement has been willful and 22 deliberate. 23 24 70. Acolyte has been damaged by defendants infringements of the 232 25 patent, in an amount to be determined at trial and in an amount adequate to 26 compensate plaintiffs injuries. 27 28
1317.010\9998

Complaint

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71.

Acolyte is entitled to an accounting for damages from defendants for

2 the infringement of the 232 patent. 3 4 72. The infringement of the 232 patent by defendants has caused Acolyte 5 to suffer irreparable harm and injury. Acolyte will continue to suffer irreparable 6 harm unless an injunction is issued enjoining and restraining defendants from 7 infringing the 232 patent. 8 9 73. Acolyte has been damaged by the acts of defendants in an amount as 10 yet unknown, but on information and belief, has caused damage or will cause 11 damage to Acolyte in excess of one million dollars ($1,000,000) 12 13 14 15 16 17 18 75. Acolyte hereby repeats and re-alleges paragraphs 1 through 75 above as 19 if fully set forth herein. 20 21 76. The 299 patent, was legally issued on July 26, 2011 and is entitled 22 Lighting Device. 23 24 77. Acolyte is the owner, by assignment, of all right, title and interest in 25 and to the 299 patent. 26 27 78. Upon information and belief, defendants have manufactured, imported, 28 distributed offered for sale and/or sold, and continue to manufacture, import,
1317.010\9998

74.

Acolyte has no adequate remedy at law.

COUNT II (Patent Infringement of U.S. Patent D 642,299)

Complaint

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1 distribute, offer for sale and/or sell LED lighting devices that infringe the 299 2 patent. 3 4 79. Defendants have been and continue to infringe the 299 patent by 5 manufacturing, importing, distributing, offering for sale and/or selling lighting 6 devices embodying the patented invention claimed in the 299 patent and will 7 continue to do so unless enjoined by this Court. 8 9 80. The infringement by defendants of the 299 patent is in direct violation 10 of Acolytes right under 35 U.S.C. 271 to exclude others from making, using, 11 selling and/or offering for sale products embodying the invention of the 299 patent. 12 13 81. Upon information and belief, each infringement has been willful and 14 deliberate. 15 16 82. Acolyte has been damaged by defendants infringements of the 299 17 patent, in an amount to be determined at trial and in an amount adequate to 18 compensate plaintiffs injuries. 19 20 83. Acolyte is entitled to an accounting for damages from defendants for 21 the infringement of the 299 patent. 22 23 84. The infringement of the 299 patent by defendants has caused Acolyte 24 to suffer irreparable harm and injury. Acolyte will continue to suffer irreparable 25 harm unless an injunction is issued enjoining and restraining defendants from 26 infringing the 299 patent. 27 28
1317.010\9998

Complaint

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85.

Acolyte has been damaged by the acts of defendants in an amount as

2 yet unknown, but on information and belief, has caused damage or will cause 3 damage to Acolyte in excess of one million dollars ($1,000,000) 4 5 6 7 8 9 10 87. Acolyte hereby repeats and re-alleges paragraphs 1 through 87 above as 11 if fully set forth herein. 12 13 88. Defendants unlawful and improper actions as set forth herein 14 misappropriate and trade upon the fine reputation and goodwill of Acolyte, thereby 15 injuring that reputation and goodwill, and unjustly diverting from Acolyte to 16 defendants the sales and benefits rightfully belong to Acolyte. 17 18 89. Defendants unlawful activities constitute unfair competition and 19 misappropriation as proscribed by the common law. 20 21 90. Defendants acts of unfair competition and misappropriation have 22 caused Acolyte to sustain monetary damage, loss and injury. 23 24 91. Defendants have engaged and continue to engage in these activities 25 knowingly and willfully. 26 27 28
1317.010\9998

86.

Acolyte has no adequate remedy at law.

COUNT III (Unfair Competition and Misappropriation under the Common Law)

Complaint

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92.

Defendants acts of unfair competition and misappropriation, unless

2 enjoined by this Court, will continue to cause Acolyte to sustain irreparable damage, 3 loss and injury. 4 5 93. Acolyte has been damaged by the acts of defendants in an amount as 6 yet unknown, but on information and belief, has caused damage or will cause 7 damage to Acolyte in excess of one million dollars ($1,000,000) 8 9 10 11 12 13 WHEREFORE, Acolyte respectfully prays for judgment against defendants 14 as follows: 15 16 17 18 A. That the 232 patent and the 299 patent were duly and legally issued, 19 are valid and are enforceable; 20 21 B. That defendants have directly infringed, contributorily infringed and/or 22 induced the infringement of the 232 patent and the 299 patent; 23 24 C. That defendants have willfully infringed the 232 patent and the 299 25 patent; 26 27 28
1317.010\9998

94.

Acolyte has no adequate remedy at law.

PRAYER FOR RELIEF

With respect to Counts I&II:

Complaint

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1 2 3

With respect to Count III: D. That defendants are liable for and unfairly competing and

4 misappropriating; 5 6 7 8 E. That this Court enter a preliminary and permanent injunction against 9 defendants (and each of their affiliates, officers, agents, servants, employees and 10 attorneys, and all persons in active concert or participation with them) 11 12 13 14 15 16 17 18 19 20 21 22 23 F. That defendants deliver and/or destroy all materials, packaging, labels, 24 tags, pamphlets, brochures, signs, sales literature, stationary, advertisements, 25 contracts, billboards, banners, posters, documents, as well as all plates, molds, 26 matrices, negatives, masters and all other means of making products which if used 27 would violate the terms of the Order herein granted; 28
1317.010\9998

With respect to all Counts:

1) enjoining defendants from committing further acts of infringement of the 232 patent and the 299 patent; 2) enjoining defendants from engaging in any acts of common law unfair competition or misappropriation which would damage or injure plaintiff; and 3) enjoining defendants from inducing, encouraging, instigating, aiding, abetting or contributing to any third-party usage of Acolytes design patents in connection with defendants business.

Complaint

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Table of Exhibits
Exhibit No. Description Pages

A B C D

United States Design Patent US D633,232, Lighting Device, dated February 22, 2011 United States Design Patent US D642,299, Lighting Device, dated July 26, 2011 Jeja Website Capture http://www.jejahk.com Jeja Quote Sheet for Submersible LED Light

26-30 31-35 36-38 39-43

'11CV2012 MMA CAB