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Glen M. Diehl Matthew P.

Hintz DIEHL SERVILLA LLC 33 Wood Avenue South Second Floor, Suite 210 Iselin, NJ 08830 Telephone: (732) 815-0404 Facsimile: (732) 815-1330 Email: gdiehl@dsiplaw.com

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Stanton Concepts, L.L.C., Plaintiff, v. Safe Skies LLC, Defendant.

Civil Action No. ______________ COMPLAINT JURY TRIAL DEMANDED

Plaintiff Stanton Concepts, L.L.C. ("Stanton Concepts"), for its complaint against Defendant Safe Skies LLC ("Safe Skies"), alleges as follows: NATURE OF THE ACTION 1. This is a civil action for infringement arising under the United States Patent Laws,

35 U.S.C. 101, et seq., and for such other relief as the Court deems just and proper. PARTIES 2. Stanton Concepts is a limited liability company organized and existing under the

laws of the State of New Jersey, having a place of business at 172 Stanton Road, P.O. Box 139, Stanton, NJ 08885.

3.

On information and belief, Safe Skies is a limited liability company organized and

existing under the laws of the State of New York, having a place of business at 954 Third Avenue, Suite 504, New York, NY 10022. JURISDICTION AND VENUE 4. This is an action arising under the patent laws of the United States. Accordingly,

this Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a). 5. This Court has personal jurisdiction over Safe Skies. On information and belief,

Safe Skies has significant contacts with this forum because Safe Skies manufactures (directly or indirectly through subsidiaries, divisions or third party manufacturers) and/or assembles products that are and have been offered for sale, sold, purchased, and used in the District of New Jersey. On information and belief, Safe Skies, directly and/or through its distribution network, place infringing devices within the stream of commerce, with the knowledge and/or understanding that such infringing devices are sold in the District of New Jersey. Moreover, on information and belief, Safe Skies expect or should reasonably expect its infringing actions to have consequences in the District of New Jersey. Therefore, exercise of jurisdiction over Safe Skies will not offend traditional notions of fair play and substantial justice. Such an exercise is consistent with New Jersey's long-arm rule pursuant to N.J. Court R. 4:4-4. 6. Venue is proper in this District pursuant to 28 U.S.C. 1391(b)(c) and 1400(b). FACTUAL BACKGROUND 7. This is an action brought by Stanton Concepts against Safe Skies for Safe Skies'

infringement of U.S. Patent No. 7,913,526 ("the '526 patent"). 8. The '526 patent, entitled "Multiple Function Lock," issued on March 29, 2011. A

copy of the '526 patent is attached to this Complaint as Exhibit 1.

9. 10.

The '526 patent is valid and enforceable under the patent laws of the United States. Stanton Concepts is the owner of all right, title and interest in the '526 patent,

including the right to bring this suit for injunctive relief and damages. COUNT I INFRINGEMENT OF U.S. PATENT NO. 7,913,526 11. Stanton Concepts incorporates by reference the preceding averments set forth in

paragraphs 1 to 10. 12. On information and belief, Safe Skies has infringed and is still infringing,

contributorily infringing or inducing infringement of the '526 patent, in violation of 35 U.S.C. 271 et seq., either directly and/or indirectly, literally or under the doctrine of equivalents, by their making, using, offering for sale and selling in the United States, and/or importing into the United States, without authority, products that infringe one or more claims of the '526 patent. 13. Safe Skies' infringing activities have caused and will continue to cause Stanton

Concepts irreparable harm, for which it has no adequate remedy at law, unless Safe Skies' infringing activities are enjoined by this Court in accordance with 35 U.S.C. 283. 14. Stanton Concepts has been and continues to be damaged by Safe Skies'

infringement of the '526 patent in an amount to be determined at trial. 15. On information and belief, Safe Skies' infringement of the '526 patent is willful and

deliberate, and justifies an increase in damages of up to three times in accordance with 35 U.S.C. 284. 16. On information and belief, Safe Skies' infringement of the '526 patent is exceptional

and entitles Stanton Concepts to attorneys fees and costs incurred in prosecuting this action under 35 U.S.C. 285.

REQUEST FOR RELIEF WHEREFORE, Stanton Concepts respectfully requests that: (a) Judgment be entered that Safe Skies have infringed one or more claims of the '526 patent; (b) Judgment be entered permanently enjoining Safe Skies, their directors, officers, agents, and employees, and those acting in privity or in concert with them, and their subsidiaries, divisions, successors and assigns, from further acts of infringement, contributory infringement, or inducement of infringement of the '526 patent; (c) Judgment be entered awarding Stanton Concepts all damages adequate to compensate it for Safe Skies' infringement of the '526 patent, including all pre-judgment and post-judgment interest at the maximum rate permitted by law; (d) Judgment be entered that Safe Skies' infringement of the '526 patent is willful and deliberate, and therefore, that Stanton Concepts is entitled to treble damages as provided by 35 U.S.C. 284; (e) Judgment that this case is declared an exceptional case within the meaning of 35 U.S.C. 285, entitling Stanton Concepts to an award of its attorneys fees and costs incurred in connection with this action; and (f) Judgment be entered awarding Stanton Concepts such other and further relief as this Court may deem just and proper.

DEMAND FOR JURY TRIAL Pursuant to Fed. R. Civ. P. 38(b) and L. Civ. R. 38.1, Stanton Concepts demands a trial by jury on all issues so triable.

Dated: December 15, 2011

Respectfully submitted, s/ Glen M. Diehl Glen M. Diehl, Esq. DIEHL SERVILLA LLC 33 Wood Avenue South Second Floor, Suite 210 Iselin, NJ 08830 Telephone: (732) 815-0404 Facsimile: (732) 815-1330 Email: gdiehl@dsiplaw.com Attorneys for Plaintiff

CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 11.2 I herby certify that the '526 patent is not the subject of any other action pending in any other court.

Dated: December 15, 2011

Respectfully submitted, s/ Glen M. Diehl Glen M. Diehl, Esq. DIEHL SERVILLA LLC 33 Wood Avenue South Second Floor, Suite 210 Iselin, NJ 08830 Telephone: (732) 815-0404 Facsimile: (732) 815-1330 Email: gdiehl@dsiplaw.com Attorneys for Plaintiff