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R&J Manufacturing v. B&G International

R&J Manufacturing v. B&G International

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: R&J Manufacturing, Inc. v. B&G International, Inc. Filed in U.S. District Court for the District of Rhode Island, no judge yet assigned. See http://news.priorsmart.com/-l7bv for more info.
Official Complaint for Patent Infringement in Civil Action No. None: R&J Manufacturing, Inc. v. B&G International, Inc. Filed in U.S. District Court for the District of Rhode Island, no judge yet assigned. See http://news.priorsmart.com/-l7bv for more info.

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Published by: PriorSmart on Dec 04, 2012
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09/18/2013

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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF RHODE ISLAND
)
R&J MANUFACTURING, INC.,
)
Plaintiff
))
vs.
)
C.
A.
No.
)
B&G INTERNATIONAL, INC.,
)
Jury Trial DemandedDefendant
)
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COMPLAINT
Plaintiff, R&J Manufacturing, Inc. ("R&J"
or
"Plaintiff'), brings this action against,defendant, B&G International, Inc. ("B&G"
or
"Defendant"), for patent infringement.
By
thisComplaint, R&J seeks,
inter alia,
injunctive relief and monetary damages, and alleges asfollows:
THE
PARTIES
1.
Plaintiff is a Rhode Island corporation, with its principal place
of
business at 1Carding Lane, Johnston, RI 02919. R&J is the owner
of
numerous patents pertaining
to
electronic article surveillance devices and tags. Among the patents owned by R&J are U.S.Letters Patents Nos. 7,626,501 and 7,518,521, as well as U.S. Design Patent No. D543,590, all
of
which disclose embodiments
of
anti-theft tags.2. Upon information and belief, Defendant is a Delaware corporation with aprincipal place
of
business located at 37 Empire Street, Newark, NJ, 07114.Page 1
-n
-
r
m
0
 
JURISDICTION
AND VENUE
3.
This action arises under the patent laws
of
the United States, 35 U.S.C.
§§
271,281, 283-285.4. This Court has original and exclusive jurisdiction over the subject matter
of
thisComplaint pursuant to 28 U.S.C.
§
1338(a) because this action arises
1.mder
an act
of
Congressrelating to patents. Jurisdiction is also conferred under, 28 U.S.C.
§§
1331 because this is a civilaction arising under the laws
of
the United States.
5.
Plaintiff is informed and believes that this Court may properly exercise
in
personam
jurisdiction over the Defendant because the Defendant regularly conducts business
in
the State
of
Rhode Island and has sufficient minimum contacts with Rhode Island. Plaintiff isinformed and believes that Defendant sells its products to retailers having retail stores in RhodeIsland.
6.
Venue is proper in this District under 28 U.S.C.
§
1391
(b)
and (c).
THE
ASSERTED
PATENTS
7.
United States Design Patent No. D543,590 entitled "Rotating Anti-Theft Tag"(the
'"590
patent"), issued
on
May 29,2007 on an application filed
on
February 3, 2006. The'590 patent is assigned to
R&J.
A true and correct copy
of
the '590 patent is attached hereto asExhibit A.
8.
United States Letters Patent No. 7,518,521 entitled "Rotating Anti-Theft Tag"(the '"521 patent"), issued
on
Aprill4,
2009 on an application filed
on
February 3, 2006. The
Page2
 
'52 I patent is assigned to R&J. A true and con·ect copy
of
he '52 I patent is attached hereto asExhibit
B.
9. United States Letters Patent No. 7,626,50I entitled, "Anti-Theft Tag" (the
'"50I
patent"), issued
on
December
I,
2009 on an application filed on
Aprili6,
2007. The
'50
I patentis assigned to R&J. A true and correct copy
of
the
'50
I patent is attached hereto as Exhibit C.
BACKGROUND
FACTS
7.
R&J is the assignee
of
the '590, '52 I and
'50
I patents by
Nunc
Pro Tunc
Assignment executed by Display Technologies, effective August 3, 20I2, including the right tosue for past infringement. Display Technologies was the assignee
of
the 590, '52 I and '501patents since their issuance.8. Defendant B&G is a wholesale manufacturer
of
security tags and hangers.
9.
Upon information and beliefB&G is offering for sale, makes, uses and sells a"swivel tag", a photo
of
which is attached hereto as Exhibit D, which swivel tag infringes one ormore claims
of
the '52 I and
'50
1 patents.I
0.
Upon information and belief, B&G is offering for sale, makes, uses and sells a"swivel tag", a photo
of
which is attached hereto as Exhibit E, which swivel tag infringes one
or
more claims
of
the '590,
'52
I and
'50I
patents.
II.
B&G has been given written notice
of
infringement by letter dated January 20,20I2 by Display Technologies, predecessor assignee to R&J
of
he
'52
I and '50 I patentsalleging infringement
of
said patents by the swivel tag
of
Exhibit
D.
I2. B&G has been given written notice
of
infringement by letter dated November I9,2012 by R&J alleging infringement
of
he '52 I and
'50
I patents by the swivel tag
of
Exhibit D.
Page3

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