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Flow Valve v. Forum Energy Technologies et. al.

Flow Valve v. Forum Energy Technologies et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00113-FHS: Flow Valve, LLC v. Forum Energy Technologies, Inc. et. al. Filed in U.S. District Court for the Eastern District of Oklahoma, the Hon. Frank H. Seay presiding. See http://news.priorsmart.com/-l7RF for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-00113-FHS: Flow Valve, LLC v. Forum Energy Technologies, Inc. et. al. Filed in U.S. District Court for the Eastern District of Oklahoma, the Hon. Frank H. Seay presiding. See http://news.priorsmart.com/-l7RF for more info.

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Published by: PriorSmart on Mar 29, 2013
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09/02/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF OKLAHOMAFLOW VALVE, LLC, an Oklahomalimited liability company,Plaintiff,v. Case No. 6:13-cv-113-FHS(1) FORUM ENERGY TECHNOLOGIES, INC., a Delawarecorporation,AND(2) WOOD FLOWLINEPRODUCTS, LLC, an Oklahoma limitedliability company,Defendants.
COMES NOW, Plaintiff, Flow Valve, LLC, (“Plaintiff”), by its attorneys, and forits Complaint against Defendants, Forum Energy Technologies, Inc. (“FET”) and WoodFlowline Products, LLC (“WFP”), states and alleges as follows:
COMPLAINT
1.
 
 This is an action for patent infringement.
Nature of the Action
2.
 
Plaintiff is an Oklahoma limited liability company having its principalplace of business in Sulphur, Oklahoma.
 The Parties
6:13-cv-00113-FHS Document 2 Filed in ED/OK on 03/28/13 Page 1 of 5
 
2
3.
 
Upon information and belief, Defendant FET is a for profit corporationorganized under the laws of the state of Delaware, and has its principal place of businessin Houston, Texas.
4.
 
Upon information and belief, Defendant WFP is an Oklahoma limitedliability company having its principal place of business in Sulphur, Oklahoma.
5.
 
Upon information and belief, Defendant WFP is wholly-owned by itsparent company, FET.
 
6.
 
 This Court has subject matter jurisdiction over this action under at least28 U.S.C. §§ 1338 and 2201.
 Jurisdiction and Venue
7.
 
 This Court has personal jurisdiction over Defendant WFP becauseDefendant is a citizen of Oklahoma and committed acts of infringement in Oklahoma.
8.
 
 This Court has personal jurisdiction over Defendant FET becauseDefendant is doing business in Oklahoma, has many economically significant contacts inOklahoma, and committed acts of infringement in Oklahoma.
9.
 
Venue is appropriate in the Eastern District of Oklahoma, pursuant to28 U.S.C. § 1391 in that a substantial part of the events or omissions giving rise toPlaintiff’s claims occurred in the Eastern District.
 
10.
 
Plaintiff is the owner of United States Letters Patent 8,215,213 (“the 213patent”), entitled WORKPIECE SUPPORTING ASSEMBLY, which issued on July 10,
Allegations of Fact
6:13-cv-00113-FHS Document 2 Filed in ED/OK on 03/28/13 Page 2 of 5
 
32012 and relates to an industrial assembly used by Plaintiff to secure and hold pieces of bent tubing, while the pieces are machined. The pieces thus manufactured in this mannerare ultimately assembled into finished products and are sold for use in the oil and gaswell completion and production business.
11.
 
Employees of Defendant, who at the time were then partial equity ownersof Plaintiff, organized WFP and in the Fall of 2008, left their employment with Plaintifand assigned their ownership in the Plaintiff limited liability company to the remainingowners of Plaintiff.
12.
 
WFP began operations in the Fall of 2008. It is a direct competitor of Plaintiff in the manufacture and sale of many products.
13.
 
 The now former employees and former partial equity owners of Plaintiff who organized and owned Defendant WFP were aware of the invention by Plaintiff of thenow patented Supporting Assembly and they were aware of Plaintiffs use of theSupporting Assembly, while they were employees and equity owners in the Plaintiflimited liability company.
COUNT I - PATENT INFRINGEMENT
14.
 
Paragraphs 1-13 above are incorporated herein by reference.
15.
 
WFP infringed the '213 patent-in-suit by making the patented inventionseveral times and then using that patented invention to manufacture products, which itsold and continues to sell.
6:13-cv-00113-FHS Document 2 Filed in ED/OK on 03/28/13 Page 3 of 5

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