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CAO Group v. Foxfury

CAO Group v. Foxfury

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00345-DB: CAO Group v. Foxfury. Filed in U.S. District Court for the District of Utah, the Hon. Dee Benson presiding. See http://news.priorsmart.com/-l8qM for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00345-DB: CAO Group v. Foxfury. Filed in U.S. District Court for the District of Utah, the Hon. Dee Benson presiding. See http://news.priorsmart.com/-l8qM for more info.

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Published by: PriorSmart on May 16, 2013
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 C.J. Veverka (Bar No. 07110)cveverka@mabr.comKirk R. Harris (Bar No. 10221)kharris@mabr.comMark W. Ford (Bar No. 10629)mford@mabr.com
 MASCHOFF BRENNAN
201 South Main Street, Suite 600Salt Lake City, UT 84111Telephone: (435) 252-1360Facsimile: (435) 252-1361
 
 Nathaniel L. Dilger (
 Pro hac vice application
forthcoming)ndilger@onellp.comPeter R. Afrasiabi (
 Pro hac vice
applicationforthcoming) pafrasiabi@onellp.com
ONE LLP
4000 MacArthur Blvd.West Tower, Suite 1100 Newport Beach, CA 92660Telephone: (949) 502-2870Facsimile: (949) 258-5081
  Attorneys for Plaintiff, CAO GROUP, INC.
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF UTAH, CENTRAL DIVISION
CAO GROUP, INC., a Utah Corporation,
COMPLAINT
JURY DEMANDPlaintiff,v.FOXFURY, LLC, a California LimitedLiability CompanyCase No. 2:13-cv-00345-DBJudge David Nuffer Defendant.
Plaintiff CAO Group, Inc. (“CAO”)
hereby complains and alleges against Defendant
FoxFury, LLC (“FoxFury”
 
or “Defendant”
) as follows:
PARTIES
1.
 
Plaintiff CAO is a Utah corporation located at 4628 West Skyhawk Drive, WestJordan, UT 84084.
 
 22.
 
On information and belief, Defendant FoxFury is a California limited liabilitycompany with a principal place of business located at 2091 Elevado Hills Dr., Vista, CA 92084.
NATURE OF THE ACTION
3.
 
This is an action for patent infringement arising under the Patent Laws of theUnited States 35 U.S.C. §§ 1
et seq
., including 35 U.S.C. § 271.4.
 
On information and belief, Defendants have infringed and continue to infringe,contribute to the infringement of, and/or actively induce others t
o infringe CAO’s U.S. Patent
 Nos.
6,954,270 (the “’270
Patent
), 7,252,678
(the “’678 Patent”),
 
and 7,267,457 (the “’457Patent”)
 
(collectively “the Asserted Patents”)
.
JURISDICTION AND VENUE
5.
 
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§§ 1331 and 1338.6.
 
This Court has personal jurisdiction over Defendant FoxFury because, oninformation and belief, FoxFury does and has done substantial business in this judicial District,including: (i) committing acts of patent infringement and/or contributing to or inducing acts of  patent infringement by others in this judicial District and elsewhere in Utah; (ii) regularlyconducting business in this State and judicial District; (iii) directing advertising to or soliciting business from persons residing in this state and judicial District; and (iv) engaging in other  persistent courses of conduct, and/or deriving substantial revenue from products and/or services provided to persons in this District and State.7.
 
Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b).
FACTUAL BACKGROUND
8.
 
Plaintiff CAO designs, develops, manufactures, and markets various products,including but not limited to forensic lights.
 
 39.
 
CAO has sought protection for its technological innovations, which has resultedin numerous issued patents, including the Asserted Patents.10.
 
T
he ’
270 Patent issued on October 11, 2005
, and is titled “
Method for DetectingForensic Evidence.
CAO is the owner by assignment of the ’
270 Patent.11.
 
The ’
457 Patent issued on September 11, 2007
, and is titled “
Method for Detecting Forensic Evidence.
CAO is the owner by assignment of the ’
457 Patent.12.
 
The ’678 Patent issued on August 7, 2001, and is titled “Forensic Light UsingSemiconductor Light Source.” CAO is the owner by assignment of the ’678 Patent.
13.
 
Defendant develops, markets, and/or manufactures a number of 
“Application
-
Specific products, with a focus in Professional Portable LED Lighting,” including forensic lights.
See 
 
On information and belief, Defendant FoxFury operates and maintains a websiteat www.foxfury.com, where
FoxFury’
s products, including its forensic lights, are marketed toconsumers, including consumers in Utah.15.
 
Some of FoxFury’s
forensic lights are marketed and sold under the
Hammer Head,
 
“MF,” and “Rook”
series of products (including, for example, the
Rook Blue 450 + 470nm FLS
). From the Rook series of products, the
Rook Blue 450 + 470 nm FLS
is anexemplary product that infringes the Asserted Patents and is re
ferred to as the “Accused
Product
.”
16.
 
Upon information and belief, FoxFury has posted videos of exemplar uses andinstructions for use of its forensic lights.
See, e.g.

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