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Ultradent Products v. Ranir

Ultradent Products v. Ranir

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00361-EJF: Ultradent Products, Inc. v. Ranir. Filed in U.S. District Court for the District of Utah, the Hon. Evelyn J. Furse presiding. See http://news.priorsmart.com/-l8sJ for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00361-EJF: Ultradent Products, Inc. v. Ranir. Filed in U.S. District Court for the District of Utah, the Hon. Evelyn J. Furse presiding. See http://news.priorsmart.com/-l8sJ for more info.

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Published by: PriorSmart on May 21, 2013
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04/25/2014

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1BRENTP. LORIMER (A3731;blorimer@wnlaw.com)THOMAS R. VUKSINICK (A3341;tvuksinick@wnlaw.com)SARAH E. JELSEMA (13885;sjelsema@wnlaw.com)
WORKMAN│NYDEGGER A
P
ROFESSIONAL
C
ORPORATION
60 East South Temple, Suite 1000Salt Lake City, UT 84111Telephone: (801) 533-9800Facsimile: (801) 328-1707Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURTDISTRICTOF UTAH, CENTRAL DIVISIONULTRADENTPRODUCTS, INC., a Utahcorporation,Plaintiff,v.RANIR LLC, a Delaware limited liabilitycompany,Defendant.))))))))))))))Civil Action No. 2:13-cv-00361COMPLAINTJURY TRIAL DEMANDEDHonorable Magistrate Judge Evelyn J. FursePlaintiff Ultradent Products, Inc. complains and alleges against defendant Ranir LLC, asfollows:
PARTIES
1. Plaintiff Ultradent Products, Inc., (“Ultradent”) is a Utah corporation having a principal place of business at 505 West 10200 South, South Jordan, Utah 84065.2. Defendant Ranir LLC (“Ranir”) is a Delaware limited liability company with its principal place of business at 4701 East Paris Avenue, S.E., Grand Rapids, MI 49512.
 
2
JURISDICTIONAND VENUE
3. This is a civil action for patent infringement brought by Ultradent for infringement committed by Ranir arising under the patent laws of the United States, and morespecifically, under Title 35 U.S.C. §§ 271, 281, 283, 284 and 285. Jurisdiction of this court isfounded upon 28 U.S.C.§§ 1331 and 1338(a).4. Upon information and belief, Ranir has transacted business, contracted to supplygoods or services, and caused injury within the state of Utah, and has otherwise purposelyavailed itself of the privileges and benefits of the laws of the state of Utah, and is thereforesubject to the jurisdiction of this court pursuant to Fed.R.Civ.P. 4(k)(1)(A) and § 78B-3-205,Utah Code Ann.5. Venue is proper in this district pursuant to 28 U.S.C. §§ 1400(b) and 1391.
FACTUALBACKGROUND
6. U.S. Patent No. 6,730,316 (“the ‘316 patent”) issued on May 4, 2004 bearing thetitle “Dental Bleach.” (Exhibit A.)7. U.S. Patent No. 7,128,899 (“the ‘899 patent”) issued on October 31, 2006 bearingthe title “Bleaching Device Comprising Barrier Layer and a Bleaching Composition ComprisingPolyvinylpyrrolidone.” (Exhibit B).8. U.S. Patent No. 7,862,801 (“the ‘801 patent”) issued on January 4, 2011 bearingthe title “Adhesive Dental Bleaching Compositions Comprising Polyvinylpyrrolidone.”(Exhibit C).
 
39. U.S. Patent No. 7,004,756 (“the ‘756 patent”) issued on February 28, 2006 bearing the title “Pre-shaped Dental Trays and Treatment Devices and Methods that Utilize SuchDental Trays.” (Exhibit D).10. U.S. Patent No. 6,964,571 (“the ‘571 patent”) issued on November 15, 2005 bearing the title “Pre-shaped Dental Trays and Treatment Devices and Methods that Utilize SuchDental Trays.” (Exhibit E).11. U.S. Patent No. 7,481,653 (“the ‘653 patent”) issued on January 27, 2009 bearingthe title “Pre-shaped Thin-Walled Dental Trays and Methods of Manufacturing and Using SuchTrays.” (Exhibit F).12. U.S. Patent No. 7,048,543 (“the ‘543 patent”) issued on May 23, 2006 bearing thetitle “Substantially Solid Bleaching Composition and a Tray-Like Configuration.” (Exhibit G).13. U.S. Patent No. 8,007,277 (“the ‘277 patent”) issued on August 30, 2011 bearingthe title “Non-custom Dental Treatment Trays and Mouth Guards Having Improved AnatomicalFeatures.” (Exhibit H).14. U.S. Patent No. 8,444,413 (“the ‘413 patent”) issued on May 21, 2013 bearing thetitle “Non-custom Dental Treatment Trays Having Improved Anatomical Features.” (Exhibit I).15. Ultradent is the owner by assignment of the ‘316, ‘899, ‘801, ‘756, ‘571, ‘653,‘543, ‘277, and ‘413 patents (the “Asserted Patents”).16. Prior to the filing of this Complaint Ranir approached Ultradent in an attempt tolicense the ‘899 and ‘801 patents. Ultradent did not agree to license the ’899 and ‘801 patents toRanir, but during the negotiations Ranir was given copies of the ‘316, ‘756, ’653, ‘543, and ‘277 patents.

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