Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1

Ratings: (0)|Views: 59 |Likes:
Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00420: . Filed in U.S. District Court for the Middle District of North Carolina, no judge yet assigned. See http://news.priorsmart.com/-l8tN for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00420: . Filed in U.S. District Court for the Middle District of North Carolina, no judge yet assigned. See http://news.priorsmart.com/-l8tN for more info.

More info:

Published by: PriorSmart on May 23, 2013
Copyright:Public Domain

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

05/24/2013

pdf

text

original

 
 
IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF NORTH CAROLINACase No. 13-cv-420CAMCO MANUFACTURING, INC.,Plaintiff,v.SEISCO INTERNATIONAL LIMITED,Defendant.COMPLAINT FOR PATENTINFRINGEMENTJURY TRIAL DEMANDED
Plaintiff Camco Manufacturing, Inc. (“Camco”) for its Complaint for PatentInfringement against Seisco International Limited (“Seisco”) alleges the following:1.
 
This action arises out of Seisco’s infringement of patents, utility and designpatents, on novel designs and inventions concerning drain pans for tankless water heaters.This is an action for injunctive and monetary relief.
THE PARTIES
2.
 
Camco is a corporation duly organized and existing under the laws of theState of North Carolina with a principal place of business and its headquarters inGreensboro, North Carolina. Camco is a leading manufacturer of a number of products,including a variety of plumbing products related to water heaters. As part of its productsuite related to water heaters, Camco manufactures and sells drain pans for use withtankless water heaters.
 
2
3.
 
Upon information and belief, Seisco is a corporation duly organized andexisting under the laws of the State of Texas with a principal place of business and itsheadquarters in Houston, Texas. Upon information and belief, Seisco supplies tanklesswater heaters and related products.
JURISDICTION AND VENUE
4.
 
Camco brings this action for patent infringement under the patent laws of the United States, namely 35 U.S.C. §§ 271, 281, 284, 285 and 289 among others. ThisCourt has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1338(a).5.
 
Seisco is subject to personal jurisdiction in the Middle District of NorthCarolina (the “District”), consistent with the principles of due process and the NorthCarolina Long Arm Statute. Upon information and belief, Seisco has sold and offered forsale infringing products in this District, has committed, induced and contributed to acts of patent infringement in this District, has placed infringing products into the stream of commerce through established distribution channels with the expectation that suchproducts will be purchased by residents of this District, has purposefully establishedsubstantial, systematic and continuous contacts within this District such that it expects orshould reasonably expect to be haled into court in this District, and has caused injury toPlaintiff in this District and/or the claims arose in this District. Seisco has sought to serveresidents of this District by designating on its website a sales representative specificallyfor handling sales in North Carolina. The actions of Seisco described in this paragraphform a substantial part of the events giving rise to this lawsuit.
 
3
6.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(c) and1400(b).
GENERAL ALLEGATIONS
7.
 
Camco is the exclusive licensee of two U.S. Patents (Asserted Patents”),both entitled Drain Pan for Mounted Water Equipment: 8,104,634 B2 (the “’634 Patent”)and D653,745 S (the “’745 Patent”). True and correct copies of the ‘634 Patent(Exhibit A) and ‘745 Patent (Exhibit B) are attached.8.
 
Camco received all substantial rights to the Asserted Patents in Septemberof 2012, through a License Agreement with the owner of the patents. In particular, theLicense Agreement provides Camco with the “exclusive right” to seek abatement of patent infringement for the entire term of the Asserted Patents and otherwise to sue forpatent infringement and all recoveries therefrom.9.
 
Seisco sells both tankless water heaters and drain pans therefor and knowsand intends that such products will be put together and otherwise used in combination bythose purchasing or utilizing such products.10.
 
Seisco commits, induces and contributes to acts of infringement by making,using, offering to sell, and/or selling in the United States, and/or importing into theUnited States tankless water heaters and drain pans that practice one or more claims ineach of the Asserted Patents. True and correct images of one such drain pan are attachedas Exhibit C.

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->