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Petter Investments v. Hydro Engineering et. al.

Petter Investments v. Hydro Engineering et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01235-LAB-WMC: Petter Investments, Inc. v. Hydro Engineering, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. Larry Alan Burns presiding. See http://news.priorsmart.com/-l8u6 for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01235-LAB-WMC: Petter Investments, Inc. v. Hydro Engineering, Inc. et. al. Filed in U.S. District Court for the Southern District of California, the Hon. Larry Alan Burns presiding. See http://news.priorsmart.com/-l8u6 for more info.

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Published by: PriorSmart on May 24, 2013
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11/24/2013

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COMPLAINT FOR PATENT INFRINGEMENTCase No. __________ 
Stephen M. Lobbin (SBN 181195)sml@eclipsegrp.comDouglas A. Dube’ (SBN 177674)dad@eclipsegrp.comEdward F. O’Connor (SBN 123398)efo@eclipsegrp.com
THE ECLIPSE GROUP LLP
550 West C Street, Suite 2040San Diego, California 92101Tel: 619.239.4340Fax: 619.239.0116Attorneys for Plaintiff 
Petter Investments, Inc. d/b/a RIVEERUNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF CALIFORNIAPetter Investments, Inc. d/b/aRIVEER
, a Michigan corporation,Plaintiff,v.
Hydro Engineering, Inc.
, a Utahcorporation,
Enviremedial Services,Inc.
, a California company,
CaliforniaCleaning Systems
, a Californiacompany, and 
J&S Equipment
, aCalifornia company,Defendants.Case No. _______________  
COMPLAINT FOR PATENTINFRINGEMENT, FALSEADVERTISING, INTENTIONALINTERFERENCE WITHPROSPECTIVE ECONOMICADVANTAGE, AND UNFAIRCOMPETITIONDEMAND FOR JURY TRIAL
For its Complaint, Plaintiff Petter Investments, Inc. d/b/a RIVEER (“Riveer”)hereby alleges as follows:
JURISDICTION AND VENUE
1.
 
This is an action including for infringement under the patent laws of theUnited States, 35 U.S.C. § 101,
et. seq.
This Court has subject matter jurisdiction
 
'13
CV1235
WMC
LAB
 
12345678910111213141516171819202122232425262728-2-
COMPLAINT FOR PATENT INFRINGEMENTCase No. __________ 
over the patent claims of this action under 28 U.S.C. §§ 1331 and 1338(a), and over the remaining claims under 28 U.S.C. § 1367(a).2.
 
This Court has personal jurisdiction over the Defendants because eachregularly conducts business in California and has committed the infringing actsalleged herein in California.3.
 
Venue is proper in this Judicial District under 28 U.S.C. §§ 1391(b)-(c)and 1400.
PARTIES
4.
 
Plaintiff Riveer is a Michigan corporation having its principal place of  business at 233 Veterans Boulevard, South Haven, Michigan 49090, and having anInternet home page at <riveer.com>.5.
 
Upon information and belief, Defendant Hydro Engineering, Inc.(“Hydro”) is a Utah corporation having its principal place of business at 865 West2600 South, Salt Lake City, Utah 84119, and having an Internet home page at<hydroblaster.com>.6.
 
Upon information and belief, Defendant Enviremedial Services, Inc.(“ESI”) is a California company having its principal place of business at 2655 VistaPacific Drive, Oceanside, California 92056.7.
 
Upon information and belief, Defendant California Cleaning Systems isa California company having its principal place of business at 3666 San GabrielRiver Parkway, Pico Rivera, California 90660.8.
 
Upon information and belief, Defendant J&S Equipment is a Californiacompany having its principal place of business at 1630 Challenge Drive, Concord,California 94520.9.
 
Upon information and belief, the non-Hydro Defendants aredistributors of the accused infringing products. If and when other distributors or customers of the accused products are ascertained who also may be subject to the personal jurisdiction of this Court, Riveer may seek leave to amend this Complaint.
 
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COMPLAINT FOR PATENT INFRINGEMENTCase No. __________ 
GENERAL ALLEGATIONS
10.
 
For many years, Riveer and Hydro have competed in the market for “modular wash rack” systems used to enable washing vehicles and equipment in amanner that allows for water and debris to be collected and recycled and/or disposed of in an environmentally-friendly way. Although Riveer is a small company withonly 35 employees, one of Riveer’s many strengths in the market is its focus on building custom solutions meeting a customer’s exact specifications for materials,design, and product capabilities.11.
 
Riveer is the owner by assignment of U.S. Patent No. 6,021,792 (“the‘792 patent”), which is entitled “Modular Cleaning Facility,” which duly and lawfully issued on February 8, 2000, and a copy of which is attached hereto asExhibit A.12.
 
The claims of the ‘792 patent are directed to a “modular cleaningsystem” and recite elements including,
inter alia
, a “modular wash rack” including a“drainage fitting,” a “coupling means,” a “tube,” and a “filtering system”comprising a “vacuum pump” and an associated “filter.” The ‘792 patent coversRiveer’s designs and protects Riveer’s exclusive right to sell its wash rack designswithout infringement by competitors such as Hydro, or its products.13.
 
On information and belief, Hydro has sold wash rack systems utilizinga vacuum pump.14.
 
Riveer is the owner by assignment of U.S. Patent No. 6,164,298 (“the‘298 patent”), which is entitled “Modular Cleaning Facility,” which duly and lawfully issued on December 26, 2000, and a copy of which is attached hereto asExhibit B.15.
 
The claims of the ‘298 patent are directed to a “modular cleaningsystem” and recite elements including,
inter alia
, a “modular wash rack” including a“frame,” a “basin,” a “grate,” a “drainage fitting” and “coupling means,” as well as a“tube” and a “pump.” The ‘298 patent covers designs including Riveer’s original

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