AAA Louvers is in the business of manufacturing, distributing, sellingand offering for sale, among other items, foundation flood vents.
AAA Louvers competes with Smart Vent for consumers of flood vent products.
Smart Vent’s U.S. Patents
On September 11, 2001, the United States Patent & Trademark Office(“USPTO”) issued U.S. Patent No. 6,287,050 (the “’050 Patent”), entitled “Foundation Flood Gate with Ventilation.” A true and correct copy of the ’050Patent is attached as Exhibit A.
On November 26, 2002, the USPTO issued U.S. Patent No. 6,485,231(the “’231 Patent”), also entitled “Foundation Flood Gate with Ventilation.” A trueand correct copy of the ’231 Patent is attached as Exhibit B.
Smart Vent is the owner by assignment of the ‘050 and ‘231 Patents,and owns all rights, title, and interest in the patents-in-suit, including the right to suefor and recover all past, present, and future damages for infringement of the patents-in-suit.
The patents-in-suit are valid, enforceable and were duly issued in fullcompliance with Title 35 of the United States Code.