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Smart Vent Products v. Aaa Louvers And Millwork

Smart Vent Products v. Aaa Louvers And Millwork

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-03643-JBS-KMW: Smart Vent Products, Inc. v. Aaa Louvers And Millwork, Inc. Filed in U.S. District Court for the District of New Jersey, the Hon. Jerome B. Simandle presiding. See http://news.priorsmart.com/-l8zT for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-03643-JBS-KMW: Smart Vent Products, Inc. v. Aaa Louvers And Millwork, Inc. Filed in U.S. District Court for the District of New Jersey, the Hon. Jerome B. Simandle presiding. See http://news.priorsmart.com/-l8zT for more info.

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Published by: PriorSmart on Jun 12, 2013
Copyright:Public Domain

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09/19/2013

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 1
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY
SMART VENT PRODUCTS, INC., ::Plaintiff, : CIVIL ACTION NO.::v. ::AAA LOUVERS AND :
JURY TRIAL DEMANDED
 MILLWORK, INC., ::Defendant. :
COMPLAINT
COMES NOW, the Plaintiff, Smart Vent Products, Inc. (“Smart Vent”), byand through its undersigned counsel, and for its complaint against Defendant, AAALouvers and Millwork, Inc. (“AAA Louvers”), avers as follows:
PARTIES
 1.
 
Smart Vent is a corporation organized under the laws of the State of Florida, with a principal place of business at 430 Andbro Drive, Unit 1, Pitman, NewJersey, 08071.2. AAA Louvers is a corporation organized under the laws of the State of  North Carolina, with a principal place of business at 7328 Siemens Road, Wendell, North Carolina 27591.
 
 2
JURISDICTION AND VENUE
 3. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §1331 and § 1338 because this Complaint raises claims arising under the laws of theUnited States, including 35 U.S.C. § 271.4. Venue is proper in this judicial district pursuant to 28 U.S.C. §1391(b)(1) because AAA Louvers is deemed to reside in this judicial district as it issubject to personal jurisdiction in this judicial district pursuant to 28 U.S.C. §§1391(b)(2), 1391(c)(2), and 1400(b) because a substantial part of the events or omissions giving rise to the claims occurred within this judicial district.
FACTS
5.
 
Smart Vent manufactures, offers to sell, and sells flood mitigation and ventilation systems in the form of foundation flood vents.
6.
 
The purpose of these vents is to allow the flood waters to flow freelyinto and out of the lower level of structures. If water pressure were to build up oneither the interior or exterior of foundation walls in a flood situation, the foundationwalls could be compromised and significant property damage could occur as aresult. Foundation flood vents automatically open to allow flood waters to reachequal levels on both sides of the walls, which decreases the potential for differencesin water pressure on opposite sides of the walls, thus lowering the possibility of structural damage to the wall.
 
 37.
 
AAA Louvers is in the business of manufacturing, distributing, sellingand offering for sale, among other items, foundation flood vents.
8.
 
AAA Louvers competes with Smart Vent for consumers of flood vent products.
Smart Vent’s U.S. Patents
9.
 
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.
10.
 
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.
11.
 
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.
12.
 
The patents-in-suit are valid, enforceable and were duly issued in fullcompliance with Title 35 of the United States Code.

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