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Stanton Concepts v. Brookstone et. al.

Stanton Concepts v. Brookstone et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Stanton Concepts, L.L.C. v. Brookstone, Inc. et. al. Filed in U.S. District Court for the District of New Jersey, no judge yet assigned. See http://news.priorsmart.com/-l8Ab for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Stanton Concepts, L.L.C. v. Brookstone, Inc. et. al. Filed in U.S. District Court for the District of New Jersey, no judge yet assigned. See http://news.priorsmart.com/-l8Ab for more info.

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Published by: PriorSmart on Jun 13, 2013
Copyright:Public Domain

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08/12/2013

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Glen M. Diehl, Esq.Charles Quinn, Esq.GRAHAM CURTIN, P.A.4 Headquarters PlazaP.O. Box 1991Morristown, NJ 07962-1991Telephone: (973) 272-1700Attorneys for Plaintiff Stanton Concepts, L.L.C
UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW JERSEY
Stanton Concepts, L.L.C.,Plaintiff,v.Brookstone, Inc. and WordLock, Inc.,Defendants.Civil Action No.:
____COMPLAINT ANDJURY DEMANDCOMPLAINT
Plaintiff Stanton Concepts, L.L.C (“Stanton Concepts”) for itsComplaint against defendant Brookstone, Inc. (“Brookstone”) and defendantWordLock, Inc. ("WordLock"), hereby alleges as follows:
THE PARTIES
1. Stanton Concepts is a limited liability company organized andexisting under the laws of the State of New Jersey, having a place of business at
 
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172 Stanton Road, P.O. Box 139, Stanton, NJ 088852. Upon information and belief, Brookstone is a corporationorganized and existing under the laws of the State of Delaware, having a place of business at One Innovation Way, Merrimack, NH 03054.3. Upon information and belief, WordLock is a corporationorganized and existing under the laws of the State of California, having a place of business at 2855 Kifer Road, Suite 245, Santa Clara, CA 95051-0800.
JURISDICTION
4. This is a civil action for the infringement of United StatesPatent No. 7,913,526 (“the 526 Patent”) under the patent laws of the United States,35 U.S.C. § 1
et. seq
.5. This Court has subject matter jurisdiction pursuant to 28 U.S.C.§§ 1331 and 1338.
FACTS
6. On March 29, 2011, the Patent Office duly and legally issuedthe 526 Patent, entitled "MULTIPLE FUNCTION LOCK."7. A true and authentic copy of the 526 Patent is attached hereto asExhibit A.8. Stanton Concepts is the owner of all right, title and interest inand to the 526 Patent.
 
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9. The 526 Patent generally relates to multiple function locks; thatis, locks having two separate functioning locking mechanisms.10. Brookstone sells devices that incorporate the claimed subjectmatter of the 526 Patent including, but not necessarily limited to, EasyCheck BigDigit Luggage Locks and Wordlock Luggage Locks.11. Brookstone is not licensed under the 526 Patent and is notauthorized or permitted to use, import, sell or offer to sell any of the subject matterclaimed in the 526 Patent.12. WordLock manufactures and sells devices that incorporate theclaimed subject matter of the 526 Patent to Brookstone for resale by Brookstone.13. WordLock is not licensed under the 526 Patent and is notauthorized or permitted to use, import, sell or offer to sell any of the subject matterclaimed in the 526 Patent.14. Brookstone has been aware of the 526 Patent and has also beenaware that its sales of luggage locks infringe the 526 Patent. Nevertheless,Brookstone has continued to sell luggage locks that infringe the 526 Patent.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,913,526
15. Stanton Concepts repeats and re-alleges the allegations of paragraphs 1-14 above as if fully set forth herein.16. In violation of 35 U.S.C. § 271, Brookstone and WordLock 

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