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Foodfresh Technologies v. Jarden

Foodfresh Technologies v. Jarden

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-00488: Foodfresh Technologies, LLC v. Jarden Corporation. Filed in U.S. District Court for the Western District of Wisconsin, no judge yet assigned. See http://news.priorsmart.com/-l8Jk for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-00488: Foodfresh Technologies, LLC v. Jarden Corporation. Filed in U.S. District Court for the Western District of Wisconsin, no judge yet assigned. See http://news.priorsmart.com/-l8Jk for more info.

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Published by: PriorSmart on Jul 11, 2013
Copyright:Public Domain

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12/18/2013

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WISCONSIN
FOODFRESH TECHNOLOGIES, LLCNo. 13-cv-488JURY TRIAL DEMANDEDPlaintiff, v.JARDEN CORPORATIONDefendant.
COMPLAINT AND DEMAND FOR JURY TRIAL
FOODFRESH TECHNOLOGIES, LLC
(“
FoodFresh
”) by and through its
undersigned attorneys Hansen Reynolds Dickinson Crueger LLC, hereby file thiscomplaint for patent infringement against JARDEN CORPORATION and allege asfollows:
THE PARTIES
1.
 
FoodFresh is a duly organized and operating Wisconsin corporation whoseprincipal place of business is located at 14 N. Hill Road, Wausau, WI 54403.2.
 
Upon information and belief, Jarden Corporation is a duly organized andoperating Delaware Corporation whose registered agent is located at Corporation TrustCenter 1209 Orange St., Wilmington, DE 19801 and whose principal place of business islocated at 555 Theodore Fremd Ave., Rye, NY 10580. Jarden Corporation provides adiverse range of consumer products. Jarden Corporation advertises its products for saleglobally, and has advertised, marketed, and sold products infringing FoodFresh
’s
intellectual property rights, including within the State of Wisconsin and this district.
 
2
JURISDICTION AND VENUE
3.
 
This is an action for patent infringement under the patent laws of theUnited States, 35 U.S.C. §§ 271,
et seq.
 4.
 
This Court has jurisdiction over the subject matter of this patentinfringement action pursuant to 28 U.S.C. §§ 1331 and 1338(a).5.
 
This Court has personal jurisdiction over Jarden Corporation becauseJarden Corporation has committed acts of patent infringement within the State of  Wisconsin giving rise to this action. Jarden Corporation
’s electronic comme
rce salesand in-store sales have established at least minimum contacts with the forum such thatthe exercise of jurisdiction over it would not offend traditional notions of fair play andsubstantial justice.6.
 
 Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(a),1391(b), 1391(c) and 1400(b) for at least the reasons that Jarden Corporation hascommitted acts within this judicial district giving rise to this action and does business inthis district, including sales, offers for sale, and providing service and/or support to itscustomers in this district.
COUNT I
(Liquid Block Bags Patent Infringement of United States Patent No. 7,270,238)7. Paragraphs 1 through 6 are incorporated by reference as if fully set forthherein.8. United States Patent No. 7,270,238 is
titled “Vacuum Sealable Bag Apparatus and Method.”
United States Patent No. 7,270,238 was duly and legally issued on September 18, 2007. A true and correct copy of United States Patent No.7,270,238 is attached as Exhibit A.
 
3
9. FoodFresh is the lawful assignee of the entire right, title and interest inand to U.S. Patent No. 7,270,238 and possesses all rights of recovery under the patentincluding the right to recover damages for past infringement.10. Upon information and belief, Jarden Corporation has been and is now making, using, selling, and offering for sale within the United States, or importing intothe United States, products under the name of Foodsaver Gamesaver Dam Liquid Block 
Bags and Foodsaver Liquid Block Bags (“Liquid Block Bags”)
. Liquid Block Bags are vacuum sealable storage bags in various sizes that infringe directly and/or indirectly onone or more claims of U.S. Patent No. 7,270,238.11. Jarden Corporation
’s infringement has been willful, deliber
ate, and withknowledge of FoodFresh
’s rights
under U.S. Patent No. 7,270,238.12. Jarden Corporation, by way of its infringing activity, has caused andcontinues to cause FoodFresh to suffer damages in an amount to be determined at trial.
PRAYER FOR RELIEF
  Wherefore, FoodFresh prays for judgment against Jarden Corporation, grantingFoodFresh the following relief: A. That this Court adjudge and decree that U.S. Patent No. 7,270,238 is validand enforceable against Jarden Corporation and that Jarden Corporation has infringedand continues to infringe the patents;B. That this Court grant injunctions enjoining the aforesaid acts of infringement by Jarden Corporation, its officers, agents, servants, employees,subsidiaries and attorneys, and those acting in concert with it, including relatedindividuals and entities, customers, representatives, OEMs, dealers, and distributors;

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