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Correct Craft IP Holdings v. 13th Floor Wakeboard Towers

Correct Craft IP Holdings v. 13th Floor Wakeboard Towers

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-01051-GAP-TBS: Correct Craft IP Holdings, LLC v. 13th Floor Wakeboard Towers, Inc. Filed in U.S. District Court for the Middle District of Florida, the Hon. Gregory A. Presnell presiding. See http://news.priorsmart.com/-l8JJ for more info.
Official Complaint for Patent Infringement in Civil Action No. 6:13-cv-01051-GAP-TBS: Correct Craft IP Holdings, LLC v. 13th Floor Wakeboard Towers, Inc. Filed in U.S. District Court for the Middle District of Florida, the Hon. Gregory A. Presnell presiding. See http://news.priorsmart.com/-l8JJ for more info.

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

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04/16/2014

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1IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF FLORIDAORLANDO DIVISIONCORRECT CRAFT IPHOLDINGS, LLC,Plaintiff,v.13TH FLOOR WAKEBOARDTOWERS, INC.,Defendant./CASE NO.
6:13-cv-1051-orl-31KRS
INJUNCTIVE RELIEFREQUESTEDJURY TRIAL REQUESTED COMPLAINTPlaintiff Correct Craft IP Holdings, LLC, hereby files its Complaintagainst Defendant 13th Floor Wakeboard Towers, Inc., and alleges asfollows:PARTIES, JURISDICTION AND VENUE1.Plaintiff Correct Craft IP Holdings, LLC (“Correct Craft”) is aFlorida limited liability company.2.Defendant 13th Floor Wakeboard Towers, Inc. (“13th Floor”),is, upon information and belief, a California corporation. Upon informationand belief, 13th Floor sells and offers for sale infringing products in theUnited States, including within Florida.
 
23.
 
This Court has jurisdiction over the subject matter of this actionas to the Defendant pursuant to 28 U.S.C. §§ 1331 and 1338(a).4.
 
This Court has
in personam
jurisdiction as to 13th Floor  because, upon information and belief, 13th Floor is subject to both generaland specific jurisdiction in this State. More particularly, upon informationand belief, 13th Floor regularly conducts business activity in the State of Florida, whether directly or through authorized dealers by selling and offering to sell products that infringe one or more claims of Correct Craft’s patents in Florida.5.
 
Venue properly lies within this judicial district and division, pursuant to 28 U.S.C. §§1391(c) and 1400(b).STATEMENT OF FACTS6.
 
Correct Craft is the sole and exclusive owner of the followingvalid and enforceable United States Patents (collectively, the “Patents-in-Suit”):PATENT NO. TITLERE37,823 (the ‘823 Patent’) Water Sport Towing Apparatus and Method 6,666,159 (the ‘159 Patent’) Water Sport Towing Apparatus7,299,761 (the ‘761 Patent’) Water Sport Towing Apparatus
 
3True and correct copies of the Patents-in-Suit are attached hereto as ExhibitsA, B, and C.7.
 
The Patents-in-Suit have each been assigned to Correct Craft.Correct Craft currently owns the Patents-in-Suit and has owned them duringthe alleged infringement of the Defendant.8.
 
Upon information and belief, 13th Floor has sold and offered for sale in the United States and in Florida water sport towing apparatusesthat directly or indirectly infringe upon one or more claims of the Patents-in-Suit. The accused products include, but are not limited to, the 13th Floor Plain Jane, Billet Custom and El Diablo lines of products.9.
 
Correct Craft affirmatively gave 13th Floor written notice of thePatents-in-Suit at least as early as June 3, 2003. Upon information and  belief, 13th Floor knew of the Patents-in-Suit prior to receiving noticedirectly from Correct Craft.10.
 
Correct Craft has not granted Defendant a license to practice thePatents-in-Suit for the accused products.

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