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Aldridge v. Harris Farms

Aldridge v. Harris Farms

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. None: Aldridge v. Harris Farms, LLC. Filed in U.S. District Court for the Eastern District of North Carolina, no judge yet assigned. See http://news.priorsmart.com/-l8Xp for more info.
Official Complaint for Patent Infringement in Civil Action No. None: Aldridge v. Harris Farms, LLC. Filed in U.S. District Court for the Eastern District of North Carolina, no judge yet assigned. See http://news.priorsmart.com/-l8Xp for more info.

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Published by: PriorSmart on Aug 20, 2013
Copyright:Public Domain

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04/26/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF NORTH CAROLINAEASTERN DIVISIONCase No: 4:13-cv-00193
 
JAMES K. ALDRIDGE, III, ))Plaintiff, )) COMPLAINTv. ))HARRIS FARMS, LLC, ) Jury Trial Demanded)Defendant. ))
Plaintiff James K. Aldridge, III, by and through its counsel, complaining of DefendantHarris Farms, LLC (“Harris Farms”), hereby demands a jury trial and alleges and says:
NATURE OF THE ACTION
1. This is an action for patent infringement arising under the patent laws of theUnited States, 35 U.S.C. §§271,
et seq
., to enjoin and obtain damages resulting from HarrisFarms’ unauthorized manufacture, use, sale, offer to sell, and/or importation into the United States for subsequent use or sale of animal feeders that infringe one or more claims of United States Patent No. 5,699,753 (“the ‘753 Patent”), attached hereto as Exhibit A and entitled “Animal Feeder.” Mr. Aldridge seeks injunctive relief to prevent Harris Farms from continuingto infringe the ‘753 Patent, and, in addition, seeks a recovery of monetary damages resultingfrom Harris Farms’ infringement of the ‘753 Patent.
PARTIES
 2. Plaintiff James K. Aldridge, III is an individual residing at 4858 W.P. HardyRoad, LaGrange, North Carolina 28551.
 
23. Plaintiff James K. Aldridge, III is the owner of all right, title and interest in and tothe ‘753 Patent.4. Upon information and belief, Harris Farms is a limited liability company having a principal place of business at 7227 Haley Industrial Drive, Nolensville, Tennessee 37135-9618.Upon further information and belief, Harris Farms manufactures, uses, sells and/or distributesanimal feeders accused of infringement herein.
JURISDICTION AND VENUE
 5. This action arises under the patent laws of the United States, including 35 U.S.C.§§271
et seq
. This Court has subject matter jurisdiction under the provisions of 28 U.S.C.§§1331 and 1338(a).6. Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b), 1391(c),and 1400(b).7. This Court has personal jurisdiction over Harris Farms, and venue is proper in thisdistrict because Harris Farms has regularly conducted business in North Carolina and this judicial district, and, upon information and belief, infringement has occurred and continues tooccur in North Carolina and this district. In addition, this Court has personal jurisdiction over Harris Farms because it has established minimum contacts with the forum, and the exercise of this Court’s jurisdiction over Harris Farms would not offend traditional notions of fair play and substantial justice.
FACTS
 8. The ‘753 Patent is generally directed to an animal feeder.9. The ‘753 Patent was duly and legally issued on December 23, 1997.
 
310. Defendant Harris Farms markets, uses, sells, offers for sale, and/or imports intothe United States animal feeders that directly infringe one or more claims of the ‘753 Patent.The infringing products include, but are not limited to, 7- and 10-pound feeders. A copy of aninternet-based advertisement for Harris Farms showing accused animal feeders is attached heretoas Exhibit B.
COUNT IPATENT INFRINGEMENT35 U.S.C. §271
11. James K. Aldridge, III realleges and incorporates by reference the preceding paragraphs of the Complaint.12. James K. Aldridge, III is the lawful owner of all right, title and interest in and tothe ‘753 Patent.13. Harris Farms uses, sells, offers to sell and/or imports into the United States for subsequent sale or use animal feeders which directly infringe at least one claim of the ‘753Patent.14. Harris Farms’ acts of infringement have caused damage to James K. Aldridge, IIIand James K. Aldridge, III is entitled to recover damages adequate to compensate for theinfringement.15. Harris Farms’ continuing infringement of the ‘753 Patent will continue to damageJames K. Aldridge, III’s business, causing irreparable harm unless enjoined by the court.
PRAYER FOR RELIEF
 WHEREFORE, James K. Aldridge, III respectfully prays for judgment against HarrisFarms, granting James K. Aldridge, III the following relief:

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