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A&J - Design Patent complaints filed 8/21

A&J - Design Patent complaints filed 8/21

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Published by slburstein
A&J - Design Patent complaints filed 8/21
A&J - Design Patent complaints filed 8/21

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Published by: slburstein on Aug 22, 2013
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11/14/2013

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF GEORGIABRUNSWICK DIVISIONA&J MANUFACTURING, LLC,a Georgia corporation,andA&J MANUFACTURING, INC.,A Florida corporation,Plaintiffs,v.RANKAM GROUP,a Californiacorporation,Defendant.)))))))))))))Civil Action No.JURY DEMANDCOMPLAINTFOR INFRINGEMENT OF U.S. PATENTS
PLAINTIFFS, A&J MANUFACTURING LLC and A&J MANUFACTURING, INC., byand through theirattorneys,andfor theirComplaint against DefendantRANKAM GROUP, stateand allege as follows:
I.PARTIESAND NATURE OF SUIT
1.This is an action for infringement of United States patents, in violation o35U.S.C.§§271, 281,283-285,and 289. Plaintiffsseek monetary relief against Defendant,and equitable relief in the form of a permanent injunction against Defendant, barring themanufacture, sale, offer for sale, use or importation of goods that infringe the patent rightsasserted.
Case 2:13-tc-05000 Document 51 Filed 08/21/13 Page 1 of 8
Case 2:13-cv-00121-LGW-JEG Document 1 Filed 08/21/13 Page 1 of 8
 
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2.Plaintiff, A&J Manufacturing, LLC is a limited liability companyorganized and existing under the laws of the state of Georgia, having a place of business at 2465DemereRoad, St. SimonsIsland, Glynn County, Georgia31522.3.Plaintiff, A&J Manufacturing, Inc. is a corporation organized and existing undethe laws of the state of Florida, having a place of business at 903 Lake Asbury Drive, GreenCove Springs, Florida 32043.4.A&J Manufacturing, LLC is the owner, by assignment, of all right, title and interest in U.S. Patent No. 8,381,712, entitled "Simultaneous Multiple Cooking ModeBarbecue Grill" (the "’712 patent").A copy of the ‘712 patent is attached as Exhibit A.5.A&J Manufacturing, LLCis further the owner, by assignment, of all right, titleand interest in U.S. Patent No. D660,646, entitled "Pair ofLids for a Dual Grill" (the "’646 patent").A copy of the ‘646 patent is attached as Exhibit B.6.A&J Manufacturing, LLC is a leading designer, developer, manufacturer and distributor of outdoor grilling products,includingmultiple-mode grill products thatembodythe inventions of the ‘712 patentandthe ‘646 patent.7.A&J Manufacturing, LLC, in cooperation with A&J Manufacturing, Inc.,(hereafter referred to collectively as "A&J"), sells and distributes, within this district and nationwide, multiple-mode grill products, including those soldunder the trademarks CHAR-GRILLER DUO and CHAR-GRILLER TRIO, both of which embodythe inventions of the‘712 patentandthe ‘646 patent.Images of the genuine A&J products are reproduced below:
Case 2:13-tc-05000 Document 51 Filed 08/21/13 Page 2 of 8
Case 2:13-cv-00121-LGW-JEG Document 1 Filed 08/21/13 Page 2 of 8
 
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Char-Griller DuoChar-Griller Trio
8.On information and belief, Defendant Rankam Group(“Rankam”)is acorporation organized and existing under the laws of the state of California, having a principal place of business at 1618 West Rosecrans Avenue, Gardena, California 90249.
II.JURISDICTION AND VENUE
9.This Court has original subject matter jurisdiction over the causes of action fo patent infringement asserted herein, pursuant to 28U.S.C.§§1331 and 1338.10.On information and belief, Rankamimportsinto,and offers to sell and sellswithin,this judicial district,barbecue grill productsthat infringeone or more claims of the‘712 patentandthe claim of the ‘646 patent. The accused barbecue grill products aredescribed more fully below. On information and belief, Rankamhas purposefully directed infringing activities toward residents of this district,and has engaged in acts of infringementwithin this district. Therefore, this Court has personal jurisdiction over Rankam.11.Venue is proper within this judicial district pursuant to 28U.S.C.§1391 (c), asRankamis a corporation subject to personal jurisdiction within this district, and 28U.S.C.§1400(b), as Rankam’s acts of patent infringement have taken place within thisdistrict.
Case 2:13-tc-05000 Document 51 Filed 08/21/13 Page 3 of 8
Case 2:13-cv-00121-LGW-JEG Document 1 Filed 08/21/13 Page 3 of 8

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