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A&J Manufacturing Et. Al. v. GHP Group Et. Al.

A&J Manufacturing Et. Al. v. GHP Group Et. Al.

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Published by PatentBlast
A&J Manufacturing et. al. v. GHP Group et. al.
A&J Manufacturing et. al. v. GHP Group et. al.

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Published by: PatentBlast on Aug 23, 2013
Copyright:Attribution Non-commercial

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08/23/2013

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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.GHP GROUP, INC.,An Illinoiscorporation,DONGGUAN KINGSUNENTERPRISESCO., LTD.,a corporation of the People’sRepublic of China,andKEESUNG MANUFACTURING CO.,LTD.,a corporation of the People’sRepublic of China,Defendants.))))))))))))))))))))))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 DefendantsGHP GROUP, INC.,DONGGUAN KINGSUN ENTERPRISES CO., LTD.,and KEESUNG MANUFACTURINGCO., LTD,state and allege as follows:
Case 2:13-tc-05000 Document 46 Filed 08/21/13 Page 1 of 8
 
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I.PARTIESAND NATURE OF SUIT
1.This is an action for infringement of United States patents, in violation o35U.S.C.§§271, 281and283-285. Plaintiffsseek monetary relief against Defendants, and equitable relief in the form of a permanent injunction against Defendants, barring themanufacture, sale, offer for sale, use or importation of goods that infringe the patent rightsasserted.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, LLC is a leading designer, developer, manufacturer and distributor of outdoor grilling products,includingmultiple-mode grill products that embodythe inventions of the ‘712 patent.6.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 patent,andotherpatents.Images of the genuine A&J products are reproduced below:
Case 2:13-tc-05000 Document 46 Filed 08/21/13 Page 2 of 8
 
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Char-Griller DuoChar-Griller Trio
7.On information and belief, Defendant GHP Group, Inc.("GHP") is a corporationorganized and existing under the laws of the state of Illinois, having a principal place of  business at8280 N. Austin Ave., Morton Grove, Illinois 60053.8.On information and belief, Defendant Dongguan Kingsun EnterprisesCo., Ltd.("Dongguan") is a corporation organized and existing under the laws of the People's Republicof China, having a principal place of business at Zone 2 Xichen Industrial District, ShiyongVillage, Hengli Town,Dongguan City,China.9.On information and belief, Defendant Keesung Manufacturing Co., Ltd. is acorporation organized and existing under the laws of the People's Republic of China, havinga principal place of business at No. 88 Yu Wo Tou Road, Dong Chong Town, Panyu,Guangzhou China.
II.JURISDICTION,VENUEAND JOINDER
10.This Court has original subject matter jurisdiction over the causes of action for  patent infringement asserted herein, pursuant to 28U.S.C.§§1331 and 1338.11.On information and belief, GHPoffers to sell and sells,within this judicialdistrict,barbecue grill productsthat infringeone ormore claims of the ‘712 patent.Theaccused barbecue grill products are described more fully below. On information and belief,
Case 2:13-tc-05000 Document 46 Filed 08/21/13 Page 3 of 8

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