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A&J Manufacturing Et. Al. v. Tractor Supply Company Et. Al.

A&J Manufacturing Et. Al. v. Tractor Supply Company Et. Al.

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Published by PatentBlast
A&J Manufacturing et. al. v. Tractor Supply Company et. al.
A&J Manufacturing et. al. v. Tractor Supply Company et. al.

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Published by: PatentBlast on Aug 26, 2013
Copyright:Attribution Non-commercial

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01/08/2014

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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.TRACTOR SUPPLY COMPANY,a Tennesseecorporation,andCHANT KITCHEN EQUIPMENT, LTD.,a corporation organized under thelaws of the People’s Republic of China,Defendants.))))))))))))))))))Civil Action No.JURY DEMANDCOMPLAINTFOR INFRINGEMENT OF U.S. PATENT
PLAINTIFFS, A&J MANUFACTURING LLC and A&J MANUFACTURING, INC., byand through theirattorneys,andfor theirComplaint against DefendantTRACTOR SUPPLYCOMPANY, state and allege as follows:
I.PARTIESAND NATURE OF SUIT
1.This is an action for infringement ofaUnited States patent, in violation o35U.S.C.§§271, 281,and 283-285. Plaintiffsseek monetary relief against Defendant, and equitable relief in the form of a permanent injunction against Defendant, barring the
Case 2:13-tc-05000 Document 52 Filed 08/21/13 Page 1 of 7
 
manufacture, sale, offerfor 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 invention of the‘712 patent.Images of the genuine A&J products are reproduced below:
Case 2:13-tc-05000 Document 52 Filed 08/21/13 Page 2 of 7
 
Char-Griller DuoChar-Griller Trio
7.On information and belief, DefendantTractor Supply Company (“Tractor Supply”)is a corporation organized and existing under the laws of the state of Tennessee,having a principal place of business at 200 Powell Place,Brentwood, Tennessee 37027.8.On information and belief, DefendantChant Kitchen Equipment (HK) Ltd.(Chant”), is organized under the laws of the People's Republic of China, and maintains its principal place of business at Suite 706, 7/F Rightful Centre 11-12, Tak Hing Street, Jordan,Kowloon, Hong Kong, China.
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, Tractor Supplyimportsintothe United States,anoffers to sell and sells within this judicial district,barbecue grill productsthat infringeone or more claims of the ‘712 patent. The accused barbecue grill products are described more fully below. On information and belief, Tractor Supplyhas purposefully directed infringingactivities toward residents of this district,and has engaged in acts of infringement within thisdistrict. Therefore, this Court has personal jurisdiction over Tractor Supply.
Case 2:13-tc-05000 Document 52 Filed 08/21/13 Page 3 of 7

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