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A&J Manufacturing Et. Al. v. Outdoor Leisure Products Et. Al.

A&J Manufacturing Et. Al. v. Outdoor Leisure Products Et. Al.

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Published by PatentBlast
A&J Manufacturing et. al. v. Outdoor Leisure Products et. al.
A&J Manufacturing et. al. v. Outdoor Leisure Products et. al.

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

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05/16/2014

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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.OUTDOOR LEISURE PRODUCTS, INC.,a Missouricorporation,andGUANGDONG CANBOELECTRICALCO., 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 DefendantsOUTDOOR LEISUREPRODUCTS, INC.and GUANGDONG CANBOELECTRICALCO., LTD,state and allege asfollows:
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 Defendants,
Case 2:13-tc-05000 Document 50 Filed 08/21/13 Page 1 of 10
 
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and equitable relief in the form of a permanent injunction against Defendants, barringthemanufacture, 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, GreenCoveSprings, 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 of Lids 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 that embodythe inventions of the ‘712 patent andthe ‘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
Case 2:13-tc-05000 Document 50 Filed 08/21/13 Page 2 of 10
 
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‘712 patentandthe ‘646 patent, among others.Images of the genuine A&J products arereproduced below:
Char-Griller DuoChar-Griller Trio
8.On information and belief, Defendant Outdoor Leisure Products, Inc.("Outdoor Leisure") is a corporation organized and existing under the laws of the state of Missouri,having a principal place of business at5400 Doniphan Drive, Neosho, Missouri 64850.9.On information and belief, Defendant Guangdong CanboElectricalCo., Ltd.("Canbo") is a corporation organized and existing under the laws of the People's Republic of China, having a principal place of business at No. 268 Qixin Road,Xintan, Shunde District,Foshan City,Guangdong Province 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, Outdoor Leisureoffers to sell and sells,within this judicial district,barbecue grill productsthat infringeone ormore claims of the ‘712 patentandthe claim of the ‘646 patent.The accused barbecue grill products are described morefully below. On information and belief, Outdoor Leisurehaspurposefully directed infringing
Case 2:13-tc-05000 Document 50 Filed 08/21/13 Page 3 of 10

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