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Precision Dynamics v. Artemax

Precision Dynamics v. Artemax

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00964-AEG: Precision Dynamics Corporation v. Artemax Inc. Filed in U.S. District Court for the Eastern District of Wisconsin, the Hon. Aaron E Goodstein presiding. See http://news.priorsmart.com/-l8YY for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00964-AEG: Precision Dynamics Corporation v. Artemax Inc. Filed in U.S. District Court for the Eastern District of Wisconsin, the Hon. Aaron E Goodstein presiding. See http://news.priorsmart.com/-l8YY for more info.

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Published by: PriorSmart on Aug 26, 2013
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06/28/2014

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QB\22389137.1
1
UNITED STATES DISTRICT COURTEASTERN DISTRICT OF WISCONSIN
PRECISION DYNAMICS CORPORATION,Plaintiff,v. Case No. 2:13-cv-964ARTEMAX, INC. d/b/a IDENTIPLUS,Defendant.
COMPLAINT
Plaintiff, Precision Dynamics Corporation, by its attorneys Quarles & Brady LLP, for itsComplaint against Artemax, Inc. d/b/a/ IdentiPlus alleges as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement brought under the patent laws of theUnited States, 35 U.S.C. § 1,
et seq.
Plaintiff seeks injunctive relief and damages arising fromDefendant’s infringement of two patents: (1) U.S. Patent No. 7,240,446 (the ‘446 Patent); and(2) U.S. Patent No. 5,799,426 (the ‘426 Patent).
THE PARTIES
2.
 
Plaintiff Precision Dynamics Corporation (“Precision Dynamics”) is a CaliforniaCorporation with its principal place of business located at 27770 North Entertainment Dr., Ste.200, Valencia, California 91355.3.
 
Precision Dynamics is a manufacturer of identification bands with adhesive labelsof the sort that are often used for patient identification by hospitals and doctors’ offices.4.
 
Defendant Artemax, Inc. is a Wisconsin corporation with corporate addresses at21365 Gateway Court, Suite 100, Brookfield, Wisconsin 53045 and 16000 West Rogers Dr.,
 
QB\22389137.1
2Suite 100, New Berlin, Wisconsin 53151.5.
 
Artemax does business as IdentiPlus and is located at 16000 West Rogers Dr.,Suite 100, New Berlin, Wisconsin 53151.6.
 
IdentiPlus is a direct competitor of Precision Dynamics in the field of identification bands.
JURISDICTION AND VENUE
7.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and1338, with reference to the United States Patent Laws, Title 35 of the United States Code.8.
 
This Court has personal jurisdiction over Defendant under 28 U.S.C. § 1400 andWis. Stat. § 801.05.9.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and 1400.
THE PATENTS-IN-SUIT
 10.
 
On July 10, 2007, U.S. Patent No. 7,240,446 entitled “ Identification Braceletwith Sealable Window” was duly and legally issued by the United States Patent and Trademark Office. A copy of the ‘446 Patent is attached as
Exhibit A.
 11.
 
Precision Dynamics is the owner by assignment of the entire right, title, andinterest in the ‘446 Patent.12.
 
The ‘446 Patent is directed to, among other things, a wrist identification braceletthat incorporates a sealable window to protect wearer-related information against contact withmoisture and the like.13.
 
On September 1, 1998, U.S. Patent No. 5,799,426 entitled “ Uniform ThicknessAdhesive Closure Identification Bracelet Formed From Relatively Permanently Bonded
 
QB\22389137.1
3Laminates, and Related Method of Identification” was duly and legally issued by the UnitedStates Patent and Trademark Office. A copy of the ‘426 Patent is attached as
Exhibit B
.14.
 
Precision Dynamics is the owner by assignment of the entire right, title, andinterest in the ‘426 Patent.15.
 
The ‘426 Patent is directed to, among other things, an identification bracelet thatincludes an integral adhesive closure that permits the bracelet to be formed in a virtually uniformthickness.
COUNT IPATENT INFRINGEMENT OF THE ‘446 PATENT
16.
 
Precision Dynamics realleges and incorporates by reference as if fully set forthherein the allegations contained in paragraphs 1 through 15.17.
 
Defendant IdentiPlus has infringed and continues to infringe, directly or indirectly, one or more claims of the ‘446 Patent, either literally or under the doctrine of equivalents, by making, using, selling and offering for sale in the United States, or importing intothe United States, identification bands that infringe at least claim 1 of the claims of the ‘446Patent.18.
 
Defendant IdentiPlus has made, used, offered for sale, sold or imported into theUnited States the IdentiPlus “Cover Seal Label Band” bracelet.19.
 
Precision Dynamics has been damaged by IdentiPlus’s infringement of the‘446 Patent in an amount to be determined at trial.20.
 
Precision Dynamics has been and continues to be irreparably injured byIdentiPlus’s continuing infringement of the ‘446 Patent, and IdentiPlus’s infringing activities willcontinue unless enjoined by this Court pursuant to 35 U.S.C. § 283.

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