- 2 -COMPLAINT FOR PATENT INFRINGEMENT AND UNFAIR COMPETITIONCASE NO.
12345678910111213141516171819202122232425262728conducting business in California, and/or the events giving rise to the claims alleged herein have asubstantial effect in California and a substantial part of such events occurred in this District. In thisregard, plaintiff is informed and believes, and on that basis alleges, that AMS has offered its productsfor sale in this District, has transacted business in this District, has committed acts of infringement inthis District and/or has placed infringing products into the stream of commerce in this District or withthe expectation that such products will be purchased by residents of this District.
Assignment to any division of the Northern District is proper under Civil Local Rule3-2(c) and the Assignment Plan of this Court because this is an Intellectual Property Action.
THE PATENT IN SUIT
On January 10, 2012,
’520 Patent titled “Sonar Mount” was duly
issued by the U.S.Patent Trademark Office to plaintiff. Plaintiff has owned the
520 Patent throughout the period of
AMS’s infringing acts and still
520 Patent. A copy of the
520 Patent is attached hereto as
The ‘520 Patent relates generally to a sonar mount for use with a boat or ship, which
allows repeatable, accurate and precise alignment of a sonar head to a boat.12.
AMS has infringed and is still infringing the
520 Patent by making, selling, offeringto sell, and/or using within the United States, sonar mounts that embody the patented invention, andAMS will continue to do so unless enjoined by this Court.13.
AMS has been on notice of and has had knowledge of the
FIRST CLAIM FOR RELIEF(Infringement of U.S. Patent No. 8,094,520)
Plaintiff incorporates and realleges paragraphs 1 through 13 of this Complaint.15.
Plaintiff is the inventor, patentee, and owner of the
AMS has been or is directly infringing the
520 Patent by, among other things,making, using, offering to sell or selling in the United States, or importing into the United States, products that are covered by at least claims 1 and 5 of the
520 Patent, including, by way of exampleand not limitation, the Uni-Mount and Hydro-Mount products.