COMPLAINT FOR PATENT INFRINGEMENTAND TRADEMARK INFRINGEMENT
Upon termination of the License Agreement, all rights and licensesgranted to CYI were immediately terminated and reverted back to BLISS.9.
The License Agreement provided CYI with one hundred and twenty(120) days from the date of termination to sell off its remaining inventory of theLicensed Items. The sell-off period ended on or about March 20, 2013.10.
After the end of the sell-off period, CYI has continued importing,selling and offering products for sale to customers within the United States,without BLISS’s authorization, including: (a) the Can You Imagine LASER STARS product; (b) the Can You Imagine LASER STARS LAMP product; and (c)the Can You Imagine LASER TWILIGHT product (referred to collectively belowas the “Accused Products”).
FIRST CAUSE OF ACTIONINFRINGEMENT OF U.S. PATENT NO. 8,057,045
BLISS repeats and re-alleges the allegations of Paragraphs 1-10above, as though fully set forth here.12.
BLISS is the owner by assignment of United States Patent No.8,057,045 ("the ‘045 Patent"), entitled "Star Field Projection Apparatus", whichwas issued by the United States Patent and Trademark Office on November 15,2011. A true and correct copy of the ‘045 Patent is attached as Exhibit A.13.
After the end of the sell-off period referenced in Paragraph 9, CYI hasinfringed the ‘045 Patent by,
, selling and offering to sell laser light projection products that are covered by one or more patent claims of the '045Patent, within the United States, during the term of the ‘045 Patent, withoutBLISS’s authorization. The infringing CYI products include each and all of theAccused Products.14.
BLISS is informed and believes, and on that basis alleges, that CYI’sinfringement of the ‘045 Patent has been willful and intentional.