COMPLAINT - 3
Plaintiff, Tomahawk 30 Importers, Ltd., is a Canadian corporation and
the exclusive licensee of the ‘965 patent.
Plaintiff, Safeguard 30, LLC is an Oregon Limited liability companywith a principal place of business in Beaverton, Oregon.5.
Defendant International Integration, LLC is a California limitedliability company with a principal place of business at 1970 W. Holt Ave.,Pomona, CA 91768.6.
This Court has personal jurisdiction over Defendants because they are physically located in this judicial district, conduct business within the State of California, have
infringed the ‘965 Patent
in this District, have committed acts of false marking, and have engaged in false advertising.
A substantial part of the acts, events, and omissions giving rise to theclaims asserted in this action occurred within this judicial District, and venue istherefore proper in this court under the provisions of 28 U.S.C. §§ 1391(b) and (c),and 1400(b). Specifically, INTEGRATION has imported and sold products thatin
fringe the ‘965 Patent from its facilities in Pomona, C
Case 2:13-cv-07158-PA-PJW Document 1 Filed 09/27/13 Page 3 of 53 Page ID #:7