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Qualitas Manufacturing v. Pentagon Manufacturing

Qualitas Manufacturing v. Pentagon Manufacturing

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-07321: Qualitas Manufacturing Incorporated v. Pentagon Manufacturing Corporation. Filed in U.S. District Court for the Northern District of Illinois, no judge yet assigned. See http://news.priorsmart.com/-l9hv for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-07321: Qualitas Manufacturing Incorporated v. Pentagon Manufacturing Corporation. Filed in U.S. District Court for the Northern District of Illinois, no judge yet assigned. See http://news.priorsmart.com/-l9hv for more info.

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Published by: PriorSmart on Oct 12, 2013
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02/20/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISEASTERN DIVISION
 QUALITAS MANUFACTURINGINCORPORATED,Plaintiff,v.PENTAGON MANUFACTURINGCORPORATION,Defendant.)))))))))))Civil Action No.: 1:13-cv-7321
JURY TRIAL DEMANDEDCOMPLAINT
Plaintiff Qualitas Manufacturing Incorporated ("QMI") states and alleges against thenamed Defendant Pentagon Manufacturing Corporation ("Pentagon"), as follows:
JURISDICTION AND VENUE
1. This is an action for patent infringement arising under the Patent Laws of theUnited States, Title 35, United States Code, §§ 1
et seq
. This Court has subject matter  jurisdiction pursuant to 35 U.S.C. §§ 271 and 281, and 28 U.S.C. §§ 1331 and 1338(a).2. This Court has personal jurisdiction over Pentagon because, on information and belief, Pentagon has transacted and continues to transact business in the State of Illinois, and thecause of action rises out of business transacted by Pentagon within the State of Illinois.3. Venue in this judicial district is proper pursuant to 28 U.S.C. §§ 1391(b), 1391(c),and 1400(b).
THE PARTIES
4. Plaintiff QMI is a corporation organized and existing under the laws of the stateof Illinois, having its principal place of business at 1661 Glenlake Avenue, Itasca, Illinois 60143.
 
25. On information and belief, Defendant Pentagon is a corporation organized andexisting under the laws of the country of Canada, having its principal place of business at 5Granite Avenue, Stonewall, Manitoba, R0C 2Z0, Canada.
FACTUAL BACKGROUNDQMI's Patent Rights
6. Plaintiff QMI is the assignee of United States Patent No. 7,357,171 ("the '171 patent"), entitled "Low-Clearance Shutter Slat," naming inventor James V. Miller, which wasduly and legally issued by the United States Patent and Trademark Office (“USPTO”) on April15, 2008. A copy of the ‘171 Patent is attached to this Complaint as Exhibit A.7. Plaintiff QMI is the assignee of United States Patent No. 7,784,522 ("the '522 patent"), entitled "Locator and Shutter Slat," naming inventor James V. Miller, which was dulyand legally issued by the United States Patent and Trademark Office (“USPTO”) on August 31,2010. A copy of the ‘522 Patent is attached to this Complaint as Exhibit B.
QMI's Patented Rolling Shutter Slat
8. QMI is a manufacturer that specializes in the manufacture, sale, and installation of rolling shutters for windows and doors.9. Rolling shutters are protective devices that constitute a curtain of slats linked byhinges that slide in a guide rail to cover and uncover a door or window or any other buildingopening. When the curtain is retracted to uncover a building opening door or window, thecurtain of linked slats is wound around a spindle inside a housing adjacent to the buildingopening.10. Prior to March 2004, QMI developed the AL-6 single wall slat for rollingshutters. Where traditional rolling shutter slats are double walled, the AL-6 slat have a main
 
3 body comprising a single wall of metal. The AL-6 slat incorporates features that allow the slat tooffer the security of a traditional double-walled slat, but with the considerable advantage of lower weight, and the ability to wind more compactly inside a housing.11. QMI has expended considerable time, effort, and resources to develop its AL-6rolling shutter slat. The AL-6 slat has been a commercial success for QMI since its introduction.12. The technology incorporated in the AL-6 slats have been granted patent protection by the United States Patent and Trademark Office, as reflected by U.S. Patent Nos.7,357,171 and 7,784,522.
Defendant's Infringing Acts
13. On information and belief, Pentagon is in the business of manufacturing, selling,importing, and/or installing rolling shutters.14. On information and belief, Pentagon is manufactures, sells, imports, and/or installs single wall slats and rolling shutters incorporating single wall slats.15. On information and belief, the single wall slats and rolling shutters incorporatingsingle wall slats manufacture, sold, imported, and/or installed by Pentagon infringe at least claim1 of the '171 patent.16. On information and belief, the single wall slats and rolling shutters incorporatingsingle wall slats manufacture, sold, imported, and/or installed by Pentagon infringe at leastclaims 1, 8, 9, and 13 of the '522 patent.
COUNT IInfringement of U.S. Patent No. 7,357,171
 17. Plaintiff re-alleges paragraphs 1-16 as if fully set forth.

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