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Transglobal Product Licensing v. Travel Hammock

Transglobal Product Licensing v. Travel Hammock

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-01979-JCM-PAL: Transglobal Product Licensing, LLC v. Travel Hammock, Inc. Filed in U.S. District Court for the District of Nevada, the Hon. James C. Mahan presiding. See http://news.priorsmart.com/-l9nm for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-01979-JCM-PAL: Transglobal Product Licensing, LLC v. Travel Hammock, Inc. Filed in U.S. District Court for the District of Nevada, the Hon. James C. Mahan presiding. See http://news.priorsmart.com/-l9nm for more info.

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Published by: PriorSmart on Oct 29, 2013
Copyright:Public Domain

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09/03/2014

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COMP
SEAN K. CLAGGETT, ESQ. Nevada Bar No. 008407WILLIAM T. SYKES, ESQ. Nevada Bar No. 009916MATTHEW S. GRANDA, ESQ. Nevada Bar No. 012753CLAGGETT & SYKES LAW FIRM8751 W. Charleston Blvd., Ste. 220Las Vegas, NV 89117(702) 655-2346 - phone(702) 655-3763 – faxsclaggett@claggettlaw.comwsykes@claggettlaw.commgranda@claggettlaw.com
 Attorneys for Plaintiff 
UNITED STATES DISTRICT COURTDISTRICT OF NEVADA
TRANSGLOBAL PRODUCT LICENSING,LLC,Plaintiff,v.THE TRAVEL HAMMOCK, INC., dbaGRAND TRUNK, INC.,Defendant. _______________________________________  CASE NO.: 13-1979DEPT. NO.:
COMPLAINT
COMES NOW, Plaintiff, TRANSGLOBAL PRODUCT LICENSING, LLC, by and through its attorneys, CLAGGETT & SYKES LAW FIRM, and complaining of the Defendant,alleges as follows:
PARTIES
1.
 
Plaintiff, TRANSGLOBAL PRODUCT LICENSING, LLC (hereinafter 
 
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“Transglobal” or “Plaintiff”) is and, at all times mentioned herein, was a limited liabilitycompany, duly formed and existing under the laws of the State of Nevada.2.
 
Plaintiff is informed and believes, and thereon alleges that Defendant, THETRAVEL HAMMOCK, INC., dba GRAND TRUNK, INC. (hereinafter “Grand Trunk” or “Defendant”) is and, at all times mentioned herein, was a for-profit corporation organized under the laws of the State of Illinois, doing business in the State of Nevada, County of Clark.
JURISDICTION AND VENUE
3.
 
This is an action for patent infringement arising under the patent laws of theUnited States, Title 35, United States Code.4.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).5.
 
On information and belief, Defendant is subject to personal jurisdiction in theDistrict of Nevada (hereinafter the “District”), consistent with the principles of due process anthe Nevada Long Arm Statute, because Defendant offers its products for sale in this District, hastransacted business in this District, has committed and/or induced acts of patent infringement inthis District, and/or have placed infringing products into the stream of commerce throughestablished distribution channels with the expectation that such products will be purchased byresidents of this District.6.
 
Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b), 1391(c), and 1400(b).
GENERAL FACTUAL ALLEGATIONS
7.
 
Plaintiff repeats and realleges each and every allegation set forth in the preceding paragraphs, as if fully set forth herein.
 
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8.
 
Plaintiff, Transglobal, is the licensee of all right, title, and interest in U.S Patent No.7,657,954 B1 (the ‘“954 Patent”), entitled, “HEAD AND FACE COVERING APPARATUS.”The patent is directed toward a U-shaped travel pillow with an attached hood that allows theuser’s face to be encapsulated by the hood. A copy of the ‘954 Patent is attached hereto asExhibit “1.”9.
 
On information and belief, Defendant is engaged in the design, manufacture, saleoffering for sale, importation into, use, and/or sale after importation into the United Statesspecifically the State of Nevada, a product entitled “Grand Trunk Blackout Pillow,” and/or “Travel Pillow-Hooded.” This product is a U-shaped travel pillow with an attached hood thatallows the user’s face to be encapsulated by the hood.10.
 
Upon information and belief, the Defendant sells the “Travel Pillow-Hooded” via thefollowing website:http://store.grandtrunkgoods.com/blackout-hooded . Upon information and  belief, the Defendant has sold the “Travel Pillow-Hooded” to residents of the State of Nevada,has marketed the “Travel Pillow-Hooded” to residents of Nevada, and/or has shipped and/or imported the “Travel Pillow-Hooded” into the State of Nevada.11.
 
Upon information and belief, the Defendant sells the “Grand Trunk Blackout Pillow”via Skymall, Inc., to include the following online Skymall, Inc. website:http://www.skymall.com/grand-trunk-blackout-pillow/HTP.html.
 
Upon information and belief,the Defendant has sold the “Grand Trunk Blackout Pillow” to residents of the State of Nevada,has marketed the “Grand Trunk Blackout Pillow” to residents of Nevada, and/or has shipped and/or imported the “Grand Trunk Blackout Pillow” into the State of Nevada.//////

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