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7.On information and belief, SPECTRUM develops, manufactures, imports, uses, offers for sale,and/or sells light-based hair treatmentappliances branded as Remington® i-LIGHT® Pro products, including at least the following product designations(individually and collectively, “Accused Products”):
Remington® i-LIGHT® Pro Intense Pulsed Light Hair Removal System,
Remington® i-LIGHT® Pro PLUS Intense Pulsed Light Hair Removal System,
Remington® i-LIGHT® Pro PLUS Quartz Intense Pulsed Light Hair Removal System,
Remington® i-LIGHT® Pro Intense Pulsed Light Hair Removal SystemSpa Kit,and
Remington® i-LIGHT® Pro Premier Intense Pulsed Light Hair Removal System.8.On information and belief, these Accused Products have been and are developed, used, manufactured, imported, offered for sale, and/or sold by SPECTRUM in the State of New York and elsewhere in the United States, and SPECTRUM actively promotes the Accused Products to consumers as products useful for treatment of undesired body hair.
JURISDICTION AND VENUE
9.This Court has subject matter jurisdiction over Dr. Jay's patent infringementclaims pursuant to28 U.S.C. §§ 1331 and 1338(a).10.Plaintiff Dr. Jay is a citizen of the State of New York. Each of Defendants SB Holdings and Spectrum Brands is a corporation incorporated under the laws of Delaware having its principal place of business in Wisconsin. Defendant Shaser is a corporation incorporated under the laws of Delaware havingits principal place of business in Massachusetts. The amount in controversy, without interest and costs, exceeds the sum or value specified by 28 U.S.C. § 1332.
Case 1:13-cv-08137-LTS Document 1 Filed 11/14/13 Page 3 of 93