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Jay, M.D. v. Spectrum Brands Holdings et. al.

Jay, M.D. v. Spectrum Brands Holdings et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-08137-LTS: Jay, M.D. v. Spectrum Brands Holdings, Inc. et. al. Filed in U.S. District Court for the Southern District of New York, the Hon. Laura Taylor Swain presiding. See http://news.priorsmart.com/-l9vx for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-08137-LTS: Jay, M.D. v. Spectrum Brands Holdings, Inc. et. al. Filed in U.S. District Court for the Southern District of New York, the Hon. Laura Taylor Swain presiding. See http://news.priorsmart.com/-l9vx for more info.

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Published by: PriorSmart on Nov 19, 2013
Copyright:Public Domain

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02/14/2014

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Case 1:13-cv-08137-LTS Document 1 Filed 11/14/13 Page 1 of 93
 
11404643_2--Page 2of 20--
3.On information and belief, Spectrum Brands, Inc. (“Spectrum Brands”)is a Delaware corporation having its principal place of business at 601 Rayovac Drive, Madison, Wisconsin53711andis a wholly owned subsidiary of SB Holdings. On information and belief, Spectrum Brands is in the business of manufacturing and selling branded consumer products, including the Remington® i-LIGHT® Pro line of hair treatment products that it markets, distributes, and sells in concert with SBHoldings and Shaser, Inc.4.On information and belief, Shaser, Inc. (“Shaser”) is a Delaware corporation havingits principal place of business at 130 New Boston Street, Suite 201, Woburn MA 01801and doingbusiness under the nameShaser BioScience, Inc. On information and belief, SB Holdings acquired an approximately 56% interest in Shaser in November 2012 and holds an option to  purchase the remaining approximately 44% interest in Shaser in 2017. On information and belief, Shaser is engaged in development of light-based medical devices, including the Remington® i-LIGHT® Pro line of hair treatment products, that it markets, distributes, and sells in concert with SB Holdings. and Spectrum Brands.5.On information and belief, Defendants SPECTRUM act in concert to develop, manufacture, import,market, distribute, and sell the Remington® i-LIGHT® Pro line of hair treatment productsand to instruct and induce consumers to use those products to treat hair.
NATURE OF THE ACTION
6.This is an action arising under the patent laws of the United States (Title 35, United States Code, § 100
et seq.)
 based upon SPECTRUM’s infringement of one or more of several U.S.  patents owned by Dr. Jay. Designation of this case for inclusion in the Pilot Project Regarding Case Management Techniques for Complex Civil Cases in the Southern District of New York (Standing Order M10-468) is believed to be appropriate and is requested by Dr. Jay.
Case 1:13-cv-08137-LTS Document 1 Filed 11/14/13 Page 2 of 93
 
11404643_2--Page 3of 20--
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

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