IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ________________________________________ BASIL R. BLAKE, an individual Plaintiff, Case No. 13-cv-1193 v. KT PRO TOOLS, LLC d/b/a KING TONY AMERICA, a limited liability company, JURY TRIAL DEMANDED Defendant. ________________________________________
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff, BASIL R. BLAKE, for his Complaint against KT PRO TOOLS, LLC d/b/a KING TONY AMERICA, alleges as follows:
1. Plaintiff, BASIL R. BLAKE
, is an individual residing at 6481 Rapids Rd., Lockport, New York. 2. Defendant, KT PRO TOOLS, LLC d/b/a KING TONY AMERICA (
is a limited liability company with its principal place of business located in City of Industry, California.
JURISIDCTION AND VENUE
3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §1331 (federal question), §1332(a) (diversity of citizenship), and §1338(a) (question related to patents). 4. Venue is proper in this judicial district pursuant to 28 U.S.C. §1391 and §1400.