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National Flooring Equipment v. Innovatech Products and Equipment Company et. al.

National Flooring Equipment v. Innovatech Products and Equipment Company et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 0:14-cv-01052: National Flooring Equipment, Inc. v. Innovatech Products and Equipment Company et. al. Filed in U.S. District Court for the District of Minnesota, no judge yet assigned. See http://news.priorsmart.com/-ladX for more info.
Official Complaint for Patent Infringement in Civil Action No. 0:14-cv-01052: National Flooring Equipment, Inc. v. Innovatech Products and Equipment Company et. al. Filed in U.S. District Court for the District of Minnesota, no judge yet assigned. See http://news.priorsmart.com/-ladX for more info.

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Published by: PriorSmart on Apr 12, 2014
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04/12/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA
 National Flooring Equipment, Inc. Plaintiff, Civil No. _______________________ v. Innovatech Products and Equipment Company and Bartell Morrison Inc. Defendants
COMPLAINT
Plaintiff, National Flooring Equipment, Inc. (“National”), for its complaint against Defendants, Innovatech Products and Equipment Company (“Innovatech”) and Bartell Morrison Inc. (“Bartell Morrison”) (collectively, “Defendants”), alleges as follows:
THE PARTIES
1. Plaintiff National is a corporation organized and operating under the laws of the State of Minnesota and is located and doing business at 9250 Xylon Avenue North, Brooklyn Park, MN 55445. 2. Defendant Innovatech is a corporation organized and operating under the laws of the State of Washington and is located and doing business at 832 80
th
 St. S.W., Everett, WA 98203.
 
 
23. Upon information and belief, Bartell Morrison is a Canadian corporation located and doing business at 375 Annagem Boulevard, Mississauga, Ontario L5T 3A7.
JURISDICTION AND VENUE
4. This is an action for patent infringement brought under the laws of the United States, 35 U.S.C. § 1 et seq., including but not limited to 35 U.S.C. §§ 271, 283, 284 and 285. 5. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a) and 1367. 6. This Court has personal jurisdiction over Defendant Innovatech. Innovatech, using the Internet and other trade channels, regularly advertises, offers for sale, sells, and delivers its products to customers in Minnesota. Innovatech has placed into commerce infringing products that have been sold to customers in Minnesota. Through such conduct Innovatech has established sufficient minimum contacts to confer to this Court personal jurisdiction over Defendant Innovatech. Stated otherwise, this Court has personal jurisdiction over Innovatech by reason of Innovatech’s activities within the State of Minnesota generally and specifically by Innovatech’s commission of acts of infringement, inducement of infringement and/or contributory infringement wherein such infringement has occurred within the State of Minnesota and this judicial district. 7. This Court has personal jurisdiction over Defendant Bartell Morrison. Bartell Morrison acquired Innovatech in 2013, and Bartell Morrison’s executive vice  president and COO serves as the general manager of Innovatech. Upon information and
 
 
3 belief, Bartell Morrison directs Innovatech’s operations including directing Innovatech to  place infringing products into commerce that have been sold to Minnesota customers. Furthermore, Bartell Morrison has a sales representative residing in Minnesota. Upon information and belief, Bartell Morrison’s Minnesota sales representative serves as Bartell Morrison’s sales agent in Minnesota, provides Minnesota customers advice about Bartell Morrison and Innovatech products and markets Bartell Morrison and Innovatech  products to Minnesota customers, including infringing products that have been sold to Minnesota customers. Through such conduct, Bartell Morrison has established sufficient minimum contacts to confer to this Court personal jurisdiction over Bartell Morrison. Stated otherwise, this Court has personal jurisdiction over Bartell Morrison by reason of Bartell Morrison’s activities within the State of Minnesota generally and specifically by Bartell Morrison’s commission of acts of infringement, inducement of infringement and/or contributory infringement wherein such infringement has occurred within the State of Minnesota and this judicial district. 8. Venue in this Court is proper pursuant to 28 U.S.C. §§ 1391(c) and 1400(b).
NATIONAL’S PATENT RIGHTS
9. National has developed and sells a variety of novel and inventive products used for installing or removing floor coverings such as carpet, tile, wood flooring, laminate flooring, and vinyl flooring. National’s products include floor stripping machines used to remove carpet, tile, adhesives, and other materials from the surface of a floor. Many of National’s products were invented by Martin L. Anderson.

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