ORIGINAL COMPLAINT Page 1
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION NEXERSYS CORPORATION, § § CIVIL ACTION No. 14-384
§ § v. § § JURY TRIAL DEMANDED PETE GUSTIN D/B/A VIRTUAL KNOCKOUT, STDIO1 LLC, and HAIRY MONSTER STUDIOS, LLC, § § § §
§ ORIGINAL COMPLAINT
Plaintiff, Nexersys Corporation (“Nexersys”), brings this suit for patent infringement against Defendants, Pete Gustin d/b/a Virtual Knockout (“VKO”), Stdio1 (“ST1”), and Hairy Monster Studios, LLC (“HMS”) (VKO, ST1, and HMS are collectively referred to as “Defendants”), and alleges as follows:
Plaintiff Nexersys is a Delaware corporation having a principal place of business at 1021 E 7th St., Ste. 100, Austin, Travis County, Texas 78702-3273. 2.
On information and belief, Defendant VKO is an individual doing business as VirtualKockout, having an address at 918 E. Imperial Dr., Hartland, Wisconsin 53029, and may be served at such address. 3.
On information and belief, Defendant ST1 is a Washington state limited liability company having a principal place of business at 15965 NE 85
St., Suite 200, Redmond, Washington 98052, and may be served through its registered agent for service of process, Matthew Hefferon at 22543 NE Alder Crest Lane, Redmond, WA 98053. 4.
On information and belief, Defendant HMS is a Wisconsin limited liability