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BLAKE, an individual Plaintiff, Case No. 13-cv-1193 v. KT PRO TOOLS, LLC d/b/a KING TONY AMERICA, a limited liability company, Defendant. ________________________________________
JURY TRIAL DEMANDED
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: THE PARTIES 1. Plaintiff, BASIL R. BLAKE (“Blake”), is an individual residing at 6481 Rapids
Rd., Lockport, New York. 2. Defendant, KT PRO TOOLS, LLC d/b/a KING TONY AMERICA (“King
Tony”) 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.
FACTS GIVING RISE TO PATENT INFRINGEMENT 5. Blake is the inventor and owner of United States Patent No. 6,195,863 that covers
a tool to insert and position the piston into a vehicular disc brake system (the “Blake Patent”). 6. The piston is an integral portion of a vehicular brake system. The piston is
located inside a caliper, and brake pads are attached to the end of the piston. When the driver depresses the brake pedal the piston slides within the caliper toward the wheel. The brake pad on the end of the piston presses against a rotor which is attached to the wheel. The pressure of the brake pad against the rotor slows the wheel. 7. When a mechanic completes the work on the vehicle’s brake system, the piston
must be aligned within the caliper. The Blake Patent describes and covers a tool that places the piston in alignment within the caliper. 8. After successfully building and testing prototypes of the Blake Tool, Blake
received the Blake Patent. 9. Defendant King Tony offers to sell and sells in this District its “Air Powered
Brake Caliper Wind Back Tool Set” that infringes the Blake Patent under 35 U.S.C. § 271(a). WHEREFORE, Blake prays that a judgment be entered in his favor and against King Tony as follows: (a) King Tony infringes U.S. Patent No. 6,195,863 under 35 U.S.C. §271; (b) Blake be awarded damages pursuant to 35 U.S.C. §284; (c) Blake be awarded prejudgment interest; (d) Blake be awarded increased damages pursuant to 35 U.S.C. §284; (e) Blake be awarded its attorney fees pursuant to 35 U.S.C. §285; and (f) any further and just relief the Court deems equitable and appropriate.
JURY DEMAND Plaintiff demands a trial by jury on all issues so triable.
Dated: February 7, 2014
By: /s/ Tejal P. Fowler Lee F. Grossman Mark M. Grossman Tejal P. Fowler GROSSMAN LAW OFFICES 225 W. Washington St. Suite 2200 Chicago, Illinois 60606 (312) 621-9000 firstname.lastname@example.org