A- 15-725704-C DISTRICT COURT CIVIL COVER SHEET XV CQrcie Ka omy, Nevada Cae No, incendie) ‘TParty Taformatlon prose hon hone a mag olives Vien) Praintiy(namaddeeniphy ‘Beda alae poe) Hany Reid aad Landra Gouls, Plants ygotic range Prpory Hong Company, «dares port. Amey (ramoudresyphoncy:SSSS*S*S*S*S~S~*SC Ry de aaa aeeeee Z a aaa LANZONE MORGAN, LLP {3783 Howard Hughes Pkwy, Suite 200 _tas Vegas. 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Esq. ‘CLERK OF THE COURT Nevada Bar No.: 12826 LANZONE MORGAN, LLP 3753 Howard Hughes Parkway, Suite 200 Las Vegas, Nevada 89169 Telephone: (702) 784-7621 Facsimile: (702) 509-9619 Jn pro per person Attomeys for Plaintift’s DISTRICT COURT CLARK COUNTY, NEVADA Harry Reid and Land Sould ) Case No: A-15-725704-C Plaintiffs, ) ) Dept.No XY ) ) COMPLAINT Hygenic Intangible Property Holding Company, ) a domestic corporation, The Hygenic Corporation, a foreign corporation, and Performance Health, LLC, a foreign limited liability company. vs. COMES NOW, Plaintiffs, HARRY REID and his wife, LANDRA GOULD, by and, through their undersigned attorney, and sues the Defendants, HYGENIC INTANGIBLE) PROPERTY HOLDING COMPANY, a domestic for-profit corporation, THE HYGENIC] CORPORATION, a foreign for-profit corporation, and PERFORMANCE HEALTH, LLC, al foreign for-profit limited liability company, and states:MON TO Al COUNTS L This is an action for damages which exceeds the amount of FIFTY THOUSAND} DOLLARS ($50,000.00), exchisive of costs, interest (including prejudgment interest), the: expenses of this litigation, and attomey fees (if any). 2. Defendant, HYGENIC INTANGIBLE PROPERTY HOLDING COMPANY, is. and was at all times material a Nevada, for-profit corporation which has its license to do business, in the State of Nevada, and whose registered agent is The Corporation Trust Company of Nevada, 701 S. Carson Street, Suite 200, Carson City, Nevada 89701. 3 Defendant, THE HYGENIC CORPORATION, is and was at all times material a| Foreign Corporation incorporated in the state of Delaware, which has its principal place of ‘business located at 1245 Home Ave., Akron, Ohio 44310, and whose registered agent is| Corporation Service Company, 2711 Centerville Rd., Suite 400, Wilmington, Delaware 19808, THE HYGENIC CORPORATION is a foreign for-profit corporation that does business in the| State of Nevada and distributes its goods, products and services in Nevada but does not maintain] | |a registered agent for services of process in Nevada. 4 Defendant, PERFORMANCE HEALTH, LLC, is and was at all times material a) Foreign Limited Liability Company formed in the state of Delaware, which has its prineipal place of business located at 1245 Home Ave., Akron, Ohio 44310, and whose registered agent is) Corporation Service Company, 2711 Centerville Rd., Suite 400, Wilmington, Delaware 19808. PERFORMANCE HEALTH, LLC is a foreign for-profit limited liability company that does| business in the State of Nevada and distributes its goods, products and services in Nevada but does not maintain a registered agent for serviees of process in Nevada.5. Defendants, HYGENIC INTANGIBLE PROPERTY HOLDING COMPANY, THE HYGENIC CORPORATION and PERFORMANCE HEALTH, LLC are inextricably intertwined. The Officers of HYGENIC INTANGIBLE PROPERTY HOLDING COMPANY on| file with the State of Nevada include, President, Marshall Dahneke and Secretary and Treasurer, Niels Lichti. ‘The contact address for both men is 1245 Home Ave. Akron, Ohio, 43310, ‘This is also the address where THE HYGENIC CORPORATION and PERFORMANCE HEALTH, LLC, are located. 6 Upon information and belief, at all relevant times material hereto, Defendants, HYGENIC INTANGIBLE PROPERTY HOLDING COMPANY, THE HYGENIC CORPORATION and PERFORMANCE HEALTH, LLC (hereinafter “Defendants"), combined to create, manufacture and market a defective product called TheraBund or Thera-Band exercise! band (hereinafter “TheraBand”), 7. TheraBand devices are clastic resistance hands designed to help prevent injury, enhance performance and rehabilitate muscles after injury or surgery. They have been used to provide avenues for strength training without the cost and space required for more bulky} equipment. They ate designed to allow a user to manually exercise based solely on the resistive! action provided by the band. 8. Plaintiff, HARRY REID is and was at all times material a resident of the State of Nevada. He was injured, while exercising at his home in Henderson, Nevada, on or about al rmoming of January 1, 2015, as the result of a defective product, TheraBand, designed, manufactured and distributed by Defendants.16 ) 1B 19 9. Plaintiff, LANDRA GOULD js and was at all times material a resident of the! State of Nevada and the spouse of Plaintiff, HARRY REID. Plaintiffs, HARRY REID and| LANDRA GOULD have been married since 1959. 10. Plaintiff, HARRY REID is Nevada's s \ior United States Senator and has served! in the U.S. Senate since January 3, 1987. During his political career, he has at various times| served as the Senate Minority Leader, Senate Majority Leader, Senate Majority Whip, Senate Minority Whip, Member of the U.S. House of Representatives from Nevada's First District, and, Lieutenant Governor of Nevada. I. Onor about the moming of January 1, 2015, Plaintiff, HARRY REID was using a’ TheraBand, heavy resistance exercise band, to exercise in his home. The TheraBand was| mounted to a sturdy object in his bathroom. While in use, the TheraBand broke or slipped out o} Mr. Reid’s hand, causing him to spin around and strike his face on a cabinet. 12. As a result of the TheraBand breaking or slipping out of his hand, Plaintiff, HARRY REID has suffered and continues to suffer from severe pain and injuries, including, but not limited to, loss of vision in his right eye, a concussion, broken orbital bones, severe disfigurement and bruising to his face, hand injuries, facial lacerations, scarring, and broken ribs. 13. On or about the morning of January 1, 2015, Plaintiff, HARRY REID was seventy-five (75) years old. 14, Nevada Revised Statutes 427A.122 defines “elderly person” as a person who is 60 years of age or older, 15. On March 14, 2013, Defendants submitted Patent Application 13/827,445, and stated the following within their patent application: FIELD OF THE INVENTION‘The present invention generally relates to an exercise device. More particularly, the! 2] present invention pertains to an clastic resistive exercise band, ; BACKGROUND OF THE INVENTION a Resistive exercising has long been incorporated into athletic training and therapeutic ° regimens in order to help prevent injury, enhance performance, and rehabilitate muscles 6 after injury or surgery. Conventional isometric or isotonic exercise devices have been| used to provide avenues for strength training and muscle therapy without the cost and| space required with more bulky equipment. In particular, many types of single loop bands i or single strip bands of elastic material have been developed that allow a user to manually| a exercise based solely on the resistive action provided by the band, For example, the user! w may exercise with an endless loop band by holding the band toward one end with a hand] or a foot and attaching the other end of the band to a stationary object, such as a door, or holding the other end with another hand or foot. Often, in order to obtain and maintain al oo proper grip on conventional bands, a user must loop the band multiple times around their| iad hand or foot, or tie knots at an appropriate location in the band. These methods to provide ° effective handles at appropriate locations along a conventional band often result in *y damage to the band and/or a localized pressure on the hand or foot area, ic, @ cutting in| » | - ofthe band, due to a significant narrowing ofthe band in and around the area of the knot. _ ‘To avoid this digging-in effect of the knotted band, the user may rely almost entirely on a oo | finger grip, for example, rather than mounting the band over a larger portion of an| 24 extremity, such as a wrist or ankle, Some users, such as the elderly or those with| 2 extensive damage to the muscles of the hands or feet, for example, may not be able to] 28 effectively grip the bands and thus may deviate from a therapeutic regimen prescribed by| 5a physician to strengthen and/or rehabilitate damaged muscles and/or cause additional injury to themselves. To alleviate this discomfort, some users may rely on special handles that have to be separately attached to the exercise device, resulting in additional cost and complexity that can be discouraging to users, ‘There is a need for an exercise device that permits easy and efficient use without the need to reconfigure the device with knots or constricting loops, wherein an isotropic nature o the material used to make the device allows the device to easily contour to the shapes off . surfaces, providing reduced slip when mounting to various objects, for example, while| simultaneously being capable of shaping to the contours of a user's anatomy for added] a comfort. 22 16. At all times material, Defendants knew or had constructive knowledge that] ‘TheraBand users may exercise with the resistance band by holding the band toward one end with +4 Ja hand or a foot and attaching the other end of the band to a stationary object. wy 17, Atall times material, Defendants were aware that in order to obtain and maintain a proper grip on TheraBands, a user must loop the band multiple times around their hand or foot, co tie knots at an appropriate location in the band in order to maintain a grip on the TheraBand. 18. At all times material, Defendants knew or had constructive knowledge that TheraBands were dangerous for use by the elderly, and those with extensive damage to the| ., | Miuseles of the hands or feet, because they may not be able to effectively grip the bands and thus| gq || may deviate from a therapeutic regimen prescribed by a physician to strengthen and/or! 23 ||tehabilitate damaged muscles and/or cause additional injury to themselves.19. At all times material, Defendants knew or had constructive knowledge of the| danger of injury to consumers, especially to the elderly, as a result of TheraBands breaking or slipping out of their hands while mounted to various sturdy objects. 20. Despite Defendants’ knowledge of the danger of the likelihood of TheraBands breaking or slipping out of the hands of its users, particularly the elderly and individuals with hand and/or foot muscle damage, Defendants did not include warnings, either general or specific, [regarding said dangers in the packaging insert in the TheraBand box owned by Plaintiff, HARRY REID. 21, Atal material times, Defendants knew or had constructive knowledge that a safe alternative design was feasible. 22. Upon information and belief, Defendants jointly marketed the defective, unreasonably dangerous TheraBand and were jointly involved in the enterprise by which] ‘TheraBand is brought to market and jointly controlled or had the ability to control the design, | manufacture or quality of TheraBand and failed to warm consumers and learned intermediaries 0 [the danger of the bands? likelihood of breaking and of causing injuries to the elderly and those with extensive damage to the muscles or the hands or feet, due to their difficulty in effectively] gripping the TheraBand. 23. Upon information and belief, Defendants market and sell TheraBand directly to! consumers in the public. 24, Upon information and belief, Defendants market and sell TheraBand as a medical device, 25. Upon information and belief, Defendants market and sell TheraBand directly to Hl . "| learned intermediaries.26. Upon information and belief, Defendants are not bulk manufacturers. 27. Upon information and belief, the TheraBand used by Plainitff, HARRY REID had a defect rendering it unreasonably dangerous; the defect existed at the time the product left the manufacturer and the defect caused his injuries. Rivera v. Philip Morris, Inc., 125 Nev. 18, 209} P.3d 271, 275 (2009); sssakis v. Knight Equipment Corp, 108 Nev. 212, 214, 826 P.2d $70, $71 (1992); Yamaha Motor Co,, Inc., 114 Nev. 233, 238-239, 955 P.2d 661, 665 (1998). 28. Upon information and belief, an appropriate warning provided by Defendants would have prompted Plaintiff, HARRY REID to take precautions to avoid his injuries. Rivera v Philip Morris, Inc., 125 Nev. 18, 209 P.3d 271, 275 (2009). 29. Upon information and belief, Defendants did not adequately communicate the| dangers that may result from the use or foreseeable misuse of TheraBands to consumers in the| public and leamed intermediaries. Fyssakis v. Knight Equipment Corp., 108 Ney. 212, 826 P.2d 570 (1992). 30. As aresult of the foregoing, Defendants’ product, the TheraBand, did not perform in keeping with the reasonable expectations of a reasonable consumer, in this instance, Plaintiff HARRY REID, causing severe damages to the consumer. COUN’ {Ic NEGLIGENCE 31, Plaintiff, HARRY REID re-asserts and re-alleges the allegations contained in| paragraphs | through 30 of this Complaint, as if each were fully set forth herein, 32. At all times material, Defendants owed a duty to the general public, and particularly, to Plaintiff, HARRY REID to design, manufacture, distribute and sell the subject resistance band in a reasonably safe condition free from dangerous hazards and not to design,manufacture, distribute and sell inherently dangerous products, and to war the public of known| dangers in using the subject resistance band, 33. Defendants breached their duty and the aforementioned accident occurred solely as a result of the carelessness, recklessness, negligence and culpable conduct of Defendants, their agents, servants and/or employees, in failing to design, manufacture, distribute and sell the} subject resistance band in a reasonably safe condition free from dangerous hazards; in éesigning| manufacturing, distributing and selling inherently dangerous products; in failing to take any) precautions under the circumstances which would have prevented the occurrence of this accident in reckless disregard of the safety of others; in placing Plaintiff, HARRY REID in a dangerous and perilous condition; in endangering the life and limb of Plaintiff, HARRY REID; in) designing, manufacturing, distributing and selling the subject resistance band in a dangerous, defective and/or hazardous condition; in failing to remedy the defective and inherently dangerous, defective and/or hazardous condition of the subject resistance band despite having actual and/or constructive notive of same; in failing to warn Plaintiff, HARRY REID that the! resistance band was dangerous, defective and/or hazardous at any time prior to the subject accident; in designing, manufacturing, distributing and selling a product that is inherently and/or unreasonably dangerous; in designing, manufacturing, distributing and selling a product that was} inherently and/or unreasonably dangerous but was not inspected and/or tested; by breaching! | certain express warranties; by breaching the implied warranty of merchantability; by breaching | the implied warranty of fitness for a particular purpose; and in other ways acting in a careless, reckless and negligent manner. 34, It was reasonably foreseeable that Defendants’ breaches would result in injury to] | Plaintiff, HARRY REID. Yet, Defendants, failed to war the elderly, those with extensive, 9damage to their hands and feet, of the increased risk of the danger of using TheraBand by that demographic population | 35. As a direct and proximate result of the carelessness and negligence of the| Defendants, Plaintiff, HARRY REID was seriously injured and suffers significant injury, pain ||and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, future medical care,| exacerbation of pre-existing injuries, loss of eamings, loss of ability to eam money. The losses are either permanent or continuing and Plaintiff, HARRY REID will continue suffering these| 4p || losses in the future. n WHEREFORE, Plaintiff, HARRY REID, demands judgment against the Defendants for damages as stated above, including general, special and punitive damages and further demands a trial by jury, together with such other and further relief as this Court deems appropriate. COUNT I STRICT LIABILITY 36. Plaintiff, HARRY REID re-asserts and re-alleges the allegations contained in| 17 || Paragraphs 1 through 35 of this Complaint, as if each were fully set forth herein, we 37. At all times material, Defendants owed a duty to the general public, and 19 || particularly, to Plaintiff, HARRY REID to design, manufacture, distribute and sell the subject] 29 || resistance band in a reasonably safe condition free from dangerous hazards and not to design, | manufacture, distribute and sell inherently dangerous products, and to warn the public of known| 22 dangers in using the subject resistance band. | 38. TheraBand, the subject resistance band, had a defect which rendered it) ‘unreasonably dangerous to the elderly and those with extensive damage to the muscles of their) 1024 23 hands and feet, due to the inability of TheraBand to be securely grasped by individuals in that demographic population. This defect existed at the time Defendants manufactured the product. 39. At the time of the subject incident, Plaintiff, HARRY REID was using the resistance band in a manner and for a purpose reasonably foreseeable to the Defendants. 40. It was reasonably foresceable that the dangerous, defective, and/or hazardous! design of the TheraBand would result in injury to users of the TheraBand, especially elderly] users like the Plaintiff, HARRY REID as a result of the product breaking or slipping out of their hand. Yet, Defendants, failed to war the elderly, and those with extensive damage to their hands| and feet, of the increased risk of the danger of using TheraBand by that demographic population, 41, Defendants breached their duty and the aforementioned accident occurred solely| as a result of the carelessness, recklessness, negligence and culpable conduct of Defendants, theie| agents, servants and/or employees, in failing to design, manufacture, distribute and sell the| subject resistance band in a reasonably safe condition free from dangerous hazards; in designing, manufacturing, distributing and selling inherently dangerous products; in failing to take any precautions under the circumstances which would have prevented the occurrence of this accident, in reckless disregard of the safety of others; in placing Plaintiff, HARRY REID in a dangerous and perilous condition; in endangering the life and limb of Plaintiff, HARRY REID; in| designing, manufacturing, distributing and selling the subject resistance band in a dangerous, defective and/or hazardous condition; in failing to remedy the defective and inherently| dangerous, defective and/or hazardous condition of the subject resistance band despite having] actual and/or constructive notice of same; in failing to warn Plaintiff, HARRY REID that the| resistance band was dangerous, defective and/or hazardous at any time prior to the subject accident; in designing, manufacturing, distributing and selling a product that is inherently and/or rt| REID’s damages. ' | / | | unreasonably dangerous; in designing, manufacturing, distributing and selling a product that was! inherently and/or unreasonably dangerous but was not inspected and/or tested; by brea ing certain express warranties; by breaching the implied warranty of merchantability; by breaching the implied warranty of fitness for a particular purpose; and in other ways acting in a careless, reckless and negligent manner. 42. Plaintiff, HARRY REID's injuries occurred solely as a result of the actions and/or) inactions of the Defendants, their agents, servants and/or employees. 43. As a direct and proximate result of the carelessness and negligence of the| Defendants, Plaintiff, HARRY REID was seriously injured and suffers significant injury, pain! and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment o life, expense of hospitalization, medical and nursing care and treatment, future medical care, exacerbation of pre-existing injuries, loss of earnings, loss of ability to eam money. The losses) are cither permanent or continuing and Plaintiff, HARRY REID will continue suffering these) losses in the future, 44, As a result of the foregoing, Defendants are strictly liable for Plaintiff, HARRY) WHEREFORE, Plaintiff, HARRY REID, demands judgment against the Defendants for) | damages as stated above, including general, special and punitive damages and further demands a trial by jury, together with such other and further relief as this Court deems appropriate COUNT Hil- FAILURE TO WARN 45. Plaintiff, HARRY REID re-asserts and re-alleges the allegations contained in paragraphs | through 44 of this Complaint, as if each were fully set forth herein.13 rr 16 46, At all times material, Defendants owed a duty to the general public, and particularly, to Plaintiff, HARRY REID to design, manufacture, distribute and sell the subject resistance band in a reasonably safe condition free from dangerous hazards and not to design, manufacture, distribute and sell inherently dangerous products, and to warn the public of known] dangers in using the subject resistance band | 47. Defendants breached their duty and the aforementioned accident accurred solely| Jas a result of the carelessness, recklessness, negligence and culpable conduct of Defendants, their agents, servants andor employees, in failing to design, manufacture, distibute and sell the | subject resistance band in a reasonably safe condition fre from dangerous hazards; in designing, manufacturing, distributing and selling inherently dangerous products; in failing to take any} precautions under the circumstances which would have prevented the occurrence of this accident in reckless disregard of the safety of others; in placing Plaintiff, HARRY REID in a dangerous and perilous condition; in endangering the life and limb of Plaintiff, HARRY REID; in| | designing, manufacturing, distributing and selling the subject resistance band in a dangerous, defective and/or hazardous condition; in failing t0 remedy the defective and inherently dangerous, defective and/or hazardous condition of the subject resistance band despite having actual and/or constructive notice of same; in failing to warn Plaintiff, HARRY REID that the} resistance band was dangerous, defective and/or hazardous at any time prior to the subject | i accident; in designing, manufacturing, distributing and selling product that is inherently and/or} unreasonably dangerous; in designing, manufacturing, distributing and selling a product that was inherently and/or unreasonably dangerous but was not inspected and/or tested; by breaching | certain express warranties; by breaching the implied warranty of merchantability; by breaching| 13the implied warranty of fitness for a particular purpose; and in other ways acting in a careless, reckless and negligent manner. 48. It was reasonably foreseeable that Defendants’ breaches would result in injury to Plaintiff HARRY REID. Yet, Defendants, failed to warn the elderly, and those with extensive damage to their hands and feet, of the increased risk of the danger of using TheraBand by that| ‘ demographic population 7 49. As a result of the foregoing, Defendants are liable for Plaintiff, HARRY REID’s| 8 « || damages 50. As a direct and proximate result of the carelessness and negligence of the| 22 || Defendants, Plaintiff, HARRY REID was seriously injured and suffers significant injury, pain| | and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment of i 15 |/liff, expense of hospitalization, medical and nursing care and treatment, future medical care, exacerbation of pre-existing injuries, loss of earnings, loss of ability to eam money. The losses} are either permanent or continuing and Plaintiff will continue suffering these losses in the future. | WHEREFORE, Plaintiff, HARRY REID, demands judgment against the Defendants for| damages as stated above, including general, special and punitive damages and further demands a : trial by jury, together with such other and further relief as this Court deems appropriate. m SS OF CONSORTIUM ef / Ss Plaintiff, LANDRA GOULD, re-alleges and adopts Paragraphs | through 50 as i sp || each were fully set forth herein, 23 52. At the time of the accident complained of in this Complaint, Plaintiffs were, 24 ||martied and continue to be married.2 53. As a result of the negligent act(s) of the Defendants, Plaintiff, LANDRA} GOULD, was caused to suffer, and will continue to suffer a loss of consortium. 54, All of the aforesaid injuries and damages were caused solely and proximately by, the negligence of the Defendant. WHEREFORE, Plaintiff, LANDRA GOULD, demands judgment against the Defendants) 6 for damages as stated above, including general, special and punitive damages and further ' demands a trial by jury, together with such other and further relief as this Court deems @ 4 | appropriate. COUNT V- PUNITIVE DAMAGES 55. Plaintiffs, HARRY REID and LANDRA GOULD re-assert and re-allege the allegations contained in paragraphs 1 through 54 of this Complaint, as if each were fully set forth 33 || herein. 56. In failing to warn the elderly and individuals with extensive damage to hand| and/or foot muscles, of the dangers of injury from the use of TheraBand, Defendants acted! fraudulently for the purposes of financial gain. . 57. Defendants’ aforementioned sctions were committed with malice and. with! / conscious disregard for the rights and safety of Plaintiff, HARRY REID. In committing the) . | aforesaid actions, Defendants had knowledge of the probable harmful consequences of theit| . actions and willfully and deliberately failed to act to avoid those consequences, justifying an| go || award of punitive damages. 23 WHEREFORE, Plaintiffs, HARRY REID and LANDRA GOULD demand judgment) za against the Defendants for damages as stated above, including general, special and punitive,2 damages and fuither demand a trial by jury, together with such other and further relief as this| Court deems appropriate. ben DATED this {4-_ day of October, 2015. 16 LANZONE MORGAN, LLP James M. Morgan, Esq. NV Bar No. 12826 3753 Howard Hughes Pkwy., Suite 200 Las Vegas, NV 89169 (888) 887-977 (tel.) 4 = Tames Wi Morgan, Ka By:oar ne wD TAFD. James M. Morgan, Esq. Nevada Bar No.: 12826 LANZONE MORGAN, LLP 3753 Howard Hughes Pakway, Suite 200 Las Vegas, Nevada 89169 Telephone: (702) 784-7621 Facsimile: (702) 509-9619 Attomeys for Plaintiffs DISTRICT COURT CLARK COUNTY, NEVADA Harry Reid and Landra Gould. Plaintifis, CASENO vs. } DEPT NO. Hygenic Intangible Property Holding Company, ) a domestic corporation, The Hygenic 3 Corporation, a foreign corporation, and 5 Performance Health, LLC, a foreign limited ) ) liability company Defendants. INITIAL APPEARANCE FEE DISCLOSURE (NRS CHAPTER 19) Pursuant to NRS Chapter 19, as amended by Senate Bill 106, filing fees are submitted for parties appearing in the above entitled action as indicated belowNew Complaint Fee (181530 $520f7] $299 [] $270.00 ppearance Fee (7j $1483.00(] $473.00[] $223.00 (1) Total of Continuation Sheet Attached TOTAL REMITTED: (Required) DA’ : October 6, 2018 ‘Total Paid S 300.00 LANZONE MORGAN LLP Nevada Bar No. | Lanzone Morgan, LLP 3753 Howard Hughes Parkway, Suite 200 Las Vegas, Nevada 89169 Telephone: 888-887-9777 Facsimile: 888-887-4506 Attorneys for Plaintiffs