IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

GURIT (UK) LIMITED Plaintiff v. HEXCEL CORPORATION Defendant.

) ) ) ) ) ) Civil Action No. ) ) Trial By Jury Demanded )

COMPLAINT FOR PATENT INFRINGEMENT 1. Plaintiff Gurit (UK) Limited (“Gurit”) brings this action seeking monetary damages and injunctive relief against defendant Hexcel Corporation (“Hexcel”) to halt Hexcel’s infringement of U.S. Patent No. 8,088,470 (“the ‘470 patent,” attached as Exhibit A). PARTIES 2. Plaintiff Gurit is, and at all relevant times has been, a corporation having a place of business in the United Kingdom. 3. Defendant Hexcel is, and at all relevant times has been, a corporation organized and existing under the laws of Delaware having its principal place of business in Stamford, Connecticut and conducting business generally in this District and having its registered agent in Delaware as the Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware. JURISDICTION AND VENUE 4. This is an action for patent infringement arising under the United States Patent Laws, 35 U.S.C. §101 et seq. The amount in controversy exceeds $75,000.

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5.

Jurisdiction and venue are proper in this Court pursuant to 28 U.S.C. §§1331, 1332 and 1338, 28 U.S.C. §1391, and 28 U.S.C. §1400(b). FACTS

6.

Plaintiff Gurit incorporates by reference each and every allegation contained in the paragraphs above as though fully set forth herein.

7.

Gurit is engaged in the design, development, sale and manufacture of preform moulding material as disclosed in the ‘470 patent.

8. 9.

Gurit owns the entire right, title and interest in and to the ‘470 patent. Hexcel is making, using and selling, offering for sale and has made, used, sold and offered for sale preform moulding material as described and claimed in the ‘470 patent which infringes each of the four (4) claims of the ‘470 patent in suit.

10.

Hexcel has had actual and constructive knowledge of the ‘470 patent in suit, including the scope and claim coverage thereof. COUNT I (DIRECT PATENT INFRINGEMENT)

11.

Gurit incorporates by reference each and every allegation contained in the paragraphs above as though fully set forth herein.

12.

Hexcel’s aforesaid activities constitute a direct infringement of the ‘470 patent in violation of 35 U.S.C. §271 et seq.

13. 14.

Hexcel’s aforesaid infringement is, and has been, willful and knowing. Gurit has suffered immediate irreparable harm and monetary damages and will continue to suffer such irreparable harm and damages as a result of Hexcel’s willful patent infringement.

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COUNT II (INDUCEMENT TO INFRINGE) 15. Gurit incorporates by reference each and every allegation contained in the paragraphs above as though fully set forth herein. 16. Hexcel has actively induced, and continues to actively induce, customers to infringe the ‘470 patent by selling its infringing products to its customers and encouraging the use of the infringing products, knowing in advance that: the claims of the ‘470 patent cover the infringing products and thus cover the use by any person of Hexcel’s infringing products in the United States; the claims of the ‘470 patent cover one or more of its customers’ use of Hexcel’s infringing products in the United States to fabricate another product; and such uses of Hexcel’s infringing products constitute a direct infringement of the ‘470 patent. 17. Hexcel’s aforesaid activities constitute an inducement to infringe the ‘470 patent in violation of 35 U.S.C. §271 et seq. 18. 19. Hexcel’s aforesaid infringement is, and has been, willful and knowing. Gurit has suffered immediate irreparable harm and monetary damages and will continue to suffer such irreparable harm and damages as a result of Hexcel’s willful patent infringement. EXCEPTIONAL CASE 20. Because of Hexcel’s willful infringement, this is an exceptional case under 35 U.S.C. § 285 and Gurit is entitled to enhanced damages and attorney’s fees incurred in connection with prosecuting this action.

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WHEREFORE, Plaintiff requests that this Court enter judgment: A. Declaring that Hexcel infringes and has infringed the ‘470 patent; B. Declaring that Hexcel’s infringement of the ‘470 patent has been willful; C. Awarding Gurit a preliminary injunction and a permanent injunction restraining Hexcel and all those in active concert or privity with it from further infringement of the ‘470 patent; D. Awarding Gurit treble damages based on Hexcel’s willful infringement of the ‘470 patent pursuant to 35 U.S.C. §284 and otherwise; E. Declaring that this is an exceptional case and awarding Gurit its reasonable attorneys fees and costs pursuant to 35 U.S.C. §285 and otherwise; and F. Granting Gurit such other and further relief as the Court deems just and proper. PLAINTIFF HEREBY DEMANDS A TRIAL BY JURY. Dated: October 8, 2012 Respectfully submitted,

/s/ Francis DiGiovanni Francis DiGiovanni (#3189) Chad S.C. Stover (#4919) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 N. Orange Street Wilmington, DE 19899 (302) 658-9141 fdigiovanni@cblh.com cstover@cblh.com Attorneys for Gurit (UK) Limited

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