IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ________________________________________ BASIL R.

BLAKE, an individual Plaintiff, Case No. ________________ v. LISLE CORPORATION, an Iowa corporation Defendant. ________________________________________

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, BASIL R. BLAKE, for his Complaint against LISLE CORPORATION, alleges as follows: THE PARTIES 1. Plaintiff, BASIL R. BLAKE (“Blake”) is an individual residing at 6481 Rapids

Rd., Lockport, New York. 2. Defendant, LISLE CORPORATION (“Lisle”) is an Iowa corporation with its

principal place of business located at 807 E. Main Street Clarinda, Iowa. 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. The driver’s action of depressing the brake pedal causes the piston to slide 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 assists the mechanic in placing the piston in alignment within the caliper. 8. After successfully building and testing prototypes of the Blake Tool, Blake

received the Blake Patent. 9. Blake signed an agreement with Inventors Express Services, Inc. which

approached several companies, including Lisle, regarding a license under the Blake Patent for manufacturing and selling the Blake Tool. 10. Lisle never took a license, and now offers to sell and sells in this District its

“Pneumatic Brake Tool” and “Pneumatic Brake Tool Kit W/ Adapters” that infringe the Blake Patent under 35 U.S.C. §271(a). 11. Lisle’s infringement of the Blake Patent has been willful.

WHEREFORE, Basil R. Blake prays that a judgment be entered in his favor and against Lisle Corporation as follows: (a) Lisle Corporation infringes U.S. Patent No. 6,195,863 under 35 U.S.C. §271; (b) Lisle Corporation’s infringement has been willful; (c) Blake be awarded damages pursuant to 35 U.S.C. §284; (d) Blake be awarded prejudgment interest;

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(e) Blake be awarded increased damages pursuant to 35 U.S.C. §284; (f) Blake be awarded his attorneys fees pursuant to 35 U.S.C. §285; and (g) 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: August 19, 2013

GROSSMAN LAW OFFICES

By: __/s/ Lee F. Grossman_________ Lee F. Grossman Mark M. Grossman Tejal P. Fowler 225 W. Washington St. Suite 2200 Chicago, Illinois 60606 (312) 621-9000 lgrossman@grossmanlegal.com

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