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UNITED STATES DISTRICT COURT FOR THE DISTRCIT OF KANSAS WINFIELD CONSUMER PRODUCTS, INC., Plaintiff, v. U ACE, INC.

and FORMOSA SAINT JOSE CORP. Defendants. COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Winfield Consumer Products, Inc. (Winfield), for its Complaint for Patent Infringement (Complaint) against Defendants U Ace, Inc. and Formosa Saint Jose Corp. (collectively Defendants), alleges as follows: PARTIES 1. Plaintiff Winfield is a corporation organized under the laws of the state of Kansas, with its principal place of business being located at 22425 D Street, Winfield, Kansas 67156. 2. Defendant U Ace, Inc. is a corporation organized under the laws of the state of California, with a place of business being located at 13642 Santa Ana Avenue, Fontana, California, 92337. 3. Upon information and belief, Defendant Formosa Saint Jose Corp. is a company incorporated in Taiwan and located at No. 319 JiaShing Street, Da-an District, Taipei 106, Taiwan and having a United States branch located at the same address as the aforementioned address of U Ace, Inc. at 13642 Santa Ana Avenue, Fontana, California, 92337. CIVIL ACTION NO. 13-CV-1321-MLB-KMH JURY TRIAL DEMANDED

JURISDICTION AND VENUE 4. This Court has jurisdiction over Winfields patent infringement claim pursuant to the patent laws of the United States, Title 35 U.S.C. 1 et seq. 5. This Court has subject matter jurisdiction over these claims pursuant to 28 U.S.C. 1331 and 1338(a). 6. Venue for this action is proper in this district pursuant to 28 U.S.C. 1391 and 1400(b), as Defendants, in their own names regularly conduct business in this judicial district and have committed and/or continue to commit acts of infringement, including offering to sell and/or selling their infringing products, in this judicial district. FACTS 7. This action arises out of Defendants infringement of at least one claim of United States Patent No. 5,891,546 (the 546 Patent), entitled Auxiliary Molded Floor Mats, which was duly and legally issued by the United States Patent and Trademark Office on April 6, 1999. (Attached as Exhibit A.) 8. Winfield is the owner of the 546 Patent with the full right to bring suit to enforce the patent and enjoin all others from practicing the invention and/or to collect damages for infringement of the claims of the 546 Patent. 9. The 546 Patent generally relates to molded floor mats or floor liners that are manufactured and designed to fit on the floor of a van, pickup truck, SUV or other vehicle wherein the floor liner catches debris, dirt, mud, water, etc., and can be removed and cleaned outside the vehicle. 10. Upon information and belief, Defendant U Ace is a U.S. branch of Defendant Formosa Saint Jose Corp.

11. Defendants have infringed and continue to infringe one or more claims of the 546 Patent in this judicial district and elsewhere by making, using, selling, offering to sell and/or importing into the United States floor liners, including floor liners sold under the name 3D Maxpider for pickup trucks, SUVs, vans and other vehicles (the Accused Products). 12. Winfield manufactures and sells floor liners throughout the United States, including in this judicial district, that incorporate the inventions as claimed and disclosed in the 546 Patent. COUNT I INFRINGEMENT 13. Winfield repeats and re-alleges the allegations set forth in paragraphs 1 through 12 set forth above as if fully set forth herein. 14. Upon information and belief, after examination of Defendants Accused Products, Defendants have infringed and continue to infringe, literally and/or under the doctrine of equivalents, one or more claims of the 546 Patent in violation of 35 U.S.C. 271 (a). 15. By reason of the acts set forth herein, Winfield has suffered, is suffering, and unless restrained by the Court, will continue to suffer injury to its business and property rights, for which it is entitled to an injunction pursuant to 35 U.S.C. 283 and/or monetary damages pursuant to 35 U.S.C. 284 in an amount proven at trial. PRAYER FOR RELIEF WHEREFORE, Winfield requests that the Court enter a judgment in its favor and against Defendants as follows: a. Declare that Defendants have infringed one or more claims of the 546 Patent; b. Declare that this case is exceptional pursuant to 35 U.S.C. 285; c. Enter a permanent injunction prohibiting Defendants, any of their parents, subsidiaries, divisions, affiliates, agents, servants, employees and those in privy with

Defendants from infringing Winfields 546 Patent pursuant to 35 U.S.C. 283; d. Award to Winfield damages for Defendants infringement of Winfields 546 Patent pursuant to 35 U.S.C. 284, with interest as well as costs, disbursements and reasonable attorneys fees incurred in this action; and e. Grant any such further relief as the Court deems appropriate. DEMAND FOR JURY TRIAL In accordance with Fed. R. Civ. P. 38(b), Winfield hereby demands a trial by a jury on all issues so triable. Respectfully Submitted, FOULSTON SIEFKIN LLP By: /s/ Todd N. Tedesco Todd N. Tedesco, #15652 1551 North Waterfront Parkway Suite 100 Wichita, Kansas 67260-4466 Tel: 316-291-9776 Fax: 866-347-5138 Email: ttedesco@foulston.com and Paul W. McAndrews Gerald C. Willis Jesse T. Dryer McAndrews, Held & Malloy, Ltd. 500 West Madison Street, Suite 3400 Chicago, Illinois 60661 Attorneys for Plaintiff