IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Group-A Autosports, Inc., Plaintiff,

Civil Action No. : ___________

v. COMPLAINT Dynamic Auto Effects, Inc. and Fatboy Garage Motorsport, Inc., Defendants.

The Plaintiff, Group-A Autosports, Inc., for its Complaint against Defendants, Dynamic Auto Effects, Inc. and Fatboy Garage Motorsport, Inc., alleges as follows:

PARTIES 1. Plaintiff, Group-A Autosports, Inc., is a California corporation having a principal

place of business at 2050 5th Street, Norco, CA 92860. 2. On information and belief, Defendant, Dynamic Auto Effects, Inc., is a California

corporation having a principal place of business at 1938 Tyler Avenue, Suite H, El Monte, CA 91733 (hereinafter “Defendant Dynamic”).. 3. On information and belief, Defendant, Fatboy Garage Motorsport, Inc., is a

California corporation having a principal place of business at 2518 Continental Avenue, El Monte, CA. 91733 (hereinafter “Defendant Fatboy”).

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JURISDICTION AND VENUE 4. 5. This action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.

§§1331 and 1338(a). 6. This Court has personal jurisdiction over Defendant Dynamic and Defendant

Fatboy based upon theirs contacts with this forum, including, the sale of infringing products within the Commonwealth of Massachusetts. 7. Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b) and

1400(b).

GENERAL FACTS 8. Plaintiff is the sole owner of U.S. Patent No. 7,857,332 that issued on December

28, 2010 (the “‘332 Patent”). A copy of the ‘332 Patent is attached hereto as Exhibit A. The ‘332 Patent is valid and enforceable. 9. Plaintiff is the sole owner of U.S. Patent No. D602,408 that issued on October 20,

2009 (the “‘408 Patent”). A copy of the ‘408 Patent is attached hereto as Exhibit B. The ‘408 Patent is valid and enforceable. 10. Plaintiff is the sole owner of U.S. Patent No. D624,460 that issued on September

28, 2010 (the “‘460 Patent”). A copy of the ‘460 Patent is attached hereto as Exhibit C. The ‘460 Patent is valid and enforceable. 11. Plaintiff is the sole owner of U.S. Patent No. D624,855 that issued on October 5,

2010 (the “‘855 Patent”). A copy of the ‘855 Patent is attached hereto as Exhibit D. The ‘855 Patent is valid and enforceable. -2-

COUNT I - PATENT INFRINGEMENT - U.S. PATENT NO. 7,857,332 12. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-11 as if

fully alleged herein. 13. On information and belief, Defendant Dynamic and Defendant Fatboy are

making, using, importing, offering for sale, and/or selling a camber arm under the trademark GODSPEED PROJECT to consumers throughout the United States, including the Commonwealth of Massachusetts (the “Infringing Product”). 14. A picture of Defendant Dynamic and Defendant Fatboy’s E-bay advertisement of

the Infringing Product is shown in Exhibit E attached hereto. 15. A picture of the Infringing Product and its packaging is shown in Exhibit F

attached hereto. 16. Defendant Dynamic and Defendant Fatboy’s manufacture, import, use, offer for

sale, and/or sale of the Infringing Product infringes the ‘332 Patent in violation of 35 U.S.C. §271. 17. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘332 Patent has

caused and continues to cause Plaintiff irreparable harm. 18. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘332 Patent has

caused and continues to cause Plaintiff monetary damage.

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COUNT II - PATENT INFRINGEMENT - U.S. PATENT NO. D602,408 19. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-18

as if fully alleged herein. 20. Defendant Dynamic and Defendant Fatboy’s manufacture, import, use, offer for

sale, and/or sale of the Infringing Product infringes the ‘408 Patent in violation of 35 U.S.C. §271. 21. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘408 Patent has

caused and continues to cause Plaintiff irreparable harm. 22. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘408 Patent has

caused and continues to cause Plaintiff monetary damage.

COUNT III - PATENT INFRINGEMENT - U.S. PATENT NO. D602,408 23. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-22

as if fully alleged herein. 24. Defendant Dynamic and Defendant Fatboy’s manufacture, import, use, offer for

sale, and/or sale of the Infringing Product infringes the ‘408 Patent in violation of 35 U.S.C. §271. 25. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘408 Patent has

caused and continues to cause Plaintiff irreparable harm. 26. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘408 Patent has

caused and continues to cause Plaintiff monetary damage.

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COUNT IV - PATENT INFRINGEMENT - U.S. PATENT NO. D624,855 27. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-26

as if fully alleged herein. 28. Defendant Dynamic and Defendant Fatboy’s manufacture, import, use, offer for

sale, and/or sale of the Infringing Product infringes the ‘855 Patent in violation of 35 U.S.C. §271. 29. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘855 Patent has

caused and continues to cause Plaintiff irreparable harm. 30. Defendant Dynamic and Defendant Fatboy’s infringement of the ‘855 Patent has

caused and continues to cause Plaintiff monetary damage.

REQUESTED RELIEF Plaintiff requests this Court to enter judgment in favor of Plaintiff against the Defendant Dynamic and Defendant Fatboy, jointly and severally, on the above counts and grant it the following relief: 1. Pursuant to 35 U.S.C. §283, an Order that Defendant Dynamic and

Defendant Fatboy be preliminary enjoined from making, importing, using, offering for sale, and/or selling the Infringing Product or any other product that infringes U.S. Patent Nos. 7,857,332; D602,408; D624,460; and/or D624,855; 2. Pursuant to 35 U.S.C. §283, an Order that Defendant Dynamic and

Defendant Fatboy be permanently enjoined from making, importing, using, offering for sale, and/or selling the First and Second Products or any other product that infringes U.S. Patent Nos. 7,857,332; D602,408; D624,460; and/or D624,855; -5-

3.

Pursuant to 35 U.S.C. §284, that Defendant Dynamic and Defendant

Fatboy pay Plaintiff actual damages as may be proved at trial, and in no event less than a reasonable royalty; 4. Pursuant to 35 U.S.C. §289, that Defendant Dynamic and Defendant

Fatboy pay Plaintiff an amount of damages equal to the profits realized by Defendant Dynamic and Defendant Fatboy’s sales of the Infringing Product as may be proved at trial; 5. 6. 7. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded interest on damages; Pursuant to 35 U.S.C. §284, that Plaintiff be awarded its costs; and Such other relief as this Court deems equitable and just.

REQUEST FOR A JURY Plaintiff hereby requests a jury on all issues triable by a jury.

Respectfully submitted,

Group-A Autosports, Inc. By its Attorney,

Dated: 01-22-2014

/s/ Steven N. Fox Steven N. Fox (BBO #554692) 62 South Main Street Sharon, MA 02067 (781) 821-8920 E-Mail: sfox@foxpatent.com

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