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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF IOWA CENTRAL DIVISION

BOVARD STUDIO, INC., Plaintiff, v. J. SUSSMAN, INC. Defendant. CIVIL NO. ______________ COMPLAINT AND JURY DEMAND

COMES NOW Plaintiff, Bovard Studio, Inc., and for its Complaint against Defendant, J. Sussman, Inc., hereby alleges as follows: PARTIES, JURISDICTION AND VENUE 1. Plaintiff, Bovard Studio, Inc. (Bovard), is a corporation organized and operated

under the laws of the State of Iowa with its principal place of business in Fairfield, Jefferson County, Iowa. 2. Upon information and belief, Defendant, J. Sussman, Inc. (Defendant), is a

corporation organized and operated under the laws of the State of New York with its principal place of business in Jamaica, Queens County, New York. 3. This Complaint contains a claim for patent infringement arising under 35 U.S.C.

271, et. seq., over which this Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a). 4. This Court has personal jurisdiction over Defendant because Defendant has the

requisite minimum contacts with the State of Iowa necessary to satisfy the due process requirements of the United States Constitution.

5.

Venue is proper in this Court pursuant to 28 U.S.C. 1391(b) and 1400(b). COUNT I -- INFRINGEMENT OF 7,607,267 PATENT

6.

On October 27, 2009, U.S. Patent Number 7,607,267 (the 267 Patent)

(attached hereto as Exhibit A), entitled Apparatus for Venting of Protective Panels was duly and legally issued to Bovard Studio, Inc. as assignee on an application filed October 3, 2003, which claims the priority of provisional patent application 60/416,310 filed October 4, 2002. 7. 8. Bovard is the owner of all right, title and interest in the 267 Patent. Defendant has been, and is, directly infringing the 267 Patent by making, using,

offering to sell, and selling within the United States, at least one infringing device sold under the collective name The 6400 Series, as depicted in Exhibit B hereto. 9. Upon information and belief, Defendants infringement of the 267 Patent was

and is willful in nature, in that Defendant acted despite an objectively high likelihood that it either knew or should have known that its actions constituted infringement of the 267 Patent, as Defendant and Bovard compete, sell, advertise and market in the same relatively small market segment pertaining to devices for protecting stained or other delicate glass windows. 10. Patent. 11. Defendants infringement of the 267 Patent has been, currently is, and in the Unless enjoined by this Court, Defendant will continue to infringe the 267

future will be, a proximate cause of substantial damage and irreparable harm to Bovard. 12. If not enjoined as requested herein, Defendants infringement of the 267 Patent

will continue to cause substantial damage and irreparable harm to Bovard.

PRAYER FOR RELIEF WHEREFORE Plaintiff, Bovard Studio, Inc., respectfully prays that this Court enter judgment in its favor and against Defendant, J. Sussman, Inc. on Count I -- Infringement of 7,607,260 Patent. In doing so, Plaintiff, Bovard Studio, Inc., further prays this Court: A. Temporarily and permanently enjoin Defendant, J. Sussman, Inc., and its

officers, agents, servants, attorneys and all persons in active concert or participation with Defendant, J. Sussman, Inc., from further acts of infringement of the 267 Patent, pursuant to 35 U.S.C. 283; B. Order Defendant, J. Sussman, Inc., to pay to Plaintiff, Bovard Studio, Inc.,

all damages adequate to compensate Plaintiff, Bovard Studio, Inc., for Defendant, J. Sussman, Inc.s, infringement of the 267 Patent, but in no event less than a reasonable royalty for the use made of the patented invention by Defendant, J. Sussman, Inc., together with all recoverable pre-judgment and post-judgment interest and costs, pursuant to 35 U.S.C. 284; C. Increase all damages Defendant, J. Sussman, Inc., is ordered to pay to

Plaintiff, Bovard Studio, Inc., up to three times the amount found or assessed by the Court or Jury, pursuant to 35 U.S.C. 284; D. Order Defendant, J. Sussman, Inc., to pay to Plaintiff, Bovard Studio, Inc.,

all attorney fees incurred by Plaintiff, Bovard Studio, Inc. in relation to this lawsuit and Defendant, J. Sussman, Inc.s, infringement of the 267 Patent; and E. circumstances. Order all such other and further relief as the Court deems just under the

JURY DEMAND Plaintiff, Bovard Studio, Inc., hereby demands a trial by jury on all issues and claims raised in this lawsuit that are triable by jury under applicable law. Dated: April 10, 2014 /s/ Brant D. Kahler Camille L. Urban, AT0008024 Brant D. Kahler, AT0009819 BROWN, WINICK, GRAVES, GROSS, BASKERVILLE AND SCHOENEBAUM, P.L.C. 666 Grand Avenue, Suite 2000 Des Moines, IA 50309-2510 Telephone: (515) 242-2400 Facsimile: (515) 242-2488 E-mail: urban@brownwinick.com kahler@brownwinick.com ATTORNEYS FOR PLAINTIFF BOVARD STUDIO, INC.