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Case 1:17-cv-01962-MHC Document 1 Filed 05/30/17 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

John C. McGoogan,

Plaintiff,
CIVIL ACTION NO. ____________
v.

Decky Co., Inc. d/b/a Decky DEMAND FOR JURY TRIAL


Company, Decky Apparel Group,
and/or Decky Brands Group,

Defendant.

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

COMES NOW Plaintiff John C. McGoogan, by its undersigned attorneys,

and files this Complaint for Damages and Injunctive Relief against Defendants

Decky Co., Inc., Decky Company, Decky Apparel Group, and Decky Brands

Group, showing the Court as follows:

PARTIES

1. Plaintiff, John C. McGoogan (McGoogan or Plaintiff) is an

individual residing in Atlanta, Georgia.

2. Upon information and belief, Defendant Decky Co. Inc. d/b/a is a

California corporation with a principal place of business at 2121 S. Wilmington

Ave, Compton, California 90220.

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3. Upon information and belief, Defendant conducts business under

various corporate pseudonyms including Decky Apparel Group, Decky Brands

Group and Decky Company.

4. Upon information and belief, Defendant promotes and sells caps on

an interactive website at decky.com.

JURISDICTION AND VENUE

5. This court has original jurisdiction over the subject matter of this

action pursuant to 28 U.S.C. 1331 and 1338(a) because this action concerns the

infringement of a United States Patent.

6. This Court has personal jurisdiction over Defendant because, upon

information and belief, it: (a) regularly conducts business and/or transacts

and/or solicits business within the State of Georgia; (b) has committed acts of

patent infringement in the State of Georgia causing injury within the State of

Georgia; (c) contracts to supply goods in this jurisdiction though an interactive

website; (d) advertises and markets infringing goods within this jurisdiction

through an interactive website; (e) derives substantial revenues from the sale of

goods in this jurisdiction; and/or (f) knows or expects its actions to have

consequences in this jurisdiction, and derives substantial revenue from interstate

or international commerce, through online sales to customers and otherwise.

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7. Venue is proper in this District and this Court pursuant to 28 U.S.C.

1391(b)

FACTUAL BACKGROUND

The Asserted Patent

8. United States Patent Number D675,403 (the 403 Patent), entitled

TOBOGGAN STYLE HAT, was duly and legally issued on February 5, 2013, and

names Plaintiff John C. McGoogan as the inventor. Attached as Exhibit 1 is a true

and correct copy of the 403 Patent.

9. The 403 Patent claims the ornamental design for the toboggan style

hat, as shown and described in the 403 Patent.

10. Plaintiff John C. McGoogan is the owner of the entire right, title, and

interest in the 403 Patent.

Defendants Infringing Products and Activities

11. Upon information and belief, the Defendant has and continues to

infringe the 403 Patent by making, selling, and offering for sale toboggan style

hats in the United States that embody the invention claimed in the 403 Patent.

Attached as Exhibit 2 are printed copies of a website offering Defendants hats

for sale under the name CCUGLOG BEANIES HYBRICAP 2 VISOR JEEP SKULL

KNIT SKI WINTER CAPS at the following website:

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https://www.buddhablessu.com/cuglog-beanies-hybricap-2-visor-jeep-skull-

knit-ski-winter-caps-neon.html

12. On January 31, 2017, Plaintiff mailed Defendant a letter regarding

the manufacture and sale of toboggan style hats that were thought to be

infringing the 403 Patent, which placed Defendants on actual notice of the 403

Patent (See Exhibit 3).

13. Upon information and belief, Defendant has known of the existence

of the 403 Patent since at least January 31, 2017, and since that time, Defendants

acts of infringement have been intentional and willful, and in disregard for the

403 Patent, without any reasonable basis for believing that it had a right to

engage in the infringing conduct.

14. On or about February 10, 2017, Plaintiff ordered a toboggan style hat

from Defendant through the above-referenced interactive website, and shortly

thereafter, the hat was delivered to Plaintiff in Atlanta, Georgia. Supporting

documentation, including a sales receipt, for this transaction and delivery is

provided herewith, as Exhibit 4.

COUNT ONE

INFRINGEMENT OF U.S. PATENT NO. D675,403

15. Plaintiff repeats and realleges paragraphs 1 through 14 hereof, as if

fully set forth herein.

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16. Upon information and belief, Defendant has been and is directly

infringing the 403 Patent by using, selling, or offering for sale in the United

States, including within this judicial district, toboggan style hats, in violation of

35 U.S.C. 271(a).

17. Upon information and belief, Defendants infringement has been,

and continues to be knowing, intentional, and willful.

18. Upon information and belief, Defendants acts of infringement of the

403 Patent have caused and will continue to cause Plaintiff damages for which

Plaintiff is entitled to compensation pursuant to 35 U.S.C. 284.

19. Upon information and belief, Defendants acts of infringement of the

403 Patent have caused and will continue to cause Plaintiff immediate and

irreparable harm unless such infringing activities are enjoined by this Court

pursuant to 35 U.S.C. 283. Plaintiff has no adequate remedy at law.

20. Upon information and belief, this case is exceptional and, therefore,

Plaintiff is entitled to an award of attorneys fees pursuant to 35 U.S.C. 285.

WHEREFORE, Plaintiff requests judgment against Defendant as follows:

1. Adjudging that Defendant has infringed the 403 Patent, in violation

of 35 U.S.C. 271(a);

2. Granting an injunction permanently enjoining Defendant, its

employees, agents, officers, directors, attorneys, successors, affiliates,

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subsidiaries and assigns, and all of those in active concert and participation with

any of the foregoing persons or entities from infringing, contributing to the

infringement of, or inducing infringement of the 403 Patent;

3. Ordering Defendant to account and pay damages adequate to

compensate Plaintiff for Defendants infringement of the 403 Patent, with pre-

judgment and post-judgment interest and costs, pursuant to 35 U.S.C. 284;

4. Ordering that the damages award be increased up to three times the

actual amount assessed, pursuant to 35 U.S.C. 284;

5. Declaring this case exceptional and awarding Plaintiff its reasonable

attorneys fees, pursuant to 35 U.S.C. 285; and

6. Awarding such other and further relief as this Court deems just and

proper.

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a jury trial for all issues so triable as a matter of

right.

DATED this 30th day of May, 2017.

TAYLOR ENGLISH DUMA LLP

/s/ Jonathan D Crumly, Sr.


Jonathan D. Crumly, Sr.
Georgia Bar No. 199466
1600 Parkwood Circle, Suite 200
Atlanta, Georgia 30339

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Telephone: (678) 426-4659


Facsimile: (770) 434-7376
Email: jcrumly@taylorenglish.com

Thomas L. Moses
Fed. ID 7049
SOUTHEAST IP GROUP, LLC
13-B West Washington Street
Greenville, South Carolina 29601
Telephone: (864) 509-1905
Facsimile: (864) 509-1907
E-mail: tmoses@seiplaw.com
(Application for Pro Hac Vice
Admission Pending)

Attorneys for Plaintiff

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Case 1:17-cv-01962-MHC Document 1 Filed 05/30/17 Page 8 of 8

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

John C. McGoogan,

Plaintiff,
CIVIL ACTION NO. ____________
v.

Decky Co., Inc. d/b/a Decky DEMAND FOR JURY TRIAL


Company, Decky Apparel Group,
and/or Decky Brands Group,

Defendants.

CERTIFICATE OF COMPLIANCE

The undersigned attorney hereby certifies, pursuant to L.R. 7.1, ND Ga.,

that the foregoing COMPLAINT was prepared in accordance with L.R. 5.1, ND

Ga. using Book Antiqua font, 13 point.

/s/ Jonathan D. Crumly, Sr.


Jonathan D. Crumly, Sr.
Georgia Bar No. 199466

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Case 1:17-cv-01962-MHC Document 1-1 Filed 05/30/17 Page 1 of 5

Exhibit 1 US00D675403S

(12) McGoogan
United States Design Patent do Patent No.: US D675,403 S
45) Date of Patent: ** Feb. 5, 2013 9

(54) TOBOGGAN STYLE HAT OTHER PUBLICATIONS


- Picture of hat as found at http://images.usoutdoorstore.com/
(76) Inventor: John C. McGoogan, Atlanta, GA (US) usoutdoorstore/products/full/coal fremont army 08.jpg (Jun. 15,
:::::: - 2009).
(**) Term: 14 Years Picture of hat as found at http://images.usoutdoorstore.com/
- usoutdoorstore/products/full/p-A5111211799.jpg (Jun. 15, 2009).
(21) Appl. No. 29/387,252 Picture of hat as found at http://imagesusoutdoostore.com/
- usoutdoorstore/products/full/coal radar blk 08.jpg (Jun. 15,
(22) Filed: Mar. 10, 2011 2009).
(51) LOC (9) Cl. .................................................. 0203 # ,,; -
(52) U.S. Cl. .......................................... D2/878; D2/889 cited by examiner
(58) Field of s Primary Examiner Karen E. Eldridge Powers
D2889, 268 84. 17i. 17104 ii. iosi. (74) Attorney, Agent, or Firm Thomas L. Moses;
2/1933, 2001:20, 13.2003, 2007, 66.1% Monahan & Moses, LLC
See application file for complete search history. (57) CLAIM
(56) References Cited The ornamental design for the toboggan style hat, as shown
and described.
|U.S. PATENT DOCUMENTS DESCRIPTION
D277,426 S :};+ 2/1985 Eisinger ......................... D2/879
* !: n ------------------- 2/209.12 FIG. 1 is a left side perspective view of my design for a
D367,552 S + 3/1996 Newman ........................ D2/882 toboggan style hat.
5,613,246 A 3/1997 Alexander FIG. 2 is a left side view thereof.
i :}; .
5 1C J19:lla ........................
D2/879 FIG. 3 is a right side view thereof.
- -
5,960,477 A * 10/1999 Dixon ......
D441.937 S + 5/2001 Thibodaux
f
... D2/879
FIG. 4 is a front view thereof.
FIG. 5 is a rear elevation view thereof.
6,398.495 B1* 102601 foam . 2/209.13 FIG. 6 is a top perspective view thereof; and,
D455,001 S + 4/2002 Soergel .... ... D2/882 FIG. 7 is a bottom perspective view thereof.
D474,001 S + 5/2003 Landers ......................... D2/882 The partial human figure shown in broken lines in FIG. 1 is
, :}; ": D2/889 environmental subject matterintended to assistin illustrating
3.096.04 fr 2013 s. ?
2001/0016958 A1 8/2001 Linday
how the design appears when worn, and forms no part of the
claimed design.
2002/0000001 A1 1/2002 Hall McKenzie The broken lines in FIGS. 4 and 7 indicate that no subject
;; A. |; * 1 matter is being claimed within the inside portion thereof.
2007/0061937 A1 3/2007 et al. The stippling in the drawings represents shading, and does
2007/0143906 A1 6/2007 Renteria not represent a material texture or tone.
2008/0163405 A1 7/2008 Jacquartet al.
2009/015 1731 A1* 6/2009 Scott et al. .................... 128/857 1 Claim, 4 Drawing Sheets
Case 1:17-cv-01962-MHC Document 1-1 Filed 05/30/17 Page 2 of 5

U.S. Patent Feb. 5, 2013 Sheet 1 of 4 US D675,403 S

F|G. 1
Case 1:17-cv-01962-MHC Document 1-1 Filed 05/30/17 Page 3 of 5

U.S. Patent Feb. 5, 2013 Sheet 2 of 4 US D675,403 S

F|G. 3
Case 1:17-cv-01962-MHC Document 1-1 Filed 05/30/17 Page 4 of 5

U.S. Patent Feb. 5, 2013 Sheet 3 of 4 US D675,403 S

&
Case 1:17-cv-01962-MHC Document 1-1 Filed 05/30/17 Page 5 of 5

U.S. Patent Feb. 5, 2013 Sheet 4 of 4 US D675,403 S

&
Case 1:17-cv-01962-MHC Document 1-2 Filed 05/30/17 Page 1 of 3

Exhibit 2
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Case 1:17-cv-01962-MHC Document 1-2 Filed 05/30/17 Page 3 of 3
Case 1:17-cv-01962-MHC Document 1-3 Filed 05/30/17 Page 1 of 3

Exhibit 3
Case 1:17-cv-01962-MHC Document 1-3 Filed 05/30/17 Page 2 of 3
Case 1:17-cv-01962-MHC Document 1-3 Filed 05/30/17 Page 3 of 3
Case 1:17-cv-01962-MHC Document 1-4 Filed 05/30/17 Page 1 of 2

Exhibit 4
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Case 1:17-cv-01962-MHC Document 1-5 Filed 05/30/17 Page 1 of 2
JS44 (Rev. 1/13 NDGA) CIVIL COVER SHEET
The JS44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form is required for the use of the Clerk of Court for the purpose of initiating the civil docket record. (SEE INSTRUCTIONS ATTACHED)

I. (a) PLAINTIFF(S) DEFENDANT(S)


John C. McGoogan Decky Co., Inc. d/b/a Decky Company, Decky
Apparel Group, and/or Decky Brands Group

(b) COUNTY OF RESIDENCE OF FIRST LISTED COUNTY OF RESIDENCE OF FIRST LISTED


PLAINTIFF Fulton County, Georgia DEFENDANT
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF


LAND INVOLVED

(c) ATTORNEYS (FIRM NAME, ADDRESS, TELEPHONE NUMBER, AND ATTORNEYS (IF KNOWN)
E-MAIL ADDRESS)

Jonathan D. Crumly, Sr., Esq.


Taylor English Duma LLP
1600 Parkwood Circle, Suite 200
Atlanta, Georgia 30339
(678) 426-4659; jcrumly@taylorenglish.com

II. BASIS OF JURISDICTION III. CITIZENSHIP OF PRINCIPAL PARTIES


(PLACE AN X IN ONE BOX ONLY) (PLACE AN X IN ONE BOX FOR PLAINTIFF AND ONE BOX FOR DEFENDANT)
(FOR DIVERSITY CASES ONLY)

PLF DEF PLF DEF

1 U.S. GOVERNMENT
PLAINTIFF
3 FEDERAL QUESTION
(U.S. GOVERNMENT NOT A PARTY)
1 1 CITIZEN OF THIS STATE 4 4 INCORPORATED OR PRINCIPAL
PLACE OF BUSINESS IN THIS STATE

2 U.S. GOVERNMENT 4 DIVERSITY 2 2 CITIZEN OF ANOTHER STATE 5 5 INCORPORATED AND PRINCIPAL


DEFENDANT (INDICATE CITIZENSHIP OF PARTIES PLACE OF BUSINESS IN ANOTHER
IN ITEM III) STATE
3 3 CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY 6 6 FOREIGN NATION

IV. ORIGIN (PLACE AN X IN ONE BOX ONLY)


TRANSFERRED FROM APPEAL TO DISTRICT JUDGE
1 ORIGINAL
PROCEEDING
2 REMOVED FROM
STATE COURT
3 REMANDED FROM
APPELLATE COURT
4 REINSTATED OR
REOPENED
5 ANOTHER DISTRICT
(Specify District)
6 MULTIDISTRICT
LITIGATION
7 FROM MAGISTRATE JUDGE
JUDGMENT

V. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE - DO NOT CITE
JURISDICTIONAL STATUTES UNLESS DIVERSITY)

This action arises from the Defendants infringement of the Plaintiffs United States Patent.

(IF COMPLEX, CHECK REASON BELOW)

1. Unusually large number of parties. 6. Problems locating or preserving evidence

2. Unusually large number of claims or defenses. 7. Pending parallel investigations or actions by government.

3. Factual issues are exceptionally complex 8. Multiple use of experts.

4. Greater than normal volume of evidence. 9. Need for discovery outside United States boundaries.

5. Extended discovery period is needed. 10. Existence of highly technical issues and proof.

CONTINUED ON REVERSE
FOR OFFICE USE ONLY

RECEIPT # AMOUNT $ APPLYING IFP MAG. JUDGE (IFP)

JUDGE MAG. JUDGE NATURE OF SUIT CAUSE OF ACTION _


(Referral)
Case 1:17-cv-01962-MHC Document 1-5 Filed 05/30/17 Page 2 of 2
VI. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY)
CONTRACT - "0" MONTHS DISCOVERY TRACK CIVIL RIGHTS - "4" MONTHS DISCOVERY TRACK SOCIAL SECURITY - "0" MONTHS DISCOVERY
150 RECOVERY OF OVERPAYMENT & 441 VOTING TRACK
ENFORCEMENT OF JUDGMENT 442 EMPLOYMENT 861 HIA (1395ff)
152 RECOVERY OF DEFAULTED STUDENT 443 HOUSING/ ACCOMMODATIONS 862 BLACK LUNG (923)
LOANS (Excl. Veterans) 444 WELFARE 863 DIWC (405(g))
153 RECOVERY OF OVERPAYMENT OF 440 OTHER CIVIL RIGHTS 863 DIWW (405(g))
VETERAN'S BENEFITS 445 AMERICANS with DISABILITIES - Employment 864 SSID TITLE XVI
446 AMERICANS with DISABILITIES - Other 865 RSI (405(g))
CONTRACT - "4" MONTHS DISCOVERY TRACK 448 EDUCATION
110 INSURANCE FEDERAL TAX SUITS - "4" MONTHS DISCOVERY
120 MARINE IMMIGRATION - "0" MONTHS DISCOVERY TRACK TRACK
130 MILLER ACT 462 NATURALIZATION APPLICATION 870 TAXES (U.S. Plaintiff or Defendant)
140 NEGOTIABLE INSTRUMENT 465 OTHER IMMIGRATION ACTIONS 871 IRS - THIRD PARTY 26 USC 7609
151 MEDICARE ACT
160 STOCKHOLDERS' SUITS PRISONER PETITIONS - "0" MONTHS DISCOVERY OTHER STATUTES - "4" MONTHS DISCOVERY
190 OTHER CONTRACT TRACK
TRACK
195 CONTRACT PRODUCT LIABILITY 375 FALSE CLAIMS ACT
463 HABEAS CORPUS- Alien Detainee
196 FRANCHISE 400 STATE REAPPORTIONMENT
510 MOTIONS TO VACATE SENTENCE
530 HABEAS CORPUS 430 BANKS AND BANKING
REAL PROPERTY - "4" MONTHS DISCOVERY 535 HABEAS CORPUS DEATH PENALTY 450 COMMERCE/ICC RATES/ETC.
TRACK 540 MANDAMUS & OTHER 460 DEPORTATION
210 LAND CONDEMNATION 550 CIVIL RIGHTS - Filed Pro se 470 RACKETEER INFLUENCED AND CORRUPT
220 FORECLOSURE 555 PRISON CONDITION(S) - Filed Pro se ORGANIZATIONS
230 RENT LEASE & EJECTMENT 560 CIVIL DETAINEE: CONDITIONS OF 480 CONSUMER CREDIT
240 TORTS TO LAND CONFINEMENT 490 CABLE/SATELLITE TV
245 TORT PRODUCT LIABILITY 891 AGRICULTURAL ACTS
290 ALL OTHER REAL PROPERTY 893 ENVIRONMENTAL MATTERS
PRISONER PETITIONS - "4" MONTHS DISCOVERY
895 FREEDOM OF INFORMATION ACT
TRACK 950 CONSTITUTIONALITY OF STATE STATUTES
TORTS - PERSONAL INJURY - "4" MONTHS 550 CIVIL RIGHTS - Filed by Counsel 890 OTHER STATUTORY ACTIONS
DISCOVERY TRACK 555 PRISON CONDITION(S) - Filed by Counsel 899 ADMINISTRATIVE PROCEDURES ACT /
310 AIRPLANE REVIEW OR APPEAL OF AGENCY DECISION
315 AIRPLANE PRODUCT LIABILITY FORFEITURE/PENALTY - "4" MONTHS DISCOVERY
320 ASSAULT, LIBEL & SLANDER TRACK OTHER STATUTES - "8" MONTHS DISCOVERY
330 FEDERAL EMPLOYERS' LIABILITY 625 DRUG RELATED SEIZURE OF PROPERTY TRACK
340 MARINE 21 USC 881 410 ANTITRUST
345 MARINE PRODUCT LIABILITY 690 OTHER 850 SECURITIES / COMMODITIES / EXCHANGE
350 MOTOR VEHICLE
355 MOTOR VEHICLE PRODUCT LIABILITY OTHER STATUTES - 0" MONTHS DISCOVERY
LABOR - "4" MONTHS DISCOVERY TRACK
360 OTHER PERSONAL INJURY
362 PERSONAL INJURY - MEDICAL
710 FAIR LABOR STANDARDS ACT TRACK
720 LABOR/MGMT. RELATIONS 896 ARBITRATION
MALPRACTICE
740 RAILWAY LABOR ACT (Confirm / Vacate / Order / Modify)
365 PERSONAL INJURY - PRODUCT LIABILITY
751 FAMILY and MEDICAL LEAVE ACT
367 PERSONAL INJURY - HEALTH CARE/
790 OTHER LABOR LITIGATION
PHARMACEUTICAL PRODUCT LIABILITY
791 EMPL. RET. INC. SECURITY ACT
368 ASBESTOS PERSONAL INJURY PRODUCT
LIABILITY
PROPERTY RIGHTS - "4" MONTHS DISCOVERY TRACK
820 COPYRIGHTS
TORTS - PERSONAL PROPERTY - "4" MONTHS
840 TRADEMARK * PLEASE NOTE DISCOVERY
DISCOVERY TRACK
370 OTHER FRAUD
TRACK FOR EACH CASE TYPE.
371 TRUTH IN LENDING PROPERTY RIGHTS - "8" MONTHS DISCOVERY TRACK SEE LOCAL RULE 26.3
380 OTHER PERSONAL PROPERTY DAMAGE 830 PATENT
385 PROPERTY DAMAGE PRODUCT LIABILITY

BANKRUPTCY - "0" MONTHS DISCOVERY TRACK


422 APPEAL 28 USC 158
423 WITHDRAWAL 28 USC 157

VII. REQUESTED IN COMPLAINT:


CHECK IF CLASS ACTION UNDER F.R.Civ.P. 23 DEMAND $_____________________________
JURY DEMAND YES NO (CHECK YES ONLY IF DEMANDED IN COMPLAINT)

VIII. RELATED/REFILED CASE(S) IF ANY


JUDGE_______________________________ DOCKET NO._______________________

CIVIL CASES ARE DEEMED RELATED IF THE PENDING CASE INVOLVES: (CHECK APPROPRIATE BOX)
1. PROPERTY INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
2. SAME ISSUE OF FACT OR ARISES OUT OF THE SAME EVENT OR TRANSACTION INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
3. VALIDITY OR INFRINGEMENT OF THE SAME PATENT, COPYRIGHT OR TRADEMARK INCLUDED IN AN EARLIER NUMBERED PENDING SUIT.
4. APPEALS ARISING OUT OF THE SAME BANKRUPTCY CASE AND ANY CASE RELATED THERETO WHICH HAVE BEEN DECIDED BY THE SAME
BANKRUPTCY JUDGE.
5. REPETITIVE CASES FILED BY PRO SE LITIGANTS.
6. COMPANION OR RELATED CASE TO CASE(S) BEING SIMULTANEOUSLY FILED (INCLUDE ABBREVIATED STYLE OF OTHER CASE(S)):

7. EITHER SAME OR ALL OF THE PARTIES AND ISSUES IN THIS CASE WERE PREVIOUSLY INVOLVED IN CASE NO. , WHICH WAS
DISMISSED. This case IS IS NOT (check one box) SUBSTANTIALLY THE SAME CASE.

/s/ Jonathan D. Crumly, Sr., Esq. May 30, 2017


SIGNATURE OF ATTORNEY OF RECORD DATE