Case 3:18-cv-03150-MEJ Document 1 Filed 05/25/18 Page 1 of 10

1
ARI LAW, P.C.
2 ALI A. AALAEI, State Bar No. 254713
E-mail: ali@arilaw.com
3 ALEXANDER CHEN, State Bar No. 245798
E-mail: alex@arilaw.com
4 90 New Montgomery St., Suite 900
San Francisco, CA 94105
5 Tel: 415-830-9968
Fax: 415-520-9456
6
Attorneys for Plaintiff
7 SANHO CORPORATION
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10

11 SANHO CORPORATION, a Delaware Case No.

corporation;
12 COMPLAINT FOR
Plaintiff,
13 (1) PATENT INFRINGEMENT
v.
(2) COPYRIGHT INFRINGEMENT
14
KAIJET TECHNOLOGY (3) UNFAIR BUSINESS PRACTICES
15 INTERNATIONAL LIMITED, INC., a (4) UNJUST ENRICHMENT
company, doing business as “j5create”; and
16 DOES 1-100, DEMAND FOR JURY TRIAL
17 Defendants.

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COMPLAINT
Case No.
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1 Plaintiff, SANHO CORPORATION (“Plaintiff”), for all causes of action against

2 Defendant KAIJET TECHNOLOGY INTERNATIONAL LIMITED, INC. doing business as

3 j5create, alleges as follows:

4
INTRODUCTION
5
1. This action arises from the unfair, unlawful, and fraudulent acts and practices of
6
defendant Kaijet Technology International Limited, Inc. (“Defendant”). Defendant has, to the
7 detriment of the plaintiff in this case, Sanho Corporation (“Plaintiff”), as set forth below,
8 unlawfully infringed, copied, and trampled on Plaintiff’s intellectual property rights and has
9 injured plaintiff as a result of unfair competition. Defendants’ unlawful and unfair conduct is
10 comprised of violations of the California Unfair Business Practices Act, the False Advertising
11 Law, the Patent Act, the Lanham Act, and the Copyright Act. Defendants’ conduct was willful,
12 and is causing Plaintiff to suffer irreparable harm.
13
JURISDICTION
14
2. This is a civil action seeking damages and injunctive relief for patent and copyright
15
infringement under the Patent Act, 35 U.S.C. § 101, et seq., and the Copyright Act, 17 U.S.C. §
16
101, et seq.
17
3. This Court has subject matter jurisdiction over Plaintiff’s claims pursuant to 28 U.S.C. §§
18
1331, and 1338.
19 4. This Court has personal jurisdiction over the Defendant because they are doing business in
20 the State of California and in this judicial district, the acts of infringement complained of herein
21 occurred in the State of California. Defendants have intended to cause and have caused injury to
22 Plaintiff and its economic advantage and goodwill in the State of California.
23
INTRADISTRICT ASSIGNMENT
24
5. Pursuant to Civil L.R. 3-2(c), this case should be subject to district-wide assignment
25
because it is an Intellectual Property Action.
26

27

28 –1–
COMPLAINT
CASE NO.
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1 VENUE

2 6. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b), (c), and 1400(b).

3 THE PARTIES
4 7. Plaintiff is a Delaware corporation, with its headquarters located in Fremont, CA.
5 Plaintiff does business in California and across the United States.
6 8. Defendant Kaijet Technology International Limited, Inc., aka j5Create, is a business entity
7 doing business in CA.
8 9. Plaintiff does not know the true names and capacity of defendants sued herein as DOES 1-
9 100, and therefore sues these defendants by such fictitious names. Plaintiff is informed and
10 believes, and on the basis of that information and belief, alleges, that each of the defendants was

11 in some manner legally responsible for the events and happenings alleged in this complaint and

12 for Plaintiff’s damages. DOES 1-100 have sold, offered for sale, and are selling the infringing

13 products online on various websites including but not limited to at eBay.com and Amazon.com,

14 although the true identities of DOES 1-100 remains unknown. Defendant Kaijet and Does 1-100

15 may be hereinafter referred to as “Defendants.” Plaintiff will amend this complaint to allege their

16 true names and capacities when ascertained.

17
GENERAL AVERMENTS
18
10. Plaintiff Sanho Corporation is a company based in Fremont, CA.
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11. Plaintiff, on or around December 5, 2016, released the HyperDrive multi-function docking
20
station. Notably, the HyperDrive multi-function docking station has a novel ornamental design.
21
The invention was displayed publicly at the Consumer Electronics Show in January of 2017.
22
Plaintiff’s product had been widely hailed in the media as Plaintiff went on to raise over $3.1M
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on Kickstarter and Indigogo. Thereafter, Plaintiff became the lawful assignee of United States
24
Patent No. US D813,875 S, (the “875 Patent”), which describes the multi-function docking
25
station. Sanho began shipping the product in or around January 2017.
26
12. Notably, Plaintiff has built goodwill and customer reputation having been operating for
27
more than 12 years, and its packaging, trademarks, tradenames, as well as the HyperDrive
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COMPLAINT
CASE NO.
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1 branding have gained secondary meaning, well before Kaijet ever began its unlawful scheme.

2 Sanho’s trademarks, tradenames, and goodwill, also carry secondary meaning with respect to the
quality, warranty guarantees, and brand reputation affiliated with Plaintiff’s products and its
3
customers’ expectations of the same.
4
13. On or around October 2017, Kaijet, or j5create, copied and began using, making, and
5
selling, Plaintiff’s invention and called it the “UltraDrive” solely to counterfeit and
6
misappropriate Plaintiff’s HyperDrive multi-function docking station. To make matters worse,
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Kaijet named and labeled its product the “UltraDrive” intentionally to confuse Sanho’s customers
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when purchasing the HyperDrive. Defendant blatantly copied the packaging of Plaintiff’s
9
product (Exhibit A), clearly intending to create confusion by consumers in misappropriating
10
Sanho’s product and ideas, infringed on Plaintiff’s intellectual property and copyrights, and
11
interfere with Plaintiff’s economic advantage engaging in unfair competition. Defendants copied
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the product and packaging, including, but not limited to, the following:
13
On the front of Packaging
14
Similar sounding product name "UltraDrive" vs "HyperDrive"
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Same product brand name placement on top left corner
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Similar product window cutout on the front left of the box
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Similar product description below the product window cutout
18 Same image of MacBook Pro on the front right of the box
19 Same call outs to "4K HDMI" and "50Gbps" speed
20 Similar orange color highlights
21 On the back of Packaging
22 Similar product image with MacBook Pro on the back top of the box
23 Similar product description below the product image
24 See Exhibit B to this Complaint.
25 14. Defendants intentionally copied the image, form, and design of Plaintiff’s product

26 including its packaging in order to misappropriate Plaintiff’s ideas, inventions, efforts, marks, and

27 economic advantage. As a result Plaintiff suffered harm.

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COMPLAINT
CASE NO.
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1 15. Prior to December 2016, Defendant Kaijet did not sell the product herein at issue. It was

2 only after Kaijet copied the product and misappropriated the idea from Sanho that it began the

3 infringing conduct.

4 16. It is undisputed that Plaintiff is the assignee of the ‘875 Patent. Plaintiff owns all right,
title and interest in the ‘875 Patent. A true and correct copy of the ‘875 Patent is attached to the
5
complaint as Exhibit C.
6
17. The ‘875 Patent claims a multi-function docking station.
7
18. Plaintiff submitted an application for copyright registration with the United States
8
Copyright Office relating to its images, advertising, and packaging for the multi-function docking
9
station on May 4, 2018, which was approved, as Registration Number VA0002103336. The
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registration included the relevant image at Exhibit A hereto.
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19. As set forth herein, after Plaintiff begin advertising and selling its product, Plaintiff
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discovered that Defendant and/or its agents had made, used, advertised, sold, and offered for sale
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products embodying the ‘875 Patent and furthermore that Defendant and/or its agents had copied
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Plaintiff’s packaging with respect to Plaintiff’s multi-function docking station product the
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HyperDrive.
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20. Notably, Defendant does not have any license, authorization, permission or consent to use
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Plaintiff’s packaging, copyrights, patents, or intellectual property.
18 21. Defendants continued to copy Plaintiff’s business. For example, after Plaintiff released
19 the product Defendant copied the product. After Plaintiff began selling its product online
20 Defendant started selling the product online. After Plaintiff started selling its product in stores at
21 Best Buy then Defendant subsequently began selling its inferior product adjacent therewith in a
22 manner that was likely to deceive a reasonable person.
23 22. On or around November 20, 2017, Plaintiff sent written notice to Defendant regarding
24 Defendant’s infringement and demanded that Defendant immediately cease and desist.
25 Defendant refused to cease and desist and has continued its unfair and unlawful scheme. As a

26 result of Defendant’s unfair scheme, Plaintiff suffered and will continue to suffer irreparable

27 harm. Plaintiff has suffered and will also suffer losses in excess of $1,000,000.00.

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COMPLAINT
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1 23. Plaintiff is entitled to injunctive relief and redress for Defendant’s willful, intentional and

2 purposeful use and exploitation of Plaintiff’s intellectual property with full knowledge that such

3 use constituted unlawful infringement of, and was in disregard of, Plaintiff’s rights, also

4 constituting unfair business practices.

5 COUNT I
6 (Patent Infringement)
7 (35 U.S.C. § 271)
8 24. Plaintiff re-alleges and incorporates by reference all paragraphs of this Complaint.
9 25. Defendant has and continues to infringe the ‘875 Patent by using, selling, and offering for
10 sale products embodying the patent-in-suit, including the Ultradrive or UltraDrive products sold

11 by Defendant.

12 26. Defendants have used, sold, and offered to sell products infringing the patent-in-suit by

13 copying the patented article and specifically targeting consumers in California and on the West

14 Coast, including Plaintiff’s customers, through online websites, including Defendant’s own

15 website and on other websites, as well as selling the infringing product in stores located in

16 California, including in San Francisco County and Alameda County.

27. Plaintiff has suffered damages as the result of Defendants’ infringement of the ‘875
17
Patent.
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28. Defendants’ infringement is willful, as Plaintiff has demanded that Defendant cease from
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infringement and the unfair business practices, but Defendant, and its affiliates and agents
20
continue to advertise, sell, and/or offer for sale, the infringing products.
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29. As a direct and proximate result of the foregoing acts and conduct, Plaintiff has sustained
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and will continue to sustain substantial, immediate, and irreparable injury, for which there is no
23
adequate remedy at law. Plaintiff is informed and believed and on that basis avers that unless
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enjoined and restrained by this Court, Defendants will continue to infringe Plaintiff’s rights.
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Plaintiff is entitled to preliminary and permanent injunctive relief to restrain and enjoin
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Defendants’ continuing infringing conduct.
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COMPLAINT
CASE NO.
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1 COUNT II

2 (Copyright Infringement)

3 (17 U.S.C. §§ 106 and 501)

4 30. Plaintiff re-alleges and incorporates by reference all paragraphs of this Complaint.
31. Through their conduct averred herein, Defendant has infringed Plaintiff’s copyright in
5
violation of Sections 106 and 501 of the Copyright Act, 17 U.S.C. §§ 106 and 501.
6
32. Defendants’ acts of infringement are willful, intentional and purposeful, in disregard of
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and with indifference to Plaintiff’s rights.
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33. As a direct and proximate result of said infringement by Defendants, Plaintiff is entitled to
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damages in an amount to be proven at trial.
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34. Plaintiff is also entitled to Defendants’ profits attributable to the infringement, pursuant to
11
17 U.S.C. § 504(b), including an accounting of and a constructive trust with respect to such
12
profits.
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35. Plaintiff further is entitled to its attorneys’ fees and full costs pursuant to 17 U.S.C. § 505
14
and otherwise according to law.
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36. As a direct and proximate result of the foregoing acts and conduct, Plaintiff has sustained
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and will continue to sustain substantial, immediately, and irreparable injury, for which there is no
17
adequate remedy at law. Plaintiff is informed and believes and on that basis avers that unless
18 enjoined and restrained by this Court, Defendants will continue to infringe Plaintiff’s rights.
19 Plaintiff is entitled to preliminary and permanent injunctive relief to restrain and enjoin
20 Defendants’ continuing infringing conduct.
21
COUNT III
22
(Violation of California Unfair Business Practices Act)
23
(Cal. Bus. & Prof. Code Section 17200)
24
29. Plaintiff herein re-alleges and incorporates by reference each and every allegation
25
contained in the instant pleading.
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30. Defendants unlawfully, unfairly, and fraudulently copied the packaging of Plaintiff’s
27
product and the product itself, in contravention of Plaintiff’s rights.
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COMPLAINT
CASE NO.
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1 31. Defendants’ conduct was a deliberate attempt to create confusion with Plaintiff’s product

2 and unfairly divert Plaintiff’s ideas, customers, and economic advantage, unfairly to Defendants.

3 32. Defendants have misled, and has attempted to mislead, consumers into believing that the

4 copied product is Plaintiff’s product and is likely to deceive an ordinary person.

5 33. Defendants’ conduct, including but not limited to, violations of applicable statutes and

6 laws, constitutes unlawful, unfair, and fraudulent business practices in violation of, inter alia,

7 California Business and Professions Code § 17200, et seq.

8 34. Defendants’ conduct was an unlawful practice under § 17200.

9 35. Defendants’ conduct was immoral, unethical, oppressive, and unscrupulous constituting

10 unfair business practices under California Business and Professions Code § 17200.

11 36. Plaintiff lost money and/or property as a result of Defendant’s unlawful, unfair, and

12 fraudulent acts.

13 37. Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.

14 38. Pursuant to California Business and Professions Code § 17203, Plaintiff seek an order

15 enjoining Defendants from engaging in further unlawful, unfair, and/or fraudulent business acts,

16 and restitution of money and/or property Plaintiff has lost on account of such acts.

17 COUNT IV

18 UNJUST ENRICHMENT

19 39. Plaintiff re-alleges and incorporates each and every paragraph of this complaint as if fully

20 set forth herein.

21 40. Defendants have engaged in unlawful, unfair, and fraudulent acts and practices, within the

22 meaning of California Business & Professions Code § 17200, et seq., and in violation of the laws

23 set forth in this complaint. As a result, Defendants have been unjustly enriched, at the expense of

24 Plaintiff.

25 41. Under the circumstances, it would be against equity and good conscience to permit

26 Defendants to retain the ill-gotten benefits that were received from and to the detriment of

27 Plaintiff. It would be unjust and/or inequitable for Defendants to retain such benefits without

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COMPLAINT
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1 restitution to Plaintiff.

2 42. Accordingly, Plaintiff seeks an order establishing Defendant(s), and any agents or sellers

3 of Defendants as constructive trustees of the profits received by collecting the unfair amounts that

4 served to unjustly enrich them, together with interest during the period in which defendants have

5 retained such funds, and requiring Defendants to disgorge those funds to Plaintiff in a manner to

6 be determined by the Court.

7 43. Therefore, Plaintiff prays for relief as set forth below.

9 JURY TRIAL DEMAND

10 Plaintiff hereby demands a trial by jury.

11
PRAYER FOR RELIEF
12
1. That judgment be entered in favor of Plaintiff against Defendant;
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2. That Defendants be preliminarily and permanently enjoined from infringement;
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3. That Plaintiff be awarded compensatory, lost profits, and special damages for the
15
infringement in an amount to be determined at trial;
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4. That the Court award Plaintiff enhanced damages and attorneys’ fees;
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5. That Plaintiff be awarded additional costs, attorney’s fees, and damages, based on
18
Defendant’s knowing and willful infringement;
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6. That Plaintiff be awarded costs of this suit, including but not limited to attorney’s fees;
20
7. That Plaintiff be awarded pre-judgment interest;
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8. That Plaintiff be awarded statutory damages or penalties;
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9. For an accounting of, and the imposition of a constructive trust with respect to,
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Defendants’ profits attributable to their infringements of Plaintiff’s intellectual property;
24
10. For reasonable and statutory attorneys’ fees;
25 11. For costs;
26 12. For such other and further relief as the Court may deem just and proper.
27 WHEREFORE, a demand for jury trial is made.
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COMPLAINT
CASE NO.
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1 Respectfully submitted,

3 Date: May 25, 2018

4 ARI LAW, P.C.

5
By: /s/ Ali A. Aalaei
6
ARI LAW, P.C.
7 ALI A. AALAEI, State Bar No. 254713
E-mail: ali@arilaw.com
ALEXANDER CHEN, State Bar No. 245798
8 E-mail: alex@arilaw.com
90 New Montgomery St., Suite 900
9 San Francisco, CA 94105
Tel: 415-830-9968
10 Fax: 415-520-9456
11 Attorneys for Plaintiff,
SANHO CORPORATION
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COMPLAINT
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Exhibit A
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Exhibit B
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Exhibit C
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JS-CAND 44 (Rev. 06/17) Case 3:18-cv-03150-MEJ Document 1-2 Filed 05/25/18 Page 1 of 1
CIVIL COVER SHEET
The JS-CAND 44 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, approved in its original form by the Judicial Conference of the United States in September 1974, is required for the Clerk of
Court to initiate the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Sanho Corporation Kaijet Technology International Limited, Inc., a company, doing business as
j5create
(b) County of Residence of First Listed Plaintiff : Alameda County of Residence of First Listed Defendant Cobb County
(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, and Telephone Number) Attorneys (If Known)
ARI LAW, P.C., Ali Ari Aalaei, Esq. 90 New Montgomery St, #900
SAN FRANCISCO, CA 94105

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
PTF DEF PTF DEF
1 U.S. Government Plaintiff 3 Federal Question Citizen of This State 1 1 Incorporated or Principal Place 4 4
(U.S. Government Not a Party)
of Business In This State
Citizen of Another State 2 2 Incorporated and Principal Place 5 5
2 U.S. Government Defendant 4 Diversity of Business In Another State
(Indicate Citizenship of Parties in Item III)
Citizen or Subject of a 3 3 Foreign Nation 6 6
Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only)

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure of 422 Appeal 28 USC § 158 375 False Claims Act
120 Marine Property 21 USC § 881 423 Withdrawal 28 USC 376 Qui Tam (31 USC
310 Airplane 365 Personal Injury – Product
130 Miller Act Liability 690 Other § 157 § 3729(a))
315 Airplane Product Liability
140 Negotiable Instrument 367 Health Care/ 400 State Reapportionment
320 Assault, Libel & Slander LABOR PROPERTY RIGHTS
150 Recovery of Pharmaceutical Personal 410 Antitrust
330 Federal Employers’ 710 Fair Labor Standards Act 820 Copyrights
Overpayment Of Injury Product Liability 430 Banks and Banking
Liability 720 Labor/Management 830 Patent
Veteran’s Benefits 368 Asbestos Personal Injury 450 Commerce
340 Marine Relations 835 Patent─Abbreviated New
151 Medicare Act Product Liability
345 Marine Product Liability 740 Railway Labor Act Drug Application 460 Deportation
152 Recovery of Defaulted PERSONAL PROPERTY 470 Racketeer Influenced &
350 Motor Vehicle 751 Family and Medical 840 Trademark
Student Loans (Excludes 370 Other Fraud Corrupt Organizations
355 Motor Vehicle Product Leave Act
Veterans) 371 Truth in Lending SOCIAL SECURITY
Liability 790 Other Labor Litigation 480 Consumer Credit
153 Recovery of 380 Other Personal Property 861 HIA (1395ff)
360 Other Personal Injury 791 Employee Retirement 490 Cable/Sat TV
Overpayment Damage Income Security Act 862 Black Lung (923) 850 Securities/Commodities/
of Veteran’s Benefits 362 Personal Injury -Medical
Malpractice 385 Property Damage Product 863 DIWC/DIWW (405(g)) Exchange
160 Stockholders’ Suits Liability IMMIGRATION
864 SSID Title XVI 890 Other Statutory Actions
190 Other Contract 462 Naturalization
CIVIL RIGHTS PRISONER PETITIONS 865 RSI (405(g)) 891 Agricultural Acts
195 Contract Product Liability Application
440 Other Civil Rights HABEAS CORPUS 893 Environmental Matters
196 Franchise 465 Other Immigration FEDERAL TAX SUITS
441 Voting 463 Alien Detainee Actions 895 Freedom of Information
870 Taxes (U.S. Plaintiff or
REAL PROPERTY 442 Employment Act
510 Motions to Vacate Defendant)
210 Land Condemnation Sentence 896 Arbitration
443 Housing/ 871 IRS–Third Party 26 USC
220 Foreclosure Accommodations 530 General § 7609 899 Administrative Procedure
445 Amer. w/Disabilities– Act/Review or Appeal of
230 Rent Lease & Ejectment 535 Death Penalty
Employment Agency Decision
240 Torts to Land OTHER
446 Amer. w/Disabilities–Other 950 Constitutionality of State
245 Tort Product Liability 540 Mandamus & Other Statutes
290 All Other Real Property 448 Education
550 Civil Rights
555 Prison Condition
560 Civil Detainee–
Conditions of
Confinement

V. ORIGIN (Place an “X” in One Box Only)

1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District (specify) Litigation–Transfer Litigation–Direct File

VI. CAUSE OF Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 USC 271; 17 USC 106, 501
ACTION
Brief description of cause:
patent; copyright; unfair competition
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, Fed. R. Civ. P. JURY DEMAND: Yes No

VIII. RELATED CASE(S), JUDGE DOCKET NUMBER

IF ANY (See instructions):
IX. DIVISIONAL ASSIGNMENT (Civil Local Rule 3-2)
(Place an “X” in One Box Only) SAN FRANCISCO/OAKLAND SAN JOSE EUREKA-MCKINLEYVILLE

DATE 05/25/2018 SIGNATURE OF ATTORNEY OF RECORD /s/ ALI A. AALAEI (SBN 254713)

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