Steer Machine Tool & Die v. SS Niles Bottle Stoppers - Complaint

Case 3:20-cv-01234-CCC Document 1 Filed 07/17/20 Page 1 of 12
IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
Steer Machine Tool & Die Corporation
Plaintiff
vs. CIVIL ACTION NO. _________________
SS Niles Bottle Stoppers, LLC and

Ruth Niles
Defendants
COMPLAINT FOR PATENT VIOLATION (INFRINGEMENT)
Plaintiff, Steer Machine Tool & Die Corporation, by its attorney, as and for its Complaint
against SS Niles Bottle Stoppers, LLC and Ruth Niles, the Defendants, alleges the following:
Parties
1. Plaintiff Steer Machine Tool & Die Corporation (hereinafter “Plaintiff” or “Steer”)
is a Pennsylvania corporation, with a principal place of business located at 3113 Lake Ariel
Highway, Honesdale, Pennsylvania, a registered office at HCR 6 Box 6025, Hawley, Pennsylvania,
and a postal address of 3113 Lake Ariel Highway, Honesdale, Pennsylvania 18431.
2. Defendant SS Niles Bottle Stoppers, LLC (hereinafter “Defendant” or “SS Niles”)
is a Pennsylvania limited liability company, with a registered office and principal place of business
located at 49 Leeds Road, Newville, Pennsylvania.
3. Defendant Ruth Niles (hereinafter “Defendant” or “Ruth”) is an adult individual
under no legal disability with a last known residence address of 49 Leeds Road, Newville,
Pennsylvania. Further, Ruth Niles is, to the information and belief of the Plaintiff, the sole owner
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of the membership of the Pennsylvania limited liability company Co-Defendant herein, SS Niles.
Jurisdiction and Venue
4. The venue for patent infringement matters is 28 U.S.C. § 1400, more particularly 28
U.S.C. § 1400(b), which provides that any civil action for patent infringement may be brought in a
judicial district where the Defendant resides or where the Defendant has committed acts of
infringement and has a regular and established place of business.
5. The Court has personal jurisdiction over Defendant SS Niles based on SS Niles’s
operation of its business and contacts within this jurisdiction.
6. This Court has personal jurisdiction over Defendant Ruth based on Ruth’s contacts
within this jurisdiction.
7. As recited above, venue is proper in this district pursuant to 28 U.S. C. § 1400(b) for
the Defendants reside in this judicial district, and the Defendant SS Niles has committed acts of
infringement and has regular established place of business.
Facts Common to All Claims for Relief
8. Steer is engaged in the business of inventing, patenting, marketing and selling, among
others, tool and die, bottle stoppers and mandrels, and other bottle stopper turning accessories, both
to individuals and business entities which have use for the same.
9. The sole membership of Steer and the sole directors and officers are two siblings,
Steven Seeuwen and Eric Seeuwen. The residency of Steven Seeuwen is in Pike County and the
residency of Eric Seeuwen is in Wayne County, Pennsylvania where the principal place of business
of Plaintiff is conducted therefrom.
10. Steven Seeuwen and Eric Seeuwen along with Ruth Niles jointly made certain new
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and useful design inventions. The design inventions made by Defendant Ruth Niles and Steven
Seeuwen and Eric Seeuwen were the subject of design patents issued by the United States Patent &
Trademark Office. The said patents issued by the United States Patent & Trademark Office were
given design patent numbers D575,639 and D758,853 (herein collectively referred to as the “Bottle
Stopper Patents”).
11. A copy of the Bottle Stopper Patents are attached as Exhibit A and Exhibit B
respectively
Defendant Ruth Niles and, through Defendant Ruth Niles (sole owner of SS Niles),
SS Niles, have had knowledge of the Bottle Stopper Patents and the designs covered therein from
the date of issuance of the Bottle Stopper Patents through the present.
12. Unhappy differences occurred between the Plaintiff and its principals, Steven
Seeuwen and Eric Seeuwen, on the one hand, and the Co-Defendants, on the other hand, which
resulted in a case in the United States Middle District of Pennsylvania assigned Case No. 3:16-cv-
320.
13. Case No. 3:16-cv-320 was initiated by Defendant SS Niles at the direction of
Defendant Ruth Niles and was filed against the Plaintiff herein Steer.
14. Said Case No. 3:16-cv-320 was settled. A copy of the CONFIDENTIAL
SETTLEMENT AGREEMENT AND MUTUAL RELEASE (hereinafter “Settlement Agreement”)
is attached hereto and made a part hereof as Exhibit C.
15. Among other matters appurtenant to this Complaint in said Settlement Agreement the
Defendants agreed to assign, and did assign their undivided one-third (1/3) interest in the Bottle
Stopper Patents equally to Steven Seeuwen and Eric Seeuwen in return for a license to Co-Defendant
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SS Niles.
16. The terms of the license to Defendant SS Niles are set out in the Settlement
Agreement (Exhibit C). A copy of the Assignment as recited above is attached as Exhibit D.
17. Steven Seeuwen and Eric Seeuwen assigned their entire right, title and interest in the
Bottle Stopper Patents to the Plaintiff Steer. Said assignment is attached hereto and made a part
hereof as Exhibit E. The assignment by the said Steven Seeuwen and Eric Seeuwen to the Plaintiff
Steer includes, among other matters, the right to obtain all remedies for past acts of infringement by
others.
18. The license granted to Defendant SS Niles, a legal entity of the Commonwealth of
Pennsylvania owned, directed and operated by Defendant Ruth Niles gave the following to
Defendant SS Niles:
a. A right to use, sell or import bottle stoppers covered by the Bottle Stopper
Patents;
b. The right to either manufacture bottle stoppers covered by the Bottle Stopper
Patents, or to have another party manufacture such bottle stoppers solely for
Defendant SS Niles.
19. The license granted to SS Niles in the Settlement Agreement (Exhibit C) was subject
to the following restrictions:
a. SS Niles was the only party given the right to sell the bottle stoppers covered
by the Bottle Stopper Patents;
b. SS Niles was not permitted to grant any sub-licenses;
c. Manufacturers of bottle stoppers covered by the Bottle Stopper Patents
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engaged by SS Niles were only permitted to manufacture and sell said bottle
stoppers to Defendant SS Niles;
d. SS Niles was not permitted to authorize any Manufacturer or any other party
to manufacture bottle stoppers covered by the Bottle Stopper Patents and sell
those bottle stoppers to any party other than SS Niles.
20. The license of SS Niles was the only license under which Defendant Ruth Niles could
directly or indirectly use, sell, import or have manufactured the bottle stoppers covered by the Bottle
Stopper Patents.
21. On information and belief, SS Niles sells a bottle stopper designated SS6000, which
is covered by D575,639, one of the Bottle Stopper Patents.
22. On information and belief, SS Niles sells a bottle stopper designated as SS8000,
which is covered by D758,853, one of the Bottle Stopper Patents.
23. The license of SS Niles was not granted to Co-Defendant Ruth Niles individually.
On the dissolution of Defendant SS Niles, merger, sale of assets, stock or other substantial change
in business operation by the Company whereby Ruth Niles is no longer the sole owner of SS Niles,
the license automatically terminates. As averred above, SS Niles, while owned and operated by Co-
Defendant Ruth Niles, is the only party permitted to sell the bottle stoppers covered by the Bottle
Stopper Patents besides the Plaintiff Steer.
24. The aforesaid Settlement Agreement was executed by Co-Defendant SS Niles through
the signature of Ruth Niles on October 3, 2016.
25. Exhibit D provides, as regards the Bottle Stopper Patents, that Ruth Niles agrees to
be legally bound in her individual capacity to perform the duties as to the said patents and license.
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26. Unquestionably, Defendants SS Niles and Ruth Niles, each and both knew and
continue to know the terms of the license specified in the Settlement Agreement (Exhibit C).
27. Defendants SS Niles and Ruth Niles, each and both knew and continue to know that
Defendant SS Niles and Ruth Niles, as the sole owner and sole member of SS Niles, never had the
right to authorize any party to manufacture bottle stoppers covered by the Bottle Stopper Patents and
sell those bottle stoppers to any party other than SS Niles.
28. Defendant SS Niles has a website. On the subject website, the said Defendant SS
Niles advertises for sale its SS-6000 (SS-301) bottle stopper. The Defendant SS Niles item SS-6000
(SS-301) bottle stopper is the bottle stopper covered by Patent D 575,639. Patent D 575,639
(Exhibit A) is one of the Bottle Stopper Patents that is the subject of the Settlement Agreement
(Exhibit D), and that was assigned by Ruth Niles to Steven Seeuwen and Eric Seeuwen and then
subsequently assigned by Steven Seeuwen and Eric Seeuwen to Plaintiff Steer (Exhibit E). The
above referenced advertisement on Defendant SS Niles Bottle Stoppers, LLC’s website is attached
hereto as Exhibit F.
29. As is conspicuous, clear and unequivocal, the said advertisement of Defendant SS
Niles’s website (Exhibit F) states “for larger quantities buy wholesale direct from the Manufacturer.”
The said SS Niles website includes a link to permit any individual and/or entity to place orders with
the Manufacturer.
Also as part of Exhibit F, the Defendants under the name American Stainless directs
the reader to the Manufacturer(s) for purchase of quantities of one or more of the Steer Bottle
Stopper Patents stoppers.
30. On information and belief, one or more orders were placed with the Manufacturer by
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entities other than SS Niles for bottle stoppers covered by one or more of the Bottle Stopper Patents
through the link provided on the SS Niles website.
31. Additionally, Ruth Niles / SS Niles advertises on a Facebook posting that Bottle
Stopper Patent D575,639 (Steer 301 cone and SS Niles SS 6000) is now available from her
Manufacturer directly, with a direct link on the Facebook posting to the Manufacturer.
32. On information and belief, the Manufacturer filled orders for bottle stoppers covered
by one or both of the Bottle Stopper Patents to entities other than SS Niles, which orders were placed
with the Manufacturer through the link on the SS Niles website and/or on the Niles Facebook
posting.
33. On information and belief, SS Niles through its sole member, Co-Defendant Ruth
Niles, authorized its Manufacturer of bottle stoppers covered by the Bottle Stopper Patents to sell
such bottle stoppers to purchasers other than Defendant SS Niles, at least by posting a link (Exhibit
F) on the webpage and also on a Facebook posting link advising others to place such orders with the
Manufacturer.
34. On information and belief, Co-Defendants SS Niles and Ruth Niles, each and both,
since October 3, 2016 and continuously thereafter to the present, have had knowledge that by
authorizing Defendant SS Niles’s Manufacturer to make bottle stoppers covered by one or both of
the Bottle Stopper Patents and to sell such bottle stoppers to entities other than SS Niles, such
Manufacturer(s) is/are infringing on one or both of the Bottle Stopper Patents.
35. On information and belief, based on the improper authorization by SS Niles through
its sole owner / member, Ruth Niles, SS Niles’s Manufacturer(s) has/have manufactured bottle
stoppers covered by one or both of the Bottle Stopper Patents and has/have sold such bottle stoppers
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to entities other than SS Niles.
The said manufacture and sale by Manufacturer to entities other than SS Niles is a
direct infringement of one or both of the Bottle Stopper Patents.
Said infringement originates with and is caused by the said improper authorization
of Defendant SS Niles through Ruth Niles, the sole owner of SS Niles.
36. On information and belief, SS Niles through Ruth Niles, the sole owner / member of
SS Niles, has actively induced such infringement of one or both of the Bottle Stopper Patents as
alleged above.
37. On information and belief, Precision Crafted Products is an authorized Manufacturer
of bottle stoppers for SS Niles
The said Precision Crafted Products has, on information and belief, manufactured
bottle stoppers covered by one or both of the Bottle Stopper Patents at the direction of SS Niles
acting through Ruth Niles as the sole owner/member of SS Niles.
On information and belief, Precision Crafted Products knowingly authorized by SS
Niles Bottle Stoppers, LLC and Ruth Niles, its sole owner/member thereof, has manufactured and
sold bottle stoppers known by Ruth Niles and SS Niles to be covered by one or both of the Bottle
Stopper Patents to entities other than SS Niles Bottle Stoppers, LLC. Such authorization to
manufacture and sell said bottle stoppers to entities other than SS Niles as attested to by Exhibit F
is improper and constitutes acts of inducing infringement under United States Patent Law.
COUNT I
Inducement of Infringement Under 35 U.S.C. 271(b)
38. Plaintiff Steer repeats and re-alleges each and every allegation and averment in
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paragraphs 1-37, which are incorporated herein by reference as if more fully set out at length.
39. Co-Defendant SS Niles and Co-Defendant Ruth Niles are liable as patent infringers.
40. The said liability of SS Niles and Ruth Niles as patent infringers arises from the active
inducement of infringement of one or both of the Bottle Stopper Patents by its Manufacturer(s).
41. The act of inducement of infringement of one or both of the Bottle Stopper Patents
has been and is committed consciously, knowingly and intentionally by the said Co-Defendants, SS
Niles and Ruth Niles. The act of inducement arises from the improper and intentional authorization
of Manufacturer(s) to manufacture bottle stoppers that are known and that have always been known
to be covered by one or both of the Bottle Stopper Patents and to sell such bottle stoppers to entities
other than SS Niles.
42. On information and belief, one or more of the Manufacturers, including the
aforementioned Precision Crafted Products, have sold bottle stoppers covered by one or both of the
Bottle Stopper Patents to entities other than SS Niles based on the averred and recited improper
authorization of SS Niles and Ruth Niles.
43. Under 35 U.S.C. 271, more particularly 271(b), and based on the above averments,
each and both of the Co-Defendants, SS Niles and Ruth Niles, have actively induced infringement
and continue to induce infringement of one or both of the Bottle Stopper Patents and therefore are
liable to Plaintiff as a patent infringer. Therefor Plaintiff is entitled to all remedy and relief under
federal patent law as more fully set forth below in the requested relief.
COUNT II
Pennsylvania Common Law - Breach of Contract
44. Plaintiff Steer repeats and re-alleges each and every allegation in paragraphs 1–43,
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which are incorporated herein by reference.
45. Count II jurisdiction is ancillary to the jurisdiction of Count I.
46. As averred above, Defendant SS Niles through its principal, sole owner and member,
Ruth Niles, executed the Settlement Agreement (Exhibit D) in settlement of a civil action in the
United States District Court for the Middle District of Pennsylvania, Scranton, Pennsylvania in the
prior litigation as averred above.
47. Said Settlement Agreement is an enforceable contract.
48. Said Settlement Agreement provided for mutual promises and undertakings of the
within Defendant, SS Niles to the Plaintiff, Steer, and of the within Plaintiff to the Defendant.
49. The Settlement Agreement also is binding on the shareholders and officers of Plaintiff
and Defendant, including Ruth Niles. (Section 11 of Settlement Agreement)
50. Said mutual promises and undertakings were fair consideration to each of the parties
to the Settlement Agreement.
51. As incorporated herein by reference to the paragraphs above, the Defendant SS Niles
and Ruth Niles, each and both, have breached various portions of the Settlement Agreement which
legally bound each other and are so stated to be legally binding on each other to the benefit and right
of the Plaintiff.
52. The Co-Defendants SS Niles and Ruth Niles have, contrary to the Settlement
Agreement, authorized a third party (Manufacturer) to manufacture bottle stoppers covered by one
or both of the Bottle Stopper Patents owned by Steer, and to sell such bottle stoppers to entities other
than SS Niles.
53. The actions of the Defendants SS Niles and Ruth Niles as regards said breaches of
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the Settlement Agreement are done knowingly and intentionally.
54. Each and all of the aforesaid activities described in the facts, the Exhibits, and the
Counts are to the detriment, harm and loss of the Plaintiff. The said Co-Defendants in having
knowingly and intentionally breached the Settlement Agreement (Exhibit C) are liable to the Plaintiff
Steer for consequential damages, incidental damages, liquidated damages and other damages that
are available, including those prescribed in the Settlement Agreement.
Requested Relief
WHEREFORE, Plaintiff Steer respectfully requests judgment against the Defendants SS
Niles and Ruth Niles as follows:
(1) Permanently restraining and enjoining Defendants SS Niles Bottle Stoppers, LLC and
Ruth Niles from authorizing any manufacturer to make bottle stoppers covered by one or both of the
Bottle Stopper Patents and selling them to entities other than SS Niles.
(2) Permanently restraining and enjoining Defendants, SS Niles and Ruth Niles from
posting link(s) to Manufacturers to place orders and buy bottle stoppers covered by one or both of
the Bottle Stopper Patents.
(3) Damages adequate to compensate Plaintiff for the infringing acts of Defendants,
including interest and costs.
(4) Trebling of Damages resulting from the willful infringing acts of Defendants.
(5) Profits lost by Plaintiff as a result of the infringing acts of Defendants and its
Manufacturers.
(6) As an alternative to patent damages under 35 U.S.C. 284, an award of Total Profits
made by Defendants, including but not limited to profits made by the direct infringing Manufacturers
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as a result of sales made by such Manufacturers to entities other than SS Niles, which were
improperly authorized by Defendants, in accordance with 35 U.S.C. 389.
(7) Attorneys’ fees based on a holding that this is an exceptional case.
(8) In addition to the compensatory relief set out above, the liquidated damages for
breach of the Settlement Agreement as set out therein together with costs, reasonable attorney’s fees
and such other relief as the Court may deem appropriate under the circumstances.
Respectfully submitted,
Dated: 07/17/20 /s/ Brigid E. Carey

Brigid E. Carey, Esquire
Pa. Attorney ID 08308
3218 Pittston Avenue
PO Box 4466
Scranton, PA 18505-6466
Phone: (570) 344-1799
Cell: (570) 430-4964
Fax: (570) 341-7060
Email: becesqnepa@aol.com
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Case 3:20-cv-01234-CCC Document 1-1 Filed 07/17/20 Page 1 of 1
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 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 by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

Steer Machine Tool & Die Corporation SS Niles Bottle Stoppers, LLC and Ruth Niles
(b) County of Residence of First Listed Plaintiff Wayne County of Residence of First Listed Defendant Cumberland
(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)
Brigid E. Carey, Esquire

PO Box 4466, Scranton, PA 18505
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)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 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 Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 USC 271(b)
VI. CAUSE OF ACTION Brief description of cause:
Inducement of infringement of patent(s)
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE Joseph Saporito DOCKET NUMBER 3:18-cv-0204
DATE SIGNATURE OF ATTORNEY OF RECORD
07/17/2020 /s/ Brigid E. Carey, Esquire
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE
This Confidential Settlement Agreement and Mutual Release (“Agreement”), by and between
SS Niles Bottle Stoppers, LLC (“SS Niles”) and Steer Machine Tool & Die Corporation (“Steer
Machine” or “Steer”), is effective as of the date of the last signature set forth below.
Whereas SS Niles has filed Case No. 3:16-cv-320, SS Niles Bottle Stoppers, LLC v. Steer
Machine Tool & Die Corp., in the United States District Court for the Middle District of
Pennsylvania (the “Lawsuit”), and
And whereas SS Niles and Steer Machine (each a “Party,” collectively the “Parties”) wish to
resolve their differences amicably with no admission of liability by either party,
Therefore, in consideration of the mutual releases, representations, and covenants contained

herein, the Parties agree as follows:
1. PAYMENT.
Together with the execution of this Agreement, Steer Machine will deliver the gross sum of
Forty-Five Thousand Dollars and Zero Cents ($45,000.00) (the “Payment”) which shall be in full
and final settlement of all claims against the Steer Machine and the Released Parties (as defined
hereafter), specifically including insurers, reinsurers and attorneys in any capacity. Steer Machine
will make the Payment in the form of one check payable to:
Ryder Lu Mazzeo & Konieczny LLC Trust (IOLTA) Account for the benefit of SS Niles
Bottle Stoppers LLC.
Steer Machine, through its agents, shall deliver the Payment to SS Niles’ agents within 30
days of Steer Machine’s receipt of a fully executed original of this Confidential Settlement
Agreement and Mutual Release (the “Agreement”).
SS Niles represents that the Payment is made in resolution of disputed legal claims and that,
at SS Niles’ request, Steer Machine will not withhold any amount from the Payment for taxes or
other regular deductions. It is understood and agreed that SS Niles shall be solely, individually and
completely responsible for payment of all local, state and federal taxes owed, if any, as a result of
any payments made pursuant to this Agreement.
2. RELEASE.
The releases in this Agreement include an express, informed, knowing and voluntary waiver
and relinquishment to the fullest extent permitted by law. With the exception of the obligations
described in this Agreement, each Party hereby releases, acquits and forever discharges every other
Party, as well as each Party’s agents, attorneys, officers, directors, insurers, employees, successors
by interest or merger, corporate parents, predecessors, affiliates, representatives, assigns, executors,
and/or administrators, in both official and individual capacities, from any and all claims, demands,
liabilities, actions and suit of whatever kind, whether known or unknown, including but not limited
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to claims for federal, state or common law violations of patent infringement, copyright infringement,
trademark infringement, trademark dilution, cyberpiracy, unfair competition, commercial
disparagement, unjust enrichment, tortious interference with prospective economic advantage,
breach of contract, and fraud, that are arising from, relating to or pertaining in any way to claims
stated in the suit captioned SS NILES BOTTLE STOPPERS, LLC V. STEER MACHINE TOOL &
DIE CORP., filed in the United States District Court for the Middle District of Pennsylvania, Case
No. 3:16-cv-320 (the “Lawsuit”) or otherwise related to their direct and indirect business
relationship through the date of this Release. The foregoing release includes, without limitation,
claims which any Party now has asserted or could have asserted, within the Lawsuit.
The Parties expressly acknowledges that this Agreement may be pled as a complete defense
and will fully and finally bar any and all claims, known or unknown, based on any matter, act,
omission, transaction, occurrence, or event that has occurred or is alleged to have occurred up to the
date of this Agreement.
When used in this Agreement, the word “Released Parties” means SS Niles, Steer Machine
and any and all of its past and present divisions, subsidiaries, parents, affiliates, joint ventures and
other related entities, and each of their past and present directors, officers, managers, partners,
owners, shareholders, members, attorneys, insurers, reinsurers, benefit plan fiduciaries, supervisors,
employees, representatives, administrators, agents, contractors and consultants and each of their
predecessors, successors, heirs, executors, and assigns, both current and former. The parties
expressly understand and agree that, when used in this Agreement, the word “Released Parties” shall
also include Ruth Niles, Steven Seeuwen, Eric Seeuwen, Dan Seeuwen and each of their
predecessors, successors, heirs, executors, and assigns, both current and former, as well as all
parents, grandparents, children, grandchildren, siblings, in-laws, and other relatives through blood or
marriage of any of the Released Parties.
3. TRADEMARK.
Steer Machine will terminate and will not hereafter use or register or attempt to register or
maintain or control the registration of the mark SS NILES, or any part of such mark, or any similar
marks, or any form of SS NILES, standing alone or as a component of, its business name, trade
name, trademark, service mark, domain name, email address, keyword, search engine term, metatag,
or any other format, anywhere in the United States, for any purpose, including, but not limited to,
LinkedIn, Twitter, Facebook, Pinterest, Google Plus, and any business or personal website.
Notwithstanding the provisions of this paragraph 3, Steer Machine may continue using the
SS BOTTLE STOPPERS mark, but not the SS NILES mark, for a period of 60 days after the
effective date of this Agreement for the sole purpose of transitioning its customers away from its use
of the mark. By the end of this 60-day period, Steer Machine will withdraw and/or cancel its
Pennsylvania Department of State fictitious name application/registration for “SS Bottle Stoppers”
and any other fictitious name applications or registrations it has that contain “SS” or “NILES”.
After this 60-day period, Steer Machine will discontinue all use of the SS BOTTLE STOPPERS
mark in any manner whatsoever. Steer Machine may continue using the domain name
<ssbottlestoppers.com> for a period of 60 days after the effective date of this Agreement for the sole
purpose of transitioning its customers to its new website. After this 60-day period, Steer will
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maintain ownership of the <ssbottlestoppers.com> domain, but all Parties will discontinue the use of
the <ssbottlestoppers.com> domain name in any manner whatsoever. Steer may not transfer the
<ssbottlestoppers.com> domain name to any other person or entity.
Notwithstanding the provisions of this paragraph 3, Steer Machine may use the designation
“SS” or “ss” (collectively “SS/ss”) in its printed materials and invoices only for the sole purpose of
abbreviating “stainless steel.” When used on said printed materials and invoices, Steer Machine
agrees to the following:
1) SS/ss also cannot be used immediately preceding or immediately after the words “bottle
stoppers” or similar variations of “bottle stoppers.” Notwithstanding the preceding
sentence, Steer Machine is permitted to use the following designation “304SS
Bottlestoppers” to identify its products, wherein the number 304 is only an example and
other numbers can be used. The Parties agree that Steer will always use the designation
304SS Bottlestoppers and SS Niles will always use the designation SS304 Bottlestoppers
to designate their bottlestopper products, wherein the number 304 is only an example and
other numbers can be used.
2) When it uses SS/ss, the font size of SS/ss shall not be any larger than the font size of the
surrounding words, nor can SS/ss be highlighted or in any way made more prominent
than the words around SS/ss.
Notwithstanding the immediately preceding paragraph and consistent with the rest of this paragraph
3, Steer Machine cannot use SS/ss as a trademark or service mark. Steer Machine cannot use SS/ss
in any domain name, email address, key word term, search engine term, metatag, or in LinkedIn,
Twitter, Facebook, Pinterest, Google Plus or any other Internet advertising
4. DOMAIN NAMES.
SS Niles represents and warrants that it owns and controls the domain names
<steerbottlestoppers.com>, <steerstainlessstoppers.com>, and <steermachinestoppers.com>
(together the “Steer Domain Names”) and that these are the only domain names under Niles’ control
that contain the word “STEER” or any variation thereof.
Steer Machine represents and warrants that it owns and controls the domain name
<ssbottlestoppers.com> and that it is the only domain name under Steer’s control that contains the
terms SS or NILES or similar terms.
No later than ten (10) days after the effective date of this Agreement, SS Niles will effectuate
an “account change” through GoDaddy.com or any other required entity whereby it will transfer
ownership of its registrations in the Steer Domain Names to Steer Machine. The Parties agree to
cooperate with each other in good faith to accomplish the transfer, including by timely confirming
the transfer to the applicable registrars and exchanging the necessary account information and
documents. Until the transfer is completed, SS Niles will not allow any of its registrations for the
Steer Domain Names to expire, and will re-register them if they would otherwise expire.
As stated in paragraph 3 above, Steer Machine may continue using the domain name
<ssbottlestoppers.com> for a period of 60 days after the effective date of this Agreement.
Page 3 of 12
5. PATENTS.
The Parties covenant, represent, and warrant that neither will contest, nor assist in any
contest in any forum, including Federal Courts, as to whether Patents D575, 639 and D758,853 (the
“Bottle Stopper Patents”) are valid and enforceable. Subject to the terms and conditions of the
Assignment Agreement attached hereto as “Exhibit A”, which is hereby incorporated by reference,
Steven Seeuwen and Eric Seeuwen grant SS Niles a royalty-free, non-exclusive, non-transferable,
irrevocable, fully-paid license under the Bottle Stoppers Patents to make, sell, use and offer for sale
such licensed bottle stoppers (“Patent License”); provided however that the Parties intend that the
license granted herein extends only to SS Niles so long as it is owned and operated by Ruth Niles.
The Patent License shall remain binding on Steer Machine, Steven Seeuwen, Eric Seeuwen
and their successors, assignees, heirs, administrators, executors, and legal representatives, unless
terminated for reasons set forth herein. SS Niles shall only exercise its rights under the Bottle
Stopper Patents to manufacture, have manufactured solely for its, use, sell or import bottle stoppers.
SS Niles may not grant any sub-licenses under this Agreement. SS Niles may not assign its rights
under this Agreement and any attempt to assign will be void. Upon dissolution of SS Niles, merger,
sale of assets, stock, or any other substantial change in business operations by the company whereby
Ruth Niles is no longer the owner of SS Niles, said license will automatically terminate and be of no
tangible or intangible value.
Nothing in this Agreement shall affect Steven Seeuwen and Eric Seeuwen’s ownership or
control of the Bottle Stopper Patents or the right to operate and carry on its business under the Bottle
Stopper Patents. Except for the non-exclusive license set forth in this Agreement, all other rights are
reserved to Steven Seeuwen and Eric Seeuwen.
For this paragraph 5 only, Ruth Niles, Steven Seeuwen and Eric Seeuwen, for the
consideration provided, agree to be legally bound in their individual capacities to perform the duties
stated in this paragraph.
6. INVENTORY AND RETURNS.
The Parties agree that SS Niles will retain any remaining inventory now in its existing
inventory and Steer Machine will waive SS Niles’ outstanding balance of $1,520.63. SS Niles shall
assume full risk and responsibility for the nature and quality of the products it provides and for
refunds, returns and for any other ancillary services SS Niles provides to its customers.
7. PRODUCT NUMBERS.
The Parties agree that Steer Machine can, and intends to continue to use its product numbers
without challenge by SS Niles
8. MUTUAL NON-DISPARAGEMENT AND CONFIDENTIALITY.
Each Party understands and agrees that it will not in any way act or seek in the present or
Page 4 of 12
future to disparage the other Party or any of the Released Parties, regarding their products, Patents,
prior business relations, past conduct during their affiliation with each other, or the matters described
within the Lawsuit.
Each Party agrees to refrain from publishing statements that are intended to, or that are
reasonably likely to, disparage, impugn, or injure the reputation of the other Party or any of the
Released Parties. This shall include, but is not limited to, any and all publications or postings on
social media (i.e. Facebook, Instagram, LinkedIn, etc). Further, each Party shall not knowingly
encourage any other person to make any public or private statements, whether written or oral, that
disparages, defames, is derogatory or mispresents the other Party. In addition, both Parties agree to
remove any existing published references to the other Party, either specifically or by reasonable
inference.
The Parties agree to keep all information concerning the Lawsuit, including but not limited to
any term of this Agreement confidential, and not to disclose such information to any other person,
except as required by law or legal process, or for the purpose of obtaining legal or financial advice
from a professional who is bound to keep the information confidential, such as an attorney or an
accountant. In the event that either Party concludes that it is compelled by law or legal process to
disclose any such information or portion thereof, such Party shall give written notice of the same to
the other Party, at least ten (10) business days before disclosing the information, to the extent
possible.
The only information that either Party may publicly communicate about the Lawsuit without
violating the terms of this paragraph is that the Parties have amicably resolved their differences and
dismissed the Lawsuit, or substantially equivalent statements. No such statements should state,
imply or suggest that either party was at fault or admitted liability.
9. BREACH OF NON-DISPARAGEMENT, CONFIDENTIALITY AND

RELATED CLAIMS -- LIQUIDATED DAMAGES.
The Parties acknowledge and agree that the time and expenses involved in proving in any
forum the actual damage or loss suffered by the other Party make this case appropriate for liquidated
damages. Accordingly, instead of requiring any proof of damages or losses, the Parties agree that, as
liquidated damages for any single incident of breach of paragraphs 3, 4, 5 or 8 (but not as a penalty),
the breaching Party shall pay the other Party the sum of Nine Thousand Dollars and Zero Cents
($9,000.00). This $9,000.00 shall be payable after a finding that the breaching Party has breached
paragraphs 3, 4, 5 or 8 of this Agreement. For purposes of this paragraph “finding” means that result
of any un-appealed or un-appealable decision. Neither the breach of said paragraphs 3, 4, 5 or 8 nor
the payment of liquidated damages shall affect the continuing validity or enforceability of this
Agreement. The prevailing party shall recover its attorneys’ fees incurred in connection with any
claim based upon a breach of paragraphs 3, 4, 5 or 8 of this Agreement.
10. NO ADMISSION OF LIABILITY.
The Consideration and other provisions in this Agreement are made as a compromise of
Page 5 of 12
disputed claims. By entering into this Agreement neither Party has “prevailed’ as to any of the
claims contained within the Lawsuit. Neither the Consideration nor this Agreement is an admission
of liability by any Party, and Steer Machine denies that its former domain name in any way infringed
upon any interest owned or controlled by SS Niles. The purpose of this Agreement is to end all
claims between the Parties within the Lawsuit.
11. BINDING ON SUCCESSORS.
This Agreement shall be binding upon the Parties hereto and their respective shareholders,
officers, directors, employees, successors, assigns, heirs, administrators, executors, and legal
representatives.
12. EXCLUSIVE JURISDICTION AND GOVERNING LAW.
The Parties consent and agree that Judge James M. Munley and Magistrate Judge Karoline
Mehalchick, United States Judges for the Middle District of Pennsylvania, to the extent they are
available in their present capacities, shall have sole and exclusive jurisdiction over any lawsuit,
claim or dispute which arises out of, relates to, or pertains in any way to the Lawsuit or the
enforcement of this Agreement. Both parties agree and explicitly waive their ability to hear any
dispute arising out of this Agreement or the Lawsuit in any other forum or jurisdiction.
This Agreement shall be construed and interpreted in accordance with the laws of the
Commonwealth of Pennsylvania and both Parties intend to be legally bound.
13. ENTIRE AGREEMENT.
This agreement is the entire agreement between the Parties and supersedes any prior
agreements or understandings between the Parties, whether written or verbal, and may only be
modified by a writing signed by the Parties.
14. SEVERABILITY.
In the event any term of this Agreement is found by the Court to be void or otherwise
unenforceable, the remainders of this Agreement shall remain valid and enforceable as though such
term were absent upon the date of its execution.
15. NOTICE.
Notices under this Agreement shall be in writing and sent via U.S. Express mail or private
express courier services (with receipt confirmed and will be effective upon receipt at the address
stated below (unless the Parties are notified in writing of a change in address, in which case notice
will be sent to the new address) and by email to the following addresses:
If to SS Niles:
Ms. Ruth Niles
SS Niles Bottle Stoppers, LLC
Page 6 of 12
49 Leeds Rd.
Newville, PA 17241
ruth@nilesbottlestoppers.com
With copy to:

Frank A. Mazzeo, Esq.
Ryder, Lu, Mazzeo & Konieczny, LLC
Suite 200
808 Bethlehem Pike
Colmar, PA 18915
fmazzeo@ryderlu.com
If to Steer Machine:
Mr. Steven Seeuwen
Steer Machine Tool & Die Corp.
76 Kernwood Dr
Honesdale, PA 18431
sales@steermachine.com
With copy to:

Margolis Edelstein
Attn: Michael R. Miller, Esq.
The Curtis Center, Suite 400E
170 S. Independence Mall W.
Philadelphia, PA 19106
mmiller@margolisedelstein.com
16. EXECUTION.
This Agreement may be executed in counterparts. Copies of the Agreement transmitted by

facsimile or in PDF format shall be as binding as an original copy.
17. UNDERSTANDING AND ACCEPTANCE OF AGREEMENT.
Each Party has had the opportunity to selects its own attorney to represent it in the Lawsuit
and review this Agreement. Each Party acknowledges it has relied upon the legal advice of its own
attorneys, who are the attorneys of the Party’s choice and it is their obligation to pay their attorneys.
The terms of this Agreement has been completely read by each Party and explained to each Party by
that Party’s attorneys. Those terms are fully understood and voluntarily accepted. This Agreement
shall be interpreted as if mutually drafted by counsel for all Parties.
WHEREFORE, the Parties, by their duly authorized representatives, have executed this
Page 7 of 12
Agreement.
SS NILES BOTTLE STOPPERS, LLC
By: ____________________________________
Date:
STEER MACHINE TOOL & DIE CORP.
By: ____________________________________
Date:
For paragraph 5, Patents, only, Ruth Niles, Steven Seeuwen and Eric Seeuwen, for the
consideration provided, agree to be legally bound in their individual capacities to perform the duties
stated in paragraph 5.
__________________ _______________________
Ruth Niles, Individual Steven Seeuwen, Individual
_____________________
Eric Seeuwen, Individual
Page 8 of 12
EXHIBIT A
ASSIGNMENT OF INVENTION
WHEREAS, I, Ruth Niles, residing at 49 Leeds Road, Newville PA 17241, have, along with
Steven Seeuwen and Eric Seeuwen, made certain new and useful design inventions, which are the subject
of U.S. Design Patent Nos. D575,639 and D758,853, hereinafter collectively referred to as “Subject
Patents”;
WHEREAS, Ruth Niles is the owner of an undivided one-third (1/3) interest in the Subject
Patents;
WHEREAS, Ruth Niles, in connection with the settlement of civil action Case No. 3:16-cv-
320, SS Niles Bottle Stoppers, LLC v. Steer Machine Tool & Die Corp, in the United States District
Court for the Middle District of Pennsylvania (the “Lawsuit”), has agreed to assign her undivided
one-third interest in the Subject Patents equally to Steven Seeuwen and Eric Seeuwen in return for a
license under the Subject Patents to be set forth in a Settlement Agreement executed on even date
herewith.
NOW, THEREFORE, in consideration of the foregoing recitals and the mutual promises
herein made and exchanged, and for other good and valuable consideration, the receipt and sufficiency
of which are hereby acknowledged Ruth Niles agrees as follows:
Ruth Niles, by these presents does agree to assign and transfer and does hereby assign and
transfer to Steven Seeuwen and Eric Seeuwen, equally, her undivided one-third interest in the
Subject Patents, and any reissues, reexaminations, renewals or extensions thereof, including the
right to recover for acts of past infringement by others.
Ruth Niles, warrants and represents that she has the right to make the assignment and transfer
set forth in this Agreement and that she has not previously granted any rights whatsoever to the
Subject Patents, or to either of them, to any other party or entity.
Page 9 of 12
TO BE HELD AND ENJOYED by Steven Seeuwen and Eric Seeuwen, their, legal representatives and
assigns to the full ends of the terms for which the Subject Patents, or any of them, have been or will have been
granted and I hereby agree for myself, my heirs, executors and administrators, to execute without further
consideration, any further legal documents and any further assignments and any releases, reissues, reexaminations,
renewals, extensions or other applications for Letters Patent that may be deemed necessary either by Steven Seeuwen
or Eric Seeuwen, fully to secure to Steven Seeuwen and Eric Seeuwen their interest as aforesaid in and to the Subject
Patents or any part thereof.
IN WITNESS WHEREOF, having read the aforesaid Assignment and intending to be legally bound thereby, I,
Ruth Niles, hereunto affix my hand and seal on this day of ,2016.
__________________________________
Name: Ruth Niles
Address: 49 Leeds Road
Newville PA 17241
Commonwealth of Pennsylvania : SS
County of __________________ :
Before me personally appeared said Ruth Niles and acknowledged the foregoing instrument to be her free
act and deed this day of September 2016.
______________________________
NOTARY PUBLIC
My commission expires:
Page 10 of 12
Steven Seeuwen, hereunto affix my hand and seal on this day of ,2016.
__________________________________
Name: Steven Seeuwen
Address: 111 Oak Ridge Drive
Hawley PA 18428
County of __________________ :
Before me personally appeared said Steven Seeuwen and acknowledged the foregoing instrument to be
his free act and deed this day of September 2016.
______________________________
NOTARY PUBLIC
Page 11 of 12
Eric Seeuwen, hereunto affix my hand and seal on this day of ,2016.
__________________________________
Name: Eric Seeuwen
Address: 308 Kemwood Drive
Honesdale PA 18431
County of __________________ :
Before me personally appeared said Eric Seeuwen and acknowledged the foregoing instrument to be his
free act and deed this day of September 2016.
______________________________
NOTARY PUBLIC
Page 12 of 12

Steer Machine Tool &amp; Die v. SS Niles Bottle Stoppers - Complaint

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Steer Machine Tool &amp; Die v. SS Niles Bottle Stoppers - Complaint

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Case 3:20-cv-01234-CCC Document 1 Filed 07/17/20 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT

Steer Machine Tool & Die Corporation

vs. CIVIL ACTION NO. _________________

SS Niles Bottle Stoppers, LLC and

COMPLAINT FOR PATENT VIOLATION (INFRINGEMENT)

2. Defendant SS Niles Bottle Stoppers, LLC (hereinafter “Defendant” or “SS Niles”)

located at 49 Leeds Road, Newville, Pennsylvania.

3. Defendant Ruth Niles (hereinafter “Defendant” or “Ruth”) is an adult individual

Jurisdiction and Venue

infringement and has a regular and established place of business.

operation of its business and contacts within this jurisdiction.

within this jurisdiction.

infringement and has regular established place of business.

Facts Common to All Claims for Relief

of Plaintiff is conducted therefrom.

SETTLEMENT AGREEMENT AND MUTUAL RELEASE (hereinafter “Settlement Agreement”)

is attached hereto and made a part hereof as Exhibit C.

to the following restrictions:

by the Bottle Stopper Patents;

b. SS Niles was not permitted to grant any sub-licenses;

c. Manufacturers of bottle stoppers covered by the Bottle Stopper Patents

stoppers to Defendant SS Niles;

those bottle stoppers to any party other than SS Niles.

is covered by D575,639, one of the Bottle Stopper Patents.

which is covered by D758,853, one of the Bottle Stopper Patents.

Stopper Patents besides the Plaintiff Steer.

the signature of Ruth Niles on October 3, 2016.

sell those bottle stoppers to any party other than SS Niles.

29. As is conspicuous, clear and unequivocal, the said advertisement of Defendant SS

Stopper Patents stoppers.

through the link provided on the SS Niles website.

Manufacturer(s) is/are infringing on one or both of the Bottle Stopper Patents.

to entities other than SS Niles.

direct infringement of one or both of the Bottle Stopper Patents.

of Defendant SS Niles through Ruth Niles, the sole owner of SS Niles.

37. On information and belief, Precision Crafted Products is an authorized Manufacturer

of bottle stoppers for SS Niles

acting through Ruth Niles as the sole owner/member of SS Niles.

On information and belief, Precision Crafted Products knowingly authorized by SS

Inducement of Infringement Under 35 U.S.C. 271(b)

other than SS Niles.

authorization of SS Niles and Ruth Niles.

Pennsylvania Common Law - Breach of Contract

which are incorporated herein by reference.

45. Count II jurisdiction is ancillary to the jurisdiction of Count I.

prior litigation as averred above.

47. Said Settlement Agreement is an enforceable contract.

and Defendant, including Ruth Niles. (Section 11 of Settlement Agreement)

to the Settlement Agreement.

the Settlement Agreement are done knowingly and intentionally.

are available, including those prescribed in the Settlement Agreement.

WHEREFORE, Plaintiff Steer respectfully requests judgment against the Defendants SS

Niles and Ruth Niles as follows:

the Bottle Stopper Patents.

including interest and costs.

improperly authorized by Defendants, in accordance with 35 U.S.C. 389.

(7) Attorneys’ fees based on a holding that this is an exceptional case.

Dated: 07/17/20 /s/ Brigid E. Carey

I. (a) PLAINTIFFS DEFENDANTS

Brigid E. Carey, Esquire

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

CONFIDENTIAL SETTLEMENT AGREEMENT AND MUTUAL RELEASE

Steer Machine Tool & Die v. SS Niles Bottle Stoppers - Complaint

Steer Machine Tool & Die v. SS Niles Bottle Stoppers - Complaint