Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 1 of 7 PageID #: 1

Yoav M. Griver, Esq.

ZEICHNER ELLMAN & KRAUSE LLP
1211 Avenue of the Americas
New York, New York 10036
Phone: (212) 826-5338
Attorneys for plaintiff Samtech LLC d/b/a Massif

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

SAMTECH LLC d/b/a MASSIF

Plaintiff, Civil No. ___________________

v.
COMPLAINT
BROOKLYN ARMED FORCES, LLC and
SPORTSMAN’S GUIDE, LLC f/k/a THE
SPORTSMAN’S GUIDE, INC.,

Defendants

Plaintiff Samtech LLC d/b/a Massif, by its attorneys Zeichner Ellman & Krause LLP, as

and for its complaint against defendants Brooklyn Armed Forces, LLC and Sportsman’s Guide,

LLC f/k/a The Sportsman’s Guide, Inc., alleges, upon information and belief, as follows:

NATURE OF THE ACTION

1. This is a civil action for patent infringement of U.S. Design Patent No. D641,137

(the ‘641 Patent), a copy of which is attached hereto as Exhibit A.

THE PARTIES

2. Plaintiff Samtech LLC d/b/a Massif (“Massif” or “Plaintiff”) is a California

limited liability company with a principal place of business in Ashland, Oregon.

3. Upon information and belief, defendant Brooklyn Armed Forces, LLC (“BAF”) is

a New York limited liability company with a principal place of business in Brooklyn, New York.
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 2 of 7 PageID #: 2

4. Upon information and belief, defendant Sportsman’s Guide, LLC f/k/a The

Sportsman’s Guide, Inc. (“Sportsman’s Guide”) is a Minnesota limited liability company with a

principal place of business in St. Paul, Minnesota. Sportsman’s Guide purchases merchandise

from suppliers located in this judicial district and operates an online business that sells

merchandise to customers in this judicial district.

5. BAF and Sportsman’s Guide are jointly referred to herein as “Defendants”.

JURISDICTION AND VENUE

6. This Court has subject matter jurisdiction over this patent infringement claim

under 28 U.S.C. § 1331 (federal question), and 28 U.S.C. § 1338 (patent infringement).

7. Defendants have committed acts of patent infringement in this judicial district.

8. This Court has personal jurisdiction over Defendants in this action.

9. Venue is proper in this district under 28 U.S.C. § 1400(b) because Defendants

have committed acts of patent infringement in this judicial district, and proper under 28 U.S.C. §

1391 because Defendants reside in this judicial district, and a substantial part of the

events/omissions giving rise to this claim occurred in this judicial district.

FACTS COMMON TO ALL CLAIMS

Massif and the ‘641 Patent

10. Massif manufactures and sells high performance apparel, including flame-

resistant apparel, to customers that include, but is not limited to, the U.S. military. Massif

operates a website at www.massif.com.

11. Massif owns several valuable U.S. patents and other intellectual property. Massif

is the assignee and owner of all right, title, and interest in and to the ‘641 Patent, which the
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 3 of 7 PageID #: 3

United States Patent and Trademark Office issued on July 12, 2011. The ‘641 Patent is a design

patent that covers and protects the ornamental design for a military style jacket.

12. Massif products which incorporate the ‘641 Patent are offered for sale to its

customers in the United States, are commercially successful, and are leading products of their kind

in the market.

13. Massif has complied with the marking requirements of 35 U.S.C. § 287(a).

Defendants’ Infringement of the ‘641 Patent

14. Defendants make, use, sold, sell, and/or offer to sell products variously known as

the “Brooklyn Armed Forces Light Weather Crewman Jacket” (the “Light Weather Jacket”) and

the “Brooklyn Armed Forces Crewman Jacket” (the “Crewman Jacket”) (jointly, the “Accused

Jackets”). Copies of the product pages from the Sportsman’s Guide website for the Light Weather

Jacket and the Crewman Jacket are attached hereto as Exhibit B.

15. Upon information and belief, Defendants have offered to sell the Accused Jackets

to potential customers in this judicial district.

16. Upon information and belief, Defendants have sold the Accused Jackets in this

judicial district and have shipped those products from, within, and into this judicial district.

17. Defendants are not licensed to make, use, sell, or offer to sell products

incorporating the ornamental design for a military style jacket protected by the ‘641 Patent.

Massif’s Notice to Defendants

18. By letter dated November 14, 2022, sent by certified mail and email, counsel for

Massif notified BAF that its Light Weather Jacket was infringing the ‘641 Patent (the “Notice

Letter”).

3
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 4 of 7 PageID #: 4

19. On November 21, 2022, a response was received from BAF principal John

Panousopoulos. In relevant part, he stated that he had “informed SportsmansGuide to

immediately take the picture down [on the website] and stop selling any of these particular

jackets.” Mr. Panouspoulos also stated that BAF was “not planning to manufacture this style

again.”

20. On January 16, 2023, counsel for Massif sent a follow-up email to BAF because

the relevant web page had not been taken down and no further substantive communication had

been received from BAF.

21. That same day, Mr. Panousopoulos replied stating, in relevant part, “we stopped

selling or manufacturing the said object and told Sportsmansguide to pull it from the website!”

22. Since that exchange, the web page for the Light Weather Jacket has been

removed, but Defendants began, or continued, making, using, selling, and offering to sell the

Crewman Jacket.

23. Despite receiving multiple notices from Massif that the Accused Jackets infringe

the ‘641 Patent, Defendants continue making, using, selling, and offering to sell the Accused

Jackets and, upon information and belief, will continue to do so unless stopped by this Court.

FIRST CAUSE OF ACTION

(Patent Infringement)

24. Plaintiff incorporates by reference paragraphs 1 through 23 above, as though fully

set forth herein.

25. Defendants’ actions averred herein constitute patent infringement in violation of 35

U.S.C. § 271.

26. Defendants have been, and currently are, directly infringing the ‘641 Patent by

making, using, selling and offering to sell the Accused Jackets in violation of 35 U.S.C. § 271(a).

4
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 5 of 7 PageID #: 5

27. Sportsman’s Guide also infringes the ‘641 Patent by actively inducing

infringement under 35 U.S.C. § 271(b). Specifically, Sportsman’s Guide actively encourages

customers to use the Accused Jackets and that customer use directly infringes the ‘641 Patent.

The foregoing constitutes active inducement of patent infringement in violation of 35 U.S.C. §

271(b).

28. Sportsman’s Guide has encouraged that infringing customer use even though it

knew (at least after being informed by BAF of the Notice Letter on or before November 21,

2022), or reasonably should have known, that Massif has a patent on the ornamental design for a

military style jacket.

29. Unless Defendants are enjoined, they will continue to infringe the ‘641 Patent

directly and to induce their customers to infringe that patent.

30. Massif has been irreparably harmed by Defendants’ infringement. Unless enjoined,

Defendants will continue to irreparably harm Massif. Monetary damages alone cannot compensate

for this harm.

31. Defendants’ infringement has been willful and deliberate.

32. No later than November 14, 2022, the date it received the Notice Letter, BAF knew

or had reason to know that Massif owned the rights to the ‘641 Patent and that the Accused Jackets

infringed that patent.

33. No later than the date when it was informed of the Notice Letter by BAF (November

21, 2022 or earlier), Sportsman’s Guide knew or had reason to know that Massif owned the rights to

the ‘641 Patent and that the Accused Jackets infringed that patent.

34. Defendants nonetheless continued offering to sell and selling the Accused Jackets to

its customers.

5
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 6 of 7 PageID #: 6

35. Massif is entitled to actual damages, including Defendants’ profits realized by its

unlawful activity, applicable interest, and the cost and effort involved in making Massif whole, under

35 U.S.C. § 284.

36. In addition, Defendants’ deliberate infringement, without any reasonable justification,

makes this an exceptional case, entitling Massif to an award of treble damages under 35 U.S.C. §

284 and an award of attorney fees under 35 U.S.C. § 285.

PRAYER FOR RELIEF

WHEREFORE, Massif prays for the following relief against Defendants:

A. A judgment from this Court that U.S. Design Patent No. D641,137 is valid and
enforceable.

B. A judgment from this Court that Defendants have infringed U.S. Design Patent
No. D641,137.

C. Permanent injunctive relief in the form of an order or orders requiring that

Defendants and their officers, agents, servants, employees, and attorneys, and all
others in active concert or participation with them, be permanently enjoined and
restrained from infringing U.S. Design Patent No. D641,137.

D. Permanent injunctive relief in the form of an order or orders requiring Defendants to

turn over to Massif all infringing products in their possession, custody, or control,
for destruction or other disposition as determined by Massif; and that Defendants
permit an agent of Massif to inspect their premises to ensure compliance with the
Court’s order.

E. An award of damages sufficient to compensate Massif for Defendants’ past

infringement of U.S. Design Patent No. D641,137, together with costs and pre-
judgment interest, under 35 U.S.C. § 284.

F. An award to Massif of treble damages under 35 U.S.C. § 284.

G. An award to Massif of its reasonable attorney’s fees under 35 U.S.C. § 285.

6
 Case 1:23-cv-01185 Document 1 Filed 02/13/23 Page 7 of 7 PageID #: 7

H. An award to Massif of such other and further relief as the Court deems just and
proper.

Dated: New York, New York

February 13, 2023 Respectfully submitted,

___/s/ Yoav M. Griver_______________________

Yoav M. Griver
ZEICHNER ELLMAN & KRAUSE LLP
1211 Avenue of the Americas
New York, New York 10036
Phone: (212) 223-0400
Attorneys for plaintiff Samtech LLC d/b/a Massif

7
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 1 of 15 PageID #: 8

EXHIBIT A
 Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 2 of 15 PageID #: 9

US00D641137S

a2) United States Design Patent 0) Patent No.: US D641,137 S

Evans et al. (45) Date of Patent: xx *Jul. 12,2011

(54) MILITARY STYLE JACKET Primary Examiner — lan Simmons

Assistant Examiner — Rashida Johnson
(75) Inventors: Lindsay M. Evans, Ashland, OR (US), (74) Attorney, Agent, or Firm — Dority & Manning, P.A.
Randy M. Benham, Grants Pass, OR
(US); Amy Lietz Roberts, Renton, WA
(US) (57) CLAIM
The ornamental design for a military style jackct, as shown
(73) Assignee: Massif Mountain Gear Company, and described.
LLC, Ashland, OR (US)

(**) ‘Term: 14 Years DESCRIPTION

(21) Appl. No.: 29/365,465 FIG. 1 is a front perspective view of a first embodiment ofa
military style jacket showing the design;
(22) Filed: Jul. 9, 2010 FIG. 2 is a front view of the military style jacket of FIG. 1;
(51) LOC (9) Ch. ieee eeecccececseeeeeseneneeesceeseneenees 02-02 FIG. 3 is a rear view of the military style jacket of FIG. 1;
(52) US. Ch eee csccceecece cae cnaeeneeensesenneeeerete D2/839 FIG. 4 is a left side view of the military style jacket of FIG. 1;
(58) Field of Classification Search ...........0...... D2/828, FIG. 5 is a right side view of the military style jacket of FIG.
D2/839, 830; 2/93, 94, 96, 98 1;
See application file for complete search history. FIG. 6 is a top view of the military style jacket of FIG. 1;
FIG. 7 is a bottom view of the military style jacket of FIG. 1;
(56) References Cited FIG. 8 is a front perspective view of the military style jacket
of FIG. 1, as worn;
U.S. PATENT DOCUMENTS FIG. 9 is a front perspective view of a second embodiment of
D58,551 S 8/1921 Dalton a military style jacket showing the design;
D59,502 S 10/1921 Meacham FIG. 10 is a front view of the military style jacket of FIG. 9;
D68,120 S 9/1925 Spencer FIG. 11 is a rear view of the military style jacket of FIG. 9;
D96,079 S 7/1935 Anderson FIG. 12 is a left side view of the military style jacket of FIG.
D243,724 S * 3/1977 Schaefer . D2/839
D306,511 S * 3/1990 Jones ........ D2/839 9;
§,127,106 A * 7/1992 Aldridge occ 2/81 FIG. 13 is a right side view of the military style jacket of FIG.
D353,254 § 12/1994 Welch 9;
D374,329 S * 10/1996 Wilde 0... eee D2/836 FIG. 14 is a top view of the military style jacket of FIG. 9;
D402,424 S$ 12/1998 Jackson FIG. 15 is a bottom view of the military style jacket of FIG. 9;
D431,345 S$ 10/2000 Newkirk, Jr.
D464,790 S 10/2002 Townes et al. and,
6,651,254 BI* 11/2003 FIG. 16 is a front perspective view of the military style jacket
D526,467 S * 8/2006 of FIG. 9, as worn.
7,171,695 B2* 2/2007 The broken lines, shown on the surface of the jacket in FIGS.
D555,878 S * 11/2007
1-16, represent stitching. The broken lines in FIGS. 8 and 16,
(Continued) showing portions of the human form, illustrate the design in
use and form no part of the claim.
FOREIGN PATENT DOCUMENTS
DE 10261359 Al * 7/2004 1 Claim, 12 Drawing Sheets
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 3 of 15 PageID #: 10

US D641,137 S
Page 2

U.S. PATENT DOCUMENTS 2009/0249529 AL* 10/2009 Rodriguez ct al. ues 2/97
7,636,948 Bl 12/2009 Crye et al. 2010/0212061 Al* « 8/2010
8 Luciano
wet ........ ”
D620,231 S * 7/2010 Parker ..ssnnsewee D2/828 2010/0212062 Al* 8/2010 Seguin et al.
D622,937 S * 9/2010 Bay D2/830 —* cited by examiner
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 4 of 15 PageID #: 11

U.S. Patent Jul. 12, 2011 Sheet 1 of 12 US D641,137S

Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 5 of 15 PageID #: 12

U.S. Patent Jul. 12, 2011 Sheet 2 of 12 US D641,137S

FG. 2
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 6 of 15 PageID #: 13

U.S. Patent Jul. 12, 2011 Sheet 3 of 12 US D641,137S

AG. 3
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 7 of 15 PageID #: 14

U.S. Patent Jul. 12, 2011 Sheet 4 of 12 US D641,1378S

FIG.4 FIG. 5
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 8 of 15 PageID #: 15

U.S. Patent Jul. 12, 2011 Sheet 5 of 12 US D641,137 S

Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 9 of 15 PageID #: 16

U.S. Patent Jul. 12, 2011 Sheet 6 of 12 US D641,1378S

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US. Patent Jul. 12, 2011 Sheet 7 of 12 US D641,137S

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U.S. Patent Jul. 12, 2011 Sheet 8 of 12 US D641,137 S

FIG. 10
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 12 of 15 PageID #: 19

U.S. Patent Jul. 12, 2011 Sheet 9 of 12 US D641,137 S

Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 13 of 15 PageID #: 20

U.S. Patent Jul. 12, 2011 Sheet 10 of 12 US D641,137S

FIG. 12 Fig. 13
Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 14 of 15 PageID #: 21

U.S. Patent Jul. 12, 2011 Sheet 11 of 12 US D641,137S

Case 1:23-cv-01185 Document 1-1 Filed 02/13/23 Page 15 of 15 PageID #: 22

US D641,137S
Sheet 12 of 12

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Case 1:23-cv-01185 Document 1-2 Filed 02/13/23 Page 1 of 6 PageID #: 23

EXHIBIT B
 Access
CaseDate: November 7, 2022Document
1:23-cv-01185 1-2 Filed 02/13/23 Page 2 of 6 PageID #: 24
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 Case
Access 1:23-cv-01185
Date: November 7, 2022Document 1-2 Filed 02/13/23 Page 3 of 6 PageID #: 25
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Case 1:23-cv-01185 Document 1-3 Filed 02/13/23 Page 1 of 2 PageID #: 29

/s/ Yoav M. Griver

 Case 1:23-cv-01185 Document 1-3 Filed 02/13/23 Page 2 of 2 PageID #: 30

Yoav M. Griver Plaintiff

/s/ Yoav M. Griver

 Case 1:23-cv-01185 Document 1-4 Filed 02/13/23 Page 1 of 2 PageID #: 31

Brooklyn Armed Forces, LLC Sportsman's Guide, LLC

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Case 1:23-cv-01185 Document 1-4 Filed 02/13/23 Page 2 of 2 PageID #: 32