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) ) Plaintiff, ) ) v. ) ) BIOFIT ENGINEERED PRODUCTS, INC. ) ) Defendant. ) COMPLAINT Plaintiff AmTab Manufacturing Corporation (AmTab), by its attorneys, complains of defendant BioFit Engineered Products, Inc. (BioFit or Defendant) and alleges as follows: Parties 1. AmTab is an Illinois corporation with its principal place of business located in Aurora, Illinois. 2. AmTab is a manufacturer of traditional-use and specialty tables and other products, including mobile folding tables. 3. On information and belief, Defendant BioFit is an Ohio corporation with its principal place of business located at 15500 BioFit Way, Bowling Green, Ohio 43402. 4. On information and belief, BioFit manufactures chairs, stools and mobile folding products including mobile folding tables, and sells those products throughout the United States, including within this District.

Civil Action No. 1:11-cv-8363

Jury Trial Demanded

Jurisdiction and Venue 5. This action is an action for patent infringement under the laws of the United States, Title 35 of the United States Code, as set forth below. 6. This Court has subject matter jurisdiction over the claims in this action pursuant to 28 U.S.C. 1331 and 1338(a). 7. Personal jurisdiction and venue are proper in this judicial district pursuant to 28 U.S.C. 1391 and 1400(b) because BioFit does business in this District and because BioFit has committed acts of infringement in this District. Patent Infringement 8. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 7, with the same force and effect as if fully set forth herein. 9. On July 20, 2010, United States Patent No. 7,758,113 entitled Stool with a Noncircular Support (the 113 Patent), a copy of which is attached hereto as Exhibit A, was duly, validly and legally issued by the United States Patent and Trademark Office. AmTab owns the full right, title and interest in and to the 113 Patent and is entitled to sue for infringement of the 113 Patent. 10. In violation of 35 U.S.C. 271, BioFit makes, uses, offers to sell, sells and/or imports products that infringe one or more claims of the 113 Patent. On information and belief, BioFit has offered for sale and/or sold such infringing products throughout the United States, including locations within this District, through established distribution channels. 11. The 113 Patent was publicly available and, on information and belief, BioFit has been fully aware of the 113 Patent.

12. AmTab manufactures and sells products covered by the 113 Patent and has marked such products pursuant to 35 U.S.C 287(a). 13. On information and belief, with full knowledge of the 113 Patent, BioFit willfully continue to make, use, offer to sell, sell and/or import products that infringe the 113 Patent. 14. BioFits acts of willful infringement have damaged, and unless enjoined by this Court, will continue to damage Plaintiff, and have caused and will continue to cause irreparable harm for which Plaintiff has no adequate remedy at law. Relief Sought WHEREFORE, Plaintiff AmTab Manufacturing Corporation respectfully requests that the Court grant the following relief: a. A preliminary and permanent injunction preventing infringement by the Defendant of U.S. Patent No. 7,758,113; b. Damages of lost profits, but in no event less than a reasonable royalty, to the maximum extent permitted by law, for Defendants past and current infringement of U.S. Patent No. 7,758,113; c. An award of treble damages and attorneys fees by reason of Defendants willful infringement of U.S. Patent No. 7,758,113; d. An award of interest, including prejudgment interest; e. An assessment of costs and disbursements of this action; and f. Such other and further relief as justice and equity may require.

Jury Demand Plaintiff AmTab Manufacturing Corporation hereby demands trial by jury.

Respectfully submitted, AMTAB MANUFACTURING CORPORATION November 22, 2011 By: /s/Eric H. Weimers One of its attorneys James D. Ryndak #2435942 Eric H. Weimers #6205977 Mark K. Suri #6199636 Jeffrey S. Dixon #6291231 RYNDAK & SURI LLP 200 W. Madison Street Suite 2100 Chicago, IL 60606 Phone: 312-214-7770 Fax: 312-214-7715