You are on page 1of 3

Case: 1:12-cv-04281 Document #: 1 Filed: 06/01/12 Page 1 of 3 PageID #:1


STEVEN M. BENNETT, an individual, Plaintiff,

) ) ) ) v. ) ) ) SUNLITE CAR COVERS, LTD., ) a California corporation ) Defendant. ) ____________________________________)

Case No.


COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, STEVEN M. BENNETT, for its Complaint against SUNLITE CAR COVERS, LTD., alleges as follows: THE PARTIES 1. Plaintiff, Steven M. Bennett (Bennett), is an individual residing at 611 Plantation Drive, Surfside Beach, South Carolina. 2. Defendant, SunLite Car Covers, Ltd. (SunLite), is a corporation with its principal place of business located at 1550 Schwab Street, Red Bluff, California. JURISIDCTION AND VENUE 3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 (federal uestion), 1332 (a) (diversity of citizenship), and 1338(a) (question related to patents). 4. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 and 1400.

Case: 1:12-cv-04281 Document #: 1 Filed: 06/01/12 Page 2 of 3 PageID #:2

FACTS GIVING RISE TO PATENT INFRINGEMENT 5. Bennett is the inventor and owner of United States Patent No. D436,341 that covers a design of a vehicular cover (Bennetts Patent). 6. SunLite offers to sell and sells in this District vehicular covers, and in particular its Nascar car cover that infringes Bennetts Patent under 35 U.S.C. 271(a). 7. Bennett has provided written notice to SunLite of its infringement of Bennetts Patent. 8. SunLite has continued to manufacture and sell the infringing Nascar car cover. 9. Sunlites infringement of Bennetts Patent has been willful, as it has been notified of its infringement of the Bennett Patent, but has continued to infringe the Bennett Patent.

WHEREFORE, Bennett prays that a judgment be entered in its favor and against SunLite as follows: (a) SunLite infringes U.S. Patent D436,341 under 35 U.S.C. 271; (b) SunLites infringement has been willful; (c) Bennett be awarded damages pursuant to 35 U.S.C. 284; (d) Bennett be awarded prejudgment interest; (e) Bennett be awarded increased damages pursuant to 35 U.S.C. 284; (f) Bennett be awarded its attorney fees pursuant to 35 U.S.C. 285; and (g) any further and just relief the Court deems equitable and appropriate.

Case: 1:12-cv-04281 Document #: 1 Filed: 06/01/12 Page 3 of 3 PageID #:3

Dated: June 1, 2012

Respectfully submitted,

By:/s/Mark M. Grossman Mark M. Grossman Lee F. Grossman Grossman Law Offices 225 W. Washington St. Suite 2200 Chicago, Illinois 60606