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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CINPRES GAS INJECTION LTD., Plaintiff, v.

VOLKSWAGEN GROUP OF AMERICA, INC., d/b/a AUDI OF AMERICA, Defendant. JURY TRIAL DEMANDED Case No. _____________

COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND

I.

THE PARTIES

1.

Plaintiff CINPRES GAS INJECTION LTD., is a United Kingdom company,

having an address at Prosperity Court, Prosperity Way, Middlewich, Cheshire CW10 0GD United Kingdom ("CINPRES"). 2. Defendant, VOLKSWAGEN GROUP OF AMERICA, INC. (hereafter referred to

as Audi of America), is a New Jersey corporation qualified to do business in Michigan under ID Number 603528, who has appointed The Corporation Company, at 30600 Telegraph Road, Suite 2345, Bingham Farms, Michigan 48025, as its registered agent and office.

II.

JURISDICTION

3. 4.

The federal claims pleaded herein arise under the Patent Act, 35 U.S.C. 1 et seq. Subject matter jurisdiction for the federal claims is conferred upon the Court by

28 U.S.C. 1338(a).

III.

PATENT INFRINGEMENT

5.

On April 4, 2004, U.S. Patent No. 6,716,387 (the 387 patent) was duly and

lawfully issued to Ronald Thomas for Process For Pressure Assisted Molding Of Hollow Articles.

6.

CINPRES is the owner by assignment of the 387 patent, as evidenced by the

records of the Assignment Branch of the United States Patent and Trademark Office, at Reel 15460, Frame 412, based on an assignment recorded June 10, 2004. 7. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 TT Exterior Rear View Mirror Housing, Part No. 8J0 857 501 A, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent. 8. A photograph of an Audi 2011 TT Exterior Rear View Mirror Housing, Part No.

8J0 857 501 A, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit A. 9. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 A4 Sunroof Wind Deflector, Part No. 8D9-877651-A, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent. 10. A photograph of an Audi 2011 A4 Sunroof Wind Deflector, Part No. 8D9-877-

651-A, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit B. 11. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 A5 Front Door Map Pocket, Part No. 8T1-867103-D, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent.

12.

A photograph of an Audi 2011 A5 Front Door Map Pocket, Part No. 8T1-867-

103-D, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit C. 13. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 Q5 Lift Gate Window Trim, Part No. 8R0-867973-A, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent. 14. A photograph of an Audi 2011 Q5 Lift Gate Window Trim, Part No. 8R0-867-

973-A, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit D. 15. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 A4 Avant Rear Lift Gate Window Trim, Part No. 8K9 867 973 1CT, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent. 16. A photograph of an Audi 2011 A4 Avant Rear Lift Gate Window Trim, Part No.

8K9 867 973 1CT, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit E. 17. Audi of America imports into the United States, offers for sale, and sells, in the

United States, vehicles fitted with the Audi 2011 Q7 Lift Gate Window Trim, Part No. 4L0 867 607 1CT, a hollow article molded by a pressure-assisted plastic injection molding process covered by claim 12 of the 387 patent.

18.

A photograph of an Audi 2011 Q7 Lift Gate Window Trim, Part No. 4L0 867 607

1CT, annotated to show fingerprints indicative of the use of a pressure-assisted molding process, is attached as Exhibit F. 19. The foregoing acts of Audi of America are unlicensed and have been done

without the authorization of CINPRES. 20. Audi of America is liable to CINPRES for infringement of the 387 patent, 35

U.S.C. 271(a) and (g). 21. 22. Upon information and belief, Audi of Americas infringement has been willful. CINPRES has been harmed, pecuniarily and irreparably, by Audi of Americas

infringing conduct. 23. Audi of Americas infringing conduct will continue unless enjoined by the Court.

IV.

DEMAND FOR RELIEF

WHEREFORE, CINPRES demands entry of judgment against Audi of America, granting relief as follows: A. A determination that Audi of America has infringed the 387 patent by the

acts complained of herein; B. C. An award of damages adequate to compensate for such infringement; An enhancement of the compensatory damages, up to three (3) times, if

such infringement is found to have been willful; D. 285; A determination that this case is exceptional, in the sense of 35 U.S.C.

E.

An order preliminarily and permanently enjoining Audi of America, its

officers, agents, servants, employees, contractors, suppliers and attorneys, and upon those persons in active concert or participation with them who receive actual notice of the order by personal service or otherwise, from committing further acts of infringement, direct or indirect, of the 387 patent; F. An award in favor of CINPRES, and against Audi of America, for the

costs incurred in bringing and maintaining this action, including reasonable attorneys' fees; and G. Such other, further, and different relief as may be just and equitable.

V.

JURY DEMAND

Plaintiff CINPRES demands trial by jury for all issues so triable. Respectfully submitted, By: /s/ Robert C.J. Tuttle MARK A. CANTOR (P32661) ROBERT C.J. TUTTLE (P25222) JOHN E. NEMAZI (P33285) BROOKS KUSHMAN P.C. 1000 Town Center Twenty-Second Floor Southfield, Michigan 48075 Tel: (248) 358-4400 Fax: (248) 358-3351 Email: mcantor@brookskushman.com rtuttle@brookskushman.com jnemazi@brookskushman.com Attorneys for Plaintiff Dated: July 9, 201