Alliance Sports Group v. Fishing Lights, Etc. - Complaint

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  • 8/20/2019 Alliance Sports Group v. Fishing Lights, Etc. - Complaint

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    Peter M. de Jonge, UT 7185Jed H. Hansen, UT 10679Eric W. Westerberg, UT 12712

    THORPE, NORTH & WESTERN, LLP

    8180 South 700 East, Suite 350

    Sandy, Utah 84070Telephone: (801) 566-6633

    Facsimile: (801) 566-0750

     Attorneys for Plaintiff

     Alliance Sports Group, L.P.

    IN THE UNITED STATES DISTRICT COURT

    DISTRICT OF UTAH, CENTRAL DIVISION

    Alliance Sports Group, L.P., a Texas limited partnership,

    Plaintiff,

    vs.

    Fishing Lights, Etc., LLC., a Kansas limited

    liability company,

    Defendant.

    COMPLAINT FOR

    DECLARATORY JUDGMENT

    WITH JURY DEMAND

    Judge Evelyn J. FurseCivil Case No. 2:15-cv-00477

    Plaintiff Alliance Sports Group, L.P. (“ASG”) (“Plaintiff”) by and through its counsel

    hereby files this Declaratory Complaint with Jury Demand against Defendant Fishing Lights,

    Etc., LLC. (“Fishing Lights, Etc.”).

    COMPLAINT 

    Plaintiff complains and alleges as follows:

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    PARTIES, JURISDICTION AND VENUE

    1.  Plaintiff ASG is a Texas limited partnership having a principal place of business at 3025

     North Great Southwest Parkway, Grand Prairie, Texas 75050 with employees and offices located

    within the state of Utah.

    2.  Upon information and belief, Defendant Fishing Lights, Etc. is a Kansas limited liability

    company with its principal place of business at 2707 Vine St., Suite #7, Hays, Kansas 67601.

    3.  This Court has subject matter jurisdiction over this action under 28 U.S.C. §§ 1331, 1367,

    and 1338. 

    4. 

    Plaintiff brings this action under Title 35, United States Code §§ 1 et seq. and under the

    Federal Declaratory Judgment Statute, Title 28, United States Code §§2201, 2202, and Utah

    common law.

    5.  This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§1331,

    1338 and 35 U.S.C. §§ 1 et seq. including, without limitation, 35 U.S.C. §§101-103, 171, and

    271.

    6.  Venue is proper in this judicial district pursuant to 28 U.S.C. §1391.

    7.  Upon information and belief, this Court has general personal jurisdiction over the

    Defendant since its contacts with the state of Utah are substantial, continuous, and systematic.

    8.  Upon information and belief, this Court also has specific personal jurisdiction over the

    Defendant as it sells products relevant to the dispute directly into the state of Utah and

    Defendant’s acts have caused damage to Plaintiff in the state of Utah.

    GENERAL ALLEGATIONS

    9.  ASG is in the business of inventing, developing, manufacturing, distributing, and selling

    various lighting products and other sports-related products, including submersible fishing lights.

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    10.  ASG markets and distributes a line of submersible fishing lights under the brand

    Quarrow® to retailers, including retailers located in the State of Utah. Images of examples of

    those products are provided below:

    11.  Retailers located in the state of Utah market and distribute certain of ASG’s Quarrow®-

     branded submersible lights in stores in the state of Utah.

    12.  Upon information and belief, Fishing Lights, Etc. is owned by Mr. Tom Payne of the

    state of Kansas.

    13.  Upon information and belief, Mr. Tom Payne is also the owner of United States Design

    Patent No. D711,573. A copy of this patent is attached hereto as Exhibit A.

    14.  Upon information, Fishing Lights, Etc. is the exclusive licensee of U.S. Design Patent

     No. D711,573 (the “‘573 Patent”) and/or has rights to enforce the ‘573 Patent against

    competitors of Fishing Lights, Etc.

    15.  Upon information and belief, Fishing Lights, Etc. is a direct competitor of ASG in the

    submersible fishing light market.

    16.  The design shown in the ‘573 Patent is strikingly similar to other designs used in

    connection with lighting device designs that existed before the filing date of the ‘573 Patent.

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    Attached hereto as Exhibit B are examples of designs that, upon information and belief, predate

    the design shown in the ‘573 Patent.

    17.  Plaintiff is aware of prior art references that were not considered during the original

     prosecution of the ‘573 Patent. Plaintiff intends to investigate inequitable conduct during

    discovery and, at such time that Plaintiff has sufficient information to plead inequitable conduct,

    will seek to do so. See Advanced Cardiovascular Sys., Inc. v. SciMed Life Sys., Inc., 989 F.

    Supp. 1237, 1247 (N.D. Cal. 1997) (”... because the legal theory implicates Federal Rule of Civil

    Procedure 9(b), requiring pleading of fraud with particularity, SciMed  was entitled to confirm

    factual allegations before amending to include the inequitable conduct defense); Enzo Life

    Sciences, Inc., v. Digene Corp., 270 F. Supp. 2d 484, 487-90 (D. Del. 2003) (“the Court

    concludes that since the Rule 9(b) ‘pleading with particularity’ requirement is implicated with

    regard to an inequitable conduct claim, Digene was prudent and possibly required to confirm the

    factual allegations through discovery”).

    18.  On or about June 16, 2015, Fishing Lights, Etc. and Mr. Payne sent a letter to

    Sportsman’s Warehouse, one of ASG’s Utah-based retailers, alleging that ASG’s Quarrow®-

     branded products infringe the ‘573 Patent demanding that Sportsman’s Warehouse immediately

    stop all manufacture, importation and/or sale of the Quarrow®-branded submersible light

     products and compensate Mr. Payne and Fishing Lights, Etc. A copy of that letter is attached

    hereto as Exhibit C.

    19. 

    ASG received notice from several of its other customers that Fishing Lights, Etc. and Mr.

    Payne have also sent cease and desist letters to those customers demanding that they also cease

    all manufacture, importation and/or sale of the Quarrow®-branded submersible light products

    and also demanding that they pay Mr. Payne and Fishing Lights, Etc. money.

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    20.  ASG, however, received no notice from Fishing Lights, Etc. or Mr. Payne regarding the

    alleged infringement of its Quarrow®-branded submersible light products.

    21.  Upon information and belief, Fishing Lights, Etc. and Mr. Payne sent cease and desist

    demand letters only to ASG’s customers with the primary intent of causing harm to ASG in the

    marketplace. Moreover, the act of demanding that ASG customers pay Fishing Lights, Etc. and

    Mr. Payne money for alleged infringement of a patent that was procured through inequitable

    conduct is a violation of established standards of conduct.

    22.  As a result of Fishing Lights, Etc.’s unlawful acts, certain of ASG’s customers have

    removed Quarrow®-branded submersible light products from their stores indicating that they

    will not sell the product until the improper allegations made by Fishing Lights, Etc. is resolved.

    23.  Fishing Lights, Etc.’s actions have created a real and substantial controversy related to

    infringement of the ‘573 Patent both by ASG and its customers, including Sportsman’s

    Warehouse, for which ASG now seeks relief.

    FIRST CAUSE OF ACTION

    (Non-Infringement of Patent 28 U.S.C. §§2201, 2202 and 35 U.S.C. §§ 271) 

    24.  Plaintiff hereby incorporates by reference each and every preceding allegation of this

    complaint as if set forth fully herein.

    25.  Plaintiff has a reasonable fear and apprehension that it will be sued for patent

    infringement and that an actual and justiciable controversy exists between the parties.

    26. 

    Plaintiff contends that the Quarrow®-branded submersible light products do not infringe

    any valid claims of the ‘573 Patent.

    27.  As such, Plaintiff is entitled to an order declaring that the Quarrow®-branded

    submersible light products do not infringe any valid claims of the ‘573 Patent.

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    SECOND CAUSE OF ACTION

    (Patent Invalidity 28 U.S.C. §§2201, 2202 and 35 U.S.C. §§ 101-103, 112, and 171) 

    28.  Plaintiff hereby incorporates by reference each and every preceding allegation of this

    Complaint as if set forth fully herein.

    29.  Plaintiff has a reasonable fear and apprehension that it will be sued for patent

    infringement and that an actual and justiciable controversy exists between the parties.

    30.  Moreover, the design shown in the ‘573 Patent is strikingly similar to other designs used

    in connection with lighting products that have existed before the filing date of the ‘573 Patent.

    31. 

    Based on the above, Plaintiff believes the ‘573 Patent is invalid at least pursuant to 35

    U.S.C. §§ 101-103, and/or 171.

    32.  As such, Plaintiff is entitled to an order declaring that the ‘573 Patent is invalid.

    THIRD CAUSE OF ACTION

    (Tortious Interference Utah Common Law)

    33.  Plaintiff hereby incorporates by reference each and every preceding allegation of this

    Complaint as if set forth fully herein.

    34.  Upon information and belief, Fishing Lights, Etc. has intentionally interfered with ASG’s

    existing and/or potential economic relations.

    35.  Upon information and belief, Fishing Lights, Etc. has intentionally interfered with

    ASG’s existing and/or potential economic relations for an improper purpose or by improper

    means, namely to disrupt ASG’s business relationships with third parties in an effort to harass

    ASG in the marketplace and unlawfully increase Fishing Lights, Etc.’s market share of

    submersible fishing lights.

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    36.  ASG has been damaged by the aforementioned acts of Fishing Lights, Etc. and will

    continue to be damaged unless Fishing Lights is preliminarily and permanently enjoined from

    the tortious acts described herein.

    37.  In addition to the above, ASG is entitled to an award of its damages for the

    aforementioned acts of Fishing Lights, Etc. in an amount to be determined by the Court.

    WHEREFORE, it is respectfully requested that the Court enter judgment in favor of

    Plaintiff as follows:

    A.  That the Court enter judgment that the Quarrow®-branded submersible light

     products do not and will not infringe the ‘573 Patent.

    B.  That the Court enter judgment that the ‘573 Patent is invalid pursuant to 35

    U.S.C. §§ 101-103, 112, and/or 171.

    C.  That the Court enter judgement that the acts described herein by Fishing Lights,

    Etc. constitute tortious interference with ASG’s business relationships.

    D. 

    That the Court aware ASG damages for Fishing Lights, Etc.’s unlawful acts.

    E.  That the Court award ASG its costs and attorney’s fees related to this action.

    F.  That Plaintiff have such other and further relief as shall seem just and proper to

    the Court.

    G.  That the Court grant preliminary and permanent injunctive relief enjoining

    Fishing Lights, Etc., its officers, directors, principals, agents, servants, employees, successors

    and assigns, and all others aiding, abetting, or acting in concert or active participation therewith,

    from directly or indirectly alleging that the Quarrow®-branded submersible light products

    infringe the ‘573 Patent.

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    JURY DEMAND

    Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Alliance Sports Group, L.P.

    hereby demands a trial by jury on all issues and claims so triable.

    Dated: July 6, 2015 /Jed H. Hansen/

    Peter M. de Jonge

    Jed H. HansenEric W. Westerberg

    THORPE NORTH & WESTERN, LLP

     Attorneys for Plaintiff

     Alliance Sports Group, L.P.

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    Exhibit A

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    Exhibit B

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    Exhibit C

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    ERICKSONK E R N E L L ~

    June 16, 2015

    FEDERAL EXPRESS

    Mr. Stu Utgaard

    Owner 

    Sportsman's Warehouse

    7035 High Tech Drive

    Midvale, Utah 84047

    Re:   u . s .   Patent No. 0711,573 and Quarrow LED Lights

    Dear Mr. Utgaard:

    We represent Tom Payne and Fishing Lights Etc., LLC for intellectual property

    matters. Mr. Payne is the inventor and owner of U. S. Patent No. 0711,573 entitled

    WATERPROOF LIGHT. A copy of the patent is enclosed for your review.

    It has come to our attention that Sportman's Warehouse is selling Quarrow®

    LED Submersible Fishing Lights. In comparing the patent drawings to the Quarrow® lights, it

    appears that the similarities in the overall design of the Quarrow® lights would deceive an

    ordinary observer into purchasing the accused devices thinking they were the patented

    device. See Egyptian Goddess, Inc.   v.  Swisa, Inc.,   543 F.3d 665, 680 (Fed. Cir. 2008).

     Accordingly, on behalf of Mr. Payne ~nd Fishing Lights Etc., we herebydemand the following:

    1. An accounting including price, quantity and inventory data for all Quarrow'"

    LED Submersible Fishing Lights sold since August 19, 2014, and currently

    in inventory;

    2. Sportman's Warehouse must cease all further sales of Quarrow® LED

    Submersible Fishing Lights, certify that such sales have been discontinued,

    and account for all product in inventory; and

    3. Sportman's Warehouse must compensate Mr. Payne for his attorney's fees

    incurred as a result of investigating and negotiating a resolution to this

    matter.

    We request a written response by July 1, 2015. We look forward to your 

    prompt response to amicably resolve this matter. If you have any questions or would like to

    discuss this offer, please do not hesitate to call.

    James   J .   Kernell •   [email protected]   • Admitted in Kansas and Missouri

    Erickson Kernell Derusseau   &  Kleypas LLC • 8900 State Line Road • Suite 500 • Leawood, Kansas 66206

    Direct: 913.499.1350 • Phone: 913.549.4700 • Fax: 913.549.4646

    Case 2:15-cv-00477-EJF Document 2-3 Filed 07/06/15 Page 2 of 6

    mailto:[email protected]:[email protected]

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    1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1

    USOOD711573S

    (12)   United States Design PatentPayne

    (10)   Patent No.:

    (45)   Date of Patent:

    US  D711,573   S**   Aug. 19,2014

    (54) WATERPROOFLIGHT

    ( 76 ) I nve ntor : T om P ayn e, H ays , K S ( US )

    ("'''') Tenn: 14 Years

    (21) Appl. No.: 29/410,250

    D690,050 S '"D690,452 S '"0694,446 S '"

    0698,056 S '"0698.073 S '"0698.959 S '"

    '" cited by examiner 

    9/2013 Ng et al. 026/809/2013   Payne 026/80

    11/2013 Zhou et al. 026/42

    1/2014   Forbes et al 026/491/2014 Ouquett e et al 026/902/2014   Shen 026/46

    References Cited 

    u. s.   PATENT DOCUMENTS

    Filed: Jan. 5,2012

    LOC (10) C\. 26-02

    U.S.CI.

    USPC D26/42

    Field of Classification Search

    USPC D26/37, 3 8, 40, 42, 46, 49, 50, 72,

    026/75-78,80,84,86,88,89,90; 362/133,

    362/217.01, 218, 219, 221-224, 240,

    362/404-408,101,477,157,158,183,184,

    362/194-196,202-208

    See application file for complete search history.

    (22)

    (51)

    (52)

    (58)

    (56)

    D333,190 S '"

    0425,234 S •0446,877 S '"0505,217 S '"0543,301 S •0550,885 S •0593,695 S •0620,627 S •0637,749 S •0638,566 S •0648,054 S '"

    0655,031 S '"0672,894 S "

    8,360,599 B2 '"

    8,388,172 B2 '"

    2/1993 Waldmann D26/755/2000 Marier 026/788/2001 Lester D26/725/2005 Bayat et al. D26/425/2007 Chen D26/429/2007 Crosby D26/766/2009 Levine D26/427/2010 Kovacik ct al. D26/425/2011 Bayat et al. D26/495/2011 Goelz et al. D26/75

    1l!2011   Zhuang D26/372/2012 Ng et al D26/80

    12/2012 Bayat et al. D26/421/2013 Iveyet al. 362/218

    3/2013 Yue et al. 362/219

    Primary Examiner -   Ian Simmons

     Assistant Examiner -   Carissa C Fitts

    (74) Attorney, Agent, or Finn -   QuickPatents; Kevin Prince

    (57) CLAIMI claim the ornamental design for an waterproof light, as

    shown and described.

    DESCRIPTION

    FIG. 1 is a perspective view of an waterproof light, showing

    my new design;

    FIG. 2 is a top plan view thereof, the bottom plan view,

    left-side elevational view, and bottom plan elevational view

    all being a mirror image thereof; and 

    FIG. 3 is a front elevational view thereof, the rear elevational

    view being a mirror image thereof; and,

    FIG. 4 is an enlarged cross-sectional view thereof, taken

    along lines 4-4 of FIG. 2.

    The broken line showing is for environmental purposes only

    and forms no part of the claimed design. TIle break lines

    applied along the length of the body of the light in the FIGS.

    1 and 2 are used to show symbolic break, with the understand-

    ing that the undisclosed portions of the light not shown in the

    drawings fonns no part of the claim design. Patentability is

     based only on those portions ofthe article that are shown in

    solid lines.

    1 Claim, 2 Drawing Sheets

    1, ' \

    , II,.  ,""

    ",{"{,

    "/   {

    /   {

    '{

    ", ,

    "III I

    I II I

    \ I.   \\   \

    "   \

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    u.s.  Patent   Aug. 19,2014 Sheet 1 of 2   US D711,573 S

    FIG. 1

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    If!:7

    ~..   ~//

    u.s.   Patent   Aug. 19, 2014 Sheet 2 of 2

    /.:::_-::::: . . .~,,I,

    II

    IIII

    US D711,573 S

    4 4

    L   ~§   3-~~

    ~19

    ~19

    ~19I Q I I S !

    9')lI Q I I S !

    i i 119

    FIG.2

    oFIG.3

    oFIG.4

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    Mr. Stu Utgaard

    June 16, 2015

    Page 2

    This letter is not intended to and may not be construed as an election of 

    remedies by Mr. Payne or Fishing Lights Etc., or as a waiver of any other or additional

    remedies available to them. All rights and remedies pursuant to law and equity are hereby

    preserved.

    Sincerely yours,

    ERICKSON KERNELL OERUSSEAU

    &   KLEYP~S, LLC

    BY:~~Ja· e J. Kernell

    JJK/ljk

    Enclosure: U. S. Patent No. 0711,573

    cc: Fishing Lights Etc., LLC   (w/o   enc.)

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    Case 2:15-cv-00477-EJF Document 1 Filed 07/06/15 Page 1 of 1Case 2:15-cv-00477-EJF Document 2-4 Filed 07/06/15 Page 1 of 1