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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIOEASTERN DIVISION
)
DINESOL PLASTICS, INC. )195 East Park Avenue )
Niles, Ohio 44446 )
Plaintiff, ))
v. ) Civil Action No.
)AVON PLASTICS, INC. )
d/b/a MASTER MARK )
PLASTIC PRODUCTS )
One Master Mark Drive )
Albany, Minnesota 56307 )Defendant. ) Jury Trial Demanded
)
COMPLAINT
The plaintiff, Dinesol Plastics, Inc. (“Dinesol”), for its complaint against
defendant, Avon Plastics, Inc., d/b/a Master Mark Plastic Products (“Master Mark”),
alleges as follows:
THE PARTIES
1. The plaintiff, Dinesol, is a corporation organized and existing under the
laws of the State of Ohio, having a principal place of business at 195 East Park Avenue,
Niles, Ohio 44446.
2. On information and belief, the defendant, Master Mark, is a corporation
organized under the laws of the State of Minnesota, having a principal place of business
at One Master Mark Drive, Albany, Minnesota 56307, and having sold its outdoor
landscape and garden products through retail outlets for resale to the general public in
the Northern District of Ohio, including Menards®
retail stores.
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JURISDICTION AND VENUE
3. This action arises under the patent laws of the United States, 35 U.S.C. § 1
et seq.
4. This Court has subject matter jurisdiction over this dispute pursuant to 28
U.S.C. §§ 1331, and 1338(a).
5. This Court may exercise personal jurisdiction over Master Mark based
upon its contacts with this forum, including, at least, regularly and intentionally doing
business with and through retail outlets here, including Menards®.
6. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b)
and 1400(b).
GENERAL ALLEGATIONS – THE DINESOL DESIGN PATENTS
7. For many years, Dinesol has engaged in the development, manufacture,
and sale of a wide array of outdoor landscape and garden products.
8. Dinesol has taken steps to protect its innovative designs, including its
outdoor decorative-lattice designs. In particular, Dinesol owns various United States
design patents relating to its lattice designs. Relevant to this dispute, Dinesol is the
owner of all right, title, and interest to each of the United States design patents identified
in Table 1 (hereafter, the “Dinesol Design Patents”). A copy of each Dinesol Design
Patent is attached to this Complaint as indicated in Table 1.
Table 1: Dinesol Design PatentsUnited States
Design Patent Number
Issue Date of Patent Complaint Exhibit
D624,201 (‘201 patent) September 21, 2010 A
D651,722 (‘722 patent) January 3, 2012 B
D672,478 (‘478 patent) December 11, 2012 C
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GENERAL ALLEGATIONS – DEFENDANT’S INFRINGING ACTIVITIES
9. Without Dinesol’s authorization, Master Mark has offered for sale and
sold in the United States decorative-lattice having designs that are covered by the Dinesol
Design Patents (hereafter, the “Infringing Lattice”). Upon information and belief, Master
Mark knowingly and intentionally continues to sell the Infringing Lattice as a copy of
Dinesol’s lattice.
10. Charts 1, 2 and 3 below demonstrate Master Mark’s infringement by
comparing images of the Infringing Lattice sold by Master Mark with figures from the
Dinesol Design Patents.
Chart 1: Images Depicting Infringement of Dinesol’s Design Patent
D624,201 by the Master Mark Lattice
D624,201 Master Mark Lattice
FIG. 1
FIG. 2
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Chart 2: Images Depicting Infringement of Dinesol’s Design Patent
D651,722 by the Master Mark Lattice
D651,722 Master Mark Lattice
FIG. 1
FIG. 2
Chart 3: Images Depicting Infringement of Dinesol’s Design Patent
D672,478 by the Master Mark Lattice
D672,478 Master Mark Lattice
FIG. 1
FIG. 3
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FIG. 2
11. Defendant Master Mark has infringed and continues to infringe the
Dinesol Design Patents within the meaning of 35 U.S.C. §271(a), at least by making,
selling and offering to sell the Infringing Lattice without Dinesol’s authorization or
license.
12. Dinesol has sold and is currently selling its decorative-lattice bearing the
design claimed in the ‘201, ‘702 and ‘478 patents.
COUNT 1: PATENT INFRINGEMENT
13. Dinesol re-alleges each and every allegation set forth in paragraphs 1
through 12 above, inclusive, and incorporates them by reference herein.
14. Master Mark has made, offered to sell, and sold into the United States,
including the State of Ohio, and still is making, offering to sell, and selling herein
decorative-lattice having designs that infringe one or more of the Dinesol Design Patents
without Dinesol’s authorization.
15. Moreover, Master Mark has made, offered to sell, and sold into the United
States, including the State of Ohio, and still is making, offering to sell, and selling herein
decorative-lattice having designs that an ordinary observer, familiar with the prior art
designs, would be deceived into believing is the same as one or more of the Dinesol
Design Patents. 16. On information and belief, Master Mark’s infringement is intentional and
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willful, making this an exceptional case.
17. Dinesol has been and will continue to be irreparably harmed by Master
Mark’s infringement of the Dinesol Design Patents.
JURY DEMAND
Dinesol demands a trial by jury.
RELIEF SOUGHT
WHEREFORE, Dinesol respectfully prays for:
A. Judgment that Defendant Master Mark infringed the Dinesol Design
Patents in violation of 35 U.S.C. § 271(a);
B. An injunction against further infringement of the Dinesol Design Patents
by Defendant Master Mark, its agents, servants, employees, officers, and all others
controlled by them;
C. An award of damages adequate to compensate Dinesol for the patent
infringement that has occurred pursuant to 35 U.S.C. § 284, which shall be trebled as a
result of Defendant’s willful patent infringement, or an award of Master Mark’s profits
from its infringement pursuant to 35 U.S.C. § 289, whichever is greater, together with
prejudgment interest and costs;
D. An assessment of costs, including reasonable attorney fees, pursuant to 35
U.S.C. § 285, with prejudgment interest; and
E. Such other and further relief as this Court deems just and proper.
Date: July 25, 2013 Respectfully submitted,
/Robert J. Herberger/ .
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Robert J. Herberger, Esq. - 0043848
Stuart A. Strasfeld, Esq. - 0012399David S. Barbee, Esq. - 0037248
R OTH, BLAIR , R OBERTS, STRASFELD & LODGE
100 East Federal Plaza, Suite #600
Youngstown, OH 44503-1893 (330)744-5211 (330)744-3184
[email protected]@roth-blair.com
Attorneys for Plaintiff
Dinesol Plastics, Inc.
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S 44 (Rev. 12/12) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, excep
rovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for theurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
I. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for
(For Diversity Cases Only) and One Box for Defendan
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6
Foreign Country
V. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTE
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 400 State Reapportionm
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 ’ 410 Antitrust
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 430 Banks and Banking
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 450 Commerce
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 460 Deportation
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liabi lity ’ 830 Patent ’ 470 Racketeer Influence
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 840 Trademark Corrupt Organizatio
Student Loans ’ 340 Marine Injury Product ’ 480 Consumer Credit
(Excludes Veterans) ’ 345 Marine Product Liability LABOR SOCIAL SECURITY ’ 490 Cable/Sat TV
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 850 Securities/Commod
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud Act ’ 862 Black Lung (923) Exchange
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) ’ 890 Other Statutory Act
’ 190 Other Contract Product Liability ’ 380 Other Personal Relations ’ 864 SSID Title XVI ’ 891 Agricultural Acts
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 893 Environmental Mat
’ 196 Franchise Injury ’ 385 Property Damage ’ 751 Family and Medical ’ 895 Freedom of Inform
’ 362 Personal Injury - Product Liability Leave Act ActMedical Malpractice ’ 790 Other Labor Litigation ’ 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 791 Employee Retirement FEDERAL TAX SUITS ’ 899 Administrative Proc
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: Income Security Act ’ 870 Taxes (U.S. Plaintiff Act/Review or App
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) Agency Decision
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 950 Constitutionality of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 State Statutes
’ 245 Tort Product Liability Accommodations ’ 530 General
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION
Employment Other: ’ 462 Naturalization Application’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 OriginalProceeding
’ 2 Removed fromState Court
’ 3 Remanded fromAppellate Court
’ 4 Reinstated or Reopened
’ 5 Transferred fromAnother District(specify)
’ 6 MultidistrictLitigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Brief description of cause:
VII. REQUESTED INCOMPLAINT:
’ CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.
DEMAND $ CHECK YES only if demanded in complaint
JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)IF ANY
(See instructions):JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
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DINESOL PLASTICS, INC.195 East Park AvenueNiles, Ohio 44446
Trumbull
Robert J. Herberger, Esq.Roth, Blair, Roberts, Strasfeld & Lodge100 East Federal Plaza, Suite #600
AVON PLASTICS, INC. d/b/a MASTER MARPLASTIC PRODUCTSOne Master Mark Dr., Albany, Minnesota 563
Stearns
35 U.S.C. § 1 et seq.
Master Mark is selling in the US decorative-lattice having designs covered by (3) of Dinesol design patents
07/25/2013 /Robert J. Herberger/
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
. Civil Categories: (Please check one category only).
1. General Civil
2. Administrative Review/Social Security
3. Habeas Corpus Death Penalty
*If under Title 28, §2255, name the SENTENCING JUDGE:
CASE NUMBER:
I. RELATED OR REFILED CASES. See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court
and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and
subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor
the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for
bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet."
This action is RELATED to another PENDING civil case. This action is REFILED pursuant to LR 3.1.
f applicable, please indicate on page 1 in section VIII, the name of the Judge and case number.
II. In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the
divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the
purpose of determining the proper division, and for statistical reasons, the following information is requested.
ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH
PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP.
(1) Resident defendant. If the defendant resides in a county within this district, please set forth the name of suchcounty
COUNTY:
Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in which
it has its principal place of business in that district.
(2) Non-Resident defendant. If no defendant is a resident of a county in this district, please set forth the county
wherein the cause of action arose or the event complained of occurred.COUNTY:
(3) Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle
place of business within the district, and the cause of action arose or the event complained of occurred outside
this district, please set forth the county of the plaintiff's residence.
COUNTY:
V. The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is
determined in Section III, please check the appropriate division.
EASTERN DIVISION
AKRON (Counties: Carroll, Holmes, Portage, Stark, Summit, Tuscarawas and Wayne)CLEVELAND (Counties: Ashland, Ashtabula, Crawford, Cuyahoga, Geauga, Lake,
Lorain, Medina and Richland)YOUNGSTOWN (Counties: Columbiana, Mahoning and Trumbull)
WESTERN DIVISION
TOLEDO (Counties: Allen, Auglaize, Defiance, Erie, Fulton, Hancock, Hardin, Henry,Huron, Lucas, Marion, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca
VanWert, Williams, Wood and Wyandot)
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STARK
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AO 440 (Rev. 12/09) Summons in a Civil Action
U NITED STATES DISTRICT COURTfor the
__________ District of __________
)
))))))
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.You also must file your answer or motion with the court.
CLERK OF COURT
Date:Signature of Clerk or Deputy Clerk
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Northern District of Ohio
Dinesol PLastics, Inc.
Avon Plastics, Inc. d/b/a Master Mark PlasticProducts
AVON PLASTICS, INC.d/b/a MASTER MARK
PLASTIC PRODUCTSOne Master Mark DriveAlbany, Minnesota 56307
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AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at (place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
My fees are $ for travel and $ for services, for a total of $
I declare under penalty of perjury that this information is true.
Date:Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
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EXHIBIT
“A”
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EXHIBIT
“B”
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EXHIBIT“C”
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