Keith Lewis v. Truck-Lite
Official Complaint for Patent Infringement in Civil Action No. 1:12-cv-00219-RJA: Keith Lewis v. Truck-Lite Co., LLC. Filed in U.S. District Court for the Western District of New York, the Hon. Richard J. Arcara presiding. See http://news.priorsmart.com/-l5G7 for more info.
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Case 1:12-cv-00219-RJA Document 1
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION KEITH LEWIS, Plaintiff, v. TRUCK-LITE CO., LLC, Defendants. ) ) ) ) ) ) ) ) )
Civil Case no. 11-cv-7073 JURY TRIAL DEMANDED
COMPLAINT Plaintiff Keith Lewis, for his complaint against Defendant Truck-Lite Co., LLC (“Truck-Lite”) alleges as follows: NATURE OF THE SUIT 1. This is a claim for patent infringement arising under the patent laws
of the United States, Title 35 of the United States Code. PARTIES 2. 3. Keith Lewis is an individual and citizen of the United Kingdom. Mr. Lewis is the sole inventor and owner of United States Patent
No. 7,252,407 (the “’407 Patent”), entitled “Lighting Apparatus.” 4. Mr. Lewis owns all right, title, and interest in, and has standing to
sue for, the infringement of the ‘407 Patent 5. The defendant has infringed one or more claims of Mr. Lewis’ ‘407
Patent by manufacturing, selling, and/or offering to sell lighting components and devices in the United States, including sales in Illinois and this judicial district. 6. Truck-Lite Co., LLC (“Truck-Lite”) has corporate headquarters at
Case 1:12-cv-00219-RJA Document 1
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310 E. Elmwood Avenue, Falconer, NY 14733. Truck-Lite is a major producer of signal lighting and forward lighting to the heavy duty truck, trailer, and commercial vehicle industries JURISDICTION AND VENUE 7. This Court has exclusive jurisdiction over the subject matter of this
case for patent infringement under 28 U.S.C. § 1338(a). 8. This Court has personal jurisdiction over the defendant because it
conducts business in Illinois, and because it has committed acts of patent infringement in Illinois and this judicial district, such as the offer and sale of infringing lighting devices to customers in Illinois. 9. The defendant has placed its infringing products in the stream of
commerce with knowledge and intent that the products would be distributed and sold, directly or through others in a distribution chain, to customers in Illinois and this judicial district. 10. Venue is proper in this judicial district under 28 U.S.C. §§ 1400(b)
and 1391. The defendant has committed acts of infringement in this district and is subject to personal jurisdiction here. PATENT INFRINGEMENT 11. Truck-Lite has infringed at least one claim of the ‘407 Patent, at
least by manufacturing, using, selling, and offering to sell LED lighting devices, including, but not limited to, lamps and work lamps identified by Truck-Lite by model numbers 07370, 81380, 81711, 81712, 27250C, 80251C, 80863, 80255, 8150, 8155 and 8160.
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12.
The defendant’s infringement has injured Mr. Lewis, and Mr. Lewis
is entitled to recover damages adequate to compensate him for such infringement, but in no event less than a reasonable royalty. 13. Mr. Lewis’ injury will continue unless and until this Court enters an
injunction against further infringement by the defendant. 14. § 287. PRAYER FOR RELIEF WHEREFORE, Plaintiff Keith Lewis respectfully requests that this Court enter judgment against the Defendant Truck-Lite Co., LLC and against its subsidiaries, successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation with it, granting the following relief: A. The entry of judgment in favor of Mr. Lewis on the claim of Mr. Lewis has complied with any applicable provisions of 35 U.S.C.
infringement of his ‘407 Patent; B. An award of damages adequate to compensate Mr. Lewis for the
infringement that has occurred (together with prejudgment interest from the date the infringement began), but in no event less than a reasonable royalty as permitted by 35 U.S.C. § 284; C. Patent; D. A finding that this case is exceptional and an award to Mr. Lewis of A permanent injunction against further infringement of the ‘407
all relief provided by 35 U.S.C. § 285; and
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E.
Such other and further relief that Mr. Lewis is entitled to under law,
and any additional relief that this Court or a jury may deem just and proper. JURY DEMAND Keith Lewis demands a trial by jury on all issues presented in this complaint.
/s/Paul C. Gibbons Raymond P. Niro ([email protected]) Paul C. Gibbons ([email protected]) Niro, Haller & Niro 181 West Madison, Suite 4600 Chicago, Illinois 60602-4515 (312) 236-0733 Fax: (312) 236-3137 Attorneys for Keith Lewis
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Filed 10/06/11 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION KEITH LEWIS, Plaintiff, v. TRUCK-LITE CO., LLC, Defendants. ) ) ) ) ) ) ) ) )
Civil Case no. 11-cv-7073 JURY TRIAL DEMANDED
COMPLAINT Plaintiff Keith Lewis, for his complaint against Defendant Truck-Lite Co., LLC (“Truck-Lite”) alleges as follows: NATURE OF THE SUIT 1. This is a claim for patent infringement arising under the patent laws
of the United States, Title 35 of the United States Code. PARTIES 2. 3. Keith Lewis is an individual and citizen of the United Kingdom. Mr. Lewis is the sole inventor and owner of United States Patent
No. 7,252,407 (the “’407 Patent”), entitled “Lighting Apparatus.” 4. Mr. Lewis owns all right, title, and interest in, and has standing to
sue for, the infringement of the ‘407 Patent 5. The defendant has infringed one or more claims of Mr. Lewis’ ‘407
Patent by manufacturing, selling, and/or offering to sell lighting components and devices in the United States, including sales in Illinois and this judicial district. 6. Truck-Lite Co., LLC (“Truck-Lite”) has corporate headquarters at
Case 1:12-cv-00219-RJA Document 1
Filed 10/06/11 Page 2 of 4
310 E. Elmwood Avenue, Falconer, NY 14733. Truck-Lite is a major producer of signal lighting and forward lighting to the heavy duty truck, trailer, and commercial vehicle industries JURISDICTION AND VENUE 7. This Court has exclusive jurisdiction over the subject matter of this
case for patent infringement under 28 U.S.C. § 1338(a). 8. This Court has personal jurisdiction over the defendant because it
conducts business in Illinois, and because it has committed acts of patent infringement in Illinois and this judicial district, such as the offer and sale of infringing lighting devices to customers in Illinois. 9. The defendant has placed its infringing products in the stream of
commerce with knowledge and intent that the products would be distributed and sold, directly or through others in a distribution chain, to customers in Illinois and this judicial district. 10. Venue is proper in this judicial district under 28 U.S.C. §§ 1400(b)
and 1391. The defendant has committed acts of infringement in this district and is subject to personal jurisdiction here. PATENT INFRINGEMENT 11. Truck-Lite has infringed at least one claim of the ‘407 Patent, at
least by manufacturing, using, selling, and offering to sell LED lighting devices, including, but not limited to, lamps and work lamps identified by Truck-Lite by model numbers 07370, 81380, 81711, 81712, 27250C, 80251C, 80863, 80255, 8150, 8155 and 8160.
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12.
The defendant’s infringement has injured Mr. Lewis, and Mr. Lewis
is entitled to recover damages adequate to compensate him for such infringement, but in no event less than a reasonable royalty. 13. Mr. Lewis’ injury will continue unless and until this Court enters an
injunction against further infringement by the defendant. 14. § 287. PRAYER FOR RELIEF WHEREFORE, Plaintiff Keith Lewis respectfully requests that this Court enter judgment against the Defendant Truck-Lite Co., LLC and against its subsidiaries, successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation with it, granting the following relief: A. The entry of judgment in favor of Mr. Lewis on the claim of Mr. Lewis has complied with any applicable provisions of 35 U.S.C.
infringement of his ‘407 Patent; B. An award of damages adequate to compensate Mr. Lewis for the
infringement that has occurred (together with prejudgment interest from the date the infringement began), but in no event less than a reasonable royalty as permitted by 35 U.S.C. § 284; C. Patent; D. A finding that this case is exceptional and an award to Mr. Lewis of A permanent injunction against further infringement of the ‘407
all relief provided by 35 U.S.C. § 285; and
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Case 1:12-cv-00219-RJA Document 1
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E.
Such other and further relief that Mr. Lewis is entitled to under law,
and any additional relief that this Court or a jury may deem just and proper. JURY DEMAND Keith Lewis demands a trial by jury on all issues presented in this complaint.
/s/Paul C. Gibbons Raymond P. Niro ([email protected]) Paul C. Gibbons ([email protected]) Niro, Haller & Niro 181 West Madison, Suite 4600 Chicago, Illinois 60602-4515 (312) 236-0733 Fax: (312) 236-3137 Attorneys for Keith Lewis
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