Case 1:10-cv-00915-AJT -TCB Document 1 Filed 08/16/10 Page 1 of 19

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION ■■■"■ '!, '7j
l-.

CORROSION TECHNOLOGY CL IT
INTERNATIONAL, LLC, A
101 Convention Center Dr., Suite 850
Las Vegas, NV 89016,

Plaintiff,

v. Civil Action No.

ANTICORROSIVESINDUSTRIALES
LTDA.,
Avenida La Divisa 01011
San Bernardo, Santiago, Chile,

ANCOR TECMIN, S.A.,

Avenida La Divisa 01011
San Bernardo, Santiago, Chile,
JURY TRIAL DEMANDED
TECMIN, S.A.
Avenida Las Esteras Norte 2560
Quilicura, Santiago, Chile,

MARCELLO MIGONE,
Burdeos 3168
Penalolen, Santiago, Chile, and

IN RE CTIANCOR.COM, an internet
domain name.

Defendants.

COMPLAINT

Plaintiff, Corrosion Technology International, LLC ("CTI"), by its undersigned

counsel, hereby files this Complaint, averring as follows:

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THE PARTIES AND THE RELATIONSHIPS BETWEEN THEM

1. Plaintiff CTI (formerly known as CTI Acquisition, LLC) is a limited liability

company organized and existing under the laws of the State of Nevada with an address at 101

Convention Center Drive, Suite 850, Las Vegas Nevada 89109, and with a mailing address of

P.O. Box 50401, Henderson, Nevada 89016.

2. Upon information and belief, Defendant Anticorrosives Industrials Ltda.

("Ancor") is a Chilean limited liability company with a principal address at Avenida La Divisa

01011, San Bernardo, Santiago, Chile.

3. Upon information and belief, Defendant Tecmin, S.A. ("Tecmin") is a Chilean

company with a principal address at Avenida Las Esteras Norte 2560, Quilicura, Santiago, Chile.

4. Upon information and belief, Defendant Ancor Tecmin, S.A. ("Ancortecmin") is a

joint venture company formed by Ancor and Tecmin as joint venturers, and with a principal

address at Avenida La Divisa 01011, San Bernardo, Santiago, Chile.

5. Upon information and belief, Marcello Migone is an individual and a citizen and

resident of Chile, with an address at Burdeos 3168, Penalolen, Santiago, Chile. Upon

information and belief, Defendant Migone is an agent and employee of Ancor and/or

Ancortecmin.

6. Plaintiff and Defendants are competitors in the business of designing and

manufacturing electrolytic refining cells and associated equipment ("Products") used in the

production of nonferrous metals, which they each sell in interstate and/or international commerce

to a global clientele.
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7. Ancortecmin maintains a website (www.ancortecmin.com') on the worldwide

web, including both Spanish- and English-language webpages, and thereby markets its Products

in international and interstate commerce to a global clientele, including residents of Virginia.

8. CTI maintains a website at www.ctiunicell.com on the worldwide web through

which it markets its Products in international and interstate commerce to a global clientele,

including residents of Virginia.

9. Pursuant to a Purchase and Sale Agreement dated December 9, 2003 (as amended

and restated on February 11, 2004) and approved by the United States Bankruptcy Court for the

Western District of Pennsylvania (the "Bankruptcy Court") in a proceeding captioned In re

Global Industrial Technologies, Inc. and docketed at No. 02-21626 (the "Bankruptcy

Proceeding"), CTI acquired certain entities and assets that had been operated by Global

Industrial Technologies, Inc. ("GTI" or "Debtor") as part of the "CTI Group" of companies,

including CTI Europe, N.V., CTI Pacific Pty. LTD and Corrosion IP Corp. (collectively, the

"CTI Entities").

10. Pursuant to a Master Agreement dated May 1, 1998, GTI, the debtor in the

Bankruptcy Proceeding, had operated the CTI Entities together with Ancor in a joint venture

called "CTI-Ancor" for the exclusive world-wide sale of the Products.

11. During the joint venture, the CTI-Ancor joint venture had registered the domain

name "ctiancor.com" with Network Solutions, LLC, a limited liability company with a principal

place of business in Herndon, Virginia.

12. As reflected in the WHOIS report attached hereto as Exhibit A. the domain name

registration identifies CTI-Ancor as the registrant, Network Solutions, LLC as the registrar and

technical contact, and Mr. Migone as the administrative contact.

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13. In connection with this domain name registration, Network Solutions, LLC and

the CTI-Ancor joint venture entered into a Service Agreement containing, upon information and

belief, the terms set forth in the standard form Service Agreement, relevant portions of which are

attached hereto as Exhibit B (the "Service Agreement").

14. In the Bankruptcy Proceeding, Defendant Ancor, made an unsuccessful attempt to

acquire the CTI Entities and assets at the auction conducted by Debtor, at which Plaintiff CTI

was the successful bidder. As a result, Plaintiff CTI became the owner of the entities that were

in the CTI-Ancor joint venture.

15. After CTI's acquisition of the CTI Entities, the joint venture between the CTI

Entities and Ancor was terminated by April 13, 2004 Order of the Bankruptcy Court (the "April

13, 2004 Order") approving a Compromise and Settlement Agreement between Defendant Ancor

and CTI and the CTI Entities. A true and correct copy of the April 13, 2004 Order is attached

hereto as Exhibit C.

16. Defendants Ancor, Tecmin and Ancortecmin (collectively, the "Corporate

Defendants") are now direct competitors of Plaintiff CTI.

JURISDICTION AND VENUE

17. Plaintiff herein asserts causes of action arising under federal law, including the

Anticybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d), and the Lanham Act, 15

U.S.C. § 1125(a), and this Court therefore has subject matter jurisdiction over these federal

causes of action pursuant to 28 U.S.C. § 1331.

18. This Court has supplemental jurisdiction over Plaintiffs causes of action arising

under state law pursuant to 28 U.S.C. § 1367.

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19. Moreover, this is an action between a citizen of Nevada and citizens or subjects of

Chile, the matter in controversy exceeds $75,000, and this Court therefore additionally and

alternatively has subject matter jurisdiction pursuant to 28 U.S.C. § 1332(a)(2).

20. The Service Agreement provides that CTI-Ancor and its agents, including each

person listed in its account as being associated with its account, agree to submit to subject matter

jurisdiction, personal jurisdiction, and venue in the United State District Court for the Eastern

District of Virginia for the adjudication of any disputes brought by a third party concerning or

arising from the use of the ctiancor.com domain name.

21. As explained more fully below, Defendants have acted as apparent agents of CTI-

Ancor in connection with the cti.ancor.com domain name, and Defendant Migone is further

listed as the administrative contact on the account.

22. Therefore, Defendants have consented to this Court's assertion of jurisdiction,

have consented to the Eastern District of Virginia as the venue of this action, and venue is

appropriate under 28 U.S.C. § 1391.

23. Moreover, this cause of action arises out of Defendants' actions and omissions

with regard to the ctiancor.com domain name registered in Virginia and the instructions given

and not given to the registrar, Network Solutions, LLC, a Virginia citizen, regarding that domain

name.

24. Accordingly, even had Defendants not consented to the assertion of personal

jurisdiction in Virginia, this cause of action arises from Defendants' contacts with Virginia such

that this Court's assertion of personal jurisdiction over Defendants comports with notions of fair

play and substantial justice.

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25. Given that a substantial portion of the events or omission giving rise to the claim

occurred in the Eastern District of Virginia, venue is additionally and alternatively proper under

28U.S.C. §1391.

26. In the alternative, even if this Court lacked personal jurisdiction over Defendants,

this Court may assert in rem jurisdiction and the Eastern District of Virginia is a proper venue

under 15 U.S.C. § 1125(d)(2) given that Network Solutions, the domain name registrar, is

located in the Eastern District of Virginia.

27. As Defendants are, upon information and belief, located in Chile, service will be

sought pursuant to the Inter-American Convention on Letters Rogatory and Additional Protocol,

to which the United States and Chile are parties, in accordance with Rules 4(f)(l) and 4(h)(2) of

the Federal Rules of Civil Procedure.

THE EVENTS GIVING RISE TO THE PLAINTIFF'S CLAIMS

28. Under the April 13, 2004 Order, any intellectual property that was owned by the

CTI Group prior to the Master Agreement was to revert to the exclusive use of the CTI Group.

29. At all relevant times, including prior to the Master Agreement and at present, CTI

and/or the CTI Entities were and are the lawful holder and owner of the name, mark and

trademark "CTI."

30. Notwithstanding the court-ordered termination of the CTI-Ancor joint venture and

CTI's exclusive right to use the mark "CTI," the Corporate Defendants continued to hold

themselves out as "CTI-Ancor," using the CTI-Ancor logo and using the ctiancor.com domain

name for the website of the joint venture Ancortecmin.

31. Accordingly, CTI and the CTI Entities brought a motion in the Bankruptcy Court

to enforce the April 13, 2004 Order.

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32. By Order filed February 4, 2005 (the "February 4, 2005 Order"), the Bankruptcy

Court granted CTFs Motion and further affirmed that Ancor and its affiliated entities were to

refrain from using any intellectual property that was owned by CTI or the CTI Entities prior to

the Master Agreement, which would include the CTI name, logo and mark.

33. The February 4, 2005 Order further provides that in the event of noncompliance,

the Order may be enforced by further proceedings in any appropriate court with jurisdiction over

the party against whom enforcement is sought. A true and correct copy of the February 2, 2005

Order is attached hereto as Exhibit D.

34. Following service of the February 4, 2005 Order, a Settlement Contract supported

by consideration was executed between CTI and the CTI Entities and Ancor, Ancortecmin and

various Ancor affiliates on or about September 28, 2005 (the "Settlement Contract"). A true and

correct copy of the Settlement Contract is attached hereto as Exhibit E.

35. Under the Settlement Contract, the Corporate Defendants agreed to stop using the

CTI name, logo or mark, whether alone or with any other name, logo or mark, in its logo,

stationary, business cards, website, advertising, promotions, products, or in any other form and to

not use the CTI-ANCOR trade name for any commercial or non-commercial purpose.

36. The Settlement Agreement also required ANCOR to have the www.ctiancor.com

web address lead to a single page informing visitors of the termination of the termination of the

joint venture and allowing visitors to then go to CTI's and ANCOR's respective new websites.

37. The Settlement Agreement further provided that any future changes to the

webpage must be agreed between CTI and Ancor, or their successor companies.
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38. Under the Settlement Agreement, Defendant Ancortecmin agreed that it would

guarantee the performance of Defendant Ancor of all its obligations under the Settlement

Agreement.

39. Defendants took no action to ensure compliance with the Settlement Contract

provision requiring that future changes to the website must be agreed to by both CTI and Ancor

and did not inform Network Solutions, LLC, the domain name registrar, of this requirement, nor

of the termination of the joint venture that had registered the domain name. To the contrary, the

domain registration misleadingly still lists CTI-Ancor (a non-existent entity) as the registrant and

Defendant Migone as the sole administrative contact.

40. Defendants did initially comply with their obligation to take actions necessary to

cause the www.citancor.com web address led to the website informing of the termination of the

CTI-Ancor joint venture and providing links to both websites.

41. Subsequently, however, there have been multiple times (including as of the filing

of this Complaint) when, as a result of the Defendants' actions, the domain name ctiancor.com

has been linked directly to the Ancortecmin home page with the result that anyone typing

www.ctiancor.com into a web browser is directed to the homepage of Defendant Ancortecmin.

42. Upon information and belief, on each of these occasions, Defendant Migone, who

is listed as the administrative contact for the ctiancor.com domain name, acting as an agent of the

Corporate Defendants and as the purported agent of the terminated CTI-Ancor joint venture,

instructed Network Solutions, LLC, the domain name registrar, to link the domain name to the

Ancortecmin home page.

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43. The distinctive "CTI" name, mark and trademark have been used by CTI and its

affiliates world-wide for more than two decades in their business of selling the Products in the

nonferrous metals market.

44. More than 80% of the Products currently in use in the world market have been

manufactured by CTI and its affiliates.

45. As a result of the extensive use by Plaintiff of the mark "CTI" and its association

with CTI's Products, CTI holds trademark rights to the name "CTI" in the markets where its

Products are sold and marketed.

46. The CTI designation, name and associated logo including "CTI" have been

consistently used for decades in product brochures, photographs, data sheets, correspondence

advertising, and product labeling.

47. The CTI mark is a recognized and respected name in the industry in which

Plaintiff and Defendants operate and do business.

48. CTI and its affiliates have engaged in extensive advertising and marketing efforts

with the goal of achieving name recognition for their businesses among the purchasing public for

their Products in Virginia and around the world.

49. Plaintiff offers it Products for sale around the world, including in Virginia.

50. CTI and its affiliates have developed excellent reputations for the quality of their

Products and service, and these reputations constitute valuable assets.

51. Defendants knew that "CTI" was Plaintiffs distinctive trademark and intellectual

property when they linked the domain names ctiancor.com to Defendant Ancortecmin's website.

52. Indeed, Defendants linked the domain name to Defendant Ancortecmin's website

with the intent of capitalizing on the reputation and goodwill their competitor, Plaintiff, and the
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former, judicially-terminated joint venture, by diverting to Defendant Ancortecmin's website

potential buyers who were attempting to get information about Plaintiffs Products and by

creating confusion about the source of the Products offered on the Ancortecmin website and

CTI's sponsorship, affiliation and/or endorsement thereof.

COUNT I
(Anticybersquatting Consumer Protection Act ("ACPA"),
15 U.S.C. § 1125(d)(l) (In Personam))

53. Plaintiff incorporates all of the allegations of paragraphs 1 - 52 as if the same

were fully set forth in this Count I and made a constituent part hereof.

54. Plaintiff is the owner of the distinctive and famous trademark "CTI."

55. The Defendants used the domain name ctiancor.com with a bad faith intent to

profit from Plaintiffs trademark.

56. The domain name ctiancor.com is identical to, conflisingly similar to and dilutive

of the Plaintiffs mark.

57. The Defendants' actions are in violation of the ACPA, 15 U.S.C. § 1125(d).

58. Upon information and belief, Plaintiff has suffered actual damages as a result of

Defendants' unlawful actions.

59. Upon information and belief, Defendants have profited as a result of their

unlawful actions.

WHEREFORE, Plaintiff respectfully requests the following:

(a) that the Court enter an judgment declaring the Defendants' actions

to be unlawful and violative of the ACPA, 15 U.S.C. 1125(d);

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(b) that the Court enter an Order canceling the domain name

ctiancor.com or, in the alternative, directing the transfer of the domain

name to ctiancor.com to Plaintiff CTI;

(c) that the Court award Plaintiff three times the amount of Plaintiffs

actual damages, or the amount of Defendants' profits, or such amount as

the Court shall find to be just, or in the alternative, at Plaintiffs election,

statutory damages in an amount not less than $1,000 and not more than

$100,000, as the Court considers just;

(d) that the Court award the Plaintiff the costs of the action and

reasonable attorney fees;

(e) that the Court award the Plaintiff prejudgment and postjudgment

interest;

(e) that the Court grant an injunction prohibiting the Defendants from

registering or using any domain name containing the word CTI or any

word confusingly similar to or dilutive of the Plaintiffs mark; and

(f) that the Court grant the Plaintiff such additional relief as may be

just and proper.

60. A JURY TRIAL IS DEMANDED.

COUNT II
(The Lanham Act, 15 U.S.C. § 1125(a))

61. Plaintiff incorporates all of the allegations of paragraphs 1 - 60 as if the same

were fully set forth in this Count II and made a constituent part hereof.

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62. Defendants have used the domain name ctiancor.com in an unauthorized manner

in interstate commerce.

63. Defendants' use of the words "cti" and/or "ctiancor" in a domain name linked to

Defendant Ancortecmin's website is likely to cause confusion or mistake in the relevant market

or to deceive in suggesting an affiliation, connection, or association of Defendant Ancortecmin

with CTI and/or the CTI Entities, or to deceive in suggesting the origin, sponsorship, or approval

of Ancortecmin's goods, services or commercial activities by the Plaintiff.

64. Defendants' use of ctiancor.com to link to Defendant Ancortecmin's website

constitutes a false designation of origin, false or misleading description of fact and or false or

misleading representation of fact, which is likely to cause confusion or mistake or to deceive as

to the affiliation, connection, or association of Defendant Ancortecmin with the Plaintiff, or of

the origin, sponsorship, or approval of Ancortecmin's goods, services or commercial activities

by the Plaintiff.

65. Defendants' use of ctiancor.com to link to Defendant Ancortecmin's website

constitutes commercial advertising or promotion and misrepresents the nature, characteristics,

qualities and/or geographic origin of Ancortecmin's services.

66. Defendants' use of ctiancor.com to link to Defendants' website is likely to cause

"initial interest confusion," in that consumers are likely to be lured to Defendant Ancortecmin's

Products by the similarity of the domain name "ctiancor.com" to Plaintiffs trademarks.

67. Defendants' conduct violates the Lanham Act, 15 U.S.C. § 1125(a).

68. Upon information and belief, Plaintiff has suffered actual damages as a result of

Defendants' unlawful actions.

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69. Upon information and belief, Defendants have profited as a result of their

unlawful actions.

WHEREFORE, Plaintiff respectfully requests the following:

(a) that the Court enter an judgment declaring the Defendants' actions

to be unlawful and violative of the Lanham Act, 15 U.S.C. 1125(a);

(b) that the Court award the Plaintiff three times the amount of its

actual damages, or the amount of Defendants' profits, or such amount as

the Court shall find to be just;

(c) that the Court award Plaintiff the costs of the action and reasonable

attorney fees;

(d) that the Court award the Plaintiff prejudgment and postjudgment

interest;

(e) that the Court grant an injunction prohibiting the Defendants from

registering or using any domain name containing the word "cti" or any

word confusingly similar to or dilutive of the Plaintiffs mark; and

(f) that the Court grant the Plaintiff such additional relief as may be

just and proper.

70. A JURY TRIAL IS DEMANDED.

COUNT III
(Breach of Contract)

71. Plaintiff incorporates all of the allegations of paragraphs 1 - 70 as if the same

were fully set forth in this Count III and made a constituent part hereof.

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72. The Settlement Contract is a legally enforceable contract supported by

consideration.

73. Under the Settlement Contract, Defendant Ancor was obligated, inter alia, to stop

using the CTI name, logo or mark, whether alone or with any other name, logo or mark, in its

website and advertising, to not use the CTI-ANCOR trade name for any commercial or non

commercial purpose, to take whatever actions were required to have the www.ctiancor.com web

address lead to a single page informing of the termination of the joint venture and allowing

visitors to link to both CTI and Ancor websites, and to not make any future changes to the

webpage with the agreement of CTI.

74. Under the Settlement Contract, Defendant Ancortecmin guaranteed the

performance of all Defendant Ancor's obligations under the Settlement Contract.

75. Defendants Ancor and Ancortecmin breached and continue to breach the

Settlement Contract by using the CTI name, logo or mark in a domain name linked to the website

of Defendant Ancortecmin, by causing the www.citiancor.com web address to lead to the

Ancortecmin homepage rather than the contractually required page, and by making these

changes to the webpage without CTI's agreement.

76. Upon information and belief, as a direct and proximate result of Defendants'

breaches, Plaintiff has suffered and continues to suffer actual, consequential, and incidental

damages in excess of $75,000.

WHEREFORE, Plaintiff respectfully requests the following:

(a) that the Court enter an judgment declaring that Defendants' actions

constitute a breach of the Settlement Contract;

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(b) that the Court award the Plaintiff compensatory damages in an

amount to be proved at trial, plus any other appropriate relief;

(c) that the Court order specific performance of the Settlement

Contract, including the specific contractual provisions requiring that the

www.ctiancor.com web address lead to a single page informing of the

termination of the joint venture and allowing visitors to link to both CTI

and Ancor websites and that further changes to the webpage may only be

made with the agreement of CTI;

(d) that the Court award Plaintiff the costs of the action and reasonable

attorney fees;

(e) that the Court award the Plaintiff prejudgment and postjudgment

interest;

(0 that the Court grant the Plaintiff such additional relief as may be

just and proper.

77. A JURY TRIAL IS DEMANDED.

COUNT IV
(Contempt of Court)

78. Plaintiff incorporates all of the allegations of paragraphs 1 - 77 as if the same

were fully set forth in this Count IV and made a constituent part hereof.

79. The Bankruptcy Court's April 13, 2004 and February 4, 2005 Orders are valid and

binding judicial decrees of which the Corporate Defendants, and, upon information and belief,

Defendant Migone, had actual or constructive knowledge.

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80. The April 13, 2004 and February 4, 2005 Orders were in favor of CTI and the CTI

Entities insofar as they clearly and expressly ordered that any intellectual property that was

owned by the CTI Group prior to the Master Agreement, which would include the name, mark

and trademark "CTI," was to revert to the exclusive use of the CTI Group and that Ancor and its

affiliated entities were to refrain from using such property.

81. In addition to the specific conduct of Defendants described in this Complaint

above, Defendants have engaged in a pattern of behavior and conduct that violates the Orders,

the Settlement Agreement, applicable law and the rights of CTI including conduct that is the

subject of actions in other countries and jurisdictions for patent infringement.

82. The Defendants have willfully, knowingly and repeatedly violated the Bankruptcy

Court's Orders by using the ctiancor.com domain name, which contains the CTI name, mark and

trademark, to link to Defendant Ancortecmin's website.

83. The Defendants' acts of repeatedly failing to abide by the Bankruptcy Court's

April 13, 2004 and February 4, 2005 Orders demonstrate a pattern of contemptuous conduct and

a profound disrespect of the court and its processes, which obstructs the administration ofjustice

and tends to bring the court into disrepute.

84. As a result of the Defendant's violations of the April 13, 2004 and February 4,

2005 Orders, Plaintiff has suffered and continues to suffer actual damages.

85. The February 4, 2005 Order expressly provides that in the event of

noncompliance, the Order may be enforced by further proceedings in any appropriate court with

jurisdiction over the party against whom enforcement is sought.

WHEREFORE, Plaintiff respectfully requests the following:

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(a) that the Court enter an judgment declaring the Defendants to be in

contempt of court;

(b) that the Court award Plaintiff damages in an amount to be proved

at trial, plus any other appropriate relief;

(c) that the Court award Plaintiff the costs of the action and reasonable

attorney fees;

(d) that the Court award the Plaintiff prejudgment and postjudgment

interest; and

(e) that the Court grant the Plaintiff such additional relief as may be

just and proper.

86. A JURY TRIAL IS DEMANDED.

COUNT V
(Anticybersquatting Consumer Protection Act ("ACPA"),
15 U.S.C. § 1125(d)(2) an Rem))

87. Plaintiff incorporates all of the allegations of paragraphs 1 - 86 as if the same

were fully set forth in this Count V and made a constituent part hereof.

88. Plaintiff is the owner of the distinctive, famous trademark "CTI."

89. The domain name ctiancor.com violates CTI's rights as the owner of the CTI

mark, including rights protected under subsections (a) and (c) of 15 U.S.C. § 1125.

90. The registrant of the domain name was CTI-Ancor, the joint venture between the

CTI Entities and Ancor that was terminated by April 13, 2004 Order of the Bankruptcy Court

(the "April 13,2004 Order").

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91. Because CTI-Ancor no longer exists, it is not possible to obtain in personam

jurisdiction over it, and therefore it is appropriate and required that this Court exercise in rem

jurisdiction over the domain name ctiancor.com pursuant to 15 U.S.C. § 1125(d)(2).

WHEREFORE, Plaintiff respectfully requests the following:

(a) that the Court enter an order for the forfeiture or cancellation of the

domain name ctiancor.com:

(b) that the Court grant the Plaintiff such additional relief as may be

just and proper; and

(c) that, pursuant to 15 U.S.C. § 1125(d)(2)(D)(i), upon receipt of a

time-stamped copy of this filed Complaint, the domain name registrar,

Network Solutions, LLC, shall: (i) expeditiously deposit with the Court

documents sufficient to establish the Court's control and authority

regarding the disposition of the registration and use of the domain name

ctiancor.com; and (ii) not transfer, suspend, or otherwise modify the

domain name during the pendency of this action, except upon order of the

Court.

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Date: AugustJb^ 2010 Respectfully submitted,

By:
Martin M. Zoltick (VSB NV30058)
mzol tick@,rfem .com fj
ROTHWELL, FIGG, ERNST & MANBECK, P.C.
1425 K St., N.W., Suite 800
Washington, DC 20005
Telephone: (202) 783-6040
Facsimile: (202)783-6031

OF COUNSEL:

James G. McLean, Esq.

Pa. I.D. No. 37463
Alexandra P. West, Esq.
Pa. I.D. No. 84903
MANION MCDONOUGH & LUCAS, P.C.
Firm I.D. No. 786
600 Grant Street, Suite 1414
Pittsburgh, PA 15219
Telephone: (412) 232-0200
Facsimile: (412)232-0206

Attorneysfor PlaintiffCorrosion Technology International, LLC

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