Jonathan Short

Mark H. Anania
McCARTER & ENGLISH, LLP
Four Gateway Center
100 Mulberry Street
Newark, NJ 07102
(973) 622-4444 (telephone)
(973) 624-7070 (facsimile)

Of counsel:
Mark D. Giarratana
Kevin L. Reiner
McCARTER & ENGLISH, LLP
CityPlace I
185 Asylum Street
Hartford, CT 06103
(860) 275-6700 (telephone)
(860) 724-3397 (facsimile)

Attorneys for Plaintiff Middle Atlantic Products, Inc.

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY



MIDDLE ATLANTIC PRODUCTS, INC.

Plaintiff,
v.
WIREPATH HOME SYSTEMS, LLC d/b/a
SNAPAV
Defendant.
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Civil Action No. ________

COMPLAINT
Plaintiff Middle Atlantic Products, Inc. (Middle Atlantic Products), with offices
at 300 Fairfield Road, Fairfield, NJ 07004, for its Complaint against WirePath Home Systems,
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LLC d/b/a SnapAV (Defendant), with offices at 1800 Continental Boulevard, Suite 200,
Charlotte, NC 28273, alleges as follows:
THE PARTIES
1. Plaintiff Middle Atlantic Products, Inc. is a New Jersey Corporation with
its principal place of business at 300 Fairfield Road, Fairfield, NJ 07004.
2. Upon information and belief, Defendant WirePath Home Systems, LLC
d/b/a SnapAV is a North Carolina Limited Liability Company with its principal place of
business at 1800 Continental Boulevard, Suite 200, Charlotte, NC 28273.
JURISDICTION AND VENUE
3. This is an action for a judgment of patent infringement arising under the
patent laws of the United States, Title 35, United States Code.
4. This Court has jurisdiction over the subject matter of this action pursuant
to 28 U.S.C. 1331 (Federal Question) and 1338(a) (Patents) in that it involves claims
arising under the Patent Laws of the United States.
5. This Court has personal jurisdiction over Defendant because, upon
information and belief, Defendant transacts business within this judicial district and has
committed acts of patent infringement directly in this District. Upon information and belief,
Defendant sells and/or offers for sale products that infringe the patent-in-suit within this
judicial district and/or has purposefully and voluntarily placed infringing products into the
stream of commerce with knowledge and expectation that they will be purchased by
consumers in this judicial district.
6. Venue is proper in this Judicial District under 28 U.S.C. 1391(b),
1391(c), and 1400(b), because a substantial part of the events giving rise to this action
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occurred in this District, in that Defendant conducts business within this District and is
actively engaged in offering products for sale within this judicial district, including the
accused products at issue in this lawsuit, and resides in this District.
COUNT I INFRINGEMENT OF U.S. PATENT NO. D586,583 S
7. Plaintiff Middle Atlantic Products re-alleges and incorporates by reference
the allegations of the foregoing paragraphs.
8. United States Design Patent No. D586,583 S ("the 583 Patent"), entitled
"Vented Electronics Rack," was duly and legally issued by the United States Patent and
Trademark Office on February 17, 2009. A copy of the 583 patent is attached hereto as
Exhibit A.
9. Middle Atlantic Products is the owner by assignment of the 583 Patent,
and has the sole right to sue and recover damages for both past and ongoing infringement
thereof.
10. Defendant has infringed, and continues to infringe, the 583 patent by
making, using, selling, offering to sell, and/or importing vented electronics racks that provide
the same or substantially the same overall effect and visual appearance to the ordinary
purchaser as the design claimed in the 583 patent. The vented electronics racks include,
without limitation, the STRONG
TM
Fixed Rack Shelf 2U (item # SR-SHELF-FIXED-2U),
the STRONG
TM
Fixed Rack Shelf 3U (item # SR-SHELF-FIXED-3U), and the STRONG
TM

Fixed Rack Shelf 4U (item # SR-SHELF-FIXED-4U).
11. The foregoing acts of patent infringement have been without authority or
license from Middle Atlantic Products.
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12. Prior to filing this Complaint, Middle Atlantic Products provided
Defendant with written notice of Defendants infringement of the 583 patent. Upon
information and belief, Defendants infringement of the 583 Patent has been and continues
to be willful, and has been conducted with an objectively reckless disregard of the high
likelihood of infringement of the 583 Patent.
13. The foregoing acts of patent infringement by the Defendant will cause
Middle Atlantic Products irreparable harm for which it has no adequate remedy at law,
including irreparable harm within the state of New Jersey and this Judicial District, and will
continue unless enjoined by this Court.
PRAYER FOR RELIEF
WHEREFORE, Middle Atlantic Products prays for a judgment against the
Defendant as follows:
A. Adjudging that Defendant has infringed the 583 patent;
B. Adjudging that Defendants infringement of the 583 patent has been willful and
deliberate;
C. Requiring Defendant to pay to Middle Atlantic Products compensatory damages
for the injuries sustained by Middle Atlantic Products in consequence of the
unlawful acts alleged herein pursuant to 35 U.S.C. 284, as well as all lawful
costs and expenses pursuant to Fed. R. Civ. P. 54(d), and that such damages be
trebled because of the willful and unlawful acts as alleged herein;
D. Requiring Defendant to account for and pay over to Middle Atlantic Products all
gains, profits and advantages derived by Defendant from the unlawful activities
alleged herein pursuant to 35 U.S.C. 289;
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E. Declaring this an exceptional case and awarding Middle Atlantic Products its
attorneys fees, as provided by 35 U.S.C. 285;
F. Awarding Middle Atlantic Products pre-judgment and post-judgment interest on
the above monetary awards;
G. Preliminarily and permanently enjoining Defendant, its officers, agents, servants
and employees, from infringing the 583 patent; and
H. Awarding Middle Atlantic Products such other and further relief as this Court
may deem just and proper.
JURY DEMAND
Pursuant to Fed. R. Civ. P. 38(b), Plaintiff hereby demands a trial by a jury on all issues
so triable.
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Respectfully submitted,
DATED: July 28, 2014 By: s/ Jonathan Short












Jonathan Short
Mark H. Anania
McCARTER & ENGLISH, LLP
Four Gateway Center
100 Mulberry Street
Newark, NJ 07102
(973) 622-4444 (telephone)
(973) 624-7070 (facsimile)

Of counsel:

Mark D. Giarratana
Kevin L. Reiner
McCARTER & ENGLISH, LLP
CityPlace I
185 Asylum Street
Hartford, CT 06103
(860) 275-6700 (telephone)
(860) 724-3397 (facsimile)

Attorneys for Plaintiff Middle Atlantic
Products, Inc.

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CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 11.2

I hereby certify that the matter in controversy is not the subject of any other action
or proceeding pending in any court, or of any pending arbitration or administrative proceeding.
Dated: July 28, 2014 Respectfully submitted,
By: s/ Jonathan Short
Jonathan Short
Mark H. Anania
McCARTER & ENGLISH, LLP
Four Gateway Center
100 Mulberry Street
Newark, NJ 07102
(973) 622-4444 (telephone)
(973) 624-7070 (facsimile)

Of counsel:

Mark D. Giarratana
Kevin L. Reiner
McCARTER & ENGLISH, LLP
CityPlace I
185 Asylum Street
Hartford, CT 06103
(860) 275-6700 (telephone)
(860) 724-3397 (facsimile)

Attorneys for Plaintiff Middle Atlantic Products, Inc.

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