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)
)
)
Plaintiff,
)
)
vs.
)
)
MYSTIC POWERBOATS INC.,
)
a Florida Corporation,
)
)
Defendant.
)
____________________________________)
CASE NO.:
COMPLAINT
COMES
NOW
the
Plaintiff,
CIGARETTE
RACING
TEAM,
LLC
complains
against
MYSTIC
POWERBOATS
INC.,
(hereinafter
action
occurred
arises
within
from,
this
inter
District,
alia,
acts
specifically
that
the
Defendant
District,
has
namely
committed
the
tort
infringement
within
alleged
this
herein,
in
acts
of
patent
infringement
District.
2
within
this
Judicial
THE PARTIES
5.
Plaintiff
is
well-established
and
highly-regarded
won
numerous
awards
and
accolades,
and
have
been
critically
2014.
11.
of all right, title, and interest in the 018 patent, and the
018 patent is valid and fully enforceable.
3
12.
has been exceptionally well received by the media and the public
alike since its debut at the Miami International Boat Show in
2012, where it garnered much media attention and was no doubt
viewed by principals and/or agents of Defendant.
13.
The
hardtop
roof
of
the
42
Huntress
is
commercial
The 42 Huntress
built
in
unveiled
conjunction
with
with
fanfare
International
agents
of
much
Boat
Show,
Defendant
Mercedes-Benzs
at
where,
again
the
no
viewed
division,
February
doubt,
the
AMG
and
2013
Miami
principals
and/or
Plaintiffs
patented
hardtop roof.
DEFENDANTS UNLAWFUL ACTIVITIES
15.
Show,
the
Defendant
publicly
displayed
its
model
M3900
that
The
accused
design
is
identical
and/or
substantially
Side View
Front View
17.
Defendants
caused
and
unauthorized
will
continue
acts
to
cause
as
described
irreparable
herein
harm
have
to
the
Plaintiff
paragraphs
incorporates
through
17,
by
as
reference
the
allegations
if
set
forth
fully
in
of
this
paragraph.
19.
making,
using,
and
offering
for
sale
in
the
United
States,
Plaintiff
has
never
authorized
or
otherwise
granted
any
Upon
information
and
belief,
Defendant
will
continue
to
Upon
information
and
belief,
the
acts
of
the
Defendant
That
this
Court
find
Defendants
aforesaid
acts
in
active
concert
or
participation
therewith,
be
making,
using,
offering
to
sell,
and/or
That
Defendant
be
required
to
deliver
up
for
as
or
not
any
less
other
than
reasonable
calculable
benefit
royalty
of
conferred
any
upon
the
infringement
of
the
claim
of
the
018
patent.
h)
That
sales
of
the
the
Plaintiff
boats
recover
that
the
featured
Defendants
the
profits
accused
design,