Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 1 of 8 Page ID #:4

Mei Tsang, Esq. (SBN 237959)

mtsang@fishiplaw.com
Joseph Andelin, Esq. (SBN 274105)
jandelin@fishiplaw.com
Fish & Tsang, LLP
2603 Main Street, Suite 1000
Irvine, California 92614-4271
Telephone: 949-943-8300
Facsimile: 949-943-8358

Attorneys for Plaintiff, The Parallax Group International, LLC.

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA, THE SOUTHERN DIVISION

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The Parallax Group International, LLC, a

California corporation,

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COMPLAINT FOR PATENT

INFRINGEMENT

Plaintiff,
v.

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Civil Action No. 8:16-cv-927

DEMAND FOR JURY TRIAL

Greatmats.com Corporation, a Wisconsin
corporation,
Defendant.

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COMPLAINT FOR PATENT INFRINGEMENT

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 2 of 8 Page ID #:5

1.

Plaintiff, by and through its attorneys of record, alleges as follows:

PARTIES

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and existing under the laws of the State of California, with a place of business at 65 Enterprise

3rd Floor, Aliso Viejo, CA 92656.

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or the Defendant), is a wholly owned corporation organized and existing under the laws of

the State of Wisconsin, with its principal place of business at 117 Industrial Ave, Milltown, WI

54858.

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Plaintiff, The Parallax Group International, LLC (Parallax), is a corporation organized

Upon information and belief, Defendant, Greatmats.com Corporation (Greatmats.com

SUBJECT MATTER JURISDICTION

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4.

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States, 35 U.S.C. 1, et seq. This Court has subject matter jurisdiction over this action

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pursuant to 28 U.S.C. 1331 and 1338(a).

This is an action for patent infringement arising under the patent laws of the United

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BACKGROUND

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5.

Parallax protects its technologies through a broad range of intellectual property rights.

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6.

Among the patents that Parallax has been awarded are the patents listed below, to which

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Parallax owns all rights, title, and interest.

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Patent Number

Title

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US 9,289,085 (the 085 patent)

Floor Matting

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US D532,238 (the 238 patent)

Floor Matting

US D543,764 (the 764 patent)

Resilient Mat

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COUNT ONE: INFRINGEMENT OF THE 085 PATENT BY GREATMATS.COM

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Plaintiff re-alleges and incorporates the allegations of paragraphs 1-6.

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The 085 patent is valid and enforceable.

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Plaintiff actively markets and sells throughout the United States products that embody at

least claim 1 of the 085 patent.

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1
COMPLAINT FOR PATENT INFRINGEMENT

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 3 of 8 Page ID #:6

10.

infringed the 085 patent through direct infringement and infringement under the doctrine of

equivalents.

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manufactured, or imported floor mats that infringe the 085 patent.

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the following infringing floor mats in the United States: the Home Sport and Play Mat, the

Martial Arts Karate Mat Premium mats, the Grappling MMA Mats, the Judo Mats Lite mats,

the Home MMA BJJ Mats, the Home Karate Sport Foam Tile mats, the Pro Martial Arts Mats

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Sport mats, the Rustic Wood Grain Foam Tile mats, the SoftFloors Economy Reversible Foam

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Tile mats, the SoftTuff Gym Floor Protect mats, and the Home Tatami Sport Tile mats (the

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085 Infringing Products), with exemplary depiction of some of the 085 Infringing Products

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found in Exhibit 1, attached.

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of the 085 patent.

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detailed in Exhibit 2, attached.

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contributed to or induced infringement of claim 1 of the 085 patent.

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suffered damages in an amount according to proof at trial.

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royalty.

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that infringe the 085 patent.

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085 patent, Plaintiff will suffer additional irreparable harm and impairment of the value of its

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patent rights. Thus, Plaintiff is entitled to an injunction against further infringement.

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COMPLAINT FOR PATENT INFRINGEMENT

Upon information and belief, and in violation of 35 U.S.C. 271, Greatmats.com has

Since at least October 28, 2006, Greatmats.com has offered for sale, sold, used,

Greatmats.com has also offered for sale, sold, used, manufactured, or imported at least

Specifically, the 085 Infringing Products infringe the subject matter protected by claim 1

Some of Greatmats.coms acts constituting infringement of claim 1 of the 085 patent are

Upon information and belief and in violation of 35 U.S.C. 271, the Defendant also

As a direct and proximate result of the Defendants acts of infringement, Plaintiff

Plaintiff is entitled to recover compensatory damages totaling no less than a reasonable

Greatmats.com continues to offer for sale, sell, use, manufacture, or import floor mats

Unless the Defendant is enjoined by this Court from continuing its infringement of the

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 4 of 8 Page ID #:7

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least as of May 19, 2016.

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085 patent on its website, www.norsk-stor.com, since at least May 19, 2016.

Upon information and belief, the Defendant had constructive notice of the 085 patent at

Parallax has offered for sale and sold products embodying and bearing the mark of the

COUNT TWO: INFRINGEMENT OF THE 238 PATENT BY GREATMATS.COM

22. Plaintiff re-alleges and incorporates the allegations of paragraphs 1-6.

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The 238 patent is valid and enforceable.

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Plaintiff actively markets and sells throughout the United States products that embody the

design claimed by the 238 patent.

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infringed the 238 patent through direct infringement and infringement under the doctrine of

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equivalents.

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manufactured, or imported floor mats that infringe the 238 patent.

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the following infringing floor mats in the United States: the Geneva Interlocking Rubber Tile

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mats, the Interlocking Rubber Tile Black mats, the Geneva Rubber Tile Black mats, the Rubber

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Tile Utility mats, the Geneva Rubber Tile 10% Color mats, the Geneva Rubber Tile 20% Color

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mats, the Interlocking Rubber Tile Color mats, the Interlocking Rubber Tile 10% Color mats,

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the Interlocking Rubber Tile 20% Color mats, the Interlocking Punter Top mats, the

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SoftRubber Floor Gym Tile mats, the Comfort Tile Designer Wood Grain mats, the Comfort

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Tile Designer Wood Grain Center Tile mats, the Comfort Tile Designer Wood Grain Kit

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Beveled Edges mats, the Comfort Carpet Tile Kit Beveled Edges mats, the Comfort Carpet

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Tile Center Tile mats, the Rustic Wood Grain Foam Tile mats, the SoftCarpet Tile mats, the

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Subfloor Dance Studio Elite mats, the Dense Foam Mats, the Aerobic Flooring Pro Tile mats,

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the BestGym Rubber Tile Interlocking mats, the Eco Interlocking Carpet Tiles mats, the Foam

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Floor Mats Premium mats, the Foam Mats Economy mats, the Foam Tiles Wood Grain mats,

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the Home Gym Mats Pebble mats, the Pebble Top Foam Gym Floor Tile mats, the Play Mats
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COMPLAINT FOR PATENT INFRINGEMENT

Upon information and belief, and in violation of 35 U.S.C. 271, Greatmats.com has

Since at least December 8, 2006, Greatmats.com has offered for sale, sold, used,

Greatmats.com has also offered for sale, sold, used, manufactured, or imported at least

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 5 of 8 Page ID #:8

Foam Puzzle Tile 4 Pack mats, the Royal Interlocking Carpet Tile mats, the SoftWoods Foam

Tiles mats, and the Sport Plus Designer Foam Tile mats (the 238 Infringing Products), with

exemplary depiction of some of the 238 Infringing Products found in Exhibit 3, attached.

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for sale, manufacture, or imported by Greatmats.com, are the same, or are substantially

identical to, the design claimed in the 238 patent.

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industry would believe the 238 Infringing Products and, upon information and belief, other

products sold, offered for sale, manufactured, or imported by Greatmats.com, are substantially

The 238 Infringing Products and, on information and belief, other products sold, offered

An ordinary observer with an understanding of the relevant prior art in the floor mat

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the same as the design claimed by the 238 patent.

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contributed to or induced infringement of claim 1 of the 238 patent.

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suffered damages in an amount according to proof at trial.

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royalty.

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that infringe the 238 patent.

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238 patent, Plaintiff will suffer additional irreparable harm and impairment of the value of its

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patent rights. Thus, Plaintiff is entitled to an injunction against further infringement.

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least as early as May 20, 2010.

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mark of the 238 patent on its website, www.norsk-stor.com, or in retail locations since at least

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May 20, 2010.

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COUNT THREE: INFRINGEMENT OF THE 764 PATENT BY GREATMATS.COM

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Upon information and belief and in violation of 35 U.S.C. 271, the Defendant also

As a direct and proximate result of the Defendants acts of infringement, Plaintiff

Plaintiff is entitled to recover compensatory damages totaling no less than a reasonable

Greatmats.com continues to offer for sale, sell, use, manufacture, or import floor mats

Unless the Defendant is enjoined by this Court from continuing its infringement of the

Upon information and belief, the Defendant had constructive notice of the 238 patent at

In addition, Parallax has offered for sale and sold products embodying and bearing the

Plaintiff re-alleges and incorporates the allegations of paragraphs 1-6.

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COMPLAINT FOR PATENT INFRINGEMENT

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 6 of 8 Page ID #:9

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The 764 patent is valid and enforceable.

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Plaintiff actively markets and sells throughout the United States products that embody the

design claimed by the 764 patent.

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infringed the 764 patent through direct infringement and infringement under the doctrine of

equivalents.

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manufactured, or imported floor mats that infringe the 764 patent.

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Upon information and belief, and in violation of 35 U.S.C. 271, Greatmats.com has

Since at least December 8, 2006, Greatmats.com has offered for sale, sold, used,

Greatmats.com has also offered for sale, sold, used, manufactured, or imported at least

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the following infringing floor mats in the United States: the Geneva Interlocking Rubber Tile

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mats, the Interlocking Rubber Tile Black mats, the Geneva Rubber Tile Black mats, the Rubber

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Tile Utility mats, the Geneva Rubber Tile 10% Color mats, the Geneva Rubber Tile 20% Color

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mats, the Interlocking Rubber Tile Color mats, the Interlocking Rubber Tile 10% Color mats,

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the Interlocking Rubber Tile 20% Color mats, the Interlocking Punter Top mats, the

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SoftRubber Floor Gym Tile mats, the Comfort Tile Designer Wood Grain mats, the Comfort

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Tile Designer Wood Grain Center Tile mats, the Comfort Tile Designer Wood Grain Kit

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Beveled Edges mats, the Comfort Carpet Tile Kit Beveled Edges mats, the Comfort Carpet

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Tile Center Tile mats, the Rustic Wood Grain Foam Tile mats, the SoftCarpet Tile mats, the

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Subfloor Dance Studio Elite mats, the Dense Foam Mats, the Aerobic Flooring Pro Tile mats,

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the BestGym Rubber Tile Interlocking mats, the Eco Interlocking Carpet Tiles mats, the Foam

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Floor Mats Premium mats, the Foam Mats Economy mats, the Foam Tiles Wood Grain mats,

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the Home Gym Mats Pebble mats, the Pebble Top Foam Gym Floor Tile mats, the Play Mats

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Foam Puzzle Tile 4 Pack mats, the Royal Interlocking Carpet Tile mats, the SoftWoods Foam

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Tiles mats, and the Sport Plus Designer Foam Tile mats (the 764 Infringing Products), with

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exemplary depiction of some of the 764 Infringing Products found in Exhibit 3, attached.

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for sale, manufacture, or imported by Greatmats.com, are the same, or are substantially

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identical to, the design claimed in the 764 patent.

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COMPLAINT FOR PATENT INFRINGEMENT

The 764 Infringing Products and, on information and belief, other products sold, offered

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 7 of 8 Page ID #:10

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industry would believe the 764 Infringing Products and, upon information and belief, other

products sold, offered for sale, manufactured, or imported by Greatmats.com, are substantially

the same as the design claimed by the 764 patent.

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contributed to or induced infringement of claim 1 of the 764 patent.

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suffered damages in an amount according to proof at trial.

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An ordinary observer with an understanding of the relevant prior art in the floor mat

Upon information and belief and in violation of 35 U.S.C. 271, the Defendant also

As a direct and proximate result of the Defendants acts of infringement, Plaintiff

Plaintiff is entitled to recover compensatory damages totaling no less than a reasonable

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royalty.

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that infringe the 764 patent.

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764 patent, Plaintiff will suffer additional irreparable harm and impairment of the value of its

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patent rights. Thus, Plaintiff is entitled to an injunction against further infringement.

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least as early as May 20, 2010.

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mark of the 764 patent on its website, www.norsk-stor.com, or in retail locations since at least

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May 20, 2010.

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Greatmats.com continues to offer for sale, sell, use, manufacture, or import floor mats

Unless the Defendant is enjoined by this Court from continuing its infringement of the

Upon information and belief, the Defendant had constructive notice of the 764 patent at

In addition, Parallax has offered for sale and sold products embodying and bearing the

PRAYER FOR RELIEF

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Plaintiff Parallax prays for judgment and relief as follows:

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A) Judgment that the 085, 238, and 764 patents are valid and enforceable;

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B) Judgment that the Defendant, its directors, officers, employees, attorneys, and agents, and

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all those persons acting in active concert or in participation with them, and their successors

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and assigns, be enjoined from further acts that infringe, contributorily infringe, or induce

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infringement of the 085, 238, and 764 patents pursuant to 35 U.S.C. 283;

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COMPLAINT FOR PATENT INFRINGEMENT

Case 8:16-cv-00927 Document 2 Filed 05/20/16 Page 8 of 8 Page ID #:11

C) Judgment that the Defendant be ordered to pay damages adequate to compensate Parallax

for infringement of the 085, 238, and 764 patents pursuant to 35 U.S.C. 284, together

with interest, including pre-judgment interest from the date infringement of each of the

patents began;

D) Judgment that the Defendant directly committed, induced, or contributed to willful

infringement of the 085, 238, and 764 patents and that the Defendant be ordered to pay

treble damages pursuant to 35 U.S.C. 284;

E) Judgment that the Defendant be ordered to pay all costs and expenses incurred by Parallax

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associated with this action pursuant to 35 U.S.C. 284;

F) Judgment that this case is exceptional, and that the Defendant be ordered to pay all of

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Parallaxs attorney fees associated with this action pursuant to 35 U.S.C. 285; and
G) Judgment that Parallax be granted any other relief as this Court finds just and proper,

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including enhanced damages.

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DEMAND FOR JURY TRIAL

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by jury in this action of all issues so triable.

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Plaintiff demands trial

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Respectfully submitted,

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FISH & TSANG, LLP

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Dated: May 20, 2016

By: /s/Joseph A. Andelin

Joseph A. Andelin, Esq.
Attorneys for Plaintiff
Parallax, Inc.

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COMPLAINT FOR PATENT INFRINGEMENT

Case 8:16-cv-00927 Document 2-1 Filed 05/20/16 Page 1 of 2 Page ID #:12

Exhibit 1

Case 8:16-cv-00927 Document 2-1 Filed 05/20/16 Page 2 of 2 Page ID #:13

Home Sport and Play Mat

Pro Martial Arts Sport

SoftTuff Gym Floor Protect

Home Tatami Sport Tile

SoftFloors Economy Reversible Foam Tile

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Exhibit 2

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Greatmats.coms Acts Constituting Infringement of Claim 1 of the 085 Patent

Upon information and belief, the 085 Infringing Products sold, offered for sale, or imported by
Greatmats.com include a body with a peripheral wall having teeth and receiving slots, as seen in Exhibit
1. These acts or features are required by and infringe claim 1.
Upon information and belief, the Home Sport and Play Mat mats and the Pro Martial Arts Sport mats
sold, offered for sale, or imported by Greatmats.com have two layers, with each layer made of closed
cell EVA foam rubber. The SoftFloors Economy Reversible Foam Tile mats and Home Tatami Sport Tile
mats sold, offered for sale, or imported by Greatmats.com have two layers, with each layer made of
foam. The the SoftTuff Gym Floor Protect mats sold, offered for sale, or imported by Greatmats.com
have two layers, with each layer made of high density fiber. In sum, each of the 085 Infringing Products
has two layers, with each layer made of the same material as the other layer, such that each layer has
the same coefficient of thermal expansion as the other layer. These acts or features are required by and
infringe claim 1.
Upon information and belief, the 085 Infringing Products sold, offered for sale, or imported by
Greatmats.com have two layers with different colors, as seen in Exhibit 1. These acts or features are
required by and infringe claim 1.
Upon information and belief, the 085 Infringing Products sold, offered for sale, or imported by
Greatmats.com have two layers that are bound together at an undulating boundary, as seen in Exhibit 1.
These acts or features are required by and infringe claim 1.

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Exhibit 3

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Dense Foam Mats

Aerobic Flooring Pro Tile

Eco Interlocking Carpet Tiles

BestGym Rubber Tile Interlocking

Foam Floor Mats Premium

Foam Mats Economy

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Foam Tiles Wood Grain

Play Mats Foam Puzzle Tile 4 Pack

Home Gym Mats Pebble

Sport Plus Designer Foam Tile

Royal Interlocking Carpet Tile

Pebble Top Foam Gym Floor Tile

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SoftWoods Foam Tiles