CLIC Goggles v. Morrison - Complaint

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 1 of 9 PageID 218
UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
CLIC GOGGLES, INC.,

Plaintiff,
v.
Civil Action No.: 6:15-cv-621-Orl-28GJK
LISA MORRISON, an individual, and

LEO KOZLOSKI, an individual,
collectively d/b/a PSI PHOTO SHOP a/k/a
PSI SUPPLY,
Defendants.
FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT

INJUNCTIVE RELIEF SOUGHT AND DEMAND FOR JURY TRIAL
Plaintiff, CliC Goggles, Inc. (hereinafter CliC), by and through undersigned
counsel, hereby sues Defendants, Lisa Morrison and Leo Kozloski (hereinafter
Defendants), and alleges as follows:
NATURE OF THE ACTION
1.
This is an action for patent infringement in connection with Defendants
making, importing, offering for sale and selling lightweight, front-connecting eyewear
that are virtually identical to eyewear inventions covered by a United States utility patent
owned and duly assigned to CliC. Defendants have obtained and are selling in the United
States through the Internet knock-offs of the patented CliC eye ware. Defendants
infringing conduct has damaged CliC and inflicted irreparable harm.
2.
CliC seeks, inter alia, disgorgement of Defendants profits from the sale
of infringing products, and injunctive relief.

JURISDICTION AND VENUE
3.
This Court has original jurisdiction over the claims for patent infringement
under 28 U.S.C. 1331 and 1338(a) in that said claims arise under the Patent Laws of
the United States, 35 U.S.C. 1 et seq.
4.
This Court has in personam jurisdiction over Defendants pursuant to FLA.
STAT. 48.193, in that: (a) Defendants are operating, conducting, engaging or carrying
on a business, in the State of Florida; (b) Defendants have committed tortious acts within
the State of Florida; and (c) Defendants are engaged in substantial and not isolated
activity within the State of Florida.
5.
Venue is proper in this District pursuant to 28 U.S.C. 1391(b) because
Defendants are residents in this District and because a substantial part of the events
giving rise to the claim occurred in this District.
THE PARTIES
6.
CliC is a corporation organized and existing under the laws of California,
with its principal place of business located at 408 Tamal Plaza Corte Madera, CA 94925.
7.
Upon information and belief, Defendant Lisa Morrison (Morrison) is an
individual residing at 1515 State Avenue, Unit L, Holly Hill, Florida, 32117.
8.
Upon information and belief, Defendant Leo Kozloski (Kozloski) is an
individual residing at 1515 State Avenue, Unit L, Holly Hill, Florida, 32117.
9.
Upon information and belief, Morrison and Kozloski have done business
and are presently doing business under the name PSI PHOTO SHOP and/or PSI
SUPPLY.
10.
Upon information and belief, Morrison and Kozloski were managers of a
now-dissolved Florida limited liability company named PSI SUPPLY, INC., with a
principal place of business at 1515 State Avenue, Unit L, Holly Hill, Florida 32117.
CLICS BUSINESS
11.
Since 2000, CliC has been involved in the business of manufacturing high
quality eyewear, including its innovative lightweight front-connecting eyewear sold in a

variety of markets.
12.
CliC offers a variety of eyewear including reading glasses, sunglasses,
goggles, and medical-specific eyewear. All of CliCs glasses include several innovative
features including a magnetic front closure system at the bridge of the glasses which
facilitates putting on and taking off the glasses. Some of CliCs glasses also include an
adjustable headband that allows the headband or strap of the glasses to expand or contract
to fit most customers.
13.
CliC products are sold throughout the world, including in the United
States and have been a critical success. Indeed, Time Magazine has called CliCs front
connection technology the best eyewear innovation since glasses were invented.
14.
As a result of the originality and high quality of its products, CliC has
developed a reputation for excellence and innovation which has generated millions of
dollars in sales and many loyal customers.
THE CLIC PATENT

15.
On July 3, 2001, U.S. Patent No. 6,253,388 (the 388 Patent), entitled
Eye Wear with Snap-Together Bridge was issued by the United States Patent and
Trademark Office, covering an useful eyewear invention. The application from which
the 388 Patent issued was filed on December 31, 1999. A true and correct copy of the
388 Patent is attached as Exhibit A hereto.
16.
CliC is the owner by assignment of the 388 Patent. CliC has owned the
388 Patent during all times relevant to allegations herein. A true and correct copy of the
electronic records pertaining to the assignment information for the 388, reflecting CliC
as the owner thereof, is attached as Exhibit B hereto.
17.
The 388 Patent in full force and effect as of the date of this Complaint
and all times relevant to the allegations herein.

18.
Subsequent to the filing of the 388 Patent, CliC began manufacturing and
selling a line of front-connecting eyewear embodying the invention covered by the 388
Patent. These products were and are presently sold under the CLIC trademark. True and
correct copies of pages from CliCs product catalog illustrating these eyewear products
are attached as Exhibit C hereto.
19.
All eye-wear embodying the 388 Patent sold by CliC since the issuance
of the 388 Patent bear the marking U.S. PAT. 6,253,388.
DEFENDANTS ACTS OF INFRINGEMENT

20.
At least as early as 2015, CliC became aware that Defendants were selling
through eBay Clic Style eyewear embodying the invention in the 388 Patent.
21.
On information and belief, Defendants are operating an eBay account
under the username psi_photo_supply and/or Psi Supply through which Defendants
offer for sale and sell eyewear embodying the invention in the 388 Patent. A true and
correct copy of Defendants eBay homepage is attached as Exhibit D hereto. A true
and correct copy of Defendants eBay listing for Clic Style MAGNETIC Reading
Glasses FRONT CONNECT Adjustable Readers All Colors obtained on March 24,
2015 is attached as Exhibit E hereto.
22.
On February 18, 2015, CliC wrote to Defendants, informing Defendants of
CliCs patent rights and placing Defendants on notice that they were infringing CliCs
patents by selling knock-off eyewear embodying the inventions in the patent. Defendants
did not respond. A true and correct copy of the February 15, 2015 letter is attached as
Exhibit F hereto.
23.
On March 4, 2015, CliC again wrote to Defendants, reasserting its patent
rights and again informing Defendants that they were infringing CliCs patent. The letter
further asserted that, following receipt of the February 18, 2015 letter, Defendants had
dropped the listing price of the infringing eyewear from $18.32 per unit to $14.97 per
unit in an attempt to dump the infringing goods. Defendants did not respond. A true
and correct copy of the March 3, 2015 letter is attached as Exhibit G hereto.
24.
On information and belief, Defendants have offered for sale and sold,
through the Internet on eBay and through other means, the knock-off eyewear to
consumers throughout the United States, including within this District.
25.
The knock-off eyewear sold by Defendants are in all respects virtually
identical copies of CliC front-connecting eyewear and of the invention covered by the
388 Patent. To wit, attached as Exhibits H hereto is a chart comparing the invention
claimed in the 388 Patent with CliCs genuine eyewear and Defendants infringing
eyewear.
COUNT I
INFRINGEMENT OF U.S. PATENT NO. 6,253,288
26.
CliC re-alleges and incorporates hereto by reference paragraphs 1-25 of
this Complaint as though fully set forth herein.

27.
Defendants have infringed and continue to infringe the 388 Patent.
Defendants have sold and offered for sale eyewear that are virtually identical to and
embody the invention claimed in the 388 Patent, and will continue to do so unless
enjoined by this Court.
28.
In addition, through the sale of its knock-off eyewear products to
consumers knowing such consumers would use and wear such eyewear in conventional
fashion, Defendants have induced infringement of the 388 Patent by others and have
committed acts of contributory infringement of the 388 Patent.
29.
CliC has complied with the notice requirement prescribed by 35 U.S.C.
287 and has otherwise given Defendants actual notice of infringement.
30.
Defendants infringement of the 388 Patent has been willful and
malicious and with actual or constructive knowledge that CliC is the owner of a patent
claiming the infringed invention.
31.
CliC has sustained damages as a result of the infringing acts of
Defendants.
32.
CliC has suffered and will continue to suffer irreparable harm unless
Defendants infringement of the 388 Patent is enjoined.

WHEREFORE, Plaintiff CliC prays that the Court:
A.
Enter a judgment that Defendants have infringed, induced infringement
and contributed to the infringement of U.S. Patent No. 6,253,388;

B.
Order Defendants to pay damages under 35 U.S.C. 285 and 289 to
adequately compensate CliC for Defendants patent infringement, including an award of

Defendants profits from its infringement of U.S. Patent Nos. 6,253,388 together with
pre- and post-judgment interest;
C.
Enter an order permanently enjoining Defendants, their officers, agents,
servants, employees, attorneys, receivers, trustees and other fiduciaries, and all other
persons in active participation with Defendants from importing, selling, offering for sale,
or using of any device that infringes the invention embodied and claimed in the 388
Patent;
D.
Find that Defendants patent infringement was willful and malicious and
award treble damages to CliC under 35 U.S.C. 284;
E.
Find this to be an exceptional case of patent infringement and award
reasonable attorneys fees to CliC under 35 U.S.C. 285;

F.
Award such other and further relief as the Court deems just and equitable.
DEMAND FOR JURY TRIAL
CliC hereby demands a trial by jury of all issues so triable.
Dated: March 29, 2016
Respectfully submitted,
s/Geoffrey Lottenberg_____
Barry L. Haley, Esq.
Fla. Bar No. 123,351
Email: blh@mhdpatents.com
Geoffrey Lottenberg, Esq.
Fla. Bar No. 56,240
Email: gl@mhdpatents.com
MALIN HALEY DiMAGGIO &
BOWEN, P.A.
1936 South Andrews Ave.
Fort Lauderdale, FL 33316
Telephone: (954) 763-3303
Facsimile: (954) 522-6507
Counsel for Plaintiff CliC Goggles,
Inc.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was filed electronically
with the Clerk of the Court using the CM/ECF, and will be served on all counsel of record. I
also certify that the foregoing document is being served by process server on March 29,
2016 on all counsel or parties who are not authorized to receive Notices of Electronic
Filings.
Dated: March 29, 2016
By:
SERVICE LIST
Lisa Morrison
1515 State Avenue, Unit L
Holly Hill, Florida 32117
Leo Kozloski
1515 State Avenue, Unit L
Holy Hill, Florida 32117
s/Geoffrey Lottenberg
Geoffrey Lottenberg, Esq.
Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 1 of 38 PageID 227
EXHIBIT A

US006253388B1
(12)
(54)
(76)
United States Patent
(10) Patent N0.:
Lando
(45) Date of Patent:
Jul. 3, 2001
EYE WEAR WITH SNAP-TOGETHER
5,390,373 *
2/1995 Flory ...................................... .. 2/430
BRIDGE
5,940,162 *
6,012,811 *
8/1999 Wong .... ..

1/2000 Chao et a1.
Inventor:
Ronald Lando, 55 Aptos Ave., San
670767926 * 6/2000 Kostka
Francisco, CA (Us) 94127
6,098,207 *
*
(*)
US 6,253,388 B1
Notice:
cued by exammer
Primary Examiner_JOhn J_ Calvert
U'S'C' 154(k)) by 0 days
Assistant ExaminerKatherine Moran

(74) Attorney, Agent, or FirmJack Lo
(57)
351/113
8/2000 Burtm .................................... .. 2/431
Subject to any disclaimer, the term of this

patent is extended or adjusted under 35
(21) Appl. N0.: 09/476,587

(22) Filed:
351/47
. 351/47
ABSTRACT
Dec. 31, 1999

The present eye wear is comprised of a pair of lenses, a pair
(51)
Int- Cl-7 -~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ " A61F 9/02

U-S- Cl- ...................... ..
of releasable connectors connected to respective inner ends

of the lenses, a pair of temples pivotally Connected to
351/124
respective outer ends of the lenses, and a rigid strap attached
(58)
Field of Search ..................... .. 2/426430, 445448,

2/454, 452; 351/41, 43, 44, 53, 65, 68,
between the rear ends of the temples. The strap is positioned

below the lenses so as to not interfere with a hairdo or
98, 124, 125, 133, 118; 600/9, 15; 24/303
helmet. The inner ends of the lenses are releasably secured

together by the connectors. To wear, the lenses are separated
(56)
References Cited
U'S' PATENT DOCUMENTS
from each other and pivoted outwardly, the strap is wrapped

around the back of the head, and the'lenses are pivoted
toward each other and secured together in front of the eyes.
466,896 *
1/1892 Warren ................................... .. 2/426
871,762 * 11/1907 Meyrowitz

1,254,090 *
177607650 *
7/1918 TTPPI_nan
5/1930 Kruenmg "" "
2,128,085
8/1938
Fischer
......
. . . . . . ..
4,479,703 * 10/1984 Enghofer

4,610,519
5,110,198 *
9/1986
Hyman
..........
The lenses are instantly separable for easily putting on or
2/426
taking off the eye wear, but they are instantly connectable
2/426
2/426
together for a secure and accurate ?t. In a second

embodiment, the strap is comprised of an adjustable-length
2/426
?exible Strap
351/123
. . . . ..
351/86
5/1992 Travis et a1. ....................... .. 351/124
14 Claims, 4 Drawing Sheets
U.S. Patent
Jul. 3, 2001
Sheet 1 0f 4
US 6,253,388 B1
U.S. Patent
Jul. 3, 2001
Sheet 2 0f 4
US 6,253,388 B1
Fig.4
U.S. Patent
Jul. 3, 2001
Sheet 4 0f 4
US 6,253,388 B1
US 6,253,388 B1
1
EYE WEAR WITH SNAP-TOGETHER

BRIDGE
toWard each other and secured together in front of the eyes.

The lenses are instantly separable for easily putting on or
taking off the eye Wear, but they are instantly connectable
BACKGROUND OF THE INVENTION
together for a secure and accurate ?t. In a second
embodiment, the strap is comprised of an adjustable-length

?exible strap.
1. Field of the Invention

This invention relates generally to eye Wear.
2. Prior Art
BRIEF DESCRIPTION OF THE SEVERAL

VIEWS OF THE DRAWING
Eye Wear includes glasses and goggles. Each one typi

cally includes a pair of lenses ?xedly connected by a bridge
at the inner ends, and a pair of temples hinged to the
respective outer ends of the lenses. The rear ends of the
temples are disconnected from each other, so that the
temples are foldable against the back of the lenses for storge.
The eye Wear is put on by opening the temples, positioning
them on the sides of the Wearers head, and pushing them
through the hair and the respective gaps betWeen the ears
and the sides of the head. This procedure is a little
cumbersome, and occasionally the Wearer is poked in the
eye by one of the temples during the process.
A retainer strap is sometimes attached betWeen the
15
FIG. 1 is a front perspective vieW of the present eye Wear.

FIG. 2 is a side perspective vieW thereof.
FIG. 3 is a front perspective vieW thereof When a pair of
lenses are separated.
FIG. 4 is a front perspective vieW thereof When Worn on
a person.
FIG. 5 is a front perspective vieW thereof When hung

around the neck of the person.
FIG. 6 is a side perspective vieW of a second embodiment
thereof.
temples for hanging the eye Wear on the neck When it is not
being Worn. The strap must be looped over the head, Which
DRAWING REFERENCE NUMERALS
makes the eye Wear even more cumbersome to put on, and
may also disturb a hairdo When looping over the head.
25
10. Lenses
Stylish DOUBLE MONOCLE sunglasses offered by

Chanel depart from the traditional construction of eye Wear
by not having a bridge. It includes a pair of lenses Which are
disconnected at their inner ends. A rigid horiZontal loop is

positioned behind the lenses and connected betWeen their
outer ends. The loop includes a pair of temple sections
coplanar With a rear section, and a pair of doWnWardly
13. Rigid Strap
14. Frames
15. Vents
16. Hooked Portions

18. Cinch
17. Flexible Strap

19. Temples
DETAILED DESCRIPTION OF THE

INVENTION
projecting ear hooks. Because the lenses are completely

disconnected at their inner ends, they are dif?cult or even 35
impossible to be aligned With each other. They Would be so

loose on the Wearer that they cannot be accurately positioned
in front of the eyes. The rear section of the loop is positioned
high on the back of the head, so that it Will interfere With a
hairdo or a helmet. The loop is not hinged to the lenses, so
that the glasses are dif?cult to put on.
OBJECTIVES OF THE INVENTION
Accordingly, the objectives of the present eye Wear are:

to be easily put on Without poking the eye;
to position lenses accurately in front of the eyes;
to be completely stable and secure When Worn;
11. Connectors
12. Temples
45
A ?rst embodiment of the present eye Wear is shoWn in a
front perspective vieW in FIG. 1 and a side perspective vieW

in FIG. 2. It is comprised of a pair of lenses 10, a pair of
releasable connectors 11 connected to respective inner ends
of lenses 10, a pair of temples 12 connected to respective
outer ends of lenses 10, and a generally rigid strap 13
attached betWeen rear ends of temples 12.
Lenses 10 are preferably mounted in respective frames 14
Which are provided With vents 15. Connectors 11 are pref
erably attached to respective inner ends of frames 14.
Temples 12 are preferably telescopic for ?tting different

Wearers. Temples 12 are preferably pivoted to the respective
outer ends of frames 14. Temples 12 preferably include
hooked portions 16 for hooking around the ears. Strap 13 is
to be easily removed;
positioned beloW lenses 10 so as to avoid interfering With a
to not interfere With a hairdo or helmet When Worn; and
hairdo or helmet. Strap 13 should be springy enough to

retain its shape When released, but are preferably also
to conveniently hang around a neck When not being Worn.
?exible enough to be bendable to some extent Without

breaking. Alternatively, strap 13 may be at the same level as
temples 12, but at the loss of some advantages.
Further objectives of the present invention Will become

apparent from a consideration of the draWings and ensuing
description.
55
BRIEF SUMMARY OF THE INVENTION
comprised of magnets, such as neodymium-iron-boron

magnets, for maximum convenience When connecting and
disconnecting, but they may be any type of releasable
connectors, such as latches, hook-and-loop fasteners, etc.
The present eye Wear is comprised of a pair of lenses, a

pair of releasable connectors connected to respective inner
ends of the lenses, a pair of temples pivotally connected to

respective outer ends of the lenses, and a rigid strap attached
betWeen the rear ends of the temples. The strap is positioned
When connectors 11 are connected together, they form a
beloW the lenses so as to not interfere With a hairdo or
helmet. The inner ends of the lenses are releasably secured

together by the connectors. To Wear, the lenses are separated
from each other and pivoted outWardly, the strap is Wrapped

around the back of the head, and the lenses are pivoted
Alternatively, connectors 11 and temples 12 may be

attached directly to lenses 10. Connectors 11 are preferably
65
bridge betWeen lenses 10. Although the eye Wear is shoWn

as a pair of goggles, it may also be a pair of glasses.
The inner ends of lenses 10 are releasably secured
together by connectors 11. To Wear, lenses 10 are separated
from each other and pivoted outWardly, as shoWn in FIG. 3,
strap 13 is Wrapped around the back of the head, and lenses
US 6,253,388 B1
3
10 are pivoted back toward each other and connected

together in front of the eyes, as shoWn in FIG. 4. The secure
ends of said frames, said temples being attached to respec

tive outer ends of said frames.
6. An eye Wear, comprising:

a pair of lenses;
a pair of releasable connectors connected to respective
inner ends of said lenses, said connectors being
connection betWeen lenses 10 ensures that they are accu
rately positioned in front of the eyes. Because the present

eye Wear is put on from the back of the head, it Will never
poke the Wearer in the eye. Lenses 10 are instantly separable

for easily putting on or taking off the eye Wear, but are
instantly connectable together for a secure and accurate ?t.
securely connectable together and releasable from each
other;
a pair of temples connected to respective outer ends of
said lenses, rear ends of said temples being hooked
doWnWard for Wrapping around a pair of ears; and
a strap connected betWeen said rear ends of said temples,
When the eye Wear is not being Worn, lenses 10 are
separated and hung around the neck under strap 13, as

shoWn in FIG. 5.
In a second embodiment, lenses 10 are connected betWeen
their outer ends by a completely ?exible strap 17, such as a
fabric or rubber strap, Which is adjustable in length With a
cinch 18 movable there along. Alternatively, strap 17 may be
said strap being rigid enough to generally retain its

15
shape When said connectors are released, and springy

enough to be bendable When ?exed and rebounding
When released, said strap being positioned beloW said
adjusted With other devices, such as a buckle, snaps, etc.

Strap 17 is attached to the rear ends of temples 19 as shoWn,
or it may be attached directly to the outer ends of frames 14.
Accordingly, the present eye Wear is easily put on Without
lenses for avoiding interfering With a hairdo or a
helmet;
Wherein When said connectors are released from each
poking the eye. It positions the lenses accurately in front of
other, said inner ends of said lenses are separable from
the eyes. It is completely stable and secure When Worn. It is
each other so that said eye Wear is easy to put on and

remove, and When said connectors are connected
easily removed. It generally does not interfere With a helmet

When Worn. It can be conveniently hung around a neck When
not being Worn.
Although the above description is speci?c, it should not
25
7. The eye Wear of claim 6, Wherein said connectors are
be considered as a limitation on the scope of the invention,
comprised of magnets.
but only as an example of the preferred embodiment. Many

variations are possible Within the teachings of the invention.
Therefore, the scope of the invention should be determined
8. The eye Wear of claim 6, Wherein said temples are
comprised of telescopic temples for ?tting different Wearers.

pivotally connected to said lenses, so that When said con
nectors are released from each other, said inner ends of said
by the appended claims and their legal equivalents, not by
the examples given.

I claim:
a pair of lenses;
lenses are pivotable outWardly for making Wearing easier.

10. The eye Wear of claim 6, further including a pair of
35
a pair of releasable connectors connected to respective
inner ends of said lenses, said connectors being

securely connectable together and releasable from each

a pair of lenses;
a pair of magnets connected to respective inner ends of
a pair of temples connected to respective outer ends of

said lenses; and
a strap connected betWeen rear ends of said temples, said
said lenses, said magnets being securely connectable
strap being rigid enough to generally retain its shape
released;
frames, said lenses being respectively mounted in said

frames, said connectors being attached to respective inner
ends of said frames, said temples being attached to respec
tive outer ends of said frames.
other;
When said connectors are released, and springy enough

to be bendable When ?exed and rebounding When
together, said lenses are secured in position relative to

each other for secure and stable positioning in front of
a pair of eyes.
together and releasable from each other; and

45
a ?exible strap connected betWeen outer ends of said
lenses;
Wherein When said connectors are released from each
Wherein When said magnets are released from each other,

said inner ends of said lenses are separable from each
other, said inner ends of said lenses are separable from
other so that said eye Wear is easy to put on and remove,
each other so that said eye Wear is easy to put on and

remove, and When said connectors are connected
and When said magnets are connected together, said

lenses are secured in position relative to each other for
secure and stable positioning in front of a pair of eyes.
together, said lenses are secured in position relative to

each other for secure and stable positioning in front of
a pair of eyes.
temples respectively connected to said outer ends of said
2. The eye Wear of claim 1, Wherein said connectors are 55 lenses, said strap being attached betWeen rear ends of said
comprised of magnets.
temples.
comprised of telescopic temples for ?tting different Wearers.

frames, said magnets being attached to respective inner ends
of said frames, said straps being connected to respective

pivotally connected to said lenses, so that When said con
nectors are released from each other, said inner ends of said
lenses are pivotable outWardly for making Wearing easier.


frames, said connectors being attached to respective inner
outer ends of said frames.

14. The eye Wear of claim 11, further including a cinch
movable along said strap for adjusting a length of said strap.

*
EXHIBIT B
EXHIBIT C
EXHIBIT D
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http://www.ebay.com/itm/ClicStyleMAGNETICReadingGlassesFRONTCONNECTAdjustableREADERSALLCOLORS/121400241226?pt=LH_
1/9
3/24/2015
ClicStyleMAGNETICReadingGlassesFRONTCONNECTAdjustableREADERSALLCOLORS
Case 6:15-cv-00621-JA-GJK
Document 20-1 Filed 03/29/16 Page 28 of 38 PageID 254
* See our reviews and feel secure in your purchase.
"Front Connect" Magnetic Adjustable Reading Glasses

FULLFRAME&FULLRIM
PICKYOURCOLOR&YOURREQUIREDSTRENGTH
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Magneticsallowtheglassestocometogetheratthebridge.
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glasseswillhangcomfortablyaroundyourneck.Thatwayyouknowexactlywheretheyarewhenyouneedthemagain.
Theyalsocanbefittedforprescriptionlenses.
Severalfashionforwardcolorsavailable:blue,black,darkbrown,yellow,amber,purple,green,bluestripe(zebra),purplestripe
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Eachcoloroffersyou9differentmagnificationstrengths:+1.00,+1.25and+1.50mildstrengths,+1.75,+2.00and+2.25medium
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Style
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Material Acetate/Magnetic/Polycarbonate
Size
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http://www.ebay.com/itm/ClicStyleMAGNETICReadingGlassesFRONTCONNECTAdjustableREADERSALLCOLORS/121400241226?pt=LH_
2/9
EXHIBIT F
EXHIBIT G
EXHIBIT H
CLAIM CHART
U.S. PATENT 6,253,338 EYE WEAR WITH SNAP-TOGETHER BRIDGE
Independent Claim 1
An eye wear,
comprising:
a pair of lenses
a pair of releasable
connectors connected
to respective inner
ends of said lenses,
said connectors being
securely connectable
together and
releasable from each
other;
Authentic CliC Product
Defendants Infringing Product
a pair of temples
connected to
respective outer ends
of said lenses; and
a strap connected
between rear ends of
said temples, said
strap being rigid
enough to generally
retain its shape when
said connectors are
released, and springy
enough to be bendable
when flexed and
rebounding when
released;
wherein when said

connectors are
released from each
other, said inner ends
of said lenses are
separable from each
other so that said eye
wear is easy to put on
and remove, and when
said connectors are
connected together,
said lenses are secured
in position relative to
each other for secure
and stable positioning
in front of a pair of
eyes.

CLIC Goggles v. Morrison - Complaint

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CLIC Goggles v. Morrison - Complaint

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Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 1 of 9 PageID 218

UNITED STATES DISTRICT COURT

CLIC GOGGLES, INC.,

Civil Action No.: 6:15-cv-621-Orl-28GJK

LISA MORRISON, an individual, and

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT

This is an action for patent infringement in connection with Defendants

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 2 of 9 PageID 219

of infringing products, and injunctive relief.

This Court has in personam jurisdiction over Defendants pursuant to FLA.

Venue is proper in this District pursuant to 28 U.S.C. 1391(b) because

CliC is a corporation organized and existing under the laws of California,

Upon information and belief, Defendant Lisa Morrison (Morrison) is an

Upon information and belief, Defendant Leo Kozloski (Kozloski) is an

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 3 of 9 PageID 220

Upon information and belief, Morrison and Kozloski were managers of a

quality eyewear, including its innovative lightweight front-connecting eyewear sold in a

CliC offers a variety of eyewear including reading glasses, sunglasses,

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 4 of 9 PageID 221

THE CLIC PATENT

and all times relevant to the allegations herein.

of the 388 Patent bear the marking U.S. PAT. 6,253,388.

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 5 of 9 PageID 222

DEFENDANTS ACTS OF INFRINGEMENT

On information and belief, Defendants are operating an eBay account

On February 18, 2015, CliC wrote to Defendants, informing Defendants of

On March 4, 2015, CliC again wrote to Defendants, reasserting its patent

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 6 of 9 PageID 223

The knock-off eyewear sold by Defendants are in all respects virtually

CliC re-alleges and incorporates hereto by reference paragraphs 1-25 of

this Complaint as though fully set forth herein.

Defendants have infringed and continue to infringe the 388 Patent.

In addition, through the sale of its knock-off eyewear products to

CliC has complied with the notice requirement prescribed by 35 U.S.C.

287 and has otherwise given Defendants actual notice of infringement.

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 7 of 9 PageID 224

Defendants infringement of the 388 Patent has been willful and

CliC has sustained damages as a result of the infringing acts of

Defendants infringement of the 388 Patent is enjoined.

Enter a judgment that Defendants have infringed, induced infringement

and contributed to the infringement of U.S. Patent No. 6,253,388;

Order Defendants to pay damages under 35 U.S.C. 285 and 289 to

adequately compensate CliC for Defendants patent infringement, including an award of

Enter an order permanently enjoining Defendants, their officers, agents,

award treble damages to CliC under 35 U.S.C. 284;

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 8 of 9 PageID 225

Find this to be an exceptional case of patent infringement and award

reasonable attorneys fees to CliC under 35 U.S.C. 285;

CliC hereby demands a trial by jury of all issues so triable.

Dated: March 29, 2016

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 9 of 9 PageID 226

Dated: March 29, 2016

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 1 of 38 PageID 227

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 2 of 38 PageID 228

United States Patent

(10) Patent N0.:

(45) Date of Patent:

EYE WEAR WITH SNAP-TOGETHER

2/1995 Flory ...................................... .. 2/430

8/1999 Wong .... ..

Ronald Lando, 55 Aptos Ave., San

670767926 * 6/2000 Kostka

Francisco, CA (Us) 94127

U'S'C' 154(k)) by 0 days