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COMPLAINT
Defendants, Hangzhou Color Powder Coating Equipment Co. Ltd. (“HCPCE”) and
Providing System Solutions, Inc., d/b/a Powder Buy the Pound (collectively,
NATURE OF ACTION
damages, and other equitable relief for Defendants’ willful infringement of United
States Design Patent Nos. D667,080 (the “’080 Patent”), D693,980 (the “’980 Patent”),
and D696,210 (the “’210 Patent”) (collectively, the “Asserted Patents”). This action
arises under the Patent Laws of the United States, 35 U.S.C. § 1, et seq.
Gema has suffered irreparable harm and will continue to suffer irreparable harm unless
and until Defendants are enjoined from further infringement by this Court.
PARTIES
coating products, including manual and automatic powder guns, powder coating
control units, and powder feed systems. Gema sells a variety of powder guns and
located at Building 34, No 536, ShunFeng Road, Yuhang, Hangzhou, China 310010.
Upon information and belief, HCPCE maintains warehouse facilities at 2011 Johnson
Industrial Blvd., Nolensville, TN, 37135-9774, and regularly conducts business in this
district, including importing, selling, and offering for sale infringing products at issue in
this case.
Pound, is a Tennessee Corporation with its principal place of business located at 2011
Johnson Industrial Blvd., Nolensville, TN, 37135-9774. Upon information and belief,
Defendant Powder Buy the Pound is in the business of selling and offering for sale
powder coating products. Upon information and belief, Defendant Powder Buy the
-2-
this case throughout the United States, including in this judicial district. For example,
upon information and belief, Defendants both sell and offer to sell products at issue in
this case through warehouse facilities located at 2011 Johnson Industrial Blvd.,
Nolensville, TN.
7. Upon further information and belief, Defendants both sell and offer to sell
products at issue in this case through fully interactive websites. Upon information and
belief, Powder Buy the Pound sells and offers for sale products at issue in this case
customers in this judicial district and throughout the United States. Upon further
information and belief, Defendant HCPCE sells and offers for sale products at issue in
8. This action arises under the Patent Laws of the United States, 35 U.S.C.
§ 1, et seq. Accordingly, this Court has subject matter jurisdiction under 28 U.S.C.
other reasons, Defendants regularly conduct business in this judicial district, have
purposefully directed infringing acts to this district, and/or have otherwise availed
-3-
that this Court’s assertion of jurisdiction over Defendants does not offend traditional
10. Among other things, Defendants have advertised, offered to sell, and sold
products that infringe the Asserted Patents within the Middle District of Tennessee. On
information and belief, Defendant Powder Buy the Pound maintains a website at
has advertised, offered to sell, and sold infringing products with “free ground shipping
for all qualifying U.S.A. orders over $100” and “same day shipping for orders placed
before 2 PM CT Mon-Fri.”
to sell, and sold infringing products, which are available to ship anywhere in the United
§§ 1391(b) and (c), and 1400(b) because, among other reasons, Defendants’ infringing
acts that give rise to the claims have occurred in this judicial district and been directed
to citizens of this judicial district. Venue in this district is also proper because Powder
Buy the Pound is incorporated in this district and maintains a principal office in this
district; and upon information and belief HCPCE, a foreign entity not incorporated in
-4-
powder guns, powder coating control units, and powder feed systems, and sells high
quality powder spray equipment products under numerous patents and federally
14. On September 11, 2012, the United States Patent and Trademark Office
(“USPTO”) duly issued the ’080 Patent, which is titled “Powder Spray Gun.”
15. Gema is the exclusive owner of the entire right, title, and interest in and to
the ’080 Patent. A true and correct copy of the ’080 Patent is attached as Exhibit A.
16. On November 19, 2013, the USPTO duly issued the ’980 Patent, which is
17. Gema is the exclusive owner of the entire right, title, and interest in and to
the ’980 Patent. A true and correct copy of the ’980 Patent is attached as Exhibit B.
18. On December 24, 2013, the USPTO duly issued the ’210 Patent, which is
19. Gema is the exclusive owner of the entire right, title, and interest in and to
the ’210 Patent. A true and correct copy of the ’210 Patent is attached as Exhibit C.
20. Upon information and belief, Defendants are in the business of selling
knock-off Gema products, and have sought to willfully infringe upon Gema’s patent
rights through their sale of competing and infringing powder spray coating products.
-5-
registered, maintained, and is responsible for domain names and corresponding web
offer for sale, sell, and distribute infringing products, specifically including, but not
limited to, the infringing “SpectraCoat Manual Gun VII,” the infringing “Gema Opti-
Select Manual Gun (Manual Gun V)” (notably, an unauthorized SpectraCoat product
marketed as a Gema product rather than an authorized Gema product), and the
infringing “Powder Coating Gun System SS200-FHS Manual with Trolley and 50lb
Hopper.”
Pound’s web page showing its offer for sale of the infringing “Spectracoat Manual Gun
VII,” for which Defendant Powder Buy the Pound offers “free ground shipping for all
Pound’s web page showing its offer for sale of the infringing “Gema Opti-Select Manual
Gun (Manual Gun V),” for which Defendant Powder Buy the Pound offers “free ground
Pound’s web page showing its offer for sale of the infringing “Powder Coating Gun
System SS200-FHS Manual with Trolley and 50lb Hopper” for which Defendant Powder
Buy the Pound offers “free ground shipping for all qualifying U.S.A. orders over $100.”
-6-
maintained, and is responsible for domain names and corresponding web pages at
and distribute infringing products, specifically including, but not limited to, the
infringing “Manual Testing Powder Gun” (also marketed as “Lab Electrostatic powder
coating gun CL-191S-TH”), the infringing “Electrostatic Powder Gun CL-161S-F,” the
infringing “Lab Powder Spray gun CL-171s-th,” and the infringing “CL-181S.”
showing its offer for sale of the infringing “Manual Testing Powder Gun,” with an
showing its offer for sale of the infringing “Electrostatic Powder Gun CL-161S-F,” with
showing its offer for sale of the infringing “Lab Powder Spray gun CL-171s-th,” with an
showing its offer for sale of the infringing “CL-181s,” with an advertised “Warehouse in
USA.”
-7-
32. Upon information and belief, Defendant Powder Buy the Pound has
completed many of its online commercial sales of infringing products through the
funds from buyers online throughout the United States, including this judicial district.
malicious and in bad faith, with the intent to mislead consumers and inflict injury on
34. Upon information and belief, Defendants are undertaking all of the above-
referenced acts of infringement in the State of Tennessee and, more particularly, in this
judicial district.
35. Gema restates and realleges each of the allegations set forth above.
36. Defendants have been and are now directly infringing the ’080 Patent in
selling and/or offering for sale products, including, without limitation, the
“SpectraCoat Manual Gun VII,” the “Gema Opti-Select Manual Gun (Manual Gun V)”
than an authorized Gema product), the “Manual Testing Powder Gun” (also marketed
as “Lab Electrostatic powder coating gun CL-191S-TH”), the “Electrostatic Powder Gun
-8-
intentionally, inequitably, and in bad faith infringed the ’080 Patent without reasonable
basis to believe they had the right to do so, and engaged in other conduct injurious to
38. Upon information and belief, Defendants will continue to engage in the
acts complained of herein unless restrained and enjoined, all to Gema’s irreparable
the ‘080 Patent, such damages alone are insufficient to compensate Gema for the
39. By reason of the acts of Defendants alleged herein, Gema has suffered
40. Gema restates and realleges each of the allegations set forth above.
41. Defendants have been and are now directly infringing the ’980 Patent in
selling and/or offering for sale products, including, without limitation, the “Powder
Coating Gun System SS200-FHS Manual with Trolley and 50lb Hopper,” the
“Electrostatic Powder Gun CL-161S-F,” and the “CL-181S,” each of which infringes
-9-
intentionally, inequitably, and in bad faith infringed the ’980 Patent without reasonable
basis to believe they had the right to do so, and engaged in other conduct injurious to
43. Upon information and belief, Defendants will continue to engage in the
acts complained of herein unless restrained and enjoined, all to Gema’s irreparable
the ‘980 Patent, such damages alone are insufficient to compensate Gema for the
44. By reason of the acts of Defendants alleged herein, Gema has suffered
45. Gema restates and realleges each of the allegations set forth above.
46. Defendants have been and are now directly infringing the ’210 Patent in
selling and/or offering for sale products, including, without limitation, the Powder
Coating Gun System SS200-FHS Manual with Trolley and 50lb Hopper,” the “Manual
Testing Powder Gun” (also marketed as “Lab Electrostatic powder coating gun CL-
191S-TH”), and the “CL-181S,” each of which infringes upon the ’210 Patent.
intentionally, inequitably, and in bad faith infringed the ’210 Patent without reasonable
- 10 -
48. Upon information and belief, Defendants will continue to engage in the
acts complained of herein unless restrained and enjoined, all to Gema’s irreparable
the ‘210 Patent, such damages alone are insufficient to compensate Gema for the
49. By reason of the acts of Defendants alleged herein, Gema has suffered
JURY DEMAND
50. A jury trial is demanded on all issues so triable, pursuant to Rule 38 of the
WHEREFORE, Gema respectfully requests that the Court award the following
relief:
Asserted Patents;
concert with them from infringing or inducing others to infringe each of the Asserted
Patents;
- 11 -
infringement of each of the Asserted Patents, such damages to be trebled because of the
account for and pay Gema the damages and or disgorge profits for the period of
post-judgment interest;
g. A judgment and order finding that this case is exceptional and that Gema
is entitled to its reasonable attorney fees, costs, and expenses that it incurs prosecuting
h. Any and all other award or relief that the Court deems just and equitable.
- 12 -
Christopher K. Larus
(admission pro hac vice pending)
Rajin S. Olson
(admission pro hac vice pending)
800 LaSalle Avenue, Suite 2800
Minneapolis, MN 55402
Telephone: 612-349-8500
Facsimile: 612-339-4181
clarus@robinskaplan.com
rolson@robinskaplan.com
- 13 -
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EXHIBIT A
(12) Sanwald
United States Design Patent (10) Patent No.: US D667,080 S
(45) Date of Patent: ... *Sep. 11, 2012
(54) POWDER SPRAY GUN D334,615 S * 4/1993 Berfield et al. .............. D23,226
5,503,880 A * 4/1996 Matschke ...... 427/475
5,678,770 A * 10/1997 Shah .............. ... 239,690
(75) Inventor: Marco Sanwald, Abtwil (CH) 5,779,162 A * 7/1998 Noakes et al. . 239,690.1
D397,421 S * 8/1998 Adams ........... ... D23,226
(73) Assignee: Illinois Tool Works Inc., Glenview, IL D441,833 S * 5/2001 Haas .............. ... D23,226
(US) D573,227 S * 7/2008 Mirazita et al. ... ... D23,226
7,617,998 B2 * 1 1/2009 Mauchle et al. .............. 239,707
(*) Notice: This patent is subject to a terminal dis * cited by examiner
claimer.
Primary Examiner — Robin V Webster
(**) Term: 14 Years (74) Attorney, Agent, or Firm — Lowe Hauptman Ham &
Berner LLP
(21) Appl. No. 29/394,935 (57) CLAM
The ornamental design for a powder spray gun, as shown and
(22) Filed: Jun. 23, 2011 described.
DESCRIPTION
(30) Foreign Application Priority Data
FIG. 1 is a left side view of a powder spray gun bearing the
Dec. 30, 2010 (EP) ................................... OO1252910 design;
(51) LOC (9) Cl. .................................................. 23-01 FIG. 2 is a left-front-bottom perspective view of the powder
(52) U.S. Cl. ...................................................... D23A223 spray gun of FIG. 1;
FIG. 3 is a left-rear perspective view of the powder spraygun
(58) Field of Classification Search ................. D23/213, of FIG. 1;
D23/223, 226; 239/525-527,690, 690.1, FIG. 4 is a bottom view of the powder spray gun of FIG. 1;
239/691; 361/226 228 FIG. 5 is a top view of the powder spray gun of FIG. 1;
See application file for complete search history. FIG. 6 is a rear view of the powder spray gun of FIG. 1; and,
FIG. 7 is a front view of the powder spray gun of FIG. 1.
(56) References Cited The right side view is a mirror-image of the left side view
except for the raised feature shown in FIGS. 4-7.
U.S. PATENT DOCUMENTS The broken lines in the drawings form no part of the claimed
4,182,490 A 1, 1980 Kennon ............................ 239,3 design.
D318,712 S * 7/1991 Buschor ....................... D23,226
D325,241 S * 4, 1992 Buschor ....................... D23,226 1 Claim, 7 Drawing Sheets
*)
Fig. 3
---------------------------------
fy
•*
EXHIBIT B
(54) POWDER SPRAY COATING CART D444,279 S * 6/2001 Kristiansen et al. ........... D34/12
6.279,838 B1 8, 2001 Sivells et al.
(75) Inventors: Marco Sanwald, Abtwil (CH): R388 s : 38 sum . . . . . . . . . . . . . . . . . . . . . . . . . R.
Hanspeter Michael, Gossau (CH) 787,090 B2 1/2011 Staub
D674,572 S * 1/2013 Sanwald et al. ............... D34/14
(73) Assignee: Illinois Tool Works Inc., Glenview, IL
(US) * cited by examiner
(**) Term: 14 Years Primary Examiner — Cynthia Ramirez
(74) Attorney, Agent, or Firm — Lowe Hauptman & Ham,
(21) Appl. No. 29/430,709 LLP
(22) Filed: Aug. 29, 2012 (57) CLAM
The ornamental design for a powder spray coating cart, as
Related U.S. Application Data shown and described.
(62) Division of application No. 29/398,559, filed on Aug. DESCRIPTION
2, 2011, now Pat. No. Des. 674,572.
51) LOC (9) Cl. .................................................. 12-02
(51) FIG. 1 is a left side view of a ppowder sprav
pray coating9. cart
(52) U.S. Cl. bearing the design and having a control unit rotated in the
USPC ........................................................... D34/14 position 0° and a cylindrical container,
(58) Field of Classification Search FIG. 2 is a right side view of the powder spray coating cart of
USPC ............ D34/12-27; 280/642, 42, 47.31, 650, FIG. 1.
280/47.18, 47.19, 47.24, 47.27, 47.28, FIG. 3 is a back-right perspective view of the powder spray
280/47.34 47,371, 79.5 79.7: 406/39, 134
See application file for complete search history.
coating cart of FIG.1:
FIG. 4 is a front-right perspective view of the powder spray
coating cart of FIG. 1;
(56) References Cited FIG. 5 is a front view of the powder spray coating cart of FIG.
1:
U.S. PATENT DOCUMENTS FIG. 6 is a bottom view of the powder spray coating cart of
D187,550 S * 3/1960 Hoover ........................ D15,150
FIG. 1; and,
3,940,065. A 2f1976 Ware et al. FIG. 7 is a top view of the powder spray coating cart of FIG.
4,588,318 A 5, 1986 O'Brien et al. 1.
D396,824 S * 8/1998 Bolster ..................... D11 (130.1
D424,771 S * 5/2000 Sivells et al. .................. D34/14 1 Claim, 7 Drawing Sheets
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
EXHIBIT C
(12) Mauchle
UnitedetStates Design Patent (10) Patent No.: US D696,210 S
al. (45) Date of Patent: . Dec. 24, 2013
(54) CONTROL UNIT FOR POWDER SPRAY D404,391 S * 1/1999 Herbstritt et al. ............ D13,162
APPLICATIONS D567,188 S * 4/2008 Mauchle et al. ... D13, 164
D575,239 S * 8/2008 Shah .............. D13,162
7,423,555 B2 * 9/2008 Chai ............................... 341 (22
(75) Inventors: Felix Mauchle, Abtwil (CH); Mario D581,879 S * 12/2008 Dukerschein et al. ....... D13/162
Vasella, Trubbach (CH) D606,033 S * 12/2009 Sonntag ................. D13, 184
D607,843 S * 1/2010 Borax ... D13,162
(73) Assignee: Illinois Tool Works Inc., St. Gallen D608,302 S * 1/2010 Liu ......... D13, 164
D611,007 S * 3/2010 Kangas ........................ D13, 164
(CH)
* cited by examiner
(**) Term: 14 Years
Primary Examiner — Selina Sikder
(21) Appl. No. 29/396,477 (74) Attorney, Agent, or Firm — Lowe Hauptman & Ham,
LLP
(22) Filed: Jun. 30, 2011 (57) CLAM
(30) Foreign Application Priority Data The ornamental design for a control unit for powder spray
applications, as shown and described.
Dec. 30, 2010 (EM) .................................. OO1252928 DESCRIPTION
(51) LOC (9) Cl. .................................................. 13-03 FIG. 1 is a front view of a control unit for powder spray
(52) U.S. Cl. applications showing our new design;
USPC ......................................................... D13/164
FIG. 2 is a left-front top perspective view thereof;
(58) Field of Classification Search FIG. 3 is a front view thereof shown in an ON state;
USPC .......... D13/162, 164; 118/308, 663: 239/600, FIG. 4 is a left-rear top perspective view thereof;
239/690; 427/180 FIG. 5 is a rear view of the control unit thereof;
See application file for complete search history. FIG. 6 is a left side view of the control unit thereof;
(56) References Cited FIG. 7 is a top view of the control unit thereof; and,
FIG. 8 is a bottom view of the control unit thereof.
U.S. PATENT DOCUMENTS The broken lines in the drawings form no part of the claimed
design.
D366.460 S * 1/1996 Jorgenson .................... D13, 177
D388,769 S * 1/1998 Pritchard et al. ............. D13,162 1 Claim, 8 Drawing Sheets
-
SSs.
SYSSS
Šss
S
SS
Fig. 1
Fig. 2
Fig. 3
Fig. 4
Fig. 5
Fig. 7
Fig. 8
It is certified that error appears in the above-identified patent and that said Letters Patent is hereby corrected as shown below:
EXHIBIT D
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EXHIBIT E
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EXHIBIT F
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POWDER COATING GUN SYSTEM SS200-FHS MANUAL WITH TROLLEY AND 50LB HOPPER
(HTTPS://WWW.POWDERBUYTHEPOUND.COM/POWDER-COATING-GUN-SYSTEM-SS200-FHS-MANUAL-WITH-TROLLEY-
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SKU: SK00940 C H AT N O W
Case 3:19-cv-00061
P d C i GDocument
S 1-7
SS200Filed
FHS M01/09/19 Page
l Wi h T ll 2 of 4
d PageID
50lb #: 52
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12/7/2018 Powder Buy the Pound: Powder Coating Gun System SS200-FHS Manual With Trolley and 50lb Hopper
Powder Coating Gun System SS200-FHS Manual With Trolley and 50lb
Hopper
$2,425.00
Shipping Weight: 125.00 pounds
Qty
ADD TO CART
DESCRIPTION +
Powder Coating Gun System SS200-FHS Manual With Trolley and 50lb Hopper
The SS200 Series of Gun Systems feature an all digital display With Digital Valve Control (DVC)
technology to give a precise powder coating production and consistent desults. All SS200 Systems
include the Control unit, Manual Gun, air and powder hoses, powder pump and Additional electrodes
and nozzles.
The SS200-FHS Comes with the addition of a 50lb hopper and Rotating hopper Trolley.
*** WARRANTY - 30 DAY MONEY BACK GUARANTEE, RESTOCKING FEE TO APPLY UNLESS RETURN IS
DUE TO MANUFACTURER'S DEFECT. This product, as supplied and distributed by Powder Buy The
Pound and delivered new is warranted by Powder Buy The Pound against manufacturing defects in
materials and workmanship for period of 1 year. This limited warranty begins on the original date of
purchase. To receive warranty service, the purchaser must contact Powder Buy The Pound for problem
determination and service procedures. Powder Buy The Pound will repair or replace this product, at
our option and at no charge as stipulated herein, with new or reconditioned parts or products if
found to be defective during the limited warranty period specified above. This limited warranty
covers manufacturing defects in materials and workmanship encountered in normal use, and shall not
apply to the following, including, but not limited to: damage which occurs in shipment; delivery and
installation; applications and uses for which this product was not intended; altered product or serial
numbers; cosmetic damage or exterior finishes; accidents, abuse, neglect, fire, water, lightning or
other acts of nature; use of products, equipment, systems, utilities, services, parts, supplies,
accessories, applications, installations, repairs, external wiring or connectors not supplied or
authorized by Powder Buy The Pound which damage this product or result in service problems;
incorrect electrical line voltage, fluctuations and surges; customer adjustments and failure to follow
operating instructions, cleaning, maintenance and environmental instructions that are covered and
prescribed in the instruction book. Powder Buy The Pound does not warrant uninterrupted or error-
free operation of the product. ***
There will be a signature required for delivery on all SpectraCoat gun orders.
C H AT N O W
Case 3:19-cv-00061 Document 1-7 Filed 01/09/19 Page 3 of 4 PageID #: 53
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12/7/2018 Powder Buy the Pound: Powder Coating Gun System SS200-FHS Manual With Trolley and 50lb Hopper
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Case 3:19-cv-00061 Document 1-7 Filed 01/09/19 Page 4 of 4 PageID #: 54
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12/7/2018 Contact Us - Hangzhou Color Powder Coating Equipment Co., Ltd
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Hangzhou Color Powder Coating Equipment Co.,Ltd
Tel:(86) 0571-8781 0513 - Fax:(86) 0571-8781 0513
Add:Building34,No 536 ,ShunFeng RD, Yuhang,Hangzhou,China 310010
Exporting department:
Ms Sally +86 13906508694 (Speaks in English)
sales@colourspray.com
Ms Sonne +86 13396517032 (Speaks in Germany)
colo@colourspray.com
Case 3:19-cv-00061 Document 1-12 Filed 01/09/19 Page 3 of 4 PageID #: 69
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12/7/2018 Contact Us - Hangzhou Color Powder Coating Equipment Co., Ltd
Agent in Russia:
Promactive ltd.
Address: h 24/1, Kaliningradskaya str., Tekstilshik, Korolev, Moscow district, 141068.
Tel. +7 495 7677249
Technical Support:
Mr Tom:hicolo@colourspray.com
Want to be a agent of COLO ? please sent email to: supuservices@hotmail.com
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