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UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ARTISENT, INC., Plaintiff, v. Civil Action No.

__________ INTERNATIONAL ARMOR CORPORATION, Defendant.

COMPLAINT Plaintiff Artisent, Inc., for its complaint against defendant International Armor Corporation, states as follows: PARTIES 1. Plaintiff Artisent, Inc. (Artisent) is a Massachusetts corporation with its

principal place of business in Boston, Massachusetts. 2. Upon information and belief, defendant International Armor Corporation

(International Armor) is a California corporation with its principal place of business in San Clemente, California. JURISDICTION AND VENUE 3. This court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

1331 and 1338(a). 4. Venue is proper in this court pursuant to 28 U.S.C. 1391(b) and 1400(b). FACTS 5. Artisent is the owner by assignment of United States Patent Nos. 7,600,268,

issued on October 13, 2009 (the 268 Patent), which is directed to a helmet retention system

with improved stability, and 7,908,667, issued on March 22, 2011 (the 667 Patent), which is directed to a mounting system for accessories on a safety helmet. Copies of the 268 and 667 Patents are attached as Exhibits A and B. 6. International Armor has made, used, offered for sale and/or sold a product known

as the FAST Ballistic Helmet 3A, and is continuing to do so. 7. By making, using, offering for sale and/or selling the FAST Ballistic Helmet 3A,

International Armor has infringed, and is continuing to infringe, the 268 and 667 Patents. 8. Upon information and belief, International Armors infringement is willful. COUNT I (Infringement of 268 Patent 35 U.S.C. 281) 9. 10. Artisent repeats and realleges paragraphs 1 through 8 as if fully set forth herein. International Armor has infringed, and is continuing to infringe, the 268 Patent. COUNT II (Infringement of 667 Patent 35 U.S.C. 281) 11. 12. Artisent repeats and realleges paragraphs 1 through 10 as if fully set forth herein. International Armor has infringed, and is continuing to infringe, the 667 Patent. PRAYER FOR RELIEF WHEREFORE, plaintiff Artisent, Inc. requests judgment as follows: 1. 2. 3. Enjoining Artisent from further infringement of the 268 and 667 Patents; Awarding Artisent damages in an amount to be proven at trial; Awarding Artisent multiple damages, costs and attorneys fees pursuant to 35

U.S.C. 285; and 4. Granting such other and further relief as this Court deems just and proper.

JURY DEMAND Plaintiff Artisent demands a trial by jury of all issues so triable.

Dated: July 8, 2011

Respectfully submitted, ARTISENT, INC., By its attorneys, /s/ David S. Godkin David S. Godkin (BBO#196530) Anne Marie Longobucco (BBO#649299) Birnbaum & Godkin, LLP 280 Summer Street Boston, MA 02210 617-307-6100 godkin@birnbaumgodkin.com longobucco@birnbaumgodkin.com

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