IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA (1) TITAN HOLDINGS, LLC, Plaintiff,

v. (1) UNDER ARMOUR, INC., Defendant. COMPLAINT COMES NOW, Plaintiff Titan Holdings, LLC (Plaintiff), and for its Complaint against Defendant Under Armour, Inc. (Defendant) states and alleges as follows: THE PARTIES
1.

Case No. CIV-11-777-D JURY DEMAND REQUESTED

Plaintiff is a Limited Liability Company organized under the laws of

Oklahoma, and has its principal place of business in Stillwater, Oklahoma.

2.

Defendant is a Corporation organized under the laws of Maryland, and has

its principal place of business in Baltimore, Maryland. JURISDICTION AND VENUE

3.

Subject matter jurisdiction is based upon 29 U.S.C. 1338.

Personal

jurisdiction is based upon F.R.Civ.P. 4(e), affecting long arm jurisdiction based upon Defendants contacts with this jurisdiction, including Defendants doing business in this district, and its commission of acts of infringement of Plaintiffs patent sued upon herein in this district. Venue is proper in this district pursuant to 28 U.S.C. 1391(c), 1400.

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COUNT I
4.

On December 19, 2000, United States Letters Patent No. 6,161,222 were

duly and legally issued for an invention on an athletic garment (the 222 patent). Plaintiff was assigned the 222 patent on January 10, 2008, and since that date Plaintiff has been and still is the owner of the 222 patent, and of all right of recovery for damages thereunder.
5.

Defendant has been infringing the 222 patent by making, using and selling

products embodying the patented invention and will continue to do so unless enjoined by this Court.
6.

Upon information and belief, Defendant has known of the 222 patent, yet

Defendant has pursued its knowing and willful infringement thereof, in flagrant disregard of Plaintiffs rights thereunder. WHEREFORE, Plaintiff demands: 1. 2. an injunction against Defendants continued infringement; an accounting for damages resulting from Defendants infringement and the

trebling of such damages because of the knowing, willful and wanton nature of Defendants conduct; 3. 4. 5. premises. an assessment of interest on the damages so computed; an award of Plaintiffs attorneys fees and costs in this action; and such other and further relief as the Court deems just and equitable in the

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DEMAND FOR JURY TRIAL Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of any issues triable of right by a jury.

ATTORNEY LIEN CLAIMED

Dated: July 12, 2011

Respectfully submitted, s/Phillip L. Free, Jr., OBA #15765 Michael E. Smith, OBA #8385 Phillip L. Free, Jr., OBA #15765 HALL, ESTILL, HARDWICK, GABLE, GOLDEN & NELSON, P.C. 100 North Broadway, Suite 2900 Oklahoma City, OK 73102-8865 Telephone: (405) 553-2828 Facsimile: (405) 553-2855 mesmith@hallestill.com pfree@hallestill.com ATTORNEYS FOR PLAINTIFF, TITAN HOLDINGS, LLC

By:

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