IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

RETRACTABLE CORD
TECHNOLOGIES LLC,

PlaintiII,


v.
CIVIL ACTION FILE

NO.

VANGUARD PRODUCTS GROUP, INC.,
d/b/a Vanguard Protex Global, and
SLED CORP., I/k/a Protex International Corp.,

DeIendants.




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PlaintiII RETRACTABLE CORD TECHNOLOGIES LLC ('PlaintiII), by
and through its undersigned counsel, Iiles this original Complaint against
DeIendant as Iollows:
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1. This is a patent inIringement action concerning DeIendant`s
inIringement oI PlaintiII`s United States Patent No. 5,516,986, entitled 'Miniature
Electric Cable ('the `986 patent), a copy oI which is attached hereto as
Exhibit A.
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2. PlaintiII is a Georgia limited liability company having a principal
oIIice in Braselton, Georgia. PlaintiII is the assignee oI all right, title and interest
in and to the `986 patent, including the right to sue Ior all past inIringement. The
`986 patent issued on May 14, 1996, aIter Iull and Iair examination by the United
States Patent OIIice. The `986 patent was valid and enIorceable until its expiration
on or about May 14, 2008, Ior non-payment oI maintenance Iees by PlaintiII`s
predecessor in interest.
3. DeIendant VANGUARD PRODUCTS GROUP, INC., d/b/a
Vanguard Protex Global ('VPG), is an Illinois corporation with a principal place
oI business in Oldsmar, Florida, and may be served with process by and through its
registered agent, Corporate Creations Network Inc., 11380 Prosperity Farms Road
#221 E, Palm Beach Gardens, FL 33410.
4. DeIendant SLED CORP., I/k/a Protex International Corp., ('Protex)
is a New York Corporation with a principal place oI business in Bohemia, New
York, and may be served with process by and through its registered agent, John F.
Woog, Esq., 666 Old Country Rd., Garden City, New York 11530.
3

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5. This action arises under the Patent Laws oI the United States, 35
U.S.C. 1 HWVHT, including, without limitation, 35 U.S.C. 271, 281, 284, and
285. This Court has subject matter jurisdiction over this case Ior patent
inIringement under 28 U.S.C. 1331 and 1338(a).
6. This Court has personal jurisdiction over each oI the DeIendants
pursuant to O.C.G.A. 9-10-91 and Iederal law on the grounds that, upon
inIormation and belieI, (i) DeIendants transact business within the State oI
Georgia; (ii) DeIendants have committed acts oI patent inIringement within and/or
directed toward residents oI the State oI Georgia; (iii) DeIendants` acts oI patent
inIringement have caused injury within the State oI Georgia, and DeIendants
regularly do or solicit business, engage in other persistent courses oI conduct,
and/or derive substantial revenue Irom goods used or consumed or services
rendered in this state; (iv) DeIendants purposeIully direct activities toward
residents oI the State oI Georgia; (v) the cause oI action set Iorth herein arises Irom
or relates to DeIendants` activities in the State oI Georgia; and/or (vi) the exercise
oI jurisdiction over DeIendants will not oIIend traditional notions oI Iair play and
substantial justice.
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7. More speciIically, each DeIendant, directly and/or through
intermediaries, has shipped, distributed, oIIered Ior sale, sold, and/or advertised
(including by the provision oI interactive web pages) its products and services in
the United States, the State oI Georgia, and the Northern District oI Georgia. Upon
inIormation and belieI, each DeIendant has committed patent inIringement in the
State oI Georgia and in the Northern District oI Georgia. Each DeIendant has
solicited customers in the State oI Georgia and in the Northern District oI Georgia.
Each DeIendant has had paying customers who are residents oI the State oI
Georgia and the Northern District oI Georgia and who each have used DeIendant`s
respective products and services in the State oI Georgia and in the Northern
District oI Georgia.
8. Venue is proper in the Northern District oI Georgia pursuant to 28
U.S.C. 1391 and 1400(b).
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9. PlaintiII realleges and incorporates by reIerence the allegations set
Iorth in paragraphs 1-8, above, as iI set Iorth verbatim herein.
10. DeIendant VPG, has directly inIringed the `986 patent in violation oI
35 U.S.C. 271(a) by making, using, selling, or oIIering Ior sale in the United
States miniature electronic cable products that embody the patented invention.
5

VPGs` inIringing products include, without limitation, its Electronic Retractable 4
Series ER-4 products, which inIringe at least claim 1 oI the `986 patent.
11. To the extent any such notice may be required, VPG received actual
notice oI its inIringement oI the `986 patent at least as early as the Iiling oI the
original complaint in this action, pursuant to 35 U.S.C. 287(a).
12. VPG`s aIoresaid activities have been without authority and/or license
Irom PlaintiII.
13. PlaintiII is entitled to recover Irom VPG the damages sustained by
PlaintiII as a result oI VPG`s wrongIul acts in an amount subject to prooI at trial,
which, by law, cannot be less than a reasonable royalty, together with interest and
costs as Iixed by this Court under 35 U.S.C. 284.
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14. PlaintiII realleges and incorporates by reIerence the allegations set
Iorth in paragraphs 1-13, above, as iI set Iorth verbatim herein.
15. DeIendant Protex, has directly inIringed the `986 patent in violation oI
35 U.S.C. 271(a) by making, using, selling, or oIIering Ior sale in the United
States miniature electronic cable products that embody the patented invention.
Protex`s inIringing products include, without limitation, its Electronic Retractable
4 Series ER-4 products, which inIringe at least claim 1 oI the `986 patent.
6

16. To the extent any such notice may be required, Protex received actual
notice oI its inIringement oI the `986 patent at least as early as the Iiling oI the
original complaint in this action, pursuant to 35 U.S.C. 287(a).
17. Protex`s aIoresaid activities have been without authority and/or
license Irom PlaintiII.
18. PlaintiII is entitled to recover Irom Protex the damages sustained by
PlaintiII as a result oI Protex`s wrongIul acts in an amount subject to prooI at trial,
which, by law, cannot be less than a reasonable royalty, together with interest and
costs as Iixed by this Court under 35 U.S.C. 284.
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19. PlaintiII hereby requests a trial by jury pursuant to Rule 38 oI the
Federal Rules oI Civil Procedure.
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PlaintiII respectIully requests that the Court Iind in its Iavor and against
DeIendants, and that the Court grant PlaintiII the Iollowing relieI:
A. An adjudication that one or more claims oI the `986 patent have been
inIringed, either literally and/or under the doctrine oI equivalents, by
each oI the DeIendants;
7

B. An accounting and an award to PlaintiII oI damages adequate to
compensate PlaintiII Ior the DeIendants` acts oI inIringement together
with pre-judgment and post-judgment interest;
C. That this Court declare this to be an exceptional case and award
PlaintiII its reasonable attorneys` Iees and costs in accordance with 35
U.S.C. 285; and
D. Any Iurther relieI that this Court deems just and proper.

This 9th day oI December, 2011.
KENT LAW, P.C.

/s/'DQLHO$.HQW
Daniel A. Kent
Georgia Bar Number 415110
dankentiplit.com
555 N Point Ctr E Ste 400
Alpharetta, GA 30022
Tel: (404) 585-4214
Fax: (404) 829-2412

Attorney Ior PlaintiII