UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
PCT INTERNATIONAL, INC.
AMPHENOL CORPORATION and
TIMES FIBER COMMUNICATIONS, INC.
Civil Action No.
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JURY TRIAL DEMANDED
Defendant.
Plaintiffs,
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COMPLAINT FOR INJUNCTIVE RELIEF
AND DAMAGES FOR PATENT INFRINGEMENT
Plaintiffs, Amphenol Corporation ("Amphenol") and Times Fiber Communications, Inc.
("TFC"), bring this complaint for patent infringement against Defendant, PCT International, Inc.
("PCT"), and allege as follows:
Nature of Action and Jurisdiction
1. This is an action seeking injunctive relief and damages for patent infringement
pursuant to the patent laws of the United States, more particularly Title 35 of the United States
Code.
2. This Court has jurisdiction over the subject matter ofthis action pursuant to 28
U.S.C. 1331 and 1338.
3. Venue is proper in the District of Connecticut pursuant to 28 U.S.C. 1391 and
1400.
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Parties
4. Plaintiff Amphenol is a Delaware corporation having its principal place of
business at 358 Hall Avenue, Wallingford, Connecticut 06492. PlaintiffTFC is a wholly owned
subsidiary of Amphenol having its principal place of business also at 358 Hall Avenue,
Wallingford, Connecticut 06492.
5. Defendant PCT is and was at all relevant times a corporation organized and
existing under the laws of the state of Nevada having a principal place of business located at
Broadway 101 Commerce Park, 2260 West Broadway Road, Suite 201, Tempe, Arizona 85202-
1899. PCT does business worldwide, including within this judicial district.
Count for Infringement ofD.S. Patent No. 7,544,094
6. On June 9, 2009, United States Patent No. 7,544,094 ("the Paglia Patent") was
duly and legally issued for an invention entitled "Connector Assembly with Gripping Sleeve." A
copy of the Paglia Patent is attached hereto as Exhibit 1.
7. Plaintiff Amphenol is the owner ofthe Paglia Patent by virtue of an assignment
from the inventors.
8. PlaintiffTFC is the exclusive licensee of the Paglia Patent.
9. The Paglia Patent teaches a sleeve that may be used with connector assemblies to
facilitate gripping and mating of a connector to its counterpart connector.
10. As of a date not yet ascertained, Defendant PCT has been, and presently is,
willfully infringing the Paglia Patent by importing into, making, using, offering for sale, and/or
selling within the United States, including within this judicial district, jumper sleeves that come
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within the scope of one or more claims of the Paglia Patent, with full knowledge and awareness
of the Paglia Patent and without the authority, consent, or approval of Plaintiffs Amphenol and
TFC.
11. Defendant PCT's jumper sleeves infringe, literally or by equivalents, one or more
valid enforceable claims of the Paglia Patent.
12. As a direct and proximate result of Defendant PCT's acts of infringement of the
Paglia Patent, Plaintiffs have suffered injury and damages for which they are entitled to relief,
including, but not limited to, monetary damages.
13. Defendant PCT has knowingly, willfully, and deliberately infringed the Paglia
Patent in conscious disregard ofPlaintiffs,, rights, making this case exceptional within the
meaning of35 U.S.c. 285 and justifying treble damages pursuant to 35 U.S.C. 284.
14. Defendant PCT will continue to infringe the Paglia Patent, causing immediate and
irreparable harm unless the Court enjoins and restrains its activities.
15. The infringement by Defendant PCT has deprived, and will further deprive
Plaintiffs of revenue which Plaintiffs would have made or would enjoy in the future; has injured
Plaintiffs in other respects; and will cause added injury and damage in the future unless
Defendant PCT is enjoined from infringing the Paglia Patent.
WHEREFORE, Plaintiffs Amphenol and TFC pray that judgment be entered in its favor
as follows:
1. temporarily, preliminarily and permanently enjoining and restraining PCT, its
officers, directors, principals, agents, servants, employees, successors and assigns, and all those
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acting in concert or participation with them, from infringing the Paglia Patent;
2. directing PCT to file with this Court and to serve on Plaintiffs a written report
under oath setting forth in detail the manner and form in which PCT has complied with the
injunction;
3. directing that PCT, at its own expense, account to Plaintiffs for profits and
damages resulting from PCT's infringement of the Paglia Patent;
4. awarding Plaintiffs treble damages pursuant to 35 U.S.C. 284;
5. ordering PCT to pay Plaintiffs their costs, expenses, and fees, including attorneys'
fees pursuant to 35 U.S.C. 285, and pre-judgment and post-judgment interest at the maximum
rate allowed by law; and
6. directing such other and further relief as the Court may deem just and proper.
Jury Trial Demand
Pursuant to Fed. R. Cir. P. 38(b), Plaintiffs demand a trial by jury on all issues triable to a
Jury.
THE PLAINTIFFS,
AMPHENOL CORPORATION and
TIMES FIBER COMMUNICATIONS, INC.
Dated: October 15,2012 By:

mas . Withetingto
COHN, BIRNBAUM & S
Counsel for Plaintiffs
100 Pearl Street, 12
th
Floor
Hartford, CT 06103
Tel: (860) 493-2200
Fax (860) 727-0361
Email: twitherington@cb-shea.com
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Of counsel:
Charles R. Wolfe, Ir.
Tara L. Marcus
BLANKROME LLP
600 New Hampshire Avenue, N.W.
Washington, D.C. 20037
Phone: (202) 772-5800
Facsimile: (202) 772-5858
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