IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UPONOR, INC.

, Plaintiff, v. Jury Trial Demanded SIOUX CHIEF MFG. CO., INC. Defendant. COMPLAINT NOW COMES Plaintiff UPONOR, INC. (Uponor), by and through its counsel, Joseph M. Vanek, Jeffrey R. Moran and John P. Bjork of Vanek, Vickers & Masini, P.C., and hereby complains against Defendant SIOUX CHIEF MFG. CO., INC. (SIOUX CHIEF) as follows: I. PARTIES AND BACKGROUND 1. Uponor is an Illinois corporation having its principal place of business at 5925 No. ______________________

148th Street West, Apple Valley, Minnesota, 55124. 2. Uponor is involved in the manufacture of polymer tubing, clamping rings

(ProPEX Rings with a leading edge chamfer and integral stop edge), and other products for the plumbing and hydronic industries, and is the owner of United States Patent No. 8,146,225 (the 225 Patent). The 225 Patent was issued on April 3, 2012, is owned by Uponor, and is entitled Method of Forming a Clamping Ring and a Clamping Ring A true and correct copy of the

225 patent as issued is attached hereto as Exhibit A. The 225 patent is directed toward a pioneering invention in the field of clamping rings used in the plumbing industry. 3. Defendant SIOUX CHIEF is, on information and belief, a Missouri corporation

having its principal place of business at 24110 South Peculiar Drive, Peculiar, Missouri, 64078.

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On information and belief, SIOUX CHIEF manufactures products that infringe

upon the 225 patent and distributes those products throughout the United States and Canada, including within this District. II. JURISDICTION AND VENUE 5. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.

1331 and 1338(a) because this action arises under the patent laws of the United States, including 35 U.S.C. 271 et seq. This Court has both general and specific personal jurisdiction over SIOUX CHIEF due to its contacts with this judicial district, such that the exercise of jurisdiction over SIOUX CHIEF would not offend traditional notions of fair play and substantial justice. 6. Venue properly lies in this District pursuant to 28 U.S.C. 1391(b), 1391(c),

and 1400(b) because SIOUX CHIEF is subject to this Courts personal jurisdiction, has committed acts within this judicial district giving rise to this action, and conducts business in this judicial district. III. COUNT I: PATENT INFRINGEMENT

7.

Uponor realleges and incorporates herein the preceding Paragraphs 1-6 as its

allegations in this Paragraph 7. 8. As a result of the pioneering invention disclosed in the 225 Patent, polymer

piping connections in the plumbing industry can be made by temporarily expanding the end of a polymer pipe and a clamping ring (both of which are elastomeric) at ambient temperature, inserting the expanded end of the pipe to a fitting on the connecting pipe via the expanded clamping ring, and allowing the expanded pipe and expanded clamping ring to retract around the fitting of the connecting pipe.

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These and other innovations have made Uponor a leader in the plumbing industry.

Uponors success in the industry is due in large part to the substantial time and resources Uponor and its related companies have devoted to research and development efforts, which have resulted in innovations such as the 225 Patent that have improved the efficiency of plumbing, heating, and cooling systems for its customers across the globe. 10. On information and belief, SIOUX CHIEF is involved in the manufacture and

sale of clamping rings within its fitting systems that use the process protected by the 225 patent under 35 U.S.C. 271 et seq.. 11. On information and belief, the specific infringing acts include, but are not

necessarily limited to, the making, importation, offering for sale, selling and distribution of clamping rings used in Sioux Chiefs PowerPEX F1960 Fitting System, specifically its PowerPEX F1960 Ring With Stop. 12. SIOUX CHIEFs acts of infringement have caused damage to Uponor in the form

of, among other things, lost business. 13. Pursuant to 35 U.S.C. 284, Uponor is entitled to recover from SIOUX CHIEF

the damages sustained by Uponor as a result of SIOUX CHIEFs infringement of the 225 patent. 14. SIOUX CHIEFs infringement of Uponors exclusive rights under the 225 Patent

will continue to damage Uponor causing irreparable harm, for which there is no adequate remedy of law, unless enjoined by this Court under 35 U.S.C. 283.

IV. PRAYER FOR RELIEF WHEREFORE, Uponor respectfully requests that this Court enter judgment against Defendant SIOUX CHIEF as follows: (a) For entry of a judgment holding that the 225 patent is good and valid in law, and has been willfully and deliberated infringed by SIOUX CHIEF; (b) For a permanent injunction, pursuant to under 35 U.S.C. 283, preventing SIOUX CHIEF and its respective directors, officers, employees, agents, subsidiaries, parents, attorneys, and all persons acting in concert, on behalf of, in joint venture, or in partnership with SIOUX CHIEF from committing any further acts of infringement; (c) For damages to be paid by SIOUX CHIEF adequate to compensate Uponor for all infringement of the 225 Patent, including interest, costs and disbursements as justified under 35 U.S.C. 284; (d) For judgment finding this to be an exceptional case, and awarding Uponor attorney fees under 35 U.S.C. 285; and (e) For such further relief at law and in equity as the Court may deem just and proper.

V. DEMAND FOR JURY TRIAL Pursuant to Federal Rule of Civil Procedure 38, Plaintiff UPONOR, INC. hereby demands a jury trial on all issues triable by a jury.

Dated: November 5, 2012

Respectfully submitted,

/s/ Joseph M. Vanek____ Joseph M. Vanek Jeffrey R. Moran John P. Bjork Vanek, Vickers & Masini, P.C. 55 West Monroe Street, Suite 3500 Chicago, Illinois 60603 (312) 224-1500 Telephone (312) 224-1510 Facsimile jvanek@vaneklaw.com jmoran@vaneklaw.com jbjork@vaneklaw.com

Counsel for Plaintiff UPONOR, INC.