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David Hong, Esq. (CA# 195795) david.hong@dhpatentlaw.com LAW OFFICE OF DAVID HONG P.O. Box 211, Santa Clarita, CA 91386-2111 Tel: (866) 824-8680 Fax: (866) 824-8680 Attorney for Plaintiff AIR DIMENSIONAL DESIGN, INC.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) AIR DIMENSIONAL DESIGN, INC., ) ) a California corporation, ) ) Plaintiff ) ) vs. ) ) TOOL KING MOTOR COMPANY, a ) ) California corporation; TONY WANG, ) ) an individual, and DOES 1-10 ) ) inclusive, ) ) Defendants ) Case No.: 2:13-CV-08522 COMPLAINT FOR PATENT INFRINGEMENT (U.S. Patent 6168657); INDUCEMENT OF INFRINGEMENT, 35 U.S.C. 271(b)

Jury Trial Requested

FIRST CAUSE OF ACTION: Patent Infringement of U.S. 6186857 JURISDICTION AND VENUE 1. The action arises under the Patent Laws of the United States, United States Code, Title 35 (a federal question type action), including but not limited to Sec. 271, 281, 283, 284, and 285; jurisdiction and venue are predicated upon the United States Code, Title 28, Sec. 1338, 1391 and 1400. Venue is proper because the Defendants reside in California, and upon information and belief, the
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Defendants reside in this Courts district and are subject to the personal jurisdiction of this Court, and a substantial part of the events or omissions giving rise to the claims occurred in this Court's district. 2. Plaintiff AIR DIMENSIONAL DESIGN, INC. (hereinafter "AirDD") is a corporation organized under the existing laws of the State of California and has an office and principal place of business at 7051-1/2 Vineland Avenue, North Hollywood, CA 91605. 3. Upon information and belief, Defendant TOOL KING MOTOR COMPANY, (hereinafter "TK"), is a corporation organized under the laws of California (CA Entity No. C3202453) and has a CA Secretary of State listed address at 2342 Sloan Dr., La Verne, CA 91750; the agent for service of process is listed as Mr. Andy Hou, 2211 S. Hacienda Blvd., #106, Hacienda Heights, CA 91745. Also, upon information and belief, Def. Tool King Motor Company has a business address 5522 Olive St., Montclair, CA 91763, which is listed on the website www.toolkingmotor.com. (EXH006; EXH007). 4. Upon information and belief, Defendant TONY WANG, an individual, is the president and contact person for Defendant TK and has an address at 2342 Sloan Dr., La Verne, CA 91750. 5. Plaintiff is unaware of the names and true capacities of Defendants, whether individual, corporate and/or partnership entities, named herein as DOES 1 through 10, inclusive, and therefore sues them by their fictitious names. Plaintiff will seek leave to amend its complaint when their true names and capacities are ascertained. Plaintiff is informed and believes and based thereon alleges that said Defendants and DOES 1 through 10, inclusive, are in some manner responsible for the wrongs alleged herein, and that at all times referenced each was the agent and
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servant of the other Defendants and was acting within the course and scope of said agency and employment. 6. Plaintiff is informed and believes, and based thereon alleges, that at all relevant times herein, Defendants and DOES 1 through 10, inclusive, knew or reasonably should have known of the acts and behavior alleged herein and the damages caused thereby, and by their inaction ratified and encouraged such acts and behavior. Plaintiffs further allege that Defendants and DOES 1 through 10, inclusive, had a non-delegable duty to prevent or cause such acts and the behavior described herein, which duty Defendants and DOES 1 though 10, inclusive, failed and/or refused to perform. 7. On Feb. 13, 2001, United States Letters Patent No. 6186857 was duly and legally issued to Plaintiff AIR DIMENSIONAL DESIGN, INC. as assignee from inventors: Mr. DORON GAZIT and Mr. ARIEH L. DRANGER, for an invention titled: Apparatus and Method for Providing Undulating Figures. (EXH001 U.S. Pat. 6186857). 8. Plaintiff is the owner of those Letters Patent since the issue date of the U.S. Patent No. 6186857. 9. PATENT INFRINGEMENT, 35 U.S.C. 271: Defendant TK has infringed U.S. Patent No. 6186857 by making, selling, and using undulating figure products embodying the patented invention, and will continue to do so unless enjoined by this court; such infringement is willful and deliberate, notice of the existence of the said patents having duly placed on all of Plaintiff's undulating figure products; the infringement by defendants of said patents of Plaintiff has deprived Plaintiff of sales and leases of its undulating figure products which it otherwise would have made (directly or through an authorized licensee) and has in
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other respects injured Plaintiff and will cause Plaintiff added injury and loss of profits unless enjoined by this Court. (EXH002 - EXH005; EXH008 EXH009). 10. Plaintiff has placed the required statutory notice on all undulating figures manufactured and sold by it under said Letters Patent, and has given written notice to Defendant of its said patent infringement. (EXH002, EXH004). 11. Unfair Competition: Defendant TK has unfairly competed with Plaintiff by copying patented features of Plaintiff's apparatus and method for providing inflated undulating figures and by otherwise causing customer confusion, all of which practices already have resulted in serious injury to Plaintiff's business position, reputation, and good will, and will result in irreparable injury to Plaintiff unless enjoined by this Court. 12. INDUCEMENT OF INFRINGEMENT, 35 U.S.C. 271(b): Upon information and belief, both Defendants TK and its president Mr. TONY WANG had knowledge of U.S. Patent No. 6186857; as a corporate officer and President of TK, Mr. WANG has actively assisted with said patent infringement by TK, has knowingly induced said patent infringement by TK; Mr. WANG has possessed the specific intent to encourage said infringement of U.S. Patent No. 6186857 by TK. Upon information and belief, Mr. WANG knew or acted with willful blindness that his actions would induce actual infringement by TK. 13. WHEREFORE, Plaintiff AIR DIMENSIONAL DESIGN, INC. prays and demands an injunction against infringement, an accounting and an award for damages in excess of $75,000 USD (Title 35, United States Code Sec. 284 (damages) and Sec. 285(attorney fees)), and an assessment of interest and costs against all Defendants; that all Defendants be compelled to pay Plaintiff punitive

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damages (35 USC 284) in excess of $225,000 USD; and for such other and further relief as may be just and equitable. Dated: 11/18/2013 Respectfully, /S/ - DAVID HONG, ESQ. David Hong, Esq., CA SBN 195795 Attorney for Plaintiff

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JURY TRIAL REQUESTED 1. Plaintiff respectfully requests a jury trial pursuant to FRCP 38. Dated: 11/18/2013 Respectfully, /S/ - DAVID HONG, ESQ. David Hong, Esq., CA SBN 195795 Attorney for Plaintiff

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