1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

CHAD HABEEB, )
)
Plaintiff, )
) Case No._____________
v. )
)
) JURY TRIAL DEMANDED
JUKES SHOES, LLC, )
)
Defendants. )

COMPLAINT
Plaintiff Chad Habeeb (Habeeb) complains against Defendant Jukes Shoes, LLC
(Jukes Shoes), and states as follows:
Nature of This Case
1. This case involves the Defendant Jukes Shoes sale of goods that infringe upon
Plaintiff Habeebs design patent, U.S. Patent No. D687,216.
Parties
2. Plaintiff, Chad Habeeb, is an individual resident and citizen of Washington D.C.,
who is domiciled in Washington D.C.
3. On information and belief, Defendant Jukes Shoes is a limited liability company
formed under the laws of the State of Texas.
Jurisdiction and Venue
4. This Court has subject matter jurisdiction over this action under to 28 U.S.C.
1331-32 and 1338.
5. Personal jurisdiction in this district is proper inasmuch as Defendant Jukes Shoes
solicit and conduct business within the State of Illinois and this district via its authorized or
Case: 1:14-cv-04649 Document #: 1 Filed: 06/19/14 Page 1 of 4 PageID #:1
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licensed interactive website located at http://www.jukzshoes.com/, thereby purposely availing
itself of the privilege of conducting business in the State of Illinois and in this district.
6. Further, as a result of its actions of patent infringement, Defendant Jukes Shoes
has also caused injury to Plaintiff in Illinois and this district.
7. Venue is proper in this Court pursuant to 28 U.S.C. 1391 because a substantial
part of the events or omissions giving rise to the claims occurred in this district.
Defendants Infringement of Plaintiff Habeebs Design PAtent
8. As outlined above, Plaintiff owns U.S. Patent No. D687,216 (the 216 Patent).
See Exhibit A.
9. The 216 Patent issued on August 6, 2013.
10. The 216 Patent claims an ornamental design for a pair of sandals featuring lines
that transgress the uppermost surface of the shoe.
11. Defendant Jukes Shoes is selling sandals under the name Tennis Flip Flops on
its website that feature lines transgressing the surface of the shoe in a manner similar to what is
claimed in the 216 Patent. See Exhibit B.
12. The Tennis Flip Flops are identical in shape, design and ornamental features to
the design claimed by the 216 Patent, including all of the non-functional elements of that
design.
13. The design of the Tennis Flip Flops are substantially similar to the design claimed
by the 216 Patent.
14. The design of the Tennis Flip Flops infringe upon the 216 Patent.


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COUNT I
Patent Infringement (Against Jukes Shoes)
15. Plaintiff Habeeb repeats and re-alleges the allegations contained in Paragraphs 1-
17 above as if fully set forth herein.
16. Defendant Jukes Shoes advertises and sells, or authorizes, or licenses the
advertising and sale of the Tennis Flip Flops.
17. The aforementioned products infringe upon the 216 Patent.
WHEREFORE, Plaintiff prays for a judgment as follows:
(A) Permanently enjoining and restraining Defendant Jukes Shoes, its officers, agents,
members, employees, representatives, assigns and all others acting in concert or
participating with any of them from:

(i) Selling, authorizing, or licensing the sale of flip flops and all other
merchandise that infringe upon U.S. Patent No. D687,216.

(B) Directing Defendant Jukes Shoes to:

(i) Pay to Plaintiff an amount adequate to compensate for the infringement of
U.S. Patent No. D687,216, but in no event less than a reasonable royalty
for the use made of the invention by Defendants, together with interests
and costs pursuant to 35 U.S.C. 284;

(C) Finding this case to be exceptional and awarding Plaintiff its reasonable attorney
fees; and

(D) Awarding Plaintiff such further relief as this Court deems just and equitable.

DEMAND FOR JURY TRIAL

Plaintiff Habeeb respectfully demands a trial by jury in this action.









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DATED: June 19, 2014 Respectfully submitted,


/s/Edward L. Bishop
Edward L. Bishop
ebishop@bdl-iplaw.com
Nicholas S. Lee
nlee@bdl-iplaw.com
Ava L. Caffarini
acaffarini@bdl-iplaw.com
Bishop Diehl & Lee, Ltd.
1750 E. Golf Road, Suite 390
Schaumburg, IL 60173
T: (847) 969-9123
F: (847) 969-9124

Counsel for Plaintiff Chad Habeeb


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EXHIBIT A
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EXHIBIT B
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J UKZ Sports Products
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ABOUT US
In April of 2011, advertising Creative
Director Kevin Puterbaugh approached
Dallas serial entrepreneur J ohnny De La
Valdene with the concept for a line of
sports flip flops that use materials from
sports balls for the insoles. Dozens of
prototypes...
Read More
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PLEASE CONTACT AT :
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Dallas, TX 75226
Tel: 214-519-1466
Fax: 214-741-1384
Email: info@jukzshoes.com
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