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Sun Lites Complaint

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Kenneth K. Tanji, Jr., SBN 162273
Jen-Feng Lee, SBN 204328
LT Pacific Law Group, LLP
17800 Castleton Street, #560
City of Industry, CA 91748
T: 626-810-7200
F: 626-810-7300

Attorneys for Plaintiff
Sun Lite Sockets Industry, Inc.



UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

Sun Lite Sockets Industry, Inc., a Taiwanese
corporation;

Plaintiff,

vs.

Mastercraft Distribution, USA, Inc., an
Arkansas corporation; Walmart Stores, Inc.,
an Arkansas corporation; and DOES 1 to 10,
inclusive;

Defendants.

CASE NO.



COMPLAINT for

1. PATENT INFRINGEMENT
2. UNFAIR COMPETITION







Come now Sun Lite Sockets Industry, Inc. (Sun Lite or Plaintiff), and for its
Complaint as stated below:


2:14-cv-6016

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Sun Lites Complaint
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JURISDICTION and VENUE

1. This court has jurisdiction of this action in that the claims arising under Title 35 of
U.S. Codes (Patent Laws), 35 U.S.C. 101 et. seq.
2. Venue is proper in this district under 28 U.S.C. 1391 and 1400.

GENERAL ALLEGATIONS

3. Plaintiff Sun Lite is a Taiwanese corporation with its principle place of business in
Taoyuan, Taiwan. Plaintiff Sun Lite, along with its associated business Rich Brand
Industries Limited, have their manufacturing facility located in Dongguan, China.
4. Plaintiff Sun Lite is in the business of, among others, designing, manufacturing
and selling lighting parts and accessories.
5. Plaintiff sells many of its products in the North American market, including the
United States. For the fruit of its intellectual creation of new product design and
development, Plaintiff would apply for U.S. patent protection.
6. Plaintiff developed a light socket strain relief mechanism and was awarded a U.S.
Patent, number 6,010,355 (355 Patent or Patent In Suit). Said 355 Patent was
filed on 4/7/1998, and was granted on 1/4/2000, entitled Pusher Switch Light
Socket. A true and correct copy of Plaintiffs 355 Patent is attached herein as
Exhibit A.
7. On information and belief, Plaintiff found infringing products offered for sales by
Walmart Stores, Inc. (Walmart). Plaintiffs investigation found infringing
products carried in Kansas and California Walmart stores.
8. Plaintiffs counsel contacted Walmart, who provided the information pertaining to
the supplier of the infringing products: Mastercraft Distribution USA, Inc.
(Mastercraft), located at 3506 Airport Road, Jonesboro, AR 72401.

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Sun Lites Complaint
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9. After some preliminary contacts with Mastercraft (its counsel) and Plaintiff placed
Mastercraft on notice of the infringement, it appeared that Mastercraft continued to
offer for sale the accused infringing products.
10. The light sockets sold/offered by Mastercraft contained the elements on the wire
support of the accused products.
11. Particularly, these elements of the accused products are found to be within the
scope of the claim: A rectangular in plane cantilever portion that has a top surface
substantially parallel to the top surface of the stand, and inner surface substantially
curvilinear.
12. Plaintiffs last purchase of the infringing products offered by Mastercraft was on
5/21/2014, at the Pico Rivera Walmart store. Plaintiff and counsel again examined
the product purchased and confirmed that it met the elements recited in the claim
of the 355 Patent. A store receipt for the purchase of the infringing product is
attached as Exhibit B.
13. Plaintiff is aware that both Mastercraft and Walmart continue to sell and offer for
sale accused products.
14. Plaintiff is unaware of the exact identities of other DOE defendants and
respectfully request the court to allow Plaintiff to amend the Complaint, after
proper chance of discovery is engaged and their identities can be ascertained.

COUNT ONE: PATENT INFRINGEMENT

15. Plaintiff incorporates by reference herein each and every allegations as if fully set
forth herein.
16. At all relevant times, Matercraft and Walmart infringed upon the 355 Patent.
17. As a proximate result of the infringing acts complained herein, Plaintiff suffered
economic harms and injuries.

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18. Defendants Mastercraft and Walmart were put on notice of Plaintiffs exclusive
rights but continued the infringement knowingly and willfully.
19. Plaintiff will continue to suffer more harms, including damages, unless Defendants
are enjoined by the Courts order.

COUNT TWO: UNFAIR COMPETITION

20. Plaintiff incorporates by reference herein each and every allegations as if fully set
forth herein.
21. On information and belief, Defendants Mastercraft and Walmart, via their
wrongful acts complained herein, unfairly competed against Plaintiffs business of
selling its own patent products.
22. As a proximate result of the infringing acts complained herein, Plaintiff suffered
economic harms and injuries.
23. In additional to damages, Plaintiff will continue to suffer more harms unless
Defendants are enjoined by the Courts order.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff demand judgment against Defendants as set forth below.
1. Defendants to be found liable for the infringing acts complained herein and to be
discovered.
2. Defendants to be enjoined to further make, use, sell, offer for sale, and otherwise
commercially exploit the infringing products complained herein.
3. Defendants to be ordered to pay compensatory damages to Plaintiff, and in an
amount not lower than a reasonable royalty fee as stated under 35 USC 287.

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Sun Lites Complaint
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4. Defendants to be found liable for their wrongful acts, and liable for Plaintiffs
attorney fees and costs, based upon a finding of exceptional case under 35 USC
285.
5. Defendants to be assessed punitive damages for their intentional infringement,
deceitful and malicious acts that caused great harm to Plaintiff.
6. Such further relief as the court may deem just and proper.

Dated: July 31, 2014

Respectfully Submitted,


/s/Jen-Feng Lee
Jen-Feng (Jeff) Lee
Kenneth K. Tanji, Jr.
Attorneys for Plaintiff













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Sun Lites Complaint
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REQUEST FOR JURY TRIAL

Pursuant to Federal Rules of Civil Procedure 38(b) and Local Rules, Plaintiff
Sun Lite Sockets Industry, Inc., hereby requests a trial by jury for all issues in this
action.

Dated: July 31, 2014

LT Pacific Law Group

/s/Jen-Feng Lee
Jen-Feng (Jeff) Lee
Kenneth K. Tanji, Jr.
Attorneys for Plaintiff