UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WISCONSIN

SPRINGS WINDOW FASHIONS, LLC,
Plaintiff,
vs.
RICHFIELD WINDOW COVERINGS, LLC,
d/b/a NIEN MADE (U.S.A.) INC.,
Defendant.

Case No. 14-cv-526
JURY TRIAL DEMANDED


COMPLAINT

Plaintiff Springs Window Fashions, LLC, by and through its attorneys, Michael Best &
Friedrich LLP, states for its Complaint against Defendant Richfield Window Coverings, LLC,
d/b/a Nien Made (U.S.A) Inc., as follows:
PARTIES
1. Springs Window Fashions, LLC is a limited liability corporation formed in the
State of Delaware with its principle place of business located at 7549 Graber Road, Middleton,
Wisconsin 53562 and is in the business of making and selling window coverings.
2. Defendant Richfield Window Coverings, LLC, d/b/a Nien Made (U.S.A.) Inc.,
(Defendant or Richfield) is a limited liability company organized and existing under the
laws of the State of California with its principal place of business at 12301 Hawkins Street, Santa
Fe Springs, California 90670. Richfield is a subsidiary of International Window Treatments,
Inc., which is a subsidiary of Norman International, Inc. and Nien Made Enterprise Co., Ltd.
Richfield is in the business of selling and distributing window coverings and devices that cut
window coverings.
- 2 -
JURISDICTION AND VENUE
3. This is an action for patent infringement in violation of 35 U.S.C. 271.
4. The matter in controversy in this action exceeds the sum or value of $75,000,
exclusive of interests and costs, and is between citizens of different states.
5. Defendant regularly transacts business in the State of Wisconsin and in this
District by making, using, selling, and/or offering to sell products within this District.
Defendants business in this District includes substantial and continuous sales of window
covering products, and delivery of same, to various retailers, including The Home Depot. These
sales have been continuous and substantial over a period of years prior to the filing of this
Complaint. Upon information and belief, representatives or agents of Defendant are present in
the state of Wisconsin on a regular basis to conduct business related to the sale of products in this
state, or to deliver Defendants products to this state.
6. Upon information and belief, Defendant has contractual obligations with The
Home Depot and other retailers related to its sale and delivery of products within this District.
7. Upon information and belief, Defendant uses, sells, offers to sell and distributes
the Accused Product (defined below) within the United States. Upon information and belief,
Defendant has plans to introduce the Accused Product into this District for use by retailers by the
end of 2014.
8. Upon information and belief, Defendant has offered to sell the Accused Product
to at least one Menards retail location in Wisconsin.
9. This Court has jurisdiction over the subject matter of this action based on 28
U.S.C. 1331, 1332, and 1338(a).
- 3 -
10. This Court has personal jurisdiction over Defendant based on Defendants
contacts with the State of Wisconsin and this District.
11. Venue is proper in this judicial district based on 28 U.S.C. 1391(b), 1391(c),
and 1400(b).
BACKGROUND FACTS
12. U.S. Patent No. 5,816,126, entitled CUTTER FOR SHORTENING BLINDS
(the 126 Patent), a copy of which is hereby attached to as Exhibit A, was duly and legally
issued by the U.S. Patent and Trademark Office on October 6, 1998. Ehud Pluber is the sole
inventor listed on the 126 Patent.
13. Holis Metal Industries, Ltd. Israeli Co. was the original assignee of the 126
patent. Shade-O-Matic Ltd. was assigned all right, title and interest in the 126 patent by
February 20, 2002.
14. Since March 15, 2002, Springs Window Fashions, LLC is the exclusive licensee
of the 126 Patent in the field of cutting machines used to cut window covering products, and has
the right to bring actions for infringement of the 126 patent.
15. U.S. Patent No. 6,435,066, entitled CUTTING APPARATUS FOR WINDOW
COVERING AND METHODS THEREFOR (the 066 Patent), a copy of which is hereby
attached to as Exhibit B, was duly and legally issued by the U.S. Patent and Trademark Office on
August 20, 2002. Darrell J. Kutchmarek and Richard L. Seiders are the inventors listed on the
066 Patent.
16. Springs Window Fashions, LLC is the owner by assignment of all right, title, and
interest in and to the 066 Patent.
- 4 -
17. On information and belief, Defendant makes, uses, has made, offers for sale, sells,
and/or imports into the United States an All In One Cutting Machine referred to as the
VAC1 for cutting apparatus for window coverings (the Accused Product) that infringes at
least claim 1 of the 126 Patent.
18. On information and belief, Defendant makes, uses, has made, offers for sale, sells,
and/or imports into the United States the Accused Product, that, when used by Defendant
infringes at least method claim 1 of 066 Patent.
COUNT I INFRINGEMENT OF U.S. PATENT NO. 5,816,126
19. Springs Window Fashions, LLC re-alleges and incorporates by reference the
foregoing paragraphs of this Complaint as though fully set forth herein.
20. Defendant has directly infringed the 126 Patent under 35 U.S.C. 271(a) by
making, using, importing, offering to sell, and/or selling the Accused Product within the United
States.
21. On information and belief, Defendants acts of direct infringement have been
willful, deliberate, and knowingly performed with reckless disregard for Springs Window
Fashions, LLCs exclusive rights to the 126 Patent and will continue unless preliminarily and
permanently enjoined by this Court.
22. As a direct and proximate result of Defendants act of direct infringement,
Springs Window Fashions, LLC has suffered injury and damage, which continues to accrue, in
an amount to be determined at trial.
23. Unless preliminarily and permanently enjoined by this Court, Defendants acts of
direct infringement will cause Springs Window Fashions, LLC further injury and damage,
- 5 -
including immediate and irreparable harm that cannot be adequately compensated by monetary
damages.
COUNT II INFRINGEMENT OF U.S. PATENT NO. 6,435,066
24. Springs Window Fashions, LLC re-alleges and incorporates by reference the
foregoing paragraphs of this Complaint as though fully set forth herein.
25. Defendant has directly infringed the 066 Patent under 35 U.S.C. 271(a) by
making, using, importing, offering to sell, and/or selling the Accused Product within the United
States.
26. On information and belief, Defendants acts of direct infringement have been
willful, deliberate, and knowingly performed with reckless disregard for Springs Window
Fashions, LLCs exclusive rights to the 066 Patent and will continue unless preliminarily and
permanently enjoined by this Court.
27. As a direct and proximate result of Defendants act of direct infringement,
Springs Window Fashions, LLC has suffered injury and damage, which continues to accrue, in
an amount to be determined at trial.
28. Unless preliminarily and permanently enjoined by this Court, Defendants acts of
direct infringement will cause Springs Window Fashions, LLC further injury and damage,
including immediate and irreparable harm that cannot be adequately compensated by monetary
damages.
JURY DEMAND
Springs Window Fashions, LLC demands a trial by jury on all matters and issues triable
by a jury.

- 6 -
REQUEST FOR RELIEF
WHEREFORE, Plaintiff Springs Window Fashions, LLC respectfully requests that this
Court grant the following relief:
A. A Judgment in favor of Springs Window Fashions, LLC on its claims of patent
infringement;
B. A Judgment that Defendant has willfully and deliberately committed acts of
patent infringement pursuant to 35 U.S.C. 271;
C. An Order pursuant to 35 U.S.C. 283 preliminarily and permanently enjoining
Defendant and their respective officers, agents, servants, employees, attorneys, and all other
persons in active concert or participation with them from manufacturing, using, offering to sell,
and selling the Accused Product and any other infringing products within the United States and
from importing the Accused Product, any other infringing products, and their component parts
into the United States;
D. An Order directing Defendant to surrender for destruction all infringing products
and manufacturing supplies for such products that are in Defendants possession or control in the
United States or in transit to the United States;
E. An Order directing Defendant to file with this Court and serve on Springs
Window Fashions, LLCs attorneys, within thirty (30) days after the date of entry of any
injunction, a report in writing and under oath setting forth in detail the manner and form in which
they have complied with the injunction;
F. An award of actual monetary damages pursuant to 35 U.S.C. 284 that Springs
Window Fashions, LLC has incurred as a result of Defendants infringement, in an amount to be
determined at trial but in no event less than a reasonable royalty;
- 7 -
G. A finding that this is an exceptional case within the meaning of 35 U.S.C. 285;
H. An Order trebling Springs Window Fashions, LLCs damages and awarding
Springs Window Fashions, LLC its attorneys fees, costs, and disbursements incurred in
prosecuting this action; and
H. An award to Springs Window Fashions, LLC of such other relief as this Court
deems just and equitable.

Dated this 28
th
day of July, 2014.
MICHAEL BEST & FRIEDRICH LLP
By: s/ Richard H. Marschall
John C. Scheller, SBN 1031247
One South Pinckney Street
P.O. Box 1806
Madison, WI 53701-1806
Phone: 608.257.3501
Fax: 608.283.2275
Email: jcscheller@michaelbest.com

Richard H. Marschall, SBN 1035851
100 E. Wisconsin Avenue
Suite 3300
Milwaukee, WI 53202
Phone: 414.271.6560
Fax: 414.277.0656
Email: rhmarschall@michaelbest.com

Attorneys for Plaintiff
Springs Window Fashions, LLC