Professional Documents
Culture Documents
KX TECHNOLOGIES, LLC
Plaintiff
v.
Dilmen LLC d/b/a Coral Premium Water Filters,
and d/b/a Performancesupplies,
and
Huseyin Dilmen d/b/a Mirage Basics
Defendants
)
)
)
)
)
) Complaint for Damages and Injunctive
) Relief for Patent Infringement and
) Unfair Trade Practices
)
)
)
)
)
COMPLAINT
Plaintiff KX Technologies, LLC ("KXT") alleges as follows:
I. NATURE OF THE ACTION
1. This is a civil action seeking damages and injunctive relief for patent infringement under
the patent laws of the United States, Title 35 of the United States Code 1, et seq., and unfair
trade practices under the Connecticut Unfair Trade Practices Act (CUTPA), C.G.S. 42-110a,
et seq.
II. JURISDICTION AND VENUE
2. Jurisdiction of this Court is proper pursuant to Title 28 U.S.C. 1331 and 1338(a).
3. This cause of action also arises in part under the Connecticut Unfair Trade Practices Act
(CUTPA), C.G.S. 42-110a, et seq. Subject matter jurisdiction for the CUTPA claim is
conferred on this Court by 28 U.S.C. 1338(b).
4. Supplemental jurisdiction for the CUTPA claim is conferred on this Court by 28 U.S.C.
1367(a).
5. Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c), and 1400(b).
III. PARTIES
6. Plaintiff KX Technologies, LLC ("KXT") is a Delaware limited liability company
authorized to do business in the State of Connecticut, having a principal place of business at 55
Railroad Avenue, West Haven, Connecticut 06516.
7. Plaintiff KXT is informed and believes that defendant Dilmen LLC is a limited liability
company organized and existing under the laws of the state of Texas. It is assigned File Number
802093087 by the Texas Secretary of State, and has a principal place of business at 5700 Braxton
Drive, Suite 100, Houston, TX 77036. Exhibit A.
8. Plaintiff is informed and believes that defendant Dilmen LLC d/b/a Coral Premium Water
Filters, and doing business under the umbrella entity of Performancesupplies (at Amazon.com),
transacts business in this district; has repeatedly solicited business in this district through various
interactive websites, including amazon.com, ebay.com, and sears.com (Exhibit B); has
distributed, used, offered for sale, or sold the infringing devices alleged herein with the
reasonable expectation that such devices are to be used or consumed in this district; has
distributed, used, offered for sale or sold other goods with the reasonable expectation that such
goods are to be used or consumed in this district; and derives revenue for goods used or
consumed, or for services rendered, in this district.
9. Plaintiff KXT is informed and believes that defendant Huseyin Dilmen is an individual
having a principal place of business at 5700 Braxton Drive, Suite 100, Houston, TX 77036.
10. Plaintiff KXT is informed and believes that defendant Dilmen LLC and defendant
Huseyin Dilmen (collectively, "Defendants") distribute, offer for sale, and/or sell the infringing
devices alleged herein under the following business entities: Performancesupplies, Coral
Premium Water Filters, and Mirage Basics; with the reasonable expectation that such devices are
to be used or consumed in this district. Exhibits B & C.
11. Plaintiff KXT is informed and believes that defendant Huseyin Dilmen is the sole
operator and owner of Dilmen LLC d/b/a Coral Premium Water Filters.
12. Plaintiff is informed and believes that Huseyin Dilmen directs and controls the infringing
activities of the business entities Dilmen LLC, dilmenllc, Mirage Basics, Coral Premium Water
Filters, and Performancesupplies, the latter being an umbrella entity for Dilmen LLC. Exhibits B
& C.
13. Plaintiff KXT is informed and believes that defendant Huseyin Dilmen is the sole owner
of the United States Trademark Registration No. 4,984,472 for selling product in interstate
commerce under the mark CORAL PREMIUM WATER FILTERS, including water filters for
refrigerators. Exhibit D.
14. Plaintiff KXT is informed and believes that defendant Huseyin Dilmen is the sole owner
of the United States Trademark Application Serial No. 86/613,293 for selling water filters in
interstate commerce under the mark MIRAGE BASICS. Exhibit E.
IV. FACTUAL BACKGROUND
15. Plaintiff KXT is the assignee and rightful owner of the following United States Patents,
which were duly and legally issued by the United States Patent and Trademark Office: a) U.S.
Patent No. 8,673,146, issued on March 18, 2014, titled "PUSH FILTER WITH FLOATING
KEY LOCK," (the "'146 Patent"; Exhibit F); and b) U.S. Patent No. 8,137,551, issued on March
20, 2012, titled "PUSH FILTER WITH FLOATING KEY LOCK" (the "'551 Patent"; Exhibit G);
(collectively referred to herein as the "PUSH-PUSH Technology Patents").
16. Relevant independent claims of the '146 Patent include Claims 1 and 15. Claim 1 of the
'146 Patent is directed to a filter housing assembly:
1. A filter housing assembly comprising:
a filter housing for enclosing a filter media, said filter housing having a body
and a top portion for forming a fluid-tight seal with said body, said filter
housing top portion including:
an ingress port;
an egress port;
a filter key located on said top portion and having a top surface, longitudinal
sides, and lateral sides, each of said filter key longitudinal sides including
a plurality of spaced protrusions or fingers extending laterally from said
top surface, wherein said fingers include winged extensions having slanted
or angled faces for mating attachment to a filter base or manifold.
'146 Patent, Claim 1, Exhibit F.
17. Claim 15 of the '146 Patent is directed to a method for extracting a filter housing
assembly from a filter base:
15. A method for extracting a filter housing assembly from a filter base comprising:
applying an axial insertion force to said filter housing assembly already
connected to said filter base towards said filter base thereby inserting a
filter key on said filter housing assembly further into a slidable floating
lock of said filter base, said filter key having longitudinal sides with a
plurality of fingers or spaced protrusions on each of said longitudinal
sides;
releasing said slidable floating lock, such that said floating lock moves relative
to said filter key under a resilient retraction force;
aligning said plurality of fingers on each longitudinal side of said filter key
between fingers or drive keys on said floating lock; and
applying an axial extraction force to said filter housing assembly to remove
said filter housing assembly from said filter base.
'146 Patent, Claim 15, Exhibit F.
18. Relevant independent claims of the '551 Patent include Claims 1 and 49. Claim 1 of the
'551 Patent is directed to a filter housing:
1. A filter housing assembly comprising:
a filter housing for enclosing a filter media, said filter housing having a body
and a top portion for forming a fluid-tight seal with said body, said filter
housing top portion including:
an ingress port;
an egress port;
a filter key located on said top portion and having a top surface, longitudinal
sides, and lateral sides, said filter key including spaced protrusions or
fingers on said longitudinal sides of said filter key extending laterally from
said top surface, wherein said filter key includes a locking nub or tab for
attachment to said top portion.
'551 Patent, Claim 1, Exhibit G.
19. Claim 49 of the '551 Patent is directed to a method of attaching a filter housing to a filter
base:
49. A method for attaching a filter housing assembly to a filter base comprising:
inserting ingress and egress ports of said filter housing assembly into ingress
and egress stanchions of said filter base;
inserting a filter key of said filter housing assembly having lateral fingers with
winged extensions into a slidable floating lock having lateral fingers or
drive keys by using said filter key to shift said slidable floating lock
longitudinally, whereby said lateral fingers of said filter key transverse said
lateral fingers or drive keys of said floating lock; and
releasing said filter housing assembly so that resilient members in said filter
base apply an extraction force to said filter housing, moving said filter
housing assembly slightly in an axial extraction direction; and
providing a retraction force to said floating lock during said releasing to align
said floating lock fingers or drive keys with said filter key fingers, such that
extraction of said filter housing assembly is prohibited.
'551 Patent, Claim 49, Exhibit G.
20. On December 9, 2015, Defendants were notified by United States Certified Mail (No.
7009 2250 0002 0062 6793) that they were offering for sale and/or selling water filters that
infringed the PUSH-PUSH Technology Patents, and were requested by Plaintiff KXT to cease
and desist the infringing activities. Exhibit H.
21. Plaintiff KXT is the assignee and rightful owner of the following United States Patents,
which were duly and legally issued by the United States Patent and Trademark Office: a) U.S.
Patent No. D656,578, issued on March 27, 2012, titled "CASSETTE FILTER," (the "'578
Patent"; Exhibit I); b) U.S. Patent No. D656,579, issued on March 27, 2012, titled "CASSETTE
FILTER AND COVER PLATE" (the "579 Patent"; Exhibit J); c) U.S. Patent No. D656,580,
issued on March 27, 2012, titled "CASSETTE FILTER MANIFOLD" (the "580 Patent"; Exhibit
K) (the design patents collectively referred to herein as the "CASSETTE FILTER Design
Patents"); and d) U.S. Patent No. 9,061,225 issued on June 23, 2015, titled "REINFORCED
RECEIVER FOR CASSETTE FILTER LOCKING CLIP" (the "225 Patent"; Exhibit L); (the
design patents and the Reinforced Receiver utility patent collectively referred to herein as the
"CASSETTE FILTER Technology Patents").
22. Relevant independent claims of the '225 Patent include Claims 1 and 11. Claim 1 of the
'225 Patent is directed to a receiver for a cassette filter housing:
1. A receiver for a cassette filter housing having an upper housing surface the
receiver comprising:
an arrow shaped elongated member parallel with an upper surface of the
cassette, the elongated member having ends and including a base portion
attached to the upper housing surface the cross-section of which is a
substantially planer segment extending to the upper surface, and an upper
receiver portion having at least one cavaliered retaining surface; and
a first reinforcement member extending outward from the base portion adjacent
one of the ends of the elongated member and perpendicular to the
elongated member, and a second reinforcement member extending
outward from the base portion adjacent the opposite end of the elongated
member and perpendicular to the elongated member the reinforcement
members affixed to the base portion and the upper housing surface;
whereby the elongated member is engagable with a locking clip having at least
one foot engagable with the at least one retaining surface when the
receiver and locking clip are in the locked position and the reinforcement
member provides support for the receiver.
'225 Patent, Claim 1, Exhibit L.
23. Claim 11 of the '225 Patent is directed to a receiver for a cassette filter housing:
11. A receiver for a cassette filter housing having an upper housing surface the
receiver comprising:
a fixed, immobile elongated member parallel with an upper surface of the
cassette, the elongated member including a base portion attached to the
upper housing surface and an upper receiver portion having at least one
retaining surface, said base portion being substantially centered on the
elongated member and retains the elongated member in a fixed position;
and
at least one triangular reinforced end member integrally formed with the
elongated member and the upper housing surface;
whereby the elongated member is engagable with a slidably engaging
manifold locking clip having at least one foot engagable with the at least
one retaining surface when the receiver and locking clip are in the locked
position and the at least one triangular reinforced end member provides
support for the receiver.
'225 Patent, Claim 11, Exhibit L.
24. On November 11, 2015, Defendants were notified by United States Certified Mail (No.
7009 2250 0002 0062 6670) that they were offering for sale and/or selling water filters that
infringed the CASSETTE FILTER Technology Patents, and were requested by Plaintiff KXT to
cease and desist the infringing activities. Exhibit M.
25. On February 16, 2016, Defendant Huseyin Dilmen was further notified by email to
remove the infringing Coral Premium Water Filters from the Amazon.com website. Exhibit N.
V. CLAIMS FOR RELIEF
FIRST COUNT
Patent Infringement of U.S. Patent No. 8,673,146
26. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-25 inclusive.
27. Plaintiff KXT is informed and believes that Defendants have infringed Claims 1, 3, 6, and
7 of the '146 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or selling in
this district and elsewhere in the United States a filter housing assembly identified by the
invention disclosed and claimed in the '146 Patent. Such infringing device includes the
replacement filter by Coral Premium Water Filters for the Frigidaire PureSource ULTRAWF
filter cartridge and by Mirage Basics ("Defendants' ULTRAWF Replacement Cartridge").
Exhibits B & C.
28. Photographs of Defendants' ULTRAWF Replacement Cartridge and its packaging, and
photographs depicting the salient features of the filter key, are attached as Exhibit O.
29. Defendants' ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 3, 6, and 7 of the '146 Patent as shown in the annotated photos of Exhibit O,
including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having
longitudinal sides 18 and lateral sides 20 including a plurality of spaced
protrusions or fingers 22 extending from the top surface of the filter key,
where the fingers include winged extensions having slanted or angled faces
24;
c) the filter key being attached to the filter housing top portion by a snap fit,
friction fit, welding, or bonding;
d) the ingress port and said egress port being off axial center of the filter housing;
and
e) the spaced protrusions or fingers being integrally formed with the filter key.
30. Plaintiff KXT is informed and believes that Defendants have infringed Claim 15 of the
'146 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
extracting a filter housing assembly from a filter base identified by the method disclosed and
claimed.
31. Defendants' inducement is identified by the method of extracting the Defendants'
ULTRAWF Replacement Cartridge as delineated on the infringing device's packaging, which
embodies the method steps of Claim 15 of the '146 Patent, specifically:
a) applying an axial insertion force to the filter housing already connected to the filter base
towards the filter base; releasing the slidable floating lock; aligning the plurality of
fingers on the floating lock; and
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b) applying an axial extraction force to the filter housing assembly to remove the filter
housing assembly from the filter base ("Push the end of the old filter straight out until it
clicks (and releases)"; Ref.: Directions on Product Packaging, Exhibit O).
32. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of
Defendants through interactive websites on the Internet and through other means.
33. Plaintiff KXT has placed Defendants on notice of the '146 Patent and of the infringement.
34. Plaintiff KXT is informed and believes that Defendants knew of the '146 Patent, and
knew that their activities would lead to direct infringement of the filter housing assembly claims,
and inducing infringement of the method claim for extracting a filter housing assembly,
identified by the '146 Patent.
35. Plaintiff KXT is informed and believes that the infringement and inducement of
infringement of the '146 Patent by Defendants by making, using, offering for sale and selling said
infringing device, and by continuing to do so after having been placed on notice of the '146
Patent, has been repeated and willful with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
36. As a direct and proximate result of Defendants' acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
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37. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendants are preliminarily and permanently enjoined from their unlawful and willful
infringement of the '146 Patent, Plaintiff KXT will suffer irreparable harm.
SECOND COUNT
Patent Infringement of U.S. Patent No. 8,137,551
38. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-37 inclusive.
39. Plaintiff KXT is informed and believes that Defendants have infringed Claims 1, 2, 6, 7,
10, and 11of the '551 Patent under 35 U.S.C. 271(a) by making, using, offering for sale and/or
selling in this district and elsewhere in the United States a filter housing assembly identified by
the invention disclosed and claimed in the '551 Patent. Such infringing device includes
Defendants' ULTRAWF Replacement Cartridge. Exhibits B & C.
40. Defendants' ULTRAWF Replacement Cartridge embodies all of the limitations and
features of Claims 1, 2, 6, 7, 10, and 11 of the '551 Patent as shown in the attached, annotated
Exhibit O photos, including:
a) a filter housing 10 having an ingress port 12 and an egress port 14;
b) a filter key 16 located on the top portion of the filter housing, having longitudinal sides 18
and lateral sides 20 including a plurality of spaced protrusions or fingers 22 on the
longitudinal sides extending laterally from the top surface of the filter key, where the
filter key includes a locking nub or tab for attachment to the top portion 26;
c) the fingers including winged extensions having slanted or angled faces 24;
d) the filter key being removably attached to the top portion of the filter housing;
e) the filter key being attached to the filter housing top portion by a snap fit, friction fit,
welding, or bonding;
f) the ingress port and said egress port being off axial center of the filter housing; and
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g) the spaced protrusions or fingers being integrally formed with the filter key.
41. Plaintiff KXT is informed and believes that Defendants have infringed Claim 49 of the
'551 Patent under 35 U.S.C. 271(b) by actively inducing infringement of the method for
attaching a filter housing assembly to a filter base identified by the method disclosed and
claimed.
42. Defendants' inducement is identified by the method of attaching the Defendants'
ULTRAWF Replacement Cartridge as delineated on the infringing device's packaging, which
embodies the method steps of Claim 49 of the '551 Patent, specifically:
a) inserting ingress and egress ports of the filter housing assembly into the stanchions of the
filter base, inserting a filter key into a slidable floating lock of the filter base, releasing the
filter housing assembly so that resilient members in the filter base apply an extraction
force ("Push the new filter straight in until it clicks"); and
b) providing a retraction force to the floating lock during the releasing to align the floating
lock fingers or drive keys with the finger key fingers.
Ref.: Directions on Product Packaging, Exhibit O.
43. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of
Defendants through interactive websites on the Internet and through other means.
44. Plaintiff KXT has placed Defendants on notice of the '551 Patent and of the infringement.
45. Plaintiff KXT is informed and believes that Defendants knew of the '551 Patent, and
knew that their activities would lead to infringement of the filter housing assembly claims, and
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inducing infringement of the method claim for extracting a filter housing assembly, as identified
by the '551 Patent.
46. Plaintiff KXT is informed and believes that the infringement and inducement of
infringement of the '551 Patent by Defendants by making, using, offering for sale and selling said
infringing device, and by continuing to do so after having been placed on notice of the '551
Patent, has been repeated and willful with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
47. As a direct and proximate result of Defendants' acts of patent infringement and
inducement of infringement, Plaintiff KXT has been and continues to be injured, and has
sustained and will continue to sustain substantial damages in an amount not presently known.
48. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendants are preliminarily and permanently enjoined from their unlawful and willful
infringement of the '551 Patent, Plaintiff KXT will suffer irreparable harm.
THIRD COUNT
Patent Infringement of the CASSETTE FILTER Design Patents
49. Plaintiff KXT realleges and incorporates herein the allegations of paragraphs 1-48
inclusive.
50. Plaintiff KXT is informed and believes that Defendants have infringed the CASSETTE
FILTER Design Patents by making, using, distributing, offering for sale and/or selling in this
district and elsewhere in the United States a cassette filter that embodies the designs of U.S.
Patent Nos. D656,578, D656,579, and D656,580. Such infringing device includes Defendants'
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WF2CB Replacement Cassette Filter for Frigidaire ("Defendants' Replacement Cassette Filter").
Exhibits B &C.
51. Defendants' WF2CB Replacement Cassette Filter embodies all of the ornamental features
of CASSETTE FILTER Design Patents.
52. Plaintiff KXT is informed and believes that offers for sale and sales of Defendants'
WF2CB Replacement Cassette Filter have been widely and repeatedly made in the United States
by and on behalf of Defendants through interactive websites on the Internet and through other
means.
53. Plaintiff KXT has placed Defendants on notice of the CASSETTE FILTER Design
Patents and of the infringement. Exhibit M.
54. Plaintiff KXT is informed and believes that Defendants knew of the CASSETTE FILTER
Design Patents, and knew that their activities would lead to infringement of the ornamental
features as identified individually by the CASSETTE FILTER Design Patents.
55. Plaintiff KXT is informed and believes that the infringement of the CASSETTE FILTER
Design Patents by Defendants by distributing, offering for sale, and selling said infringing device,
and by continuing to do so after having been placed on notice of the CASSETTE FILTER Design
Patents, has been repeated and willful with conscious disregard for the rights of Plaintiff KXT,
and will continue unless enjoined by this Court.
56. As a direct and proximate result of Defendants' acts of patent infringement, Plaintiff KXT
has been and continues to be injured, and has sustained and will continue to sustain substantial
damages in an amount not presently known.
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57. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendants are preliminarily and permanently enjoined from their unlawful and willful
infringement of the CASSETTE FILTER Design Patents, Plaintiff KXT will suffer irreparable
harm.
FOURTH COUNT
Patent Infringement of U.S. Patent No. 9,061,225
58. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-57 inclusive.
59. Plaintiff KXT is informed and believes that Defendants have infringed Claims 1-4 and
11-16 of the '225 Patent under 35 U.S.C. 271(a) by making, using, distributing, offering for
sale, and/or selling in this district and elsewhere in the United States a cassette filter identified by
the invention disclosed and claimed in the '225 Patent. Such infringing device includes
Defendants' Replacement Cassette Filter. Exhibits B & C.
60. Defendants' Replacement Cassette Filter embodies all of the limitations and features of
Claims 1-4 and 11-16 of the '225 Patent as shown in the attached Exhibit P photos, including:
a) a fixed, immobile elongated member parallel 40 with an upper surface of the cassette 42,
the elongated member 40 including a base portion 44 attached to the upper housing
surface 42 and an upper receiver portion 46 having at least one retaining surface 48, said
base portion being substantially centered on the elongated member and retains the
elongated member in a fixed position; and
b) at least one triangular reinforced end member 50 integrally formed with the elongated
member and the upper housing surface;
c) the first and second reinforcement members being affixed to the upper receiver portion;
d) each end of the elongated member includes a pair of reinforcement members 52a,b
extending in opposite directions from each other and substantially perpendicular to the
elongated member length;
e) the receiver is made of polypropylene;
f) the triangular reinforced member 50 includes stepped portions 52a,b; and
g) the triangular reinforced member is solid.
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61. Plaintiff KXT is informed and believes that offers for sale and sales of said infringing
device have been widely and repeatedly made in the United States by and on behalf of
Defendants through interactive websites on the Internet and through other means.
62. Plaintiff KXT has placed Defendants on notice of the '225 Patent and of the infringement.
63. Plaintiff KXT is informed and believes that Defendants knew of the '225 Patent, and
knew that their activities would lead to infringement of the receiver for a cassette filter housing,
as identified by the '225 Patent.
64. Plaintiff KXT is informed and believes that the infringement of the '225 Patent by
Defendants by making, using, offering for sale and selling said infringing device, and by
continuing to do so after having been placed on notice of the '225 Patent, has been repeated and
willful with conscious disregard for the rights of Plaintiff KXT, and will continue unless
enjoined by this Court.
65. As a direct and proximate result of Defendants' acts of patent infringement, Plaintiff KXT
has been and continues to be injured, and has sustained and will continue to sustain substantial
damages in an amount not presently known.
66. Plaintiff KXT has no adequate remedy of law against these acts of patent infringement.
Unless Defendants are preliminarily and permanently enjoined from their unlawful and willful
infringement of the '225 Patent, Plaintiff KXT will suffer irreparable harm.
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FIFTH COUNT
VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT UNDER
CONNECTICUT GENERAL STATUTES 42-110a, ET SEQ.
67. Plaintiff realleges and incorporates herein the allegations of paragraphs 1-66 inclusive.
68. This is an action for unfair methods of competition, and unfair and deceptive acts and
practices in the conduct of the Defendants' trade in violation of the Connecticut Unfair Trade
Practices Act ("CUTPA"), pursuant to C.G.S. 42-11Oa, et seq.
69. This Court has pendent jurisdiction under 28 U.S.C. 1367(a). Venue is proper under 28
U.S.C. 1391.
70. Plaintiff KXT is informed and believes that upon receiving notice of infringement
Defendants' transferred offers for sale of the aforementioned infringing products to other
websites, and offered for sale the aforementioned infringing products under other brand names in
a deliberate attempt to conceal Defendants' on-going infringing activities, and to obfuscate
Plaintiff's attempts to enforce its intellectual property.
71. By committing the acts herein alleged, Defendants have engaged in unfair methods of
competition and unfair and deceptive acts and practice in the conduct of trade within the State of
Connecticut in violation of C.G.S. 42-110a, et seq., causing confusion to consumers in the
trade, damage and loss profits to Plaintiff.
72. Defendants knew or should have known that the aforementioned acts are in violation of
C.G.S. 42-110a, et seq.
73. Plaintiff KXT has suffered an ascertainable loss of money and property as a result of
Defendants' acts or practices in this district prohibited by C.G.S. 42-110a, et seq.
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6. That Defendants account for (a) all gains, profits, and advantages derived by Defendants
by said trade practices and unfair competition, and (b) all gains, profits, and advantages derived
by Defendants by their infringement of Plaintiffs intellectual property.
7. That Plaintiff granted such other and further relief as the Court deems just and proper.
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Respectfully submitted,
KX TECHNOLOGIES, LLC
by:
KXIN905_Complaint.doc
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT F
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therein; the floating lock having a bottom surface, a top surface, and longitudinal and lateral sides, and seated within the
non-floating port formed recess, the floating lock including:
at least one drive key on the longitudinal side extending
laterally inwards at the bottom surface for slidably receiving
an angled boss or winged extension from a complementary
mating filter housing assembly, the at least one drive key
including an angled portion exposed towards the bottom surface, and an edge or wedge on each of the drive key bottom for
releasably contacting with a portion of the complementary
mating filter housing assembly boss or winged extension; a
position key centered about lateral sides of the floating lock,
and located above the at least one drive key to provide a
physical stop during insertion of the complementary mating
filter housing assembly; at least one resilient member in contact with the floating lock for applying a longitudinal retraction force in a direction that tends to push or pull the floating
lock back to an original position; a rear plate for slidably
securing the floating lock within the non-floating port; shutoff
plugs in each of the stanchions forterminating fluid flow from
the ingress and egress ports when the complementary mating
filter housing assembly is removed from the filter base; a
resilient member within each of the stanchions for applying
an axial extraction force to the complementary mating filter
housing assembly, and simultaneously move the shutoff
plugs into position to cease fluid flow when the complementary mating filter housing assembly is extracted.
In a seventh aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the
combination comprising: a filter base having an ingress port
and an egress port on a base platform; a slidable floating lock
in slidable contact of the filter base, the floating lock having a
plurality of drive keys or lateral extensions separated by gaps;
a resilient member in contact with the floating lock, providing
a retraction force for the floating lock; and a filter housing
assembly including: a filter key having a plurality of lateral
extensions separated by gaps, such that when the filter housing assembly is inserted into the filter base, the fingers of the
filter key slidably contact the lateral extensions of the floating
lock to shift the floating lock relative to the base platform,
allowing the fingers on the filter key to traverse between the
lateral extensions on the floating lock, and upon retraction of
the floating lock by the resilient member, the fingers on the
filter key align with the lateral extensions on the floating lock
to prevent extraction of the filter housing assembly.
The floating lock includes a bottom surface, a top surface,
and longitudinal and lateral sides, and wherein the lateral
extensions include drive keys on the longitudinal sides
extending laterally inwards at the bottom surface for slidably
receiving the filter key, each of the drive keys including an
angled portion exposed towards the bottom surface, and an
edge or wedge on each of the drive key bottom for releasably
contacting with a portion of the filter key; and a position key
centered about the floating lock, and located above the drive
keys to provide a physical stop during insertion of the filter
housing assembly.
The combination may also include a rear plate for securing
the floating lock within the filter base; shutoff plugs in each of
the stanchions for terminating fluid flow from the ingress and
egress ports when the filter housing assembly is extracted
from the filter base; and a resilient member within each of the
stanchions for applying an axial extraction force to the filter
housing assembly, and simultaneously moving the shutoff
plugs into position to cease fluid flow when the filter housing
assembly is extracted.
In an eight aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the
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manly used in the art for sealing adjoining components, typically adjoining plastic components. As discussed in further
detail below, filter key 5 is connected to filter manifold 3.
Filter key 5 may be formed as one piece with filter manifold
3, or may be securely attached by other methods, such as
bonding, welding, press fit, friction fit, or the like. Filter key
5 may also be removably attached for replacement by an end
user. Filter manifold 3 is attached to filter head 2. Filter
manifold 2 may be removably attached as well for replacement by an end user. Filter media 8 is located in filter housing
1. Each end of filter media 8 is secured by a cap that facilitates
the direction of the fluid being treated by the filter. At one end,
filter media 8 is secured by a closed end cap 7, and at the other
end by open end cap 6. Filter media 8 may be any filter media
known in the art, and preferably, is a carbon block filter. It is
typically shaped in a similar fashion as filter housing 1, which
in the preferred embodiment is cylindrical. Open end cap 6 is
designed to interface and be in fluid communication with
filter head 2. Filter housing assembly 200 is a finished assembly including filter housing 1, which encompasses filter
media 8 by closed end cap 7 at one end, and open end cap 6 at
the other. Generally, a-ring seals, such as a-ring seal 9, are
used to prevent water leakage where different components are
expected to mate. Filter manifold 3 and filter key 5 are joined
with filter head 2, and secured to filter housing 1 to form the
assembled filter housing apparatus 200. These components
may be integral, permanently secured, or removably attached
to one another, and to filter head 2. FIG. lB is a side plan view
of the preferred embodiment of the filter assembly of the
present invention.
FIG. 2A is a perspective view of filter key 5. FIG. 2B is a
lateral side view of filter key 5. As previously noted, the
bottom of filter key 5 is attached to filter manifold 3 by any
number of fastening schemes, or may be integrally formed
with filter manifold 3. FIG. 2C depicts a groove 51 that is
preferably shaped to receive a complementary protrusion on
filter manifold 3, and is preferably shaped to receive a dovetail protrusion; however, other connecting, complementary
shapes are not excluded. The connection of filter key 5 with
filter manifold 3 may be bonded, sonic welded, press fitted,
friction fitted, or the like. As depicted in the illustrative
embodiment, groove 51 is shaped to accept a snap feature for
a press or snap fit located on filter manifold 3. In this manner
filter key 5 may be removably attached to filter manifold 3.
Similarly, filter manifold 3 may be designed to be removably
attached to filter head 2. Thus, the design has more flexibility
to introduce and accommodate different key configurations,
which can be used to designate specific filter types, and purposely reject other filter types.
FIG. 4A depicts a perspective view of the one embodiment
of filter manifold 300. Port 310 is shown off center of filter
manifold 300. FIG. 4A depicts the filter manifold without
extension support members. Preferably, port 310 is an outlet
port; however, the present invention is not limited to a specific
ingress and egress location, and may have these ports interchanged. When port 310 is used as an egress or outlet port,
filter manifold 300 takes fluid from filter media 8 through the
center port of open cap 6, and directs fluid flow radially
outwards from the axial center to port 310. In this embodiment, the ingress port is located on filter head 2. By locating
the ingress and egress ports off axis, filter housing assembly
200 has a more robust design, with enhanced structural integrity for mounting to the filter base, and for remaining fixably
in place during attachment. Referring to FIGS. 4A-4C, in a
preferred attachment scheme for filter key 5, a protrusion 32
or 320 is formed on or nearthe center line of filter manifold 3
or 300. Protrusion 32 or 320 is preferably a rectangular
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floating port 11 will also hold floating lock 1200 and floating
lock 1212 of FIG. 8. For simplicity, reference is made chiefly
to the interaction of non-floating port 11 with floating lock 12,
although the applicability of non-floating port 11 includes
usage with floating lock 1200and1212 as well. Non-floating
port 11 includes a protruding encasement 1102, larger than
floating lock 12, and made to enclose floating lock 12 therein.
Encasement 1102 prevents over-travel of floating lock 12, and
protects it when installed from extraneous, unintended movement. FIG. 9B is a top plan view of non-floating port 11.
Stanchions llOla,b are located on opposite sides of encasement 1102. Ports 1103 represent the ingress and egress ports
for the fluid. Shut-off stanchions llOla,b include shutoff
plugs 14, which act as valve seals to stop fluid flow when the
filter cartridge is being removed. Shut-off stanchions llOla,b
are preferably cylindrical in shape, containing spring activated, a-ring sealed plugs for sealing the ingress and egress
lines during filter cartridge removal. In a preferred embodiment, rear plate 13 is snap fitted into non-floating port 11. In
order to accommodate this, snap fittings 1105 are shown on
non-floating port 11 that receive a corresponding fitting 135
on rear plate 13.
Referring to FIG. 1, floating lock 12 is supported by nonfloating port 11 and rear plate 13. FIG. lOA is a top plan view
of one embodiment of rear plate 13 of the present invention.
FIG. lOB depicts a bottom perspective view ofrear plate 13.
Rear plate 13 secures floating lock 12 within a support structure in non-floating port 11. Rear plate 13 is preferably
attached by snap fit to non-floating port 11, although other
attachment schemes known in the art may be easily
employed, such as bonding, welding, and assorted mechanical fasteners. Rear plate 13 is formed with extensions 132 on
each end, and shaped gaps 133 therebetween. Gaps 133 are
shaped to go around shut-off stanchions llOla,b of nonfloating port 11. In this embodiment, rear plate 13 includes a
center aperture 131 that allows for longitudinal movement of
floating lock 12. Floating lock 12 may include an extension
member opposite the face configured with fingers and gaps, in
order to permit resilient components, such as helical or torsion springs to act upon it. FIGS. 3C and 3E are side views of
the floating lock showing extension member 128. FIG. 3B is
a perspective view of the floating lock 12 with extension
member 128. FIG. SE depicts floating lock 1212 with extension member 1280. In these embodiments, the extension
member is acted upon by resilient devices held by the rear
plate.
FIG. lOC is a top plan view of another embodiment of the
rear plate 1300 of the present invention. In this embodiment,
the topside of rear plate 1300 includes a domed, slotted cover
1302 over the center aperture. Cover 1302 is formed to encase
springs or other resilient members about the extension member 128 extending from floating lock 12. Dome 1302 includes
a slot 1304 that is made to receive the extension member 128
from floating lock 12. Slot 1304 helps retain linear movement
offloating lock 12 inside dome 1302. In this embodiment, two
complementary resilient members, such as springs, would
reside on each side of the extension member 128 of floating
lock 12. One resilient member preferably applies force on the
floating lock extension member in one direction, while the
other resilient member applies force to the floating lock
extension member in the opposite direction. In this manner,
no matter which way floating lock 12 is moved or shifted, a
retraction force presents itself to return floating lock 12 to its
original, centered position.
At all times during insertion, the filter housing assembly is
under extraction forces that tend to push the housing out of the
filter base. These extraction forces result from resilient mem-
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EXHIBIT G
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therein; the floating lock having a bottom surface, a top surface, and longitudinal and lateral sides, and seated within the
non-floating port formed recess, the floating lock including:
at least one drive key on the longitudinal side extending
laterally inwards at the bottom surface for slidably receiving
an angled boss or winged extension from a complementary
mating filter housing assembly, the at least one drive key
including an angled portion exposed towards the bottom surface, and an edge or wedge on each of the drive key bottom for
releasably contacting with a portion of the complementary
mating filter housing assembly boss or winged extension; a
position key centered about lateral sides of the floating lock,
and located above the at least one drive key to provide a
physical stop during insertion of the complementary mating
filter housing assembly; at least one resilient member in contact with the floating lock for applying a longitudinal retraction force in a direction that tends to push or pull the floating
lock back to an original position; a rear plate for slidably
securing the floating lock within the non-floating port; shutoff
plugs in each of the stanchions forterminating fluid flow from
the ingress and egress ports when the complementary mating
filter housing assembly is removed from the filter base; a
resilient member within each of the stanchions for applying
an axial extraction force to the complementary mating filter
housing assembly, and simultaneously move the shutoff
plugs into position to cease fluid flow when the complementary mating filter housing assembly is extracted.
In a seventh aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the
combination comprising: a filter base having an ingress port
and an egress port on a base platform; a slidable floating lock
in slidable contact of the filter base, the floating lock having a
plurality of drive keys or lateral extensions separated by gaps;
a resilient member in contact with the floating lock, providing
a retraction force for the floating lock; and a filter housing
assembly including: a filter key having a plurality of lateral
extensions separated by gaps, such that when the filter housing assembly is inserted into the filter base, the fingers of the
filter key slidably contact the lateral extensions of the floating
lock to shift the floating lock relative to the base platform,
allowing the fingers on the filter key to traverse between the
lateral extensions on the floating lock, and upon retraction of
the floating lock by the resilient member, the fingers on the
filter key align with the lateral extensions on the floating lock
to prevent extraction of the filter housing assembly.
The floating lock includes a bottom surface, a top surface,
and longitudinal and lateral sides, and wherein the lateral
extensions include drive keys on the longitudinal sides
extending laterally inwards at the bottom surface for slidably
receiving the filter key, each of the drive keys including an
angled portion exposed towards the bottom surface, and an
edge or wedge on each of the drive key bottom for releasably
contacting with a portion of the filter key; and a position key
centered about the floating lock, and located above the drive
keys to provide a physical stop during insertion of the filter
housing assembly.
The combination may also include a rear plate for securing
the floating lock within the filter base; shutoff plugs in each of
the stanchions for terminating fluid flow from the ingress and
egress ports when the filter housing assembly is extracted
from the filter base; and a resilient member within each of the
stanchions for applying an axial extraction force to the filter
housing assembly, and simultaneously moving the shutoff
plugs into position to cease fluid flow when the filter housing
assembly is extracted.
In an eight aspect, the present invention is directed to a
filter base in combination with a filter housing assembly, the
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manly used in the art for sealing adjoining components, typically adjoining plastic components. As discussed in further
detail below, filter key 5 is connected to filter manifold 3.
Filter key 5 may be formed as one piece with filter manifold
3, or may be securely attached by other methods, such as
bonding, welding, press fit, friction fit, or the like. Filter key
5 may also be removably attached for replacement by an end
user. Filter manifold 3 is attached to filter head 2. Filter
manifold 2 may be removably attached as well for replacement by an end user. Filter media 8 is located in filter housing
1. Each end of filter media 8 is secured by a cap that facilitates
the direction of the fluid being treated by the filter. At one end,
filter media 8 is secured by a closed end cap 7, and at the other
end by open end cap 6. Filter media 8 may be any filter media
known in the art, and preferably, is a carbon block filter. It is
typically shaped in a similar fashion as filter housing 1, which
in the preferred embodiment is cylindrical. Open end cap 6 is
designed to interface and be in fluid communication with
filter head 2. Filter housing assembly 200 is a finished assembly including filter housing 1, which encompasses filter
media 8 by closed end cap 7 at one end, and open end cap 6 at
the other. Generally, a-ring seals, such as a-ring seal 9, are
used to prevent water leakage where different components are
expected to mate. Filter manifold 3 and filter key 5 are joined
with filter head 2, and secured to filter housing 1 to form the
assembled filter housing apparatus 200. These components
may be integral, permanently secured, or removably attached
to one another, and to filter head 2. FIG. lB is a side plan view
of the preferred embodiment of the filter assembly of the
present invention.
FIG. 2A is a perspective view of filter key 5. FIG. 2B is a
lateral side view of filter key 5. As previously noted, the
bottom of filter key 5 is attached to filter manifold 3 by any
number of fastening schemes, or may be integrally formed
with filter manifold 3. FIG. 2C depicts a groove 51 that is
preferably shaped to receive a complementary protrusion on
filter manifold 3, and is preferably shaped to receive a dovetail protrusion; however, other connecting, complementary
shapes are not excluded. The connection of filter key 5 with
filter manifold 3 may be bonded, sonic welded, press fitted,
friction fitted, or the like. As depicted in the illustrative
embodiment, groove 51 is shaped to accept a snap feature for
a press or snap fit located on filter manifold 3. In this manner
filter key 5 may be removably attached to filter manifold 3.
Similarly, filter manifold 3 may be designed to be removably
attached to filter head 2. Thus, the design has more flexibility
to introduce and accommodate different key configurations,
which can be used to designate specific filter types, and purposely reject other filter types.
FIG. 4A depicts a perspective view of the one embodiment
of filter manifold 300. Port 310 is shown off center of filter
manifold 300. FIG. 4A depicts the filter manifold without
extension support members. Preferably, port 310 is an outlet
port; however, the present invention is not limited to a specific
ingress and egress location, and may have these ports interchanged. When port 310 is used as an egress or outlet port,
filter manifold 300 takes fluid from filter media 8 through the
center port of open cap 6, and directs fluid flow radially
outwards from the axial center to port 310. In this embodiment, the ingress port is located on filter head 2. By locating
the ingress and egress ports off axis, filter housing assembly
200 has a more robust design, with enhanced structural integrity for mounting to the filter base, and for remaining fixably
in place during attachment. Referring to FIGS. 4A-4C, in a
preferred attachment scheme for filter key 5, a protrusion 32
or 320 is formed on or nearthe center line of filter manifold 3
or 300. Protrusion 32 or 320 is preferably a rectangular
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floating port 11 will also hold floating lock 1200 and floating
lock 1212 of FIG. 8. For simplicity, reference is made chiefly
to the interaction of non-floating port 11 with floating lock 12,
although the applicability of non-floating port 11 includes
usage with floating lock 1200and1212 as well. Non-floating
port 11 includes a protruding encasement 1102, larger than
floating lock 12, and made to enclose floating lock 12 therein.
Encasement 1102 prevents over-travel of floating lock 12, and
protects it when installed from extraneous, unintended movement. FIG. 9B is a top plan view of non-floating port 11.
Stanchions llOla,b are located on opposite sides of encasement 1102. Ports 1103 represent the ingress and egress ports
for the fluid. Shut-off stanchions llOla,b include shutoff
plugs 14, which act as valve seals to stop fluid flow when the
filter cartridge is being removed. Shut-off stanchions llOla,b
are preferably cylindrical in shape, containing spring activated, a-ring sealed plugs for sealing the ingress and egress
lines during filter cartridge removal. In a preferred embodiment, rear plate 13 is snap fitted into non-floating port 11. In
order to accommodate this, snap fittings 1105 are shown on
non-floating port 11 that receive a corresponding fitting 135
on rear plate 13.
Referring to FIG. 1, floating lock 12 is supported by nonfloating port 11 and rear plate 13. FIG. lOA is a top plan view
of one embodiment of rear plate 13 of the present invention.
FIG. lOB depicts a bottom perspective view ofrear plate 13.
Rear plate 13 secures floating lock 12 within a support structure in non-floating port 11. Rear plate 13 is preferably
attached by snap fit to non-floating port 11, although other
attachment schemes known in the art may be easily
employed, such as bonding, welding, and assorted mechanical fasteners. Rear plate 13 is formed with extensions 132 on
each end, and shaped gaps 133 therebetween. Gaps 133 are
shaped to go around shut-off stanchions llOla,b of nonfloating port 11. In this embodiment, rear plate 13 includes a
center aperture 131 that allows for longitudinal movement of
floating lock 12. Floating lock 12 may include an extension
member opposite the face configured with fingers and gaps, in
order to permit resilient components, such as helical or torsion springs to act upon it. FIGS. 3C and 3E are side views of
the floating lock showing extension member 128. FIG. 3B is
a perspective view of the floating lock 12 with extension
member 128. FIG. SE depicts floating lock 1212 with extension member 1280. In these embodiments, the extension
member is acted upon by resilient devices held by the rear
plate.
FIG. lOC is a top plan view of another embodiment of the
rear plate 1300 of the present invention. In this embodiment,
the topside of rear plate 1300 includes a domed, slotted cover
1302 over the center aperture. Cover 1302 is formed to encase
springs or other resilient members about the extension member 128 extending from floating lock 12. Dome 1302 includes
a slot 1304 that is made to receive the extension member 128
from floating lock 12. Slot 1304 helps retain linear movement
offloating lock 12 inside dome 1302. In this embodiment, two
complementary resilient members, such as springs, would
reside on each side of the extension member 128 of floating
lock 12. One resilient member preferably applies force on the
floating lock extension member in one direction, while the
other resilient member applies force to the floating lock
extension member in the opposite direction. In this manner,
no matter which way floating lock 12 is moved or shifted, a
retraction force presents itself to return floating lock 12 to its
original, centered position.
At all times during insertion, the filter housing assembly is
under extraction forces that tend to push the housing out of the
filter base. These extraction forces result from resilient mem-
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surface, said filter key lateral support members having a separation approximately equal to said filter key width, said filter
key location boss and said filter key lateral support members
forming a structural support with exposed surfaces for attaching said filter key to said filter head.
23. The filter housing assembly of claim 22 wherein said
filter key location boss includes an aperture for receiving a
locking nub or tab from said filter key.
24. The filter housing assembly of claim 15 wherein said
filter key second attachment structure includes a complementary groove or slot on said filter key bottom to attach with said
axially extending protrusion of said filter manifold.
25. The filter housing assembly of claim 15 wherein said
filter manifold includes an ingress or egress port located off
axial center of said filter housing.
26. The filter housing assembly of claim 15 wherein said
filter manifold first attachment structure includes a groove or
slot to receive and attach a structural member from said filter
key bottom.
27. The filter housing assembly of claim 26 wherein said
filter key second attachment structure includes a complementary axially extending protrusion on said filter key bottom to
mate with said groove or slot of said filter manifold.
28. The filter housing assembly of claim 15 wherein said
first attachment structure includes an axially extending protrusion having a dovetail shape.
29. The filter housing assembly of claim 15 wherein said
filter manifold includes radially extending arms about said
base portion, providing structural support for a shroud.
30. The filter housing assembly of claim 15 including a
boss extending in an axial direction above said top surface of
said filter key, said boss having an angled face of predetermined width ramping upwards from said filter key top surface
and lateral segments or wings extending beyond said boss
width.
31. A filter base for releasably connecting to a complementary mating filter housing assembly comprising:
a base platform having fluid ingress and egress ports; and
a floating lock in sliding communication with said base
platform, having a bottom surface, a top surface, and
longitudinal and lateral sides, said floating lock including:
spaced protrusions, drive keys, or fingers on said longitudinal sides extending laterally inwards, including at
least one shaped protrusion, finger, or drive key for
slidably contacting said complementary mating filter
housing assembly, said at least one shaped protrusion,
finger, or drive key including an angled face exposed
towards the bottom surface, and an edge or wedge
opposite said angled face for releasably securing said
complementary mating filter housing assembly.
32. The filter base of claim 31 wherein said floating lock
includes a position stop centered about said lateral sides, and
located above said at least one drive key to provide a physical
stop during insertion of said complementary mating filter key.
33. The filter base of claim 32 wherein said position key
includes a track structure longitudinally across said floating
lock.
34. The filter base of claim 31 including an enclosure for
receiving said floating lock, said enclosure allowing said
floating lock to slidably move therein.
35. The filter base of claim 31 including an ingress stanchion in fluid communication with said filter base ingress port
and, when connected to said complementary mating filter
housing assembly, in fluid communication with an ingress
port from said complementary mating filter housing assembly, and an egress stanchion in fluid communication with said
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filter base egress port, and when connected to said complementary mating filter housing assembly, in fluid communication with an egress port from said complementary mating
filter housing assembly.
36. The filter base of claim 35 wherein said ingress stanchion includes a shutoff plug to block fluid flow from said
ingress port during extraction of said filter housing assembly,
said shutoff plug in contact with a resilient member to apply
axial or vertical force to said shutoff plug.
37. The filter base of claim 35 wherein said egress stanchion includes a shutoff plug to block fluid flow from said
egress port during extraction of said filter housing assembly,
said shutoff plug in contact with a resilient member to apply
axial or vertical force to said shutoff plug.
38. The filter base of claim 31 including a rear plate
attached to said base platform for at least partially housing
said floating lock.
39. The filter base of claim 31 including at least one resilient member in contact with said floating lock to provide a
retraction force when said floating lock is acted upon by said
filter housing assembly during insertion or extraction of said
filter housing assembly.
40. A filter base for releasably receiving a complementary
mating filter housing assembly comprising:
a base platform having a top surface;
a port for fluid ingress;
a port for fluid egress;
an upper ingress stanchion in fluid communication with
said ingress port, said upper ingress stanchion extending
upwards from said base platform top surface, said upper
ingress stanchion including a first shutoff plug and a
resilient member to apply axial or vertical force to said
first shutoff plug to block fluid flow from said ingress
port during extraction of said filter housing assembly;
an upper egress stanchion in fluid communication with said
egress port, said upper egress stanchion extending
upwards from said base platform top surface, said upper
egress stanchion including a second shutoff plug and a
resilient member to apply axial or vertical force to said
second shutoff plug to block fluid flow from said egress
port during extraction of said filter housing assembly;
a lower ingress stanchion in fluid communication with said
upper ingress stanchion and said ingress port, said lower
ingress stanchion extending axially downwards from
said base platform for receiving an ingress port from said
filter housing assembly;
a lower egress stanchion in fluid communication with said
upper egress stanchion and said egress port, said lower
egress stanchion extending axially downwards from said
base platform for receiving an egress port from said filter
housing assembly;
an enclosure for at least partially receiving a floating lock,
said enclosure allowing said floating lock to slidably
move therein;
said floating lock having longitudinal sides and lateral
sides, including:
spaced fingers, drive keys, or protrusions located on at
least one of said longitudinal sides for releasably mating with fingers of a complementary mating filter key,
at least one of said fingers, drive keys, or protrusions
located on an inside face of said floating lock longitudinal side, and having an angled surface for slidably
contacting fingers on said complementary mating filter housing assembly, such that when said fingers of
said complementary mating filter housing assembly
are inserted within said floating lock, said angled
surface slidably contacts said filter housing assembly
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EXHIBIT H
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