Cambria Company v. Stylen Quaza - Complaint

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 1 of 29
IN THE UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
CAMBRIA COMPANY LLC,
Plaintiff,
v.
Case No. 16-cv-2402
STYLEN QUAZA LLC, VICOSTONE

JOINT STOCK COMPANY, BUILDING
PLASTICS INC., SOLIDTOPS LLC,
DORADO SOAPSTONE LLC, AND
PENTAL GRANITE AND MARBLE INC.
DEMAND FOR JURY TRIAL
Defendants.
COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Cambria Company LLC (Cambria) files this Complaint and demand for jury
trial seeking relief for patent infringement by Defendants Stylen Quaza LLC DBA Vicostone
USA and Vicostone Joint Stock Company (referred to collectively herein as Vicostone),
Building Plastics Inc. (BPI), Solidtops LLC (Solidtops), Dorado Soapstone LLC (Dorado),
and Pental Granite and Marble Inc. (Pental) (collectively, the Defendants). Cambria states
and alleges the following:
NATURE OF THE ACTION
1.
This is an action for infringement of United States Design Patent Nos. D712,666
(the 666 patent), D712,670 (the 670 patent), D751,298 (the 298 patent), D712,161 (the
161 patent), and D737,058 (the 058 patent) (collectively, the Asserted Patents) under
35 U.S.C. 1 et seq. On information and belief, Defendants Vicostone, BPI, Solidtops,
Dorado, and Pental make, use, sell and/or offer to sell or import into the United States certain
products (referred to herein as the Accused Products) that embody Cambrias patented designs.
THE PARTIES
2.
Plaintiff Cambria is a limited liability company organized under the laws of
Minnesota with its principal place of business at 805 Enterprise Drive East, Suite H, Belle
Plaine, Minnesota, 56011.
3.
Cambria owns all rights and title in and to each of the Asserted Patents, including
the right to sue for all infringement thereof, including past infringement.
4.
On information and belief, Defendant Stylen Quaza LLC, otherwise known as
Vicostone USA is a limited liability company organized under the laws of Texas with its
principal place of business at 11620 Goodnight Ln. Suite 100, Dallas, Texas 75229.
5.
On information and belief, Defendant Stylen Quaza LLC develops, manufactures,
imports, sells for importation, and/or sells after importation into the United States quartz slabs
and portions thereof under the trade name Vicostone quartz, together with Defendant
Vicostone Joint Stock Company.
6.
On information and belief, Defendant Vicostone Joint Stock Company is a
corporation organized under the laws of Vietnam with its principal place of business at Hoa Lac
Hi-tech Park, Thachthat, Hanoi, Vietnam.
7.
On information and belief Defendant Vicostone Joint Stock Company develops,
manufactures, imports, sells for importation, and/or sells after importation into the United States
quartz slabs and portions thereof under the trade name Vicostone quartz, together with
Defendant Stylen Quaza LLC.
8.
On information and belief, Defendant Building Plastics Inc. is a corporation
organized under the laws of Tennessee with its principal place of business at 3263 Sharpe Ave.,
Memphis, Tennessee 38111.
9.
On information and belief, Defendant BPI develops, manufactures, imports, sells
for importation, and/or sells after importation into the United States quartz slabs and portions
thereof under the trade name Prestige Stone quartz. On information and belief, BPIs quartz
slabs and portions thereof are manufactured in China by Fasa Industrial Corporation, Ltd. and
Foshan FASA Building Material Co., Ltd. (referred to collectively herein as Fasa).
10.
On information and belief, Defendant Solidtops is a limited liability company
organized under the laws of Maryland with its principal place of business at 27964 Oxford Rd.,
Oxford, Maryland 21654.
11.
On information and belief, Defendant Solidtops develops, manufactures, imports,
sells for importation, and/or sells after importation into the United States quartz slabs and
portions thereof under the trade name Quartz Source.
12.
On information and belief, Defendant Dorado is a limited liability company
organized under the laws of Colorado with its principal place of business at 940 S. Jason St. Unit
9, Denver, Colorado, 80223.
13.
On information and belief, Defendant Dorado develops, manufactures, imports,
portions thereof under the trade name NUSTONE quartz.
14.
On information and belief, Defendant Pental is a corporation organized under the
laws of Washington with its principal place of business at 713 South Fidalgo St., Seattle,
Washington 98108.
15.
On information and belief, Defendant Pental develops, manufactures, imports,
portions thereof under the trade name Pental Quartz.
JURISDICTION AND VENUE

16.
This action for design patent infringement arises under the Patent Laws of the
United States, specifically 35 U.S.C. 271, 281-285.

17.
This civil action asserts claims arising under the Patent Laws of the United States,
35 U.S.C. 1 et seq. This Court has subject matter jurisdiction under 28 U.S.C. 1331 and
1338(a).
18.
This Court has personal jurisdiction over Defendants Vicostone, BPI, Solidtops,
Dorado, and Pental for at least the following reasons:

a.
Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have
established minimum contacts with this forum such that the exercise of jurisdiction over them
would not offend traditional notions of fair play and substantial justice;
b.
Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have done and
continue to do business in Minnesota, including but not limited to sale of the Accused Products.
On information and belief, Defendants Vicostone, BPI, Solidtops, Dorado, and Pental sell the
Accused Products in the State of Minnesota through company-owned and independent
Minnesota distributors;
c.
On information and belief, Defendants Vicostone, BPI, Solidtops, Dorado,
and Pental, or entities operating on behalf of Vicostone, BPI, Solidtops, Dorado, and Pental, have
entered into contracts with one or more Minnesota residentsspecifically, distributors and
dealersto supply products or services within the State of Minnesota; and
d.
Defendants Vicostone, BPI, Solidtops, Dorado, and Pental maintain
warranty services, which are referenced on their websites, on Accused Products within the State
of Minnesota.
e.
As such, upon information and belief, Defendants Vicostone, BPI,
Solidtops, Dorado, and Pental have intended to benefit by doing business in the State of
Minnesota, and personal jurisdiction over them is appropriate.
f.
Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have also
caused injury to Cambria, a limited liability company organized under the laws of Minnesota
with its principal place of business in Minnesota, by infringing Cambrias patents as set forth
below.
19.
Venue is proper in this Judicial District under 28 U.S.C. 1391(b) and (c) and
1400(b), at least because Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have
committed acts of infringement in this district and Cambria has suffered harm resulting from that
infringement in this district.
BACKGROUND OF THE ACTION
20.
Cambria is the leading designer and manufacturer of quartz products, specializing
in quartz stone products. Founded in 2000, Cambria has been at the forefront of the rapidlydeveloping United States market for quartz surface products. Cambrias quartz surface product
success has attracted numerous competitors to the marketplace, including Defendants Vicostone,
BPI, Solidtops, Dorado, and Pental.
21.
Upon information and belief, Defendants Vicostone, BPI, Solidtops, Dorado, and
Pental make, use, sell and/or offer to sell or import into the United States quartz surface
products. Many of those products embody Cambrias innovative designs, which are protected
under Cambrias U.S. design patents. Cambria owns all rights, title and interests in and to the
Asserted Patents, including the rights to recover for past, present, and future infringements and
violations thereof. By virtue of the activities set forth above, Defendants Vicostone, BPI,
Solidtops, Dorado, and Pental infringe one or more designs claimed in the Asserted Patents.
COUNT I: INFRINGEMENT OF U.S. DESIGN PATENT NO. D712,666
(VICOSTONE)
22.
Cambria incorporates by reference the allegations contained in paragraphs 1-21
above as if repeated here in full.

23.
Cambria is the lawful owner of the 666 patent, entitled Portion of a Slab. The
United States Patent and Trademark Office duly and legally issued the 666 patent on September
9, 2014. A true and correct copy of the 666 patent is attached to this Complaint as Exhibit A.
24.
On information and belief, Defendant Vicostone has actual knowledge of the 666
patent, at least by virtue of the filing of this Complaint.

25.
On information and belief, Defendant Vicostone has been and currently is
infringing the design claimed in the 666 patent by making, using, offering for sale, and/or
selling within or importing into the United States, without authority, products embodying the
patented design claimed in the 666 patent. Specifically, Vicostones Cosmic Black products
directly infringe the 666 patent because an ordinary observer, giving such attention as a
purchaser usually gives, would be deceived by the substantial similarity between the designs so
as to be induced to purchase Vicostones Cosmic Black products believing them to be the
same as the design embodied and claimed in the 666 patent. Review of Vicostones Cosmic
Black products demonstrates that the products literally infringe the 666 patent:
Photograph Comparing Color Photograph Submitted to the USPTO for U.S. Design
Patent No. D712,666 (left) to Physical Sample of Accused Vicostone Cosmic Black
Product (right)
26.
On information and belief, with knowledge of the 666 patent, Defendant
Vicostone has actively induced and continues to induce direct infringement of the 670 patent by
others by, among other things, providing third parties, such as distributors and dealers, with the
Accused Products.
27.
Vicostone has contributed and continues to contribute to the others infringement of the 666
patent by, among other things, providing third parties, such as distributors and dealers, with the
Accused Products.
7
28.
Cambria has suffered and will continue to suffer damage due to Defendant
Vicostones infringement of the 666 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
recover damages adequate to compensate for such infringement, including a recovery of
Defendant Vicostones total profits derived from its unlawful conduct alleged herein or lost
profits, but in no event less than a reasonable royalty for infringing the 666 patent, together with
interest and costs fixed by this Court.
29.
Defendant Vicostone has engaged and is engaged in willful and deliberate
infringement of the 666 patent or, at the very least, a reckless disregard for Cambrias patent
rights. Defendant Vicostones continued infringement following notice of the 666 patent claims
qualifies as willful, and Cambria is entitled to treble damages, attorneys fees, and costs incurred
in this action, along with prejudgment interest under 35 U.S.C. 284, 285.
30.
Cambria is entitled to a permanent injunction preventing Defendant Vicostone
from further infringing the 666 patent. Defendant Vicostones infringement of the 666 patent
has caused and will continue to cause irreparable harm to Cambria that will continue unless and
until it is enjoined by this Court.
COUNT II: INFRINGEMENT OF U.S. DESIGN PATENT NO. D751,298
(VICOSTONE)
31.

32.
298 Patent was duly and legally issued by the United States Patent and Trademark Office on
March 15, 2016. A true and correct copy of the 298 patent is attached to this Complaint as
Exhibit B.
33.
On information and belief, Defendant Vicostone has actual knowledge of the 298

34.
On information and belief, Defendant Vicostone has been and currently is
patented design claimed in the 298 patent. Specifically, Vicostones White Macaubas
products directly infringe the 298 patent because an ordinary observer, giving such attention as
a purchaser usually gives, would be deceived by the substantial similarity between the designs so
as to be induced to purchase Vicostones White Macaubas products believing them to be the
same as the design embodied and claimed in the 298 patent. Review of Vicostones White
Macaubas products demonstrates that the products literally infringe the 298 patent:
Patent No. D751,298 (left) to Physical Sample of Accused Vicostone White Macaubas
Product (right)
35.
Vicostone has actively induced and continues to induce direct infringement of the 298 patent by
Accused Products.
36.
Vicostone has contributed and continues to contribute to the others infringement of the 298
10
Accused Products.
37.
Vicostones infringement of the 298 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
Defendant Vicostones total profits derived from its unlawful conduct alleged herein or lost
38.
Defendant Vicostone has engaged and is engaged in willful and deliberate
rights. Defendant Vicostones continued infringement following notice of the 298 patent claims
39.
Cambria is entitled to a permanent injunction preventing Defendant Vicostone
from further infringing the 298 patent. Defendant Vicostones infringement of the 298 patent
COUNT III: INFRINGEMENT OF U.S. DESIGN PATENT NO. D737,058
(BPI)
40.

41.
Cambria is the lawful owner of 058 patent, entitled Portion of a Slab. The
058 patent was duly and legally issued by the United States Patent and Trademark Office on
11
August 25, 2015. A true and correct copy of the 058 patent is attached to this Complaint as
Exhibit C.
42.
On information and belief, Defendant BPI has actual knowledge of the 058

43.
On information and belief, Defendant BPI has been and currently is infringing the
design claimed in the 058 patent by making, using, offering for sale, and/or selling within or
importing into the United States, without authority, products embodying the patented design
claimed in the 058 patent. Specifically, BPIs Dark Reflections products directly infringe the
058 patent because an ordinary observer, giving such attention as a purchaser usually gives,
would be deceived by the substantial similarity between the designs so as to be induced to
purchase BPIs Dark Reflections products believing them to be the same as the design
embodied and claimed in the 058 patent. Review of BPIs Dark Reflections products
demonstrates that the products literally infringe the 058 patent:
12
Patent No. D737,058 (left) to Physical Sample of Accused BPI Dark Reflections
Product (right)
44.
On information and belief, with knowledge of the 058 patent, Defendant BPI has
actively induced and continues to induce direct infringement of the 058 patent by others by,
among other things, providing third parties, such as distributors and dealers, with the Accused
Products.
45.
On information and belief, with knowledge of the 058 patent, Defendant BPI has
contributed and continues to contribute to the others infringement of the 058 patent by, among
other things, providing third parties, such as distributors and dealers, with the Accused Products.
13
46.
Cambria has suffered and will continue to suffer damage due to Defendant BPIs
infringement of the 058 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to recover
damages adequate to compensate for such infringement, including a recovery of Defendant BPIs
total profits derived from its unlawful conduct alleged herein or lost profits, but in no event less
than a reasonable royalty for infringing the 058 patent, together with interest and costs fixed by
this Court.
47.
Defendant BPI has engaged and is engaged in willful and deliberate infringement
of the 058 patent or, at the very least, a reckless disregard for Cambrias patent rights.
Defendants BPIs continued infringement following notice of the 058 patent claims qualifies as
willful, and Cambria is entitled to treble damages, attorneys fees, and costs incurred in this
action, along with prejudgment interest under 35 U.S.C. 284, 285.
48.
Cambria is entitled to a permanent injunction preventing Defendant BPI from
further infringing the 058 patent. Defendant BPIs infringement of the 058 patent has caused
and will continue to cause irreparable harm to Cambria that will continue unless and until it is
enjoined by this Court.
COUNT IV: INFRINGEMENT OF U.S. DESIGN PATENT NO. D712,161
(SOLIDTOPS)
49.

50.
September 2, 2014. A true and correct copy of the 161 patent is attached to this Complaint as
Exhibit D.
14
51.
On information and belief, Defendant Solidtops has actual knowledge of the 161

52.
On information and belief, Defendant Solidtops has been and currently is
patented design claimed in the 161 patent. Specifically, Solidtops Lamar products directly
infringe the 161 patent because an ordinary observer, giving such attention as a purchaser
usually gives, would be deceived by the substantial similarity between the designs so as to be
induced to purchase Solidtops Lamar products believing them to be the same as the design
embodied and claimed in the 161 patent. Review of Solidtops Lamar products demonstrates
that the products literally infringe the 058 patent:
15
Patent No. D712,161) (left) to Physical Sample of Accused Solidtops Lamar Design
(right)
53.
Solidtops has actively induced and continues to induce direct infringement of the 161 patent by
Accused Products.
54.
Solidtops has contributed and continues to contribute to the others infringement of the 161
16
Accused Products.
55.
Solidtops infringement of the 161 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
Defendant Solidtops total profits derived from its unlawful conduct alleged herein or lost
56.
Defendant Solidtops has engaged and is engaged in willful and deliberate
rights. Defendant Solidtops continued infringement following notice of the 161 patent claims
57.
Cambria is entitled to a permanent injunction preventing Defendant Solidtops
from further infringing the 161 patent. Defendant Solidtops infringement of the 161 patent
COUNT V: INFRINGEMENT OF U.S. DESIGN PATENT NO. D712,670
(DORADO)
58.

59.
17
Exhibit E.
60.
On information and belief, Defendant Dorado has actual knowledge of the 670

61.
On information and belief, Defendant Dorado has been and currently is infringing
the design claimed in the 670 patent by making, using, offering for sale, and/or selling within or
claimed in the 670 patent. Specifically, Dorados Caramel products directly infringe the 670
patent because an ordinary observer, giving such attention as a purchaser usually gives, would be
deceived by the substantial similarity between the designs so as to be induced to purchase
Dorados Caramel products believing them to be the same as the design embodied and claimed
in the 670 patent. Review of Dorados Caramel products demonstrates that the products
literally infringe the 670 patent:
18
Patent No. D712,670 (left) to Physical Sample of Accused Dorado Caramel Design
(right)
62.
On information and belief, with knowledge of the 670 patent, Defendant Dorado
has actively induced and continues to induce direct infringement of the 670 patent by others by,
Products.
63.
has contributed and continues to contribute to the others infringement of the 670 patent by,
19
Products.
64.
Dorados infringement of the 670 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
Defendant Dorados total profits derived from its unlawful conduct alleged herein or lost profits,
but in no event less than a reasonable royalty for infringing the 670 patent, together with interest
and costs fixed by this Court.
65.
Defendant Dorado has engaged and is engaged in willful and deliberate
rights. Defendant Dorados continued infringement following notice of the 670 patent claims
66.
Cambria is entitled to a permanent injunction preventing Defendant Dorado from
further infringing the 670 patent. Defendant Dorados infringement of the 670 patent has
caused and will continue to cause irreparable harm to Cambria that will continue unless and until
it is enjoined by this Court.
COUNT VI: INFRINGEMENT OF U.S. DESIGN PATENT NO. D712,161
(DORADO)
67.

68.
20
Exhibit D.
69.
On information and belief, Defendant Dorado has actual knowledge of the 161
patent, at least by virtue of the filing of this Complaint. In addition, Cambria sent Dorado a letter
on Mary 22, 2015, informing it of its infringement. Dorado, however, has continued to make,
use, offer to sell, and/or sell in or import into the United States quartz surface products that
infringe the 161 patent.
70.
claimed in the 161 patent.
71.
claimed in the 161 patent. Specifically, Dorados Raven products directly infringe the 161
Dorados Raven products believing them to be the same as the design embodied and claimed
in the 161 patent. Review of Dorados Raven products demonstrates that the products
21
Patent No. D712,161 (left) to Physical Sample of Accused Dorado Raven Design
(right)
72.
Products.
73.
Products.
22
74.
Dorados infringement of the 161 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
Defendant Dorados total profits derived from its unlawful conduct alleged herein or lost profits,
75.
Defendant Dorado has engaged and is engaged in willful and deliberate
rights. Defendant Dorados continued infringement following notice of the 161 patent claims
76.
Cambria is entitled to a permanent injunction preventing Defendant Dorado from
further infringing the 161 patent. Defendant Dorados infringement of the 161 patent has
caused and will continue to cause irreparable harm to Cambria that will continue unless and until
it is enjoined by this Court.
COUNT VII: INFRINGEMENT OF U.S. DESIGN PATENT NO. D712,666
(PENTAL)
77.

78.
Exhibit A.
23
79.
On information and belief, Defendant Pental has actual knowledge of the 666

80.
On information and belief, Defendant Pental has been and currently is infringing
claimed in the 666 patent.
81.
On information and belief, Defendant Pental has been and currently is infringing
claimed in the 666 patent. Specifically, Pentals Volcano products directly infringe the 666
Pentals Volcano products believing them to be the same as the design embodied and claimed
in the 666 patent. Review of Pentals Volcano products demonstrates that the products
24
Patent No. D712,666 (left) to Physical Sample of Accused Pental Volcano Product
(right)
82.
On information and belief, with knowledge of the 666 patent, Defendant Pental
Products.
83.
On information and belief, with knowledge of the 666 patent, Defendant Pental
25
Products.
84.
Pentals infringement of the 666 patent. Thus, under 35 U.S.C. 289, Cambria is entitled to
Defendant Pentals total profits derived from its unlawful conduct alleged herein or lost profits,
85.
Defendant Pental has engaged and is engaged in willful and deliberate
rights. Defendant Pentals continued infringement following notice of the 666 patent claims
86.
Cambria is entitled to a permanent injunction preventing Defendant Pental from
further infringing the 666 patent. Defendant Pentals infringement of the 666 patent has caused
and will continue to cause irreparable harm to Cambria that will continue unless and until it is
enjoined by this Court.
EXCEPTIONAL CASE
87.
This case is exceptional against Defendants Vicostone, BPI, Solidtops, Dorado,
and Pental.
PRAYER FOR RELIEF
88.
WHEREFORE, Cambria respectfully requests this Court enter:
26
a.
A judgment in favor of Cambria that Defendant Vicostone has directly
infringed the 666 patent and the 298 patent;

b.
A judgment in favor of Cambria that Defendant Vicostone has induced
infringement of the 666 patent and the 298 patent;

c.
A judgment in favor of Cambria that Defendant Vicostone has contributed
to the infringement of the 666 patent and the 298 patent;

d.
A judgment in favor of Cambria that the Defendants BPI has directly
infringed the 058 patent;

e.
A judgment in favor of Cambria that the Defendants BPI has induced
infringement of the 058 patent;

f.
A judgment in favor of Cambria that the Defendants BPI has contributed
to the infringement of the 058 patent;

g.
A judgment in favor of Cambria that Defendant Solidtops has directly

h.
A judgment in favor of Cambria that Defendant Solidtops has induced

i.
A judgment in favor of Cambria that Defendant Solidtops has contributed
to the infringement of the 161 patent t;

j.
A judgment in favor of Cambria that Defendant Dorado has directly
infringed the 670 patent and the 161 patent;

k.
A judgment in favor of Cambria that Defendant Dorado has induced
infringement of the 670 patent and the 161 patent;
27
l.
A judgment in favor of Cambria that Defendant Dorado has contributed to
the infringement of the 670 patent and the 161 patent;

m.
A judgment in favor of Cambria that Defendant Pental has directly

n.
A judgment in favor of Cambria that Defendant Pental has induced

o.
A judgment in favor of Cambria that Defendant Pental has contributed to
the infringement of the 666 patent;

p.
A judgment in favor of Cambria that this case is exceptional within the
meaning of 35 U.S.C. 285, and an award to Cambria of its reasonable attorneys fees,
expenses, and costs incurred in this action;
q.
A permanent injunction enjoining Defendants Vicostone, BPI, Solidtops,
Dorado, and Pental and their officers, directors, agents, servants, affiliates, employees, divisions,
branches, subsidiaries, parents, and all others acting in active concert or participation with them,
from infringing, inducing the infringement of, or contributing to the infringement of the Asserted
Patents;
r.
A judgment requiring the Defendants Vicostone, BPI, Solidtops, Dorado,
and Pental to pay to Cambria the extent of Defendants total profit and revenue realized and
derived from their infringement of the Assert Patents, and actual damages in an amount not less
than a reasonable royalty for Defendants infringement;
s.
An award of enhanced damages not less than three times the damages
assessed for Defendants infringement of the Asserted Patents, in accordance with 35 U.S.C.
284; and
28
t.
Any and all relief as this Court deems proper and just.
DEMAND FOR JURY TRIAL
89.
Cambria demands trial by jury on any and all issues so triable.
Dated: July 12, 2016
FISH & RICHARDSON P.C.

By: s/ Rebecca L. Shult
Rebecca L. Shult (#0387968)
Joseph A. Herriges (#390350)
3200 RBC Plaza
60 South Sixth Street
Minneapolis, MN 55402
Telephone: (612) 335-5070
Facsimile: (612) 288-9696
shult@fr.com
herriges@fr.com
OF COUNSEL:
Ahmed J. Davis (Pro Hac Vice pending)
1425 K Street, NW, 11th Floor
Washington, DC 20005
Telephone: (202) 783-5070
Facsimile: (202) 783-2331
davis@fr.com
John S. Goetz (Pro Hac Vice pending)
Vivian Cheng (Pro Hac Vice pending)
601 Lexington Avenue, 52nd Floor
New York, NY 10022
Telephone: (212)-765-5070
goetz@fr.com
cheng@fr.com
Attorneys for Cambria Company LLC
29
CASE 0:16-cv-02402 Document 1-1 Filed 07/12/16 Page 1 of 4

USO0D712666S
(12) United States Design Patent (10) Patent N0.2

Grzeskowiak et al.
( 54 )
(71)
PORTION OFASLAB
-
- -
Appl1cant. Cambrla Company LLC, Eden Pra1r1e,
4,248,652 A *
2/1981
Civardiet a1. .............. .. 156/219
8/1982
McCartney ...... ..
428/151
5,023,130 A
6/1991
Simpson et al.
442/408
13370,350
6/1996
Spadacini
5,556,671 A *
9/1996
Miura et al.
......
428/152
. . . . ..
135/32
.................. .. 428/15
git
er
(.US) summer Lalfe Kath Eden

Pralnef MN (Us); Martlll E- Dav,
13501,091 s *
13525,434 s *
Excels1or, MNwS)
D557,902 S *
D560,915 S *
Assignee: Cambria Company LLC, Eden Prairie,
1/2005 McGahee ...................... .. D5/62

7/2006 Mangrum
135/36
12/2007 Parrish ...... ..
2/2008 Ci'ye et al. ..
D5/26
D5/62
136151762 S *
5/2010 Klmmel ~~~~ ~~
D5/62
MN (Us)
D631,670 S *
2/2011 Jackson ..
D5/99
D655,094 S
3/2012
D5/32
14 Years
D656,323 S
13663,959 s
*
*
3/2012 Jeronimo
D5/62
7/2012 Brookman ..................... .. 135/62
**
Term
Sep. 9, 2014
4,342,805 A *
(72) Inventors: Jon Louis Grzeskowiak, Prior Lake,
4*
5,354,596 A ,,, 10/1994 Chew et al
MN (Us)
(73)
US D712,666 S
(45) Date of Patent:
(21) App1.No.: 29/442,508
Key .......... ..
(Commued)
OTHER PUBLICATIONS
(22) Filed:
Mar. 15, 2013
(51)
LOC (10) Cl
(52)
U s Cl
0 5_0 6
.
.............................................. ..
Cambria Color ParysTM The Jewel CollectionTM Sample Book, Ver

Sion 11A_0324, printed Apr 21, 2011, 22 pages
USPC ........................................................... .. D5/44
(58)
(Continued)
Field of Classi?cation Search

USPC .......... .. 135/4, 6, 8, 11, 16, 19, 43, 44, 46, 47,
D5/48, 53, 56, 57, 6&64, 66, 99; D6/602,
D6/612, 613, 617; D19/1, 5; D25/138;

2/900, 15/208; 28/143, 150, 160, 163;
112/401, 416 439; 428/15, 32 665,
428/85, 91, 151, 152, 153, 187, 190, 542.2,

428/542.6; 442/408
See application ?le for complete search history.

(56)
(74) Attorney, Agent, or Firm i Fish & Richardson P.C.
(57)
CLAIM
The ornamental de81gn for a portlon ofa slab, as shown and
descrlbed
DESCRIPTION
References Cited
The ?le of this patent contains at least one drawing/photo
U.S. PATENT DOCUMENTS
graph executed in color. Copies of this patent with color

drawing(s)/photograph(s) will be provided by the Of?ce upon
request and payment of the necessary fee.
1,344,570 A *
6/1920
D67,245 S *
1,596,482 A *
5/1925 Ulmer
8/1926 Ewen
D90,466 S
D162,280
Primary Examiner * Karen S Acker
Warren ....................... .. 162/126
D5/62
264/74
8/1933 Willheim .
3/1951
Barash
.....
3,515,619 A *
6/1970 Barnette ..
D232,595 S
8/1974
D5/62
. . . ..
The sole FIGURE is a top plan View of a portion of a slab,

showing our new design.
The portion of a slab is ?at.
D5/62
428/15
Willard .......................... .. D5/53
1 Claim, 1 Drawing Sheet

(1 of 1 Drawing Sheet(s) Filed in Color)
US D712,666 S
Page 2
(56)
References Cited
D700,440 S
2004/0209009 A1*
3/2014 Johnston ........................ .. D5/62

10/2004
Opsommer et a1. .......... .. 428/15
US. PATENT DOCUMENTS

OTHER PUBLICATIONS
D670,085 S
11/2012
g i
Brookman et a1. ............ .. D5/62
gi??ln?les 6131f
D693,583 S
D697,3l9 S
11/2013
son et a .
D232
................ ..
Georgevitch .... ..
Cambria WaterstoneTM CollectionTM Sample Book, Version 11A

-
D5/62
1/2014 Brookman et a1. ............ .. D5/62
* cited by examiner
U S. Patent
Sep. 9, 2014
US D712,666 s
UNITED STATES DEPARTMENT OF COMMERCE

United States Patent and Trademark Office
February 10, 2016
THIS IS TO CERTIFY THAT ANNEXED HERETO IS A TRUE COPY FROM

THE RECORDS OF THIS OFFICE OF:
U.S. PATENT: D737, 058

ISSUE DATE: August 25, 2015
By Authority of the
Under Secretary of Commerce for Intellectual Property
and
Director of thec~//.~~/jf~/~ff,.~/United.~~es~/ea/A/~-~tand~.,~~/Tradem,
ark Office
/ Sylvia ~blley
Certifying Officer
US00D737058S
12) United States Design Patent (lO) Patent No.:

Davis et al.
References Cited
(56)
(54)
PORTION OF A SLAB
(71)
Applicant: Cambria Company LLC, Eden Prairie,
US D737,058 S
** Aug. 25, 2015

MN (US)
(72)
Inventors: Martin E. Davis, Excelsior, MN (US);

Jon Louis Grzeskowiak, II, Prior Lake,
MN (US); Summer Lane Kath, Eden
Prairie, MN (US)
(73)
Assignee:
Cambria Company LLC, Eden Prairie,

MN (US)
(**)
Term:
14 Years
(21)
App1. No.: 29/474,410
(22)
Filed:
(51)
LOC (10) Cl ................................................. 05-06
(52)
U.S. CI.
1,344,570
D67,245
1,596,482
D90,466
2,028,948
Dl13,909
D162,280
2,565,491
2,693,658
3,021,247
3,515,619
D232,595
3,864,193
D234,646
4,248,652
4,342,805
5,023,130
A
S
A
S
A
S
S
A
A
A
A
S
A
S
A
A
A
6/1920
5/t925
8/1926
8/1933
1/1936
*
* 3/1939
3/1951
*
8/1951
* 11/1954
2/1962
*
6/1970
8/1974
2/1975
*
3/1975
*
2/1981
8/1982
6/1991
Warren
Ulmer
Ewea
Willheim
Pohlmann ..................... 428/203
Horowitz ......................... D5/37
Barash
Francis, Jr ..................... 428/152
Nobis ........................... 118/120
Stephens ....................... 156/222
Bamette
Willard
Friersonetal ................ 428/133
Nugent ............................ D5/62
Civardi et al.
McCartney
Simpson et al.
(Continued)
Sep. 12, 2014
OTHER PUBLICATIONS
Cambria 2010 Collection, 2010, 44 pages.
(Continued)
USPC ............................................................. D5/44

(58)
Field of Classification Search

USPC ............ D5/1, 6, 9, 13, 14, 16, 21, 24, 26-28,
D5/30, 32, 44, 53, 56, 58~52; D6/304,
Primary Examiner -- Karen S Acker

Assistant Examiner- Wendy Arminio
(74) Attorney, Agent, or Firm -- Fish & Richardson P.C.
D6/620; D19/1, 5; D25/138, 151; D2/505,
CLAIM
(57)
The ornamental design for a portion of a slab, as shown and
described.
D2/506; 2/207, 900; 15/208; 28/143, 150,
DESCRIPTION
D6/583-585, 587, 589-591,598, 599,
28/160, 163; 112/401,416, 439; 428/6,

428/15, 32, 66.5, 85, 91, 151-153, 187,
428/190, 542.2, 542.6; 442/408
CPC ........... B31F 1/07; B32B 3/266; B32B 5/024;
B44F 1/00; B44F 1/02; B44F 1/08; B44F
1/10; B44F 5/00; B44F 7/00; B44F 9/00;
B44F 9/04; D03D 1/00; D04H 1/00; D10B
2503/04; D21H 27/02
See application file for complete search history.
The file of this patent contains at least one drawing]photograph executed in color. Copies of this patent with color
dmwing(s)/photograph(s) will be provided by the Office upon
The sole FIGURE is a top plan view of a portion of a slab
The portion of a slab is fiat.
(1 of I Drawing Sheet(s) Filed in Color)
Copy provided by USPTO from the PIRS Image Database on 02/03/2016
US D737,058 S
Page 2
(56)
References Cited
5,354,596
D370,350
5,556,671
5,927,034
D453,629
A
S
A
A *
S
10/1994
6/1996
9/1996
7/1999
2/2002
1/2004
DI~84,707 S
1/2005
01,091 S
6,933,023 B2 *
8/2005
6,946,508 B2* 9/2005
D525,434 S
7/2006
D557,902 S
12/2007
D560,915 S
2/2008
D572,845 S * 7/2008
7,645,405 B2*
1/2010
D615,762 S
5/2010
D631,670 S
2/2011
3/2012
D655,094 S
D656,323 S
3/2012
7/2012
D663,959 S
Chewetal.
Spadaclni
Miuraetal.
Cole ............................... 52/391
Kxaker
Kxaker
McGahee
Clausen et al .................. 428/17
Yuiatwaetal ................ 524/401
Mangrum
Parrish
Cryeetal.
Paxketal ..................... D25/151
Suit ............................... 264/140
Kimmel
Jackson
Key
Jeronimo
Brookrnan
D670,085
D676,979
D679,099
D685,999
D693,583
D697,319
D700,440
D705,455
D705,956
D712,667
D712,668
D724,055
2002/0016399
2004/0209009
2008/0113124
2013/0137810
2013/0168607
S
11/2012 Brookman et al.
S
2/2013 Canales et al.
S
4/2013 Johnson et al.
S
7/2013 Johnson et al.
11/2013 Georgevitch
S
S
1/2014 Brookrnan et al.
S
3/2014 Johnston
S *
5/2014 Choietal .................... D25/151
S *
5/2014 Choietal .................... D25/151
S
9/2014 Grzeskowiaketal.
S *
9/2014 Grzeskowiaketal ........... D5/44
S *
3/2015 Tice ............................. D14/216
AI*
2/2002 Mazur ........................... 524/425
A1
10/2004 Opsommer et al.
AI*
5/2008 Parketal ........................ 428/15
AI*
5/2013 Shin .............................. 524/437
AI*
7/2013 Leeetal .................. 252/301.36
OTHER PUBLICATIONS
Cambria2011 Collection, 2011, 26 pages.

Cambria 2014 Collection, 2014, 42 pages.
* cited by examiner
U.S. Patent
Aug. 25, 2015
Copy provided by USPTO f~om the PIRS Image Database on 02/03/2016
US D737,058 S
PTO-1683
(Rev. 7-96)

USO0D712161S
(12) United States Design Patent (10) Patent No.:

Grzekowiak et a].
(54)
PORTION OF A SLAB
-
~ -
Inventors: Jon Louis Grzekowiak, Prior Lake, MN

~
8/1982 McCartney ................. .. 428/151
6/1991 Simpson et al.
5,354,596 A
5,556,671
D525,434
Frame? MN ws) Mam E DaVls
A
S
10/1994
9/1996
Chew et al.
442/408
428/152
Miura et al. ..................
..
n 428/15
2/2002 Kraker
1/2004 Kraker
*
7/2006
Mangrum
McGahee
. . . . . . . . . . . . . . . . . . . . . . ..
D5/36
D557,902 s * 12/2007 Parrish ........................... .. D5/26
Exce151or, MN (U S)
(73) Assignee:
Sep. 2, 2014
5,023,130 A *
D484,707 S
Summer Lane
.
Kath,
Eden -
4*
4,342,805 A *
D453,629 s
(72)
US D712,161 S
(Continued)
Company LLC, Eden Prairie,
OTHER PUBLICATIONS
Cambria Color ParysTM The Jewel CollectionTM Sample Book, Ver
(**)
Term
14 Years
sion llA-0324, printed Apr. 21, 2011, 22 pages.
(21) Appl. No.: 29/442,519

(22)
Filed:
(51)
LOC (10) Cl.
(Continued)
Mar. 15, 2013
Primary Examiner * Karen S Acker
.............................................. .. 05 _ 06
(52) US. Cl.

USPC
(58)
Allorn W, A 3enl, or Firm * Fish & Richardson PC.
(57)
........................................................... ..
The ornamental de51gn for a portion of a slab, as shown and
Field of Class1?catlon Search
described
135/48, 53, 56, 57, 6W64, 66, 99; D6/602,

D6/612, 613, 617; D19/1, 5; D25/138;
2/900; 15/208; 28/143: 150: 160: 163;
112/401> 416> 439; 428/15 32 665
428/85, 91 151 152s 153s 187s 190 542-2,

_
CLAIM
D5/44
USPC .......... .. D5/4, 6, 8, 11, 16, 19, 43, 44, 46, 47,
(56)
74
4286426; 442/408
'
DESCRIPTION
The ?le of this patent contains at least one drawing/photo
graph executed in color. Copies of this patent With color
drawing(s)/photograph(s) Willbeprovidedby the Of?ceupon

see apphcanon ?le for complete searCh hlstOI'YRe ferences Ct

d
1 e
The sole FIGURE is a top plan View of a portion of a slab,

Such a synthetic mold slab may be, for example, thermo
formed or otherwise compacted to a selected slab shape from
1,344,570 A *
6/1920
Warren ....................... .. 162/126
D67,245 S *
1,596,482 A *
5/1925 Ulmer
8/1926 Ewen
D5/62
264/74
D90,466 S
8/1933 Willheim .
D162,280 S
3/1951
Barash ..
D5/62
. D5/62
3,515,619 A *
6/1970 Barnette
D232,595
8/1974
Willard
4,248,652 A *
2/1981
Civardiet al. .............. .. 156/219
428/15
.... ... .
. . . ..
D5/53
a mixture including particulate mineral material, resin binder,

and pigments so that the solid surface portion of the synthetic
molded slab is suitable for use in living or working spaces
(e.g., along a countertop, table, ?oor, or the like).

The portion of a slab is ?at.

(1 of 1 Drawing Sheet(s) Filed in Color)
US D712,161 S
Page 2
(56)
References Cited
D685,999 s
US PATENT DOCUMENTS
115-60915 S
2/2008
Crye etal n D5/62
13615,762 s *
5/2010 Kimmel
13631,670 s
13655,094 s
2/2011
3/2012
*
*
13700,440 s *
2004/0209009 A1*
13656323 S *
3/2012 JefOIlimO ~
D5/62
7/2012 Brookman
135/62
D670,085 s * 11/2012 Brookman et a1.
7/2013 Johnson etal. ................ .. 135/62
3/2014
10/2004
135/62
135/62
Johnston ........................ ..135/62

Opsommeretal. .......... .. 428/15
135/62
Jackson ......................... .. 135/99

Key ............................... .. 135/32
13663,959 s
D693,583 s * 11/2013 Georgevitch

13697,319 s * 1/2014 Brookman et a1.
135/62
13676,979 s
2/2013
Canales et a1. ..
D679,099 s
4/2013
Johnson et a1. ................ .. 135/62
D25/138
OTHER PUBLICATIONS
Cambria WaterstoneTM CollectionTM Sample Book, Version 11A

.
0818 Prnted Sep' 26 2011 Pages'

_
* cued by exammer
U S. Patent
Sep. 2, 2014
US D712,161 S

UNITED STATES PATENT AND TRADEMARK OFFICE
CERTIFICATE OF CORRECTION
PATENT No.
:D712,161S
APPLICATION NO.
: 29/442519
DATED
INVENTOR(S)
: September 2, 2014
: Jon Louis Grzeskowiak, II et a1.
Page 1 of1
It is certified that error appears in the above-identi?ed patent and that said Letters Patent is hereby corrected as shown below:
ON THE TITLE PAGE ITEM (72)
Column 1, line 1 (inventors), please delete Grzekowiak and insert --Grzeskowiak--, therefor.
Signed and Sealed this

Sixth Day of January, 2015
WMZ44L_
Michelle K. Lee
Deputy Director 0fthe United States Patent and Trademark O?ice
D 7569718
UNITED STATES DEPARTMENT OF COMMERCE

United States Patent and Trademark Office
February 10, 2016
THIS IS TO CERTIFY THAT ANNEXED HERETO IS A TRUE COPY FROM

THE RECORDS OF THIS OFFICE OF:
U.S. PATENT: D712,670

ISSUE DATE: September 09, 2014
By Authority of the
Under Secretary of Commerce for Intellectual Property
and Director of the United S~(fl~P~f,~t and Tra~iernark Office
/SY,~7IA
?_LLEY
Ce~fffying H~
Officer
--
US00D712670S
(12) United States Design Patent (lO) Patent No.:

Grzeskowiak et al.
(54)
PORTION OF A SLAB
(71)
Applicant: Cambria Company LLC, Eden Prairie,
4,342,805
5,023,130
5,354,596
D370,350
5,556,671
D453,629
D484,707
D501,091
D525,434
D557,902
D560,915
D615,762
D631,670
D655,094
D656,323
D663,959
MN (US)
(72)
Inventors: Jon Louis Grzeskowiak, Prior Lake,

MN (US); Summer Lane Kath, Eden
Prairie, MN (US); Martin E. Davis,
Excelsior, MN (US)
(73)
Assignee:
Cambria Company LLC, Eden Prairie,

MN (US)
(**)
Term:
14 Years
(21)
Appl. No.: 29/442,513
US

A
A
A
S
A
S
S
S
S
S
S
S
S
S
S
S
**
D712,670 S
Sep. 9, 2014
*
8/1982 McCartney ................... 428/151
* 6/1991 Simpson et al ............... 442/408
* 10/1994 Chewetal .................... 428/152
6/1996 Spadacini ........................ D5/32
*
*
9/1996 Miura et al ..................... 428/15
2/2002 Kraker
1/2004 Kraker
*
1/2005 McGahee ........................ D5/62
*
7/2006 Mangrum ........................ D5/36
* 12/2007 Parrish ............................. D5/26
* 2/2008 Clyeetal ........................ D5/62
*
5/2010 Kimmel ........................... D5/62
*
2/2011 Jackson ........................... D5/99
*
3/2012 Key ................................. D5/32
*
3/2012 Jeronimo ......................... D5/62
*
7/2012 Brookman ....................... D5/62
(Continued)
OTHER PUBLICATIONS
(22)
Filed:
(51)
LOC (10) CI ................................................. 05-06

U.S. CI.
USPC ............................................................. D5/44
(52)
(58)
Mar. 15, 2013
Field of Classification Search

USPC ............ D5/4, 6, 8, 11, 16, 19, 43, 44, 46, 47,
D5/48, 53, 56, 57, 60-64, 66, 99; D6/602,
D6/612, 613, 617; D19/1, 5; D25/138;
2/900; 15/208; 28/143, 150, 160, 163;
112/401,416, 439; 428/15, 32, 66.5,
428/85, 91,151,152, 153, 187, 190, 542.2,
428/542.6; 442/408
See application file for complete search history.
References Cited
(56)

1,344,570
D67,245
1,596,482
D90,466
D162,280
3,515,619
D232,595
4,248,652
A
S
A
S
S
A
S
A
*
*
*
*
*
*
*
*
6/1920
5/1925
8/1926
8/1933
3/1951
6/1970
8/1974
2/1981
Warren ......................... 162/126

Ulmer .............................. D5/62
Ewen .............................. 264/74
Willheim ......................... D5/62
Barash ............................. D5/62
Bamette ......................... 428/15
Willard ............................ D5/53
Civardi et al ................. 156/219
Cambria Color ParysTM The Jewel CollectionTM Sample Book, Version 11A-0324, printed Apr. 21, 2011, 22 pages.
(Continued)
Primary Examiner -- Karen S Acker
(74) Attorney, Agent, or Firm -- Fish & Richardson P.C.
(57)
CLAIM
The ornamental design for a portion of a slab, as shown and

described.
DESCRIPTION
The file of this patent contains at least one dmwing/photograph executed in color. Copies of this patent with color
dmwing(s)/photograph(s) will be provided by the Office upon
request and payment ofthe necessary fee.
The sole FIGURE is a top plan view of a portion of a slab,
The portion of a slab is fiat.
(1 of I Drawing Sheet(s) Filed in Color)
US D712,670 S
Page 2
References Cited
(56)
3/2014 Johnston .......................... D5/62

D700,440 S *
2004/0209009 A1 * 10/2004 Opsommer et al ............. 428/15

OTHER PUBLICATIONS
D670,085
D676,979
D679,099
D685,999
D693,583
D697,319
S
S
S
S
S
S
* 11/2012 Brookmanetal ............... D5/62

* 2/2013 Canales etal ................ D25/138
* 4/2013 Johnson et al ................... D5/62
* 7/2013 Johnsonetal ................... D5/62
* 11/2013 Georgevitch .................... D5/62
*
1/2014 Brookmanetal ............... D5/62
Cambria WaterstoneTM CollectionTM Sample Book, Version llA0818, printed Sep. 26, 2011, 23 pages.
* cited by examiner
,~
U.S. Patent
Sep. 9, 2014
US D712,670 S
PTO- 1683
(Rev. 7-96)

Cambria Company v. Stylen Quaza - Complaint

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CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 1 of 29

IN THE UNITED STATES DISTRICT COURT

Case No. 16-cv-2402

STYLEN QUAZA LLC, VICOSTONE

DEMAND FOR JURY TRIAL

COMPLAINT FOR PATENT INFRINGEMENT

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 2 of 29

Plaintiff Cambria is a limited liability company organized under the laws of

On information and belief, Defendant Stylen Quaza LLC, otherwise known as

On information and belief, Defendant Stylen Quaza LLC develops, manufactures,

On information and belief, Defendant Vicostone Joint Stock Company is a

On information and belief Defendant Vicostone Joint Stock Company develops,

On information and belief, Defendant Building Plastics Inc. is a corporation

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 3 of 29

On information and belief, Defendant BPI develops, manufactures, imports, sells

On information and belief, Defendant Solidtops is a limited liability company

On information and belief, Defendant Solidtops develops, manufactures, imports,

On information and belief, Defendant Dorado is a limited liability company

On information and belief, Defendant Dorado develops, manufactures, imports,

On information and belief, Defendant Pental is a corporation organized under the

On information and belief, Defendant Pental develops, manufactures, imports,

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 4 of 29

JURISDICTION AND VENUE

United States, specifically 35 U.S.C. 271, 281-285.

Dorado, and Pental for at least the following reasons:

Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have

On information and belief, Defendants Vicostone, BPI, Solidtops, Dorado,

Defendants Vicostone, BPI, Solidtops, Dorado, and Pental maintain

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 5 of 29

As such, upon information and belief, Defendants Vicostone, BPI,

Defendants Vicostone, BPI, Solidtops, Dorado, and Pental have also

Cambria is the leading designer and manufacturer of quartz products, specializing

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 6 of 29

Cambria incorporates by reference the allegations contained in paragraphs 1-21

above as if repeated here in full.

patent, at least by virtue of the filing of this Complaint.

On information and belief, Defendant Vicostone has been and currently is

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 7 of 29

On information and belief, with knowledge of the 666 patent, Defendant

On information and belief, with knowledge of the 666 patent, Defendant

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 8 of 29

Defendant Vicostone has engaged and is engaged in willful and deliberate

Cambria is entitled to a permanent injunction preventing Defendant Vicostone

Cambria incorporates by reference the allegations contained in paragraphs 1-30

above as if repeated here in full.

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 9 of 29

patent, at least by virtue of the filing of this Complaint.

On information and belief, Defendant Vicostone has been and currently is

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 10 of 29

On information and belief, with knowledge of the 298 patent, Defendant

On information and belief, with knowledge of the 298 patent, Defendant

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 11 of 29

Defendant Vicostone has engaged and is engaged in willful and deliberate

Cambria is entitled to a permanent injunction preventing Defendant Vicostone

Cambria incorporates by reference the allegations contained in paragraphs 1-39

above as if repeated here in full.

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 12 of 29

patent, at least by virtue of the filing of this Complaint.

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 13 of 29

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 14 of 29

Cambria is entitled to a permanent injunction preventing Defendant BPI from

Cambria incorporates by reference the allegations contained in paragraphs 1-48

above as if repeated here in full.

CASE 0:16-cv-02402 Document 1 Filed 07/12/16 Page 15 of 29