Equalia v. Kushgo - Complaint

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 1 of 14
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A Professional Corporation
Las Vegas
Ropers Majeski Kohn & Bentley
STEPHEN J. ERIGERO (SBN 11562)

TIMOTHY J. LEPORE (SBN 13908)
LAEL D. ANDARA (California SBN 215416)
MARIE E. SOBIESKI (California SBN 278008)
ROPERS, MAJESKI, KOHN & BENTLEY
3753 Howard Hughes Pkwy., Suite 200
Las Vegas, NV 89169
Telephone:
(702) 954-8300
Facsimile:
(650) 780-1701
Email:
stephen.erigero@rmkb.com
timothy.lepore@rmkb.com
lael.andara@rmkb.com
marie.sobieski@rmkb.com
Attorneys for Plaintiffs
EQUALIA, LLC and HOVERBOARD
TECHNOLOGIES CORPORATION
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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EQUALIA, LLC, a California limited

liability company, and HOVERBOARD
TECHNOLOGIES CORPORATION, a
California corporation,
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Plaintiffs,
CASE NO.
COMPLAINT FOR:
(1) PATENT INFRINGEMENT UNDER 35
U.S.C. 271; and
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v.
(2) UNFAIR AND DECEPTIVE TRADE

PRACTICES UNDER 15 U.S.C. 45.
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KUSHGO LLC dba HALO BOARD, a

California limited liability company;
HALO BOARD LLC, an Oregon limited
liability company; ARTHUR
ANDREASYAN, an individual; and
SHENZHEN WINDGOO INTELLIGENT
TECHNOLOGY CO. LTD., a foreign
company,
DEMAND FOR JURY TRIAL

[Out of state counsel will comply with LR IA
11-2 within 45 days]
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Defendants.
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Plaintiffs EQUALIA, LLC, a California limited liability company, and HOVERBOARD
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TECHNOLOGIES CORPORATION, a California corporation (collectively known as "Equalia"),
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as and for their complaint against Defendants KUSHGO LLC dba HALO BOARD, a California
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limited liability company ("Kushgo"), HALO BOARD, LLC, an Oregon limited liability
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COMPLAINT FOR PATENT INFRINGEMENT

AND UNFAIR AND DECEPTIVE TRADE
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company, ARTHUR ANDREASYN, an individual (collectively "HaloBoard"), and SHENZHEN
WINDGOO INTELLIGENT TECHNOLOGY CO. LTD. ("Windgoo"), a foreign company, and
allege as follows:
I.
INTRODUCTION
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1.
The Court has jurisdiction over this action because it is an action for patent
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infringement arising under the Patent Laws of the United States, 35 U.S.C. 101 et seq. Equalia
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owns exclusive rights in the ornamental design claimed in United States Design Patent No.
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the Equalia Patent is attached hereto as Exhibit A.
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2.
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D768,252, titled PITCH-PROPELLED VEHICLE ("Equalia Patent"). A true and correct copy of
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Equalia also owns exclusive rights in the utility patent described in United States
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Patent No. 9,211,470, titled PITCH-PROPELLED VEHICLE. A true and correct copy of the '470
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patent is attached hereto as Exhibit B.
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3.
Defendants have used and continue to use the claimed design of the Equalia Patent
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without Equalia's permission, on products that Defendants make, use, offer for sale, sell, and/or
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import into the United States.
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4.
Equalia seeks, among other relief, an injunction preventing Defendants from
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further infringing the Equalia Patent, and damages and/or a disgorgement of Defendants' profits
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from their patent infringement.
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II. PARTIES
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5.
Equalia, LLC is a California limited liability company in the automation, electric
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vehicle, and control system consumer marketplace. Equalia, LLC's principal place of business is
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located at 380 Logue Avenue, Mountain View, California 94043.
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Hoverboard Technologies Corporation is a California corporation in the business
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of developing, marketing, and selling personal transportation vehicles. Hoverboard Technologies
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Company's principal place of business is located at 380 Logue Avenue, Mountain View, CA
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94043.
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Hereinafter, Equalia, LLC and Hoverboard Technologies Corporation shall be

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referred to collectively as "Equalia" and all such references shall include Equalia, LLC and
Hoverboard Technologies Corporation.
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Upon information and belief, Kushgo LLC is a California limited liability
company having an address at 3940 Laurel Canyon Boulevard #376, Studio City, California
91604. Kushgo LLC has also been known to do business as "Halo Board" and "SegAway
Hoverboard". Kushgo LLC shall be referred to hereafter as "Kushgo."
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Upon information and belief, Halo Board LLC is a business holding itself out as an
Oregon limited liability company having an address of 4755 SW Griffith Drive, Beaverton,
Oregon 97005. On information and belief, Halo Board LLC is not registered with the Oregon
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Secretary of State.
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Upon information and belief, Arthur Andreasyan is an individual holding himself
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out as the Chief Executive Office of Halo Board LLC having an address at 3940 Laurel Canyon
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Boulevard, Studio City, California 91604.
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Hereafter, Halo Board LLC and Arthur Andreasyan shall be referred to
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collectively as "Halo Board" and all such references shall include Halo Board LLC and Arthur
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Andreasyan collectively.
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Upon information and belief, Shenzhen Windgoo Intelligent Technology Co. Ltd.
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is a foreign company having an address at 216 Zone 1, Building B, Mingyou Industrial Products
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Displaying & Purchasing Center, Bao'an, Shenzhen, People's Republic of China and 5th Floor,
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Building 7, Changfeng Industrial Park, Donkeng Village, Guangming New Area, Shenzhen,
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People's Republic of China. Shenzhen Windgoo Intelligent Technology Co. Ltd. shall be referred
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to hereafter as "Windgoo." Upon information and belief, Windgoo also maintains a United States
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warehouse at 1933 W. 11th St., Suite 5, Upland CA 91786.
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Hereafter, Kushgo, Halo Board, and Windgoo shall be referred to collectively as
"Defendants."
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III. JURISDICTION AND VENUE
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This is a civil action for patent infringement arising under the patent laws of the
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United States, Title 35, United States Code 1 et seq., including 35 U.S.C. 271.
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least 28 U.S. C. 1331 (federal question); 28 U.S.C. 1338 (a) (action arising under the Patent
Act); 28 U.S.C. 1338(b) (unfair competition joined with claims under the Patent Act); and 28
U.S.C. 1367 (supplemental jurisdiction).
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This Court has personal jurisdiction over this matter because Defendants, for one
or more of the following reasons:
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This Court has original jurisdiction over the subject matter of this action under at
a. The exercise of personal jurisdiction over Defendants by this Court is

consistent with the Federal Due Process Clause, Defendants having established minimum
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contacts with this forum such that the exercise of jurisdiction over Defendants would not offend
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traditional notions of fair play and substantial justice;
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b. Defendants have done and continue to do business in the State of Nevada

and with one or more residents of the State of Nevada, including this District;
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c. Defendants direct into the State of Nevada, including this District,

commerce, goods, and advertising including by electronic and other means;
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d. Defendants have entered into contracts with one or more residents of the
State of Nevada to supply products within the State of Nevada, including in this District;
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e. Defendants have offered, and continue to offer, products constituting patent
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infringement and products that constitute unfair and deceptive trade practices relating to this
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complaint in the State of Nevada, including this District; and
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f. Defendants have committed tortious injury to Equalia and to Equalia's

business operations within that State of Nevada, including this District.
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Venue is proper in this district pursuant to 28 U.S.C. 1391 because Defendants
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do, and have done, substantial business in this judicial District, including: (i) regularly doing
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business or soliciting business by virtue of Defendants' nationwide sales and offers to sell through
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its website; and (ii) engaging in other persistent courses of conduct, including trade shows, and/or
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deriving substantial revenue from products and/or services provided to persons in this District and
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State.
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This Court's exercise of personal jurisdiction over Defendants is consistent with
the Constitution of the United States and the State of Nevada.

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Venue is proper in this jurisdictional district under 28 U.S.C. 1391 and 1400 at
least because Defendants reside in this district by transacting and soliciting business in this
district, including with respect to products that infringe the Equalia Patent, and committing acts of
patent infringement in this district by selling and offering for sale products that infringe on the
Equalia Patent.
IV.
FACTUAL BACKGROUND
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A.
The Equalia Patent
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Equalia is an innovator in the field of single-wheeled electric personal mobility
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devices. Equalia designs, develops, and markets for sale single-wheeled electric mobility devices,
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including devices known as "hoverboards." Equalia's hoverboards provide unique and distinctive
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qualities to riders, as well as high quality engineering and construction.
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Equalia is in the process of launching a hoverboard product which consists of a
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board with one centered electrically-powered wheel for locomotion for a single rider. This
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hoverboard was first promoted through the crowdfunding site Kickstarter for approximately one
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month, lasting from September 17, 2015 to October 21, 2015. The Kickstarter page is located at
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https://www.kickstarter.com/projects/552747221/hoverboard-the-next-evolution-in-personal19
electric/. Equalia further promotes this hoverboard through its website at
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http://www.hoverboard.com, in the media, and at trade shows, including the Computer
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Electronics Show held annually in Las Vegas, Nevada.
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Equalia's hoverboard is anticipated to retail for $4,375 when made available for
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sale in 2017. A low-cost version will be available in early 2017 to retail between $995 and
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$1,195.
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Equalia has taken steps to protect its innovative technology and designs, including
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its hoverboard-related designs. In particular, Equalia owns various United States patents,
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including design patents relating to its hoverboard designs.
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D768,252, titled PITCH-PROPELLED VEHICLE, was duly and legally issued by the United
States Patent and Trademark Office ("USPTO"). The Equalia Patent has remained in force since
that time and continues to be in force. See Exhibit A. The Equalia Patent gives Equalia the right to
exclude others from making, using, offering for sale, and selling the invention claimed in the
patent within the United States, and from importing the invention claimed in the patent into the
United States.
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On October 4, 2016, the Equalia Patent, United States Design Patent No.
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The Equalia Patent covers an ornamental design for a single-wheeled electric
personal mobility device.

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Equalia owns all right, title, and interest in, and has the right to sue and recover for
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past, present, and future infringement of, the Equalia Patent from the date the patent duly and
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legally issued to Equalia.
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Equalia has extensively promoted, advertised, and used products embodying the
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Equalia Patent design throughout the United States, including, but not limited to, brochures, trade
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show displays and materials, signage, and online to distinguish Equalia's products from those
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offered by others.
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Although Equalia's hoverboard embodying the Equalia Patent has not been sold on
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the open market, it has garnered significant discussions and press which has created value in the
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design of the product. Equalia previously displayed its hoverboard to the public at large at the
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2016 Computer Electronics Show ("CES") in Las Vegas, Nevada, from January 6-9, 2016, and
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through numerous television and trade show appearances. For example, the Equalia hoverboard
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has been featured on General Electric's Projects Garage, as well as the nationwide morning
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program Live Kelly & Michael Show. Equalia has also given demos of its hoverboard, including
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at the CDX Global Forum in 2016. A true and correct copy of the YouTube pages hosting these
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videos is attached hereto as Exhibit C.
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The Equalia Patent is presumed to be valid.
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B.
Defendants' Infringing Activity
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On information and belief, without Equalia's authorization, Defendants have made,

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used, offered for sale, sold, and/or imported into the United States products having designs that
violate the Equalia Patent (hereafter, the "Infringing Products"). The Infringing Products include
at least products identified by the model name "Halo Board" as well as Defendants' products
bearing the same or substantially similar infringing designs, regardless of the model name.
Publically available materials advertising the Infringing Products are attached hereto as Exhibit
D.
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On information and belief, the overall appearance of the design of the Equalia
Patent and corresponding designs of the Defendants Infringing Products are substantially the
same.
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On information and belief, an ordinary observer will perceive the overall
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appearance of the designs of the Equalia Patent and the corresponding design of Defendants'
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Infringing Products to be substantially the same. Defendants' products have been characterized as
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"knock-offs" of Equalia's products.
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On information and belief, Kushgo filed a trademark application with the USPTO
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for the mark "HALO BOARD", serial no. 87017860, on April 28, 2016. In that application,
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Kushgo states that it has been using the mark for sale of its product, depicted in the specimen,
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since at least April 25, 2016. The product depicted in the specimen has an overall appearance
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nearly identical to the Equalia Patent design. A true and correct copy of the trademark
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application, including the specimen, is attached hereto as Exhibit E. Halo Board is the current
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assignee of the HALO BOARD trademark application.
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Specimen included with the "HALO BOARD" trademark (see id, pg. 7):
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Equalia's hoverboard embodying the Equalia Patent:
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Windgoo openly admits that they have copied the Equalia products which embody
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the Equalia Patent. Attached hereto as Exhibit F is a true and correct copy of correspondence
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from Wingdoo in which it acknowledges copying. Upon information and belief, Windgoo's
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business model is based on copying patented technology and selling it through retailers and
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wholesalers and retailers in the United States and abroad.
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35.
On information and belief, Defendants are affiliated with numerous additional
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companies which assist with manufacturing and/or selling and distribution of the Infringing
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Products in the United State and abroad. These companies advertise products identical or nearly-
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identical to the Infringing Products, indicating that they are made with the same base design and
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parts from the same molds. Attached hereto as Exhibit G is a true and correct copy of
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advertisements of a third-party Infringing Product, including a picture of the Equalia board
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embodying the Equalia Patent at the upper left. Upon information and belief, these companies are
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partners or have purchase or supply relationships with Kushgo, Halo Board, and/or Windgoo, or
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were former iterations of the Kushgo, Halo Board, and/or Windgoo entities.
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36.
The design of the Infringing Products is so similar to the subject matter of the
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Equalia Patent that customers are likely to be deceived and persuaded to purchase the Infringing
Products thinking they are actually buying products protected by the Equalia Patent.
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Table 1 below illustrates Defendants' infringement by comparing figures from the
Equalia Patent with exemplary images of the Infringing Products. On information and belief,
Defendants' Infringing Products are identical, and therefore their depictures are used
interchangeably.
Table 1. Comparison of Equalia Patent and Infringing Product
Equalia Patent (US Design Patent D768,252) Infringing Products
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38.
The Infringing Products share the following elements of the Equalia Patent:
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Oblong shaped board with upwardly-tipped ends;
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Single wheel elements in center of board;
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Rounded board ends;
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Lighting strip along perimeter edge;
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Dark, arched-shaped display on top-front of board;
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Gripping sticker at top of board with decorative crossing-lines pattern;
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Speakers on each end of board at same location with decorative colored
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outline;
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viii)
Road-lighting feature mounted between speakers to light roadway;
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ix)
Triangular skid-plates on each corner;
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x)
Decorative circular features on skid-plates;
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xi)
Rubber scrapers/bumpers on each side of wheel on top of board;
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xii)
Protective dome over wheel on top of board;
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xiii)
Raised decorative features on sides of centered wheel dome;
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xiv)
Decorative and functional screw holes around perimeter of board;
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xv)
Decorative double heavy-chamfered edges around board for thinner
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appearance;
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xvi)
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Decorative chamfer angle which tracks the centered side edge stripe.
Comparison of Equalia's hoverboard and the Infringing Products demonstrates the
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infringed design elements of the Equalia Patent. Attached hereto as Exhibit H is a comparison of
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the Equalia hoverboard and an example of Defendants' Infringing Product.
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40.
On information and belief, Defendants intended to copy the design covered by the
Equalia Patent.
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On information and belief, Defendants had pre-suit knowledge of the Equalia
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Patent at least because Equalia's marketing of its products embodying the claims of the Equalia
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Patent. Commensurate with this filing, Equalia mailed Defendants courtesy copies of this
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Complaint and the Equalia Patent. Thus, Defendants had knowledge of the Equalia Patent at least
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42.
On information and belief, Kushgo and/or Halo Board sells and offers to sell its
products, including the Infringing Products, directly to end-user customers through its website, as
well as to third-party resellers through its wholesale distribution channel. For example, the
website located at www.haloboard.com offers Infringing Products for sale (see Exhibit D, pg. 8),
and accepts sign-ups from wholesale and retail distributers (see Exhibit H). Attached hereto as
Exhibit I is a true and correct copy of the dealer signup form available on the
www.haloboard.com website.
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since the filing of this Complaint.
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On information and belief, Windgoo sells and offers to sell its products, including
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the Infringing Products, to distributers and wholesalers through its website, as well as through
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direct marketing. For example, an email received from Daisy Ding of Windgoo's International
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Sales department, Ms. Ding states that Windgoo has "start[ed] to produce your style hoverboard"
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and "we have a warehouse in LA, this products will also provide there." Windgoo openly solicits
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sales of Infringing Products via direct email marketing. See Exhibit F, pg. 3. Windgoo makes no
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attempt to hide the fact that it is copying products directly, and readily provided pictures of the
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Infringing Products in an effort to market them to Equalia. Id. The emails from Windgoo also
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indicate that the company has started to produce the Infringing Products and provides that these
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Infringing Products are already available in the United States. Id. at pg. 4.
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On information and belief, Kushgo and/or Halo Board sell and offer to sell
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Infringing Products directly to end-user customers in the United States, including Nevada. Third-
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party resellers also sell and offer to sell the Infringing Products in the United States, including
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Nevada.
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45.
On information and belief, Windgoo sells and offers to sell Infringing Products to
distributers and wholesalers in the United States, including Nevada.

46.
On information and belief, Defendants have infringed and continue to infringe the
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Equalia Patent within the meaning of 35 U.S.C. 271 at least by making, using, selling, offering
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to sell, and/or importing the Infringing Products into the United States without Equalia's
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authorization.
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Infringing Products at CES 2017 to be held January 5-8, 2017 in Las Vegas, Nevada. Attached
hereto as Exhibit J is a true and correct copy of advertising released by Kushgo and/or Halo
Board in advance of CES.
FIRST CLAIM FOR RELIEF
(Infringement under 35 U.S.C. 271 of the Equalia Patent against All Defendants)
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On information and belief, Defendants intend to exhibit and offer for sale the
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Plaintiffs incorporate by reference all allegations contained in the foregoing
paragraphs as through fully set forth herein.

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Defendants have infringed, and continue to infringe, the Equalia Patent.
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Defendants, without authorization from Equalia, have made, used, offered for sale, sold, and/or
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incorporated in or into the United States, and continues to make, use, offer for sale, sell, and/or
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import in or into the United States, products having designs which are substantially the same as
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the ornamental design of the Equalia Patent and that infringe the Equalia Patent.
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50.
Defendants' actions constitute infringement of the Equalia Patent in violation of 35
U.S.C. 271.
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Defendants' infringement of Equalia's rights under the Equalia Patent has and will
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continue to damage Equalia's business, causing irreparable harm, for which there is no adequate
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remedy at law, unless Defendants are enjoined by this Court.
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52.
Defendants have willfully infringed the Equalia Patent, entitling Equalia to
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increased damages under 35 U.S.C. 284 and to attorney's fees and costs incurred in prosecuting
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this action under 35 U.S.C. 285.
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53.
Alternatively, Equalia is entitled to recover Defendants' total profits from their sale
of the Infringing Products under 35 U.S.C. 289.
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SECOND CLAIM FOR RELIEF
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(Unfair and Deceptive Trade Practices under 15 U.S.C. 45 against All Defendants)
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54.
Plaintiffs incorporate by reference all allegations contained in the foregoing
paragraphs as through fully set forth herein.

55.
Since the Equalia Patent was issued by the USPTO, it has continuously been the
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Plaintiffs allege, on information and belief that Defendants have been making,
using, and/or selling or offering for sale products embodying the Equalia Patent in the United
States, and have consequently been engaged in unfair and deceptive trade practices and unfair
competition against Plaintiffs to Plaintiff's irreparable damage.
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property of Equalia.
57.
Defendants' actions constitute unfair and deceptive trade practices against Equalia
in violation of 15 U.S.C. 45.

58.
Defendants' unfair and deceptive trade practices utilizing the Equalia Patent has
and will continue to damage Equalia's business, causing irreparable harm, for which there is no
adequate remedy at law, unless Defendants are enjoined by this Court.
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REQUEST FOR RELIEF

Wherefore, Plaintiffs Equalia, LLC and Hoverboard Technologies Corporation request
that this Court grant the following relief:
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1. A judgment that Defendants infringe the Equalia Patent;
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2. A preliminary and permanent injunction enjoining Defendants, and all persons acting in
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concert with Defendants, from infringing the Equalia Patent, including but not limited to making,
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using, selling, offering for sale, and importing the Infringing Products;
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3. A judgment and order requiring Defendants to pay Equalia a reasonable royalty for
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infringement of the Equalia Patent pursuant to 35 U.S.C. 284, or the total profit made by
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Defendants from their infringement of the Equalia Patent pursuant to 35 U.S.C. 289;
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4. A judgment and order requiring Defendants to pay Equalia supplemental damages or
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profits for any continuing post-verdict infringement up until entry of the final judgment, with an
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accounting, as needed;
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5. A judgment and order requiring Defendants to pay Equalia increased damages up to three
times the amount found or assessed pursuant to 35 U.S.C. 284;
6. A judgment and order requiring Defendants to pay Equalia pre-judgment and postjudgment interest on any damages or profits awarded;
7. A determination that this action is an exceptional case pursuant to 35 U.S.C. 285;
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8. An award of Equalia's attorneys' fees for bringing and prosecuting this action;
9. An aware of Equalia's costs and expenses incurred in bringing and prosecuting this action;
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and
10. Such further and additional relief as this Court and/or a jury deems just and proper.
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Dated: December 9, 2016
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By: /s/ Timothy J. Lepore
STEPHEN J. ERIGERO
TIMOTHY J. LEPORE
LAEL D. ANDARA
MARIE E. SOBIESKI
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DEMAND FOR JURY TRIAL
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Plaintiffs hereby demand a jury trial.
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Dated: December 9, 2016
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By: /s/ Timothy J. Lepore

STEPHEN J. ERIGERO
TIMOTHY J. LEPORE
LAEL D. ANDARA
MARIE E. SOBIESKI
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Case 2:16-cv-02851-RFB-CWH Document 1-1 Filed 12/09/16 Page 1 of 2
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Las Vegas
STEPHEN J. ERIGERO (SBN 11562)

TIMOTHY J. LEPORE (SBN 13908)
LAEL D. ANDARA (California SBN 215416)
3753 Howard Hughes Pkwy., Suite 200
Las Vegas, NV 89169
Telephone:
(702) 954-8300
Facsimile:
(650) 780-1701
Email:
stephen.erigero@rmkb.com
timothy.lepore@rmkb.com
lael.andara@rmkb.com
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DISTRICT OF NEVADA
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EQUALIA, LLC, a California limited

liability company, and HOVERBOARD
TECHNOLOGIES CORPORATION, a
CASE NO.
INDEX OF EXHIBITS TO COMPLAINT
FOR:
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Plaintiffs,
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(1) PATENT INFRINGEMENT UNDER 35

U.S.C. 271; and
v.
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KUSHGO LLC dba HALO BOARD, a

California limited liability company;
HALO BOARD LLC, an Oregon limited
liability company; ARTHUR
ANDREASYAN, an individual; and
SHENZHEN WINDGOO INTELLIGENT
TECHNOLOGY CO. LTD., a foreign
company,
(2) UNFAIR AND DECEPTIVE TRADE

PRACTICES UNDER 15 U.S.C. 45.
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Defendants.
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EXHIBIT
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United States Design Patent No. D786,252
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United States Patent No. 9,211,470
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Examples of the Equalia Hoverboard in Media
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HaloBoard Website Screenshots
4830-9789-7021.1
DESCRIPTION
INDEX OF EXHIBITS
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EXHIBIT
DESCRIPTION
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E
HALO BOARD Trademark Application
Email Chain with Windgoo Representative
Innovioboard Instagram Screenshot
Comparison of Equaila Hoverboard and Infringing Products
HaloBoard Dealer Signup Screenshot
HaloBoard CES Announcements
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4830-9789-7021.1
-2-
INDEX OF EXHIBITS
EXHIBIT A
United States Design Patent
No. D786,252
EXHIBIT B
United States Patent No.
9,211,470

US0092.11470B2
(12) United States Patent

Bigler
(10) Patent No.:

(45) Date of Patent:
6,050,357 A.
(54) PITCH-PROPELLED VEHICLE

(71) Applicant: Equalia LLC, Sunnyvale, CA (US)
6,302,230
6,311,795
6,367,817
6,408,240
6,581,714
6,651,763
6,651,766
6,796,394
6,796,396
6,827,163
6,848,527
6,866,107
6,874,591
7,172,044
7,370.713
7,467,681
7,479,097
7,481,291
7,739,076
7,811,217
7,840,378
(72) Inventor: Robert A. Bigler, Cupertino, CA (US)

(73) Assignee: Equalia LLC., Sunnyvale, CA (US)
(*) Notice:
Subject to any disclaimer, the term of this

patent is extended or adjusted under 35
U.S.C. 154(b) by 0 days.
(21) Appl. No.: 14/058,937

(22) Filed:
Oct. 21, 2013
(65)
Prior Publication Data
|US 2015/0107922 A1
Apr. 23, 2015
Dec. 15, 2015
4/2000 Staelin et al.
10/2001
11/2001
4/2002
6/2002
6/2003
1 1/2003
1 1/2003
9/2004
9/2004
12/2004
2/2005
3/2005
4/2005
2/2007
5/2008
12/2008
1/2009
1/2009
6/2010
10/2010
1 1/2010
Kamen et al. ................. 180/171

Skotnikov et al.
Kamen et al. .............. 280/5,507
Morrell et al. .................. 70 1/82
Field et al. .....
... 180/333
Kamen et al. ......
... 180/171
Kamen et al. ..
... 180/218
Lin ................
... 180/181
Kamen et al. ......
... 180/272
Amsbury et al. ..
... 180/7.1
Nelson ................... ... 180/181
Heinzmann et al.
... 180/7.1
Morrell et al. .....
... 180/179
Bouvet ........
... 180/181
Kamen .......
... 180/7.1
Hiramatsu .........
... 180/188
Rosborough et al.
... 482/146
Nishikawa .........
... 180/218
Vocket al. ..
... 702/182
Odien .........
... 482/147
Vock et al. .................... 702/182
(Continued)
(51) Int. Cl.

A63C 17/12
A63C H 7/OH
A63C H 7/08
(2006.01)
(2006.01)
(2006.01)
(52) U.S. CI.

CPC ............... A63C 17/12 (2013.01); A63C 17/016
(2013.01); A63C 17/08 (2013.01)

(58) Field of Classification Search
USPC ................................ 180/181; 280/78, 87,042
See application file for complete search history.

(56)
References Cited
|U.S. PATENT DOCUMENTS
4,073,356
4,106,786
4,795,181
5,701,965
5,791,425
5,839,737
5,971,091
6,017,297
B1 *
B1
B1 *
B1*
B1*
B1 *
B2 *
B1*
B2 *
B2 *
B2 *
B2 *
B2 *
B2 *
B1*
B2 *
B2 *
B2 *
B1*
B2 *
B2 *
US 9,211,470 B2
A
A
A
A
A
A
A
A
* 2/1978 Schlicht ........................ 180/181

* 8/1978 Talbott .............................. 280/8
* 1/1989 Armstrong ...
. 280/87,042
* 12/1997 Kamen et al. ....
... 180/7.1
* 8/1998 Kamen et al. .................. 180/7.1
* 11/1998 Kruczek ..........
. 280/11.115
* 10/1999 Kamen et al. ................. 180/218
* 1/2000 Collins ......................... 482/146
FOREIGN PATENT DOCUMENTS

WO
2012113011 A1
8/2012
Primary Examiner Jeffrey J Restifo

(74) Attorney, Agent, or Firm Haverstock & Owens LLP
(57)
ABSTRACT
A method, system and apparatus for carrying a user including

a board for supporting the user, a ground-contacting member
coupled with the board, a motorized drive assembly coupled
with the ground-contacting member and one or more sensors
coupled with the drive assembly. In operation, the drive
assembly adjusts the velocity of the ground-contacting mem
ber based on one or more distances of the board from a surface
below the board as detected by the sensors. As a result, the

system is able to maintain a desired velocity when ascending,
descending or traversing uneven ground without the need for
excessive and sometimes impossible tilting of the board.
26 Claims, 7 Drawing Sheets
US 9,211,470 B2
Page 2
(56)
References Cited
|U.S. PATENT DOCUMENTS
8,170,780
8.256,545
8,467,941
8,562,386
B2 * 5/2012
B2 * 9/2012
B2 * 6/2013
B2 * 10/2013
Field et al. .................... 701/124

Oikawa ....
180/65. 1
Field et al. ...................... 70 1/49
Carlson et al. ................ 446/431
8,616,313 B2 * 12/2013 Simeray et al. ............ 180/65.51

..., 702/142
8,731,865 B2 + 5/2014 Vocket al. ...
2004/0065494 A1 * 4/2004 Nelson .......................... 180/181
2006/0012141 A1
1/2006 Bouvet
2011/0295454 A1 12/2011 Meyers
* cited by examiner
U.S. Patent
Dec. 15, 2015
Sheet 1 of 7
US 9,211,470 B2
U.S. Patent
Dec. 15, 2015
Sheet 2 of 7
US 9,211,470 B2
f
23
U.S. Patent
Dec. 15, 2015
Sheet 3 of 7
US 9,211,470 B2
9 0|
U.S. Patent
Dec. 15, 2015
Sheet 4 of 7
US 9,211,470 B2
U.S. Patent
Dec. 15, 2015
Sheet 5 of 7
US 9,211,470 B2
U.S. Patent
Dec. 15, 2015
Sheet 6 of 7
202
204
2 06
US 9,211,470 B2
o 8
20
220
I/O | OP
Interface
HW
Bus
Operation
230
Protocol
Module
Storage
212
Fig. 2
8
U.S. Patent
Dec. 15, 2015
Sheet 7 of 7
A user/rider assumes a position on the board
US 9,211,470 B2
302
Of the Vehicle.
The user/rider operates the vehicle by causing the board

to tilt or pitch with respect to the surface such that the
motors cause the ground-contacting member to propel
the vehicle in the direction of the tilt/pitch.
304
Fig. 3
US 9,211,470 B2
1
PITCH-PROPELLED VEHICLE
FIELD OF THE INVENTION
The present invention relates to the field of vehicles. More

specifically, the present invention relates to the field of
vehicles having pitch-sense based motion.
BACKGROUND OF THE INVENTION

10
There are many known types of commercial and recre

ational vehicles for transporting people. Most of these
vehicles are designed to be stable with respect to tipping by
incorporating three or four wheels that balance and support
the user and the remainder of the vehicle. For example, a
15
skateboard is a well known vehicle that uses four wheels that
are positioned to create a stable platform for the board and the
user in all directions. However, many users enjoy the chal
lenge of riding at least partially unstable vehicles. A scooteris
an example of such a partially unstable vehicle because it is
stable in the direction of the alignment of the wheels, but can
tip side to side perpendicular to the alignment. Similarly, a
unicycle, which uses a single wheel, is unstable with respect
to tipping in all directions.
Recently, vehicles, such as a segway, have been created that
utilize balance assisting systems to not only help stabilize an
otherwise unstable vehicle, but also utilize the tipping of the
vehicle to control its movement. Although this stabilization
sections of a discontinuous wheel. The vehicle is able to

20
25
30
35
SUMMARY OF THE INVENTION
A vehicle for carrying a user including a board for support

ing the user, a ground-contacting member coupled with the
board, a motorized drive assembly coupled with the ground
contacting member and one or more sensors coupled with the
drive assembly. In operation, the drive assembly adjusts the
velocity of the ground-contacting member based on one or
45
50
detected by the sensors and operating the vehicle by causing

the board to tilt with respect to the surface. In some embodi
ments, the board is elongated along a dimension in a fore-aft
plane that aligns with the forward and reverse directions of
travel of the vehicle. In some embodiments, one or more fore
55
detected by the sensors. In some embodiments, the board is

elongated along a dimension in a fore-aft plane that aligns
sensors of the sensors are positioned at the fore end of the

elongated dimension of the board and one or more aft sensors
of the sensors are positioned at the aft end of the elongated
dimension of the board. In some embodiments, the drive
with the forward and reverse directions of travel of the

60
the sensors are positioned at the fore end of the elongated

dimension of the board and one or more aft sensors of the
sensors are positioned at the aft end of the elongated dimen

sion of the board. In some embodiments, the drive assembly
adjusts the velocity of the ground-contacting member based
on the one or more distances by using the distances to calcu
late a pitch of the board with respect to the surface and
Another aspect of the present application relates to a

method of carrying a user. The method comprises assuming a
position on a vehicle comprising a board for supporting the
user, a single ground-contacting member coupled with the
drive assembly, wherein the drive assembly adjusts the veloc
ity of the ground-contacting member based on one or more
distances of the board from a surface below the board as
vehicle. In some embodiments, one or more fore sensors of
the sensors are acoustic sensors and the drive assembly com
prises a direct drive motor that drives the ground-contacting
member. In some embodiments, the drive assembly delays
each adjustment of the velocity of the ground-contacting
member for a period, wherein the length of the period for each
adjustment is based on a calculated time that the ground
contacting member will contact a point on the surface on
which the adjustment was based. In some embodiments, the
vehicle further comprises one or more rider sensors coupled
to the ground-contacting member, wherein the rider sensors
sense when a user or payload is on the board based on a force
on the board by the ground-contacting member detected by
the rider sensors.
40
more distances of the board from a surface below the board as
detected by the sensors. As a result, the system is able to

maintain a desired velocity when ascending, descending or
traversing uneven ground without the need for excessive and
sometimes impossible tilting of the board.
In one aspect the present application relates to a vehicle for
carrying a user. The vehicle comprises a board for supporting
the user, a ground-contacting member coupled with the
drive assembly, wherein the drive assembly adjusts the veloc
further comprise one or more locking fasteners coupled to the

board, wherein the ground-contacting member is able to
selectively couple and decouple from the board via the fas
teners by locking or unlocking the fasteners. The vehicle is
able to further comprise one or more grips coupled to the top
of the board such that the grips protruding above the board for
a user to lift the board with their feet. In some embodiments,
and movement control works well on even surfaces, it is
unable to adequately operate on or adjust to uneven surfaces

which are often encountered when riding such a vehicle.
Further, they are able to be both complicated and expensive in
design, which increases the likelihood of breaking down, the
cost of repairs and the overall cost of manufacture.
2
applying a force to the ground-contacting member in order to
achieve a predefined velocity of the ground-contacting mem
ber that corresponds to the pitch. In some embodiments, the
pitch is calculated by determining a difference between one or
more distances and an average of two or more of the distances
such that the drive assembly adjusts for unevenness in the
surface. In some embodiments, the board as balanced by the
ground-contacting memberis unstable with respect to tipping
along the fore-aft plane when the motorized drive assembly is
not in operation, and the motorized drive assembly is config
ured to automatically balance the board with respect to tip
ping along the fore-aft plane when the motorized drive assem
bly is in operation. The vehicle is able to further comprise a
vehicle locking module operatively coupled with the drive
assembly, wherein the vehicle locking module prevents
operation of the drive assembly when locked. In some
embodiments, the ground-contacting member comprises one
of the group consisting of a wheel, a ball, a tread and arcuate
65
assembly adjusts the velocity of the ground-contacting mem

ber based on the one or more distances by using the distances
to calculatea pitch of the board with respect to the surface and
applying a force to the ground-contacting member in order to
achieve a predefined velocity of the ground-contacting mem
ber that corresponds to the pitch. In some embodiments, the
pitch is calculated by determining a difference between one or
more distances and an average of two or more of the distances
such that the drive assembly adjusts for unevenness in the
surface. In some embodiments, the board as balanced by the
10
US 9,211,470 B2
3
ground-contacting member is unstable with respect to tipping
along the fore-aft plane when the motorized drive assembly is
not in operation, and the motorized drive assembly is config
ured to automatically balance the board with respect to tip
ping along the fore-aft plane when the motorized drive assem
bly is in operation. In some embodiments, the vehicle further
comprises a vehicle locking module operatively coupled with
the drive assembly, wherein the vehicle locking module pre
vents operation of the drive assembly when locked. In some
embodiments, the ground-contacting member comprises one
of the group consisting of a wheel, a ball, a tread and arcuate
4
FIG. 1E illustrates a bottom view of a pitch propelled
vehicle according to some embodiments.
FIG. 2 illustrates a block diagram of an exemplary control
ler according to some embodiments.
FIG.3 illustrates a flow chart of a method of carrying a user
according to some embodiments.
DETAILED DESCRIPTION
10
sections of a discontinuous wheel. The method is able to
further comprise selectively coupling or decoupling the

ground-contacting member from the board via one or more
locking fasteners coupled to the board by locking or unlock
ing the fasteners. In some embodiments, the vehicle further
comprises one or more grips coupled to the top of the board
such that the grips protruding above the board for a user to lift
the board with their feet. In some embodiments, the sensors
are acoustic sensors and the drive assembly comprises a direct

drive motor that drives the ground-contacting member. In
some embodiments, the drive assembly delays each adjust
ment of the velocity of the ground-contacting member for a
period, wherein the length of the period for each adjustmentis
based on a calculated time that the ground-contacting mem
ber will contact a point on the surface on which the adjust
15

20
30
SOI. S.
In yet another aspect, the present application relates to a

vehicle for carrying a user. The vehicle comprises an elon
gated board for supporting the user, wherein the board is
elongated along a dimension in a fore-aft plane that aligns
35
with the forward and reverse directions of travel of the
vehicle, a single ground-contacting member coupled with the

board, one or more sensors coupled to the board and a motor
ized drive assembly operatively coupled with the ground
contacting member and the sensors, wherein the drive assem
bly adjusts the velocity of the ground-contacting member
based on a pitch of the board as indicated by one or more
distances of the board from a surface below the board
40
45
detected by the sensors, wherein the motorized drive assem

bly automatically stabilizes the board about the ground-con
tacting member such that desired distances between the sur
face and the fore end and the surface and the aft end of the
board are maintained, wherein the desired distances are
50
dynamically determined as an average current distance

detected between the fore end of the board and the surface and
the aft end of the board and the surface. In some embodi
ments, the pitch is defined as a degree of deviation from an

angle of the board about the ground-contacting memberwhen
automatically stabilized by the drive assembly.
55
BRIEF DESCRIPTION OF THE DRAWINGS
FIG. 1A illustrates a side view of a pitch propelled vehicle

FIG. 1B illustrates a top perspective view of a pitch pro
pelled vehicle according to some embodiments.
FIG. 1C illustrates a bottom perspective view of a pitch
propelled vehicle according to some embodiments.
FIG. 1D illustrates a top view of a pitch propelled vehicle
detected by the sensors. As a result, the vehicle provides the

advantage of altering the pitch/velocity relationship when
traveling uphill, downhill or on uneven surfaces that make a
pitch/velocity relationship with respect to gravity untenable.
As used herein the term ground is able to be the earth, the
floor or any other surface over which the vehicle 100 is able to
travel.
25
ment was based. In some embodiments, the vehicle further
comprises one or more rider sensors coupled to the ground

contacting member, wherein the rider sensors sense when a
user or payload is on the board based on a force on the board
by the ground-contacting member detected by the rider sen
Embodiments of a system, device and method of a pitch

propelled vehicle including a board for supporting the user, a
ground-contacting member coupled with the board, a motor
ized drive assembly coupled with the ground-contacting
member and one or more sensors coupled with the drive
assembly. In operation, the drive assembly adjusts the veloc
60
65
FIGS. 1A-1E illustrate a pitch-propelled vehicle 100

according to some embodiments. As shown in FIGS. 1A-1E,
the vehicle 100 comprises a platform or board 102, a guard
103, a ground-contacting member 104, a drive assembly 106
(a-g), one or more grips 108 and one or more scrapers 109 all
operatively coupled together. Alternatively, one or more of
the above components are able to be omitted. The board 102
is able to be rigid and detachably coupled to the ground
contacting member 104 such that when balanced the ground
contacting member 104 is able to hold/support the board 102
and the board 102 is able to support the rider(s) above the
ground. In some embodiments, the board 102 comprises a
member fastener assembly 105 that detachably couples the
ground-contacting member 104 and/or some or all of the
drive assembly 106 (a-g) to the board 102. As a result, the
ground-contacting member 104 is able to be selectively sepa
rated from or coupled to the board 102 by unlocking or
locking the member fastener 105. This locking/unlocking
mechanism of the member fastener 105 is able to be a key
lock, a snap-fit connection, screw on/off or other types of
fasteners that are able to hold the ground-contacting member
104 and/or some or all of the drive assembly 106 (a-g) in a
locked position with respect to the board 102. Thus, the
vehicle 100 provides the advantage of easily replacing or
repairing the board 102 and/or the ground-contacting mem
ber 104 using the member fastener 105.
As shown in FIG. 1A, the guard 103 shields a rider from the
top of the ground-contacting member 104 as it protrudes
through the board 102. This provides the advantage of pre
venting a rider from being injured by stepping on or otherwise
contacting the ground-contacting member 104. Although as
shown, the guard 103 covers a portion of the sides of the
ground-contacting member 104 as it protrudes through the
top of the board 102, it is understood that more or less (e.g. all)
of the ground-contacting member 104 is able to be shielded
by the guard 103. As shown in FIG. 1A, two scrapers 109 are
positioned on either side of the ground-contacting member
104 such that the scrapers 109 are adjacent to and/or surround
lower ends of the member 104. As a result, the scrapers 109
are able to protect the vehicle 100 from debris such as rocks
from entering the vehicle 100 between the ground-contacting
member 104 and the board 102. In particular, the scrapers 109
are able to be sized to fill any gap between the ground
11
US 9,211,470 B2
5
contacting member 104 and the underside of the board 102
and/or be positioned as close as possible to the ground-con
tacting member 104 to block debris from entering the vehicle
100 through such a gap. Further, it is contemplated that the
guard 103 and/or grips 108 are able to be similarly positioned
on the top of the board 102 to block debris from entering the
vehicle 100 through a gap between the board 102 and the
ground-contacting member 104 on the top side of the board
102. Additionally, it is contemplated that more or less than
two scrapers 109 are able to be used.
ate sections of a wheel or ball, clusters of wheels, tracks,

10
The board 102 is able to have a thickness and broad and/or
substantially flat top/bottom surface for receiving/supporting

the feet of a rider. In some embodiments, the board 102 is able
to have an oblong top surface with an elongated dimension in

a fore/aft direction similar to the board of a skateboard. In
15
particular, this elongated dimension is able to substantially

align with the orientation of the ground-contacting member
104 such that a rider is able to ride the board 102 sideways to
the direction of travel like one would ride a skateboard. Alter
natively, the top surface of the board 102 is able to be sub

stantially circular, ovular, rectangular, square or otherwise
shaped. As shown in FIGS. 1A-1E, the board 102 is able to
angle upwards at the fore and aft ends in order to provide
better control to a rider and to prevent the feet of the rider from
sliding off the board 102. Alternatively, the board 102 is able
to be flat or bend downwards or upwards at one or both of the
ends at the same or different angles. In some embodiments,
the board 102 is at least partially hollow such that the board
102 is able to house and protect some or all of the drive
assembly 106, the grips 108 and/or the ground-contacting
member 104. Alternatively, the board 102 is able to be solid.
As shown in FIGS. 1B and 1D, the board 102 is able to have
a textured surface 112 and/or include textured pads 112
coupled to the top surface of the board 102 in order to improve
20
traction between the feet of the rider and the surface of the
board 102.
35
As shown in FIGS. 1A-1E, the vehicle 100 comprises two

grips 108 positioned adjacent to the member fastener 105 on
the fore and aft ends of the board 102. Alternatively, any
number of grips 108 are able to be used and positioned on any
portion of the board 102. For example, the board 102 is able
to have multiple coupling locations configured to releasably
couple to one or more grips 108 such that a user is able to
select an ideal location and number of grips to releasably
attach to the board 102. Alternatively or in addition, the
coupling locations are able to be adjustable such that for each
coupling location (and/or grip 108) a user is able to adjust the
position of the grip from a range of positions enabled by the
coupling location. Thus, the board 102 and grips 108 provide
the advantage of enabling a user to adjust the width, orienta
tion, number and/or other characteristics of the grips 108 in
order to best grip the vehicle 100 with their feet. In the same
manner, one or more of the grips 108 are able to be replaced
on the board 102 with grips 108 of different sizes, colors,
shapes and other characteristics as desired. In some embodi
ments, as shown in FIGS. 1A-1E, one or more of the grips 108
are able to be wholly or partially textured in order to increase
the ability of a user to hold onto the grips 108 with their feet.
Alternatively, the grips 108 are able to be omitted.
As shown in FIGS. 1A-1E, the ground-contacting member
104 is able to comprise a single wheel. In some embodiments,
the ground-contacting member is able to be a wheel or wheels
25
30
40
treads or other types of ground-contacting members well

known in the art. Further, although only a single ground
contacting member 104 is shown, a plurality of ground-con
tacting members 104 are contemplated. In some embodi
ments, the ground-contacting member 104 is able to comprise
a plurality of grooves for operable coupling to the drive
assembly 106 in order to be rotated and/or otherwise driven
by the drive assembly 106. In such embodiments, the member
104 is able to be off-center with respect to the board 102,
which enables the board 102 to be closer to the ground when
supported above the ground by the member 104. Alternatively
or in addition, other power transfer mechanisms are able to be
used such as an axle wherein the board 102 is centered about
the axle and/or other mechanisms well known in the art.
As shown in FIGS. 1A-1E, the drive assembly 106 com

prises one or more motors 106a, batteries 106b, controllers
106c, rider sensors 106d, ground sensors 106e and/or user
displays 106?, safety elements 106g all operably coupled
together in order to operate the vehicle 100. Alternatively, the
drive assembly 106 is able to comprise more or less compo
ments and/or more or less quantities of each component.
Although shown in particular positions within FIGS. 1A-1E,
it is understood that one or more of the components of the
drive assembly 106 are able to be positioned anywhere on or
within the board 102. For example, in some embodiments
only a single user display 106f is able to be used or the user
displays 106fare able to be omitted. The drive assembly 106
is housed by the board 102. As a result, the board 102 is able
to protect the drive assembly 106 from damage. Alternatively,
one or more components of the drive assembly 106 are able to
be fully or partially exposed. Although as shown in FIGS. 1C
and 1E the vehicle 100 comprises a finite number of motors
106a, batteries 106b, controllers 106c, rider sensors 106d,
ground sensors 106e, user displays 106f and/or safety ele

ments 106g, it is understood that more or less of each are
contemplated including the omission of one or more of the
components.
45
50
The one or more motors 106a are operably and/or

mechanically coupled to the ground-contacting member 104
in order to cause the ground-contacting member 104 to rotate
and thereby stabilize and move the vehicle 100. In some
embodiments, the motors 106a are able to engage or couple
with the plurality of grooves within the ground-contacting
member 104 in order to translate motion/power of the motors
106a to the ground-contacting member 104. For example, one
or more of the motors 106a are able to be electric and/or direct
55
drive motors (e.g. motors with a direct drive mechanism that

couples to the member without any reductions such as a
gearbox) that directly mechanically couple with the grooves
of the member 104 in order to cause the member 104 to
60
that have a small width such as 1.5 inches or less, or /th the
width of the board 102 or less, which enables the vehicle 100
to more easily be turned by tilting the board 102 and the wheel
104 to the left or the right side. Additionally, because the
member 104 is detachably coupled to the board 102 as
6
described above, members 104 having different widths and/or
other dimensions are able to be interchanged as desired to
adjust the characteristics of the balance and turning of the
ground-contacting member 104 and thereby the vehicle 100.
Alternatively, the ground-contacting member 104 is able to
comprise, individually or in combination, wheels, balls, arcu
65
rotate/actuate as controlled by the controllers 106c. As a

result, in such embodiments the vehicle 100 is able to provide
the advantages of increased efficiency due to no intermediary
power loss, reduced noise and longer lifetime due to less/
simpler parts, high torque at lower revolutions perminute and
faster/precise positioning by eliminating mechanical back
lash, hysteresis and elasticity. Alternatively, one or more of
the motors 106a are able to be non-direct drive and/or electric
motors such as combustion, hydraulic or other types of direct

or indirect drive motors.
12
13
US 9,211,470 B2
9
positioned at the fore and aft ends of the board 102. Alterna
tively, the safety elements 106g are able to be positioned on
other portions of the board 102.
The controllers 106c are operably coupled to the motors
106a, the rider sensors 106d, the ground sensors 106e, the
user displays 106f and/or safety elements 106g in order to
control their operation according to a predefined operation
protocol module as described below. In some embodiments,
the controllers 106c and one or more other components of the
vehicle 100 are able to be coupled together by a controller
area network (CAN) bus. Alternatively, other networks are
able to be used. FIG. 2 illustrates a block diagram of an
exemplary controller 106c according to some embodiments.
As shown in FIG. 2, the controller 106c comprises a network
interface 202, a memory 204, a processor 206, I/O device(s)
208, a bus 210 and a storage device 212. Alternatively, one or
more of the illustrated components are able to be removed or
substituted for other components well known in the art. The
choice of processor is not critical as long as a suitable pro
cessor with sufficient speed is chosen. The memory 204 is
able to be any conventional computer memory known in the
art. The storage device 212 is able to include a hard drive,
CDROM, CDRW, DVD, DVDRW, flash memory card or any
other storage device. The controller 106c is able to include
one or more network interfaces 202. An example of a network
10
15
board 102 and the surface as detected by one or more of the

ground sensors 106e. Alternatively, the board pitch is able to
be dynamically determined by the distance detected between
only one end of the board 102 and the surface. Alternatively,
the board pitch is able to be dynamically determined based on
25
the difference between the current distance detected between

the fore end of the board 102 and the surface and the current
distance detected between the aftend of the board 102 and the
surface.
30
sideration detected changes the in surface that are about to be

traversed by the ground-contacting member 104 when adjust
ing the force applied to the ground-contacting member 104 in
order to achieve the desired velocity, acceleration and/or
torque. In particular, because the sensors 106e are a distance
in front (and behind) the ground-contacting member 104,
they are able to detect (or map) characteristics of and changes
in the ground/surface before the ground-contacting member
104 reaches the changes. As a result, the controller 106c is
able to adjust the command signals sent to the ground-con
tacting member 104 based on the characteristics/changes in
the ground before the ground-contacting member 104 has
encountered the characteristics/changes. In such embodi
In some embodiments, the controller 106c takes into con
35
40
ments, the controller 106c is able to determine a time in the

45
member 104 relative to the board 102 oranother static marker.
These components are well known in the art and not described
herein for the sake of brevity.
In operation, when implementing the operation protocol,
the controller 106c determines the distance between one or
both the fore and aft ends of the board 102 and the ground (or
surface below the board 102) based on the input from one or
more of the ground sensors 106e. Subsequently, based on the
determined distance(s), the controller 106c calculates a pitch
of the board 102 relative the ground and causes the motors
106a to apply a force to the ground-contacting member 104
based on the determined board pitch. For example, if the
controller 106c determines that the board 102 is pitched at a
first level, the controller 106c causes the ground-contacting
member 104 (via the motors 106a) to slow down, speed up
and/or reverse direction in order to approach and eventually
match a desired velocity, acceleration and/or torque associ
ated with the pitch of the first level. As a result, in general,
when a user leans to pitch the board 102 in the aft or fore
directions relative to the ground, the controller 106c will
cause the ground-contacting member 104 and thus the vehicle
100 to move (or reverse direction and then move) in the aft or
In some embodiments, the board pitch is dynamically

determined based on an average of the current distance
20
be included in the controller 106c. In some embodiments,
operation protocol hardware 220 is included, wherein the

hardware implements a portion or all of the operation proto
col. Although as shown in FIG. 2, the controller 106c includes
software 230 and hardware 220 for implementing the opera
tional protocol, the operation protocol is able to be imple
mented in hardware, firmware, software or any combination
thereof. Additionally, the controller 106c is able to comprise
one or more components not shown in FIG. 2 that enable the
controller 106c to perform commutation and other calcula
tions. For example, the controller 106c is able to comprise an
encoder for encoding the position of the ground-contacting
forward at the desired rate.

detected between the fore end of the board 102 and the surface
and the current distance detected between the aft end of the
interface includes a network card connected to an Ethernet or
other type of LAN. The I/O device(s) 208 are able to include
one or more of the following: keyboard, mouse, monitor,
display, printer, modem, touchscreen, button interface and
other devices. The operation protocol 230 used to operate the
vehicle 100 is able to be stored in the storage device 212 and
memory 204 and processed as programs are typically pro
cessed. More or less components shown in FIG. 2 are able to
10
fore directions, respectively. As a result, the vehicle 100 pro
vides the advantage of compensating for changes in ground
level when determining the pitch of the board because the
board pitch is determined relative to the ground. This is
important when the vehicle 100 is traversing uneven surfaces
as they can limit the ability of the board to pitch. For example,
in systems where pitch is based on a deviation of the board
angle with respect to gravity, when going up hill it can
become difficult or impossible to keep the board pitched
forward because the hill/ground blocks further pitching. In
contrast, the pitch-propelled vehicle 100 described herein is
able to determine the pitch relative to the hill/ground such that
less forward pitch is still able to cause the vehicle 100 to move
50
55
60
65
future when the ground-contacting member 104 is expected

to reach the characteristics/changes and adjust the timing of
the control signals associated with the characteristics/
changes to correspond to the determined time. The time is
able to be determined based on the current position of the
ground-contacting member 104 relative to the characteristics/
changes and the velocity, acceleration and/or torque of the
ground-contacting member 104.
For example, if the controller 106c detects an upcoming
inclination of the surface (based on the current direction of
travel, a previously determined distance and the currently
determined distance between the surface and one or more of
the ground sensors 106e on leading side of the direction of

travel), the controller 106c is able to increase the amount of
force applied to the ground-contacting member 104 to com
pensate for the anticipated upcoming inclination. Similarly,
the force is able to be decreased to compensate for anticipated
upcoming declination. In other words, even if the current
detected pitch corresponds to a first force level, a higher or
lower force level is able to be applied in anticipation of the
detected or mapped characteristics/changes. As a result, the
vehicle 100 provides the advantage of providing predictive
control of the ground-contacting member 104 to compensate
for incoming obstacles and terrain.
14
15
US 9,211,470 B2
14
13
5. The vehicle of claim 1, further comprising a vehicle
locking module operatively coupled with the drive assembly,
wherein the vehicle locking module prevents operation of the
drive assembly when locked.
6. The vehicle of claim 1, wherein the ground-contacting
member comprises one of the group consisting of a wheel, a
15. The method of claim 14, wherein the board as balanced
ball, a tread and arcuate sections of a discontinuous wheel.
7. The vehicle of claim 1, further comprising one or more

locking fasteners coupled to the board, wherein the ground
contacting member is able to selectively couple and decouple
from the board via the fasteners by locking or unlocking the
10
17. The method of claim 13, wherein the vehicle further
fasteners.

grips coupled to the top of the board such that the grips
protruding above the board for a user to lift the board with
15
their feet.
9. The vehicle of claim 1, wherein the sensors are acoustic
sensors and the drive assembly comprises a direct drive motor

that drives the ground-contacting member.
10. The vehicle of claim 1, wherein the drive assembly
delays each adjustment of the velocity of the ground-contact
ing member for a period, wherein the length of the period for
each adjustment is based on a calculated time that the ground
which the adjustment was based.
rider sensors coupled to the ground-contacting member,
wherein the rider sensors sense when a user or payload is on
the board based on a force on the board by the ground
contacting member detected by the rider sensors.
12. A vehicle for carrying a user comprising:
a board for supporting the user;
a ground-contacting member coupled with the board;
a motorized drive assembly coupled with the ground-con
tacting member; and
one or more sensors coupled with the drive assembly,
wherein the drive assembly adjusts the velocity of the
ground-contacting member based on one or more dis
tances of the board from a surface below the board as
detected by the sensors, wherein one or more fore sen

sors of the sensors are positioned at the fore end of the
elongated dimension of the board and one or more aft
sensors of the sensors are positioned at the aft end of the
elongated dimension of the board.
13. A method for carrying a user comprising:
assuming a position on a vehicle comprising:
a single ground-contacting member coupled with the
board;
a motorized drive assembly coupled with the ground

contacting member; and
forward and reverse directions of travel of the vehicle.
comprises a vehicle locking module operatively coupled with

the drive assembly, wherein the vehicle locking module pre
vents operation of the drive assembly when locked.
18. The method of claim 13, wherein the ground-contact
ing member comprises one of the group consisting of a wheel,
a ball, a tread and arcuate sections of a discontinuous wheel.
20
19. The method of claim 13, further comprising selectively

coupling or decoupling the ground-contacting member from
the board via one or more locking fasteners coupled to the
board by locking or unlocking the fasteners.
25
comprises one or more grips coupled to the top of the board

such that the grips protruding above the board a user to lift the
board with their feet.
21. The method of claim 13, wherein the sensors are acous
35
tic sensors and the drive assembly comprises a direct drive

motor that drives the ground-contacting member.
22. The method of claim 13, wherein the drive assembly
delays each adjustment of the velocity of the ground-contact
ing member for a period, wherein the length of the period for
each adjustment is based on a calculated time that the ground
which the adjustment was based.
40
comprises one or more rider sensors coupled to the ground

contacting member, wherein the rider sensors sense when a
user or payload is on the board based on a force on the board
by the ground-contacting member detected by the rider sen
30
SOI. S.
45
24. A method for carrying a user comprising:

assuming a position on a vehicle comprising:
board;
50
a motorized drive assembly coupled with the ground

contacting member; and
55
detected by the sensors by using the distances to cal

culate a pitch of the board with respect to the surface
and applying a force to the ground-contacting mem
ber in order to achieve a predefined velocity of the
ground-contacting member that corresponds to the
pitch; and
operating the vehicle by causing the board to tilt with
respect to the surface.
14. The method of claim 13, wherein the board is elongated
along a dimension in a fore-aft plane that aligns with the
by the ground-contacting member is unstable with respect to

tipping along the fore-aft plane when the motorized drive
assembly is not in operation, and the motorized drive assem
bly is configured to automatically balance the board with
respect to tipping along the fore-aft plane when the motorized
drive assembly is in operation.
16. The method of claim 13, wherein the pitch is calculated
by determining a difference between the one or more dis
tances and an average of two or more of the distances such
that the drive assembly adjusts for unevenness in the surface.
60
detected by the sensors; and

operating the vehicle by causing the board to tilt with
respect to the surface, wherein one or more fore sensors
of the sensors are positioned at the fore end of the elon
gated dimension of the board and one or more aft sensors
of the sensors are positioned at the aft end of the elon
gated dimension of the board.
25. A vehicle for carrying a user comprising:
an elongated board for supporting the user, wherein the
board is elongated along a dimension in a fore-aft plane
that aligns with the forward and reverse directions of
travel of the vehicle:
65

board;
one or more sensors coupled to the board; and
16
US 9,211,470 B2
15
a motorized drive assembly operatively coupled with the
ground-contacting member and the sensors, wherein the
drive assembly adjusts the velocity of the ground-con
tacting member based on a pitch of the board as indi
cated by one or more distances of the board from a
surface below the board detected by the sensors;
wherein the motorized drive assembly automatically sta
bilizes the board about the ground-contacting member
such that desired distances between the surface and a
fore end and the surface and an aft end of the board are
16
10
maintained, wherein the desired distances are dynami

cally determined as an average current distance detected
between the fore end of the board and the surface and the
aft end of the board and the surface.
26. The vehicle of claim 25, wherein the pitch is defined as

a degree of deviation from an angle of the board about the
ground-contacting member when automatically stabilized by
the drive assembly.
15
17
EXHIBIT C
Examples of the Equalia
Hoverboard in Media
EXHIBIT D
HaloBoard Website
Screenshots
12/1/2016
Case 2:16-cv-02851-RFB-CWHHaloBoard|OfficialHaloBoard
Document 1-5 Filed 12/09/16 Page 2 of 9
OFFICIA L HA L OB OA RD
E V E RYO N ES D R E A M E L EC T R I C S K AT E B OA R D
PLAYVIDEO
BUYNOW
W O R RY- F R E E G U A R A N T E E
J USTSTEPON& GO
156POINTSAFETYINSPECTION
LEANFORWARDTOGO
SPEEDUPTO12MPH
SAFETYHOLOGRAMCERTIFICATE
ACTIONPACKEDBOARD
EXCLUSIVE8INCHTIRE
WILLNOTOVERHEATORMALFUNCTION
NEWHALORIDINGTECHNOLOGY
HALOLEDPATHWAYLIGHTS
CERTIFIEDFIRESAFESAMSUNGBATTERIES
HALOSENSORSSELF-BALANCETHEBOARD
PLAYMUSICONYOURHALOBOARD
https://www.haloboard.com/
B L UETOOTHMUSIC& MOR
1/6
12/1/2016
PA R T N E R S M A D E H A L O B O A R D T H E B E S T R A N K E D E L E C T R I C S K A T E B O A R D 2 0 1 7
C E R T I F I E D S A M S U N G B AT T E R I E S
B L U E T O O T H M U S I C P L AY B A C K
S A M E D AY F R E E S H I P P I N G
Halo Board and Halo Rover at the Surf Expo 2016!!
B OA RDS INT HEPRESS ST ORE SUPPORT 8 0 0 - 5 5 7 - 4 0 1 4
2/6
12/1/2016
HA L OB OA RD
L IFESTYL E
IT'S TIME
BUYNOW
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 2
1 1
2 8
7 FREESHIPPINGSAMEDAYFEDEX ORDERNOW
ZOOMTHROUGH
A IR
FEEL THE
S E N S AT I O N
3/6
12/1/2016
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 2
1 1
2 8
EVERYONES
DREA MB OA RD
EXPERIENCE
THE THRILL
BUYNOW
4/6
12/1/2016
IT' SCA L L ED
HA L OB OA RD
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 2
1 1
2 8
J OINTHE
FUTURE
G E T Y O U R S T O D AY
BUYNOW
5/6
12/1/2016
I N S TA G R A M
0:00 /0:15
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 2
1 1
2 8
0:00 /0:06
FOL L OW
A B OUTUS
PRIVA CYPOL ICY
J OINA FFIL IATEPROGRA M
TERMS
ONEWHEEL
HA L OB OA RDREVIEWS
EL ECTRICSK ATEB OA RD
HA L OB OA RD
B ECOMEADEA L ER
RETURNPOL ICY
SIGNUPTOGETTHELATESTONSALES,NEWRELEASESANDMORE
Enteryouremailaddress...
SIGNUP
2016HALOBOARD.
6/6
12/1/2016
HaloBoardTechnology
Case 2:16-cv-02851-RFB-CWH Document
1-5 Filed 12/09/16 Page 8 of 9
HA L OB OA RDTECHNOL OGY
HA L OB OA RD
ARTCOMESTOREALLIFEFORMWITHTHESMARTHALOBOARDTECHNOLOGY.WITHSTRATEGICALLYPLACEDMICROSENSORSTHEHALOBOARD
RECOGNIZESYOURMINIMALMOVEMENTSTOLEARNYOURIDINGBEHAVIOR.WITHTIMEITWILLADJUSTTOYOURRIDINGBEHAVIORASRECOGNIZESYO
CONSTANTMOVEMENTS.RANKEDTHEMOSTINTELLIGENTELECTRICSKATEBOARD,THESMARTHALOTECHNOLOGYDOESJUSTTHIS.
FOL L OW
A B OUTUS
PRIVA CYPOL ICY
TERMS
ONEWHEEL
HA L OB OA RD
B ECOMEADEA L ER
RETURNPOL ICY
SIGNUP
2016HALOBOARD.
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 5
4 0
1 0
0
https://www.haloboard.com/pages/halo-board-technology
1/1
EXHIBIT E
HALO BOARD Trademark
Application
Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number.
PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp 02/28/2018)
Trademark/Service Mark Application, Principal Register

TEAS Plus Application
Serial Number: 87017860
Filing Date: 04/28/2016
NOTE: Data fields with the * are mandatory under TEAS Plus. The wording "(if applicable)" appears where the field is only mandatory
under the facts of the particular application.
The table below presents the data as entered.

Input Field
TEAS Plus
Entered
YES
MARK INFORMATION
*MARK
HALO BOARD
*STANDARD CHARACTERS
YES
USPTO-GENERATED IMAGE
YES
LITERAL ELEMENT
HALO BOARD
*MARK STATEMENT
The mark consists of standard characters, without claim to any

particular font, style, size, or color.
REGISTER
Principal
APPLICANT INFORMATION
*OWNER OF MARK
Kushgo LLC
*STREET
PO BOX 3940 Laurel Canyon Boulevard #376
*CITY
Studio City
*STATE
(Required for U.S. applicants)
California
*COUNTRY
United States
*ZIP/POSTAL CODE
(Required for U.S. applicants)
91604
PHONE
8005789456
EMAIL ADDRESS
support@haloboard.com
AUTHORIZED TO COMMUNICATE VIA EMAIL
Yes
WEBSITE ADDRESS
www.haloboard.com
LEGAL ENTITY INFORMATION

*TYPE
LIMITED LIABILITY COMPANY
* STATE/COUNTRY WHERE LEGALLY ORGANIZED
California
GOODS AND/OR SERVICES AND BASIS INFORMATION

* INTERNATIONAL CLASS
012

*IDENTIFICATION
Vehicles, namely, electronically motorized skateboards
*FILING BASIS
SECTION 1(a)
FIRST USE ANYWHERE DATE
At least as early as 04/25/2016
FIRST USE IN COMMERCE DATE
At least as early as 04/25/2016
SPECIMEN
FILE NAME(S)
\\TICRS\EXPORT16\IMAGEOUT
16\870\178\87017860\xml1\ FTK0003.JPG
SPECIMEN DESCRIPTION
screenshot of the applicants website
ADDITIONAL STATEMENTS INFORMATION

*TRANSLATION
(if applicable)
*TRANSLITERATION
(if applicable)
*CLAIMED PRIOR REGISTRATION
(if applicable)
*CONSENT (NAME/LIKENESS)
(if applicable)
*CONCURRENT USE CLAIM
(if applicable)
CORRESPONDENCE INFORMATION
*NAME
Kushgo LLC
FIRM NAME
Kushgo LLC
*STREET
*CITY
Studio City
*STATE
(Required for U.S. addresses)
California
*COUNTRY
United States
*ZIP/POSTAL CODE
91604
*EMAIL ADDRESS
*AUTHORIZED TO COMMUNICATE VIA EMAIL
Yes
FEE INFORMATION
APPLICATION FILING OPTION
TEAS Plus
NUMBER OF CLASSES
FEE PER CLASS
225
*TOTAL FEE PAID
225
SIGNATURE INFORMATION
* SIGNATURE
/arthur andreasyan/
* SIGNATORY'S NAME
arthur andreasyan
* SIGNATORY'S POSITION
ceo
SIGNATORY'S PHONE NUMBER
8005789456
* DATE SIGNED
04/28/2016

Under the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless it displays a valid OMB control number.
PTO Form 1478 (Rev 09/2006)
OMB No. 0651-0009 (Exp 02/28/2018)
Trademark/Service Mark Application, Principal Register

TEAS Plus Application
Filing Date: 04/28/2016
To the Commissioner for Trademarks:

MARK: HALO BOARD (Standard Characters, see mark)
The literal element of the mark consists of HALO BOARD.
The mark consists of standard characters, without claim to any particular font, style, size, or color.
The applicant, Kushgo LLC, a limited liability company legally organized under the laws of California, having an address of
Studio City, California 91604
United States
8005789456(phone)
requests registration of the trademark/service mark identified above in the United States Patent and Trademark Office on the Principal Register
established by the Act of July 5, 1946 (15 U.S.C. Section 1051 et seq.), as amended, for the following:
For specific filing basis information for each item, you must view the display within the Input Table.
International Class 012: Vehicles, namely, electronically motorized skateboards
Use in Commerce: The applicant is using the mark in commerce on or in connection with the identified goods/services. The applicant attaches, or
will later submit, one specimen as a JPG/PDF image file showing the mark as used in commerce on or in connection with any item in the class of
listed goods/services, regardless of whether the mark itself is in the standard character format or is a stylized or design mark. The specimen image
file may be in color, and the image must be in color if color is being claimed as a feature of the mark.
In International Class 012, the mark was first used by the applicant or the applicant's related company or licensee predecessor in interest at least
as early as 04/25/2016, and first used in commerce at least as early as 04/25/2016, and is now in use in such commerce. The applicant is
submitting one(or more) specimen(s) showing the mark as used in commerce on or in connection with any item in the class of listed
goods/services, consisting of a(n) screenshot of the applicants website.
Specimen File1
For informational purposes only, applicant's website address is: www.haloboard.com

The applicant's current Correspondence Information:
Kushgo LLC
Kushgo LLC
Studio City, California 91604
support@haloboard.com (authorized)
E-mail Authorization: I authorize the USPTO to send e-mail correspondence concerning the application to the applicant or applicant's attorney
at the e-mail address provided above. I understand that a valid e-mail address must be maintained and that the applicant or the applicant's
attorney must file the relevant subsequent application-related submissions via the Trademark Electronic Application System (TEAS). Failure to
do so will result in an additional processing fee of $50 per international class of goods/services.
A fee payment in the amount of $225 has been submitted with the application, representing payment for 1 class(es).
Declaration
The signatory believes that: if the applicant is filing the application under 15 U.S.C. 1051(a), the applicant is the owner of the

trademark/service mark sought to be registered; the applicant is using the mark in commerce on or in connection with the goods/services in the
application; the specimen(s) shows the mark as used on or in connection with the goods/services in the application; and/or if the applicant filed
an application under 15 U.S.C. 1051(b), 1126(d), and/or 1126(e), the applicant has a bona fide intention, and is entitled, to use the mark in
commerce on or in connection with the goods/services in the application. The signatory believes that to the best of the signatory's knowledge and
belief, no other persons, except, if applicable, concurrent users, have the right to use the mark in commerce, either in the identical form or in such
near resemblance as to be likely, when used on or in connection with the goods/services of such other persons, to cause confusion or mistake, or
to deceive. The signatory being warned that willful false statements and the like are punishable by fine or imprisonment, or both, under 18 U.S.C.
1001, and that such willful false statements and the like may jeopardize the validity of the application or any registration resulting therefrom,
declares that all statements made of his/her own knowledge are true and all statements made on information and belief are believed to be true.
Signature: /arthur andreasyan/ Date Signed: 04/28/2016

Signatory's Name: arthur andreasyan
Signatory's Position: ceo
RAM Sale Number: 87017860

RAM Accounting Date: 04/29/2016
Internet Transmission Date: Thu Apr 28 15:18:48 EDT 2016
TEAS Stamp: USPTO/FTK-XXX.XXX.XXX.XX-201604281518480
99415-87017860-550d966993d98a5d054bfd9c6
1dc54a04c336d9729eac34777189d2954d8d05a1
-CC-1642-20160428143728559657
EXHIBIT F
Email Chain with Windgoo
Representative
11/17/2016
Re:Re:SkywalkerboardforChristmasdaytakingfromLosAngeles
Case 2:16-cv-02851-RFB-CWH
From:"daisy"<daisy@windgoo.com>
Sent:Friday,January22,201612:22AM
To:"rbigler"<rbigler@hoverboard.com>
Subject:Re:Re:SkywalkerboardforChristmasdaytakingfromLosAngeles
HiRobert:
Thanksforyourreply.
Yes,wedon'tproducethisproductbefore.Butthisproductisournewmodelfor2016.
Wearetherealmanufacturerforthisproduct,followingisthepicthecustomervisitedourfactoryandtestedtheproduct
yesterday.
Forthepatent,wemakethemouldbyourself,itisnotsamewithothers.Plsdon'tworryaboutthispoint.
Ifyouhaveinterest,youcouldvisitourfactory.
Bestregards
Daisy
DaisyDingInternationalSales
ShenzhenWindgooIntelligentTechnologyCo.Ltd
LAwarehouse:1933W.11thSt.SuiteFUpland,CA91786USA
SalesCenter:216,Zone1,BulidingB,MingyouIndustrialProductsdisplaying
&PurchasingCenter,Bao'an,Shenzhen,China
https://mail.cloudaccess.net/Main/frmMessagePrint.aspx?popup=true&messageid=446&folder=Sent+Items&user=rbigler&domain=hoverboard.com&mapped= 2/9
11/17/2016
Factorybase:5thFloor,Building7,ChangfengIndustrialPark,DongkengVillage,GuangmingNe
wArea.Shenzhen,China
Web:www.windgoo.com
Skype:daisy.ding25
Whatsapp:+8618771146153
From:RobertBigler
Date:2016012102:23
To:daisy
Subject:Re:Re:[FWD:FW:SkywalkerboardforChristmasdaytakingfromLosAngeles]
ThankyouDaisy,
MyresearchshowsclearlythatyouareNOTthemanufacturerofthisHoverboardinourstyle.Youcouldbeagoodpartnerfor
importingthisHoverboard,butweneedtotalkdirectlytothefactoryandalsohavearelationshipdirectlywiththem.AndIneed
tovisittheirfactorytoworkwiththemandmakesuretheirproductisofgoodqualityanddoesnotviolateanyUSpatents.Only
thencanweimporttheproductandsellmany.
Pleaseaskthefactorytoreachouttomedirectly.Butalsopleasestayinvolvedandhelpwiththeimportingandsalesthrough
yourownchannels.ThankYou,
RobertBigler
CEO
HoverboardTechnologies
380LogueAvenue
MountainView,CA,94043
rbigler@hoverboard.com(rbigler@hoverboard.com)
www.hoverboard.com(rbigler@hoverboard.com)
Office:650.417.7700x7707
Cell:408.691.2415
From:"daisy"<daisy@windgoo.com>
Sent:Tuesday,January19,201610:16PM
To:"rbigler"<rbigler@hoverboard.com>
Subject:Re:Re:[FWD:FW:SkywalkerboardforChristmasdaytakingfromLosAngeles]
HiRobert:
Gladtoreceiveyourfeedback.
Ofcoursewewillmakesuretheyworkwellaswealsowanttoselllargeqty.
Forthesample,Iwillcheckandletyou.
Iamsurewewillbethegoodpartner,IevershareyouwehavewarehouseinLA.
Whenyoucooperatewithus,ifyouhaveanyquestion,youcouldgotoourwarehousedirectly.Thiswillbebetterforyouto
providetheafterservice.
Regardingvisitingourwarehouse,ofcourse,warmlywelcome.
Plsletmeknowthetimeyoumaycome,aswewillstartourChineseSpringHolidayattheendoflastmonth.
Hereshareyouonepicofournewfactory.
Hopewecouldstarttocooperatesoon
11/17/2016
Bestregards
Daisy
Factorybase:5thFloor,Building7,ChangfengIndustrialPark,DongkengVillage,GuangmingNe
wArea.Shenzhen,China
Web:www.windgoo.com
Skype:daisy.ding25
Whatsapp:+8618771146153
From:RobertBigler
Date:2016012013:29
To:daisy
Subject:Re:[FWD:FW:SkywalkerboardforChristmasdaytakingfromLosAngeles]
HiDaisy,WecouldsellthousandsoftheseiftheyworkOK.Wemayneedsomeimprovements.Howsooncanyougetmea
sample?Ifthislooksgoodtoworktogether,mayIvisityourfactory?Robert
SentfrommyVerizonWireless4GLTEDROID
daisy<daisy@windgoo.com>wrote:
HelloRobert:
Happytoshareyouwealsostarttoproduceyourstylehoverboard.
Followingyoucouldseethepics:
11/17/2016
AswehavewarehouseinLA,thisproductswillalsoprovidethere.Thiswillbebetterforyoutotakethem.
Anyinterest,plsfeelfreetocontactme.
Lookingforwardtohearfromyousoon
Bestregards
Daisy
Factorybase:5thFloor,Building7,ChangfengIndustrialPark,DongkengVillage,GuangmingN
ewArea.Shenzhen,China
Web:www.windgoo.com
Skype:daisy.ding25
Whatsapp:+8618771146153
From:RobertBigler
Date:2015120200:59
To:daisy@windgoo.com
Subject:fw:[FWD:FW:SkywalkerboardforChristmasdaytakingfromLosAngeles]
HelloDaisy,
WouldyourcompanybeinterestedinworkingwithustomanufactureourHoverboard(http://www.hoverboard.com)together?
Pleaseletmeknow.ThankYou,Robert
RobertBigler
CEO
11/17/2016
HoverboardTechnologies
380LogueAvenue
MountainView,CA,94043
rbigler@hoverboard.com(rbigler@hoverboard.com)
Office:650.417.7700x7707
Cell:408.691.2415
From:daisy[mailto:daisy@windgoo.com]
Sent:Tuesday,December01,20158:02AM
To:info<info@equalia.com>
Subject:SkywalkerboardforChristmasdaytakingfromLosAngeles
Hellofriend:
ThisisDaisyfromwindgoocompany,wearethemanufactureroftheskywalkerboard.
TheChristmasdayiscomingsoon,doyoualreadygetenoughstocknow?
WehavewarehouseinLosAngeles,whichcouldletyoureceivethegoodsinveryshortme.
Followingshareyouourhotmodels:
11/17/2016
11/17/2016
Anyneed,plscontactme.
Bestregards
Daisy
DaisyDingInternaonalSales
11/17/2016
SalesCenter:216,Zone1,BulidingB,MingyouIndustrialProductsdisplaying&PurchasingCenter,Bao'an,Shenzhen,
China
Factorybase:5thFloor,Building7,ChangfengIndustrialPark,DongkengVillage,GuangmingNewArea.Shenzhen,C
hina
Web:www.windgoo.com
Skype:daisy.ding25
Whatsapp:+8618771146153
Attachments:
Catch.jpg
10443_Catch.jpg
10443_Catch(0122162237).jpg
Catch(0120140(0122162237).jpg
Catch7968(0120(0122162237).jpg
10443_Catch(012(0122162237).jpg
Catch9CC9(1130(0122162237).jpg
Catch2A70(1130(0122162237).jpg
CatchD5EB(1130(0122162237).jpg
Catch8C06(1130(0122162237).jpg
10443_Catch(012(0122162237)(1).jpg
EXHIBIT G
Innovioboard Instagram
Screenshot
EXHIBIT H
Comparison of Equaila
Hoverboard and Infringing
Products
Table 2. Comparison of Equalia product embodying Equalia Patent and Infringing Product
1.
Equalia product on
bottom;
Infringing Product at
top.
2.
Equalia product on
bottom;
top.
3.
Equalia product at
bottom, Infringing
Product at top.
4.
Equalia product at
bottom, Infringing
Product at top.
5.
Equalia product on
left, Infringing Product
o right.
6.
Equalia product at top,
bottom.
EXHIBIT I
HaloBoard Dealer Signup
Screenshot
12/1/2016
BecomeaDealer
1-10 Filed 12/09/16 Page 2 of 3
B E C O M E A D E A L E R
EditFormBuilder
BECOME A DEALER
*Company Name
*Company Name
*First Name
*Last Name
*First Name
*Last Name
*Best Phone Number
*Website
*Best Phone Number
*Website
Email Address
Email Address
*Address
*Street Address
*Street Address
Address line 2
Address line 2
*City
*State
*City
*State
*Postal / Zip Code
*Country
*Postal / Zip Code
- *Country -
Company Brief Introduction
Company Brief Introduction

Which Products Is Your Company Interested In?
Halo Board Halo Rover Halo Go
FOL L OW
A B OUTUS
PRIVA CYPOL ICY
TERMS
ONEWHEEL
HA L OB OA RD
B ECOMEADEA L ER
RETURNPOL ICY
HOURS
MINUTES
SECONDS
SIGNUP
2016HALOBOARD.
CYBERDEALSALEENDS 0
ORDERNOW
9 0
9 4
3 6
7 3
4 2
3 FREESHIPPINGSAMEDAYFEDEX
https://www.haloboard.com/pages/become-a-reseller
1/2
12/1/2016
BecomeaDealer
1-10 Filed 12/09/16 Page 3 of 3
HOURS
MINUTES
SECONDS
CYBERDEALSALEENDS 0
9 0
9 4
3 6
7 3
4 2
https://www.haloboard.com/pages/become-a-reseller
2/2
EXHIBIT J
HaloBoard CES
Announcements
12/6/2016
HaloBoardCES2017Launch-Booth#42959-YouTube
Search
Halo Board CES 2017 Launch - Booth #42959
Up next
Halo Board CES 2017 Launch - Booth #42959
Autoplay
Halo Board How To Riding Tutorial
Halo Board
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Add to
97
Share
Halo Board
1,682 views
421 views
More
1:27
Published on Nov 18, 2016
Guys Remove Their

Blackheads
Like what you see? Join us at CES 2017 at the Sands Expo booth #42959 and check out our boards in
person!
BuzzFeedVideo
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Open Saturday Night
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The Truthful Echidnas
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4:58
2016 Nine-Point Rides
Tech Know 2 weeks ago

Is that the stary board you guys are launching?! That's awesome!!!
125
World Surf League
VIDEOS
Reply
View all 3 replies
Tech Know 1 week ago
$8 Salmon Vs. $56

Salmon
Wow that sounds awesome! Looking forward to seeing some cool videos on it! :)
Reply
Seun Akognon 1 day ago
Skip navigation+Halo Board great video! will there be commercials of the halo board on TV?
Reply
Christopher Poole 2 weeks ago
https://www.youtube.com/watch?v=QxqVfy4yVrE
BuzzFeedVideo
10:36
Donald Trump's
False Claims and
Foreign
Late
NightPolicy
with Seth Meyers
1/3
12/6/2016
Hey I am broke and I comment and like all of you videos wanna give me one??? plz I am
Search
desperate also 13
10:53
SOLOPATTINO vs
Hoverboard - Full
test
di Giorgio
SOLOPATTINO
Reply
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2:16
CES Unveiled CES

2017
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617 views
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3/3

AO 440 (Rev. 06/12) Summons in a Civil Action

for the
District of Nevada
EQUALIA, LLC, a California limited liability company, and

HOVERBOARD TECHNOLOGIES CORPORATION, a
Plaintiff(s)
v.
KUSHGO LLC dba HALO BOARD, a California limited
liability company; HALO BOARD LLC, an Oregon limited
liability company; ARTHUR ANDREASYAN, an
individual; and SHENZHEN WINDGOO INTELLIGENT
TECHNOLOGY CO. LTD., a foreign company,
)
)
)
)
)
)
)
)
)
)
)
)
)
Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION

To: (Defendants name and address)
Kushgo LLC dba Halo Board
A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are:
Stephen J. Erigero (SBN 11562)
Timothy J. Lepore (SBN 13908)
Lael D. Andara (CA SBN 215416)
Ropers, Majeski, Kohn & Bentley
3753 Howard Hughes Pkwy, Ste 200
Las Vegas, NV 89169
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
American LegalNet, Inc.

www.FormsWorkFlow.com

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)
I personally served the summons on the individual at (place)
on (date)
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, and mailed a copy to the individuals last known address; or
I served the summons on (name of individual)
, who is
designated by law to accept service of process on behalf of (name of organization)

on (date)
; or
I returned the summons unexecuted because
; or
Other (specify):
My fees are $
for travel and $
for services, for a total of $
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:



for the
District of Nevada

Plaintiff(s)
v.
)
)
)
)
)
)
)
)
)
)
)
)
)
Civil Action No.
Defendant(s)

HALO BOARD LLC

Las Vegas, NV 89169
CLERK OF COURT
Date:


Civil Action No.

PROOF OF SERVICE
on (date)
; or
on (date)
, who is

on (date)
; or
; or
Other (specify):
My fees are $
for travel and $
Date:
Servers signature
Servers address



for the
District of Nevada

Plaintiff(s)
v.
)
)
)
)
)
)
)
)
)
)
)
)
)
Civil Action No.
Defendant(s)

ARTHUR ANDREASYAN

Las Vegas, NV 89169
CLERK OF COURT
Date:


Civil Action No.

PROOF OF SERVICE
on (date)
; or
on (date)
, who is

on (date)
; or
; or
Other (specify):
My fees are $
for travel and $
Date:
Servers signature
Servers address



for the
Northern District of California
EQUALIA, LLC, a California limited liability

company, and HOVERBOARD TECHNOLOGIES
CORPORATION, a California corporation,
Plaintiff(s)
v.
Defendant(s)
)
)
)
)
)
)
Civil Action No.
)
)
)
)
)
)
)

SHENZHEN WINDGOO INTELLIGENT TECHNOLOGY CO. LTD

Las Vegas, NV 89169
CLERK OF COURT
Date:


Civil Action No.

PROOF OF SERVICE
on (date)
; or
on (date)
, who is

on (date)
; or
; or
Other (specify):
My fees are $
for travel and $
Date:
Servers signature
Servers address

JS 44 (Rev. 11/15)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
EQUALIA, LLC, and HOVERBOARD TECHNOLOGIES CORPORATION KUSHGO LLC dba HALO BOARD and SHENZHEN WINDGOO
INTELLIGENT TECHNOLOGY CO. LTD
County of Santa Clara
County of Los Angeles
(b) County of Residence of First Listed Plaintiff
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES)
NOTE:
(c) Attorneys (Firm Name, Address, and Telephone Number)
(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (If Known)
Stephen J. Erigero, Timothy J. Lepore; Ropers Majeski Kohn & Bentley

3753 Howard Hughes Pkwy., Suite 200, Las Vegas, NV 89169
Telephone: (702) 954-8300
II. BASIS OF JURISDICTION (Place an X in One Box Only)

1
U.S. Government
Plaintiff
Federal Question
(U.S. Government Not a Party)
U.S. Government
Defendant
Diversity
(Indicate Citizenship of Parties in Item III)
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

(For Diversity Cases Only)
PTF
Citizen of This State
1
DEF
1
and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State
Citizen of Another State
Incorporated and Principal Place

of Business In Another State
Citizen or Subject of a
Foreign Country
Foreign Nation
IV. NATURE OF SUIT (Place an X in One Box Only)

CONTRACT
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
625 Drug Related Seizure

of Property 21 USC 881
690 Other
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
OTHER STATUTES
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding
2 Removed from
State Court
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. 271; 15 U.S.C. 45
VI. CAUSE OF ACTION Brief description of cause:
This case arises from Defendants infringement of Plaintiffs' registered patents
CHECK IF THIS IS A CLASS ACTION

VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE
CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:
DEMAND $
DOCKET NUMBER
SIGNATURE OF ATTORNEY OF RECORD
/s/ Timothy J. Lepore
12/09/2016
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
Print
APPLYING IFP
Save As...
JUDGE
MAG. JUDGE
Reset
JS 44 Reverse (Rev. 11/15)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)
(b)
(c)
Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V.
Origin. Place an "X" in one of the six boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI.
Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

Equalia v. Kushgo - Complaint

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Equalia v. Kushgo - Complaint

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Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 1 of 14

Ropers Majeski Kohn & Bentley

STEPHEN J. ERIGERO (SBN 11562)

UNITED STATES DISTRICT COURT

EQUALIA, LLC, a California limited

(2) UNFAIR AND DECEPTIVE TRADE

KUSHGO LLC dba HALO BOARD, a

DEMAND FOR JURY TRIAL

Plaintiffs EQUALIA, LLC, a California limited liability company, and HOVERBOARD

TECHNOLOGIES CORPORATION, a California corporation (collectively known as "Equalia"),

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 2 of 14

company, ARTHUR ANDREASYN, an individual (collectively "HaloBoard"), and SHENZHEN

WINDGOO INTELLIGENT TECHNOLOGY CO. LTD. ("Windgoo"), a foreign company, and

Ropers Majeski Kohn & Bentley

Equalia seeks, among other relief, an injunction preventing Defendants from

Equalia, LLC is a California limited liability company in the automation, electric

located at 380 Logue Avenue, Mountain View, California 94043.

Hoverboard Technologies Corporation is a California corporation in the business

of developing, marketing, and selling personal transportation vehicles. Hoverboard Technologies

Hereinafter, Equalia, LLC and Hoverboard Technologies Corporation shall be

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 3 of 14

Hoverboard Technologies Corporation.

Upon information and belief, Kushgo LLC is a California limited liability

Hoverboard". Kushgo LLC shall be referred to hereafter as "Kushgo."

Ropers Majeski Kohn & Bentley

Upon information and belief, Arthur Andreasyan is an individual holding himself

Boulevard, Studio City, California 91604.

Hereafter, Halo Board LLC and Arthur Andreasyan shall be referred to

warehouse at 1933 W. 11th St., Suite 5, Upland CA 91786.

Hereafter, Kushgo, Halo Board, and Windgoo shall be referred to collectively as

III. JURISDICTION AND VENUE

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 4 of 14

U.S.C. 1367 (supplemental jurisdiction).

or more of the following reasons:

a. The exercise of personal jurisdiction over Defendants by this Court is

traditional notions of fair play and substantial justice;

b. Defendants have done and continue to do business in the State of Nevada

c. Defendants direct into the State of Nevada, including this District,

e. Defendants have offered, and continue to offer, products constituting patent

complaint in the State of Nevada, including this District; and

f. Defendants have committed tortious injury to Equalia and to Equalia's

Venue is proper in this district pursuant to 28 U.S.C. 1391 because Defendants

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 5 of 14

This Court's exercise of personal jurisdiction over Defendants is consistent with

the Constitution of the United States and the State of Nevada.

Ropers Majeski Kohn & Bentley

The Equalia Patent

Equalia is an innovator in the field of single-wheeled electric personal mobility

Equalia is in the process of launching a hoverboard product which consists of a

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 6 of 14

The Equalia Patent covers an ornamental design for a single-wheeled electric

personal mobility device.

legally issued to Equalia.

videos is attached hereto as Exhibit C.

The Equalia Patent is presumed to be valid.

Defendants' Infringing Activity

On information and belief, without Equalia's authorization, Defendants have made,

COMPLAINT FOR PATENT INFRINGEMENT

Case 2:16-cv-02851-RFB-CWH Document 1 Filed 12/09/16 Page 7 of 14