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COMPLAINT
Jezign Licensing, LLC (“Jezign”) brings this patent-infringement action against Skechers
Parties
1. Jezign is a New York limited liability company, having its principal place of
3. This action arises under the patent laws of the United States, 35 U.S.C. §§ 101, et
seq.
Case 8:16-cv-01193-TDC Document 1 Filed 04/21/16 Page 2 of 4
4. This Court has subject matter jurisdiction over this action under 28 U.S.C.
5. This Court has personal jurisdiction over Skechers. Skechers conducts continuous
and systematic business in this District, and this patent-infringement case arises in part directly
from Skechers’s continuous and systematic activity in this District. This Court’s exercise of
jurisdiction over Skechers would be consistent with the Maryland long-arm statute and
1400(b).
7. Jezign owns the exclusive rights in the ornamental designs claimed in United
States Design Patent No. D554,848 (the “‘848 Patent”) (attached hereto as Exhibit A).
8. Without Jezign’s authorization, Skechers made, used, offered for sale, sold,
and/or imported into the United States shoes having designs that infringe the ‘848 Patent
(hereinafter the “Infringing Shoes”). The Infringing Shoes include at least the model named
“Sporty Shorty Revv Air Flintz” and shoes bearing the same or substantially similar infringing
system within the sole is substantially the same as the design claimed in the ‘848 Patent.
10. An ordinary observer will perceive the substantial similarity between the design
of Jezign’s ‘848 Patent and the corresponding design of Skechers’ Infringing Shoes.
11. The table below illustrates Skechers’ infringement by comparing a figure from the
-2-
Case 8:16-cv-01193-TDC Document 1 Filed 04/21/16 Page 3 of 4
12. Jezign has been and will continue to be irreparably harmed by Skechers’
b. The total profit made by Skechers from its infringement of the ‘848 Patent
c. Injunctive relief;
e. Such other and further relief as the Court may deem just and proper.
Jezign demands a trial by jury on all matters and issues triable by jury.
-3-
Case 8:16-cv-01193-TDC Document 1 Filed 04/21/16 Page 4 of 4
/s/
Andrew D. Freeman (Fed. Bar No. 03867)
Albert Elia (Fed. Bar No. 14130)
Brown Goldstein & Levy, LLP
120 E. Baltimore St., Suite 1700
Baltimore, MD 21202
Tel: (410) 962-1030
Fax: (410) 385-0869
adf@browngold.com
aelia@browngold.com
-4-
Case 8:16-cv-01193-TDC Document 1-1 Filed 04/21/16 Page 1 of 7
Exhibit A
Case 8:16-cv-01193-TDC Document 1-1 Ill Filed
Illlll llllllll lllll llllll04/21/16 Page 2 of 7
llll lllll lllll 111111111111111111111111111111111
USOOD554848S
DESCRIPTION
Related U.S. Application Data FIG. 1 is a perspective view of the illuminated shoe lower
(63) Continuation-in-part of application No. 10/386,509, in accordance with a first embodiment of the invention.
filed on Mar. 13, 2003, now Pat. No. 6,837,590, FIG. 2 is a front view of the illuminated shoe lower shown
09/963,787, filed on Sep. 27, 2001, now abandoned. FIG. 3 is a rear view of the illuminated shoe lower shown in
FIG. 1.
illustrated in FIG. 1.
See application file for complete search history. FIG. 6 is a perspective view of an illuminated shoe lower in
4,158,922 A 611979 Dana, III FIG. 8 is a perspective view of an illuminated shoe lower in
D341,478 s * 11/1993 Forland et al ............... D2/977 accordance with still another embodiment of the invention;
6,050,007 A 412000 Angelieri et al. The broken lines in the shoe upper depicted in the drawings
6,457,261 Bl 10/2002 Crary are for illustrative purposes only and form no part of the
6,618,959 Bl 9/2003 Sussmann claimed design. The broken lines extending from the trans
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Case 8:16-cv-01193-TDC Document 1-2 Filed 04/21/16 Page 1 of 1
16-cv-1191, 16-cv-1192
Case 8:16-cv-01193-TDC Document 1-3 Filed 04/21/16 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
To: (Defendant’s name and address) SKECHERS U.S.A., INC., 228 Manhattan Beach Blvd., Manhattan Beach CA
90266-5347
Serve on:
CSC-Lawyers Incorporating Service Company
7 St. Paul Street, Suite 820
Baltimore, Maryland 21202
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 plaintiff’s attorney,
whose name and address are:
Andrew D. Freeman Matthew Wawrzyn
Brown Goldstein & Levy, LLP Wawrzyn & Jarvis LLC
120 E. Baltimore Street, Suite 1700 223 S. Wacker Dr., 84th Fl.
Baltimore, Maryland 21202 Chicago, IL 60606
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: 04/21/2016
Signature of Clerk or Deputy Clerk
Case 8:16-cv-01193-TDC Document 1-3 Filed 04/21/16 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
’ I left the summons at the individual’s 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 individual’s last known address; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
Date:
Server’s signature
Server’s address