Case 1:12-cv-10162-RWZ Document 1 Filed 01/27/12 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS EURO-PRO OPERATING LLC, Plaintiff, v. BISSELL HOMECARE, INC. and HSN, INC., Defendants. CIVIL ACTION NO. JURY DEMAND

COMPLAINT Plaintiff Euro-Pro Operating LLC, (Euro-Pro), by its attorneys, for its Complaint against Defendants Bissell Homecare, Inc. (Bissell) and HSN, Inc. (HSN) (collectively Defendants), alleges as follows: NATURE OF THE ACTION 1. This is an action for infringement of U.S. Patent No. 8,052,342 (the 342

patent) under 35 U.S.C. 271 (a), (b), and (c). THE PARTIES 2. Plaintiff Euro-Pro, is a limited liability company organized and existing under the

laws of the State of Delaware, with a principal place of business at 180 Wells Avenue, Suite 200, Newton, Massachusetts 02459. 3. On information and belief, Defendant Bissell is a corporation organized and

existing under the laws of the State of Michigan, with a principal place of business at 2345 Walker Avenue Northwest, Grand Rapids, Michigan 49544. 4. On information and belief, Defendant HSN is a corporation duly organized and

existing under the laws of the State of Delaware, with a principal place of business at 1 HSN Drive, St. Petersburg, Florida 32729.

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JURISDICTION AND VENUE 5. This action arises under the patent laws of the United States of America, United

States Code, Title 35, Section 1, et seq. This Court has subject matter jurisdiction over the action under 28 U.S.C. 1331 and 1338. 6. On information and belief, Defendants transact business in the District of

Massachusetts, including the sale and offering for sale of products, including but not limited to the Bissell Steam Mop Select (Bissell Select). 7. Upon information and belief, Defendants sell products directly to persons residing

in Massachusetts via the Internet and telephone. 8. These contacts constitute sufficient contacts with this District to subject

Defendants to personal jurisdiction. 9. 10. Accordingly, this Court has personal jurisdiction over Defendants for this action. Venue is proper in this Court under 28 U.S.C. 1391 and 1400(b). Upon

information and belief, Defendants conduct substantial business in this District and have committed and continue to commit acts of infringement in this District. BACKGROUND 11. The 342 patent, entitled Universal Connector for a Fluid Mop, issued on

November 8, 2011, naming Maximilian Rosenzweig and Ognjen Vrdoljak as the inventors. A copy of the 342 patent is attached to this complaint as Exhibit A. 12. Euro-Pro is the owner of all right, title and interest in the 342 patent, including

the right to sue, enforce, and recover all damages, past and future, for all infringements. 13. Select. Defendant Bissell makes, uses, imports, sells, and/or offers for sale the Bissell

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14.

Defendant HSN uses, sells, and/or offers for sale the Bissell Select. COUNT I

15. 16.

The allegations of paragraphs 1-14 are incorporated as if fully set forth herein. Defendants are infringing the claims of the 342 patent by making, using, offering

to sell, and/or selling at least the Bissell Select. 17. 18. Defendants acts of infringement have injured and damaged Euro-Pro. Upon information and belief, Defendants infringement has been willful and will

continue to be willful, making this case exceptional and entitling Euro-Pro to increased damages and reasonable attorneys fees pursuant to 35 U.S.C. 284 and 285 of the patent statute. PRAYER FOR RELIEF Wherefore, Plaintiff Euro-Pro requests the following relief: (a) Judgment against Defendants as to infringement of the 342 patent; (b) Preliminary and permanent injunctions preventing Defendants and their officers, directors, agents, servants, employees, attorneys, licensees, successors, assigns and customers, and those in active concert or participation with any of them, from making, using, importing, selling, or offering to sell any devices or systems that infringe the 342 patent; (c) Judgment against Defendants for money damages sustained as a result of Defendants infringement of the 342 patent and an accounting / supplemental damages; (d) Judgment against Defendants for treble money damages pursuant to 35 U.S.C. 284 sustained as a result of Defendants willful infringement of the 342 patent; (e) Costs, pre-judgment interest and post-judgment interest and reasonable attorneys fees incurred in connection with this action pursuant to 35 U.S.C. 285; and, (f) Such other relief as this court finds just and proper. -3-

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JURY DEMAND Plaintiff Euro-Pro requests trial by jury.

Respectfully Submitted, EURO-PRO OPERATING LLC, By its attorneys,

Dated: January 27, 2012

/s/ Michael N. Rader________________ Michael N. Rader (BBO #646990) mrader@wolfgreenfield.com John L. Strand (BBO #654985) jstrand@wolfgreenfield.com WOLF, GREENFIELD & SACKS, P.C. 600 Atlantic Avenue Boston, Massachusetts 02210 Tel. 617.646.8000 Fax 617.646.8646

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