IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN PRECITEC, INC.

, a Delaware corporation,

) ) Plaintiff, ) ) v. ) ) ) AMERICAN LASER ENTERPRISES, LLC., ) a Michigan limited liability company, ) ) Defendant. ) )

Case No. _____________ JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT AND REQUEST FOR JURY TRIAL Plaintiff, Precitec, Inc., for its Complaint against Defendant, American Laser Enterprises, LLC, alleges as follows: The Parties 1. Plaintiff, Precitec, Inc. (Precitec), is a corporation existing under the laws of the

state of Delaware, having a place of business at 28043 Center Oaks Ct., Wixom, Michigan, 48393. 2. On information and belief, Defendant American Laser Enterprises, LLC.

(ALE), is a limited liability company organized under the laws of the state of Michigan, and has its principal place of business at 28221 Beck Rd., Unit A-4, Wixom, Michigan, 48393. Jurisdiction and Venue 3. This is an action for patent infringement under the patent laws of the United

States, Title 35, United States Code. 4. This Court has subject matter jurisdiction under 28 U.S.C. 1331 and 1338(a).

6. 7.

This Court has personal jurisdiction over ALE at least under M.C.L. 600.711. Venue is proper before this Court under 28 U.S.C. 1391 and 1400. Causes of Action for Patent Infringement

8.

On February 6, 1996, United States Patent No. 5,489,888 (the 888 patent) was

duly and legally issued to Manfred Jagiella and Killian Barth, on an invention entitled Sensor System For Contactless Distance Measuring. The 888 patent was assigned to and is owned by Precitec. A copy of the 888 patent is attached hereto as Exhibit 1. 9. Upon information and belief, ALE has contributorily infringed, and/or actively

induced infringement of, the 888 patent in violation of 35 U.S.C. 271 by making, using, inducing others to use, offering for sale, and/or selling sensor systems, nozzles, and/or other parts that infringe one or more of the claims of the 888 patent, both within and outside this judicial district, without authority to do so. 10. Upon information and belief, Susan Land Sprentall and Donald E. Sprentall are

the principals of, and control, ALE. Ms. Sprentall is a former employee of Precitec, and Mr. Sprentall was employed by a Precitec subsidiary. As such, Susan Land Sprentall and Donald E. Sprentall, were and are aware of the 888 patent. 11. willful. 12. Precitec has been irreparably damaged and will continue to be irreparably Upon information and belief, ALEs infringement of the 888 patent has been

damaged by ALEs infringement unless this Court enjoins ALE from continuing its infringement. Prayer for Relief Wherefore, Plaintiff Precitec prays for the entry of judgment from this Court that:

(a) enforceable; (b)

United States Patent No. 5,489,888 was duly and legally issued, and is valid and

Defendant contributorily infringed United States Patent No. 5,489,888 and/or

actively induced infringement of United States Patent No. 5,489,888 by others; (c) Defendant be preliminarily and permanently enjoined from engaging in any

further acts of infringement of United States Patent No. 5,489,888; (d) Plaintiff Precitec be awarded damages adequate to compensate for the

infringement by Defendant, pursuant to 35 U.S. C. 284; (e) Defendants infringement has been willful, thereby entitling Plaintiff Precitec to

recover treble damages; (f) The infringement by Defendant has been such as to render this action exceptional,

and Plaintiff Precitec be awarded reasonable attorneys fees, pursuant to 35 U.S.C. 285; and (g) Plaintiff Precitec be awarded such other and further relief as this Court may deem

to be appropriate.

Request for Jury Trial Plaintiff, Precitec, Inc., hereby makes demand for a trial by jury pursuant to Rule 38 of the Federal Rules of Civil Procedure as to all issues of this lawsuit.

RADER, FISHMAN & GRAUER PLLC

Dated: March 21, 2012

By /s/ Charles A. Bieneman___________ R. Terrance Rader (P28747) Charles A. Bieneman (P66755) Leigh C. Taggart (P63765) 39533 Woodward Avenue, Suite 140 Bloomfield Hills, Michigan 48304 Tel.: (248) 594-0600 Fax: (248) 594-0610 Attorneys for Plaintiff Precitec, Inc.

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