COMPLAINT FOR PATENT INFRINGEMENT

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Richard A. Clegg (SBN 211213)
LAW OFFICE OF RICHARD CLEGG
501 West Broadway, Suite 800
San Diego, California 92101
Telephone: (619) 400-4920
rick@rclegglaw.com
Counsel for Plaintiff
Bliss Holdings LLC
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
BLISS HOLDINGS LLC, a California
Corporation,
Plaintiff,
v.
AMERICAN D.J. SUPPLY, INC., a
California Corporation,

Defendant.



CIVIL ACTION NO. __________________

COMPLAINT FOR PATENT
INFRINGEMENT


Plaintiff Bliss Holdings LLC (BLISS) alleges as follows for its complaint
against defendant American D.J. Supply, Inc. (ADJ):
PARTIES
1. BLISS is a limited liability corporation organized and existing under the
laws of the State of California, with a primary place of business at 745 South Vinewood
Street, Escondido, CA.
2. ADJ is a corporation organized and existing under the laws of the State of
California, with a principal place of business at 6122 S. Eastern Avenue, Commerce, CA.
__________________
'12CV1128 BLM JAH
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 1 of 10



COMPLAINT FOR PATENT INFRINGEMENT


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
JURISDICTION AND VENUE
3. This is an action for patent infringement, arising under the patent laws of
the United States, including 35 U.S.C. 271 et seq. This court has subject matter
jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a).
4. ADJ is subject to personal jurisdiction in this judicial district because,
BLISS is informed and believes and on that basis alleges, ADJ has sold its accused
products to customers within this judicial district; has placed its accused products into the
stream of commerce, through established distribution channels, knowing or reasonably
foreseeing that the products would be sold to customers within this judicial district; and
has offered the accused products for sale to customers within this judicial district, via an
interactive web site through which the products can be purchased from within this
judicial district.
5. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b),
(c) and 1400.
FIRST CAUSE OF ACTION
INFRINGEMENT OF U.S. PATENT NO. 8,057,045
6. BLISS is the owner of United States Patent No. 8,057,045 ("the 045
Patent"), entitled "Star Field Projection Apparatus", which was issued by the United
States Patent and Trademark Office on November 15, 2011. A true and correct copy of
the 045 Patent is attached as Exhibit A.
7. ADJ has infringed the 045 Patent by, inter alia, selling and offering to sell
laser light projection products that are covered by one or more patent claims of the '045
Patent, within the United States, during the term of the 045 Patent, without BLISSs
authorization. The accused ADJ products (collectively, the Accused Products) include:
(a) the Micro 3D; (b) the Royal 3D; (c) the Galaxian; (d) the Galaxian 3D; and (e) the
Galaxian Royale.
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 2 of 10



COMPLAINT FOR PATENT INFRINGEMENT


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
8. Each of the Accused Products includes all the elements of at least one
patent claim of the 045 Patent. Each of the Accused Products is a laser light projection
apparatus that generates a moving field of pinpoint lights. Each of the Accused Products
includes a laser that is powered by a power supply. In each of the Accused Products, the
laser is positioned to direct light through a first wheel and a second wheel. The first
wheel is a diffractive optical element. The first wheel is positioned between the laser and
the second wheel. The second wheel is a grating wheel that is rotated by an electrically
powered motor.
9. BLISS has suffered monetary damages as a result of ADJs acts of
infringement.
10. BLISS has suffered irreparable harm as a result of ADJs acts of
infringement and will continue to suffer irreparable harm unless and until ADJ is
enjoined from committing further acts of infringement.
PRAYER FOR RELIEF
WHEREFORE, BLISS prays for the Court to grant BLISS the following relief:
1. Enter judgment that ADJ has directly infringed the '045 Patent and award
monetary damages to BLISS that are adequate to compensate it for ADJs infringement,
along with prejudgment interest;
2. Enter an injunction to prevent further infringements by ADJ or any other
persons acting in concert with ADJ;
3. Award BLISS its costs of suit in connection with this action;
4. Grant BLISS such other and further relief as the Court deems proper.

[SIGNATURE ON NEXT PAGE]



Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 3 of 10



COMPLAINT FOR PATENT INFRINGEMENT


1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Respectfully submitted,

Dated: May 8, 2012

/s Richard A. Clegg/
___________________________________
Richard A. Clegg
E-mail: rick@rclegglaw.com

Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 4 of 10






































EXBIBIT A

0NITEB STATES PATENT N0. 8,uS7,u4S
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 5 of 10
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 6 of 10
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 7 of 10
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 8 of 10
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 9 of 10
'12CV1128 BLM JAH
Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 10 of 10