Eagle Eyes Traffic Industry USA v. JL Concepts - Complaint

Case 2:19-cv-07328 Document 1 Filed 08/23/19 Page 1 of 14 Page ID #:1
1 ALEXANDER CHEN [SBN 245798]

[email protected]
2 WILLIAM R. WALZ [SBN 136995]
[email protected]
3 THEODORE LEE [SBN 281475]
[email protected]
4 INHOUSE CO. LAW FIRM
7700 Irvine Center Drive, Suite 800
5 Irvine, CA 92618
Telephone: 949-250-1555
6 Facsimile: 714-882-7770
7 Attorneys for Plaintiff
8 Eagle Eyes Traffic Industry USA Holding LLC
9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA
11 WESTERN DIVISION
12
13 )
EAGLE EYES TRAFFIC INDUSTRY USA ) Case No.
14 HOLDING LLC, a Chinese company, )
)
15 )
Plaintiff, COMPLAINT FOR PATENT
)
16 ) INFRINGEMENT
vs. )
17 ) DEMAND FOR JURY TRIAL
18 )
JL CONCEPTS INC. dba GT RACERS, a )
19 California Corporation; and DOES 1 )
through 50, inclusive. )
20 )
Defendants. )
21 )
)
22 )
)
23
24
25
26
27
28
1 Plaintiff Eagle Eyes Traffic Industry USA Holding LLC (“Eagle Eyes”) presents the following
2 allegations and facts in support of this Complaint and demands a jury trial on all causes of action stated
3 herein against the named Defendant as follows:
4 JURISDICTION AND VENUE
5 1. This is a civil action for infringement of a patent, arising under the laws of the United
6 States relating to patents, including, without limitation, 35 U.S.C. § 101, et seq., 35 U.S.C. § 271 and §
7 281. Plaintiffs seek preliminary and permanent injunctions and monetary damages for patent
8 infringement.
9 2. This Court has subject matter jurisdiction over this case for patent infringement under 28
10 U.S.C. §§ 1331 and 1338(a) and pursuant to the patent laws of the United States of America, 35 U.S.C.
11 § 101, et seq.
12 3. Venue properly lies within the Central District of California pursuant to 28 U.S.C.
13 sections 1391(b) and (c); 28 U.S.C. section 1400; and 18 U.S.C. section 1965. On information and
14 belief, Defendant conducts substantial business directly and through third parties or agents in this
15 judicial district by selling and offering to sell the infringing products and by conducting other business
16 in this judicial district. Furthermore, Plaintiffs have been harmed by Defendant’s conduct, business
17 transactions and sales in this district.
18 4. This Court has personal jurisdiction over Defendant because, on information and belief,
19 Defendant transacts continuous and systematic business within the State of California and the Central
20 District of California. In addition, this Court has personal jurisdiction over the Defendant because, on
21 information and belief, this lawsuit arises out of Defendant’s infringing activities, including, without
22 limitation, the making, using, selling and/or offering to sell infringing products in the State of California
23 and the Central District of California. Finally, this Court has personal jurisdiction over Defendant
24 because, on information and belief, Defendant has made, used, sold and/or offered for sale its infringing
25 products and placed such infringing products in the stream of interstate commerce with the expectation
26 that such infringing products would be made, used, sold and/or offered for sale within the State of
27 California and the Central District of California.
28
1 5. Upon information and belief, certain of the products manufactured by or for Defendant
2 have been and/or are currently sold and/or offered for sale to consumers including, but not limited to,
3 consumers located within the State of California at, among other places, ebay.com’s website located at
4 https://www.ebay.com.
5 PARTIES
6 6. Plaintiff Eagle Eyes Traffic Industry USA Holding, LLC (“Eagle Eyes”) is a Nevada
7 limited liability company having its principal place of business at 7260 West Azure Drive, Suite 140,
8 Las Vegas Nevada 89130.
9 7. Defendant JL Concepts, LLC dba GT Racers(“JLConcepts”) is a corporation registered
10 and existing under the laws of the State of California, with an office and principal place of business
11 located at 21912 Garcia Lane, Walnut, California 91789.
12 8. Plaintiff is ignorant of the true names and capacities of defendants who are named herein
13 under the fictitious names DOES 1-50, inclusive. Plaintiff will seek leave of court to amend this
14 complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes,
15 and thereon alleges, that each of the fictitiously named DOE defendants is responsible in some manner
16 for the wrongful conduct alleged herein. Plaintiff further alleges that each defendant acted in concert and
17 participation with, as agents or representatives of, at the request of, or on behalf of JL Concepts. Each
18 charge and allegation alleged herein is, therefore, also alleged against each fictitiously named DOE
19 defendant.
20 THE ASSERTED PATENTS
21 9. On September 17, 2013, the United States Patent and Trademark office, duly and legally
22 issued United States Design Patent No. D690,040, entitled “Exterior Surface Configuration of a
23 Vehicular Headlight” (“the ’040 patent”). The patent’s named inventor is Ching-Tsung Lai, and Plaintiff
24 Eagle Eyes is assignee and owner of the entire right, title, and interest in and to the ’040 Patent and
25 vested with the right to bring this suit for damages and other relief. A true and correct copy of the ’040
26 Patent and its respective assignments are attached hereto as Exhibit “A.”
27 10. On June 10, 2014, the United States Patent and Trademark office, duly and legally issued
28 United States Design Patent No. D706,966, entitled “Light Guide Bar For Vehicle Lamp” (“the ’966
1 Patent”). The patent’s named inventor is Ching-Tsung Lai, and Plaintiff Eagle Eyes is the assignee and
2 owner of the entire right, title, and interest in and to the ‘966 Patent and vested with the right to bring
3 this suit for damages and other relief. A true and correct copy of the ‘966 Patent and its respective
4 assignments are attached hereto as Exhibit “B.”
5 11. On June 10, 2014, the United States Patent and Trademark office, duly and legally issued
6 United States Design Patent No. D706,967, entitled “Light Guide Bar For Vehicle Lamp” (“the ’967
7 patent”). The patent’s named inventor is Ching-Tsung Lai, and Plaintiff Eagle Eyes is assignee and
8 owner of the entire right, title, and interest in and to the ’967 Patent and vested with the right to bring
9 this suit for damages and other relief. A true and correct copy of the ’967 Patent and its respective
10 assignments are attached hereto as Exhibit “C.”
11 12. The ‘040 Patent, ‘966’ Patent, and ‘967 Patent are collectively referred to as the
12 “Patented Designs.”
13 DEFENDANT’S INFRINGEMENT OF EAGLE EYES’ PATENTS
14 13. The Defendant’s accused products for purposes of the asserted patents include the
15 Defendant’s projection headlights incorporating the Patented Designs.
16 14. In particular, Defendant copied from Eagle Eye’s Patented Designs in designing its
17 “2007-2014 GMC Sierra 1500/2500 Chrome Drl U-Halo Led Projector Headlights.”
18 COUNT ONE
19 INFRINGEMENT OF THE ’040PATENT BY DEFENDANT
20 15. Plaintiff re-alleges and incorporates by reference each of the allegations set forth in
21 paragraphs 1 through 14 above.
22 16. Defendant has knowledge of infringement of the ’040 Patent since at least the filing of
23 this complaint.
24 17. Design Patent ‘040 has one single claim directed to the ornamental design for an exterior
25 surface configuration of a vehicular headlight as shown below:
26
27
28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
18. Defendant JLC copied the design for its 2007-2014 GMC Sierra 1500/2500 Chrome Drl
15
U-Halo Led Projector Headlights from the headlight design of the ’040 Patent. A side-by-side
16
comparison of the ’040 Patented design and an exemplary specimen of Defendant JC Concept’s
17
headlight is shown below, with the photograph of the exemplary Defendant JL Concepts:
18
Eagle Eyes’ JL Concepts’ GT Racers
19 D690,040 Patent Headlight
20
21
22
23
24
25
26
27
28
1
19. As depicted above, the headlight design of the Defendant’s 2007-2014 GMC Sierra
2
1500/2500 Chrome Drl U-Halo Led Projector Headlights is the same or substantially the same as the
3
headlight design of the Plaintiff’s ’040 Patent. The headlight designs are so similar in overall impression
4
as to be nearly identical such that an ordinary observer, giving such attention as a purchaser usually
5
gives, would be so deceived by the substantial similarity between the designs so as to be induced to
6
purchase Defendant JL Concepts’ GT Racer products believing them to be substantially the same as the
7
headlight design protected by the ’040Patent.
8
20. Plaintiff has not granted a license or any other authorization to Defendant JL Concepts to
9
make use, offer for sale, sell or import headlights that embody the headlight design patented in the ’040
10
Patent and which is proprietary to Plaintiff.
11
21. Plaintiff alleges upon information and belief that, without authority, Defendant has
12
infringed and will continue to infringe the ’040 patent by, inter alia, making, using, offering to sell, or
13
selling in the United States, including in the State of California and within this District, products
14
infringing the ornamental design covered by the ’040 patent in violation of 35 U.S.C. § 271, including
15
but not limited to Defendant JL Concepts’2007-2014 GMC Sierra 1500/2500 Chrome Drl U-Halo Led
16
Projector Headlights.
17
22. Defendant JL Concepts infringes the ’040 patent because, inter alia, in the eye of an
18
ordinary observer, giving such attention as a purchaser usually gives, the headlight design of the ’040
19
patent and the headlight designs of Defendant JL Concepts’ products including without limitation the
20
headlight designs of the 2007-2014 GMC Sierra 1500/2500 Chrome Drl U-Halo Led Projector
21
Headlight products are substantially the same, the resemblance being such as to deceive such an
22
ordinary observer, inducing him to purchase one supposing it to be the other.
23
23. Defendant JL Concepts’ acts of infringement of the ’040 patent were undertaken without
24
authority, permission or license from Plaintiff. Defendant JL Concepts’ infringing activities violate 35
25
U.S.C. § 271.
26
24. Plaintiff is informed and believes that Defendant intentionally sells, ships or otherwise
27
delivers the accused products in the United States, with knowledge that are designed to and do practice
28
the infringing features of the ’040 Patent.
1 25. Plaintiff is without an adequate remedy at law and has thus been irreparably harmed by
2 these acts of infringement. Plaintiff asserts upon information and belief that infringement of the asserted
3 claims of the ’040 Patent is continuous and ongoing unless and until Defendant is enjoined from further
4 infringement by the Court.
5 COUNT TWO
6 INFRINGEMENT OF THE ’966 PATENT BY DEFENDANT
10 this complaint.
11 28. Design Patent ‘966 has one single claim directed to the ornamental design for a light
12 guide bar for a vehicle lamp as shown below:
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
2
3
4
5
6
7
8
9
10
11
12
29. Defendant JL Concepts copied the design of the U-Bar Light Guide Bar from the design
13
of the ’966 Patent. A side-by-side comparison of the ’966 patented design and an exemplary specimen
14
of Defendant JL Concepts’ U-Bar Light Guide Bar is shown below:
15
16 Eagle Eye’s JL Concepts’ GT Racers
D706,966 Light Guide Bar
17
18
19
20
21
22
23
24
25
26
27
28
1 30. As shown in the pictures, the Light Guide Bar of Defendant is the same or substantially
2 the same as the design of the ’966 patent. The Light Guide Bar designs are so similar as to be nearly
3 identical such that an ordinary observer, giving such attention as a purchaser usually gives, would be so
4 deceived by the substantial similarity between the designs so as to be induced to purchase Defendant JL
5 Concepts’ products believing them to be substantially the same as the Light Guide Bar protected by the
6 ’966 Patent.
7 31. Plaintiff has not granted a license or any other authorization to Defendant JL Concepts to
8 make use of, offer for sale, sell or import headlights that embody the Light Guide Bar design patented in
9 the ’966 Patent and which is proprietary to Plaintiff.
10 32. Plaintiff alleges upon information and belief that, without authority, Defendant has
11 infringed and will continue to infringe the ’966 patent by, inter alia, making, using, offering to sell, or
12 selling in the United States, including in the State of California and within this District, products
13 infringing the ornamental design covered by the ’966 Patent in violation of 35 U.S.C. § 271, including
14 but not limited to Defendant JL Concepts’ Light Guide Bar incorporated in its 2007-2014 GMC Sierra
15 1500/2500 Chrome Drl U-Halo Led Projector Headlights.
16 33. Defendant JL Concepts infringes the ’966 Patent because, inter alia, in the eye of an
17 ordinary observer, giving such attention as a purchaser usually gives, the Light Guide Bar design of the
18 ’966 Patent and the light guide bar designs of Defendant JL Concepts’ products including without
19 limitation the Light Guide Bar designs incorporated in its headlight of the 2007-2014 GMC Sierra
20 1500/2500 Chrome Drl U-Halo Led Projector Headlight products are substantially the same, the
21 resemblance being such as to deceive such an ordinary observer, inducing him to purchase one
22 supposing it to be the other
23 34. Defendant JL Concepts’ acts of infringement of the ’966 Patent were undertaken without
24 authority, permission or license from Plaintiff. Defendant JL Concepts’ infringing activities violate 35
25 U.S.C. § 271.
26 35. Plaintiff is informed and believes that Defendant intentionally sells, ships or otherwise
27 delivers the accused products in the United States, which products imitate and in fact infringe upon the
28 features of the ’966 Patent.

3 claims of the ’966 Patent is continuous and ongoing, and will continue to harm Plaintiff unless and until
4 Defendant is enjoined from further infringement by the Court.
5
6 COUNT THREE
7 INFRINGEMENT OF THE ’967PATENT BY DEFENDANT
11 this complaint.
12 39. Design Patent ‘967 has one single claim directed to the ornamental design for a light
13 guide bar for a vehicle lamp as shown below:
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
2
3
4
5
6
7
8
9
10
11
12
40. Defendant JL Concepts copied the design of the U-Bar
Bar Light Guide Bar from the design
13
of the ’967 Patent. A side-by-side
side comparison of the ’967 patented design and an exemplary specimen
14
of Defendant JL Concepts’ U-Bar
Bar Light Guide Bar is shown below:
15
16
17 Eagle
le Eye’s JL Concepts’’ GT Racers
D706,967 Light Bar Guide
18
19
20
21
22
23
24
25
26
27
28
1 41. As shown in the above pictures, the Light Guide Bar of Defendant is the same or
2 substantially the same as the design of the ’967 Patent. The Light Guide Bar designs are so similar as to
3 be nearly identical such that an ordinary observer, giving such attention as a purchaser usually gives,
4 would be so deceived by the substantial similarity between the designs so as to be induced to purchase
5 Defendant JL Concepts’ products believing them to be substantially the same as the Light Guide Bar
6 protected by the ’967 Patent.
7 42. Plaintiff has not granted a license or any other authorization to Defendant JL Concepts to
8 make use of, offer for sale, sell or import headlights that embody the Light Guide Bar design patented in
9 the ’967 Patent and which is proprietary to Plaintiff.
10 43. Plaintiff alleges upon information and belief that, without authority, Defendant has
11 infringed and will continue to infringe the ’967 patent by, inter alia, making, using, offering to sell, or
12 selling in the United States, including in the State of California and within this District, products
13 infringing the ornamental design covered by the ’967Patent in violation of 35 U.S.C. § 271, including
14 but not limited to Defendant JL Concepts’ Light Guide Bar incorporated in its 2007-2014 GMC Sierra
15 1500/2500 Chrome Drl U-Halo Led Projector Headlight.
16 44. Defendant JL Concepts infringes the ’967 Patent because, inter alia, in the eye of an
17 ordinary observer, giving such attention as a purchaser usually gives, the Light Guide Bar design of the
18 ’967Patent and the Light Guide Bar design incorporated in the its headlight of Defendant JL Concepts’
19 products including without limitation the Light Guide Bar design incorporated in the headlight designs
20 of the GMC Sierra U-Bar Halo Projector products are substantially the same, the resemblance being
21 such as to deceive such an ordinary observer, inducing him to purchase one supposing it to be the other
22 45. Defendant JL Concepts’ acts of infringement of the ’967 Patent were undertaken without
23 authority, permission or license from Plaintiff. Defendant JL Concepts’ infringing activities violate 35
24 U.S.C. § 271.
25 46. Plaintiff is informed and believes that Defendant intentionally sells, ships or otherwise
26 delivers the accused products in the United States, which products which imitate and in fact infringe
27 upon the features of the ’967 Patent.
2 claims of the ’967Patent is continuous and ongoing, and will continue to harm Plaintiff unless and until
3 Defendant is enjoined from further infringement by the Court.
4
5 PRAYER FOR RELIEF
6 WHEREFORE, Plaintiff prays for relief and judgment as follows:
7 1. The determination that Defendant has infringed the Patents -in-Suit;
8 2. That Defendant, Defendant’s officers, agents, servants, employees, and attorneys, and
9 those persons in active concert or participation with them, be preliminarily and permanently enjoined
10 from infringement of the Patents--in-Suit, including but not limited to any making, using, offering for
11 sale, selling, or importing of unlicensed infringing products within and without the United States;
12 3. Compensation for all damages caused by Defendant’s infringement of the Patents -in-
13 Suit to be determined at trial;
14 4. A finding that this case is exceptional and an award of reason

reasonable
able attorney’s fees
15 pursuant to 35 U.S.C. § 285;
16 5. Granting Plaintiff’s pre-and post-judgment interest on its damages, together with all
17 costs and expenses; and,
18 6. Granting Plaintiff such other and further relief as the Court may deem just and proper.
19
20
DATED: August 21, 2019 INHOUSE CO. LAW FIRM
21
22
23
By: ____________________________
24
Alexander Chen, Esq.
25 William Walz, Esq.
Theodore Lee, Esq.
Eagle Eyes Traffic Industry USA Holding LLC
27
28
DEMAND FOR JURY TRIAL

1
2
3 Plaintiff hereby demands a trial by jury on all claims.
4
5
DATED: August 21, 2019 INHOUSE CO. LAW FIRM
6
7
8
9 By: ____________________________
Alexander Chen, Esq.
10 William Walz, Esq.
Theodore Lee, Esq.
12 Eagle Eyes Traffic Industry USA Holding LLC
13
14
15
16
17
18
19
20
21
22
23
24
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Case 2:19-cv-07328 Document 1-1 Filed 08/23/19 Page 1 of 26 Page ID #:15
Exhibit A
USOOD69004OS
(12) United States Design Patent (10) Patent No.: US D690,040 S

Lai (45) Date of Patent: Sep. 17, 2013
(54) EXTERIOR SURFACE CONFIGURATION OF (56) References Cited
VEHICULAR HEADLIGHT
U.S. PATENT DOCUMENTS
(71) Applicant: Litek Enterprise Co., Ltd, Tainan (TW) D538,956 S * 3/2007 Ishii ............................... D26/28
D544,614 S * 6/2007 Markefka ...... ... D26, 28
D556,349 S * 1 1/2007 Golden et al. . ... D26, 28
(72) Inventor: Ching-Tsung Lai, Tainan (TW) D561,358 S * 2/2008 Tachibana ...... ... D26, 28
D570,007 S * 5/2008 Hsu ........ ... D26, 28
(73) Assignee: Litek Enterprise Co., Ltd., Tainan D582,587 S * 12/2008 Yang .......... ... D26, 28
(TW) D593,232 S * 5/2009 Koman et al. .. ... D26, 28
D635,694 S * 4/2011 Yang et al. ..................... D26/28
(**) Term: 14 Years * cited by examiner
(21) Appl. No. 29/441,544 Primary Examiner — Marcus Jackson
(74) Attorney, Agent, or Firm — Muncy, Geissler, Olds &
(22) Filed: Jan. 7, 2013 Lowe, PLLC
(57) CLAM
(30) Foreign Application Priority Data I claim, the ornamental design for an exterior Surface con
figuration of a vehicular headlight, as shown and described.
Dec. 4, 2012 (TW) ................................. 1O 1307219 DESCRIPTION
(51) LOC (9) Cl. .................................................. 26-06
(52) U.S. Cl. FIG. 1 is a perspective view of an exterior surface configura
USPC D26/28 tion of a vehicular headlight showing my present design;
58) Field ?ci - - - - - ificati- - - - - -s - - - - - - - h- - - - - - - - - - - - - - - - - - - - - - FIG. 2 is a front view thereof;
(58) Field of Classification Searc FIG. 3 is a left view thereof; and,
USPC ............ D26/28–36; 362/459 468, 475-478, FIG. 4 is a top plan view thereof.
362/485 487
See application file for complete search history. 1 Claim, 4 Drawing Sheets
U.S. Patent Sep. 17, 2013 Sheet 1 of 4 US D690,040 S
[
s

F I G . 4
Exhibit B
USOOD706966S
(12) United States Design Patent (10) Patent No.: USD706,966S

Lai (45) Date of Patent: Jun. 10, 2014
(56) References Cited
(54) LIGHT GUIDE BAR FORVEHICLE LAMP
(75) Inventor: Ching-Tsung Lai, Tainan (TW) D295,064 S * 4, 1988 Hardiman et al. ........... D21,613
D345,331 S * 3/1994 Smith ................ D12,222
(73) Assignee: Litek Enterprise Co., Ltd., Tainan D449,393 S * 10/2001 Yamamoto et al. ... D26, 28
D469,196 S * 1/2003 Ohsawa et al. ................ D26/35
TW
(TW) * cited by examiner
(**) Term: 14 Years Primary Examiner — Marcus Jackson
(74) Attorney, Agent, or Firm — WPAT, P.C.; Anthony King
(21) Appl. No. 29/417,089 (57) CLAM
I claim, the ornamental design for a light guide bar for a
(22) Filed: Mar 29, 2012 vehicle lamp, as shown and described.
DESCRIPTION
(51) LOC (10) Cl. ................................................ 26-06
FIG. 1 is a perspective view of a light guide bar for a vehicle
(52) U.S. Cl. lamp showing my present design;
USPC ........................................................... D26/35 FIG.
FIG. 23 isis aa front viewthereof;
rear view thereof;
(58) Field of Classification Search FIG. 4 is a left view thereof;
FIG. 5 is a right view thereof;
USPC ............. D10/1144; 26/28–36; 362/459. 468, FIG. 6 is a top plan view thereof; and,
362/475 478, 485 487 FIG. 7 is a bottom plan view thereof.
U.S. Patent Jun. 10, 2014 Sheet 1 of 4 USD706,966S
F I G 1


F I G . 6
F I G . 7
Exhibit C
USOOD706967S
(12) United States Design Patent (10) Patent No.: USD706,967 S

Lai (45) Date of Patent: Jun. 10, 2014
(56) References Cited
(54) LIGHT GUIDE BAR FORVEHICLE LAMP
(75) Inventor: Ching-Tsung Lai, Tainan (TW) D295,064 S * 4, 1988 Hardiman et al. ........... D21,613
D345,331 S * 3/1994 Smith .......................... D12/222
(73) Assignee: Litek Enterprise Co., Ltd., Tainan D449,393 S * 10/2001 Yamamoto et al. ... D26, 28
D469,196 S * 1/2003 Ohsawa et al. ................ D26/35
TW
(TW) * cited by examiner
(**) Term: 14 Years Primary Examiner — Marcus Jackson
(74) Attorney, Agent, or Firm — WPAT, P.C.; Anthony King
(21) Appl. No. 29/417,090 (57) CLAM
I claim, the ornamental design for a light guide bar for a
(22) Filed: Mar 29, 2012 vehicle lamp, as shown and described.
DESCRIPTION
(51) LOC (10) Cl. ................................................ 26-06
FIG. 1 is a perspective view of a light guide bar for a vehicle
(52) U.S. Cl. lamp showing my present design;
USPC ........................................................... D26/35 FIG.
FIG. 23 isis aa front viewthereof;
rear view thereof;
(58) Field of Classification Search FIG. 4 is a left view thereof;
FIG. 5 is a right view thereof;
USPC .......... D10/114.4; D26/28–36; 362/459–468, FIG. 6 is a top plan view thereof; and,
362/475 478, 485 487 FIG. 7 is a bottom plan view thereof.
U.S. Patent Jun. 10, 2014 Sheet 1 of 4 USD706,967 S
F I G .. 1
F I G .. 2
F I G 3

F I G . 7

Eagle Eyes Traffic Industry USA v. JL Concepts - Complaint

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Case 2:19-cv-07328 Document 1 Filed 08/23/19 Page 1 of 14 Page ID #:1

1 ALEXANDER CHEN [SBN 245798]

9 UNITED STATES DISTRICT COURT

17 transactions and sales in this district.

27 California and the Central District of California.

8 Las Vegas Nevada 89130.

9 7. Defendant JL Concepts, LLC dba GT Racers(“JLConcepts”) is a corporation registered

11 located at 21912 Garcia Lane, Walnut, California 91789.

20 THE ASSERTED PATENTS

10 assignments are attached hereto as Exhibit “C.”

13 DEFENDANT’S INFRINGEMENT OF EAGLE EYES’ PATENTS

15 Defendant’s projection headlights incorporating the Patented Designs.

19 INFRINGEMENT OF THE ’040PATENT BY DEFENDANT

21 paragraphs 1 through 14 above.

25 surface configuration of a vehicular headlight as shown below:

8 paragraphs 1 through 25 above.

12 guide bar for a vehicle lamp as shown below:

9 the ’966 Patent and which is proprietary to Plaintiff.

15 1500/2500 Chrome Drl U-Halo Led Projector Headlights.

22 supposing it to be the other

28 features of the ’966 Patent.

7 INFRINGEMENT OF THE ’967PATENT BY DEFENDANT

9 paragraphs 1 through 36 above.

13 guide bar for a vehicle lamp as shown below:

9 the ’967 Patent and which is proprietary to Plaintiff.

15 1500/2500 Chrome Drl U-Halo Led Projector Headlight.

27 upon the features of the ’967 Patent.

7 1. The determination that Defendant has infringed the Patents -in-Suit;

13 Suit to be determined at trial;

14 4. A finding that this case is exceptional and an award of reason

15 pursuant to 35 U.S.C. § 285;

17 costs and expenses; and,

DEMAND FOR JURY TRIAL

(12) United States Design Patent (10) Patent No.: US D690,040 S

U.S. Patent Sep. 17, 2013 Sheet 1 of 4 US D690,040 S

U.S. Patent Sep. 17, 2013 Sheet 2 of 4 US D690,040 S

U.S. Patent Sep. 17, 2013 Sheet 3 of 4 US D690,040 S

U.S. Patent Sep. 17, 2013 Sheet 4 of 4 US D690,040 S

(12) United States Design Patent (10) Patent No.: USD706,966S

U.S. Patent Jun. 10, 2014 Sheet 1 of 4 USD706,966S

U.S. Patent Jun. 10, 2014 Sheet 2 of 4 USD706,966S

U.S. Patent Jun. 10, 2014 Sheet 3 of 4 USD706,966S

U.S. Patent Jun. 10, 2014 Sheet 4 of 4 USD706,966S

(12) United States Design Patent (10) Patent No.: USD706,967 S

U.S. Patent Jun. 10, 2014 Sheet 1 of 4 USD706,967 S

U.S. Patent Jun. 10, 2014 Sheet 2 of 4 USD706,967 S

U.S. Patent Jun. 10, 2014 Sheet 3 of 4 USD706,967 S

U.S. Patent Jun. 10, 2014 Sheet 4 of 4 USD706,967 S

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