IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION ) ) ) ) ) ) ) ) ) ) ) ) )

A-VENTURES, INC., Plaintiff, v. NORMAN INTERNATIONAL, INC., Defendant.

Civil Action No. 3:13-cv-230 Jury Trial Demanded

COMPLAINT Plaintiff A-Ventures, Inc. (AVI) hereby files its Complaint against Norman International, Inc. (Norman), and alleges on personal knowledge as to its actions, and upon information and belief as to the actions of others, as follows: NATURE OF THE SUIT 1. This is a claim for patent infringement arising under the patent laws of the

United States, Title 35 of the United States Code. THE PARTIES 2. AVI is a corporation organized and existing under the laws of the State of

South Carolina, having a principal place of business at 4201-A Sentry Post Road, Charlotte, NC 28208. 3. AVI is a manufacturer and supplier of hardware and poly profiles for the

shutter industry.

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On October 24, 2006, United States Patent No. 7,124,537 (the 537

patent) was duly and legally issued for an invention entitled Decorative Shutter with Hidden Louver Control. A copy of the 537 patent is attached hereto at Exhibit A. 5. AVI is the owner and assignee of the 537 patent, and AVI owns all right,

title, and interest in and to the 537 patent. 6. Upon information and belief, Norman is a corporation organized and

existing under the laws of the State of California, having a principal place of business at 12301 Hawkins Street, Santa Fe Springs, California 90670. JURISDICTION AND VENUE 7. This Court has subject matter jurisdiction over this action upon at least the

following grounds: (a) 28 U.S.C. 1331, this being a civil action arising under the laws of the United States; and (b) 28 U.S.C. 1338(a), this being a civil action arising under the Patent Laws of the United States, namely, 35 U.S.C. 1 et seq.; 8. This Court has personal jurisdiction over Norman inasmuch as Norman is

doing business in this State, has significant contacts with this State, has offered for sale and sold infringing products in this State, maintains sales representatives in this State, has purposefully shipped or caused to be shipped infringing products into this State through established distribution channels, and/or has committed acts in this State that are the subject of the counts set forth herein. 9. Venue is proper in this District under the provisions of 28 U.S.C.

1391(b) and (c) insofar as Norman has committed acts of infringement in this District.

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COUNT I PATENT INFRINGEMENT UNDER 35 U.S.C. 271 10. AVI incorporates by reference the allegations contained in Paragraphs 1

through 9 above. 11. 12. Pursuant to 35 U.S.C. 282, the 537 patent is presumed valid. Norman has made, used, sold, offered to sell and/or imported into the

United States window and door shutters including a hidden louver control system that infringe the 537 patent, and continues to do so without authority from AVI. 13. Norman is directly infringing, literally and/or under the doctrine of

equivalents, the 537 patent, including but not limited to Claim 1 of the 537 patent. 14. Normans infringing acts include, but are not limited to, the manufacture,

use, sale, offer for sale, and/or importation of infringing window and door shutters, including but not limited to such window and door shutters employing or incorporating InvisibleTilt. Norman is therefore liable for infringement of the 537 patent pursuant to 35 U.S.C. 271. 15. On information and belief, Norman has made, used, sold, offered to sell,

and/or imported, and continues to make, use, sell, offer for sale, and/or import, products that infringe the 537 patent. 16. Normans infringing activities have harmed AVI, and AVI is entitled to

recover damages adequate to compensate it for such infringement. Further, Normans infringing activities are harming AVI and will continue to harm AVI, causing irreparable injury for which there is no adequate remedy at law unless and until enjoined by the Court.

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RELIEF SOUGHT WHEREFORE, AVI respectfully requests that the Court enter judgment against Norman and against its subsidiaries, successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation with them, granting the following relief: A. The entry of judgment in favor of AVI and against Norman for

infringement of the 537 patent; B. An award of damages against Norman for an amount that will adequately

compensate AVI for Normans infringement, but under no circumstances an amount less than a reasonable royalty for Normans use of AVIs patented inventions as permitted by 35 U.S.C. 284; C. 285; D. A permanent injunction prohibiting Norman and its subsidiaries, An award to AVI of all remedies available under 35 U.S.C. 284 and

successors, parents, affiliates, officers, directors, agents, servants, employees, and all persons in active concert or participation with them, from further infringement of the 537 patent; E. The entry of judgment in favor of AVI and against Norman for pre-

judgment and post-judgment interest on all damages awarded to AVI; and F. The entry of such other and further relief that AVI is entitled to under law

and any other and further relief that this Court or a jury may deem just and proper. DEMAND FOR JURY TRIAL AVI requests a trial by jury on all issues presented in this Complaint.

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This 11th day of April, 2013. _s/ Jason A. Friday_____________ Kirk T. Bradley (N.C. Bar. #26490) kirk.bradley@alston.com Jason A. Friday (N.C. Bar #38168) jason.friday@alston.com ALSTON & BIRD LLP 101 South Tryon Street, Suite 4000 Charlotte, North Carolina 28280-4000 (704) 444-1000 (telephone) (704) 444-1111 (facsimile) Attorneys for Plaintiff A-Ventures, Inc.

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