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 1. For its Complaint, Plaintiff National Products, Inc.

(NPI) states and alleges as follows: The Parties NPI is a corporation organized and existing under the laws of the State of v. CHOE Technology, Defendant. JURY TRIAL DEMANDED UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE NATIONAL PRODUCTS, INC., Plaintiff, COMPLAINT Case No. 2:14-cv-348

Washington, having its principal place of business at 8410 Dallas Avenue S., Seattle, Washington 98108. 2. NPI is a market leader in the design, manufacture, and sale of innovative

mounting systems, including suction cup mounts capable of securing a variety of portable devices. 3. Upon information and belief, CHOE Technology (CHOE) is a corporation

organized and existing under the laws of the Peoples Republic of China, having its principal place of business at 4B Huashang International, Donghuan 2nd Road, Longhua District,
COMPLAINT Case No. 2:14-cv-348 -1FENWICK & WEST LLP
1191 SECOND AVENUE, 10TH FLOOR SEATTLE, WASH NGTON 98101 TELEPHONE 206.389.4510 FACS M LE 206.389.4511

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Shenzhen, Guangdong 518000, China. 4. Upon information and belief, CHOE is a manufacturer, distributor, and seller

of wireless charging systems and a wireless car charger dock for mobile phones that includes a suction cup mount. CHOE markets, distributes, and sells its products to the public throughout the United States, including within this judicial district, directly through its internet website and through online retailers such as Amazon.com. On information and belief, CHOE has advertised, distributed, and sold the products which are the subject of the patent infringement alleged in this lawsuit in this district. Jurisdiction and Venue 5. This is an action for patent infringement arising under the Acts of Congress

relating to patents, 35 U.S.C. 271, 281285. 6. 1338(a). 7. Venue is proper in this judicial district under 28 U.S.C. 1391 and 1400(b). The 420 Patent 8. On December 23, 2003, U.S. Patent No. 6,666,420 (the 420 patent), entitled This Court has subject matter jurisdiction under 28 U.S.C. 1331 and

Suction Cup Having Compact Axial Installation and Release Mechanism, was duly and legally issued to Jeffrey D. Carnevali. NPI acquired all right, title, and interest to the patent on May 20, 2005. NPI has owned the 420 patent throughout the period of CHOEs infringing acts and still owns the patent. A copy of the 420 patent is attached as Exhibit A. The 420 patent is generally directed towards a suction cup apparatus that mounts and secures a variety of portable devices. Count I Patent Infringement 9. 10. NPI realleges and reincorporates the allegations in paragraphs 18 above. CHOE has been, is currently, and will continue to directly infringe one or more

claims of the 420 patent by making, using, offering to sell, and/or selling within the United
COMPLAINT Case No. 2:14-cv-348 -2FENWICK & WEST LLP
1191 SECOND AVENUE, 10TH FLOOR SEATTLE, WASH NGTON 98101 TELEPHONE 206.389.4510 FACS M LE 206.389.4511

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States, and/or importing into the United States, products that infringe the 420 patent, including without limitation all Qi Wireless Car Charger Docks, including in this judicial district. 11. As a direct and proximate consequence of CHOEs infringement of the 420

patent, NPI has suffered irreparable harm, and NPI will continue to suffer irreparable harm in the future unless CHOE is enjoined from infringing the 420 patent. 12. Upon information and belief, the continued infringement by CHOE of the 420

patent is willful. Prayer for Relief WHEREFORE, NPI prays for the following relief: a. b. A judgment that CHOE has infringed the 420 patent; An order preliminarily and permanently enjoining and restraining CHOE, its

officers, directors, agents, servants, employees, licensees, attorneys, and all other persons acting under or through CHOE, directly or indirectly, from infringing the 420 patent; c. A judgment and order requiring that CHOE pay damages under 35 U.S.C.

284, including treble damages as provided by 35 U.S.C. 284, with prejudgment interest; d. A judgment and order directing CHOE to pay the costs of this action

(including all disbursements) and attorneys fees as provided by 35 U.S.C. 285, with prejudgment interest; e. Such other and further relief as the Court may deem just and equitable.

COMPLAINT Case No. 2:14-cv-348

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FENWICK & WEST LLP

1191 SECOND AVENUE, 10TH FLOOR SEATTLE, WASH NGTON 98101 TELEPHONE 206.389.4510 FACS M LE 206.389.4511

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COMPLAINT Case No. 2:14-cv-348

Demand for Jury Trial NPI hereby demands a trial by jury of all issues so triable.

NATIONAL PRODUCTS, INC. By its attorneys, Dated: March 10, 2014 FENWICK & WEST LLP

By: s/David K. Tellekson David K. Tellekson (WSBA No. 33523) By: s/Elizabeth B. Hagan Elizabeth B. Hagan (WSBA No. 46933) 1191 Second Avenue, 10th Floor Seattle, WA 98101 Telephone: 206.389.4510 Facsimile: 206.389.4511 Email: dtellekson@fenwick.com edavison@fenwick.com ehagan@fenwick.com Attorneys for Plaintiff National Products, Inc.

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FENWICK & WEST LLP

1191 SECOND AVENUE, 10TH FLOOR SEATTLE, WASH NGTON 98101 TELEPHONE 206.389.4510 FACS M LE 206.389.4511