C.J. Veverka (Utah State Bar No. 7110; Email: cveverka@mabr.

com)
R. Parrish Freeman (Utah State Bar No. 7529; Email: pfreeman@mabr.com)
Rachel Jacques (Utah State Bar No. 13250; Email: rjacques@mabr.com)
MASCHOFF BRENNAN
1389 Center Drive, Suite 300
Park City, Utah 84098
Telephone: (435) 252-1360
Facsimile: (435) 252-1361

Attorneys for Plaintiff
Wilson Electronics, LLC

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
CENTRAL DIVISION


Wilson Electronics, LLC, a Delaware limited
liability company,

Plaintiff,
v.

CellPhone-Mate, Inc., a California corporation,

Defendant.
Civil Action No. 2:14-cv-00548-PMW

COMPLAINT FOR PATENT
INFRINGEMENT

Magistrate Paul M. Warner

(JURY TRIAL DEMANDED)

For its complaint against defendant CellPhone-Mate, Inc. (Defendant or CellPhone-
Mate), plaintiff Wilson Electronics, LLC (Plaintiff or Wilson) hereby as follows:
PARTIES
1. Wilson is a limited liability company organized and existing under the laws of the
State of Delaware, with its principal place of business located at 3301 East Deseret Drive, Saint
George, Utah 84790.

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2. Upon information and belief, Defendant is a corporation organized and existing
under the laws of the State of California, with its principal place of business located at 48346
Milmont Drive, Fremont, California 94538.
JURISDICTION
3. This is a civil action for patent infringement brought by Wilson for acts
committed by Defendant arising under the patent laws of the United States, 35 U.S.C. 1 et seq.
4. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.
1331 and 1338(a).
5. Upon information and belief, Defendant has sold or contracted for the sale of
infringing goods within the State of Utah or induced others to sell or contract for the sale of
infringing goods within the State of Utah. These actions by Defendant have resulted in injury to
Wilson and relate to, and in part give rise to, the claims asserted herein.
6. This Courts exercise of personal jurisdiction over Defendant is consistent with
the Constitutions of the United States and the State of Utah. Moreover, this Court has personal
jurisdiction over Defendant pursuant to the Utah Long Arm Statute, Utah Code Ann. 78B-3-
205.
7. Pursuant to 28 U.S.C. 1391(c), Defendant is deemed to reside in this judicial
district for purposes of venue.
8. Venue is proper in this judicial district pursuant to, at least, 28 U.S.C.
1391(b)(1), 1391(b)(2), and 1400(b).

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FIRST CLAIM FOR RELIEF
(Infringement of the D694,735 Patent)
9. Wilson hereby incorporates the allegations of the preceding paragraphs 1 through
8 of this Complaint into this First Claim for Relief as though fully set forth herein.
10. United States Design Patent Nos. D694,735 (the 735 Patent) titled Amplifier
Case with Moderate Flanges issued from the United States Patent and Trademark Office
(USPTO) on December 3, 2013. (A true and correct copy of the 735 Patent is attached hereto
as Exhibit 1.)
11. Wilson is the owner of all right, title, and interest in and to the 735 Patent,
including the right to sue for and recover all past, present, and future damages for infringement
of the 735 Patent, and to enjoin acts of infringement of the 735 Patent.
12. Neither Wilson nor any authorized third party has licensed or otherwise
authorized Defendant to practice the 735 Patent.
13. Defendant has made, used, offered to sell, sold, and/or imported into the United
States, and still is making, using, offering to sell, selling, and/or importing into the United States
several products having a design that infringes Wilsons 735 Patent, without Wilsons
authorization. Such products include, but are not necessarily limited to, the Flex2Go 3G cell
phone signal booster kit for vehicles.
14. Wilson has been irreparably harmed and will continue to be irreparably harmed
by Defendants infringement of the 735 Patent unless Defendant is enjoined by this Court from
committing further acts of infringement of the 735 Patent.

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PRAYER FOR RELIEF
WHEREFORE, Wilson prays for entry of a final order and judgment that:
1. Defendant has infringed the 735 Patent;
2. Defendant account for and pay to Wilson all damages caused by its infringement
of the 735 Patent and a trebling of damages for willful infringement under 35 U.S.C. 284, or
an award of Defendants profits from its infringement pursuant to 35 U.S.C. 289, whichever is
greater;
3. Wilson be granted permanent injunctive relief pursuant to 35 U.S.C. 283
enjoining Defendant, its officers, agents, servants, employees, and all those persons in active
concert or participation with them from further acts of patent infringement;
4. Wilson be granted pre-judgment and post-judgment interest on the damages
caused to it by reason of Defendants infringement of the 735 Patent;
5. The Court declare this an exceptional case and that Wilson be granted its
reasonable attorneys fees in accordance with 35 U.S.C. 285;
6. Costs be awarded to Wilson; and
7. Wilson be granted such other and further relief as the Court may deem just and
proper under the circumstances.

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DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Wilson demands trial by
jury on all claims and issues so triable.

DATED: July 28, 2014 MASCHOFF BRENNAN

By: /s/ R. Parrish Freeman
C.J. Veverka
R. Parrish Freeman
Rachel Jacques
Attorneys for Wilson Electronics, LLC