WhatRHolding - Bouncy House Copyright Trade Dress Patent PDF

Jeffrey S.
Kravitz (SBN 66481)

jskravitz@foxrothchild.com
Lena N. Bacani (SBN 213556)
lbacani@foxrothschild.com
FOX ROTHSCHILD LLP
1055 W. 7th Street, Suite 1880
Los Angeles, CA 90017-2544
Telephone: 213.624.6560 I Facsimile: 213.622.1154
Attorneys for Plaintiffs WhatRU Holding, LLC
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
LOS ANGELES DIVISION
Case No.: 2:14-CV-05187-BRO-
PLA
AMENDED COMPLAINT FOR:
1. PATENT INFRINGEMENT (35
U.S.C. 271 AND 281)
2. COPYRIGHT INFRINGEMENT
(17 U.S.C. 101, et seq.)
3. TRADE DRESS INFRINGMENT
4. TRADE DRESS DILUTION
AND FEDERAL UNFAIR
COMPETITION (15 U.S.C.
1125(a))
5. CALIFORNIA UNFAIR
COMPETITION (CAL. BUS. &
PROF. CODE 17200, et seq.)
JURY TRIAL DEMANDED
WHATRU HOLDING, LLC,
a Minnesota limited liability company,
Plaintiff,
vs.
BOUNCING ANGELS, INC., a
California corporation, EZ
INFLATABLES, INC. a California
corporation, and DOES 1-10 inclusive,
Defendants.
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Case 2:14-cv-05187-BRO-PLA Document 91 Filed 09/18/14 Page 1 of 47 Page ID #:647
Plaintiff WhatRU Holding, LLC ("WhatRU Holding" ), for its Complaint
against Defendants Bouncing Angels, Inc., EZ Inflatables, Inc. and DOES 1 to 10
(collectively, "Defendants"), alleges and states as follows:
NATURE OF THE ACTION
1. This is an action for patent infringement under the patent laws of the
United States, 35 U.S.C. 1, et seq., including 35 U.S.C. 271 and 281; for
copyright infringement under the Copyright Act of 1976, 17 U.S.C. 101, et seq.; for
trade dress infringement, federal unfair competition and false designation of origin
under Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a); and for the related unfair
competition claim under the laws of the State of California, Cal. Bus. & Prof. Code
17200, et seq. The claims arise out of Defendants' actions with respect to certain
inflatable bouncer products, as more fully described herein, owned, patented, and
copyrighted by Plaintiff and which contain Plaintiff's valuable trade dress.
JURISDICTION AND VENUE
2. This Court has original subject matter jurisdiction over the claims in this
action that relate to patent infringement, trade dress infringement, false designation of
origin and federal unfair competition pursuant to 35 U.S.C. 271 and 281, 28 U.S.C.
1331 and 1338, 15 U.S.C. 1121(a), and 1125(a) as these claims arise under the
laws of the United States. The Court has supplemental jurisdiction over the claims in
this Complaint that arise under state statutory or common law pursuant to 28 U.S.C.
1367(a) because the state law unfair competition claim is so related to the federal
claims that it forms part of the same case or controversy and derives from a common
nucleus of operative facts.
3. This Court has personal jurisdiction over Defendants by virtue of the fact
that Defendants are California corporations with their principal place of business in
this District who are transacting business in this District.
4. Venue is proper in this district pursuant to 28 U.S.C. 1391(b)(1), (2)
and 1400(a) and (b).
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THE PARTIES
5. Plaintiff WhatRU Holding, LLC ("WhatRU") is a Minnesota limited
liability company organized and existing under the laws of the State of Minnesota, and
maintains its principal place of business at 10665 Alameda Avenue in Inver Grove
Heights, MN 55077. WhatRU Holding designs original inflatables, including
bouncers and other party accessories. WhatRU Holding is the sole and exclusive
assignee of a utility patent in an inflatable bouncer, as defined below, and the owner
and licensor of copyrights in two inflatable sculptures entitled "Carousel Bouncer"
and "Fire Truck Bus" as further defined below.
6. Defendant Bouncing Angels, Inc. is a corporation organized and existing
under the laws of the State of California, and maintains its principal place of business
at 895 North Todd Avenue, Azusa, CA 91702. Defendant does business in this
District and holds itself out as a manufacturer of inflatable party supplies, including
bouncers, covered under the patent-in-suit and/or copyrights owned by Plaintiff.
7. Defendant EZ Inflatables, Inc. is a corporation organized and existing
under the laws of the State of California, and maintains its principal place of business
at the same address as Defendant Bouncing Angels, which is at 895 North Todd
Avenue, Azusa, CA 91702. Defendant does business in this District and holds itself
out as a manufacturer of inflatable party supplies, including a bouncer, covered under
the patent-in-suit and/or the copyrights owned by Plaintiff.
8. Plaintiff does not know the true names of Defendants DOES 1 to 10 and
therefore sues them by those fictitious names. Plaintiff is informed and believes, and
on the basis of that information and belief alleges, that each of those Defendants was
in some manner legally responsible for the events and happenings alleged in this
Complaint and for Plaintiff's damages. The names, capacities and relationships of
DOES 1 to 10 will be alleged by amendment to this Complaint when they become
known.
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The '608 PATENT
9. On October 30, 2003, inventors Robert Field and Brian Field filed a
patent application in the United States Patent and Trademark Office ("USPTO")
covering a novel inflatable bouncer. In response, the USPTO issued U.S. Patent No.
7,108,608 (the '608 Patent"). A true and correct copy of the '608 Patent is attached
hereto as "Exhibit A" and by reference is made a part hereof.
10. WhatRU Holding is the owner by assignment of all legal rights, title, and
interest in, to, and under the '608 Patent, including the right to bring the suit for
damages and injunctive relief for infringement thereof.
WHATRU HOLDING'S COPYRIGHTS
THE '471 COPYRIGHT
11. Since 1996, Robert and Brian Field have endeavored to create unique and
original inflatable bouncers and party accessories. They started a company to sell
their unique creations, called Cutting Edge Creations, Inc.
12. In 2002, Cutting Edge Creations, Inc. ("Cutting Edge") completed an
original work of an inflatable sculpture entitled "Carousel Bouncer," and first
published said work in the United States on November 20, 2002.
13. "Carousel Bouncer" consists of an inflatable sculpture which is shaped to
resemble a circus carousel.
14. "Carousel Bouncer" has been registered with the United States Copyright
Office as Copyright Registration No. VA-1-201-471 (the '471 Copyright"), having
an effective date of registration of June 6, 2003. A true and correct copy of the '471
Copyright is attached hereto, marked as "Exhibit B" and by reference is made a part
hereof.
15. In 2010, Cutting Edge was forced to liquidate when its only secured
lender, Eagle Valley Bank, declined to renew Cutting Edge's annual note, despite the
fact that Cutting Edge was in compliance.
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16. On September 28, 2010, WhatRU Holding, LLC, a company formed by
Robert and Brian Field, purchased the '471 Copyright and all legal rights thereto.
17. WhatRU Holding is the owner of the '471 Copyright, and was and
continues to be the owner of all legal rights, title, and interest in, to, and under the
`471 Copyright.
THE '909 COPYRIGHT
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18. In 2008, Cutting Edge completed an original work of an inflatable

8 sculpture entitled "Fire Truck Bus," and first published said work in the United States
9 on November 15, 2008.
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19. "Fire Truck Bus" consists of an inflatable sculpture which is shaped to

11 resemble a fire truck.
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20. "Fire Truck Bus" has been registered with the United States Copyright
13 Office as Copyright Registration No. VA-1-835-909 (the '909 Copyright"), having
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an effective date of registration of October 31, 2012. A true and correct copy of the
15 `909 Copyright is attached hereto, marked as "Exhibit C" and by reference is made a
16 part hereof.
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21. WhatRU Holding is the owner of the '909 Copyright, and was and
18 continues to be the owner of all legal rights, title, and interest in, to, and under the
19 `909 Copyright.
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DEFENDANTS' INFRINGING ACTIVITIES
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22. During the 2012 trade show for the International Association of
22 Amusement Parks and Attractions ("IAAPA") in Orlando, Florida, WhatRU Holding
23 employees were surprised to discover that Defendants were advertising to sell knock-
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offs of WhatRU Holding's Carousel and Fire Truck bouncers in Defendants' catalogs
25 that were being handed out to trade show customers.
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23. WhatRU Holding immediately contacted the IAAPA show's
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management about Defendants' blatant violation of WhatRU Holding's copyrights.

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24. The IAAPA's legal department subsequently forced Defendants to
remove the image of their Carousel product from their catalog. While Defendants did,
in fact remove the image of the Carousel for a time, Defendants began to again hand
out catalogs that included the Carousel the last two days of the IAAPA show. The
IAAPA informed WhatRU Holding that they would issue sanctions against
Defendants for their willful infringement of WhatRU Holdings' copyrights, but
WhatRU Holding has never received notice that such sanctions were actually levied.
25. At no time has WhatRU Holding authorized Defendants to offer for sale,
sell, use, and/or import or to make the invention protected by the '608 Patent.
26. At no time has WhatRU Holding authorized Defendants to sell, adapt,
distribute, reproduce, or display and import into the United States the works which are
the subject of the '471 and '909 Copyrights.
27. Defendants, through their agents, employees, or representatives, have and
continue to, intentionally and willfully infringe the '608 Patent and '471 Copyright by
directly or indirectly making, using, offering for sale, selling, and distributing in
interstate commerce certain products, such as that identified as "Carousel Jumper"
(Model No. B101). Photographic depictions of these products are attached hereto,
marked as "Exhibit D" and "Exhibit E," and by reference made a part hereof.
Defendants have and are presently offering for sale, selling, and distributing these
products on their on-line websites at www.bouncingangels.com and www.ez-
inflatables.com.
28. Defendants, through their agents, employees, or representatives, have and
continue to, intentionally and willfully infringe the '909 Copyright by directly or
indirectly making, using, offering for sale, selling, and distributing in interstate
commerce certain products, such as that identified as "Fire Engine" (Model No.
B148). Photographic depictions of these products are attached hereto, marked as
"Exhibit F" and "Exhibit G," and by reference made a part hereof. Defendants have
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and are presently offering for sale, selling, and distributing these products on their on-
line websites at www.bouncingangels.com and www.ez-inflatables.com.
29. Upon information and belief, Defendants are presently offering for sale,
selling, and distributing these products, either directly or indirectly, on other websites.
FIRST CLAIM FOR RELIEF
INFRINGEMENT OF THE '608 PATENT
30. WhatRU Holding realleges and incorporates by reference all of the
preceding paragraphs of this Complaint as though fully set forth herein.
31. Defendants, through their agents, employees and representatives, have
infringed and continue to infringe at least Claim 1 of the '608 Patent (Exhibit A) in
violation of 35 U.S.C. 271(a) by at least directly and/or indirectly making, using,
selling, offering for sale, and/or importing an inflatable bouncer called the "Carousel
Jumper" (Model No. B101) (Exhibits D and E) as claimed in the '608 Patent.
32. Defendants have induced, caused, and/or contributed to the infringement
of the '608 Patent by contributing to or inducing others to make, sell, offer for sale, or
import into the United States inflatable bouncers covered by the '608 Patent in
violation of 35 U.S.C. 271(b) and (c).
33. WhatRU Holding has given notice to the public of the articles patented
under the '608 Patent in accordance with 35 U.S.C. 287(a).
34. Defendants' infringing activities have been and continue to be knowing,
deliberate, willful, and wanton, and in conscious disregard of WhatRU Holding's
patented rights, making this an exceptional case within the meaning of 35 U.S.C.
285.
35. WhatRU Holding has sustained damages as a direct and proximate result
of Defendants' infringing activities and will continue to sustain damages in the future
unless the infringement of the '608 Patent is permanently enjoined by this Court.
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36. Pursuant to 35 U.S.C. 284, WhatRU Holding is entitled to damages for
Defendants' infringing acts and treble damages together with interests and costs as
fixed by this Court.
37. Pursuant to 35 U.S.C. 285, this action qualifies as an exceptional case
and WhatRU Holding is entitled to reasonable attorneys' fees for the necessity of
bringing this claim.
38. Due to the aforesaid infringing acts, WhatRU Holding has suffered great
and irreparable injury, for which WhatRU Holding has no adequate remedy at law.
Defendants will continue to infringe the '608 Patent to the great and irreparable injury
of WhatRU Holding, unless enjoined by this Court.
SECOND CLAIM FOR RELIEF
COPYRIGHT INFRINGEMENT
40. Defendants' products identified as "Carousel Jumper" (Model No. B101)
(Exhibits D and E) are substantially similar to the work copyrighted by the '471
Copyright (Exhibit B) and constitute an unauthorized copy or derivative work thereof.
41. Defendants' products identified as "Fire Engine" (Model No. B148)
(Exhibits F) are substantially similar to the work copyrighted by the '909 Copyright
(Exhibit C) and constitute an unauthorized copy or derivative work thereof.
42. Defendants, through their agents, employees and representatives, have
willfully, directly, and/or indirectly, sold and are offering for sale in interstate
commerce unauthorized copies or derivative works of WhatRU Holding's copyrighted
works and have in fact sold and distributed such unauthorized copies or derivative
works for financial gain.
43. Defendants, through their agents, employees, and representatives, have
infringed and continue to infringe the '471 and '909 Copyrights in violation of 17
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U.S.C. 106, 501(a), and 602(a) by distributing, selling, and displaying the
copyrighted works and importing the copyrighted works into the United States.
44. Defendants have induced, caused, and materially contributed to the
infringement of the '471 and '909 Copyrights in violation of 17 U.S.C. 106 and
501(a) and are, therefore, liable as contributory infringers. Such acts include, but
are not necessarily limited to, Defendants' offering to sell, selling, and distributing the
copyrighted works or derivative works thereof to others to offer to sell, distribute and
display.
45. WhatRU Holding has sustained damages as a direct and proximate result
of Defendants' infringing activities and will continue to sustain damages in the future
unless Defendants' infringement of the '471 and '909 Copyrights is permanently
enjoined by this Court pursuant to 17 U.S.C. 502.
46. Defendants' infringing activities have damaged WhatRU Holding,
entitling it to actual damages and Defendants' profits, or statutory damages, under 17
U. S .C. 504.
47. Defendants' infringing activities have been and continue to be knowing,
deliberate, willful, and wanton, and in conscious disregard of WhatRU Holding's
copyrights, entitling WhatRU Holding to increased statutory damages under 17 U.S.C.
504(b)(2).
48. WhatRU Holding is entitled to its costs and reasonable attorneys' fees for
the necessity of bringing this claim under 17 U.S.C. 505.
49. By reason of Defendants' direct and/or indirect infringement of WhatRU
Holding's copyrights, WhatRU Holding has sustained and will continue to sustain
substantial and irreparable injury and loss, and has sustained and will continue to
sustain damages, unless Defendants are enjoined from such conduct by this Court.
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THIRD CLAIM FOR RELIEF
FEDERAL TRADE DRESS INFRINGEMENT
(15 U.S.C. 1125(a))
51. Subsequent to acquisition of secondary meaning by WhatRU Holding's
non-functional trade dress described herein, Defendants developed, manufactured,
imported, advertised, used, and/or sold products that use trade dress substantially and
confusingly similar to WhatRU Holding's non-functional trade dress. Particularly,
Defendants' "Carousel Jumper" (Model No. B101) (Exhibits D and E) is substantially
similar to the design, image, and overall appearance of WhatRU Holding's "Carousel
Bouncer." Defendants' "Fire Engine" (Model No. B148) (Exhibits F and G) is
substantially similar to the design, image, and overall appearance of WhatRU
Holding's "Fire Truck Bus."
52. Defendants' "Carousel Jumper" and "Fire Engine" products identified
herein are directed to the same consumers as WhatRU Holding's "Carousel Bouncer"
and "Fire Truck Bus" ("WhatRU Holding's Trade Dress").
53. Defendants' use of a trade dress that imitates or simulates WhatRU
Holding's Trade Dress as set forth above is likely to cause confusion, or to cause
mistake, or to deceive as to the affiliation, connection, or association of the
Defendants with WhatRU Holding among members of the public or as to the origin,
sponsorship, or approval of Defendants' products by WhatRU Holding.
54. Defendants' use of confusingly similar trade dress is likely to and does
permit Defendants to misappropriate and unfairly trade upon the valuable good will
and reputation of WhatRU Holding.
55. WhatRU Holding is informed and believes, and thereon alleges, that
Defendants' acts of trade dress infringement were undertaken willfully with the
express intent to cause confusion, and to mislead and deceive the purchasing public.
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Defendants have derived and received, and will continue to derive and receive, gains,
profits and advantages from Defendants' trade dress infringement in an amount not
presently known by WhatRU Holding.
57. Defendants, by their above-described actions, have infringed and
continue to infringe the rights of WhatRU Holding in its WhatRU Holding Trade
Dress in violation of Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a).
58. As a direct and proximate result of Defendants' actions constituting trade
dress infringement, WhatRU Holding has suffered, and continues to suffer, great and
irreparable injury, for which WhatRU Holding has no adequate remedy at law.
59. Pursuant to 15 U.S.C. 1117, WhatRU Holding is entitled to damages
for Defendants' infringing acts, up to three times actual damages as fixed by this
Court, and its reasonable attorneys' fees for the necessity of bringing this claim.
FOURTH CLAIM FOR RELIEF
FALSE DESIGNATION OF ORIGIN AND FEDERAL UNFAIR
COMPETITION
(15 U.S.C. 1125(a))
61. Defendants deliberately market, promote, and advertise products that are
outwardly extremely like and similar to the look, feel, appearance, and design of
products produced by WhatRU Holding.
62. Defendants' use of WhatRU Holding's Trade Dress without WhatRU
Holding's consent constitutes a false designation of origin, which is likely to cause
confusion, or to cause mistake, or to deceive as to the affiliation, connection, or
association of Defendants with WhatRU Holding, or as to the origin, sponsorship, or
approval of Defendants' goods and/or commercial activities by WhatRU Holding in
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violation of 15 U.S.C. 1125(a) and constitutes unfair competition with WhatRU
Holding.
63. Defendants' use of the WhatRU Holding Trade Dress without WhatRU
Holding's consent constitutes a false designation of origin, which in commercial
advertising or promotion, misrepresents the nature, characteristics, qualities, or
geographic origin of Defendants' goods or commercial activities in violation of 15
U.S.C. 1125(a) and constitutes unfair competition with WhatRU Holding.
64. WhatRU Holding has a well-known and established history of designing
and licensing these particular inflatables and party accessories. By engaging in
national advertising via their websites www.bouncingangels.com and www.ez-
inflatables.com that reflect products that are outwardly extremely like and similar to
WhatRU Holding's, Defendants create a false impression in a substantial number of
consumers' minds that their products are in fact affiliated with, the same as, sponsored
by, manufactured by, or condoned by WhatRU Holding, thereby enhancing the image
of Defendants through this false association.
Defendants' actions were undertaken willfully with full knowledge of the falsity of
such designation of origin, and false descriptions, representations or advertisements.
profits and advantages from Defendants' unfair competition and false designation of
origin in an amount that is not presently known to WhatRU Holding. As a direct and
proximate result of Defendants' actions, WhatRU Holding has been damaged and is
entitled to monetary relief in an amount to be determined at trial.
67. Due to Defendants' above-described actions, WhatRU Holding has
suffered and continues to suffer great and irreparable injury, for which WhatRU
Holding has no adequate remedy at law.
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68. Pursuant to 15 U.S.C. 1117, WhatRU Holding is entitled to damages
for Defendants' acts constituting false designation of origin and unfair competition, up
to three times actual damages as fixed by this Court, and its reasonable attorneys' fees
for the necessity of bringing this claim.
FIFTH CLAIM FOR RELIEF
UNFAIR COMPETITION
(Cal. Bus & Prof. Code 17200, et seq. and California common law)
preceding paragraphs of this Complaint as through fully set forth herein.
70. The foregoing acts of Defendants constitute unfair competition under
California Business and Professions Code 17200, et seq. and the common law of the
State of California.
profits and advantages from Defendants' unfair competition in an amount that is not
presently known to WhatRU Holding. By reason of Defendants' wrongful acts as
alleged in this Complaint, WhatRU Holding has been damaged and is entitled to
monetary relief in an amount to be determined at trial.
72. By their actions, Defendants have injured and violated WhatRU
Holding's rights and have irreparably injured WhatRU Holding, and such irreparable
injury will continue unless Defendants are enjoined by this Court.
WHEREFORE, WhatRU Holding prays for the following relief:
(A) A judgment that the '608 Patent is valid and has been infringed by
Defendants;
(B) An accounting for damages, and judgment thereon, resulting from
Defendants' infringement of the '608 Patent, together with
prejudgment and post-judgment interest;
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(C) A judgment that Defendants knowingly and willfully engaged in
infringement of the '608 Patent, and the trebling of damages
pursuant to 35 U.S.C. 284;
(D) A permanent injunction against Defendants, their officers, agents,
employees, parent, and subsidiary corporations, assigns, successors
in interest, and all those persons in active concert or participation
with them, enjoining them from continued actual infringement of
the '608 Patent;
(E) A judgment holding this action to be an exceptional case and an
award to WhatRU Holding for its attorneys' fees pursuant to 35
U.S.C. 285;
(F) A judgment that the '471 and '909 Copyrights are valid and have
been infringed by Defendants;
(G) A permanent injunction against Defendants, their officers, agents,
with them, enjoining them from infringing or contributorily
infringing the '471 and '909 Copyrights in any manner, directly or
indirectly;
(H) A permanent injunction against Defendants, their officers, agents,
with them, enjoining them from copying, offering to sell, selling,
importing, marketing, distributing, or placing in interstate
commerce any versions, revisions or modifications of the works
subject to the '471 or '909 Copyrights or any derivative works
based thereon, including, but not limited to "Carousel Jumper" and
"Fire Engine;"
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(I) An accounting for all gains, profits, and advantages derived from
its infringement of WhatRU Holding's copyrights;
(J) A judgment in favor of WhatRU Holding and against Defendants
in an amount equal to the damages sustained by WhatRU Holding
and the profits earned by Defendants from the copyright
infringements alleged herein pursuant to 17 U.S.C. 504(b);
(K) A judgment in favor of WhatRU Holding and against Defendants
for statutory damages pursuant to 17 U.S.C. 504(c)(1) and (c)(2);
(L) An order in favor of WhatRU Holding and against Defendants for
the impounding and destruction of all infringing works pursuant to
17 U.S.C. 503;
(M) A judgment in favor of WhatRU Holding and against Defendants
for attorneys' fees and costs pursuant to 17 U.S.C. 505;
(N) A judgment in favor of WhatRU Holding and against Defendants
on WhatRU Holdings' claims of trade dress infringement, false
designation of origin and unfair competition under 15 U.S.C.
1125(a);
(0) A permanent injunction against Defendants, their officers, agents,
in interest, and all persons in active concert or participation with
them, enjoining them from engaging in the following activities and
from assisting or inducing, either directly or indirectly, others to
engage in the following activities:
(i) Manufacturing, using, displaying, distributing, selling, or
offering to sell any goods that infringe WhatRU Holding's
Trade Dress, or any goods that use other trade dress that is
confusingly similar to WhatRU Holding's Trade Dress;
(ii) Falsely designating the origin of Defendants' goods;
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(iii) Unfairly competing with WhatRU Holding in any manner
whatsoever;
(iv) Causing a likelihood of confusion or injuries to WhatRU
Holding's business reputation; or
(P) A judgment in favor of WhatRU Holding and against Defendants
in an amount equal to damages sustained by WhatRU Holding and
the profits earned by Defendants from the trade dress infringement,
false designation of origin, and unfair competition alleged herein
pursuant to 15 U.S.C. 1117(a);
(Q) A judgment that Defendants knowingly and willfully engaged in
the infringement of WhatRU Holding's Trade Dress, false
designation of origin and unfair competition, and a trebling of
damages pursuant to 15 U.S.C. 1117(a);
(R) A judgment holding this action to be an exceptional case and an
award to WhatRU Holding for its attorneys' fees and costs
pursuant to 15 U.S.C. 1117(a);
(S) A judgment in favor of WhatRU Holding and against Defendants
on WhatRU Holding's California state and common law unfair
competition claim, and that Defendants' acts of unfair competition
were intentional, willful and done knowingly;
(T) A permanent injunction against Defendants, their officers, agents,
employees, parent, and subsidiary corporations, assigns, and
successors in interest, and all persons in active concert or
participation with them, enjoining them from continuing said acts
of unfair competition;
(U) For damages, directly and indirectly, caused by said acts of unfair
competition, and for costs of suit; and
(V) Such other and further relief as the Court deems just and proper.
ACTIVE 26433329v4 08/13/2014
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1
Respectfully submitted,
Dated: August 14, 2014 FOX ROTHSCHILD LLP
By Jeffrey S. Kravitz
Lena N. Bacani
Attorneys for Plaintiff WhatRU Holding, LLC
ACTIVE 26433329v4 08/13/2014
17
/s/ Lena Bacani
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1
DEMAND FOR JURY TRIAL

Plaintiff WHATRU Holding, LLC hereby demands a trial by jury on all issues
so triable.
Respectfully submitted,
Dated: August 4, 2014 FOX ROTHSCHILD LLP
By Jeffrey S. Kravitz
Lena N. Bacani
Attorneys for Plaintiff WhatRU Holding, LLC
ACTIVE 26433329v4 08/13/2014
18
COMPLAINT CASE NO. 2 :14-CV-05187-BRO-PLA
/s/ Lena Bacani
EXHIBIT A
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 01 1 1 ) 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
(12) United States Patent
(lo) Patent No.: US 7,108,608 B2

Field et al.
(45) Date of Patent: Sep. 19, 2006

(54) INFLATABLE BOUNCER
(75) Inventors: Robert Field, Lakeville, MN (US);
Brian Field, Inver Grove Heights, MN
(US)
(73) Assignee: Cutting Edge Creations, Eagan, MN
(US)
( * )
Notice: Subject to any disclaimer, the term of this

patent is extended or adjusted under 35
U.S.C. 154(b) by 0 days.
(21) Appl. No.: 10/698,000
(22) Filed: Oct. 30, 2003
(65)
Prior Publication Data

US 2005/0107174 Al May 19, 2005
(51) Int. Cl.
A61G 31/00 (2006.01)
(52) U.S. Cl. 472/134; 52/2.11; 482/27
(58) Field of Classification Search 472/134;
52/2.11, 2.17, 2.18, 2.21, 2.22, 2.24; 446/220,
446/221, 223, 225, 226; 482/27-29, 26
See application file for complete search history.
(56)
References Cited
U.S. PATENT DOCUMENTS
2,875,771 A 3/1959 Brewin 52/2.11
2,946,337 A * 7/1960 Wolshin 52/2.21
4,295,302 A * 10/1981 Liu 52/2.21
5,226,261 A * 7/1993 Wilbourn et al. 52/2.21
5,247,768 A * 9/1993 Russo 52/2.13
5,462,505 A * 10/1995 Blair et al. 482/27
5,471,797 A * 12/1995 Murphy 52/2.17
5,555,679 A * 9/1996 Scherba 52/2.18
5,570,544 A 11/1996 Hale et al. 52/2.18
5,678,357 A * 10/1997 Rubio et al. 52/2.17
5,772,535 A * 6/1998 Murphy 473/415
5,893,238 A * 4/1999 Peacock et al. 52/2.18
5,987,822 A * 11/1999 McNiff et al. 52/2.11
6,029,404 A * 2/2000 Lewis 52/2.18
6,565,405 Bl * 5/2003 Hsu et al. 446/89
6,679,811 B1* 1/2004 Chen 482/29
6,722,084 Bl* 4/2004 Berman 52/2.11
* cited by examiner
Primary ExaminerKien Nguyen
(74) Attorney, Agent, or FirmSchwegman, Lundberg,
Woessner & Kluth, P.A.
(57) ABSTRACT
An inflatable bouncer includes an inflatable bottom section,
an inflatable inner column coupled to a center of the bottom
section, and a plurality of inflatable columns around a
periphery of the bottom section. An uninllated roof extends
between the inner column and the outer columns.
7 Claims, 4 Drawing Sheets
U.S. Patent Sep. 19, 2006
Sheet 1 of 4 US 7,108,608 B2
150
.,ik 152
K100
R411
VIlit
110
- - - - - _ _ _ _ _ _
120- r
sVIP
A
110 _ L. . -
FIG. 1
1.10
130
FIG. 2
Sheet 2 of 4 US 7,108,608 B2
Sheet 3 of 4 US 7,108,608 B2
12Z
---130
1
I/5
110
FIG. 3
Z O O
2 : 3 5
2 2 2
2 4 0
)A 0
2 : 10 -----
' ' ' -. --- Z I O
2 4 2 4 5
2 10
FIG. 4
Sheet 4 of 4 US 7,108,608 B2
US 7,108,608 B2
1
INFLATABLE BOUNCER
FIELD
This invention relates to the field of inflatables, and more 5
specifically to inflatable bouncers.
BACKGROUND
Inflatables, such as inflatable bouncers, are air-inflated 10
devices that are typically used for children's amusement as
well as advertising purposes. Inflatables have been designed
to resemble real-life objects, such as ships, fire trucks, and
animals. Inflatable bouncers include a bottom, inflated
bouncing section. Some bouncers include a roof. However, 15
when designing such bouncers to look like a real-life object,
present designs do not provide for a realistic appearance in
all cases. What is needed is an inflatable bouncer structure
allowing for a roofed-type bouncer having a realistic appear-
ance. 20
SUMMARY
An apparatus comprising an inflatable bouncer having an
uninflated roof with a central portion and a periphery,
25
wherein the uninflated roof is supported in its center portion
by an inflated column.
BRIEF DESCRIPTION OF THE DRAWINGS
30
FIG. 1 shows an inflatable bouncer according to one
embodiment of the inventive subject matter disclosed
herein.
FIG. 2 shows a top view of the inflatable bouncer of FIG.
1.
35
FIG. 3 shows a side view of the inflatable bouncer of FIG.
1.
FIG. 4 shows a side view of an inflatable bouncer accord-
ing to one embodiment of the inventive subject matter
disclosed herein.
40
DETAILED DESCRIPTION
The following detailed description and accompanying
drawings show various embodiments according to the inven-

45
tive subject matter disclosed herein. These embodiments are
described in sufficient detail to enable those skilled in the art
to practice the invention. Other embodiments may be uti-
lized and structural changes may be made without departing
from the scope of the present invention. 50
FIGS. 1-3 show a perspective view, top view, and side
view, respectively, of a bouncer 100 according to one
embodiment of the inventive subject matter disclosed
herein. Bouncer 100 includes an inflatable bottom section
110, an inflatable inner column 120, a plurality of inflatable 55
outer columns 130, an upper inflatable support 140, and a
roof 150. Bouncer 100 is used for children or adults to
bounce and play inside, for instance at fairs, carnivals, or
other events. In this example, bouncer 100 is designed to
look like a carousel. A blower 105 is coupled to the bouncer 60
to keep the bouncer inflated. Blower 105 can be a high
output blower, for example.
Referring to FIG. 2, a top view of bouncer 100 is shown
without the roof. Inflatable bottom section 110 can be a
circular, round, inflated section made of vinyl, for example. 65
In this example, bottom section 110 is about 3 feet high and
has a diameter of approximately 25 feet. The height and
2
diameter can vary to any desired sized. Various embodi-
ments have a diameter of approximately 15 feet to approxi-
mately 30 feet. Bottom section includes a periphery 112 and
a central area 114.
Inner column 120 is attached to and extends upward from
bottom section 110. In this example, inner column 120 is in
the center of bottom section 110. However, in some embodi-
ments, the inner column is anywhere within the central area
114 of the bottom section. In some embodiments, two or
more inner columns are located in the central area 114. Inner
column 120 is inflatable and can be made of the same
material as the bottom section. In this example, inner
column 120 is approximately 20 feet high and includes a
knob 122 at its peak designed to look like the top of a
carousel.
Outer columns 130 are coupled to bottom section 110
around the periphery of the bottom section. Each of the outer
columns is inflatable and made of the same material as the
bottom section. In one embodiment, eight outer columns are
used and positioned equidistant from each other around the
periphery of the bottom section. 'Ile outer columns are
shorter than the inner column. In one embodiment, the outer
columns are approximately 10-15 feet high.
Upper inflatable support 140 is an inflatable section
attached to the top of outer columns 130. In this example,
upper support 140 has approximately the same diameter as
bottom section 110.
Each of bottom section 110, inner column 120, outer
columns 130, and support 140 are connected together so that
the interiors of the members communicate with each other
so that air blown into the bouncer through the bottom section
inflates each other section.
Roof 150 is an uninflated flexible sheet of material
coupled at its inner portion 152 to inner column 120 and at
its periphery or outer portion 154 to either upper support 140
or to the tops of columns 130. In this example, to allow
bouncer 100 to better resemble a carousel, roof 150 is
attached to inner column 120 below knob 122 and the roof
then hangs or drapes down and the outer portion 154 is
attached to the upper support 140. This unsupported-by-air,
uninflated appearance of roof 150 gives bouncer 100 the
appearance of a carousel. In some embodiments, upper
section 140 can be omitted and roof 150 is coupled to the
tops of each of outer columns 130.
In one embodiment, bouncer 100 includes a mesh wall
160 extending around the outside of the bouncer and extend-
ing between bottom section 110 and section 140. A plurality
of animal silhouettes 170 are attached to mesh wall 160 at
locations around the bouncer. In one embodiment, silhou-
ettes 170 are digitally printed vinyl sheets which can be
printed to depict the decorations and colors of typical
carousel animals. In one embodiment, the printed vinyl
silhouettes can be cut to look like horse silhouettes, for
example.
An inner play area 175 of bouncer 100 is accessible
through a door 177 in mesh wall 160. The inner area 175 is
uninflated. The only portions of bouncer 100 that are inflated
by blower 105 are the bottom section 110, the inner column
120, the outer columns 130, and upper section 140.
In various embodiments, the bouncer can be oval, rect-
angular, or other shapes, depending on the design the
designer is trying to capture.
FIG. 4 shows a side view of an inflatable bouncer 200 in
accordance with one embodiment of the inventive subject
matter disclosed herein. Bouncer 200 is designed to
resemble a cake. Bouncer 200 includes an inflatable bottom
section 210, an inflatable inner column 220 coupled proxi-
US 7,108,608 B2
3
mate the central area of bottom section 210, one or more
inflatable outer columns 230 around the periphery of the
bottom section, and an uninflated roof 240 coupled to and
extending generally horizontally between inner column 220
and outer columns 230. 5
In one embodiment, one or more candle figures 235 can
extend from the top of inner column 220. An upper portion
222 of inner column 220 can have an enlarged diameter to
provide for a tiered look for bouncer 200. Bottom section
210 can be round, oval, square or other desired shape. A io
mesh wall 245 can extend around the outer area of the
bouncer.
The structure of bouncer 200 allows for the realistic
appearance of a cake by utilizing inflated inner column 220
to support the uninflated roof 240. Other bouncers can be 15
designed utilizing such a structure as shown for the carouse]
of bouncer 100 and the cake of bouncer 200.
According to one method of the inventive subject matter
disclosed herein, there is provided a technique to support the
roof of an inflatable to provide a more realistic looking 20
design. One en IN Oiment includes supporting an uninflated
roof with a center portion and a periphery, wherein the roof
is supported in the center portion by an inflated column. This
allows the roof to naturally hang down and provide the
desired look for the inflatable structure. In some examples 25
the roof can be extended between the central inflated column
and a plurality of outer inflated columns.
The above description is intended to be illustrative, and
not restrictive. Many other embodiments will be apparent to
those of skill in the art upon reviewing the above descrip- 30
t1011. lime scope of the inventitut should, therefore, be deter-
mined with reference to the appended claims, along with the
full scope of equivalents in which such claims are entitled.
What is claimed is:
1. An inflatable device comprising: 35
a circular, inflatable bottom section having a periphery
and a central area;
an inflatable inner column coupled to the bottom section
proximate the central area and extending upward to a
peak;
4
a plurality of inflatable, outer columns coupled proximate
the periphery;
an upper support section coupled to a lop of each of the
outer columns;
a wall extending between the bottom section and the
upper support section and having a door; and
an uninflated roof attached to the inner column at a
location below the peak and supported by the inner
column and the upper support section such that the
inflatable bouncer has the appearance of a carousel.
2. The inflatable device of claim 1, further including
silhouettes of animals on the mesh wall.
3. The inflatable device of claim 1, wherein the inner
column is attached at a center of the bottom section.
4. The inflatable device of claim 1, wherein the wall
includes a mesh wall.
5 . The inflatable device of claim 1, wherein the inner
column is taller than the each of the outer columns.
6. An inflatable bouncer comprising:
an inflatable bottom section having a periphery and a
central area;
an inflatable inner column coupled to the bottom section
proximate the central area;
a plurality of inflatable, outer columns coupled proximate
the periphery; and
an uninflated roof attached to the inner column and
extending generally horizontally between the inner
column and the outer columns such that the inflatable
bouncer has the appearance of a cake, wherein a top
portion of the inflatable inner column includes one or
more candle figures.
7. The inflatable bouncer of claim 6, including a wall
extending between the roof and the bottom section.
EXHIBIT B
<e . ,9
Ry014 Go ki
COPYRIGHT CLAIMANT(11) Name end address most b e g i v e n evert tf the claims* is the nom as the
author given te awe 2 V
Cutti n g Edge Creations Inc 920 Apollo Road Suite 100 Eagan MN 55121
Tran sfe r Lithe clumi n g e ) dome d he i r 03 trace 4 i s fan ) cli ffctroi t fron t the author(e )
wood in apace 2give a
hod statement d howthe claurwrifs) obtained ownership of the copyri g ht V
APPLICATION RECEIVED
ONE 4i 4ST 1~ lEage
1
1TWO DEPOSITSRECEIV
8
FUNDS
4
se . Inwroceons
woos cornpiewg
ode epees
OFFICIAL SEAL
Case 2:14-cv-05187-BRO-PLA Document 1-1 Filed 10/04/13
CERTIFICATE OF REGISTRATION
4.05 COP ykto
This Certificate Issued under the seal of the Copyright
Office In accordance with title 17, United States Code,
attests that registration has been made for the workIdentified
below.The information on this certificate has been made a
part of the Copyright Office records.
4,01A CP e _ &A.
RE ISTER OF COPYRIGHTS
United States of America
Page 10 of 21 Page ID #:24
FORM VA l e
Fore Work of the Vi sual Ade
UNITED STATESCOPYRIGHT OFFICE
VA 1-201-471
i mn i tg i n
ttl-hC,11%(L OF REGISTRAIION
"%NW 62003
Rosh
Veer
DO NOT MD'SABOVE THISLINE IF YOU NEED MORE SPACE USE A SEPARATE CONTINUATION SHEET
Thle of Thi s Work V
CAROUSEL BOUNCER
NATURE OP TIM WORK Va.. matmodona
SCULPTURE
1
Pre v i ous or Alte r. Ti tle s
rub li e adon us a Con tri b ab on U dui work was publuhed al a coetribuitoo M a periodical serial or collection give information about the collective work is which the
contribution appeared Tillie of Colledire Wort
If tablisted m a periodical re sera[ give Whams V Number 'r ham Dale Om Pages V
NAME OF AUTHOR V
a Cutting Edge Creations Inc
DATF13 OP BIRTH AND DEATH
Year Born V Year Died V
NOTE
Un de r the le e
the author 01
we re mad.
for hi re to
g e n e rally the
e mploye r n ot
the e mploye e
(mws me tro
li on s) For an y
part ol thi s
work that was
0 Technical drawing
0 Text
0 Architectural work
Te chn i cal drawi n g
0 Te xt
0 Archi te ctural we e k
WIN tide ecnklbutioa to the work a Ant a Nalionahty or Docrilimle
"workmade for hlra"*
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Yes
0 No
OR { Calt" air
Docosctkd a
Unitexi States
Nature of Authorship Check a)rpropn ste hos (es) SOS las trilatIOtta
LE 3 Dimensional sculpture 0 Map
V) 2 Durensional artwork
0 Photograph
K Reproduction of work of art
0 letwetry design
V
Was tide ecatrIbotioa lo lbs work a
"work mad* he hi re "
Nature of Authorshi p Che e kappropriate booths) Se e In structi on s
o 3 Di me n si on al sculpture 0 hli p
O 2 Don e asson al artwork0 Photograph
O Re producti on of wok of art 0 Je we lry de si g n
Was Thai Author a Contributioa to the Work
Pseudonymous,
Anonymous?
0 ye, 0 ihn intwat toWNW

K Yes
0 No "Ye e se e dre ade d
of time question* se
irsinceone
Was Thi s Author a Con trtb ub on to the Work
Amapa&0 Yes 13 No 1" arMer Slth:
Pseudonymous, 0 Yes 0 No -140
me ri t:don s
made tor Mn
Na
cheek Yes in m of
Author
the span
provided give
the employer
(or other
parson tor
whom the work
was prepared) 0 Yes

Author of
OR cauts of es
OM part and
0 No DOM=
Lase the
space for dates
of birth and
death blank
Name of
Author s Nationality or Domi ci le
Ci oun dy
Dates of Bi rth an d De ath
Year Ikon VYe ar Di e d
Year la Wkkk Creation of ibis Work Wes Dam an d Nati on of net Publicatioas Perticuiar Work
a ci g e ""
Thi b tforme tIon this informe r on
Month .ISOYEMERR_ Dery Yew ...2021_
2002
must be 1110011 b grzilisihis work
Yew In an we n has been published
Noon
MORE ON BACK to. Ocalf411 al amicable seems frowheft $41 on the reverse skis of LPN Ms
3
EXHIBIT C
Certificate of Registration
This Certificate issued under the seal of the Copyright
Office in accordance with title 17, United States Code,
attests that registration has been made for the work
identified below The ink on this certificate has
been made a part of the Copyright Office records.
Register of Copyrights, United States of America
Registration Number
VA 1-835-909
Effective date of
registration:
October 31, 2012
Title

Title of Work: Fire Truck Bus
Completion/ Publication

Year of Completion: 2008
Date of 1st Publication: November 15, 2008 Nation of 1st Publication: United States

Author

I Author: Whatru Holding, LLC
Author Created: 2-D artwork, sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimant
Copyright Claimant:
Rights and Permissions
Organization Name:
Address:
Certification
Whatru Holding, LLC
10665 Alameda Ave, Inver Grove Heights, MN, 55077, United States
Whatru Holding, LLC
10665 Alameda Ave
Inver Grove Heights, MN 55077
Name: Brian Field
Date: October 25, 2012
Page 1 of 1
Fire Truck Bouncer - VA 1-835-909
EXHIBIT D
:0'
2013 PRODUCT CATALOG

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WINIVINE4M4.
111!=
1

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41.41 is Ms
Gail No km
EXHIBIT E
iili
lid!: 11111H
lin 1/ 1111!
EXHIBIT F
8811111151 MO S'
WEB SP EC I A L S
IKF auk ma,
facebook.
Fire Truck Jumper I Bouncing Angels Inflatables - Bouncer, Moonwalk, and Inflatable U... Page 1 of 2
HOME PAGE OUR PRODUCTS OUR SPECIA ABOUT OUR COMPANY INFLATABLE RESOURCES CONTACT US
I NFL A TA BL E JUMP ERS
I NFL A TA BL E C OMBOS
I NFL A TA BL E WA TER C OMBOS
I NFL A TA BL E I NTERA C TI VES
I NFL A TA BL E BRA NDI NG
I NFL A TA BL E SL I DES
I NFL A TA BL E WA TER SL I DES
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I NFL A TA BL E GA MES
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2014 C A TA L OG
Search Our Site:
Bouncing Angels Home Page I Our Products I Inflatable Jumpers I Fire Truck Jumper
P RODUC T DESC RI P TI ON:
I TEMSDETA I L S: I TEMSI NC L UDES:
Model #: B148 1 1.5 HP Air Blower
Size(s): 14L x 11W x 10H 4 Anchoring Spikes
Indoor: Yes 1 Tarp
Outdoor: Yes 1 Air Flow Zipper
Warranty: 3.5 Years 4 Patch Kit
1 Vinyl Cement (Glue)
1 Safety Rules
1 Business Card Holder
SEA RC H
http://www.bouncingangels.com/products/inflatable jumpers/fire truck jumper 7/31/2014
V
r
VI;
I
Front
0B- inchLates PreInstalled Blower flaw locations
Fire Truck Bouncer - VA 1- 835- 909
EXHIBIT G
2014 P DUCT 'CATALOG
FIRE ENGINE - B148
Length: 14 FTWidth: 11 FTHeight 10FT
HALLOWEEN JUMPER - B185
Length: 13 FTWidth: 13 FTHeight: 14 FT
Length: 15 FTWidth: 15 FTHeight: 14 FT
HUMMER OFF-ROAD JUMPER - 8162
Length: 19 FT Width: 13 FTHeight 11 FT
56
BASKETBALLJUMPER - B187
Length; - " Width: ' Height: I ". FT
Length' ' Width; ' - Height: ' FT

FOOTBALLJUMPER - B186
Length: 13 FT Width: 13 FTHeight: 14 FT
Length: 15 FT Width: 15 FT Height 14 FT

WESTERN DIGITALPRINTJUMPER - B169
Length: 15 FT Width: 15 FT Height: 14 F


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Jeffrey S.

Kravitz (SBN 66481)

18. In 2008, Cutting Edge completed an original work of an inflatable

19. "Fire Truck Bus" consists of an inflatable sculpture which is shaped to

DEFENDANTS' INFRINGING ACTIVITIES

23. WhatRU Holding immediately contacted the IAAPA show's

management about Defendants' blatant violation of WhatRU Holding's copyrights.

DEMAND FOR JURY TRIAL

(lo) Patent No.: US 7,108,608 B2

(45) Date of Patent: Sep. 19, 2006

Notice: Subject to any disclaimer, the term of this

Prior Publication Data

0 ye, 0 ihn intwat toWNW

was prepared) 0 Yes

2013 PRODUCT CATALOG

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