Hanson v. Tiger Supplies - Complaint

Case 2:17-cv-11808 Document 1 Filed 11/17/17 Page 1 of 11 PageID: 1
WEITZMAN LAW OFFICES, LLC

Kenneth S. Weitzman (Bar No. 021451992)
425 Eagle Rock Avenue, Suite 102
Roseland, New Jersey 07068
Tel.: (973) 403-9940
Fax: (973)-403-9944
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY
JAMES HANSON,
DOCUMENT FILED ELECTRONICALLY
Plaintiff,
v. Civil Action No. _______________
TIGER SUPPLIES INC. aka ADIR CORP.,

and ADIR CORPORATION OF NY, COMPLAINT AND DEMAND
FOR JURY TRIAL
Defendants.
Plaintiff James Hanson (Plaintiff) for his Complaint against the Defendants, Tiger
Supplies Inc. aka Adir Corp. (hereinafter Defendant or Tiger Supplies) and Adir Corporation
of NY (herein after Defendant or Adir Corp.), alleges as follows:
NATURE OF THIS ACTION
1. This is a civil action for the infringement of United States Design Patent No.
D557,543 (the 543 Patent) under the Patent Laws of the United States, 35 U.S.C. 100 et
seq., arising from Defendants manufacture, use, offer to sell, sale and/or importation of
infringing blueprint support racks.
THE PARTIES
2. Plaintiff James Hanson is an individual residing in Lilburn, Georgia.
Page 1 of 11
3. Upon information and belief, Defendant Tiger Supplies is a New Jersey
corporation, is registered to use the alternative name Adir Corp. in New Jersey, and has its
principal place of business at 27 Selvage Street, Irvington, New Jersey 07111.
4. Upon information and belief, Defendant Adir Corporation of NY is a New York
corporation also having its principal place of business at 27 Selvage Street, Irvington, New
Jersey 07111.
JURISDICTION AND VENUE
5. This Court has subject matter jurisdiction over this complaint pursuant to 28
U.S.C. 1331 and 1338(a), because this is an action arising under the Patent Laws of the
United States, 35 U.S.C. 100 et seq.
6. This Court has personal jurisdiction over the Defendant Tiger Supplies because:
(a) Tiger Supplies is a New Jersey corporation having its principal place of business in Irvington,
New Jersey, (b) upon information and belief, Tiger Supplies regularly transacts and solicits
business in New Jersey through the offer for sale, sale and/or importation of products in New
Jersey; and (c) Tiger Supplies is committing and has committed acts of patent infringement by
manufacturing, offering for sale and selling infringing products within New Jersey, including via
its interactive ecommerce website at www.tigersupplies.com and its brick-and-mortar showroom
located in Irvington, New Jersey.
7. This Court has personal jurisdiction over Defendant Adir Corp. because: (a) upon
information and belief, Adir Corp. has its principal place of business in Irvington, New Jersey;
(b) upon information and belief, Adir Corp. regularly transacts and solicits business in New
Jersey through the manufacture, offer for sale, sale and/or importation of products in New Jersey;
Page 2 of 11
and (c) Adir Corp. is committing and has committed acts of patent infringement by
manufacturing, offering for sale, and selling infringing products within New Jersey.
8. Venue is proper in this judicial district under 28 U.S.C. 1400(b) because: (i) both
Defendants have committed acts of infringement by selling and offering for sale infringing
products within this district and have a regular and established place of business in this district;
and (ii) with respect only to Defendant Tiger Supplies, Defendant Tiger Supplies resides in this
district.
THE PATENT-IN-SUIT
9. On December 18, 2007, the 543 Patent, entitled Support Rack For Holding
Rolled Drawings, was duly and legally issued by the U.S. Patent and Trademark Office
(USPTO). A true and correct copy of the 543 Patent is attached as Exhibit A. The 543
Patent is valid, enforceable and currently in full force and effect.
10. Plaintiff is the inventor and owner of all right, title and interest in and to the 543
Patent.
FACTS COMMON TO ALL CLAIMS FOR RELIEF
11. Plaintiff invents and designs document organizational tools for the architectural,
engineering and building industry.
12. Plaintiff commercializes floor supported and wall mounted blueprint storage racks
covered by the 543 Patent under the trademark Vis-I-Rack through his company Interactive
Building Services, Inc. dba www.planracks.com, located in Lilburn, Georgia, as well as through
authorized wholesale distributors.
Page 3 of 11
13. Defendants are direct competitors with Plaintiffs company, Interactive Building
Services, Inc., which manufactures, fabricates, markets and distributes organizational tools for
the architectural, engineering and building industry.
14. Upon information and belief, Defendant Adir Corp. designs, manufactures, offers
for sale, and sells office supply products under the brand AdirOffice, including blueprint
storage racks.
15. Upon information and belief, Defendant Tiger Supplies offers for sale and sells
various products for contractors, engineers and surveyors, including Defendant Adir Corp.s
AdirOffice brand blueprint storage racks.
DEFENDANTS INFRINGING ACTIVITIES
16. On information and belief, Defendants have manufactured, offered for sale, sold,
and/or imported into the United States blueprint storage racks that infringe the 543 Patent.
17. On information and belief, an ordinary observer will perceive the overall
appearance of the designs of Defendants blueprint storage racks to be substantially the same as
and/or a colorable imitation of the overall appearance of the designs of the 543 Patent.
18. Table 1 below compares representative figures of the 543 Patent with
representative images of Defendants AdirOffice Standing Blueprint Storage Rack Model Nos.
ADI692-01-BLK and ADI692-01-WHI.
Page 4 of 11
U.S.Patent
U.S. Patent Dec.
Dec. 18,18, 2007
2007 Sheet6 of
Sheet 6 of1313 USUSD557,543
D557,543S S
Table 1: Comparison of 543 Patent and Defendants Standing Blueprint Storage Rack
U.S.Patent
U.S. Patent Dec.Dec.543 Sheet
18,18, Patent
2007
2007 Sheet 13 13 Figures
7 of
7 of USUSD557,543
D557,543S S AdirOffice Model No. ADI692-01-BLK
U.S.Patent
U.S. Patent Dec.18,18,2007
Dec. 2007 Sheet1212ofof1313
Sheet USD557,543
US D557,543S S
U.S.Patent
U.S. Patent Dec.
Dec. 18,18, 2007
2007 Sheet13 13Of Of
Sheet 13 13 USUSD557,543
D557,543S S
AdirOfficeStanding
AdirOffice StandingBlueprint
BlueprintStorage
StorageSteel
SteelRack
RackADI692-01-BLK-
ADI692-01-BLK-
19. In the eye of the ordinary observer familiar with the relevant prior art, giving such
attention as a purchaser usually gives, the claimed design of the 543 Patent and Defendants
AdirOffice Standing Blueprint Storage Racks are substantially the same, such that the ordinary
observer would be deceived into believing that Defendants AdirOffice Standing Blueprint
Storage Racks are the design claimed in the 543 Patent.
20. Table 2 below compares representative figures of the 543 Patent with
representative images of Defendants AdirOffice Wall Mount Blueprint Storage Rack Model
Nos. ADI692-50-BLK and ADI692-50-WHI.

FG. 29
FG. 29 FIG 5O5O
FIG AdirOfficeWall
WallMount
MountBlueprint
Blueprint50-Inch
50-InchBlack
BlackSteel
SteelRack
RackADI692-50-BLK
ADI692-50-BLK
FC 27
FC 27 AdirOffice
Page 5 of 11
U.S. Patent Dec. 18, 2007 Sheet 12 of 13 US D557,543 S
U.S. Patent Dec. 18, 2007 Sheet 13 Of 13 US D557,543 S
U.S. Patent Dec. 18, 2007 Sheet 13 Of 13 US D557,543 S AdirOffice Standing Blueprint Storage Steel Rack ADI692-01-BLK-
Table 2: Comparison of 543 Patent and Defendants Wall Mount

AdirOffice Standing Blueprint
Blueprint Storage Storage
Steel Rack Rack
ADI692-01-BLK-
543 Patent Figures AdirOffice Model No. ADI692-50-BLK
FG. 29 FIG 5O AdirOffice Wall Mount Blueprint 50-Inch Black Steel Rack ADI692-50-BLK
FC 27
FG. 29 FIG 5O AdirOffice Wall Mount Blueprint 50-Inch Black Steel Rack ADI692-50-BLK
FC 27
21. In the eye of the ordinary observer familiar with the relevant prior art, giving such
attention as a purchaser usually gives, the claimed design of the 543 Patent and Defendants
AdirOffice Wall Mount Blueprint Storage Racks are substantially the same, such that the
ordinary observer would be deceived into believing that Defendants AdirOffice Wall Mount
Blueprint Storage Racks are the design claimed in the 543 Patent.
22. Plaintiff did not give Defendants authorization or license to make, use, offer to
sell, sell, or import the infringing blueprint storage racks.
23. Defendants have directly infringed, and continue to directly infringe, the 543
Patent by making, using, offering to sell, selling and/or importing blue print storage racks,
including AdirOffice Model Nos. ADI692-01-BLK, ADI692-01-WHI, ADI692-50-BLK and
ADI692-50-WHI, having substantially the same ornamental design as the design claimed in the
543 Patent, in violation of 35 U.S.C. 271(a) and 289.
Page 6 of 11
24. Upon information and belief, Defendants market and sell the infringing blueprint
storage racks via Defendant Tiger Supplies ecommerce website at www.tigersupplies.com, its
brick-and-mortar showroom located in Irvington, New Jersey, and on third party ecommerce
websites including Amazon.com.
25. Upon information and belief, Defendants have engaged and continue to engage in
the above activities willfully and without the authorization of Plaintiff, with the knowledge that
the design of each infringing blueprint storage rack is substantially the same as the designs of the
543 Patent.
26. Defendants unauthorized acts as described herein have caused and will continue
to cause irreparable damage to Plaintiff and his business unless restrained by this Court.
CLAIM FOR RELIEF

(Infringement Under 35 U.S.C. 271 of the 543 Patent)
27. Plaintiff re-alleges and incorporates by reference the allegations contained in
paragraphs 1 through 28 above as though fully set forth herein.
28. Defendants, without authorization from Plaintiff, have made, used, offered for
sale, sold, and/or imported into or in the United States, and continue to make, use, offer for sale,
sell, and/or import into or in the United States, blueprint storage racks having designs that
infringe the 543 Patent.
29. By the foregoing acts, Defendants have infringed and continue to infringe the
543 Patent in violation of 35 U.S.C. 271(a) and 289.
30. Defendants conduct violates 35 U.S.C. 271 and has caused, and unless enjoined
by this Court pursuant to 35 U.S.C. 283, will continue to cause, Plaintiff to sustain irreparable
damage, loss, and injury, for which Plaintiff has no adequate remedy at law.
Page 7 of 11
31. Plaintiff has suffered pecuniary damages in amounts to be determined at trial as a
result of Defendants infringement of the 543 Patent, pursuant to 35 U.S.C. 284 and 289.
32. Defendants have also profited from, and continue to profit from, their infringing
conduct.
33. Upon information and belief, Defendants aforesaid conduct has been undertaken
knowingly, willfully, and in bad faith, and with knowledge of Plaintiffs rights. Such acts
constitute willful infringement and make this case pursuant to 35 U.S.C. 284 and 285, and
entitle Plaintiff to enhanced damages and reasonable attorney fees.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court:
A. Enter judgment that Defendants have infringed Plaintiffs 543 Patent and that
such infringement has been willful;
B. Enter a permanent injunction against Defendants, pursuant to 35 U.S.C. 283
and/or the equitable powers of this Court, to prevent further infringement of the 543 patent;
C. Award damages, in an amount to be determined, adequate to compensate Plaintiff
for the infringement that has occurred, pursuant to 35 U.S.C. 284;
D. Order Defendants to account for and pay to Plaintiff any and all profits made by
Defendants from sales of its infringing products pursuant to 35 U.S.C. 289;
E. Order Defendants to pay Plaintiff its costs and attorneys fees in this action
pursuant to 35 U.S.C. 285 and/or other applicable laws; and
F. Award Plaintiff such other and further relief as the Court deems just and proper.
Page 8 of 11
JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.
Dated: November 17, 2017 By: /s Kenneth S. Weitzman

Tel. (973) 403-9940
Email: kweitzman@weitzmanip.com
Attorneys for Plaintiff James Hanson
Page 9 of 11
CERTIFICATION PURSUANT TO L. CIV. R. 11.2
Pursuant to Local Civil Rule 11.2, the undersigned hereby certifies that this matter is not
the subject of any other action pending in any court, or of any pending arbitration or
administrative proceeding.

Tel. (973) 403-9940
Page 10 of 11
RULE 201.1 CERTIFICATION
Pursuant to L. Civ. R. 201.1, the undersigned counsel for Plaintiff hereby certifies
that, in addition to monetary damages, Plaintiff seeks injunctive and other equitable relief, and
therefore this action is not appropriate for compulsory arbitration.

Tel. (973) 403-9940
Page 11 of 11
Case 2:17-cv-11808 Document 1-1 Filed 11/17/17 Page 1 of 16 PageID: 12
EXHIBIT A
USOOD557543S
(12) United States Design Patent (10) Patent No.: US D557,543 S

Hanson (45) Date of Patent: . Dec. 18, 2007
(54) SUPPORT RACK FOR HOLDING ROLLED shown for illustrative purposes only and forming no part of
DRAWINGS the claimed design;
(76) Inventor: James Hanson, 1986 Kensington High FIG. 7 is a front elevational view of a support rack for
holding rolled drawings showing a second embodiment of
St., Lilburn, GA (US) 30047 my new design;
(**) Term: 14 Years FIG. 8 is a top plan view thereof;
FIG. 9 is a left side elevational view thereof;
(21) Appl. No.: 29/247,524 FIG. 10 is a right side perspective view thereof;
(22) Filed: Jun. 23, 2006 FIG. 11 is a top, front, and left side perspective view thereof;
(51) LOC (8) Cl. ................................................. 06-04 FIG. 12 is a front elevational view of a support rack for
(52) U.S. Cl. ....................................................... D6/570 holding rolled drawings showing a third embodiment of my
(58) Field of Classification Search ......... D6/320-324, new design;
D6/327, 396, 462, 465, 512, 555, 409, 449, FIG. 13 is a top plan view thereof;
D6/552-553,566-574; 211/13.1, 16, 17, FIG. 14 is a left side elevational view thereof;
211/23, 49.1, 59.4, 64, 70.5, 70.6, 86.01,
211/87.01, 90.01, 90.02, 105.1, 123, 126.1, FIG. 15 is a right side perspective view thereof;
211/126.2, 190, 128.1, 191, 1811, 182, 175, FIG. 16 is a top, front, and left side perspective view thereof;
211/207: 108/2829, 42, 59, 64,91; 248/49, FIG. 17 is a front elevational view of a support rack for
248/67.7, 175, 176.1 holding rolled drawings showing a fourth embodiment of
See application file for complete search history. my new design;
(56) References Cited FIG. 18 is a top plan view thereof;
U.S. PATENT DOCUMENTS FIG. 19 is a left side elevational view thereof;
4,347,795 A * 9/1982 Makinen ...................... D6,570
FIG. 20 is a right side perspective view thereof;
FIG. 21 is a top, front, and left side perspective view thereof;
(Continued) FIG. 22 is a front elevational view of a support rack for
Primary Examiner Brian N Vinson holding rolled drawings showing a fifth embodiment of my
new design;
(57) CLAM
FIG. 23 is a top plan view thereof;
The ornamental design for a Support rack for holding rolled FIG. 24 is a left side elevational view thereof;
drawings, as shown and described. FIG. 25 is a right side perspective view thereof;
DESCRIPTION FIG. 26 is a top, front, and left side perspective view thereof;
FIG. 1 is a front elevational view of a support rack for FIG. 27 is a front elevational view of a support rack for
holding rolled drawings showing a first embodiment of my holding rolled drawings showing a sixth embodiment of my
new design; new design;
FIG. 2 is a top plan view thereof; FIG. 28 is a top plan view thereof;
FIG. 3 is a left side elevational view thereof; FIG. 29 is a left side elevational view thereof;
FIG. 4 is a right side perspective view thereof; FIG. 30 is a right side perspective view thereof; and,
FIG. 5 is a top, front, and left side perspective view thereof; FIG. 31 is a top, front, and left side perspective view thereof.
FIG. 6 is a top, front, and left side perspective view thereof,
with the broken-line disclosure of rolled drawings being 1 Claim, 13 Drawing Sheets
Ss r
-1. -
US D557,543 S
Page 2
U.S. PATENT DOCUMENTS D466,748 S * 12/2002 Battaglia et al. ............. D6,566

D486,683 S * 2/2004 Devine .......... D6,566
D294,098 S * 2/1988 Mayo .......................... D6,566 D495,531 S * 9/2004 Allshouse et al. ........... D6,462
D362,576 S * 9/1995 Mele ... D6,566
D390,724 S * 2/1998 Parker et al. D6,462
D409,005 S * 5/1999 Knight ........................ D6,570 * cited by examiner
FG 2
FG 3

U.S. Patent Dec. 18, 2007 Shee 3. Of 13 US D557,543 S

FIG 7
U.S. Patent Dec. 18, 2007 Sheet S of 13 US D557,543 S
//



FC 21
FG. 22

FG. 29 FIG 5O
FC 27
U.S. Patent Dec. 18, 2007 Sheet 13 Of 13 US D557,543 S

JS 44 (Rev. 06/17) CIVIL COVER SHEET

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purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

JAMES HANSON TIGER SUPPLIES INC. aka ADIR CORP.
ADIR CORPORATION OF NY
(b) County of Residence of First Listed Plaintiff Gwinnett County, Georgia County of Residence of First Listed Defendant Essex County, New Jersey
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1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
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Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
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VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement of US Patent No. D557,543
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DATE SIGNATURE OF ATTORNEY OF RECORD
11/17/2017 s/ Kenneth S. Weitzman
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Case 2:17-cv-11808 Document 1 Filed 11/17/17 Page 1 of 11 PageID: 1

WEITZMAN LAW OFFICES, LLC

UNITED STATES DISTRICT COURT

v. Civil Action No. _______________

TIGER SUPPLIES INC. aka ADIR CORP.,

of NY (herein after Defendant or Adir Corp.), alleges as follows:

NATURE OF THIS ACTION

infringing blueprint support racks.

2. Plaintiff James Hanson is an individual residing in Lilburn, Georgia.

3. Upon information and belief, Defendant Tiger Supplies is a New Jersey

principal place of business at 27 Selvage Street, Irvington, New Jersey 07111.

4. Upon information and belief, Defendant Adir Corporation of NY is a New York

JURISDICTION AND VENUE

United States, 35 U.S.C. 100 et seq.

its interactive ecommerce website at www.tigersupplies.com and its brick-and-mortar showroom

located in Irvington, New Jersey.

Patent is valid, enforceable and currently in full force and effect.

FACTS COMMON TO ALL CLAIMS FOR RELIEF

engineering and building industry.

authorized wholesale distributors.

the architectural, engineering and building industry.

AdirOffice brand blueprint storage racks.

DEFENDANTS INFRINGING ACTIVITIES

ADI692-01-BLK and ADI692-01-WHI.

Storage Racks are the design claimed in the 543 Patent.

Nos. ADI692-50-BLK and ADI692-50-WHI.

Table 2: Comparison of 543 Patent and Defendants Wall Mount

543 Patent Figures AdirOffice Model No. ADI692-50-BLK

sell, sell, or import the infringing blueprint storage racks.

including AdirOffice Model Nos. ADI692-01-BLK, ADI692-01-WHI, ADI692-50-BLK and

543 Patent, in violation of 35 U.S.C. 271(a) and 289.

websites including Amazon.com.

CLAIM FOR RELIEF

27. Plaintiff re-alleges and incorporates by reference the allegations contained in

paragraphs 1 through 28 above as though fully set forth herein.

infringe the 543 Patent.

543 Patent in violation of 35 U.S.C. 271(a) and 289.

31. Plaintiff has suffered pecuniary damages in amounts to be determined at trial as a

entitle Plaintiff to enhanced damages and reasonable attorney fees.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court:

such infringement has been willful;

B. Enter a permanent injunction against Defendants, pursuant to 35 U.S.C. 283

C. Award damages, in an amount to be determined, adequate to compensate Plaintiff

for the infringement that has occurred, pursuant to 35 U.S.C. 284;

Defendants from sales of its infringing products pursuant to 35 U.S.C. 289;

pursuant to 35 U.S.C. 285 and/or other applicable laws; and

Plaintiff demands a trial by jury on all issues so triable.

WEITZMAN LAW OFFICES, LLC

Dated: November 17, 2017 By: /s Kenneth S. Weitzman

Attorneys for Plaintiff James Hanson

CERTIFICATION PURSUANT TO L. CIV. R. 11.2

WEITZMAN LAW OFFICES, LLC

Dated: November 17, 2017 By: /s Kenneth S. Weitzman

Attorneys for Plaintiff James Hanson

RULE 201.1 CERTIFICATION

therefore this action is not appropriate for compulsory arbitration.

WEITZMAN LAW OFFICES, LLC

Dated: November 17, 2017 By: /s Kenneth S. Weitzman

Attorneys for Plaintiff James Hanson

(12) United States Design Patent (10) Patent No.: US D557,543 S

U.S. PATENT DOCUMENTS D466,748 S * 12/2002 Battaglia et al. ............. D6,566

U.S. Patent Dec. 18, 2007 Sheet 1 of 13 US D557,543 S

U.S. Patent Dec. 18, 2007 Sheet 2 of 13 US D557,543 S