Sunteți pe pagina 1din 22

Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.

1 Page 1 of 7

Will Lemkul (SBN 219061)


1 MORRIS, SULLIVAN & LEMKUL, LLP
9915 Mira Mesa Blvd. Suite 300
2 San Diego, CA 92131
Phone: (858) 566-7600
3 Fax: (858) 566-6602
lemkul@morrissullivanlaw.com
4 Attorney for HACHIGIAN INDUSTRIES, INC.
5
6
7
8 IN THE UNITED STATES DISTRICT COURT
9 FOR THE SOUTHERN DISTRICT OF CALIFORNIA
10
HACHIGIAN INDUSTRIES, INC., a CASE NO. '18CV0653 BTM JLB
11 California corporation,
COMPLAINT FOR:
12 Plaintiff,
1. Patent Infringement; and
13 v. 2. Unfair Competition
14 EVOLVE USA LLC, a California DEMAND FOR JURY TRIAL
Limited Liability Company; and DOES 1
15 through 50, inclusive
16
Defendants.
17
18
Plaintiff HACHIGIAN INDUSTRIES, INC. brings this action against the
19
Defendant EVOLVE USA LLC for injunctive relief and damages under the laws of the
20
United States of America and the State of California as follows:
21
SUBJECT MATTER JURISDICTION AND VENUE
22
1. This action involves claims for patent infringement that arise under the
23
Federal Patent Act, 35 U.S.C. §§ 101 et seq. This Court has exclusive subject matter
24
jurisdiction over the claims in this action under 28 U.S.C. §§ 1331 and 1338(a).
25
2. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391(b) and/or (c).
26
The infringing products which are the subject of this litigation were advertised,
27
distributed, sold, and/or offered for distribution and sale in the Southern District of
28
California and the claims alleged in this action arose in the Southern District of
1
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.2 Page 2 of 7

1 California. Additionally, the majority of the witnesses and documents related to this
2 action are located in California.
3 PARTIES AND PERSONAL JURISDICTION
4 3. Plaintiff HACHIGIAN INDUSTRIES, INC. (hereinafter “HACHIGIAN”) is
5 and at all relevant times was a California corporation, with its principal place of business
6 in Encinitas, California.
7 4. Upon information and belief, Defendant EVOLVE USA LLC (hereinafter
8 “EVOLVE”), is a California limited liability company with its principal place of business
9 in San Francisco, California. Upon information and belief, EVOLVE transacts business
10 in California, including, but not limited to importing, distributing, advertising, selling
11 and/or offering for sale the goods at issue in this Complaint. The acts of infringement and
12 other wrongful acts alleged in this Complaint occurred in the Southern District of
13 California.
14 5. HACHIGIAN is ignorant of the true names and capacities of defendants
15 DOES 1 through 50, inclusive, and by reason thereof sues said Defendants by their
16 fictitious names. HACHIGIAN will obtain leave of court, if necessary, to amend this
17 Complaint to allege the true names and capacities of these fictitiously named Defendants
18 when their identities are fully and finally ascertained.
19 NATURE OF THE DISPUTE
20 6. HACHIGIAN is widely recognized for its diving and spearfishing products,
21 including flotation devices and other flotation related products, which HACHIGIAN has
22 created, manufactured and/or distributed throughout the United States under the name
23 GANNET and/or GANNET DIVE COMPANY USA (hereinafter collectively
24 “GANNET”). HACHIGIAN has expended substantial resources in developing and
25 protecting the inflatable device primarily for flotation identified in United States Patent
26 No. D783,205 S (hereinafter “Subject Patent”). See, Exhibit A attached hereto and
27 incorporated herein by reference. Accordingly, HACHIGIAN has developed a significant
28 amount of goodwill related to the Subject Patent.

2
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.3 Page 3 of 7

1 7. HACHIGIAN is the owner of the Subject Patent. On or about March 19,


2 2018, Garo Jack Hachigian transferred all right, title and interest in the Subject Patent to
3 HACHIGIAN.
4 8. The Subject Patent discloses an ornamental design of an inflatable device
5 primarily for flotation, and was filed on or about April 14, 2015 and issued on or about
6 April 4, 2017.
7 9. HACHIGIAN owns all rights, title and interest in the Subject Patent,
8 including the right to protect and enforce the intellectual property rights and interests
9 arising from the Subject Patent.
10 10. The Subject Patent is valid and subsisting.
11 11. On information and belief, Defendants, EVOLVE and DOES 1 through 50,
12 inclusive, and each of them, without the consent of HACHIGIAN, have infringed and are
13 still infringing the Subject Patent by designing, manufacturing, licensing, distributing,
14 importing and/or selling inflatable devices primarily for flotation and/or other floatation
15 products that encompass the design of and/or are substantially the same to the Subject
16 Patent. In particular, Defendants, and each of them, are at a minimum designing,
17 manufacturing, licensing, distributing, importing and/or selling certain inflatable devices
18 primarily for flotation referred to as “Evolve Carbon Hybrid 3ATM” floats, which include
19 designs that encompass the design of and/or are substantially the same to the Subject
20 Patent. See, Exhibit B attached hereto and incorporated herein by reference.
21 12. On information and belief, Defendants, and each of them, will continue to
22 design, manufacture, license, distribute, import and/or sell “Evolve Carbon Hybrid
23 3ATM” floats and/or other similar floatation products which encompass the design of
24 and/or are substantially the same to the Subject Patent unless enjoined by this Court.
25 13. At all relevant times herein, upon information and belief, one or more
26 principals and/or officers of EVOLVE, had direct knowledge of the existence and scope
27 of coverage of the Subject Patent.
28 14. Specifically, on or about February 13, 2018, counsel for HACHIGIAN sent a

3
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.4 Page 4 of 7

1 notification letter to EVOLVE, explicitly notifying EVOLVE of the existence and/or


2 potential relevance of the Subject Patent to EVOLVE’s “Evolve Carbon Hybrid 3ATM”
3 floats and/or other similar floatation products. See, Exhibit C attached hereto and
4 incorporated herein by reference.
5 15. EVOLVE did not respond to HACHIGIAN’s February 13, 2018 letter.
6 Instead, Defendants, and each of them, have continued to design, manufacture, license,
7 distribute, import and/or sell “Evolve Carbon Hybrid 3ATM” floats and/or other similar
8 floatation products which encompass the design of and/or are substantially the same to the
9 Subject Patent despite the direct knowledge of one or more officers as to the existence and
10 scope of coverage of the Subject Patent.
11 FIRST CLAIM FOR RELIEF
12 (Patent Infringement under 35 U.S.C. § 271 against all Defendants –
13 U.S. Patent No. D783, 205 S)
14 16. HACHIGIAN realleges, and incorporates herein by this reference, each and
15 every allegation set forth in paragraphs 1 through 15, inclusive.
16 17. Defendants, and each of them, have been and are directly infringing the
17 Subject Patent under 35 U.S.C. § 271(a) by making, using, offering to sell, and selling,
18 the “Evolve Carbon Hybrid 3ATM” floats and/or other similar floatation products within
19 the United States.
20 18. Upon information and belief, Defendants’ customers and other users of
21 Defendants’ “Evolve Carbon Hybrid 3ATM” floats and/or other similar floatation products
22 have been and are directly infringing the design in the Subject Patent under 35 U.S.C. §
23 271(a).
24 19. Defendants, and each of them, have been and are actively inducing
25 infringement of the design in the Subject Patent under 35 U.S.C. § 271(b) by providing to
26 customers, including customers in this judicial district, its “Evolve Carbon Hybrid 3ATM”
27 floats and/or other similar floatation products. On information and belief, Defendants, and
28 each of them, knew, or should have known, that its customers and other users of its

4
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.5 Page 5 of 7

1 products would use Defendants’ products to infringe the Subject Patent and intended such
2 infringement.
3 20. Defendants’ infringement, and inducement to infringe the Subject Patent
4 have been willful and have deliberately injured and will continue to injure HACHIGIAN
5 unless and until this Court enters a preliminary or permanent injunction prohibiting
6 further infringement and, specifically, enjoining further manufacture, use, importation,
7 sale, and/or offer for sale of products that fall within the scope of the design in the Subject
8 Patent.
9 21. Defendants’ infringement, and inducement to infringe the Subject Patent
10 have been willful and have deliberately injured and/or damaged HACHIGIAN in an
11 amount to be determined at trial.
12 SECOND CLAIM FOR RELIEF
13 (Unfair Competition against All Defendants)
14 22. HACHIGIAN realleges, and incorporates by this reference, each and every
15 allegation set forth in paragraphs 1 through 21, inclusive.
16 23. The acts and conduct of Defendants, and each of them, alleged in this
17 Complaint (i) constitute an unfair competition at common law; (ii) violate Sections 17200
18 et seq. and 17500 et seq. of the California Business and Professions Code; and/or (iii)
19 constitute an infringement of HACHIGIAN’s statutory rights in its Subject Patent and
20 improper and unfair competition with HACHIGIAN.
21 24. Defendants have been engaged in trade and commerce in California through
22 advertising, selling and distributing goods.
23 25. Defendants have employed unlawful, unfair and/or fraudulent business
24 methods, acts and practices within the meaning of Sections 17200 et seq. and 17500 et
25 seq. of the California Business and Professions Code. These acts or practices include, but
26 are not limited to, infringement of products that fall within the scope of the design in the
27 Subject Patent.
28 26. Defendants’ conduct as alleged above has caused HACHIGIAN

5
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.6 Page 6 of 7

1 ascertainable damages and has damaged and will continue to damage HACHIGIAN’s
2 goodwill and reputation and has resulted in a loss of profits to HACHIGIAN in an
3 amount which is unknown at the present time, but which is in excess of the jurisdictional
4 minimum of this court. Further, Defendants, and each of them, have made profits from
5 the infringing use and from the acts of unfair competition, the extent of such profits being
6 currently unknown to HACHIGIAN, but in excess of the jurisdictional minimum of this
7 Court.
8 27. Defendants’ acts are capable of repetition and have harmed and continue to
9 harm the public interest.
10 28. HACHIGIAN is entitled to an award of damages and its attorney’s fees and
11 costs.
12 29. Defendants used such unlawful and unfair trade methods, practices and acts
13 willfully and knowingly.
14 30. Unless permanently restrained and enjoined, Defendants, and each of them,
15 will continue to offer goods using a design which infringes HACHIGIAN’s Subject
16 Patent and causing HACHIGIAN substantial damages to its business, reputation and
17 goodwill. Because the amount of these damages cannot be readily ascertained,
18 HACHIGIAN is without an adequate remedy at law.
19 PRAYER FOR RELIEF
20 WHEREFORE, HACHIGIAN respectfully requests judgment as follows:
21 1. That the Court enter a judgment against Defendants, and each of them, that
22 they have:
23 a. Infringed the rights of HACHIGIAN in the Subject Patent and/or
24 induced others to infringe the Subject Patent;
25 b. Competed unfairly with HACHIGIAN at common law and in
26 violation of Sections 17200 et seq. and 17500 et seq. of the California Business and
27 Professions Code; and
28 c. Otherwise injured the business reputation and business of

6
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1 Filed 03/30/18 PageID.7 Page 7 of 7

1 HACHIGIAN by their acts and conduct set forth in the Complaint.


2 2. That the Court issue a permanent injunction prohibiting further infringement,
3 and inducement to infringe of the Subject Patent;
4 3. That the Court enter a judgment, order, or award of damages adequate to
5 compensate HACHIGIAN for Defendants’ infringement of the Subject Patent, based on
6 lost sales, lost profits, price erosion, loss of market share, or any other applicable theory,
7 together with prejudgment interest from the date infringement of the Subject Patent
8 began;
9 4. That the Court find that this case is exceptional and an award to
10 HACHIGIAN of its attorneys’ fees and costs as provided by 35 U.S.C. § 285;
11 5. That the Court enter a judgement, order or award of increased damages as
12 permitted by 35 U.S.C. § 284, together with prejudgment interest; and
13 6. Such other and further relief as this court or a jury may deem proper and just.
14 DEMAND FOR JURY TRIAL
15 HACHIGIAN hereby demands a trial by jury on its claims herein and all issues and
16 claims so triable in this action.
17
18
19 Dated: March 30, 2018 MORRIS, SULLIVAN & LEMKUL, LLP

20
21 By: s/ Will Lemkul
Will Lemkul
22 Attorney for HACHIGIAN
INDUSTRIES, INC.
23
24
25
26
27
28

7
COMPLAINT
Case 3:18-cv-00653-BTM-JLB Document 1-1 Filed 03/30/18 PageID.8 Page 1 of 1
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS


HACHIGIAN INDUSTRIES, INC., a California corporation, EVOLVE USA LLC, a California Limited Liability Company; and DOES
1 through 50, inclusive
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Will Lemkul, Esq. (SBN 219061) MORRIS, SULLIVAN & LEMKUL, LLP '18CV0653 BTM JLB
9915 Mira Mesa Blvd. Suite 300 SD, CA 92131 (858) 566-7600

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 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
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Federal Patent Act, 35 U.S.C. §§ 101 et seq
VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement; and Unfair Competition
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
03/30/2018 s/ Will Lemkul
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE


Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.9 Page 1 of 9

















(;+,%,7$
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.10 Page 2 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.11 Page 3 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.12 Page 4 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.13 Page 5 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.14 Page 6 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.15 Page 7 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.16 Page 8 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-2 Filed 03/30/18 PageID.17 Page 9 of 9
Case 3:18-cv-00653-BTM-JLB Document 1-3 Filed 03/30/18 PageID.18 Page 1 of 2

















(;+,%,7%
Case 3:18-cv-00653-BTM-JLB Document 1-3 Filed 03/30/18 PageID.19 Page 2 of 2


Case 3:18-cv-00653-BTM-JLB Document 1-4 Filed 03/30/18 PageID.20 Page 1 of 3

















(;+,%,7&
Case 3:18-cv-00653-BTM-JLB Document 1-4 Filed 03/30/18 PageID.21 Page 2 of 3

ROEDER & BRODER LLP


Intellectual Property Law Firm
Patents, Trademarks and Copyrights

JAMES P. BRODER TELEPHONE


jbroder@rbiplaw.com 13400 Sabre Springs Pkwy., Ste. 155 (858) 635-2142
San Diego, California 92128 FACSIMILE
(858) 635-9686

February 13, 2018

VIA FEDEX

Evolve USA LLC


Attn: Legal Department
74-5576 Pawai Place Ste. J #668
Kailua-Kona, HI 96740

Re: Notice of U.S. Design Patent No. D783,205 S

To Whom It May Concern:

This office has been retained by Garo Jack Hachigian and Gannet Dive
Company USA (hereinafter “Gannet”) to represent their intellectual property
rights in relation to certain design patents. The purpose of this correspondence is
to notify you, and thus, Evolve USA LLC (hereinafter “Evolve”), that Mr. Hachigian,
the CEO of Gannet, is the owner of U.S. Design Patent No. D783,205 S
(hereinafter the “Issued Patent”). I have enclosed a copy of the Issued Patent for
your reference.

Mr. Hachigian is interested and/or concerned about one or more of the


activities and/or products being manufactured, advertised, distributed and/or sold
by Evolve, to the extent that such activities and/or products may be covered by the
Issued Patent. In particular, it has come to our attention that Evolve is advertising,
distributing and/or selling one or more products online (e.g.,
www.evolvediving.com) and/or in various retail locations that may be relevant
relative to the intellectual property set forth in the Issued Patent. For example,
certain products manufactured under the general name Evolve Carbon Hybrid
3ATM Floats that are being advertised, distributed and/or sold by Evolve may be
relevant to the intellectual property shown and described in the Issued Patent. We
believe that the enclosed Issued Patent may be of interest to you, given the
products that you are offering. You now have explicit notification of the Issued
Patent.

Accordingly, I would request that you, your intellectual property attorney or


another appropriate representative of Evolve contact me immediately or no more
than 10 days from the date of this correspondence to discuss this matter and the
potential relevance of the Issued Patent.
Case 3:18-cv-00653-BTM-JLB Document 1-4 Filed 03/30/18 PageID.22 Page 3 of 3
Evolve USA LLC
February 13, 2018
Page 2

Certainly, if upon your review of the enclosed Issued Patent you believe it to
be irrelevant to the issue of your activities and/or product(s), please provide me with
any facts or information that tends to support your position, and I will give them my
immediate attention.

I look forward to hearing from you at your earliest opportunity, but no more
than ten (10) days from the date of this correspondence.

Very truly yours,

ROEDER & BRO


BRODER LLP

     
JAMES
JA
AM
MES
ES P
P. BRODER
BROD
BR

JPB:dne
Enclosure (US Design Patent No. D783,205 S)

cc: Garo Jack Hachigian, CEO, Gannet Dive Company USA