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 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA SKULL SHAVER, LLC Plaintiff, v. FREEDOM GROOMING, Defendant. : : : : : : : : : :  No. _________________ VERIFIED COMPLAINT JURY TRIAL DEMANDED Plaintiff Skull Shaver, LLC (“Plaintiff”), by and through its undersigned counsel, hereby brings this Complaint against Defendant Freedom Grooming and in support thereof says: PARTIES 1.
 
Plaintiff Skull Shaver, LLC is a limited liability company of New Jersey, having its principle place of business at 1503 Glen Avenue, Suite 601, Moorestown, NJ 08057. 2.
 
Defendant Freedom Grooming (“Defendant”) is, upon information and  belief, a corporate entity organized under the laws of Pennsylvania, located at 1631 Wethersfield Drive, Allentown, PA 18104 and having a place of business at 233 Mickley Road, Whitehall, PA 18052. JURISDICTION AND VENUE 3.
 
This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1338(a) because the cause of action arises under the Patent Laws of the United States and, specifically, 35 U.S.C. §§ 271 and 289.
Case 5:20-cv-03670 Document 1 Filed 07/28/20 Page 1 of 5
 
 2 4.
 
This Court has personal jurisdiction over the Defendant because it is located in this judicial district and incorporated in this district. 5.
 
Venue is proper pursuant to 28 U.S.C. §1400(b) in that Defendant resides in this judicial district. DESIGN PATENT INFRINGEMENT 6. Skull Shaver is in the business of designing and selling electric shavers in the United States and throughout the world. 7. Skull Shaver is the owner of U.S. Design Patent No. D672504 entitled “Electric Head Shaver” which duly and legally issued on December 11, 2012 (hereinafter the “Patent”). The Patent is in full force and effect and a copy is attached hereto as Exhibit A. 8. In contravention to 35 U.S.C. §§271 and 289, Defendant has willfully and deliberately infringed the Patent by making, using, selling, and/or offering to sell, or causing others to make, use, sell, and/or offer to sell an electric shaver which it refers to as “Eagle Flex Shaver” or “Flex Series Grooming Kit” (hereinafter “Flex Series”) and which embodies the invention claimed in the Patent. Photographs of the Flex Series shaver are attached hereto as Exhibit B. 9. Defendant’s shavers are relatively inexpensive costing only about $60.00. 10. On information and belief, Defendant’s Flex Series shavers are sold only online, and are not available in stores. 11. As a result of the manner in which the Flex Series shavers are sold, a  prospective consumer does not have an opportunity to closely examine the same. He or she can see only what is shown on online.
Case 5:20-cv-03670 Document 1 Filed 07/28/20 Page 2 of 5
 
 3 12. Although there are some differences in the designs, the overall appearance of the Flex Series shaver is substantially the same as the design in the Patent or is at least a colorable imitation thereof. 13. By way of example, both designs compromise: (1) a housing which contains the battery-operated electrical source and drive components; (2) a central hub extending from under the center of the housing to the cutter mechanism, connecting the two parts; and (3) the cutter mechanism defines a plane. 14. The ordinary observer, seeing the Flex Series shaver on online, would be deceived into believing that the Flex Series shaver is the same as the patented design. WHEREFORE, Skull Shaver prays for judgment against Defendant as follows: A. That, pursuant to 35 U.S.C. §283, preliminary and final injunctions be issued enjoining Defendant, its officers, agents, servants, employees and all those persons in active concert or participation with any of them from further infringement of the Patent; B. That, pursuant to 35 U.S.C. §284, Defendant account to Skull Shaver for damages for all past infringement, including treble damages because of the willful nature of such infringement; C. That, pursuant to 35 U.S.C. §285, Skull Shaver be awarded costs and attorney’s fees incurred in connection with this action; D. That, pursuant to 35 U.S.C. §289, Defendant account to Skull Shaver for the total extent of Defendant’s profits resulting from Defendant’s past infringement; and E. Such other and further relief as this court deems just and proper.
Case 5:20-cv-03670 Document 1 Filed 07/28/20 Page 3 of 5

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