1 LANDVER LAW CORPORATION, APC

Alina Landver (SBN 231077)

2 9301 Wilshire Boulevard, Suite 605
Beverly Hills, California 90210
3 Tel: (310) 461-3737
Fax: (310) 461-3736
4 Email: alina@landverlaw.com
5 KEENER AND ASSOCIATES, P.C.
Kevin Keener (pro hac vice pending)
6 161 North Clark Street, Suite 1600
Chicago IL 60601
7 Tel: (312) 523-2164
Email: kevin.keener@keenerlegal.com
8
Attorneys for Plaintiff
9 NG IMPORTS
10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
12 NG IMPORTS, a California Corporation, CASE NO. 2:20-cv-09776
13 Plaintiff,
vs. COMPLAINT FOR DECLARATORY
14 JUDGMENT OF PATENT NON-
ZHENGZHOU KERUI ELECTRONIC INFRINGEMENT, INVALIDITY,
15 COMMERCE COMPANY, LTD. a China AND UNENFORCEABILITY
Corporation,
16 JURY TRIAL DEMANDED
Defendant.
17
18

19
20
21
22
23
24
25
26
27

28

COMPLAINT FOR DECLARATORY JUDGMENT

 1 Plaintiff, NG Imports, complaining of the defendant herein, respectfully
2 shows to this Court, and alleges as follows:
3 NATURE OF THE CASE
4 1. This is an action for declaratory judgment of non-infringement,
5 invalidity, and unenforceability of U.S. Patent No. D879,382 (“the ‘382 patent”). A
6 true and accurate copy of the ‘382 patent is attached hereto as Exhibit 1.
7 THE PARTIES
8 2. Plaintiff NG Imports (“Plaintiff”) is a California Corporation with its
9 principal place of business located at 1446 E. 33rd Street, Signal Hill California
10 90755.
11 3. Defendant Zhengzhou Kerui Electronic Commerce Company, Ltd.
12 (“Defendant”), upon information and belief, is a Chinese Corporation with its
13 principal place of business located at No. 101, Unit 1, Building 3, No. 4,
14 Agricultural Road, Jinshui District, Zhengzhour City, China.
15 JURISDICTION AND VENUE
16 4. This Court has original jurisdiction over the subject matter of this action
17 pursuant to 28 U.S.C. §§ 1331, 1338, 2201, and 2202 as well as 35 U.S.C. § 271.
18 5. Upon information and belief, Defendant is subject to personal
19 jurisdiction in this Court, because Defendant operates its business in this judicial
20 district, and has continuously and systematically transacted business and supplied
21 goods and services directed to consumers residing in this judicial district, including
22 to some extent using the challenged patents at issue in this judicial district.
23 Furthermore, Defendant affirmatively reached out and performed acts in this
24 jurisdiction with respect to the patent at issue. Upon information and belief,
25 Defendant regularly and continuously transacts business in the Central District of
26 California, is continuously engaged in substantial and not isolated activity within the
27 Central District of California, and has otherwise engaged in conduct sufficient to
28

1
COMPLAINT FOR DECLARATORY JUDGMENT
 1 subject Defendant to the personal jurisdiction of this Court in accordance with due
2 process.
3 6. Defendant has purposefully availed itself of the benefit of this State and
4 judicial district, such that maintenance of suit in this judicial district would not
5 violate due process.
6 7. Venue in this district is proper under 28 U.S.C. § 1391 because a
7 substantial part of the events or omissions giving rise to the claim occurred in this
8 district.
9 8. Plaintiff further demands a trial by jury in all matters triable by a jury.
10 FACTUAL BACKGROUND
11 9. Plaintiff imports, manufactures, offers for sale, and sells wigs and wig
12 accessories in the United States under the name Milano Collection.
13 10. One of the wig accessories that Plaintiff has developed and sells is a
14 partial lace headband that is placed under a wig to hold a wig onto a person’s head.
15 This item is sold under the name “Lace WiGrip Comfort Band.”
16 11. The Lace WiGrip Comfort Band has a “T”-shaped lace section
17 positioned in the middle of the headband. The lace section allows users to create a
18 natural looking part in a wig while it is worn.
19 12. Plaintiff filed for a design patent for its Lace WiGrip Comfort Band on
20 August 14, 2019. Plaintiff obtained the design patent from the USPTO for this
21 product, which issued on January 21, 2020 under U.S. Patent No. D873,493. A true
22 and accurate copy of Plaintiff’s design patent is attached hereto as Exhibit 2.
23 13. Notwithstanding Plaintiff’s registered patent, Plaintiff recently received
24 a cease and desist letter, dated October 7, 2020, from Defendant’s attorney. The
25 cease and desist letter alleged that Plaintiff’s Wig Grip products infringed
26 Defendant’s U.S. Patent No. D879,382. This letter demanded that Plaintiff “(1)
27 immediately cease and desist the marketing, importing, manufacturing, offer for
28 sale, and sale of the Wig Grips, [and] (2) immediately destroy all unauthorized
2
COMPLAINT FOR DECLARATORY JUDGMENT
 1 items, which include the Wig Grips that are in [Plaintiff’s] possession, custody, or
2 control.”
3 14. Under all of the circumstances, there a substantial controversy between
4 Plaintiff and Defendant. Plaintiff and Defendant have adverse legal interests of
5 sufficient immediacy and reality to warrant the issuance of a declaratory judgment.
6 COUNT ONE
7 Declaratory Judgment of Non-Infringement of U.S. Patent No. D879,382
8 15. Plaintiff herein repeats, realleges and reiterates each and every
9 allegation as set forth in Paragraphs 1 through 14 as if fully set forth herein.
10 16. A real and actual controversy exists between the parties based on
11 Defendant’s claim that Plaintiff allegedly infringes the claim of the ‘382 patent.
12 Plaintiff and Defendant have adverse interests in the subject matter of the dispute.
13 17. Plaintiff does not infringe, induce infringement of, and/or contributorily
14 infringe, and has not infringed, induced infringement of, and/or contributorily
15 infringed any valid and enforceable claim of the ‘382 patent.
16 18. Plaintiff seeks a declaratory judgment that its wig grip headbands do
17 not infringe, and at all times have never infringed, the ‘382 patent.
18 19. The controversy between the parties is amenable to specific relief
19 through a decree of a conclusive character.
20 20. Without declaratory relief, Plaintiff will be irreparably harmed and
21 damaged.
22 21. Plaintiff is entitled to a judicial declaration that Plaintiff has not and
23 will not infringe, directly or indirectly, any valid and enforceable claim of the ‘382
24 patent.
25 COUNT TWO
26 Declaratory Judgment of Invalidity of U.S. Patent No. D879,382
27 22. Plaintiff herein repeats, realleges and reiterates each and every
28 allegation as set forth in Paragraphs 1 through 19 as if fully set forth herein.
3
COMPLAINT FOR DECLARATORY JUDGMENT
 1 23. Plaintiff believes that the ‘382 patent is invalid and void for failure to
2 comply with one or more sections of Title 35 of the United States Code, including,
3 without limitation, 35 U.S.C. §§ 101, 102, 103, 112, and/or 171 and/ or 37 CFR §
4 1.56.
5 24. A real and actual controversy exists between the parties as to whether
6 the claim of the ‘382 patent is valid. Plaintiff and Defendant have adverse interests
7 in the subject matter of the dispute.
8 25. Plaintiff publicly disclosed and sold its lace wig grip headbands prior to
9 Defendant filing the application for patent for the ‘382 patent.
10 26. The controversy between the parties is amenable to specific relief
11 through a decree of a conclusive character.
12 27. Without declaratory relief, Plaintiff will be irreparably harmed and
13 damaged.
14 28. Plaintiff is entitled to a judicial declaration that each claim of the ‘382
15 patent is invalid for failure to satisfy one or more conditions of patentability set forth
16 in 35 U.S.C. §§ 101, 102, 103, 112, and/or 171 and/ or 37 CFR § 1.56.
17 PRAYER FOR RELIEF
18 WHEREFORE Plaintiff prays that the Court enter judgment against Defendatn as
19 follows:
20 (1) A declaration that Plaintiff has not infringed, induced infringement of, or
21 contributorily infringed, and does not infringe, induce infringement of, and/or
22 contributorily infringe, any valid or enforceable claim of U.S. Patent No. D879,382;
23 (2) A declaration that U.S. Patent No. D879,382 is invalid or unenforceable and
24 void for failure to comply with one or more sections of Title 35 of the United States
25 Code, including, without limitation, 35 U.S.C. §§ 101, 102, 103, 112 and/or 171
26 and/or failure to comply with 37 C.F.R. § 1.56;
27 (3) A declaration that this case is “exceptional” within the meaning of 35 U.S.C. §
28 285;
4
COMPLAINT FOR DECLARATORY JUDGMENT
 1 (4) An award to Plaintiff of its costs, attorney fees, and expenses pursuant to 35
2 U.S.C. § 285; and
3 (5) That Plaintiff be awarded any such other and further relief as this Court
4 seems, just, proper and equitable under the facts and circumstances presented herein.
5 Dated: October 23, 2020
6 Respectfully submitted,
7
8
9 By: ______/s/Alina Landver____________
Alina Landver
10 California Bar # 231077
11 Landver Law Corporation APC
8200 Wilshire Boulevard, PH Suite 400
12 Beverly Hills, California 90211
Tel: (310) 461-3737
13 Fax: (310) 461-3736
Email: alina@landverlaw.com
14
15
16 By: /s/Kevin Keener
17 Kevin Keener (IL Bar No. 6296898)
Pro Hac Vice pending
18 161 North Clark Street, Suite 1600
Chicago, Illinois 60601
19 Tel: (312) 523-2164
Email: kevin.keener@keenerlegal.com
20
21 Attorneys for Plaintiff
22
23
24
25
26
27

28

5
COMPLAINT FOR DECLARATORY JUDGMENT
EXHIBIT 1
EXHIBIT 2
 NAME, ADDRESS, AND TELEPHONE NUMBER OF ATTORNEY(S) CLEAR FORM
OR OF PARTY APPEARING IN PRO PER
LANDVER LAW CORPORATION, APC
Alina Landver (SBN 231077)
9301 Wilshire Boulevard, Suite 605
Beverly Hills, California 90210
Tel: (310) 461-3737; Fax: (310) 461-3736
Email: alina@landverlaw.com

ATTORNEY(S) FOR: Plaintiff, NG IMPORTS

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
NG IMPORTS, a California Corporation, CASE NUMBER:

2:20-cv-09776
Plaintiff(s),
v.
ZHENGZHOU KERUI ELECTRONIC
CERTIFICATION AND NOTICE
COMMERCE COMPANY, LTD. a China
OF INTERESTED PARTIES
Corporation, (Local Rule 7.1-1)
Defendant(s)

TO: THE COURT AND ALL PARTIES OF RECORD:

The undersigned, counsel of record for Plaintiff, NG IMPORTS, a California Corporation

or party appearing in pro per, certifies that the following listed party (or parties) may have a pecuniary interest in
the outcome of this case. These representations are made to enable the Court to evaluate possible disqualification
or recusal.
(List the names of all such parties and identify their connection and interest. Use additional sheet if necessary.)

PARTY CONNECTION / INTEREST

NG IMPORTS, a California Corporation, Plaintiff

SZHENGZHOU KERUI ELECTRONIC COMMERCE Defendant

COMPANY, LTD. a China Corporation,

October 23, 2020 /ALINA LANDVER/

Date Signature

Attorney of record for (or name of party appearing in pro per):

Plaintiff, NG IMPORTS, a California Corporation

CV-30 (05/13) NOTICE OF INTERESTED PARTIES

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the
Central District
__________ District of
of California
__________

NG IMPORTS, a California Corporation, )

)
)
)
Plaintiff(s) )
)
v. Civil Action No. 2:20-cv-90776
)
ZHENGZHOU KERUI ELECTRONIC COMMERCE )
COMPANY, LTD. a China Corporation, )
)
)
Defendant(s) )

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address) ZHENGZHOU KERUI ELECTRONIC COMMERCE COMPANY, LTD. a China
Corporation.
6No. 101, Unit 1, Building 3, No. 4, Agricultural Road, Jinshui District, Zhengzhour
City, China.

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
LANDVER LAW CORPORATION, APC
9301 Wilshire Boulevard, Suite 605
Beverly Hills, California 90210

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No. 2:20-cv-90776

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

’ I personally served the summons on the individual at (place)

on (date) ; or

’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or

’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or

’ I returned the summons unexecuted because ; or

’ Other (specify):
.

My fees are $ for travel and $ for services, for a total of $ 0.00 .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

Print Save As... Reset

 UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
I. (a) PLAINTIFFS ( Check box if you are representing yourself ) DEFENDANTS ( Check box if you are representing yourself )

NG IMPORTS, a California Corporation ZHENGZHOU KERUI ELECTRONIC COMMERCE COMPANY, LTD. a China Corporation

(b) County of Residence of First Listed Plaintiff Los Angeles, CA County of Residence of First Listed Defendant Zhengzhour China
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

(c) Attorneys (Firm Name, Address and Telephone Number) If you are Attorneys (Firm Name, Address and Telephone Number) If you are
representing yourself, provide the same information. representing yourself, provide the same information.
LANDVER LAW CORPORATION, APC.
9301 WILSHIRE BLVD. SUITE 605
BEVERLY HILLS CA 90210 Ph. 310-461-3737

II. BASIS OF JURISDICTION (Place an X in one box only.) III. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only
(Place an X in one box for plaintiff and one for defendant)
PTF DEF PTF DEF
1. U.S. Government 3. Federal Question (U.S. 1 1 Incorporated or Principal Place 4 4
Citizen of This State
Plaintiff Government Not a Party) of Business in this State
Citizen of Another State 2 2 Incorporated and Principal Place 5 5
of Business in Another State
2. U.S. Government 4. Diversity (Indicate Citizenship Citizen or Subject of a
Foreign Country 3 3 Foreign Nation 6 6
Defendant of Parties in Item III)

IV. ORIGIN (Place an X in one box only.)

6. Multidistrict 8. Multidistrict
1. Original 2. Removed from 3. Remanded from 4. Reinstated or 5. Transferred from Another Litigation - Litigation -
Proceeding State Court Appellate Court Reopened District (Specify) Transfer Direct File

V. REQUESTED IN COMPLAINT: JURY DEMAND: Yes No (Check "Yes" only if demanded in complaint.)
CLASS ACTION under F.R.Cv.P. 23: Yes No MONEY DEMANDED IN COMPLAINT: $
VI. CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
Declaratory Judgment of Non-Infringement of U.S. Patent No. D879,382; Declaratory Judgment of Invalidity of U.S. Patent No. D879,382

VII. NATURE OF SUIT (Place an X in one box only).

OTHER STATUTES CONTRACT REAL PROPERTY CONT. IMMIGRATION PRISONER PETITIONS PROPERTY RIGHTS
375 False Claims Act 110 Insurance 240 Torts to Land 462 Naturalization Habeas Corpus: 820 Copyrights
Application
120 Marine 245 Tort Product 463 Alien Detainee 830 Patent
376 Qui Tam Liability 465 Other 510 Motions to Vacate
(31 USC 3729(a)) 290 All Other Real Sentence 835 Patent - Abbreviated
130 Miller Act Immigration Actions
400 State Property TORTS 530 General New Drug Application
140 Negotiable
Reapportionment Instrument TORTS PERSONAL PROPERTY 535 Death Penalty 840 Trademark
410 Antitrust 150 Recovery of PERSONAL INJURY 880 Defend Trade Secrets Act
370 Other Fraud Other:
430 Banks and Banking Overpayment & 310 Airplane of 2016 (DTSA)
Enforcement of 371 Truth in Lending 540 Mandamus/Other
450 Commerce/ICC 315 Airplane SOCIAL SECURITY
Judgment Product Liability 550 Civil Rights
Rates/Etc. 380 Other Personal
320 Assault, Libel & Property Damage 861 HIA (1395ff)
151 Medicare Act 555 Prison Condition
460 Deportation Slander
385 Property Damage 862 Black Lung (923)
470 Racketeer Influ- 152 Recovery of 560 Civil Detainee
330 Fed. Employers' Product Liability Conditions of
enced & Corrupt Org. Defaulted Student Liability 863 DIWC/DIWW (405 (g))
Loan (Excl. Vet.) BANKRUPTCY Confinement
480 Consumer Credit 340 Marine 864 SSID Title XVI
422 Appeal 28 FORFEITURE/PENALTY
490 Cable/Sat TV 153 Recovery of 345 Marine Product
Overpayment of USC 158 625 Drug Related 865 RSI (405 (g))
850 Securities/Com- Liability
Vet. Benefits 423 Withdrawal 28 Seizure of Property 21
modities/Exchange 350 Motor Vehicle USC 881 FEDERAL TAX SUITS
160 Stockholders' USC 157
890 Other Statutory Suits 355 Motor Vehicle CIVIL RIGHTS 690 Other 870 Taxes (U.S. Plaintiff or
Actions Product Liability Defendant)
190 Other 440 Other Civil Rights LABOR 871 IRS-Third Party 26 USC
891 Agricultural Acts 360 Other Personal
Contract Injury 441 Voting 710 Fair Labor Standards 7609
893 Environmental Act
Matters 195 Contract 362 Personal Injury-
Product Liability Med Malpratice 442 Employment 720 Labor/Mgmt.
895 Freedom of Info. 365 Personal Injury- 443 Housing/ Relations
Act 196 Franchise Accommodations
Product Liability 740 Railway Labor Act
896 Arbitration REAL PROPERTY 445 American with
367 Health Care/ 751 Family and Medical
210 Land Pharmaceutical Disabilities-
899 Admin. Procedures Employment Leave Act
Condemnation Personal Injury
Act/Review of Appeal of Product Liability 446 American with 790 Other Labor
Agency Decision 220 Foreclosure
Disabilities-Other Litigation
368 Asbestos
950 Constitutionality of 230 Rent Lease & Personal Injury 791 Employee Ret. Inc.
448 Education
State Statutes Ejectment Product Liability Security Act

FOR OFFICE USE ONLY: Case Number:

CV-71 (10/20) CIVIL COVER SHEET Page 1 of 3
 UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET

VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will be initially assigned. This initial assignment is subject
to change, in accordance with the Court's General Orders, upon review by the Court of your Complaint or Notice of Removal.
QUESTION A: Was this case removed
from state court? STATE CASE WAS PENDING IN THE COUNTY OF: INITIAL DIVISION IN CACD IS:
Yes No
Los Angeles, Ventura, Santa Barbara, or San Luis Obispo Western
If "no, " skip to Question B. If "yes," check the
box to the right that applies, enter the Orange Southern
corresponding division in response to
Question E, below, and continue from there. Riverside or San Bernardino Eastern

QUESTION B: Is the United States, or B.1. Do 50% or more of the defendants who reside in YES. Your case will initially be assigned to the Southern Division.
one of its agencies or employees, a the district reside in Orange Co.? Enter "Southern" in response to Question E, below, and continue
PLAINTIFF in this action? from there.
check one of the boxes to the right
Yes No
NO. Continue to Question B.2.

B.2. Do 50% or more of the defendants who reside in YES. Your case will initially be assigned to the Eastern Division.
If "no, " skip to Question C. If "yes," answer the district reside in Riverside and/or San Bernardino Enter "Eastern" in response to Question E, below, and continue
Question B.1, at right. Counties? (Consider the two counties together.) from there.

check one of the boxes to the right NO. Your case will initially be assigned to the Western Division.
Enter "Western" in response to Question E, below, and continue
from there.

QUESTION C: Is the United States, or C.1. Do 50% or more of the plaintiffs who reside in the YES. Your case will initially be assigned to the Southern Division.
one of its agencies or employees, a district reside in Orange Co.? Enter "Southern" in response to Question E, below, and continue
DEFENDANT in this action? from there.
check one of the boxes to the right
Yes No
NO. Continue to Question C.2.

C.2. Do 50% or more of the plaintiffs who reside in the YES. Your case will initially be assigned to the Eastern Division.
If "no, " skip to Question D. If "yes," answer district reside in Riverside and/or San Bernardino Enter "Eastern" in response to Question E, below, and continue
Question C.1, at right. Counties? (Consider the two counties together.) from there.

check one of the boxes to the right NO. Your case will initially be assigned to the Western Division.
Enter "Western" in response to Question E, below, and continue
from there.
A. B. C.
Riverside or San Los Angeles, Ventura,
QUESTION D: Location of plaintiffs and defendants? Orange County Bernardino County Santa Barbara, or San
Luis Obispo County
Indicate the location(s) in which 50% or more of plaintiffs who reside in this district
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Check up to two boxes, or leave blank if none of these choices
apply.)

D.1. Is there at least one answer in Column A? D.2. Is there at least one answer in Column B?
Yes No Yes No
If "yes," your case will initially be assigned to the If "yes," your case will initially be assigned to the
SOUTHERN DIVISION. EASTERN DIVISION.
Enter "Southern" in response to Question E, below, and continue from there. Enter "Eastern" in response to Question E, below.
If "no," go to question D2 to the right. If "no," your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.

QUESTION E: Initial Division? INITIAL DIVISION IN CACD

Enter the initial division determined by Question A, B, C, or D above: WESTERN

QUESTION F: Northern Counties?

Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, or San Luis Obispo counties? Yes No
CV-71 (10/20) CIVIL COVER SHEET Page 2 of 3
 UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET

IX(a). IDENTICAL CASES: Has this action been previously filed in this court? NO YES

If yes, list case number(s):

IX(b). RELATED CASES: Is this case related (as defined below) to any civil or criminal case(s) previously filed in this court?
NO YES
If yes, list case number(s):

Civil cases are related when they (check all that apply):

A. Arise from the same or a closely related transaction, happening, or event;

B. Call for determination of the same or substantially related or similar questions of law and fact; or

C. For other reasons would entail substantial duplication of labor if heard by different judges.

Note: That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases related.

A civil forfeiture case and a criminal case are related when they (check all that apply):

A. Arise from the same or a closely related transaction, happening, or event;

B. Call for determination of the same or substantially related or similar questions of law and fact; or
C. Involve one or more defendants from the criminal case in common and would entail substantial duplication of
labor if heard by different judges.

X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT): /ALINA LANDVER/ DATE: 10-23-2020

Notice to Counsel/Parties: The submission of this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein
neither replaces nor supplements the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. For
more detailed instructions, see separate instruction sheet (CV-071A).

Key to Statistical codes relating to Social Security Cases:

Nature of Suit Code Abbreviation Substantive Statement of Cause of Action

All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also,
861 HIA include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the program.
(42 U.S.C. 1935FF(b))

862 BL All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C.
923)

863 DIWC All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus
all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g))

863 DIWW All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as
amended. (42 U.S.C. 405 (g))

864 SSID All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as
amended.

865 RSI All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended.
(42 U.S.C. 405 (g))

CV-71 (10/20) CIVIL COVER SHEET Page 3 of 3