UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN GII ACQUISITION, LLC, a Michigan limited liability company, d/b/a

General Inspection, LLC, Case No. _________ Plaintiff, v. CYBERNET SYSTEMS CORPORATION, a Delaware corporation, Defendant. JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND

I. 1.

THE PARTIES

Plaintiff GII Acquisition, LLC, is a Michigan limited liability

company, doing business as General Inspection, LLC (General Inspection), having an address at 10585 Enterprise Drive, Davisburg, Michigan 48350. 2. Defendant Cybernet Systems Corporation (Cybernet), is a Delaware

corporation, having its principal place of business at 3885 Research Park Dr., Ann Arbor, Michigan 48108-1639. 3. Cybernet has appointed The Corporation Company, 2711 Centerville

Rd., Ste. 400, Wilmington, Delaware 19808, as its agent for service of process.

II. 4.

JURISDICTION

The federal claims pleaded herein arise under the Patent Act, 35

U.S.C. 1 et seq. 5. Subject matter jurisdiction for the federal claims is conferred upon the

Court by 28 U.S.C. 1338(a).

III. 6.

PATENT INFRINGEMENT

On July 22, 2008, U.S. Patent No. 7,403,872 (the 872 patent) was

duly and lawfully issued to James W. St. Onge et al for Method and System for Inspecting Manufactured Parts and Sorting the Inspected Parts. A true and correct copy of the 872 patent is at Exhibit A. 7. General Inspection is the owner by assignment of the 872 patent, as

evidenced by the records of the Assignment Branch of the United States Patent and Trademark Office, at Reel 19678, Frame 859. 8. Cybernet has made, used, sold, and offered for sale, in the United

States, an Automated Tactical Ammunition Classification system (ATAC system), without the consent of General Inspection. 9. Upon information and belief, after an inquiry reasonable under the The factual

circumstances, the ATAC system infringes the 872 patent.

contentions of this paragraph will likely have evidentiary support after a reasonable opportunity for further case investigation and discovery. 10. General Inspection has complied with the statutory requirement of placing a

notice of the 872 patent on all ammunition inspection systems it manufactures and sells.

11.

General Inspection gave Cybernet written notice of the infringement

of the 872 patent on at least as early as September 24, 2012. 12. General Inspection has been harmed, pecuniarily and irreparably, and

will continue to be unless Cybernets infringement is enjoined by the Court.

IV.

DEMAND FOR RELIEF

WHEREFORE, General Inspection demands entry of judgment against Cybernet granting relief as follows: A. A determination that Cybernet has infringed 872 patent by the

acts complained of herein; B. An award of damages adequate to compensate for such

infringement; C. An enhancement of the compensatory damages, up to three (3)

times, if such infringement is found to have been willful; D. A determination that this case is exceptional, in the sense of

35 U.S.C. 285; E. An order preliminarily and permanently enjoining Cybernet, its

officers, agents, servants, employees, contractors, suppliers and attorneys, and upon those persons in active concert or participation with them who

receive actual notice of the order by personal service or otherwise, from committing further acts of infringement of the 872 patent; F. An award in favor of General Inspection, and against Cybernet,

for the costs incurred in bringing and maintaining this action, including reasonable attorneys' fees; and G. Such other, further, and different relief as may be just and

equitable on the proofs.

V.

JURY DEMAND

Plaintiff General Inspection demands trial by jury for all issues so triable. Respectfully submitted, BROOKS KUSHMAN P.C. Dated: November 26, 2013 /s/ Robert C.J. Tuttle ROBERT C. J. TUTTLE (P25222) THOMAS A. LEWRY (P36399) BRIAN C. DOUGHTY (P71652) 1000 Town Center, Twenty-Second Floor Southfield, Michigan 48075 Tel: (248) 358-4400 / Fax: (248) 358-3351 Email: rtuttle@brookskushman.com tlewry@brookskushman.com bdoughty@brookskushman.com Attorneys for Plaintiff