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COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

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GREENBERG TRAURIG, LLP
J. Rick Tach (CA Bar No. 195100)
(tacher@gtlaw.com)
Michael A. Piazza (CA Bar No. 235881)
(piazzam@gtlaw.com)
Roger L. Scott (CA Bar No. 247165)
(scottro@gtlaw.com)
Shaun A. Hoting (CA Bar No. 260656)
(hotings@gtlaw.com)
Jenny S. Kim (CA Bar No. 282562)
(kimje@gtlaw.com)
3161 Michelson Drive, Suite 1000
Irvine, California 92612
Telephone: (949) 732-6500
Facsimile: (949) 732-6501

Attorneys for Plaintiff FlowRider Surf, Ltd.

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA

FLOWRIDER SURF, LTD., a Canadian
corporation,

Plaintiff,

vs.

RICHARD ALLESHOUSE, an
individual; YONG YEH, an individual;
PACIFIC SURF DESIGNS,INC., a
Delaware corporation; and DOES 1-10,

Defendants.
CASE NO. ________________________

COMPLAINT FOR DAMAGES AND
INJUNCTIVE RELIEF

(1) Breach of Contract
(2) Conversion
(3) Fraud and Deceit Intentional
Misrepresentation
(4) Tortious Interference With
Economic Relationship and
Prospective Economic Advantage
(5) Patent Infringement of U.S. Patent
No. 6,491,589
(6) Unfair Business Practices in
Violation of Cal. Bus. & Prof. Code
17200, et seq.

DEMAND FOR JURY TRIAL

'14CV1110 BLM GPC

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Plaintiff FlowRider Surf, Ltd. (FlowRider or Plaintiff) complains and alleges
as follows against Defendants Richard Alleshouse (Alleshouse), Yong Yeh (Yeh),
Pacific Surf Designs (PSD), and Does 1-10 (collectively, Defendants):
NATURE OF ACTION
1. This is an action for patent infringement, breach of contract, and unfair
business practices arising under the patent laws of the United States, Title 35 of the
United States Code, California common law, and California Business & Professions
Code 17200, et seq. Plaintiff seeks damages, attorneys' fees, costs, pre-judgment and
post-judgment interest, and preliminary and permanent injunctive relief.
JURISDICTION & PARTIES
2. This Court has subject matter jurisdiction over this case under 28 U.S.C.
1338(a), 1367(a).
3. In the alternative, this Court has subject matter jurisdiction over this case
under 28 U.S.C. 1332 because there is diversity among the parties.
a. Plaintiff FlowRider is a Canadian corporation with a principal place of
business at 6700 McMillan Way, Richmond, British Columbia, Canada,
V6W 1J7.
b. Plaintiff is informed and believes that Defendant Alleshouse is the Chief
Operating Officer of PSD and is a citizen of the State of California.
c. Plaintiff is informed and believes that Defendant Yeh is the Chief Executive
Officer of PSD and is a citizen of the State of California.
d. Plaintiff is informed and believes that Defendant PSD is a Delaware
corporation with a principal place of business at 3266 Via Bartolo, San
Diego, California 92111.
e. Defendant Does 1-10 are parties whose identities are not yet known to the
Plaintiff. To the extent their identities become known to the Plaintiff, the
Doe defendants will be named and their activities pleaded in an amended
complaint.

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f. The amount in controversy, without interests and costs, exceeds $75,000.
4. This Court has personal jurisdiction over Defendant Alleshouse based on the
following: (a) Defendant Alleshouse is present, doing business, and/or residing in this
District; and (b) Defendant Alleshouse has committed tortious acts that he knew or
should have known would cause injury to Plaintiff in the State of California.
5. This Court has personal jurisdiction over Defendant Yeh based on the
following: (a) Yeh is present, doing business, and/or residing in this District; and (b)
Yeh has committed tortious acts that he knew or should have known would cause injury
to Plaintiff in the State of California.
6. This Court has personal jurisdiction over Defendant PSD based upon the
following: (a) PSDs principal place of business is in this District; (b) PSD transacts
business in and maintains continuous and systematic contacts with this District and the
State of California; and (c) PSD has committed acts of patent infringement complained of
herein and/or contributed to or induced those acts of patent infringement by others in this
District and elsewhere in California and the United States.
7. This Court has personal jurisdiction over Defendants Does 1-10 based on the
following: (a) on information and belief Defendants Does 1-10 are present and/or doing
business in this District; and (b) Defendants Does 1-10 have committed tortious acts that
they knew or should have known would cause injury to Plaintiff in the State of
California.
8. Venue is proper in the United States District Court for the Southern District
of California under 28 U.S.C. 1391(b), 1400(b).
FACTUAL ALLEGATIONS
BACKGROUND OF ASSERTED PATENT
9. Plaintiff is the exclusive worldwide licensee of United States Patent No.
6,491,589 (the 589 Patent or Asserted Patent), entitled Mobile Water Ride Having
Sluice Slide-Over Cover and issued December 10, 2002 Exhibit 1.

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10. Although the invention set forth in the Asserted Patent is best described by
its claims, the patent is generally directed to a simulated wave water ride attraction
having one or more sluice slide-over covers for ensuring the safety of riders and lowering
the risk of injury or interference with ride operation.
11. On January 31, 2014, Plaintiff acquired a license to all rights in the Asserted
Patent from Wave Loch, Inc. (Wave Loch), together with the other intellectual
property rights for the underlying technology though the parties Contribution Agreement
(Agreement). Under the terms of the Agreement, Plaintiff is the exclusive worldwide
licensee of the Asserted Patent and has the right to enforce the intellectual property
rights, including bringing actions for past patent infringement and breach of contractual
agreements regarding the intellectual property.
12. Accordingly, Plaintiff has standing to sue for infringement of the Asserted
Patent.
13. Plaintiff developed a product, the FlowRider (Plaintiffs Product),
incorporating the intellectual property licensed in the Agreement. This product practices
the Asserted Patent.
14. Product sales sheets and photographs of Plaintiffs FlowRider product are
attached hereto as Exhibit 2.
DEFENDANT ALLESHOUSES EMPLOYMENT WITH WAVELOCH
15. Defendant Alleshouse was a field engineer, product manager, and
manufacturing engineering manager employed at Wave Loch.
16. On September 8, 2008, Wave Loch and Defendant Alleshouse executed a
Covenant Against Disclosure and Covenant Not to Compete (NDA). A true and
correct copy of Defendant Alleshouses NDA is attached hereto as Exhibit 3.
17. Plaintiff is the assignee of any and all rights Wave Loch possessed under the
NDA.
18. The NDA included several provisions relevant to this action. The NDA
provides:

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1. Confidentiality:
a. Covenant against Disclosure. Except as permitted by Company
[i.e., Wave Loch] in writing, or as otherwise required by law, while
Employee [i.e., Defendant Alleshouse] is performing services for Company,
and at all times thereafter, Employee shall not divulge, furnish or make
accessible to anyone or use in any way confidential, proprietary or secret
knowledge or information of Company that Employee has acquired or shall
acquire while performing services for Company, whether developed by
Employee or others, concerning (i) confidential, propriety or secret
inventions, compositions, methods of manufacture, discoveries, designs,
drawings, models, processes, formulas, plans, devices, or material directly or
indirectly useful in any aspect of Company business, including but not
limited to any information regarding sheet flow, stationary wave, moving
reef, boat wave, surf pool, wave pool and ride surface technologies, (ii)
customer lists, supplier lists or price lists (iii) computer programs or logical
flow diagrams (iv) strategic or other business memoranda, manuals or
forms, (v) marketing or sales plans, (vi) financial data or business models, or
(vii) information identified as secret or confidential which, from the
circumstances, in good faith and conscience Employee should realize should
be treated as confidential (collectively Confidential Information).
Employee acknowledges that the above described Confidential Information
constitutes a unique and valuable asset of Company and represents a
substantial investment of time and expense by Company, and that any
disclosure or other such use of such Confidential Information other than for
the sole benefit of Company is wrongful and would cause irreparable harm
to Company.
. . .
2. Developments and Improvements.
a. Assignment. In consideration of compensation paid by
Company, Employee agrees that all right, title and interest in all inventions,
improvements, developments, trade-secret, copyrightable or patentable
material that Employee conceives or hereafter may make or conceive,
whether solely or jointly with others:
(a) with the use of the Companys time, materials, or facilities;
or
(b) resulting from or suggested by Employees work for
Company; or
(c) in any way connected to any subject matter within the
existing or contemplated business of Company

Shall automatically be deemed to become the property of Company as soon

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as made or conceived, and Employee agrees to assign to Company, its
successors, assigns, . . . all of Employees rights and interest in said
inventions, improvements, and developments in all countries worldwide.
Employees obligation to assign the rights to such inventions shall survive
the discontinuance or termination of this Agreement for any reason.

3. Covenant not to Compete. Employee covenants and agrees that
Employee shall not use any Confidential Information to directly or indirectly
(whether as principal, agent, director of a company, or otherwise) carry on,
be engaged by, or take part in any commercial or business endeavor.
. . .
5. Prior Inventions. If, prior to the date of execution hereof, Employee
has made or conceived of any unpatented inventions, improvements, or
developments, whether patentable or unpatentable, which Employee desires
to have excluded from this Agreement, Employee has written below
Employees name (and on an attached page, if necessary) a complete list
thereof.
. . .
8. Injunctive Relief. Employee expressly acknowledges that, in the
event that the provisions of Paragraphs 1, 2 or 3 are breached, Company will
suffer damages incapable of ascertainment and will be irreparably damaged
if any provision of Paragraphs 1, 2 or 3 is not enforced. Therefore, should
any dispute arise with respect to the breach or threatened breach of any
provision of Paragraphs 1, 2 or 3, Employee agrees and consents that, in
addition to any and all other remedies available to Company, an injunction
or restraining order or other equitable relief may be issued or ordered by a
court of competent jurisdiction restraining any breach or threatened breach
of any such provisions.
9. Recovery of Costs. If any legal action or other proceeding . . . is
brought for enforcement of the [NDA], or because of an alleged dispute,
breach . . . in connection with any of the provisions of this Agreement, the
successful or prevailing party shall be entitled to recover reasonable
attorneys fees . . . .
19. Significantly, in the space provided in the NDA wherein Defendant
Alleshouse could, per NDA Paragraph 5, specify his prior inventions, he handwrote
NONE.
20. After signing the NDA, Defendant Alleshouse became part of the Wave
Loch team. As part of the team, Defendant Alleshouse had access to Wave Lochs trade

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secrets including its yet-to-be-marketed products, customer lists, marketing strategies,
business plans, supplier information, and the like.
21. As part of the Wave Loch team, Defendant Alleshouse was tasked with
researching water ride surface technologies, including developing membrane adhesion
methods and testing membrane materials for use in Wave Loch products. Defendant
Alleshouse continuously performed this research using Wave Lochs resources, funds,
and facilities.
22. Defendant Alleshouse never applied for any patents related to ride surface
technologies while employed at Wave Loch.
23. In or about early 2012, and continuing through approximately July 2012,
Defendant Alleshouse had numerous conversations with Wave Lochs Vice President of
Sales, Andrew Thatcher wherein he inquired about Wave Lochs proprietary sales,
marketing, and operational information. Defendant Alleshouse told Mr. Thatcher that he
was seeking an MBA degree and wanted to gain a better understanding of Wave Lochs
overall business to assist in his education and his work at Wave Loch.
24. Believing Defendant Alleshouses inquiries were for a legitimate purpose,
Mr. Thatcher disclosed significant information pertaining to Wave Lochs proprietary
sales, marketing, and operational information.
25. Defendant Alleshouses statements to Mr. Thatcher were false. On
information and belief based on the subsequent events, the true purpose of Defendant
Alleshouses questions was to extract proprietary information from Wave Loch so that he
could start a competing company, Defendant PSD. Had Mr. Thatcher known the true
reasons for Defendant Alleshouses statements, he would not have disclosed Wave
Lochs confidential and proprietary information.
26. On July 27, 2012, Alleshouse resigned his employment with Wave Loch.
27. On August 12, 2012, Wave Loch wrote Defendant Alleshouse to remind him
of his obligations under the NDA. A true and correct copy of Wave Lochs August 27,
2012 letter is attached hereto as Exhibit 4.

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DEFENDANTS ALLEHOUSE AND YEH FORM PSD TO ENGAGE IN UNFAIR
COMPETITION WITH WAVE LOCH
28. Defendant PSD is a company that directly competes with Plaintiff by
offering the same types of water attractions to Plaintiffs current and potential customers.
29. On information and belief, on August 10, 2012, just 14 days after resigning
from Wave Loch, Defendant Alleshouse incorporated Defendant PSD.
30. On information and belief, Defendant Yeh is Defendant Alleshouses
business partner in the formation and operation of Defendant PSD.
31. On information and belief, on September 11, 2012, Defendants Alleshouse
and Yeh registered Defendant PSD to do business in California; Defendant Yeh is listed
as Defendant PSDs agent for service of process with the California Secretary of State.
32. Upon leaving Wave Loch and founding PSD, Defendant Alleshouse applied
for patents covering ride surface technologies; the applications are currently pending, and
are not yet available for public viewing.
33. Defendant PSDs publicly-available website (http://pacificsurfdesigns.com/)
lists these patents as applying to its purported innovations related to ride surface
technologies. On information and belief, all of Defendants innovations are based on
the research Defendant Alleshouse conducted while employed at Wave Loch.
34. Plaintiff is informed and believes that Defendant Alleshouse used Wave
Lochs proprietary information including the Asserted Patent to create infringing
products for Defendants benefit.
35. Defendant PSDs website contains renderings of each of Defendant PSDs
products. Plaintiff is informed and believes that Defendants make, have made, import,
use, offer for sale and/or sell products that infringe one or more claims of the Asserted
Patent, including, but not limited to, The Off-the-Wall, The Makaha, The Waikiki,
and The Supertube (collectively, the Accused Products).
36. The webpage for PSDs product The Off-the-Wall
(http://pacificsurfdesigns.com/waves/offthewall/) is attached hereto as Exhibit 5.

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37. The webpage for PSDs product The Makaha
(http://pacificsurfdesigns.com/waves/the-makaha/) is attached hereto as Exhibit 6.
38. The webpage for PSDs product The Waikiki
(http://pacificsurfdesigns.com/waves/the-waikiki/) is attached hereto as Exhibit 7.
39. The webpage for PSDs product The Supertube
(http://pacificsurfdesigns.com/waves/the-supertube/) is attached hereto as Exhibit 8.
40. Plaintiff is informed and believes that Defendants have and continue to
infringe, contributorily infringe, and/or induce infringement of the Asserted Patent by
knowingly and actively (1) making, having made, importing, using, offering for sale
and/or selling products that infringe one or more claims of the Asserted Patent, including,
but not limited to the Accused Products, (2) inducing others to do the same, and (3)
contributing to the manufacture, import, use, sale, or offer for sale of products that
infringe one or more claims of the Asserted Patents.
41. The Accused Products infringe at least one or more claims of the Asserted
Patent.
42. While at Wave Loch, Defendant Alleshouse was also instructed to create a
design for an angular exit area for use in Wave Loch water rides called the Flow Curl.
Below is an image of the original design Defendant Alleshouse created while at Wave
Loch and which was saved on Wave Lochs internal computer system:

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43. Upon leaving Wave Loch and starting Defendant PSD, Defendant
Alleshouse, in violation of the NDA, used the design he created while at Wave Loch to
create a competing product, the Supertube for Defendant PSD. Defendant PSD
advertises the Supertube on their publicly available website:









44. During his tenure at Wave Loch, Defendant Alleshouse also became aware
that one of Wave Lochs customers, Customer 1, contracted with Wave Loch to
manufacture water rides for Customer 1s facilities. Moreover, Defendant Alleshouse
became aware that Wave Loch received significant quantities of repeat business from
Customer 1 for the continued maintenance of the Wave Loch water rides in Customer 1s
facilities.
45. Upon information and belief, using the confidential information regarding
Wave Loch manufacturing methods, products, and business strategiesincluding the
maintenance agreementswith Customer 1, Defendant Alleshouse approached Customer
1 and persuaded Customer 1 to use his newly-formed company, Defendant PSD, for
maintenance of certain of the Wave Loch water rides installed in Customer 1s facilities.

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46. As a direct result of Defendants actions, Plaintiff has been deprived of the
income resulting from the continued maintenance of Wave Loch water rides in Customer
1s facilities.
FIRST CLAIM FOR RELIEF
(Breach of Contract: Against Defendant Alleshouse)
47. Plaintiff incorporates the allegations in the preceding paragraphs as if fully
set forth herein.
48. On September 8, 2008, Wave Loch and Defendant Alleshouse entered the
NDA wherein Defendant Alleshouse agreed to refrain from disclosing, furnishing, or
making accessible to anyone or use in any way any confidential, proprietary, or secret
knowledge or information of Wave Loch that Defendant Alleshouse acquired while
working for Wave Loch.
49. Wave Loch performed all of its obligations under the NDA except for those
excused by Defendant Alleshouses conduct.
50. Wave Loch has assigned all rights and obligations under the NDA, Plaintiff
has the right to enforce the covenant against disclosure on behalf of Wave Loch.
51. On information and belief, Defendant Alleshouse breached the NDA by
gathering the confidential Wave Loch information identified throughout this complaint
including: (1) the model and engineering specifications for the double-barrel half pipe
product that Wave Loch created but has yet to bring to market; (2) Wave Lochs
customer and supplier lists; and (3) Wave Lochs sales and marketing information, plans,
business models, and strategies, and disclosing that information to Defendants and others.
52. As a result of the breach, and as agreed-upon in the NDA, Plaintiff has
suffered, and will continue to suffer irreparable harm.
53. As a result of Defendants breach, Plaintiff has also suffered monetary harm
in an amount to be proven at trial.
54. As a result of the harm suffered as alleged herein, Plaintiff is entitled to all

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of the remedies available under the laws of the State of California, including equitable
remedies and damages in an amount to be determined at trial.
SECOND CLAIM FOR RELIEF
(Conversion: Against Defendant Alleshouse)
55. Plaintiff incorporates the allegations in the preceding paragraphs as if fully
set forth herein.
56. Based on conduct wholly independent of the existence, knowledge,
misappropriation and usage of Plaintiffs trade secrets, Defendant Alleshouse removed
proprietary and confidential information belonging to Plaintiff , without authorization, or
in excess of his authorization, for his personal economic advantage and, upon
information and belief, to use for the benefit of a competitor, Defendant PSD, to compete
with Plaintiff unfairly.
57. As a proximate result of Defendant Alleshouses removal and retention of
proprietary and confidential information and property, Defendant Alleshouse has caused
Plaintiff to suffer damages in an amount to be proven at trial.
58. Each of the acts of conversion by Defendant Alleshouse was done willfully
and maliciously, with the deliberate intent to injure Plaintiffs business, thereby entitling
Plaintiff to exemplary damages and attorneys fees to be proven at trial.
THIRD CLAIM FOR RELIEF
(Fraud and Deceit Intentional Misrepresentation:
Against Defendant Alleshouse)
59. Plaintiffs re-allege and incorporate the allegations in the preceding
paragraphs as if fully set forth herein.
60. Defendant Alleshouse made a representation as to a material fact, namely,
that he was inquiring about Wave Loch confidential and proprietary information to gain a
better understanding of Wave Lochs business to help him obtain his master of business
administration degree.

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61. This representation was false;
62. Defendant Alleshouse knew that the representation was false when made;
and made the representation with an intent to defraud the Plaintiff, for the purpose of
inducing the Plaintiff to rely upon it and to act on it by providing Plaintiff's confidential
and proprietary business information to Defendant Alleshouse.
63. Plaintiff was unaware of the falsity of the representation; and acted in
reliance upon the truth of the representation and was justified in relying upon the
representation.
64. As a result of the reliance upon the truth of the representation, Plaintiff
sustained damage in an amount to be proven at trial.
FOURTH CLAIM FOR RELIEF
(Tortious Interference With Economic Relationship And Prospective Economic
Advantage: Against All Defendants)
65. Plaintiffs re-allege and incorporate the allegations in the preceding
paragraphs as if fully set forth herein.
66. Plaintiffs relationship with its customers is advantageous to Plaintiff. There
exists a probability of future economic benefit to Plaintiff from its business relationship
with its customers, including Customer 1.
67. Plaintiff is informed and believes and on that basis alleges that using the
confidential information Defendant Alleshouse obtained during his employment with
Wave Loch, Defendants intentionally interfered with Plaintiffs business relationship that
existed between Plaintiff and at least one of its customers.
68. Defendants' intentional wrongful conduct, including Defendant Alleshouses
breach of the NDA was intended to, and did, disrupt the economic relationships between
Plaintiff and at least one of its customers.
69. As a direct and proximate result of Defendants' conduct, Plaintiff has
suffered damages in an amount to be determined at trial.

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70. In doing the acts herein alleged, Defendants acted with oppression, fraud,
malice, and in conscious disregard Plaintiffs rights, and Plaintiff is therefore entitled to
punitive damages according to proof at the time of trial.
FIFTH CLAIM FOR RELIEF
(Infringement of the 589 Patent: Against All Defendants)
71. Plaintiff incorporates the allegations in the preceding paragraphs as if fully
set forth herein.
72. Plaintiff holds an exclusive worldwide license to the 589 Patent. Plaintiff
therefore has standing to sue for infringement of the 589 Patent.
73. Upon information and belief, Defendants have infringed and continue to
infringe the 589 Patent by knowingly and actively making, having made, importing,
using, offering to sell, or selling products that infringe one or more claims of the 589
Patent, including, but not limited to, the Accused Products or components thereof that
incorporate, without license, the inventions developed by Wave Loch and protected by
one or more claims in the 589 Patent, or by knowingly and actively inducing or
contributing to the infringement of the 589 Patent by others.
74. Plaintiff has complied with 35 U.S.C. 287.
75. As a direct and proximate result of Defendants infringement, Plaintiff has
suffered, and will continue to suffer, injury.
SIXTH CLAIM FOR RELIEF
(Unfair Competition Under Cal. Bus. & Prof. Code 17200, et seq.:
Against All Defendants)
76. Plaintiff incorporates the allegations in the preceding paragraphs as if fully
set forth herein.
77. Defendants business practices as alleged above in the First and Second
Claims for relief violate Californias Unfair Competition Law (UCL), Business &
Professions Code 17200 et seq., which prohibits any unlawful business act or

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practice. Defendants engaged in unlawful business acts and practices by violating
Plaintiffs patents and encouraging others to do so, breaching the covenant not to
compete contained in the NDA, and breaching the covenant against disclosure contained
in the NDA.
78. As a result of the breach, and as agreed-upon in the NDA, Plaintiff has
suffered, and will continue to suffer irreparable harm.
79. As a result of Defendants breach, Plaintiff has also suffered monetary harm
in an amount to be proven at trial.
80. As a result of the harm suffered as alleged herein, Plaintiff is entitled to all
of the remedies available under the laws of the State of California, including equitable
remedies and damages in an amount to be determined at trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays that the Court grant the following
relief:
A. For judgment that Defendants have infringed the Asserted Patent;
B. For judgment that Defendants willfully infringed the Asserted Patent;
C. An award of damages adequate to compensate Plaintiff for patent
infringement, as well as prejudgment interest from the date the infringement began, but
in no event less than a reasonable royalty as permitted by 35 U.S.C. 285;
D. A finding that, to the extent the Defendants knew of their infringing
activities, the Defendants infringement was willful;
E. An award of treble damages for the period of any willful infringement
pursuant to 35 U.S.C. 284;
F. A finding that this case is exceptional and an award of interest, costs and
attorneys fees incurred by Plaintiff in prosecuting this action as provided by 35 U.S.C.
285; and
G. A preliminary and permanent injunction prohibiting the Defendants, their
respective officers, agents, servants, employees and/or all persons acting in concert or

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participation with them, or any of them, from engaging in further infringement and/or
acts of infringement and inducement of the Asserted Patents;
H. A finding that Defendant Alleshouse has breached a valid and enforceable
covenant not to compete;
I. For general and consequential damages as a result of Defendants tortious
actions;
J. For an award of pre-judgment and post-judgment interest as provided by
law;
K. For the imposition of a constructive trust on all profits and/or monies
Defendants wrongfully obtained;
L. Attorneys fees and costs of the suit as provided under the NDA; and
M. For such other and further relief as this Court or a jury may deem just and
proper.
JURY DEMAND
Plaintiff demands a trial by jury on all issues triable by jury.

DATED: May 1, 2014 GREENBERG TRAURIG, LLP
By /s/ J. Rick Tach
J. Rick Tach (CA Bar No. 195100)
Michael A. Piazza (CA Bar No. 235881)
Roger L. Scott (CA Bar No. 247165)
Shaun A. Hoting (CA Bar No. 260656)
Jenny S. Kim (CA Bar No. 282562)

Attorneys for Plaintiff,
FlowRider Surf, Ltd.

OC 287242204v15

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