RimBlades v. Amazon - Com - Complaint

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 1 of 11
PageID #: 1
Brian Cummings (10146)

CUMMINGS MANOOKIAN PLC
1003 Bishop St., #2700
Honolulu, HI 96813
Tel: (615) 266.3333
Fax: (615) 266.0250
Email: bcummings@cummingsmanookian.com
Attorney for Plaintiff RimBladesUSA, LLC
IN THE UNITED STATES DISTRICT COURT

IN AND FOR THE DISTRICT OF HAWAII
RIMBLADESUSA, LLC,
a Hawaii domestic limited liability company,
COMPLAINT
Plaintiff,
vs.
Case No. 16-463
AMAZON.COM, INC.,
a Delaware corporation,
Defendant.
Plaintiff RimBladesUSA, LLC, by and through its undersigned attorney, brings this
complaint (the Complaint) against Defendant Amazon.com, Inc.
PRELIMINARY STATEMENT
1.
RimBladesUSA, LLC brings this action under U.S. patent laws 35 U.S.C. 1 et seq.,
including 35 U.S.C. 271, under the Lanham Trademark Act, 15 U.S.C. 1125 and 1501
et seq., and under various Hawaii state laws and common law provisions.
PARTIES, JURISDICTION, & VENUE
2.
Plaintiff RimBladesUSA, LLC (RimBlades or Plaintiff) is a domestic limited liability

company lawfully registered and existing under the laws the State of Hawaii. RimBlades
conducts business in Hawaii and its principal office is located at 61-278 Kamehameha
Highway, Unit #3, Haleiwa, Hawaii 96712.
PageID #: 2
3.
Defendant Amazon.com, Inc. (Amazon or Defendant) is a corporation organized and

existing under the laws of the State of Delaware with its principal place of business located
in Seattle, Washington.
4.
This Court has subject matter jurisdiction over RimBlades federal claims asserted herein
pursuant to 28 U.S.C. 1331 and 1338.
5.
This Court has supplemental jurisdiction over RimBlades state law claims pursuant to 28
U.S.C. 1367(a).
6.
This Court may exercise personal jurisdiction over Amazon because Amazon has
purposefully directed its business activities toward the State of Hawaii.
7.
Amazons contacts with Hawaii are substantial, continuous, and systematic, and this action
is based on activities that arise out of or are related to those contacts. (Additional allegations
relevant to personal jurisdiction are set forth in the general allegations that follow).
8.
This action properly lies in the District of Hawaii, pursuant to 28 U.S.C. 1391(b) because
claims asserted herein arose in this judicial district.
9.
Accordingly, venue is proper pursuant to 28 U.S.C. 1391.

GENERAL ALLEGATIONS
RimBlades Products and Intellectual Property

10.
RimBlades is in the business of inventing, developing, manufacturing, distributing, and

selling various automobile accessories.
11.
RimBlades is the owner of one design patent designated as United States Design Patent
No. US D747,257 S. A copy of the RimBlades Design Patent is attached hereto as Exhibit
A. The RimBlades Patent claims the design of a wheel rim trim.
12.
RimBlades is the owner of one utility patent designated as United States Patent No. US
7,296,860 B2. This utility patent is also being infringed per the facts, averments, and
theories included herein in this Complaint. A copy of the RimBlades Utility Patent is
attached hereto as Exhibit B. The RimBlades Utility Patent claims the patent of a rim
protector.
13.
RimBlades manufactures, markets, and sells automobile accessory products throughout the
United States, including alloy wheel protectors that are sold under the Scuffs and
Trims4Rims mark (the RimBlades Products).
14.
Through the extensive sale, marketing, and distribution of the RimBlades Products, the
design and trade dress of the RimBlades Products has become distinctive and consumers
associate the design and trade dress with RimBlades.
2
PageID #: 3
Amazon.com
15.
Amazon is one of the worlds largest online retailers of a wide range of products, including
automobile accessories. Amazon owns, operates, maintains and controls the website
www.amazon.com.
16.
Through its website, (www.amazon.com), Amazon sells products directly to customers all
over the United States (including Hawaii) and throughout the word.
17.
Amazon also facilitates, encourages, participates in, and permits sales between third-party
sellers and customers. Third-party sellers use Amazon to list, market, sell, and distribute
their products. Amazon processes payments made by customers and provides the
technology and infrastructure to complete the sales between third parties and their
customers.
18.
Additionally, Amazon operates a fulfillment service and network (the fulfillment

service) whereby third-party sellers send their products to Amazon fulfillment centers
across the United States. Upon completing a sale on Amazon.com, Amazon ships the
products for the sellers and provides customer service on behalf of the sellers.
Amazons Misconduct
19.
Upon information and belief, Amazon markets, sells, offers for sale, fulfills sales,
distributes, and/or imports into the United States automobile accessories (the Infringing
Products) that infringe on the RimBlades Design Patent and on the RimBlades Utility
Patent (the RimBlades Patents).
20.
Upon information and belief, Amazons continued marketing, sales, offers for sale,
fulfillments of sales, distributions, and/or imports of the Infringing Products has injured, is
injuring, and will continue to cause irreparable injury to RimBlades.
21.
Domestic and international third-party sellers (particularly sellers based in China) use
Amazons fulfillment service to sell products that infringe on RimBlades patents,
trademark, and other intellectual property rights pertaining to the RimBlades products.
22.
Amazons fulfillment service provides the technology, infrastructure, and logistics to

enable the sale and shipment of products that infringe on RimBlades patents, trade dress,
and common law rights.
23.
Upon information and belief, Infringing Products have been sold on amazon.com (or
through Amazons fulfillment service) to many customers in Hawaii.
24.
Amazon has marketed the Infringing Products to Hawaii customers, offered to sell the
Infringing Products to Hawaii customers, processed payments from Hawaii customers,
completed sales of the Infringing Products to Hawaii customers, and shipped and/or
distributed infringing products to Hawaii customers.
3
PageID #: 4
25.
Because there are so many sellers on Amazon.com who sell and (offer to sell) infringing
products, it is difficult for RimBlades to maintain an accurate and comprehensive list of all
of Amazons infringing product listings. The list of infringing product listings will continue
to change as new sellers emerge. To the best of RimBlades knowledge, information, and
belief, the infringing product listings include, but are not limited to, the listings on Exhibit
C.
26.
Additionally, upon information and belief, Amazon acted in an objectively reckless manner
with respect to RimBlades patent rights. Amazon has been made aware of the infringing
product listings yet has taken no action whatsoever to remove those listings.
27.
On information and belief, Amazon has used, marketed, sold, offered for sale, participated
in and substantially contributed to sales, and/or imported into the United States the
Infringing Products knowing that it was highly likely that their acts would constitute
infringement of a valid patent.
28.
Consequently, Amazon has engaged in willful infringement of the RimBlades Patents

which is actionable pursuant to 35 U.S.C. 271 and RimBlades is therefore entitled to treble
damages, attorneys fees, court costs, and prejudgment interest pursuant to 35 U.S.C.
284 and 285.
29.
Amazon has used, marketed, sold, offered for sale, participated in and substantially
contributed to sales, and/or imported into the United States the Infringing Products which
copy the trade dress of RimBlades Products.
30.
Through its website and its fulfillment service, Amazon is in direct competition with
RimBlades and the Infringing Products are substantially identical to RimBlades Products.
31.
Infringing Products sold on amazon.com and through Amazons fulfillment service are
marketed through identical channels of trade as those channels used by RimBlades.
32.
Infringing Products sold on amazon.com and through Amazons fulfillment service are
marketed to identical customers that RimBlades markets to.
33.
Amazon has used, marketed, sold, offered for sale, participated in and substantially
contributed to sales, and/or imported into the United States product designs that are
confusingly similar to the RimBlades Products.
34.
The infringing product designs are likely to cause confusion or mistake as to the affiliation,
connection, or association of the Infringing Products to their true manufacturer.
35.
The infringing product designs are likely to cause confusion or mistake as to the affiliation,
connection, or association of RimBlades Products with RimBlades.
36.
Upon information and belief, Amazon has purposefully marketed, sold, offered for sale,
distributed, and/or imported counterfeit copies of RimBlades Products.
4
PageID #: 5
37.
Upon information and belief, and Amazon has purposefully marketed, sold, offered for
sale, distributed, and/or imported products that infringe on RimBlades trade dress.
38.
Upon information and belief, Amazon has unlawfully benefited from RimBlades goodwill
in the marketplace by marking, selling, offering for sale, distributing, and/or importing
counterfeit copies of RimBlades Products.
39.
RimBlades has been and continues to be significantly damaged by Amazons actions. So

long as Amazon continues to perform the unlawful and improper actions described in this
Complaint, RimBlades will continue to suffer irreparable harm that will not be fully
compensable by money damages.
40.
On October 28, 2015 and again on November 2, 2105, RimBlades counsel sent a notice
of patent and trademark infringement to Amazon, and demanded that Amazon remove all
infringing products from amazon.com. RimBlades October 28, 2015 notice is attached
hereto as Exhibit D. RimBlades November 2, 2015 notice is attached hereto as Exhibit E.
FIRST CAUSE OF ACTION

PATENT INFRINGEMENT OF THE RIMBLADES PATENTS UNDER 35 U.S.C. 271
41.
The preceding allegations are incorporated herein by reference.
42.
RimBlades owns the RimBlades Patents.
43.
Amazon uses, markets, sells, offers for sale, participates in, substantially contributes to
sales, and/or imports into the United States automobile accessories that directly infringe on
the RimBlades Patents.
44.
RimBlades has not granted Amazon (or any third-party sellers on amazon.com) permission,
license, or authorization to use the designs in the RimBlades Design Patent, nor has it
granted Amazon or (or any third-party sellers on amazon.com) permission, license, or
authorization to use the RimBlades Utility Patent in the manner described herein.
45.
Upon information and belief, Amazons infringing activities in violation of 35 U.S.C. 1

et seq., including 35 U.S.C. 271, have damaged RimBlades in an amount to be proven at
trial. Among other remedies, RimBlades is entitled to its lost profits, or in the alternative,
a reasonable royalty to adequately compensate RimBlades for Amazons infringing
activities under 35 U.S.C. 284.
46.
Further, the harm to RimBlades arising from Amazons unlawful acts is not adequately or
fully compensable by money damages. RimBlades has suffered and continues to suffer
irreparable harm and RimBlades has no adequate remedy at law. RimBlades will continue
to suffer this Harm until Amazons infringing conduct is preliminarily and permanently
enjoined.
PageID #: 6
47.
On information and belief, Amazon acted in an objectively reckless manner with regard to
RimBlades patent rights.
48.
Upon information and belief, Amazon used, marketed, sold, offered for sale, participated
in and substantially contributed to sales, and/or imported into the United States the
Infringing Products knowing that it was highly likely that its actions would constitute
infringement of a valid patent.
49.
Amazon knew or reasonably should have known that its actions were highly likely to result
in the infringement of a valid patent.
50.
Amazon has engaged in willful infringement of the RimBlades Patents, and RimBlades is
therefore entitled to treble damages, attorneys fees, costs incurred in this action, and
prejudgment interest pursuant to 35 U.S.C. 284 and 285.
SECOND CAUSE OF ACTION
CONTRIBUTORY PATENT INFRINGEMENT, 35 U.S.C. 271(C)
51.
The preceding paragraphs are incorporated herein by reference.
52.
Through its website and its fulfillment service, Amazon sells, offers to sell, and/or imports
the Infringing Products.
53.
Amazon permits, assists, and encourages third-parties to post the Infringing Products for
sale on amazon.com.
54.
Amazon permits, assists, and encourages the sale of Infringing Products on amazon.com
and through its fulfillment service.
55.
Amazon has been made aware of multiple infringing product listings. (See Exhibits D and
E).
56.
Amazon has nevertheless taken no action to prevent the marketing, sale, offer for sale,
and/or importation of the Infringing Products.
57.
The Infringing Products are not a staple or article suitable for any substantial noninfringing
use.
THIRD CAUSE OF ACTION

TRADE DRESS INFRINGEMENT AND UNFAIR COMPETITION, 15 U.S.C. 1125(A)
AND COMMON LAW
58.
PageID #: 7
59.
The trade dress design features associated with the RimBlades Products are indicative of
RimBlades and its automobile accessories, are inherently distinctive, and have acquired
secondary meaning with the consuming public.
60.
The Infringing Products use design features that are likely to cause confusion or mistake,
or to deceive as to the affiliation, connection, association, origin, sponsorship, or approval
of their goods and commercial activities in light of RimBlades trade dress.
61.
By engaging in the activities set forth herein, Amazon has infringed RimBlades trade dress
and is liable for unfair competition under 15 U.S.C. 1125(a)(1)(A) and under the common
law.
62.
RimBlades has suffered actual damages as a result of Amazons trade dress infringement
and unfair competition in an amount to be proven at trial.
63.
Additionally, the harm to RimBlades arising from Amazons acts is not fully compensable
by money damages. RimBlades has suffered and continues to suffer irreparable harm.
RimBlades has no adequate remedy at law and the harm to RimBlades will continue until
Amazons conduct is preliminarily and permanently enjoined.
64.
Amazons continued use, marketing, sale, and offers for sale of RimBlades trade dress is
willful and intentional. As a result, RimBlades is also entitled to treble damages, attorneys
fees, and costs.
FOURTH CAUSE OF ACTION
CONTRIBUTORY TRADE DRESS INFRINGEMENT
65.
66.
On its website and through it fulfillment service, Amazon continues to provide the
technology, infrastructure, and logistics to enable the sale and shipment of products that
infringe on RimBlades patents, trade dress, and common law rights.
67.
Amazon owns, operates, controls, and maintains its website and its fulfillment service.
68.
Amazon has complete control over product listings on its website and has complete control
over its fulfillment centers.
69.
Despite being alerted to infringing product listings on its website (see Exhibits C and D),
Amazon knowingly continues to facilitate, encourage, permit and assist third parties to sell
products that infringe on RimBlades trade dress.
70.
RimBlades has suffered actual damages as a result of Amazons contributory trade dress
infringement in an amount to be proven at trial.
71.
PageID #: 8
RimBlades has no adequate remedy at law and the harm to RimBlades will continue unless
FIFTH CAUSE OF ACTION
VICARIOUS TRADE DRESS INFRINGEMENT
72.
73.
Amazon, the third parties that sell infringing products on amazon.com, and the third parties
that sell infringing products through Amazons fulfillment service all have authority to bind
one another in transactions with customers.
74.
Amazon and these third-party sellers exercise joint ownership or control over the
marketing, sale, offers for sale, and/or distribution of products that infringe on RimBlades
trade dress.
75.
Amazon knowingly facilitates, encourages, permits and assists the third-party sellers to
enable the sale and delivery of products that infringe on RimBlades trade dress.
76.
Amazon has the authority and ability to remove infringing product listings from its website
but has failed to do so, despite RimBlades requests.
77.
Amazon has the authority and ability to stop the fulfillment of sales of the Infringing
Products, but has failed to do so, despite RimBlades requests.
78.
RimBlades has suffered actual damages as a result of Amazons vicarious trade dress
infringement in an amount to be proven at trial.
79.
RimBlades has no adequate remedy at law and the harm to RimBlades will continue until
SIXTH CAUSE OF ACTION
COUNTERFEITING, 15 U.S.C. 1117
80.
81.
On its website and through its fulfillment service, Amazon markets, sells, offers for sale,
distributes, and/or imports counterfeit copies of RimBlades Products.
PageID #: 9
82.
The counterfeit copies sold, offered for sale, distributed, and/or imported by Amazon are
counterfeit products pursuant to 15 U.S.C. 1117.
83.
RimBlades has been and continues to be irreparably harmed by Amazons unlawful

counterfeiting.
84.
RimBlades should be awarded damages in amount to be determined at trial.
85.
Amazons counterfeiting was done willfully. RimBlades is therefore entitled to treble

damages, statutory damages, attorneys fees, and court costs.
SEVENTH CAUSE OF ACTION
UNFAIR COMPETITION, HAWAII REV. STAT. 480-2 (2013) AND/OR HAWAII
COMMON LAW
86.
87.
RimBlades owns the RimBlades Patents.
88.
Amazon has engaged in unfair competition by infringing on the RimBlades Patents.
89.
Amazon uses, markets, sells, offers for sale, and/or imports into the United States
automobile accessories that infringe the RimBlades Patents.
90.
Amazon has also engaged in unfair methods of competition by infringing RimBlades trade
dress.
91.
RimBlades has been injured by Amazons unfair competition. Customers are buying the
Infringing Products on amazon.com and through Amazons fulfillment service.
92.
By engaging in the actions described herein, Amazon has engaged in unfair competition
under Hawaii Rev. Stat. 480-2 (2013), including via a capacity to mislead, and/or
Hawaii Common Law.
93.
RimBlades has suffered actual damages as a result of Amazons unfair practices in an

amount to be proven at trial. In addition, and pursuant to Hawaii Rev. Stat. 480-2 (2013),
RimBlades seeks and is entitled to an award of treble damages.
94.
The harm to RimBlades caused by Amazons conduct is not adequately or fully

compensable by money damages. RimBlades has suffered and continues to suffer
irreparable harm and has no adequate remedy at law. The harm to RimBlades will continue
unless Amazons unfair and unlawful conduct is preliminarily and permanently enjoined.
95.
RimBlades should also be awarded its attorneys fees and court costs.
PageID #: 10
CONCLUSION & REQUEST FOR RELIEF

WHEREFORE, based on the foregoing, Plaintiff RimBladesUSA, LLC respectfully
requests a judgment from the Court as follows:
(1)
Amazon has directly and willfully infringed the RimBlades Patents;
(2)
Amazon is liable for contributory infringement of the RimBlades Patents;
(3)
Amazon has engaged in direct, contributory, and vicarious trade dress infringement;
(4)
Amazon has engaged in the willful counterfeiting of RimBlades products;
(5)
Amazon has engaged in unfair competition pursuant to Hawaii Rev. Stat. 480-2 (2013)
and/or Hawaii common law;
(6)
Preliminary and permanent injunctive relief enjoining Amazon, its officers, directors,
principals, agents, employees, successors and assigns, and all others aiding, abetting, or
acting in concert or active participation therewith, from directly or indirectly infringing
RimBlades patents and trade dress, including without limitation, injunctive relief
precluding Amazon from marketing, selling, offering for sale, or importing products that
infringe RimBlades patents and trade dress;
(7)
A judgment against Amazon for RimBlades actual damages in an amount to be proven at

trial;
(8)
A judgment awarding RimBlades treble damages to be determined at trial;
(9)
A judgment awarding RimBlades its attorneys fees and court costs;
(10)
A judgment awarding RimBlades prejudgment and post-judgment interest, as applicable,

at the highest lawful rate; and
(11)
A judgment awarding RimBlades such other and further relief, at law or equity, to which
RimBlades may be justly entitled.
Respectfully submitted on this the 18th day of August, 2016.
10

PageID #: 11
/s/ Brian Cummings

Brian Cummings
Brian Cummings (10146)
1003 Bishop St., #2700
Honolulu, HI 96813
Tel: (615) 266.3333
Fax: (615) 266.0250
Email: bcummings@cummingsmanookian.com
11

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 1 of 8
PageID #: 12
PageID #: 13
PageID #: 14
PageID #: 15
PageID #: 16
PageID #: 17
PageID #: 18
PageID #: 19
PageID #: 20
PageID #: 21
PageID #: 22
PageID #: 23
PageID #: 24
PageID #: 25
PageID #: 26
PageID #: 27
PageID #: 28
PageID #: 29
PageID #: 30
PageID #: 31
ase 1:16-cv-00463 Document 1-3 Filed 08/19/16 Page 1 of 4
ASIN- B0117WVHKG
ASIN- B0117WVBU2
PageID #: 3
PageID #: 3
ASIN- B01FA2WB72

ASIN- B01ARL4GFQ
PageID #: 3
ASIN- B01GD4F9L6

ASIN- B00U2SQ2D4
PageID #: 3
ASIN- B01FP0KT50
Kenton Fedde, PhD, JD
PageID #: 36
18325 Allenton Woods Ct

Wildwood, Missouri 63069
KFedde@ FeddeLaw.com
Attorney at Law
Admitted in Missouri and the USPTO
NOTICE OF CLAIMED COPYRIGHT INFRINGEMENT

DMCA TAKEDOWN NOTICE
FROM:
Kenton Fedde, J.D., Ph.D., Esq.
Attorney at Law (MO, USPTO)
The Fedde Law Firm
Wildwood, MO
Mo Bar #53344
kfedde@feddelaw.com
314.378.8390 (voice)
314.667.3332 (fax)
ATTORNEY FOR COPYRIGHT OWNERS:
Adam Dangleman
RimBladesUSA LLC
61-278 Kamehameha Hwy #3
Haleiwa HI 96712
adam@rimbladesusa.com
Darren Bowden
Managing Director
Rimblades LTD
Taunton, United Kingdom, TA1 1UB
darren@rimblades.com
Date: 28 October 2015

TO:
Amazon Abuse Center
Amazon Web Services
Internet Service Provider
abuse@amazonaws.com
ec2-abuse@amazon.com
314-378-8390 (phone)
314-667-83332 (fax)
PageID #: 37
28 October 2015; Page 2 of 12

Dear Sirs:
My clients are the owners of certain copyrighted images (see as PLATE 1
below) which depict products sold under their proprietary trademark name
RIMBLADES. As set forth in Table 1, each of these images can be found
on Amazon web sites established by my clients. For your convenience, the
URLs are functional links.
Websites that your company hosts contain images that are infringing on at
least one of these copyrights owned by my clients and infringing on their
trademark. These webpages of third parties are set forth in Table II. We
ask that you remove or disable access to these URLs.
Additionally, the products being sold on these websites are covered by at
least claim 1 of a valid U.S. patent (US 7,296,860) and two pending US
design patents.
In accordance with takedown notice provision of the Digital Millennium
Copyright Act, by signing below, I attest, on behalf of my clients that the
foregoing information is accurate and that I believe in good faith that use of
the referenced material in the manner complained of is not authorized by the
copyright owner, its agent, or the law.
I further attest under penalty of perjury that I am authorized to act on the
copyright owner's behalf.
If I may in any way assist your investigation, please do not hesitate to call
or write me directly. The courtesy of receipt confirmation is respectfully
requested.
Sincerely,
Kenton Fedde, Ph.D., J.D.

Attorney at Law
CC:
Adam Dangleman by e-mail adam@rimbladesusa.com

Darren Bowden by e-mail darren@rimblades.com
PageID #: 38
Table 1 Client Web Sites containing Proprietary Images
B00JY8H0WK
http://www.amazon.com/dp/B00JY8H0WK?m=A2N
WH6KRS75TOH&ref_=v_sp_widget_detail_page
RimBlades
USA.
B00JY8TKO6
http://www.amazon.com/dp/B00JY8TKO6?m=A2NW
H6KRS75TOH&ref_=v_sp_widget_detail_page
RimBlades
USA.
B00JY97K7Y
http://www.amazon.com/dp/B00JY97K7Y?m=A2NW
RimBlades
USA.
B00JY91FI4
http://www.amazon.com/dp/B00JY91FI4?m=A2NWH
6KRS75TOH&ref_=v_sp_widget_detail_page
RimBlades
USA.
B00JY94Y3C
http://www.amazon.com/dp/B00JY94Y3C?m=A2NW
RimBlades
USA.
B00JY8RX6S
http://www.amazon.com/Rimblades-Red-ProtectorRubberMoulding/dp/B00JY8RX6S/ref=lp_9219688011_1_1
?srs=9219688011&ie=UTF8&qid=1445486417&sr=8
-1
RimBlades
USA.
B00JY8RX6S
http://www.amazon.com/dp/B00JY8RX6S?m=A2NW
RimBlades
USA.
B00L45J7XG
http://www.amazon.com/dp/B00L45J7XG?m=A2NW
RimBlades
USA.
B00JY99I7O
http://www.amazon.com/dp/B00JY99I7O?m=A2NW
RimBlades
USA.
B00JY8V4XG
http://www.amazon.com/Rimblades-Blue-ProtectorRubberMoulding/dp/B00JY8V4XG/ref=aag_m_pw_dp?ie=U
TF8&m=A2NWH6KRS75TOH
PageID #: 39

Table 2. Third Party Web site containing infringing images.
ASIN
B00W97BE70
B00JY8RX6S
B00JY8RX6S
B00JY99I7O
B00JY8V4XG
B00JY8WDN6
B00JY8TKO6
B00JY8TKO6
B00JY91FI4
B00JY8RX6S
Amazon Website
http://www.amazon.com/gp/product/B00W97BE7
0/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=AZAPWOP3U4U52
http://www.amazon.com/gp/product/B00JY8RX6
S?psc=1&redirect=true&ref_=ox_sc_act_title_2&
smid=A261JEZXVVD8S
http://www.amazon.com/Rimblades-RedProtector-RubberMoulding/dp/B00JY8RX6S/ref=sr_1_1?m=A261J
EZXVVD8S&s=merchantitems&ie=UTF8&qid=1445571478&sr=11&keywords=kabis
http://www.amazon.com/Rimblades-YellowProtector-RubberMoulding/dp/B00JY99I7O/ref=sr_1_2?m=A261J
EZXVVD8S&s=merchantitems&ie=UTF8&qid=1445571478&sr=12&keywords=kabis
http://www.amazon.com/gp/product/B00JY8V4X
G/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&
smid=A3NN4M02ONBDU7
http://www.amazon.com/gp/product/B00JY8WD
N6/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1
&smid=A3NN4M02ONBDU7
http://www.amazon.com/gp/product/B00JY8TKO
6?psc=1&redirect=true&ref_=ox_sc_act_title_1&
smid=A3NN4M02ONBDU7
6?psc=1&redirect=true&ref_=ox_sc_imb_mini_d
etail&smid=A3KE0O4W1D9P09
http://www.amazon.com/Rimblades-PinkProtector-RubberMoulding/dp/B00JY91FI4/ref=sr_1_1?ie=UTF8&
qid=1445488437&sr=81&keywords=B00JY91FI4
smid=A1O54JL4S1M6ZV
Sold By
Benefit4u.
BIZBUY
INTERNATIONAL.
BIZBUY
INTERNATIONAL.
BIZBUY
INTERNATIONAL.
BLINQ.
BLINQ.
BLINQ.
FBA warehouse
FBA warehouse
FBA warehouse
PageID #: 40
B00JY99I7O
B00JY8H0WK
B00JY8V4XG
B00JY8WDN6
B00JY8TKO6
B00JY97K7Y
B00JY91FI4
B00JY94Y3C
B00JY8RX6S
B00JY99I7O
B00JY8H0WK
B00JY8V4XG
http://www.amazon.com/Rimblades-YellowProtector-RubberMoulding/dp/B00JY99I7O/ref=lp_9219688011_1
_7?srs=9219688011&ie=UTF8&qid=144548641
7&sr=8-7
http://www.amazon.com/gp/product/B00JY8H0W
K/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=A1VNZ64RONCC4W
smid=A1VNZ64RONCC4W
http://www.amazon.com/gp/product/B00JY8WD
N6/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1
&smid=A1VNZ64RONCC4W
6?keywords=B00JY8TKO6&qid=1445489557&re
f_=sr_1_1&sr=8-1
http://www.amazon.com/Rimblades-OrangeProtector-RubberMoulding/dp/B00JY97K7Y/ref=lp_9219688011_1
_9?srs=9219688011&ie=UTF8&qid=144548641
7&sr=8-9
http://www.amazon.com/gp/product/B00JY91FI4/
ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&sm
id=A1VNZ64RONCC4W
http://www.amazon.com/Rimblades-PurpleProtector-RubberMoulding/dp/B00JY94Y3C/ref=lp_9219688011_1
_6?srs=9219688011&ie=UTF8&qid=144548641
7&sr=8-6
smid=A1VNZ64RONCC4W
http://www.amazon.com/gp/product/B00JY99I7O
/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=A1VNZ64RONCC4W
http://www.amazon.com/Rimblades-BlackProtector-RubberMoulding/dp/B00JY8H0WK/ref=sr_1_3?ie=UTF8
&qid=1445498322&sr=83&keywords=kabis+and+rimblades
smid=A3TWCQLN5VJN1X
FBA warehouse
gotoshop
gotoshop
gotoshop
gotoshop
gotoshop
gotoshop
gotoshop
gotoshop
gotoshop
JJHOBBYMALL
JJHOBBYMALL
PageID #: 41
B00JY8WDN6
B00JY97K7Y
B00JY94Y3C
B00L45J7XG
B00JY99I7O
http://www.amazon.com/Rimblades-GreenProtector-RubberMoulding/dp/B00JY8WDN6/ref=sr_1_3?ie=UTF8
&qid=1445490255&sr=83&keywords=Blinq+rimblades
http://www.amazon.com/gp/product/B00JY97K7
Y?me=&qid=1445487887&redirect=true&ref_=ol
p_product_details&sr=8-1
http://www.amazon.com/gp/product/B00JY94Y3
C/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&
smid=A3TWCQLN5VJN1X
http://www.amazon.com/Rimblades-WhiteProtector-RubberMoulding/dp/B00L45J7XG/ref=sr_1_9?ie=UTF8
&qid=1445498322&sr=89&keywords=kabis+and+rimblades
/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=A3TWCQLN5VJN1X
JJHOBBYMALL
JJHOBBYMALL
JJHOBBYMALL
JJHOBBYMALL
JJHOBBYMALL
B00JY8H0WK
K?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY8V4XG
G?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY8TKO6
6?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY97K7Y
http://www.amazon.com/gp/product/B00JY97K7
Y?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY91FI4
http://www.amazon.com/gp/product/B00JY91FI4
?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY94Y3C
C?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY8RX6S
S?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
PageID #: 42
B00JY99I7O
?m=A1O54JL4S1M6ZV&ref_=aag_m_pw_dp
TeaNoCar
B00JY91FI4
id=A1TJT0UXQDT0JP
THE CHEAPEST
B00JY8H0WK
K/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=A22HM933SU4SJE
Tiznow
B00JY8TKO6
smid=A22HM933SU4SJE
Tiznow
B00JY91FI4
id=A22HM933SU4SJE
Tiznow
B00JY94Y3C
C/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&
smid=A22HM933SU4SJE
Tiznow
B00JY8RX6S
smid=A22HM933SU4SJE
Tiznow
B00JY8RX6S
http://www.amazon.com/Rimblades-RedProtector-RubberMoulding/dp/B00JY8RX6S/ref=sr_1_1?m=A2PB
RZHQGHQQBV&s=merchantitems&ie=UTF8&qid=1445573378&sr=11&keywords=kabis
Trust market
B00JY8RX6S
S?psc=1&redirect=true&ref_=ox_sc_act_title_10
&smid=A2PBRZHQGHQQBV
Trust market
B00JY8RX6S
S/ref=ox_sc_imb_mini_detail?ie=UTF8&psc=1&s
mid=A2PBRZHQGHQQBV
Trust market
B00JY8V4XG
http://www.amazon.com/Rimblades-BlueProtector-RubberMoulding/dp/B00JY8V4XG/ref=sr_1_1?ie=UTF8
&qid=1445489101&sr=81&keywords=B00JY8V4XG
Verdes
PageID #: 43
B00JY8V4XG
http://www.amazon.com/Rimblades-BlueProtector-RubberMoulding/dp/B00JY8V4XG/ref=lp_9219688011_
1_8?srs=9219688011&ie=UTF8&qid=14454864
17&sr=8-8
Verdes
B00JY91FI4
id=A1KO9ZGWBIQK3J
Verdes
B00JY8RX6S
smid=A1KO9ZGWBIQK3J
Verdes
B00JY8TKO6
smid=A1KO9ZGWBIQK3J
Verdes
PageID #: 44
PLATE 1: Client Images (from websites set forth in Table 1

PageID #: 45

PageID #: 46

PageID #: 47
Kenton Fedde, PhD, JD
PageID #: 48

Wildwood, Missouri 63069
KFedde@ FeddeLaw.com
Attorney at Law
Admitted in Missouri and the USPTO
NOTICE OF PATENT INFRINGEMENT
Date: 02 November 2015
FROM:
Kenton Fedde, J.D., Ph.D., Esq.
Attorney at Law (MO, USPTO)
The Fedde Law Firm
Wildwood, MO
Mo Bar #53344
kfedde@feddelaw.com
314.378.8390 (voice)
314.667.3332 (fax)
ATTORNEY FOR:
Adam Dangleman
Owner / Manager
RimBladesUSA LLC
61-278 Kamehameha Hwy #3
Haleiwa HI 96712
adam@rimbladesusa.com
Darren Bowden
Managing Director
Rimblades LTD
Taunton, United Kingdom, TA1 1UB
darren@rimblades.com
TO:
Amazon.com Legal Department
410 Terry Avenue North
Seattle, WA 98109-5210
fax: (206) 266-7010
314-378-8390 (phone)
314-667-83332 (fax)
PageID #: 49
02 Nov 2015; Page 2 of 15

Dear Sirs:
My client, Adam Dangleman, is the owner/manager of RimBladesUSA LLC. Client
Darren Bowden is owner of Rimblades LTD (U.K.)
Mr. Dangleman is an Amazon seller of the product Rimblades. Samples of his
products can be seen on Amazon websites set forth in Table I (below) and shown in
Plate A (below).
Mr. Dangleman is the owner of US patent No. 7,296,860 (the Dangleman Patent;
attached) that covers Rimblades. An element by element detailed infringement analysis
is shown in Appendix A (below).
There are at least eight third party venders that are selling Rimblades products on
Amazon; these products are stored and being shipped from Amazons U.S. Fulfillment
Center. These vendors and infringing Rimblades products are set forth in Table II.
Accordingly, with this letter, we put you on notice that the products listed in Table II
infringe the Dangleman Patent and continued storage of these products in the
Amazon Fulfillment Center and continued listing of these products for sale on your web
site make Amazon liable as a patent infringer under at least 35 U.S.C. 271(a) and
271(b) (inducement to infringe) and for conspiracy to commit patent infringement.
Accordingly, we must ask that you immediately remove or disable access to the
URLs listed in Table II and that you remove these products from your US location in a
commercially reasonable manner.
There are also at least three third party venders that are selling Rimblades products on
Amazon; these products are stored and shipped to Amazon purchasers from a U.S.
location.
With this letter, we put you on notice that the products listed in Table III infringe the
Dangleman Patent and continued listing these products for sale on you web site make
Amazon liable as a patent infringer under at least 35 U.S.C. 271(a) and 271(b)
(inducement to infringe) and for conspiracy to commit patent infringement.
I feel compelled to also draw your attention to Commil USA v. Cisco Systems (S. Ct.2015)
that clearly reads that a defendants belief regarding patent validity is not a defense to
inducement.
Under separate cover, we have also sent Amazon a DMCA Takedown notice due to
copyright infringement of my clients Rimblades images being used by these third party
vendors.
I attest, on behalf of my Mr. Dangleman, that the foregoing information is accurate and
that I believe in good faith that use of the referenced material in the manner complained
of is not authorized by the patent owner, its agent, or the law.
I further attest under penalty of perjury that I am authorized to act on behalf of Mr.
Dangleman, the patent owner.
PageID #: 50
02 Nov 2015; Page 3 of 15

If I may in any way assist your investigation, please do not hesitate to call or write me
directly. Otherwise, we expect that you will immediately comply with this notice of
infringement letter.
The courtesy of receipt confirmation is respectfully requested.
Sincerely,
Kenton Fedde, Ph.D., J.D.

Attorney at Law
CC:
Adam Dangleman by e-mail adam@rimbladesusa.com

Darren Bowden by e-mail darren@rimblades.com
Amazon Abuse Center, AWS, abuse@amazonaws.com
PageID #: 51
02 Nov 2015; Page 4 of 15
Table 1 Dangleman Patented Rimblades Products Listed on AWS
ASIN
Website
Sold By
B00JY8H0WK
http://www.amazon.com/dp/B00JY8H0WK?m=A2N
WH6KRS75TOH&ref_=v_sp_widget_detail_page
RimBlades
USA.
B00JY8TKO6
http://www.amazon.com/dp/B00JY8TKO6?m=A2NW
RimBlades
USA.
B00JY97K7Y
http://www.amazon.com/dp/B00JY97K7Y?m=A2NW
RimBlades
USA.
B00JY91FI4
http://www.amazon.com/dp/B00JY91FI4?m=A2NWH
6KRS75TOH&ref_=v_sp_widget_detail_page
RimBlades
USA.
B00JY94Y3C
http://www.amazon.com/dp/B00JY94Y3C?m=A2NW
RimBlades
USA.
B00JY8RX6S
http://www.amazon.com/Rimblades-Red-ProtectorRubberMoulding/dp/B00JY8RX6S/ref=lp_9219688011_1_1
?srs=9219688011&ie=UTF8&qid=1445486417&sr=8
-1
RimBlades
USA.
B00JY8RX6S
http://www.amazon.com/dp/B00JY8RX6S?m=A2NW
RimBlades
USA.
B00L45J7XG
http://www.amazon.com/dp/B00L45J7XG?m=A2NW
RimBlades
USA.
B00JY99I7O
http://www.amazon.com/dp/B00JY99I7O?m=A2NW
RimBlades
USA.
PageID #: 52
02 Nov 2015; Page 5 of 15
B00JY8V4XG
http://www.amazon.com/Rimblades-Blue-ProtectorRubberMoulding/dp/B00JY8V4XG/ref=aag_m_pw_dp?ie=U
TF8&m=A2NWH6KRS75TOH
Table II Amazon Sellers selling Rimblades products that infringe the Dangleman
Patent and ship from Amazon Fulfillment Center
Website
Sold By
Shipped
From
B00JY8TKO6
http://www.amazon.com/gp/product/B00JY8TKO6?psc=
1&redirect=true&ref_=ox_sc_act_title_1&smid=A3NN4M
02ONBDU7
BLINQ.
Amazon
Fulfillment
Center
B00JY8TKO6
1&redirect=true&ref_=ox_sc_imb_mini_detail&smid=A3
KE0O4W1D9P09
FBA warehouse
Amazon
Fulfillment
Center
B00JY91FI4
http://www.amazon.com/Rimblades-Pink-ProtectorRubberMoulding/dp/B00JY91FI4/ref=sr_1_1?ie=UTF8&qid=144
5488437&sr=8-1&keywords=B00JY91FI4
FBA warehouse
Amazon
Fulfillment
Center
B00JY8RX6S
http://www.amazon.com/gp/product/B00JY8RX6S?psc=
1&redirect=true&ref_=ox_sc_act_title_4&smid=A1O54JL
4S1M6ZV
FBA warehouse
Amazon
Fulfillment
Center
ASIN
PageID #: 53
02 Nov 2015; Page 6 of 15
B00JY99I7O
http://www.amazon.com/Rimblades-Yellow-ProtectorRubberMoulding/dp/B00JY99I7O/ref=lp_9219688011_1_7?srs=
9219688011&ie=UTF8&qid=1445486417&sr=8-7
FBA warehouse
Amazon
Fulfillment
Center
B00JY8H0WK
http://www.amazon.com/gp/product/B00JY8H0WK/ref=o
x_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A1VNZ64
RONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY8V4XG
http://www.amazon.com/gp/product/B00JY8V4XG/ref=o
RONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY8WDN6
http://www.amazon.com/gp/product/B00JY8WDN6/ref=o
RONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY8TKO6
http://www.amazon.com/gp/product/B00JY8TKO6?keyw
ords=B00JY8TKO6&qid=1445489557&ref_=sr_1_1&sr=
8-1
gotoshop
Amazon
Fulfillment
Center
B00JY97K7Y
http://www.amazon.com/Rimblades-Orange-ProtectorRubberMoulding/dp/B00JY97K7Y/ref=lp_9219688011_1_9?srs
=9219688011&ie=UTF8&qid=1445486417&sr=8-9
gotoshop
Amazon
Fulfillment
Center
PageID #: 54
02 Nov 2015; Page 7 of 15
B00JY91FI4
http://www.amazon.com/gp/product/B00JY91FI4/ref=ox_
sc_imb_mini_detail?ie=UTF8&psc=1&smid=A1VNZ64R
ONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY94Y3C
http://www.amazon.com/Rimblades-Purple-ProtectorRubberMoulding/dp/B00JY94Y3C/ref=lp_9219688011_1_6?srs
=9219688011&ie=UTF8&qid=1445486417&sr=8-6
gotoshop
Amazon
Fulfillment
Center
B00JY8RX6S
1&redirect=true&ref_=ox_sc_act_title_3&smid=A1VNZ6
4RONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY99I7O
http://www.amazon.com/gp/product/B00JY99I7O/ref=ox
_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A1VNZ64
RONCC4W
gotoshop
Amazon
Fulfillment
Center
B00JY8H0WK
http://www.amazon.com/Rimblades-Black-ProtectorRubberMoulding/dp/B00JY8H0WK/ref=sr_1_3?ie=UTF8&qid=1
445498322&sr=8-3&keywords=kabis+and+rimblades
JJHOBBYMALL
Amazon
Fulfillment
Center
B00JY8V4XG
http://www.amazon.com/gp/product/B00JY8V4XG/ref=o
x_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A3TWCQ
LN5VJN1X
JJHOBBYMALL
Amazon
Fulfillment
Center
PageID #: 55
02 Nov 2015; Page 8 of 15
B00JY8WDN6
http://www.amazon.com/Rimblades-Green-ProtectorRubberMoulding/dp/B00JY8WDN6/ref=sr_1_3?ie=UTF8&qid=1
445490255&sr=8-3&keywords=Blinq+rimblades
JJHOBBYMALL
Amazon
Fulfillment
Center
B00JY97K7Y
http://www.amazon.com/gp/product/B00JY97K7Y?me=&
qid=1445487887&redirect=true&ref_=olp_product_detail
s&sr=8-1
JJHOBBYMALL
Amazon
Fulfillment
Center
B00JY94Y3C
http://www.amazon.com/gp/product/B00JY94Y3C/ref=ox
_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A3TWCQL
N5VJN1X
JJHOBBYMALL
Amazon
Fulfillment
Center
B00L45J7XG
http://www.amazon.com/Rimblades-White-ProtectorRubberMoulding/dp/B00L45J7XG/ref=sr_1_9?ie=UTF8&qid=14
45498322&sr=8-9&keywords=kabis+and+rimblades
JJHOBBYMALL
Amazon
Fulfillment
Center
B00JY99I7O
http://www.amazon.com/gp/product/B00JY99I7O/ref=ox
_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A3TWCQL
N5VJN1X
JJHOBBYMALL
Amazon
Fulfillment
Center
B00JY91FI4
sc_imb_mini_detail?ie=UTF8&psc=1&smid=A1TJT0UX
QDT0JP
THE
CHEAPEST
Amazon
Fulfillment
Center
PageID #: 56
02 Nov 2015; Page 9 of 15
B00JY8H0WK
http://www.amazon.com/gp/product/B00JY8H0WK/ref=o
x_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A22HM9
33SU4SJE
Tiznow
Amazon
Fulfillment
Center
B00JY8TKO6
1&redirect=true&ref_=ox_sc_act_title_1&smid=A22HM9
33SU4SJE
Tiznow
Amazon
Fulfillment
Center
B00JY91FI4
sc_imb_mini_detail?ie=UTF8&psc=1&smid=A22HM933
SU4SJE
Tiznow
Amazon
Fulfillment
Center
B00JY94Y3C
http://www.amazon.com/gp/product/B00JY94Y3C/ref=ox
_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A22HM93
3SU4SJE
Tiznow
Amazon
Fulfillment
Center
B00JY8RX6S
1&redirect=true&ref_=ox_sc_act_title_7&smid=A22HM9
33SU4SJE
Tiznow
Amazon
Fulfillment
Center
B00JY8RX6S
http://www.amazon.com/Rimblades-Red-ProtectorRubberMoulding/dp/B00JY8RX6S/ref=sr_1_1?m=A2PBRZHQG
HQQBV&s=merchantitems&ie=UTF8&qid=1445573378&sr=11&keywords=kabis
Trust market
Amazon
Fulfillment
Center
B00JY8RX6S
1&redirect=true&ref_=ox_sc_act_title_10&smid=A2PBR
ZHQGHQQBV
Trust market
Amazon
Fulfillment
Center
PageID #: 57
02 Nov 2015; Page 10 of 15
B00JY8RX6S
http://www.amazon.com/gp/product/B00JY8RX6S/ref=o
x_sc_imb_mini_detail?ie=UTF8&psc=1&smid=A2PBRZ
HQGHQQBV
Trust market
Amazon
Fulfillment
Center
B00JY8V4XG
http://www.amazon.com/Rimblades-Blue-ProtectorRubberMoulding/dp/B00JY8V4XG/ref=sr_1_1?ie=UTF8&qid=14
45489101&sr=8-1&keywords=B00JY8V4XG
Verdes
Amazon
Fulfillment
Center
B00JY8V4XG
http://www.amazon.com/Rimblades-Blue-ProtectorRubberMoulding/dp/B00JY8V4XG/ref=lp_9219688011_1_8?srs
=9219688011&ie=UTF8&qid=1445486417&sr=8-8
Verdes
Amazon
Fulfillment
Center
B00JY91FI4
sc_imb_mini_detail?ie=UTF8&psc=1&smid=A1KO9ZG
WBIQK3J
Verdes
Amazon
Fulfillment
Center
B00JY8RX6S
1&redirect=true&ref_=ox_sc_act_title_5&smid=A1KO9Z
GWBIQK3J
Verdes
Amazon
Fulfillment
Center
B00JY8TKO6
1&redirect=true&ref_=ox_sc_act_title_2&smid=A1KO9Z
GWBIQK3J
Verdes
Amazon
Fulfillment
Center
PageID #: 58
02 Nov 2015; Page 11 of 15

Table III Amazon Sellers selling Rimblades products that infringe the Dangleman
Patent and ship from US Locations
Sold By
Shipped
From
http://www.amazon.com/gp/product/B00
W97BE70/ref=ox_sc_imb_mini_detail?ie=
UTF8&psc=1&smid=AZAPWOP3U4U52
Benefit4u.
NJ
B00JY8RX6S
http://www.amazon.com/gp/product/B00J
Y8RX6S?psc=1&redirect=true&ref_=ox_s
c_act_title_2&smid=A261JEZXVVD8S
BIZBUY
INTERNATIONAL.
NJ
B00JY8V4XG
Y8V4XG/ref=ox_sc_imb_mini_detail?ie=
UTF8&psc=1&smid=A3NN4M02ONBDU7
BLINQ.
MD
B00JY8WDN6
Y8WDN6/ref=ox_sc_imb_mini_detail?ie=
UTF8&psc=1&smid=A3NN4M02ONBDU7
BLINQ.
MD
ASIN
Website
B00W97BE70
PageID #: 59
02 Nov 2015; Page 12 of 15
PLATE A: Client Images from Client AWS sites set forth in Table I

02 Nov 2015; Page 13 of 15
PageID #: 60
PageID #: 61
02 Nov 2015; Page 14 of 15

Appendix A: Infringement Analysis
Rimblades infringes at least Claim 1 of U.S. Patent 7,296,860 (attached) because it
comprises every element as set forth below.
Claim 1. A rim protection apparatus adhered to the periphery of a rim of a motor vehicle
wheel, the apparatus comprising:
a circular, impact-absorbing, protective ring comprising:
a first part covering a first surface of the rim in a first plane, the first plane being
the plane of a sidewall of the motor vehicle wheel;
a second part perpendicular to the first part covering a second surface of the rim,
the second surface of the rim being perpendicular to the first surface of the rim;
a means for adhering said impact absorbing protective ring around the periphery
of the rim in a flush mounting,
such that the apparatus covers the circumferential edge of the rim, wherein said
impact absorbing protective ring is securely coupled to the wheel;
an adhesive layer disposed on at least one area of said first part and said second
part of said impact absorbing protective ring;
wherein said impact absorbing protective ring is configured such that it may be
adhered and removed by hand solely by means of said adhesive layer; and,
wherein said impact-absorbing protective ring comprises a front surface and an
inner surface, the inner surface being coupled with the rim of the wheel when the
apparatus is fitted around the periphery of the rim of the wheel, the-outer surface
being a decorative surface accenting the color and appearance of the wheel,
said impact absorbing protective ring having an inner edge and an outer edge.
Rimblades photograph
PageID #: 62
02 Nov 2015; Page 15 of 15
1. As shown in the diagram above, whether uninstalled or installed on a rim, the

Rimblades include the claimed "first part" and "a second part perpendicular to
the first part.
2. Rimblades has the 860 element impact absorbing protective ring.
a. Rimblades are made of rubber and thermoplastic vulcanizate (TPV),
which fall within the meaning of "impact absorbing protective ring" .
b. Rimblades advertisement specifically states that TPV has the
appearance and feel of rubber "but the element of plastic means they
are durable" . http://www.rimblades.com/shop/rimblades-alloy-wheelrim-protectors/. Indeed, rubber substances that appear and feel like
rubber and plastics would be immediately recognized by one skilled in
the art as examples of impact absorbing materials.
PageID #: 63
PageID #: 64
PageID #: 65
PageID #: 66
PageID #: 67
PageID #: 68
PageID #: 69
PageID #: 70
PageID #: 71
PageID #: 72
PageID #: 73
PageID #: 74

RimBlades v. Amazon - Com - Complaint

Hochgeladen von

Dokumentinformationen

Originalbeschreibung:

Originaltitel

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

RimBlades v. Amazon - Com - Complaint

Hochgeladen von

Copyright:

Verfügbare Formate

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 1 of 11

Brian Cummings (10146)

IN THE UNITED STATES DISTRICT COURT

Case No. 16-463

Plaintiff RimBladesUSA, LLC (RimBlades or Plaintiff) is a domestic limited liability

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 2 of 11

Defendant Amazon.com, Inc. (Amazon or Defendant) is a corporation organized and

Accordingly, venue is proper pursuant to 28 U.S.C. 1391.

RimBlades Products and Intellectual Property

RimBlades is in the business of inventing, developing, manufacturing, distributing, and

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 3 of 11

Additionally, Amazon operates a fulfillment service and network (the fulfillment

Amazons fulfillment service provides the technology, infrastructure, and logistics to

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 4 of 11

Consequently, Amazon has engaged in willful infringement of the RimBlades Patents

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 5 of 11

RimBlades has been and continues to be significantly damaged by Amazons actions. So

FIRST CAUSE OF ACTION

The preceding allegations are incorporated herein by reference.

RimBlades owns the RimBlades Patents.

Upon information and belief, Amazons infringing activities in violation of 35 U.S.C. 1

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 6 of 11

The preceding paragraphs are incorporated herein by reference.

THIRD CAUSE OF ACTION

The preceding allegations are incorporated herein by reference.

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 7 of 11

The preceding allegations are incorporated herein by reference.

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 8 of 11

The preceding paragraphs are incorporated herein by reference.

The preceding paragraphs are incorporated herein by reference.

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 9 of 11

RimBlades has been and continues to be irreparably harmed by Amazons unlawful

RimBlades should be awarded damages in amount to be determined at trial.

Amazons counterfeiting was done willfully. RimBlades is therefore entitled to treble

The preceding paragraphs are incorporated herein by reference.

RimBlades owns the RimBlades Patents.

Amazon has engaged in unfair competition by infringing on the RimBlades Patents.

RimBlades has suffered actual damages as a result of Amazons unfair practices in an

The harm to RimBlades caused by Amazons conduct is not adequately or fully

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 10 of 11

CONCLUSION & REQUEST FOR RELIEF

Amazon has directly and willfully infringed the RimBlades Patents;

Amazon is liable for contributory infringement of the RimBlades Patents;

Amazon has engaged in the willful counterfeiting of RimBlades products;

A judgment against Amazon for RimBlades actual damages in an amount to be proven at

A judgment awarding RimBlades treble damages to be determined at trial;

A judgment awarding RimBlades its attorneys fees and court costs;

A judgment awarding RimBlades prejudgment and post-judgment interest, as applicable,

Case 1:16-cv-00463 Document 1 Filed 08/19/16 Page 11 of 11

CUMMINGS MANOOKIAN PLC

/s/ Brian Cummings

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 1 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 2 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 3 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 4 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 5 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 6 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 7 of 8

Case 1:16-cv-00463 Document 1-1 Filed 08/19/16 Page 8 of 8

Case 1:16-cv-00463 Document 1-2 Filed 08/19/16 Page 1 of 12

Case 1:16-cv-00463 Document 1-2 Filed 08/19/16 Page 2 of 12

Case 1:16-cv-00463 Document 1-2 Filed 08/19/16 Page 3 of 12