Case 2:21-cv-02446 Document 1 Filed 03/19/21 Page 1 of 10 Page ID #:1

1 CONSTANTINE MARANTIDIS, CA Bar No. 173318

cmarantidis@lewisroca.com
2 G. WARREN BLEEKER, CA Bar No. 210834
wbleeker@lewisroca.com
3 KYLE W. KELLAR, CA Bar No. 294253
kkellar@lewisroca.com
4 LEWIS ROCA ROTHGERBER CHRISTIE LLP
655 N. Central Avenue, Suite 2300
5 Glendale, CA 91203-1445
Telephone: (626) 795-9900
6 Facsimile: (626) 577-8800
7 Attorneys for Plaintiff
8 Meissner Filtration Products, Inc.

9
10 UNITED STATES DISTRICT COURT

11 CENTRAL DISTRICT OF CALIFORNIA

655 North Central Avenue

Glendale, CA 91203-1445

12
MEISSNER FILTRATION Case No. 2:21-cv-02446
13 PRODUCTS, INC.,
14 Plaintiff, COMPLAINT FOR PATENT
Suite 2300

INFRINGEMENT
15 vs.
16 SANI-TECH WEST, INC.; and
TBL PERFORMANCE PLASTICS LLC, DEMAND FOR JURY TRIAL
17
Defendants.
18
19
20 Plaintiff Meissner Filtration Products, Inc. (“Meissner” or “Plaintiff”)
21 through its undersigned counsel, brings this action against Defendants Sani-Tech
22 West, Inc. (“Sani-Tech”) and TBL Performance Plastics LLC (“TBL Plastics”)
23 (collectively, “Defendants”). In support of the Complaint, Plaintiff alleges as
24 follows:
25 JURISDICTION AND VENUE
26 1. This is an action for patent infringement pursuant to 35 U.S.C. § 271
27 et seq. This Court has exclusive subject matter jurisdiction over this action under
28 28 U.S.C. §§ 1331 and 1338(a).
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1 2. This Court has personal jurisdiction over Defendants because, on

2 information and belief, they have done substantial business in this judicial district.
3 Further, Defendant Sani-Tech West has a regular and established place of
4 business in this judicial district at 1020 Flynn Road, Camarillo, California 93012.
5 3. Venue is proper in this Court under 28 U.S.C. §§ 1391(b)(2),
6 1391(c)(2), and 1400(b) based on the forgoing facts and because, on information
7 and belief, a substantial part of the acts or omissions giving rise to the claim,
8 including Defendants’ acts of infringement, have occurred in this judicial district.
9 THE PARTIES
10 4. Meissner is a corporation organized and existing under the laws of
11 the State of California having a principal place of business at 1001 Flynn Road,
655 North Central Avenue

Glendale, CA 91203-1445

12 Camarillo, California 93012.

13 5. On information and belief, Defendant Sani-Tech West, Inc. is a
14 California corporation having a business address of 1020 Flynn Road, Camarillo,
Suite 2300

15 California 93012 and an agent address of 4195 E. Thousand Oaks Boulevard,

16 Suite 250, Westlake Village, California 91362.
17 6. On information and belief, Defendant TBL Performance Plastics
18 LLC is a New Jersey corporation having a business address of 18 White Lake
19 Road, Sparta, New Jersey 07871.
20 7. On information and belief, Defendant Sani-Tech West is the parent
21 corporation of Defendant TBL Plastics.
22 FACTUAL BACKGROUND AND NATURE OF ACTION
23 8. United States Patent No. 7,373,825 (“the ’825 Patent”), titled
24 “GAUGE TEE DEVICE,” was duly issued by the United States Patent and
25 Trademark Office (“USPTO”) on May 20, 2008. A true and correct copy of the
26 ’825 Patent is attached hereto as Exhibit A.
27 //
28 //

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1 9. Meissner owns by assignment the entire right, title, and interest in

2 and to the ’825 Patent. As the owner of the entire right, title, and interest in and
3 to the ’825 Patent, Meissner possesses the right to sue and to recover for
4 infringement of the ’825 Patent.
5 10. The ’825 Patent is directed to a disposable sanitary gauge tee.
6 11. Figure 8 of the ’825 Patent, which illustrates non-limiting aspects of
7 some of the claimed embodiments, illustrates a gauge tee device 10” having a
8 pressure fluid passageway 24”, the pressure fluid passageway 24” having a
9 diameter at its proximal end 22” that is substantially the same as the diameter at
10 its distal end 30”.
11
655 North Central Avenue

Glendale, CA 91203-1445

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23 12. Meissner sells products embodying the invention of the ’825 Patent,
24 called Single-Use Gauge Tees. Since at least December 2016, Meissner has
25 identified the ’825 Patent on its Single-Use Gauge Tees that are covered by this
26 patent.
27 //
28 //
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1 The only independent claim of the ’825 Patent, claim 1, recites:

2
1. A disposable sanitary gauge tee with no dead zone for
3 use in pressure measurement of fluid in disposable tubing comprising:
4 a body including a main fluid passageway in fluid connection
with a proximal end of a pressure fluid passageway;
5
said main fluid passageway including a fluid port and a second
6 fluid port, wherein a hose barb is operatively attached to said body at
7 said fluid port and said second fluid port, wherein said disposable
tubing can be removably attached to said hose barbs;
8
said pressure fluid passageway including a distal end for
9 removable attachment of a sanitary pressure gauge and a
10 biocompatible gauge protector for isolation of said fluid from said
sanitary pressure gauge; and
11
said proximal end of said pressure fluid passageway being
655 North Central Avenue

Glendale, CA 91203-1445

12 substantially the same diameter as said distal end of said pressure

13 fluid passageway, therein providing a total transfer of fluid within said
pressure fluid passageway during fluid flow.
14
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15 13. Defendants are currently making, using, offering for sale, and/or
16 selling disposable sanitary gauge tees, which they market as aSURE Instrument
17 Fittings, that infringe the ’825 Patent, including at least those identified by
18 product numbers 23-181010 and 23-181012 (collectively, the “Accused
19 Products”). Defendant TBL Plastic’s website, a true and correct copy of which is
20 attached hereto as Exhibit B, shows and describes the aSURE Instrument Fittings.
21 (Exhibit B, page 3).
22 14. Defendants’ disposable sanitary gauge tees, including at least those
23 identified by product numbers 23-181010 and 23-181012, each have, either
24 literally or under the doctrine of equivalents, all the elements of at least claim 1 of
25 the ’825 Patent as described in the chart attached hereto as Exhibit C and as
26 follows:
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1 (i) Defendant TBL Plastics describes the Accused Products

2 on its website as the “aSURE Instrument fitting[s].” The Accused
Products do not have a dead zone and may be used to measure
3 pressure in disposable tubing;
4 (ii) The Accused Products have a body including a main fluid
5 passageway in fluid connection with a proximal end of a pressure
fluid passageway;
6
(iii) The main fluid passageway of the Accused Products
7 includes a fluid port and a second fluid port, and a hose barb is
operatively attached to the body at the fluid port and the second fluid
8
port. Disposable tubing can be removably attached to said hose barbs;
9 (iv) The pressure fluid passageway of the Accused Products
10 includes a distal end for removable attachment of a sanitary pressure
gauge and a biocompatible gauge protector for isolation of the fluid
11 from the sanitary pressure gauge; and
655 North Central Avenue

Glendale, CA 91203-1445

12 (v) The proximal end of the pressure fluid passageway of the

13 Accused Products has substantially the same diameter as the distal end
of the pressure fluid passageway such that a total transfer of fluid is
14 provided within the pressure fluid passageway during fluid flow.
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16 15. As would be understood by one of ordinary skill in the art,
17 “substantially the same diameter” as recited in claim 1 of the ’825 Patent does not
18 require exactly the same diameter at the proximal and distal ends of the pressure
19 fluid passageway but covers variations between the diameter at the proximal and
20 distal ends of the pressure fluid passageway. As can be seen at least in Figure 8
21 of the ’825 Patent, which is reproduced again below, such variations in diameters
22 of the proximal end 22” and the distal end 30” of the pressure fluid passageway
23 24” were shown in at least one illustrated embodiment:
24 //
25 //
26 //
27 //
28 //

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11 16. For example, as described at column 6, lines 48–50 of the ’825
655 North Central Avenue

Glendale, CA 91203-1445

12 Patent, “[t]he proximal end 22” is almost or substantially the same diameter as the
13 distal end 30” of the pressure fluid passageway 20”.”
14 17. Further, Defendants market and sell the Accused Products with a
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15 biocompatible gauge protector affixed to the pressure fluid passageway. On

16 information and belief, the biocompatible gauge protector is affixed to the
17 pressure fluid passageway after manufacture of the sanitary gauge tee and as a
18 secondary step. The Accused Products, thus, include “a distal end for removable
19 attachment of a sanitary pressure gauge and a biocompatible gauge protector for
20 isolation of the fluid from the sanitary pressure gauge” as recited in claim 1 after
21 manufacture and prior to attachment of the biocompatible gauge protector.
22 18. Nevertheless, on information and belief, the biocompatible gauge
23 protector sold with the Accused Products can be removed from the disposable
24 sanitary gauge tee without destroying the disposable sanitary gauge tee, rendering
25 the distal end of the pressure fluid passageway of the Accused Products “for
26 removable attachment of a sanitary pressure gauge and a biocompatible gauge
27 protector for isolation of the fluid from the sanitary pressure gauge” even after
28 Defendants affix the biocompatible gauge protector to the Accused Products.
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1 19. In addition, because the pressure fluid passageway in the Accused

2 Products performs substantially the same function in substantially the same
3 manner as in the claimed embodiment to obtain the same result, any difference
4 between the Accused Products and claim 1 of the ’825 Patent is insubstantial and
5 does not avoid infringement.
6 20. Accordingly, Defendants have infringed, and continue to infringe, at
7 least claim 1 of the ’825 Patent by making, using, offering for sale, and/or selling
8 the Accused Products, which embody all of the features of at least claim 1 of the
9 ’825 Patent.
10 21. Meissner contacted Defendant TBL Plastics as early as January 3,
11 2020, informing it of Meissner’s patent rights in the ’825 Patent. A true and
655 North Central Avenue

Glendale, CA 91203-1445

12 correct copy of the January 3, 2020, letter is attached hereto as Exhibit D.

13 Counsel for Defendant TBL Plastics responded on February 5, 2020. A true and
14 correct copy of the February 5, 2020, letter is attached hereto as Exhibit E. Since
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15 being put on notice of the ’825 Patent, Defendants have not ceased offering for
16 sale or selling the Accused Products.
17 CLAIM FOR RELIEF
18 (Patent Infringement of U.S. Patent No. 7,373,825)
19 22. Meissner incorporates and re-alleges Paragraphs 1 through 22 of this
20 Complaint as if fully set forth herein.
21 23. The USPTO duly issued the ’825 Patent on May 20, 2008.
22 24. The ’825 Patent is valid and enforceable.
23 25. Meissner has, since at least December 2016, marked its products
24 covered by the ’825 Patent pursuant to 35 U.S.C. § 287.
25 26. Defendants have infringed at least claim 1 of the ’825 Patent, either
26 literally or under the doctrine of equivalents, by making, using, offering to sell,
27 and/or selling in the United States its aSURE Instrument Fittings, including at
28
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1 least product numbers 23-181010 and 23-181012 (referred to above and below as
2 the “Accused Products”).
3 27. Defendants’ infringement of the ’825 Patent has injured Meissner,
4 and Meissner is entitled to recover damages adequate to compensate it for
5 Defendants’ infringement, which in no event can be less than a reasonable
6 royalty.
7 28. Upon information and belief, Defendants’ infringement was willful
8 because Defendants made, used, offered for sale, and/or sold, and continue to do
9 the same, the Accused Products despite an objectively high likelihood that their
10 actions constituted infringement of a valid patent, and Defendants knew or should
11 have known of such risk when they infringed the ’825 Patent.
655 North Central Avenue

Glendale, CA 91203-1445

12 29. Defendants were put on actual notice of the ’825 Patent as early as
13 February 5, 2020, but continued to make, use, offer for sale, and sell the Accused
14 Products. Such infringement is willful.
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15 30. Pursuant to 35 U.S.C. § 284, the Court should award Meissner treble
16 damages as a result of Defendants’ willful infringement.
17 31. Defendants’ infringement of the ’825 Patent is exceptional.
18 Accordingly, pursuant to 35 U.S.C. § 285, Meissner is entitled to recover from
19 Defendants its reasonable attorneys’ fees and costs incurred in prosecuting this
20 action.
21
22 PRAYER FOR RELIEF
23 WHEREFORE, Plaintiff respectfully requests that this Court enter
24 judgment as follows:
25 1. That Defendants have infringed the ’825 Patent;
26 2. That Defendants’ infringement of the ’825 Patent has been willful;
27 3. Entry of a permanent injunction against further infringement of
28 the ’825 Patent;

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1 4. An award of damages adequate to compensate Meissner for

2 Defendants’ infringement of the ’825 Patent, including pre-judgment interest and
3 costs;
4 5. An Order requiring Defendants to account for and pay to Meissner
5 any and all profits made by Defendants from their sales of the Accused Products
6 pursuant to 35 U.S.C. § 289;
7 6. An award of all other damages permitted by 35 U.S.C. § 284;
8 7. A determination that this is an exceptional case within the meaning
9 of 35 U.S.C. § 285 and an award to Meissner of its costs and reasonable
10 attorneys’ fees incurred in this action; and
11 8. Such other relief as this Court deems just and proper.
655 North Central Avenue

Glendale, CA 91203-1445

12
13 Dated: March 19, 2021 Respectfully submitted,
14 LEWIS ROCA ROTHGERBER
Suite 2300

CHRISTIE LLP
15
16 By /s/Kyle W. Kellar
Constantine Marantidis
17
G. Warren Bleeker
18 Kyle W. Kellar
19 Attorneys for Plaintiff
20 Meissner Filtration Products, Inc.
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1 JURY DEMAND
2 Plaintiff requests a jury trial of all issues in this action so triable.
3
4 Dated: March 19, 2021 Respectfully submitted,
5 LEWIS ROCA ROTHGERBER
CHRISTIE LLP
6
7 By /s/Kyle W. Kellar
Constantine Marantidis
8 G. Warren Bleeker
9 Kyle W. Kellar
10 Attorneys for Plaintiff
11 Meissner Filtration Products, Inc.
655 North Central Avenue

Glendale, CA 91203-1445

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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 12 of 29 Page ID #:22

Exhibit A
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Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 13 of 29 Page ID #:23

Exhibit A
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Exhibit A
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Exhibit A
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Exhibit B
 Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 17 of 29 Page ID #:27

aSURE
™

Fittings
Superior Alignment Ensures
Seal Integrity
Exclusive
Fused Gasket The Only Sanitary Fitting Available with
Design Patent Pending
Patent Pending
a One-Piece Composite Gasket Design.

Materials
of Construction
Adapter Body; Polypropylene
Gasket; Cellgyn™ TPE

TM

Performance Plastics
Exhibit B
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TM

Performance Plastics

aSURE Fittings
™

The New Concept in Functional Design!

The aSURE™ utilizes a unique approach that incorporates an elastomeric
TPE (Cellgyn™) gasket fused into a singular sanitary fitting, forming a
one-piece composite design. The result is a gendered fitting that can be
used in conjunction with any standard sanitary connection. It provides
superior ergonomics and less risk of contamination.

aSURE™ fittings have been developed for single-use connectivity

applications where the most stringent practices are required. They are
manufactured from medical-grade materials and are animal derived
component free (ADCF).

Features Benefits
One Piece Design Ensures Proper Alignment
Medical Grade Materials/ ADCF Lowers Risk of Contamination
No Solvents or Cements Gendered Connection Aids in Proper Work Instruction
Gamma Stable 25 kGy to 40 kGy / Autoclavable Superior Economics
Gendered Connection Eliminates Lost or Misused Gaskets
Single Use Technology Excellent Compatibility with Most Acids and Bases

Mini Sanitary X Hose Barb

F-AS-14MPHR075-125 Mini Tri-Clamp x 1/8" Mono Barb Adapter Biocompatibility:
F-AS-14MPHR075-187 Mini Tri-Clamp x 3/16" Mono Barb Adapter All materials in contact with fluid path meet USP Class VI
<88> requirements, FDA Title 21 CFR 177.1520 , are Animal
F-AS-14MPHR075-250 Mini Tri-Clamp x 1/4" Mono Barb Adapter
Derived Component Free (ADCF) , and REACH Compliant
F-AS-14MPHR075-375 Mini Tri-Clamp x 3/8" Mono Barb Adapter
F-AS-14MPHR075-500 Mini Tri-Clamp x 1/2" Mono Barb Adapter Manufacturing:
F-AS-14MPHR075-750 Mini Tri-Clamp x 3/4" Mono Barb Adapter Manufactured and Packaged in an ISO Class 7
1-1/2” Sanitary X Hose Barb (Class 10,000) Environment
F-AS-14MPHR150-250 1-1/2” Tri-Clamp x 1/4" Mono Barb Adapter
F-AS-14MPHR150-375 1-1/2” Tri-Clamp x 3/8" Mono Barb Adapter
F-AS-14MPHR150-500 1-1/2” Tri-Clamp x 1/2" Mono Barb Adapter
F-AS-14MPHR150-750 1-1/2” Tri-Clamp x 3/4" Mono Barb Adapter
F-AS-14MPHR150-1000 1-1/2” Tri-Clamp x 1" Mono Barb Adapter

aSURE™ Fittings Patented one-piece, composite design.

Exhibit B
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™ Cellgyn (TPE) ™

Diaphragm
aSURE
™

Instrument Fitting
Provides a Protective Barrier for
Aseptic Applications
The aSURE™ instrument fitting was developed as a
means to maintain a sterile barrier where disposable
manifolds are used on hybrid single-use process equip-
ment. Fixed or tethered pressure-monitoring devices
provide extremely high accuracy and are often hard
wired into a central control panel. The aSURE™ instru-
ment fitting provides a practical means of maintaining
a sterile barrier on a complex manifold set, and provides
a barrier without the need to have a gauge present
during the sterilization process.

Features Benefits Available Sizes

One Piece Design Maintains a Sterile Barrier PN: 23-181010
Medical Grade Materials/ ADCF Works with Any 1-1/2” Sanitary Pressure Instrument Sanitary Fitting Instrument Tee
1-1/2” TC X 1/2" Hose Barb (600 Series)
No Solvents or Cements Safe Disposal (no electronics or metals) Material: ADCF Polyethylene/ Cellgyn™ TPE
Gamma Stable from 25 kGy to 40 kGy Re-use of Instrument Means Better Economics
PN: 23-181012
Gendered Connection Non-Restrictive Flow Path Sanitary Fitting Instrument Tee
1-1/2” TC X 1" Hose Barb (600 Series)
Single Use Technology No Dead Leg
Material: ADCF Polyethylene/ Cellgyn™ TPE

*Accuracy:
0 to 15 psi (0 to 1.0 bar): + 0.0% / - 6.5%
15 to 60 psi (1.0 to 4.1 bar): + 0.0% /- 0.6%

Leak Testing:
Pressure-Decay Testing is performed on each unit before
packaging
Biocompatibility:
All materials in contact with fluid path meet USP Class VI <88>
requirements, FDA Title 21 CFR 177.1520 , are Animal Derived Component
Free (ADCF) , and REACH Compliant
Manufacturing:
Manufactured and packaged in an ISO Class 7 (Class 10,000) environment

Superior alignment ensures seal integrity. TM

Performance Plastics
Exhibit B
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Related Products

aSURE WFI Sampler

Visit us on-line at
™
™ www.tblplastics.com
to learn more.

aSURE™ WFI Samplers are a simple solution for achieving a contaminant-free sample
from a WFI use point. The assemblies come double bagged in an easy peel, low
permeability, medical-grade pouch and are gamma irradiated to ensure microbial
control. All assembly is conducted in a state-of-the-art ISO Class 7 cleanroom.

Demand the one-piece aSURE™ design for the cleanest hassle-free connection.

aSURE™ WFI samplers are manufactured from medical-grade polypropylene and

Cellgyn™ (TPE) materials.

Note: Pictured with Bio-Ease clamp (Optional)

Biocompatibility:
All materials in contact with fluid path meet USP Class VI <88> requirements, FDA Title 21 CFR
177.1520 , are Animal Derived Component Free (ADCF) , and REACH Compliant

AS-CGN04.3.1299-18 aSURE™ WFI Sampler Hose Mini (TC) Connection

¼” ID X 7/16” OD Cellgyn (TPE) Tube X 18" Length, Double Bagged/ Gamma Treated
AS-CGN04.3.1299-36 aSURE™ WFI Sampler Hose Mini (TC) Connection
¼” ID X 7/16” OD Cellgyn (TPE) Tube X 36" Length, Double Bagged/ Gamma Treated
AS-CGN04.3.2499-18 aSURE™ WFI Sampler Hose 1-1/2" (TC) Connection
¼” ID X 7/16 OD Cellgyn (TPE) Tube X 18" Length, Double Bagged/ Gamma Treated
AS-CGN04.3.2499-36 aSURE™ WFI Sampler Hose 1-1/2" (TC) Connection
¼” ID X 7/16” OD Cellgyn (TPE) Tube X 36" Length, Double Bagged/ Gamma Treated

Made in the USA

TBL Performance Plastics

18 White Lake Road, Sparta, NJ 07871 TM

Tel 973.383.2834 Fax 973.383.4161 sales@tblplastics.com www.tblplastics.com Performance Plastics

Exhibit B
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Exhibit C
 Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 22 of 29 Page ID #:32

US Patent No. 7,373,825 TBL Performance Plastics Tee

(As shown in FIG. 1 Below)

1. A disposable sanitary gauge tee with no 1. A disposable sanitary gauge tee 1 with no

dead zone for use in pressure measurement of dead zone for use in pressure measurement of

fluid in disposable tubing comprising: fluid in disposable tubing comprising:

a body including a main fluid passageway in a body 10 including a main fluid passageway

fluid connection with a proximal end of a 20 in fluid connection with a proximal end 22

pressure fluid passageway; of a pressure fluid passageway 12;

said main fluid passageway including a fluid said main fluid passageway including a fluid

port and a second fluid port, wherein a hose port 16 and a second fluid port 18, wherein a

barb is operatively attached to said body at hose barb 14 is operatively attached to said

said fluid port and said second fluid port, body at said fluid port and said second fluid

wherein said disposable tubing can be port, wherein said disposable tubing can be

removably attached to said hose barbs; removably attached to said hose barbs;

said pressure fluid passageway including a said pressure fluid passageway 12 including a

distal end for removable attachment of a distal end 30 for removable attachment of a

sanitary pressure gauge and a biocompatible sanitary pressure gauge and a biocompatible

Exhibit C
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gauge protector for isolation of said fluid from gauge protector 26 for isolation of said fluid

said sanitary pressure gauge; from said sanitary pressure gauge;

and said proximal end of said pressure fluid and said proximal end 22 of said pressure fluid

passageway being substantially the same passageway 12 being substantially the same

diameter as said distal end of said pressure diameter 23 as said distal end of said pressure

fluid passageway, therein providing a total fluid passageway, therein providing a total

transfer of fluid within said pressure fluid transfer of fluid within said pressure fluid

passageway during fluid flow. passageway during fluid flow. (This

embodiment is described on column 6, lines

48-56 in reference to FIG. 8. In FIG. 8, the

diameter at the absolute distal end of the fluid

passage is greater than at the proximal end.

Thus, “substantially the same” allows for some

leeway in the difference between the

diameters at the proximal and distal ends of

the pressure fluid passage)

8. The disposable sanitary gauge tee of claim 8. The disposable sanitary gauge tee of claim

Exhibit C
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1 for use in a process selected from the group 1 for use in a process selected from the group

consisting of aseptic filtration, upstream consisting of aseptic filtration, upstream

management of chromatography with management of chromatography with

disposable devices, capsule conditioning, disposable devices, capsule conditioning,

capsule flushing, viral clearance filtration or capsule flushing, viral clearance filtration or

processes, buffer filtration or flushes, processes, buffer filtration or flushes,

diafiltration, monitoring air blow-down of diafiltration, monitoring air blow-down of

process tubing or systems, aseptic process tubing or systems, aseptic

downstream pressure measurement of downstream pressure measurement of

filtration or validated processes, aseptic filtration or validated processes, aseptic

measurement of tangential flow filtration, measurement of tangential flow filtration,

disposable system production of disposable system production of

carcinogenic/oncological products, or any carcinogenic/oncological products, or any

other process with cleaning validation issues. other process with cleaning validation issues.

Exhibit C
-31-
 Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 25 of 29 Page ID #:35

FIG. 1 TBL Performance Plastics Tee

Exhibit C
-32-
Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 26 of 29 Page ID #:36

Exhibit D
 Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 27 of 29 Page ID #:37

Constantine Marantidis
Lewis Roca Rothgerber Christie LLP 655 North Central Avenue 626.795.9900 main Partner
Post Office Box 29001 Suite 2300 626.577.8800 fax Admitted in California
Glendale, CA 91209-9001 Glendale, CA 91203-1445 lrrc.com CMarantidis@lrrc.com

January 3, 2020

Via Email With Confirmation By Mail

sales@tblplastics.com

Robert DuPont
TBL Performance Plastics
18 White Lake Road
Sparta, New Jersey 07871

Re: U.S. Patent No. 7,373,825 entitled Gauge Tee Device

LRRC Ref. 408325-00300

Dear Mr. DuPont:

We are intellectual property counsel for Meissner Filtration Products, Inc. ("Meissner"). We
recently became aware of your new single-use instrument tee fittings, from a brochure entitled
“aSURE Instrument Fitting”, a copy of which is enclosed herein for your reference. While we
have not evaluated your new tee fittings, we would like to make you aware of U.S. Patent No.
7,373,825 (a copy of which is enclosed herein), owned by Meissner, which may cover such tee
fittings.

Please revert back to us with any questions, comments, or concerns, or if you are interested in
purchasing such tee fittings directly from Meissner.

Very truly yours,

Constantine Marantidis

CM/rl
Enclosures

Exhibit D
-33-
109755661_1
Albuquerque / Colorado Springs / Denver / Irvine / Las Vegas / Los Angeles / Phoenix / Reno / Silicon Valley / Tucson
Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 28 of 29 Page ID #:38

Exhibit E
Case 2:21-cv-02446 Document 1-1 Filed 03/19/21 Page 29 of 29 Page ID #:39

Exhibit E
-34-