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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN FEDERAL-MOGUL WORLD WIDE, INC.

, and FEDERAL-MOGUL CORPORATION, Plaintiffs, vs. NJT ENTERPRISES d/b/a MAYCO INTERNATIONAL LLC, and JVIS-USA LLC, Defendants. / JURY TRIAL DEMANDED Case No. Hon.

COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs FEDERAL-MOGUL WORLD WIDE, INC., and FEDERAL-MOGUL CORPORATION (collectively "Plaintiffs") by its undersigned attorneys, for their Complaint for Patent Infringement against Defendants NJT ENTERPRISES LLC d/b/a MAYCO

INTERNATIONAL LLC. (NJT) and JVIS-USA LLC (JVIS) (collectively Defendants) state as follows: JURISDICTION AND VENUE 1. This is an action for patent infringement arising under the patent laws of the United States, title 35 of the United States Code. The Court has subject matter jurisdiction under 28 U.S.C. 1331 and 1338(a). 2. This Court has personal jurisdiction over NJT and JVIS, as both defendants are incorporated in the State of Michigan. 3. Venue is proper in this district pursuant to 28 U.S.C. 1391(b) and (c), and 1400(b).

THE PARTIES 4. Plaintiff FEDERAL-MOGUL WORLD WIDE, INC., is a Michigan Corporation with a principal place of business located in Southfield, Michigan. 5. Plaintiff FEDERAL-MOGUL CORPORATION is a Delaware corporation with its principal place of business in Southfield, Michigan. 6. On information and belief, Defendant NJT is a Michigan corporation with a principal place of business located in Sterling Heights, Michigan. 7. On information and belief, Defendant JVIS is a Michigan corporation with a principal place of business located in Sterling Heights, Michigan. 8. On information and belief, Defendants JVIS and NJT are corporate affiliates and share a common interest. COUNT 1 INFRINGEMENT OF U.S. PATENT NO. 6,234,439 9. Plaintiffs repeat and reallege the allegations of paragraphs 1 through 8 as if set forth herein. 10. U.S. Patent No. 6,234,439 (the 439 patent), entitled Illuminated Cup Holder Assembly, was duly and legally issued on May 22, 2001, by the United States Patent and Trademark Office. FEDERAL-MOGUL WORLD WIDE, INC. owns the 439 patent by assignment and FEDERAL-MOGUL CORPORATION is FEDERAL-MOGUL WORLD WIDE, INCs licensee under the 439 patent. A true and correct copy of the 439 patent is attached hereto as Exhibit A. 11. NJT and JVIS have infringed and continue to infringe, literally or under the doctrine of equivalents, one or more claims of the 439 patent, directly, contributorily, and/or by inducement, by making, using, selling, and/or offering to sell in this country, without a

license, cup holder assemblies used in at least the Chrysler 2011 Jeep Grand Cherokee model, in violation of 35 U.S.C. 271. 12. On information and belief, Defendants NJT and JVIS acted in concert with one another to infringe the 439 patent. 13. Further discovery may reveal that the Defendants infringement of the 439 patent has been and continues to be willful and carried out with full knowledge of the 439 patent. 14. Plaintiffs have been and will continue to be damaged by Defendants infringement of the 439 patent. 15. Plaintiffs have been irreparably harmed by Defendants infringement of the 439 patent. Plaintiffs will continue to be irreparably harmed unless that infringement is enjoined. COUNT 2 BREACH OF CONTRACT 16. Plaintiffs repeat and reallege the allegations of paragraphs 1 through 15 as if set forth herein. 17. On or about October 1, 2009, FEDERAL-MOGUL CORPORATION entered into a Mutual Confidentiality Agreement (the MCA) with Mayco International, LLC (NJT). Under that agreement, NJT agreed not to reveal any of FEDERAL-MOGUL CORPORATIONs confidential information regarding the WK-LED Cup Holder to any third party or its subsidiaries, consultants, investors or employees. NJT also agreed not to exploit FEDERAL-MOGUL CORPORATIONs confidential information regarding the WK-LED Cup Holder for any purpose other than the design and engineering of the WKLED Cup Holder by FEDERAL-MOGUL CORPORATION. The MCA has specific and enforceable terms.

18.

On or about January 29, 2010, JVIS submitted a blanket purchase order to FEDERALMOGUL CORPORATION for illuminated cup holders. The blanket purchase order has specific and enforceable terms.

19.

In reliance on this purchase order, FEDERAL MOGUL CORPORATION expended over $440,000.00 in production tooling toward the JVIS blanket purchase order.

20.

On or about October 7, 2011, NJT cancelled FEDERAL-MOGUL CORPORATIONs contract with JVIS stating that NJT would mold and assemble the contracted cup holders themselves.

21.

On information and belief, NJT breached the MCA by exploiting FEDERAL-MOGUL CORPORATIONs proprietary information to make and sell illuminated cup holders.

22.

FEDERAL-MOGUL CORPORATION suffered damages as a result of NJTs breach of the MCA in an amount to be proven at trial.

23.

NJT and JVIS breached the blanket purchase order by cancelling the contract without compensating FEDERAL-MOGUL CORPORATION for the tooling and production costs incurred.

24.

On information and belief, Defendants NJT and JVIS acted in concert with one another to breach the MCA and blanket purchase order with FEDERAL-MOGUL

CORPORATION. 25. FEDERAL-MOGUL CORPORATION suffered damages as a result of Defendants breach of the blanket purchase order in an amount to be proven at trial. 26. Plaintiffs have suffered and will continue to suffer irreparable harm resulting from Defendants breach of the MCA and blanket purchase order.

COUNT 3 UNJUST ENRICHMENT 27. Plaintiffs repeat and reallege the allegations of paragraphs 1 through 26 as if set forth herein. 28. Defendants have received valuable benefits from Plaintiffs, i.e., the confidential and proprietary information sent to Defendants, and have used that information to create illuminated cup holder assemblies. providing that information. 29. Plaintiffs have been damaged by Defendants failure to compensate Plaintiffs, and Defendants gaining the benefit of Plaintiffs work without payment to Plaintiffs constitutes unjust enrichment in an amount to be proven at trial. RELIEF REQUESTED WHEREFORE, Plaintiffs respectfully requests the following relief: a. b. A judgment that Defendants have infringed the 439 patent; A preliminary and permanent injunction, issued pursuant to 35 U.S.C. 283, Defendants have not compensated Plaintiffs for

restraining and enjoining Defendants and their officers, agents, attorneys and employees, and those acting in privity or concert with them, from infringing the 439 patent for the full term thereof; c. d. e. A judgment that NJT breached the MCA; A judgment that NJT and JVIS breached the blanket purchase order agreement; A preliminary and permanent injunction restraining and enjoining Defendants and

their officers, agents, attorneys and employees, and those acting in privity or concert with them from using any of Plaintiffs proprietary or confidential information and technology obtained by Defendants pursuant to the MCA and blanket purchase order;

f.

An award of damages to Plaintiffs, including pre-judgment and post-judgment

interest, in an amount adequate to compensate for Defendants breach of the MCA and blanket purchase order agreement and Defendants infringement of the 439 patent, and if willful infringement is shown, treble damages pursuant to 35 U.S.C. 284; g. h. Costs and expenses in this action; A declaration that this is an exceptional case and an award of attorneys fees,

disbursements, and costs of this action pursuant to 35 U.S.C. 285; and i. such other and further relief as the Court may deem just and proper.

Respectfully submitted, HONIGMAN MILLER SCHWARTZ AND COHN LLP

By: /s/ J. Michael Huget___________________ J. Michael Huget (P39150) 130 S. First Street 4th Floor Ann Arbor, MI 48104-1386 (734) 418-4254 Salmaan T. Quader (P73649) 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8480 Dated: December 14, 2011

JURY DEMAND Plaintiffs Federal-Mogul World Wide, Inc., and Federal-Mogul Corporation hereby request a trial by jury of all issues so triable. Respectfully submitted, HONIGMAN MILLER SCHWARTZ AND COHN LLP

By:/s/J. Michael Huget ________________________ J. Michael Huget (P39150) 130 S. First Street 4th Floor Ann Arbor, MI 48104-1386 (734) 418-4254 Salmaan T. Quader (P73649) 39400 Woodward Avenue Suite 101 Bloomfield Hills, MI 48304-5151 (248) 566-8480 Dated: December 14, 2011
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