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, Plaintiff, Electronic Filing v. THORLEY INDUSTRIES, LLC (D/B/A 4MOMS), Defendant. Jury Trial Demanded COMPLAINT Plaintiff Wonderland Nurserygoods Co., Ltd., for its Complaint for Patent Infringement against Thorley Industries LLC (d/b/a 4moms), hereby states as follows: JURISDICTION AND VENUE 1. This is a civil action for infringement of United States Patent No. 8,047,609 ("the C.A. No.: The Hon.

`609 patent"). This action is based upon the Patent Laws of the United States, Title 35, United States Code, including 35 U.S.C. 271 and 281-285. Jurisdiction is conferred on this Court pursuant to 28 U.S.C. 1331 and 1338(a). 2. This Court has personal jurisdiction over Thorley Industries, LLC (d/b/a 4moms)

("Defendant") because Defendant is a resident of this judicial district, has conducted business and sells its products in this judicial district and, furthermore, Defendant has committed acts of infringement in this judicial district by using, advertising, marketing, offering for sale, and selling products that infringe the '609 patent in this judicial district. 3. Venue is proper in this district under 28 U.S.C. 1391(b) and/or (c), and 28

U.S.C. 1400(b), because, inter alia, Defendant is subject to personal jurisdiction in this District. 1

THE PARTIES 4. Wonderland is a limited liability company organized and existing under the laws

of Taiwan ROC, having a place of business at 10F, NO.433, Rui Kwang Road, Neihu Taipei, Taiwan. 5. patent. 6. On information and belief, Defendant is a limited liability corporation organized Wonderland is the owner of and has the right to sue for infringement of the '609

under the laws of the State of Pennsylvania, having a place of business at 40 24 th Street, Pittsburgh, Pennsylvania 15222. 7. Defendant designs, builds, distributes, markets, sells, and/or offers for sale, in the

United States and in this District, products for infants and young children, including the "mamaRoo" variable motion infant seat. BACKGROUND 8. On November 1, 1993, the '609 Patent, entitled "Infant Rocking Chair and

Driving Device for Driving the Same" was duly and legally issued to Wonderland as assignee. The named inventors of the '609 Patent are Shun-Min Chen and Jun-Xu Jin. A copy of the '609 Patent is attached hereto as Exhibit "A". 9. Defendant has and continues to make, use, sell, and offer for sale in the United

States, and import into the United States, infant rocking chairs (the "Accused Product"), including but not limited to the "mamaRoo" variable motion infant seat. 10. The Accused Product includes a driving device for an infant rocking chair

comprising a first motion mechanism and a second motion mechanism that work in cooperation to impart a curved swinging motion with both back-and-forth and up-and-down motion. 2

Photographs of an example of the Accused Product and its driving device are attached hereto as Exhibit "B". CLAIM FOR RELIEF (INFRINGEMENT OF U.S. PATENT NO. 8,047,609) 11. 12. Paragraphs 1-10 are incorporated by reference as if restated fully herein. By making, using, selling, and offering for sale in the United States, and

importing into the United States, the Accused Product, Defendant has infringed and is continuing to infringe on at least one claim of the '609 Patent in violation of 35 U.S.C. 271. 13. By reason of the ongoing and continuous infringement by Defendant of the '609

Patent, Wonderland is entitled to an entry of an injunction against Defendant, preventing further infringement of Wonderland's patent rights, pursuant to 35 U.S.C. 283. 14. Wonderland has suffered and is continuing to suffer damages as a result of

Defendant's infringement of the '609 Patent, and Wonderland is entitled to compensation or other damages as allowed to the full extent of the law, pursuant to 35 U.S.C. 284. PRAYER FOR RELIEF WHEREFORE, Wonderland respectfully requests entry of relief against Defendant as follows: (a) Entering judgment that Defendants, by reason of the making, using, selling, and offering for sale in the United States, and the importing into the United States, of the Accused Product, infringe the '609 Patent in violation of 35 U.S.C. 271; (b) Awarding Wonderland damages to the full extent permitted by 35 U.S.C. 284, including interest, by reason of Defendant's infringement of the '609 Patent;


Entering a permanent injunction against Defendant, barring and enjoining further making, using, selling, and offering for sale in the United States, and importation into the United States, of all infringing products; and,


Awarding Wonderland costs and fees under 35 U.S.C. 285, and all other relief as this Court deems proper.

Pursuant to Federal Rule of Civil Procedure 38(b), Wonderland hereby demands a trial by jury on all issues triable of right by a jury.

Date: February 16, 2012 Avrum Levicoff, E quire Pa. I.D. #: 26044 Edward I. Levicoff, Esquire Pa. I.D. #: 200108 Levicoff, Silko & Deemer, P.C. Centre City Tower, Suite 1900 650 Smithfield Street Pittsburgh, PA 15222-3911 Telephone: 412-434-5200 Facsimile: 412-434-5203 ATTORNEYS FOR PLAINTIFF, WONDERLAND NURSERYGOODS CO., LTD.