acolyte technologies v. jeja international et. al

8/4/2019 Acolyte Technologies v. Jeja International et. al.

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1317.010\9998Com laint

Mark D. Kremer (SB# 100978)[email protected]

CONKLE, KREMER & ENGELProfessional Law Corporation3130 Wilshire Boulevard, Suite 500Santa Monica, California 90403-2351

Phone: (310) 998-9100 Fax: (310) 998-9109

Steven [email protected]

Richard S. [email protected]

GOTTLIEB, RACKMAN & REISMAN, P.C.270 Madison AvenueNew York, New York 10016Telephone: (212) 684-3900Facsimile: (212) 684-3999

Attorneys for PlaintiffAcolyte Technologies Corporation

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA

ACOLYTE TECHNOLOGIESCORPORATION, a New York

corporation,

Plaintiff,

v.

JEJA INTERNATIONALCORPORATION LIMITED, a foreign

corporation; EVELYN KIM, anindividual; INHO KIM, an individual;CHOONG BIN LIM, an individual;SOOK JA LIM, an individual; CEONGLIM an individual; and DOES 1-10,

Defendants.

CIVIL ACTION NO.

COMPLAINT FORINFRINGEMENT OFU.S. PATENT NOS. D633,232 &D642,299 AND UNFAIRCOMPETITION

'11CV2012 CABMMA


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Plaintiff, Acolyte Technologies Corporation, (hereinafter plaintiff and/or

Acolyte), by way of its Complaint against the corporate defendant Jeja

International Corporation, Limited (Jeja), and individual defendants Evelyn Kim,

Inho Kim, Choong Bin Lim, Sook Ja Lim and Ceong Lim, all d/b/a La Bonita

(hereinafter collectively the individual defendants), and Does 1-10, alleges as

follows:

NATURE OF ACTION

1. Through the design of innovative LED lighting products, Acolytecreated and established a market for lighting products that are used to adorn and

lighten dcor and floral arrangements. Plaintiff is the recognized leader in this new

industry. As alleged herein, the defendants have slavishly copied and sold

plaintiffs original and protected product designs and engaged in acts of unfair

competition.

2. Through this action and the accompanying documents, plaintiff seeks apreliminary and permanent injunction against defendants. Plaintiff also seeks

damages for the willful, malicious and deliberate design patent infringement, unfair

competition and related wrongful activities. Plaintiffs claims arise and are asserted

under the patent laws of the United States, 35 U.S.C. 100 et seq., and the common

law.

THE PARTIES

3. Acolyte is a New York corporation, with an office and place ofbusiness located at 44 East 32nd Street, New York, New York 10016.


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4. Acolyte creates, designs, imports, and distributes LED lightingproducts throughout the United States and the world. Acolytes LED lighting

products are protected by patents and are well-known and recognized in the industry

and by the purchasing public.

5. Upon information and belief, defendant Jeja is a foreign corporationincorporated in Hong Kong and located at Flat/Rm 611 6/F Ricky CTR 36 Chong

Yip Street, Kwun Tong Kowloon, Hong Kong. As an integral part of its business

Jeja markets and sells LED lighting products for event and floral design to

importers, suppliers and also directly to wholesale customers throughout the United

States.

6. Upon information and belief, the individual defendants together dobusiness under the name La Bonita. Together, the individual defendants own and

operate a store that sells LED lighting products for event and floral design to local

customers. La Bonita is located at 693 Palomar Street, Chula Vista, California

91911.

7. Upon information and belief, defendants Does 1-10 are individualsand/or business entities whose identities are presently unknown to plaintiff. To the

extent their identities become known to plaintiff, the Doe defendants will be joined

and the activities in which they engaged will be further pleaded in an Amended

Complaint.

8. Upon information and belief, Does 1-10 are engaged in the business ofimporting and distributing LED lighting products for event and floral design which

are alleged herein to infringe Acolytes rights.


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9. Upon information and belief, Does 1-10 purchase infringing LEDlighting products from Jeja and sell those products to the individual defendants and

other individuals or entities in the United States. Accordingly, the identities of

Does 1-10 are known to Jeja, and one or more of Does 1-10 are known to the

individual defendants.

JURISDICTION AND VENUE

10. Upon information and belief, Jeja and the individual defendants dobusiness in the State of California and in the United States by selling LED lighting

products and other merchandise to customers in California and in the United States.

11. Upon information and belief, Jeja also does business in the State ofCalifornia by virtue of the interactive and non-passive website owned and operated

by it which is accessible and accessed by customers in the State of California, and

through which the products at issue herein are advertised, marketed and sold to

customers in California. The website owned and operated by Jeja is

www.jejahk.com.

12. Upon information and belief, all of the defendants reside and/ortransact business in this judicial district, and this Court therefore has personal

jurisdiction over defendants.

13. This Court has jurisdiction over the subject matter of this actionpursuant to 28 U.S.C. 1331 and 1338(a) and (b).

14. This Court has diversity jurisdiction over this dispute under 28 U.S.C1332 since this dispute exceeds $75,000 and is between citizens of different states.


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15. This Court has supplemental jurisdiction over the state law causes ofaction pursuant to 28 U.S.C. 1367.

16. Venue is proper in this district under 28 U.S.C. 1391(b) and (c),and/or 28 U.S.C. 1400(b).

FACTS COMMON TO ALL COUNTS

A. ACOLYTES INTELLECTUAL PROPERTY RIGHTS

17. Prior to Acolytes entry into the marketplace, there were an extremelylimited number of products available that were effective in visually enhancing an

event or floral arrangement for a reasonable cost. The dearth of desirable products

led to a need for elegant and innovative lighting products that could be used to adorn

and lighten the environment, dcor and floral arrangements.

18. After its inception in 2002, Acolyte addressed this need by creating,designing, manufacturing, marketing and selling its new and original wireless LED

lighting products.

19. Acolytes products were and continue to be meticulously designed andengineered according to Acolytes product specifications, using Acolytes own

product molds. The design and engineering process was and continues to be apainstaking process that often takes about year to conclude from the time of

conception through to completion, with multiple revisions along the way. Acolytes

products are constructed using high-quality materials and electronic components

that meet Acolytes specifications and demands for quality and excellence that are

only found in authentic Acolyte products.


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20. Through the hard work of its management and dedicated employees,Acolyte developed an extremely successful business designing, manufacturing,

marketing, and selling many different types of LED lighting products on a

wholesale basis throughout the United States and in various markets around the

world.

21. As a result, many LED lighting products sold by Acolyte have enjoyedtremendous success and notoriety with its customers. Among Acolytes greates

successes is its original waterproof LED lighting device marketed under the

trademark SUBMERSIBLE since 2005.

22. Acolyte regularly markets, advertises and promotes itsSUBMERSIBLE products in industry publications such as Flowers &, Florists

Review and other print publications. Acolyte also attends and participates in

various trade shows throughout the United States.

23. In addition to Acolytes own advertising in industry and trademagazines and at trade shows throughout the United States, Acolyte also utilizes a

group of independent sales representatives that market and promote Acolytes

SUBMERSIBLE product line to customers across the United States on behalf of

and for the benefit of Acolyte.

24. As a result of its own advertising and promotional activities and thoseof its sales representatives, as well as its own commercial success, Acolyte has built

up a significant amount of goodwill under its SUBMERSIBLE product line in the

industry and with its customers.


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Acolytes Design Patent Rights

25. In recent years, Acolyte has expanded its SUBMERSIBLE productline and sought to protect a number of its newer designs via design patents. In

particular, since 2009, Acolyte has filed numerous applications for design protection

in the United States and in a number of countries throughout the world, including

China, Japan, Europe and Canada.

26. As a result of Acolytes design application filing program, many ofAcolytes newer LED lighting products are already protected by design patents (or

analogous forms of protection) in the United States, Europe, China, Canada and

Japan.

27. For example, one of Acolytes designs is covered by U.S. DesignPatent No. D 633,232 and is entitled Lighting Device (the 232 patent). The

application for the 232 design patent was filed on November 10, 2009. On

February 22, 2011, the U.S. Patent Office issued the 232 patent which claimed the

ornamental design for a lighting device as shown and described. A copy of this

patent is attached hereto as Exhibit A. An illustration of the lighting device that is

shown and protected by the 232 patent is presented below:


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1317.010\9998-7-Com laint

28. Another related Acolyte design is covered by U.S. Design Patent NoD 642,299 and is entitled Lighting Device (the 299 patent). The application for

the 299 design patent was filed on April 30, 2010. On July 26, 2011, the U.S

Patent Office issued the 299 patent which claimed the ornamental design for a

lighting device as shown and described. A copy of this patent is attached hereto as

Exhibit B. An illustration of the lighting device that is shown and protected by the

299 patent is presented below:


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29. One of the Acolyte products that embodies the designs shown andclaimed in the 232 patent and the 299 patent is the Acolyte SUB-9 lighting

device which is shown below:

30. The SUB-9 is a waterproof lighting device having an array of LEDsdisposed within a translucent, plastic housing. The SUB-9 lighting device

represents one of a number of LED lighting products added to Acolytes

SUBMERSIBLE product line.


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B. DEFENDANT JEJA INFRINGES ACOLYTES DESIGN PATENTRIGHTS

31. Upon information and belief, the corporate defendant Jeja InternationalCorp. manufactures, advertises and sells LED lighting devices to supplier(s) and

customers located in the United States that infringe the 232 patent and the 299

patent.

32. Jejas infringing products are advertised on its website located atwww.jejahk.com. A copy of Jejas website showing the infringing products is

attached hereto as Exhibit C.

33. The infringing lighting devices advertised and sold by Jeja are a virtualcopy of the designs that are protected by Acolytes 232 patent and the 299 patent

(Copycat SUB-9 Lighting Device).


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1317.010\9998-10-Com laint

34. For comparison, a photograph of the Copycat SUB-9 Lighting Deviceas advertised and sold by Jeja through its website is shown beside the designs

protected by the 232 patent and the 299 patent:

COPYCAT SUB-9 232 DESIGN PATENT


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35. Moreover, a true and accurate electronic copy of Jejas quotation sheet with prices and minimum order quantities (MOQ) depicting the Copycat SUB-

9 Lighting Device and a 14-LED version thereof is attached hereto as Exhibit D.

36. A photograph of the Copycat SUB-9 Lighting Device as depicted in theJeja quotation sheet is depicted below:


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1317.010\9998-12-Com laint

37. Jejas Copycat SUB-9 Lighting Device and the infringing 14-LEDversion thereof are available for viewing on the web on Jejas website at

http://www.jejahk.com/en/pro.asp?action=overmore.

38. Upon information and belief, Jeja manufactures markets and sellsinfringing lighting devices, such as the Copycat SUB-9 Lighting Device and the 14-

LED version thereof, to U.S. importers and U.S. wholesale distributors directly, via

email and through its website www.jejahk.com.

39. As readily apparent from the illustrations and pictures shown hereinthe Copycat SUB-9 Lighting Device and the 14-LED version thereof, which are

marketed and sold by Jeja, share the same design features claimed in the 232 patent

and the 299 patent.

40. Upon information and belief, based on the similarities between theCopycat SUB-9 Lighting Device and the 14-LED version thereof, which are


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1317.010\9998-13-Com laint

marketed and sold by Jeja, and the designs shown in the 232 patent and the 299

patent, an ordinary observer would be deceived into believing that the Copycat

SUB-9 Lighting Device and the 14-LED version thereof are the patented product

shown in these patents.

41. Upon information and belief, Jeja is presently shipping a significantamount of infringing products into the United States.

42. Upon information and belief, a specific shipment of infringing productsbelieved to be originating from Jeja is currently on a ship scheduled to arrive in the

United States in September 2011. This particular shipment is more fully discussed

in Plaintiffs motion for expedited relief which is filed concurrently with this

Complaint.

C. THE INDIVIDUAL DEFENDANTS INFRINGE ACOLYTES DESIGNPATENT RIGHTS

43. The individual defendants, through their business La Bonita, market,promote and sell the lighting devices manufactured by Jeja described herein.

44. For comparison, a photograph of the Copycat SUB-9 Lighting Deviceas sold by the individual defendants is shown beside the designs protected by the

232 patent and the 299 patent:


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45. Upon information and belief, the individual defendants, through theirbusiness La Bonita, purchased the Copycat SUB-9 Lighting Device from a supplier

of Jejas products who is currently unidentified but who is known to the individual

defendants.

D. ACOLYTE WILL SUFFER IRREPARABLE HARM

46. Upon information and belief, all of the defendants identified hereindirectly compete with Acolyte in connection with the sale of LED lighting devices

for event design.

47. Upon information and belief, defendants have sold and offered for salethe Copycat SUB-9 Lighting Device to companies and individuals that would

otherwise have purchased authentic SUB-9, SUBMERSIBLE and other related

products from Acolyte or an authorized distributor of Acolyte.

48. Upon information and belief, the importation, sale and offer for sale bydefendants of infringing LED lighting products is with full knowledge of Acolytes

patent rights and business operations.

49. Upon information and belief, the importation, sale and offer for sale bydefendants of infringing LED lighting products is done with intent to unfairly

compete with Acolyte.

50. Acolyte and defendants are direct competitors vying for the business ofthe same or substantially the same group of customers.


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51. By their infringing acts, defendants have irreparably harmed Acolyteand such injury will continue and grow unless defendants are enjoined by this Court

52. Acolyte has built its reputation on the quality and the uniqueness of itsproducts.

53. The infringing products accused herein are more cheaply constructedand more cheaply priced than the authentic products manufactured and sold by

Acolyte.

54. Defendants importation, distribution, sale and offer for sale of theinfringing products accused herein, as well as other copycat products, have created

and will continue to create confusion, irreparably damaging Acolytes reputation

and goodwill.

55. Defendants importation, distribution, sale and offer for sale of theinfringing products accused herein, as well as other copycat products, has

irreparably decreased and will continue to irreparably decrease the size of Acolytes

market share and, if not enjoined, will cost Acolyte its position as the market leader.

56. Defendants importation, distribution, sale and offer for sale of theinfringing products accused herein, as well as other copycat products, will result in

reduced cash flow to Acolyte and irreparable price erosion of Acolytes patentedproducts in that Acolyte will be forced to drastically change its pricing structure in

order to compete with lower-priced, knock-off products.

57. If defendants are not enjoined from infringing the 232 patent and the299 patent, other potential competitors will be encouraged to distribute knock-off


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products resembling those in the asserted patents, and will flood the market with

even more cheaply-made and cheaply-priced copycat products. Some of these

potential competitors are Acolytes own current customers.

58. If defendants are enjoined from infringing the 232 patent and the 299patent, other infringing competitors will be deterred from continuing to infringe

Acolytes patents and will be deterred from doing so in the future.

59. If defendants are not enjoined from infringing the 232 patent and the299 patent, Acolyte will lose sales of related products that are not protected by

Acolytes patents and/or other forms of intellectual property.

60. Due to defendants actions, Acolyte is deeply concerned that it will losea number of customers.

61. Because of Acolytes business and reputation, as well as the value of itspatents, Acolyte will be irreparably harmed if defendants are not enjoined, and

money damages cannot sufficiently compensate Acolyte for the damage caused by

defendants infringing acts.

62. In contrast, none of the defendants will suffer any recognizableirreparable harm if they are enjoined.

COUNT I

(Patent Infringement of U.S. Patent D 633,232)

63. Acolyte hereby repeats and re-alleges paragraphs 1 through 63 above asif fully set forth herein.


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64. The 232 patent, was legally issued on February 22, 2011 and isentitled Lighting Device.

65. Acolyte is the owner, by assignment, of all right, title and interest inand to the 232 patent.

66. Upon information and belief, defendants have manufactured, importeddistributed offered for sale and/or sold, and continue to manufacture, import

distribute, offer for sale and/or sell LED lighting devices that infringe the 232

patent.

67. Defendants have been and continue to infringe the 232 patent bymanufacturing, importing, distributing, offering for sale and/or selling lighting

devices embodying the patented invention claimed in the 232 patent and/or will

continue to do so unless enjoined by this Court.

68. The infringement by defendants of the 232 patent is in direct violationof Acolytes right under 35 U.S.C. 271 to exclude others from making, using

selling and/or offering for sale products embodying the invention of the 299 patent.

69. Upon information and belief, each infringement has been willful anddeliberate.

70. Acolyte has been damaged by defendants infringements of the 232patent, in an amount to be determined at trial and in an amount adequate to

compensate plaintiffs injuries.


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71. Acolyte is entitled to an accounting for damages from defendants forthe infringement of the 232 patent.

72. The infringement of the 232 patent by defendants has caused Acolyteto suffer irreparable harm and injury. Acolyte will continue to suffer irreparable

harm unless an injunction is issued enjoining and restraining defendants from

infringing the 232 patent.

73. Acolyte has been damaged by the acts of defendants in an amount asyet unknown, but on information and belief, has caused damage or will cause

damage to Acolyte in excess of one million dollars ($1,000,000)

74. Acolyte has no adequate remedy at law.

COUNT II

(Patent Infringement of U.S. Patent D 642,299)


76. The 299 patent, was legally issued on July 26, 2011 and is entitledLighting Device.

77. Acolyte is the owner, by assignment, of all right, title and interest inand to the 299 patent.

78. Upon information and belief, defendants have manufactured, importeddistributed offered for sale and/or sold, and continue to manufacture, import


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distribute, offer for sale and/or sell LED lighting devices that infringe the 299

patent.

79. Defendants have been and continue to infringe the 299 patent bymanufacturing, importing, distributing, offering for sale and/or selling lighting

devices embodying the patented invention claimed in the 299 patent and will

continue to do so unless enjoined by this Court.

80. The infringement by defendants of the 299 patent is in direct violationof Acolytes right under 35 U.S.C. 271 to exclude others from making, using

selling and/or offering for sale products embodying the invention of the 299 patent.

81. Upon information and belief, each infringement has been willful anddeliberate.

82. Acolyte has been damaged by defendants infringements of the 299patent, in an amount to be determined at trial and in an amount adequate to

compensate plaintiffs injuries.

83. Acolyte is entitled to an accounting for damages from defendants forthe infringement of the 299 patent.

84. The infringement of the 299 patent by defendants has caused Acolyteto suffer irreparable harm and injury. Acolyte will continue to suffer irreparable

harm unless an injunction is issued enjoining and restraining defendants from

infringing the 299 patent.


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COUNT III

(Unfair Competition and Misappropriation under the Common Law)


88. Defendants unlawful and improper actions as set forth hereinmisappropriate and trade upon the fine reputation and goodwill of Acolyte, thereby

injuring that reputation and goodwill, and unjustly diverting from Acolyte to

defendants the sales and benefits rightfully belong to Acolyte.

89. Defendants unlawful activities constitute unfair competition andmisappropriation as proscribed by the common law.

90. Defendants acts of unfair competition and misappropriation havecaused Acolyte to sustain monetary damage, loss and injury.

91. Defendants have engaged and continue to engage in these activitiesknowingly and willfully.


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92. Defendants acts of unfair competition and misappropriation, unlessenjoined by this Court, will continue to cause Acolyte to sustain irreparable damage

loss and injury.




PRAYER FOR RELIEF

WHEREFORE, Acolyte respectfully prays for judgment against defendants

as follows:

With respect to Counts I&II:

A. That the 232 patent and the 299 patent were duly and legally issuedare valid and are enforceable;

B. That defendants have directly infringed, contributorily infringed and/orinduced the infringement of the 232 patent and the 299 patent;

C. That defendants have willfully infringed the 232 patent and the 299patent;


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With respect to Count III:

D. That defendants are liable for and unfairly competing andmisappropriating;

With respect to all Counts:

E. That this Court enter a preliminary and permanent injunction againstdefendants (and each of their affiliates, officers, agents, servants, employees and

attorneys, and all persons in active concert or participation with them)

1) enjoining defendants from committing further acts of infringement ofthe 232 patent and the 299 patent;

2) enjoining defendants from engaging in any acts of common law unfaircompetition or misappropriation which would damage or injure

plaintiff; and

3) enjoining defendants from inducing, encouraging, instigating, aidingabetting or contributing to any third-party usage of Acolytes design

patents in connection with defendants business.

F. That defendants deliver and/or destroy all materials, packaging, labels,tags, pamphlets, brochures, signs, sales literature, stationary, advertisements

contracts, billboards, banners, posters, documents, as well as all plates, molds,

matrices, negatives, masters and all other means of making products which if used

would violate the terms of the Order herein granted;


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Exhibit No.

Table of Exhibits

Description Pages

A United States Design Patent US D633,232, Lighting Device,

dated February 22, 2011

26-30

B United States Design Patent US D642,299, Lighting Device,

dated July 26, 2011

31-35

C Jeja Website Capture http://www.jejahk.com 36-38

D Jeja Quote Sheet for Submersible LED Light 39-43


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'11CV2012 CAMMA

acolyte technologies v. jeja international et. al

Documents