bliss holdings v. american d.j. supply

8/2/2019 Bliss Holdings v. American D.J. Supply

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COMPLAINT FOR PATENT INFRINGEMENT

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Richard A. Clegg (SBN 211213)

LAW OFFICE OF RICHARD CLEGG

501 West Broadway, Suite 800

San Diego, California 92101

Telephone: (619) 400-4920

[email protected]

Counsel for Plaintiff

Bliss Holdings LLC

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF CALIFORNIA

BLISS HOLDINGS LLC, a CaliforniaCorporation,

Plaintiff,

v.

AMERICAN D.J. SUPPLY, INC., aCalifornia Corporation,

Defendant.

CIVIL ACTION NO. __________________

COMPLAINT FOR PATENT

INFRINGEMENT

Plaintiff Bliss Holdings LLC (BLISS) alleges as follows for its complaint

against defendant American D.J. Supply, Inc. (ADJ):

PARTIES

1. BLISS is a limited liability corporation organized and existing under thelaws of the State of California, with a primary place of business at 745 South Vinewood

Street, Escondido, CA.

2. ADJ is a corporation organized and existing under the laws of the State ofCalifornia, with a principal place of business at 6122 S. Eastern Avenue, Commerce, CA.

__________________'12 CV1128 BLMJAH

Case 3:12-cv-01128-JAH-BLM Document 1 Filed 05/08/12 Page 1 of 10


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JURISDICTION AND VENUE

3. This is an action for patent infringement, arising under the patent laws ofthe United States, including 35 U.S.C. 271 et seq. This court has subject matter

jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a).

4. ADJ is subject to personal jurisdiction in this judicial district because,BLISS is informed and believes and on that basis alleges, ADJ has sold its accused

products to customers within this judicial district; has placed its accused products into the

stream of commerce, through established distribution channels, knowing or reasonably

foreseeing that the products would be sold to customers within this judicial district; and

has offered the accused products for sale to customers within this judicial district, via an

interactive web site through which the products can be purchased from within this

judicial district.

5. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b),(c) and 1400.

FIRST CAUSE OF ACTION

INFRINGEMENT OF U.S. PATENT NO. 8,057,045

6. BLISS is the owner of United States Patent No. 8,057,045 ("the 045Patent"), entitled "Star Field Projection Apparatus", which was issued by the United

States Patent and Trademark Office on November 15, 2011. A true and correct copy of

the 045 Patent is attached as Exhibit A.

7. ADJ has infringed the 045 Patent by, inter alia, selling and offering to selllaser light projection products that are covered by one or more patent claims of the '045

Patent, within the United States, during the term of the 045 Patent, without BLISSs

authorization. The accused ADJ products (collectively, the Accused Products) include:

(a) the Micro 3D; (b) the Royal 3D; (c) the Galaxian; (d) the Galaxian 3D; and (e) the

Galaxian Royale.



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8. Each of the Accused Products includes all the elements of at least onepatent claim of the 045 Patent. Each of the Accused Products is a laser light projection

apparatus that generates a moving field of pinpoint lights. Each of the Accused Products

includes a laser that is powered by a power supply. In each of the Accused Products, the

laser is positioned to direct light through a first wheel and a second wheel. The first

wheel is a diffractive optical element. The first wheel is positioned between the laser and

the second wheel. The second wheel is a grating wheel that is rotated by an electrically

powered motor.

9. BLISS has suffered monetary damages as a result of ADJs acts ofinfringement.

10. BLISS has suffered irreparable harm as a result of ADJs acts ofinfringement and will continue to suffer irreparable harm unless and until ADJ is

enjoined from committing further acts of infringement.

PRAYER FOR RELIEF

WHEREFORE, BLISS prays for the Court to grant BLISS the following relief:

1. Enter judgment that ADJ has directly infringed the '045 Patent and award

monetary damages to BLISS that are adequate to compensate it for ADJs infringement,

along with prejudgment interest;

2. Enter an injunction to prevent further infringements by ADJ or any other

persons acting in concert with ADJ;

3. Award BLISS its costs of suit in connection with this action;

4. Grant BLISS such other and further relief as the Court deems proper.

[SIGNATURE ON NEXT PAGE]



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Respectfully submitted,

Dated: May 8, 2012 /s Richard A. Clegg/___________________________________

Richard A. Clegg

E-mail: [email protected]



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'12 CV1128 BLMJAH


bliss holdings v. american d.j. supply

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