man-q v. conair - complaint

8/20/2019 Man-Q v. Conair - Complaint

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I N T H E U N I TE D S T AT E S D I ST R IC T C O U R T

F O R T H E E A S T E R N D I S T R I C T O F V I R G I N I A

Man-Q Corp.,

Pla in t i f f

V .

Conair Corp.,

Defendan t

i::: c : t : g p u: 13

Civ i l A c t i o n N o

J U RY T R I A L D E M A N D E D

C O M P L A I N T F O R PAT E N T I N F R I N G E M E N T

PlaintiffMan-Q Corp. ( Man-Q ), by and through its attorneys, for its complaint against

Defendant Conair Corp. ( Conair ) alleges as follows:

N AT U R E O F T H E A C T I O N

1. This is a patent infringement action arising under the Patent Laws of the United

States, Title 35, Section 1, et. seq.

T H E PA R T I E S

2. PlaintiffMan-Q is a Taiwanese corporation having its principal place of business

at 7/F, No. 17, Siping St., Chungshan Dist., Taipei City, Taiwan.

3. Man-Q was founded by Mr. Kai-Mou Tsai, a prolific innovator and manufacturer

of hair care products and accessories who is the named inventor of over 50 patents granted by the

United States Patent and Trademark Office ( USPTO ). Man-Q is the assignee of a number of

U.S. patents invented by Mr. Tsai as well as Mr. Shih-Ling Hsu, a fellow Taiwanese inventor in

the hair care product and accessory industry.

Case 1:15-cv-01367-LMB-TCB Document 1 Filed 10/20/15 Page 1 of 10 PageID# 1


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4. Upon information and belief, Defendant Conair is a corporation organized and

existing under the laws of Delaware, with its principal place of business located at 1 Cummings

Point Road, Stamford, CT 06902.

5. Upon information and belief, Conair sells hair accessories under its own name

and as Scunci,®a division of the Conair Corporation,with sales in the United States, includingin

th is district .

J U R I S D I C T I O N A N D V E N U E

6. This is a patent infringement action arising under the Patent Laws of the United

States, Title 35, Section 1, et. seq. This court has subject matterjurisdiction under 28 U.S.C. §§

1331,1332, and 1338(a).

7. Venue is proper under 28 U.S.C. § 1391(b), 35 U.S.C. § 293, and/or Va. Code

Ann. § 8.01-328.1.

8. Venue is proper in this District under 28 U.S.C. § 1391(b) because Defendant

Conair maintains substantial, continuous and systematic contacts within the Commonwealth of

Virginia. Conair thus has purposefully availed itself of the privilege of conducting activities in

this judicial district and division, thereby invoking the benefits and protections of the laws of the

Commonwealth of Virginia.

9. Defendant Conair, directly or through intermediaries (including distributors,

retailers, subsidiaries, affiliates, agents, and others) ships, distributes, offers for sale, sells, and/or

advertises its products relating to hair accessories in the United States, the State of Virginia, and

the Eastern District of Virginia. On information and belief, Conair has committed acts of patent

infringement in Virginia including offering for sale and/or selling infringing hair accessory

products in Virginia and the Eastern District of Virginia. Conair's products have been sold and



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used in Virginia and the Eastern District of Virginia, and on information and belief, continue to

be purchased and used by consumers in Virginia and the Eastern District of Virginia. In

addition, Conair operates a retail website at http://www.conair-store.com where it advertises,

offers to sell, and sells various Conair products directly to consumers, including those located in

the Eastern District of Virginia.

10. Pursuant to 35 U.S.C. § 293, the Eastern District of Virginia has jurisdiction of a

nonresident patentee such as Man-Q, regarding its U.S. patents or rights thereunder.

B A C K G R O U N D

T h e P a t e n t s

11. U.S. Design Patent No. D391,020 (the '020 patent ), titled Hair Clip, was duly

issued by the United States Patent and Trademark Office ( USPTO ) on February 17, 1998. Mr.

Tsai is the sole inventor listed on the face of the '020 patent. Mr. Tsai assigned his rights in the

'020 patent to Man-Q. Man-Q is the legal owner of the '020 patent and has the entire right, title

and interest in and to the '020 patent. A true and correct copy of the '020 patent is attached as

Exhib i t 1.

12. U.S. Design Patent No. D404,524 (the '524 patent ), titled Hair Clasp, was

duly issued by the USPTO on January 19,1999. Mr. Tsai is the sole inventor listed on the face

of the '524 patent. Mr. Tsai assigned his rights in the '524 patent to Man-Q. Man-Q is the legal

owner of the '524 patent and has the entire right, title and interest in and to the '524 patent. A

true and correct copy of the '524 patent is attached as Exhibit 2.

13. U.S. Design Patent No. D627,509 (the '509 patent ), titled Hair Raiser, was

duly issued by the USPTO on November 16, 2010. Mr. Tsai is the sole inventor listed on the

face of the '509 patent. Mr. Tsai assigned his rights in the '509 patent to Man-Q. Man-Q is the



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18. On information and belief, during the term of the '524 patent, Conair and its

Scunci division manufactured, marketed, or sold in the United States, or imported into the United

States, hair clasps that fall within the scope of the '524 patent, including those made of metal

wi th a chain- l ink adornmen t .

19. On information and belief, Conair and its Scunci division manufacture, market, or

sell in the United States, or import into the United States, hair raisers that fall within the scope of

the '509 patent, including at least hair raisers having product numbers 20034-W and 55768-P.


sell in the United States, or import into the United States, hair retainers that fall within the scope

of the '296 patent, including at least hair retainers having the product number 39046-A.


sell in the United States, or import into the United States, hair bands that fall within the scope of

the '815 patent, including at least hair bands having product numbers 39202-A, 39445-A, and

39642-A.


sell in the United States, or import into the United States, hair ornaments that fall within the

scope of the '982 patent, including at least hair ornaments having the product number 38277-A.

23. On information and belief, the acts of infringement by Defendant Conair and its

S c u n ci d i v is i o n h av e b ee n a nd cont inue to b e in tent ional and wil l fu l .

C O U N T 1 - P AT EN T I N FR I N G EM E N T O F U.S . D E S I G N PAT E N T N O . D 3 9 L 0 2 0

24. Plaintiff Man-Q re-alleges and incorporates paragraphs 1-23 of this Complaint.

25. Upon information and belief. Defendant Conair and its Scunci division have

infringed the '020 patent by manufacturing, marketing, and selling in the United States, or



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importing into the United States, one or more of the hair clips identified in this Complaint,which

embody the design covered by the '020 design patent.

26. Defendant Conair's acts of infringement have caused damage to Man-Q.

27. On information and belief, the acts of infringement by Defendant Conair have

been intentional and willful, making this case exceptional and entitling Man-Q to increased

damages and other reliefpursuant to35U.S.C.§§284 and 285.

C O U N T 2 - P AT EN T I N FR I N G EM E N T O F U.S. D E S I G N PAT E N T N O . D404 .524



infringed the '524 patent by manufacturing, marketing, and selling in the United States, or

importing into the United States, one or more of the hair clasps identified in this Complaint,

which embody the design covered by the '524 design patent.

30. Defendant Conair's acts of infringement have caused damage to Man-Q.



damages and other reliefpursuant to 35 U.S.C. §§ 284 and 285.

C O U N T 3 - PAT E N T I N F R I N G E M E N T O F U.S. D E S I G N PAT E N T N O . D627 .509



infringed and continue to infringe the '509 patent by manufacturing, marketing, and selling in the

United States, or importing into the United States one or more of the hair raisers identified in this

Complaint, which embody the design covered by the '509 design patent.



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34. Defendant Conair's acts of infringement have caused damage to Man-Q and will

continue to do so unless and until enjoined.




C O U N T 4 - P AT E N T I N F RI N G EM E N T O F U.S. D E S I G N PAT E N T N O . D635 ,296


37. Upon information and belief, Defendant Conair and its Scunci division have


United States, or importing into the United States one or more of the hair raisers identified in this







C O U N T 5 - P AT EN T I N FR I N GE M E N T O F U.S. D E S I G N PAT E N T N O . 0 6 6 8 , 8 1 5




United States, or importing into the United States one or more of the hair bands identified in this




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C O U N T 6 - P A T EN T I N FR I N G EM E N T O F U.S . PAT E N T N O . 8 . 1 6 L 9 8 2




United States, or importing into the United States one or more of the hair ornaments identified in

this Complaint, which are covered by the '815 design patent.






E X C E P T I O N A L C A S E

48. This case is exceptional within the meaning of 35 U.S.C. § 285. PlaintiffMan-Q

is entitled to an award of its attorneys' fees in connection herewith.

J U R Y D E M A N D

49. Plaintiff Man-Q requests a jury for all issues so triable in connection with this

m a t t e r .



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P R A Y E R F O R R E L E F

WHEREFORE, Plaintiff Man-Q prays for a judgment against Defendant Conair, as

follows:

a. A judgment that Defendant Conair has infringed the '020, '524,'509, '296, '815,

and '982 patents, and that such infringement was willful;

b. An award of damages to Plaintiffagainst Conair for infringement of the '020,

'524, '509, '296, '815, and '982 patents under 35 U.S.C. § 284 and/or § 289;

c. In the event Plaintiffelects to recover damages under 35 U.S.C. § 284, an increase

of the sums awarded to Plaintiff to three times actual damages, according to 35 U.S.C. § 284;

d. That Conair, its officers, agents, and employees be permanently enjoined from

infringing the '509, '296, '815, and '982 patents;

e. A declaration that Plaint iffMan-Q's case against Conair is an exceptional case

pursuant to 35 U.S.C. § 285 and therefore subject to attorneys' fees;

f An award of costs and attorneys' fees to Man-Q; and

g. Such other relief as the Court deems just and reasonable.



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Dated: October 20 , 2015

Respectfully submitted,

D G K e y I P G r o u p

Berna rc r J . D i M u r o

Virginia Bar No. 18784Sara SakagamiVirginia Ba r No. 77278D i M u r o G i n s b e r g P. C .

1101 King Street, Suite 610Alexandria, Virginia 22314Phone: (703) 684-4333Fax: (703) 548-3181

Emai l : bd imuro@dimuro . com:[email protected]

Cecil E. Key, Esq.Virginia Bar No. 41018K ey IP L aw Group , PLLC1934 Old Gallows R oa d, S u it e 35 0

Vienna, Virginia 22182Phone: (703)752-6276Fax: (703)752-6201Email: [email protected]

Attorneys fo r PlaintiffMAN-Q CORPORATION

10



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E x h i b i t 1

Case 1:15-cv-01367-LMB-TCB Document 1-1 Filed 10/20/15 Page 1 of 57 PageID# 11


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United States Patent twiTkai

[54] HAIR C U P

P6 ] Inventor Kai-Mou Tsai . 4/F.. No. 1. Lane 135,Tao-HsiangRd., PeitouDist. Ta )̂eiCity. Taiwan

♦ ] Term: 14 Years

[21] Appl. No.: 70304

[221 Filed: May 5,1997

[511 LOC (6) CL 28-03[52] US . Cl D28/40

D28/39-43; 132/273.132/275-284

[58] Field of Search

[56] References Cited

U.S. PATENT DOCUMENTS

D. 202.016

D. 272^611,675,8064.011,6395.537.724

8/1965 Sdomon2/1984 btcando7/1928 Holden3 /1 97 7 K ol es ke7/1996 Cho u

... D28/40D28/39X

._ 1 3 2 0 7 6 X132 ^76 X1 3 2 Q 7 9 X

i H i n i i i i i n i nUS00D391020S

[11] Patent Number: Des. 391,020[45] Date of Patent: ♦ F e b17,1998

Primary Examiner—Ted SboomanAssistant Examiner—C. TUttle

Attorney, Agent, or F/m—Morton J. Rosenberg; David I.Klein; Ju n Y. Le e

[57] C L A I M

The ornamental design for a hair clip, as shown anddescribed.

DESCRIPTION

FIG. 1isa perspectiveview ofa hair clipshowingmy newdesign:FIG.2 is a top planview thereof;FIG. 3 is a bottomplan view thereof;FIG. 4 is a front elevational view thereof;FIG. 5 is a rear elevational view thereof;FIG. 6 is a left sideelevationalview thereof;FIG. 7 is a rightsideelevational view thereof; and,FIG. 8 is an elevational view of the present invention.showing the hair clip opened.

1 Qaim, 5 Drawing Sheets



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U.S. Patent Feb.17,1998 sheet1of5 Des. 391,020

F I 6 . 1



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U.S. Patent Feb.n, im sheet2ofs Des. 391,020

iniHHUiUiiHinin

K

31

F I G . 2

m

F I G . 3



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PHtCIlt Febt17j 1998 Sheet3of5 Des. 391,020

F I 6 . 4

F I G . 5



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U.S. Patent Feb.17,im sheet4of5 Des. 391,020

F I G . 6

FIG.7



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U.S. Patent Feb.17,1998 sheet5ofs Des. 391,020

FIG.8



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E x h i b i t 2



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United States Patent [i9iTs a i

[54] HAIR CLASP

[76] Inventor: KaMVlou ftai, 4/F., No. 1, Lane 135,Tao-Hsiang Rd., Peitou Dist., TaipeiCity, Taiwan

[ ♦ ] Notice: The portion of the terra of this patentsubsequent to Jun. 30, 2012, has beend i sc l a imed .

♦ ] Term: 14 Years

[21] Appl. No.: 58,668

[22] Filed: Aug. 20, 1996

[51] LOC (6) Cl 28-03[52] U.S. Cl D28/41[58] Field of Search D28/39-43; 02/865,

D2/875; 132/273, 275; Dll /3-5 , 12, 15,18

[56] References Cited

U . S. PAT EN T D O C U M E N T S

D.44,556 8/1913 Cunningham Dll/5D. 90,188 6/1933 Behr D28/41

D. 172,122 5/ 1954 Arm brust Dll/15D. 205,576 8/1966 Day D28/41

llllllllllllllllllllllllllllllillllllliUS00D404524S

[11] Patent Number: Des . 404 ,524I45| Date of Patent: $sc#Jan. 19,1999

D. 214,525D. 342,154

6/1969

12/1993

Weitz D l l / 1 5

Capello D28/41 X

O T H E R P U B U C A n O N S

Hong Kong Enterpr ise Feb. 1982, p. 101 hair bands indicated by arrows.

Primary Philip S. HyderAssistant E x a m i n e r — C . Tutt le

Attorney, Agent, or Firm—Rosenberg, Klein & Bilker

157] C L A I M

The ornamental design for a hair clasp, as shown anddescribed.

D E S C R I P T I O N

FIG. 1 is a perspective view of a hair clasp showing mydesign;FIG. 2

FIG. 3

FIG. 4FIG. 5

FIG. 6FIG. 1;FIG. 7F IG . 1 .

is a top view of the hair clasp shown in FIG. 1;i s a bottom view of the hair clasp shown in FIG. 1;

is a front view of the hair clasp shown in FIG. 1;is a rear view of the hair clasp shown in FIG. 1;is a left elevational view of the hair clasp shown inand,

is a right elevational view of the hair cla.spshown in

1 Claim, 4 Drawing Sheets



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U.S. Patent jan. 19,1999 sheet 1 of 4 Des. 404,524

FIG.1



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U.S. Patent jan. 19,1999 sheet 2 of 4 Dcs. 404,524

F I 6 . 2

FIG. 3



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U.S. P a t e n t Jan. 19, 1999 Sheet 3 of 4 Des. 404,524

F I G . 4

FIG.5



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U.S. P a t e n t Jan. 19, 1999 Sheet 4 of 4 Des. 404,524

F I G . 6

F I G . 7



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I H i i l H i i U y i H I I i lUS00D627509S

12)United States Design Patent do Patent No.:Tsai (45) Date of Patent:

US D627,509 SNov. 16,2010

(S4) HAIR RAISER

(76) Inventor: Kal-Mou Tsai, 14F., No. 63,Chilin Rd.,ChungshanDist., TaipeiCity (TW)

(*») Term: 14 Years

(21) Appl. No.: 29/347,379

(22) Filed: Dec. 18,2009

(51) LOC(9)CI 28-03(52) U.S.CI D28/10(58) Field of Classification Search D28/10.

D28/93, 99; 132/200, 53-55,210, 207, 333Sec application file for complete search history.

(56) References Cited

U . S . PAT E N T D O C U M E N T S

3,126,017 A ♦ 3/1964 Sidelman 132/543,808,736 A ♦ 5/1974 Teraan et a 446/2964,625,739 A ♦ 12/1986 Hamazaki 132/544,825,886 A » 5/1989 Allen 132/.545,117,846 A ♦ 6/1992 Finamoreetal 132/545,765,571 A ♦ 6 /1 99 8 D ln ne l 132/2105,865,191 A 2/1999 Kimeta 132/2106,209,549 B1 4/2001 Lundc 132/2007,264,003 B2 * 9/2007 Chayeb 132/54

2009/0032042 Al » 2/2009 Fitzpatrick 132/54

2010/0163069 A l 7/2010 I m a i e t a l 132/54

* cited by examiner

Primary Examiner—^JenniferRivard(74) Attorney, Agent, or Firm—Rosenberg, Klein & Lee

(57) C L A I M

The ornamental design for a hair raiser, as shown anddesc r ibed .


FIG. 1 is a perspective view of a hair raiser and showing mynew design;FIG. 2 is a top plan view thereof ;

FIG. 3 isa bottom plan view thereof;FIG. 4 is a f ront e leva tional view thereof;

FIG. 5 is a rear elevational view thereof;

F IG . 6 is a left side elevational view thereof;

FIG. 7 is a right side elevational view thereof; and,FIG. 8 is a schematic applied view.Tlie broken l ines shown i n F IG . 8 i l lust ra te the env i ronmentand form no part of the claimed design.

1 Claim, 5 Drawng Sheets

N



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U.S. Paten t Nov. 16,2010 sheet 1of5 US D627,509 S

m m

FIG. I



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U.S. Patent Nov. 16,2010 sheet 2of5

FIG. 2

FIG.ri

0

US D627 ,509 S



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U.S . P a t e n t Nov. 16,2010 Sheet 3 of 5 US D627,509 S

mnrntnnrnmnmnTmmTTrmTm

FIG. 4

FIG. 5



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U.S. P a t e n t Nov. 16,2010

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FIG. 6

FIG. 7

US D627,509 S



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FIG. 8



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n i n i i i i i i i i i i n i i i iUS00D635296S

12)United States Design Patent (lo)Patent No.:Hsu (45) Date of Patent:

US D635,296 SMar. 29,2011

(54) HAIR RETAINER

(76) Inventor: Shih-Ling Hsu, Tainan (TW)

(**) Term: 14 Years

(21) Appl. No.: 29/369,381

(22) Filed: Sep. 8,2010

(51) LOC(9)CI 28-03(52) U.S.CI D28/39(58) Field of Classification Search D28/31-34,

D 2 8 /3 9 - 43 : 1 3 2/ 2 73 - 28 4

See application file for complete search history.

(56) References Cited


0119,846 S * 4/1940 Kayn D28/423,076,465 A * 2/1963 Solomon 132/2833,535,746 A * 10/1970 Thomas. Jr. 24/30.5 1»D280,447 S ♦ 9/1985 Vcrdiicci D28/42D280,942 S 10/1985 Topalian D28/426,609,525 B 2* &'2003 Potter e ta l 132/280D582.095 S ♦ 12/'2008 Minnelli D28/42

D592.803 S0626.690 S

0626.691 S* cited by examiner

5 / 2 0 0 9 Tsai 0 2 8 / 3 911/2010 Hs u 0 2 8 / 4 2

11/2010 H su 0 2 8 / 4 2

PrimaryExaminer — Janice E SeegerAssistant E x a m i n e r — Zenia I Benne t t

(74) Attorney, Agent, or Firm — Alan Kamrath; Kamrath &A s s o ci a te s PA

(57) CLAIMThe omamental design for a hair retainer, as shown anddescribed.


FIG. 1 is a perspective view of a hair retainer showing mydesign;FIG. 2 is a front elevational view thereof;FIG. 3 is a rear elevational view thereof;FIG. 4 is a left e leva tional view thereof;FIG. 5 is a right elevational view thereof;FIG. 6 isa top plan viewthereof; and,FIG. 7 isa bottom plan view thereof.




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U.S. Patent Mar. 29,2011 sheet 1of7 US D635,296 S

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IliilMIWIIIIIUS00D668815S

12)United States Design Patent (lo)PatentNo.:Hsu (45) Date of Patent:

US D668,815SOct. 9,2012

(54) HAIR BAND

(76) Inventor: Shih-Ling Hsu,Tainan(TW)

(••) Terra: 14 Years

(21) Appl.No.: 29/411,500

(22) Filed: Jan. 21,2012

(51) L0C(9)CI 28-03(52) U.S.CI D28/41(58) Field of Classification Search D28/21-34,

D28/39-43; 132/101.126,128-131,144,132/148,219,275-284

Seeapplication Hie for completesearch history.

(56) Refcrcnccs Cited

U.S. PATENT DOCUMENTS

D402,302 S ♦ 12/1998 Ferro D16/309D4(M,524 S * 1/1999 Tsai D28/415,979,466 A ♦ 11/1999 Chung 132/275

y. \

6,000,409 A ♦D422,750 S ♦

0 53 7, 98 4 S ♦D620,640 S *

citedby examiner

12/1999 Chung 132/2784/2000 Chou D28/41

3/2007 S t e a d i e d a l D28/417/2010 Kichijo D28/41

PrimaryExaminer—ZeniaBennett

(57) CLAIMThe ornamental design for a hair band, as shown anddescribed.

DESCRIPTION

FIG.1is a perspectiveviewofa hairband showing mynewdesign thereof;FIG. 2 is a frontelevationalview thereof;FIG. 3 is a rear elevational view thereof;FIG.4 isa left side elevational view thereof;

FIG.5 isa rightsideelevational view thereof;FIG.6 isa lopplanview thereof; and,FIG.7is a bottom planview thereof.


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IG. 2



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FIG. 3



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V /

FIG. 4



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FIG. 5



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FIG. 7



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(12) U n it ed S t at es P a t e n tH su

(54) HAIR ORNAMENT

(76) Inventor: Shih LingHsu, Tainan (TW)

( * ) Notice: Subject to any disclaimer, the term of thispatent is extended or adjusted under 35U.S.C. 154(b) by 184 days.

(21) Appl.No.: 12/793,053

(22) Filed: Jun.3,2010

(65) Prior Publication Data

US 2011/0297178 A1 Dec. 8,2011

(51) Int.CI.A45D8/20

(2006.01)(52) U.S.CI 132/277; 24/489; 24/499; 24/DIG. 22(58) Field of Classification Search 132/273,

132/277, 278See application file for complete search history.

141(151)

iiiiiiiiiniiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiUS008161982B2

(10) Pa ten t No.:

(45) Date o f Patent:US 8,161,982 B2

Apr. 24,2012

(56) R e f c r c n c c s C i t e d


6,325,073 B l 12/2001 Di Maria Poole et al 132/275

* cited by examiner

Primary Examiner — Rachel Steitz

(57) A B S T R A C T

A hair ornament includes a body having an engagement section to be in contact with hair of a user. The engagementsection includes a row of plates arranged along a lengthdirection of tlie body. Two of the row of plates adjacent tocach other arcconncctcd by a conncctingmember having firstand second ends.The first end of each connecting member ispivotablyconnectedto oneof twoadjacentplates.The secondend of each connecting member is pivotably connected to theother of the two adjacent plates. A spacing between twoadjacent plates is adjustable by pivoting the two adjacentplates to adjust an overall length of the body in the lengthdirection of the body.

6 Claims, 13 Drawing Sheets



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U.S. Patent Apr. 24,2012 sheet 1of 13 US 8,161,982 B2

161 1.6

141(151) 15

F I G . 1



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1 I

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241(251)

26 261

F I G . 5



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34 3 331(341)

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F I G . 1 0



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431(441)

451 452 \431

F I G .1 1

US 8,161,982 B2



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U.S. Patent Apr. 24,2012 sheet 11 of 13 US 8,161,982 B2

F I G . 1 2



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U.S. Patent Apr. 24,2012 sheet13 of13

F I G . 14P r i o r A rt

US 8,161,982 B2



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H A IR O R N A M E N T

B A C K G R O U N D O F T H E I N V EN T I ON

1. Field o f th e Invention

The present invention relates to a hair ornament and, moreparticularly, to a hair ornament that has an adjustable contacta r ea w i th t h e h a i r o f th e user.

2. Description of the Related ArtConventional hair ornaments iiave various types and have

an engagement section for contact with the hair of the user.The engagement section generally includes a couple of platesthat can be in contact with tlie hair by extending tliroughorclamping the hair,allowing the hair ornament tobe positionedo n th e hair.

FIG. 14 shows a conventional hair ornament including abody 1' having two symmetric clamping portions 11' eachhavingan engagement section 111' at a lowerend thereof.Theengagement section 111' includes a plurality of teeth or plates112' at a bottom end thereof. 'ITieclamping portions 11' arepivoted together.A spring 12' is attached between the clamp

ingportions11' to bias theclamping portions11'to a positionclamping thehair.The plates 12' areextended through thehairto prevent the body 1' from falling from thehair. However,anoverall width A of theengagement sections 111' of theclampingportions 11'and theextendingarea of theplates 112' in thehairare fixed. Namely,the hair ornamentcan notbe adjustedaccording to differing head sizes and differing hair amountso f d i f l e ren t use r s.

Thus, a need exists foran adjustable hair ornament that canbe adjusted accordmg to differing head sizes and differinghair amounts o f di ffe ren t use r s .

BRIEF S U MM A RY O F T H E INVENTION

The present invention solves this need and other problemsin the field of adjustable hair ornaments by providing, in apreferred form, a hair ornament including a body having anengagement section adapted to be in contact with hair of auser. The engagement section includes a row of platesarranged along a length direction of thebody.Two of the rowof platesadjacent toeach other are connected by a connectingmember having first and second ends. The first end of eachconnecting member is pivotably connected to one of twoadjaccnt plates. Tlic sccond end of each connccting memberis pivotably connected to theother of thetwo adjacent plates.A spacing between two adjacent plates is adjustable by pivoting thetwo adjacent plates to adjust an overall length of thebody in the length direction of tlie body.

In a preferred form, the body includes first and secondclamping portions that are pivoted together. An elastic element is mounted between the first and second clamping portions. Each of the firstand second clamping portions includesa pressing portion on an end thereof. Each of the first andsecond clamping portions includes the engagement section.Each plate includes firstand second pivotal portions. The firstand second ends of each connecting member include thirdand fourth pivotal portions.The first and second pivotal portions are one of a pin and a hole. The third and fourth pivotalportions are theother of the pin and the hole. The third pivotalportionofcachconnccting memberispivotablycngag^withthe first pivotal portion of one of two adjacent plates. Tliefourthpivotalportion of eachconnecting member ispivotablyengaged with the second pivotal portion of the other of thetwo adjacent plates. Th e pressing portions are provided atcenters of tlie first and second clamping portions. An extension extends from each of two opposite sides of each of tlie

first and second pressing portions. Each extension includes aguide slot extending in the length direction and slideablyreceiving one of the first and second pivotal portions of atleast one of the plates.

5 Inanother preferred form, thebody includes first and sec

ond clamping portions pivoted together at first ends thereof.Each of the first and second clamping portions includes anengaging portion ona second endthereof. Each of thefirstandsecond clamping portions ftirther includes the engagement

10 section intermediate th e first an d s e c o nd e n d s. T h e first an dsecond clamping portions are openable to receive the hair ofthe user. The engaging portions are releasably engaged witheach other such that the engagement section of each of thefirstandsecond clamping portions clamps thehair of the user.

15 Each plate includes firstand sccond pivotal portions. The firstand second ends of each connecting member include thirdand fourth pivotal portions. The first and second pivotal portions are one of a pin and a hole. The third and fourth pivotalportionsare the other of thepin and the hole. The thu-dpivotal

20 portion of each connecting member ispivotably engaged withtlie first pivotal portion of one of two adjacent plates. Tlie

fourthpivotalportion of eachconnccting member ispivotablyengaged with the second pivotal portion of the other of thetwo adjacent plates. The first end of each of the first and

25 second clamping portions includes first and second extensions spaced in a direction perpendicularto the length direction. Each engaging portion includes third and fourth extensions spaced in the direction perpendicular to the lengthdirection. The engagement section of the first clamping por-

30 t ion is m o u nt e d b e tw e e n th e first a n d t hi rd extensions. Tlieengagement section of the second clamping portion ism o u nt e d b e tw e e n t h e s e co n d an d fou r th ex tens ions. Each o fthe first,second, third, and fourth extensions includes a guideslot extending in tlie length direction and slideably receiving

35 one of the first and second pivotal portions of at least one oftlie plates.

In a further preferred form, the body includes first andsccond gripping portions. The engagement scction is intermediate the first and second gripping portions. Each of the

40 plates includes firstand secondpivotalportions. The firstandsecond ends of each connecting member include third andfourth pivotal portions. The first and second pivotal portionsare one of a pin and a hole. The third and fourth pivotalportions are theother of thepin and thehole. The thirdpivotal

45 portion of cach connccting member ispivotably engaged withthe first pivotal portion of one of two adjacent plates. Thefourthpivotalportion of eachconnecting member ispivotablyengaged with the second pivotal portion of the other of thetwo adjacent plates. Each of the first and second gripping

50 portions includes first and second extensions spaced in adirection perpendicular to the length direction. Each of thefirstand second extensions includes a guide slot extending inthe length direction and slideably receiving one of the firstand second pivotal portions of at least one of the plates.

55 In another preferred form, the body includes firetand second two clamping plates pivotably connected to each other.The first and second clamping plates are openable to receivetliehair of the user.Tlie hair of the user isclamped by the firstand second clamping plates when the first and second clamp-

60 ing portions are pivoted to a clamping position. The secondclamping plate includes the engagement scction. Each plateincludes first and second pivotal portions. Tlie first and second ends of each connecting member include third and fourthpivotal portions. The firstand second pivotal portionsare one

65 ofa pin and a hole. Thethird and fo i^ pivotal portionsarethe other of the pin and the hole. The thinj pivotal portion ofeach connecting member is pivotably engaged with the first



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pivotal portion of one of two adjacent plates. The fourthpivotal portion of each connecting member is pivotablyengaged with the second pivotal portion of the other of thetwo adjacent plates. ITie second clamping plate includes firstandsecond ends. The firstend of the secondclamping plate ispivotably connccted to the first clamping plate. Each of tlicfirstandsecondends of thesecond clampingplate includesanextension having a guide slot. Each guide slot extends in thelength direction and slideably receives one of the first andsecond pivotal portions of at least one of the plates.

The present invention will bccome dearer in light of thefollowingdetailed description of illustrativeembodiments ofthis invention described in connection with the drawings.

D E S C R I P T I O N O F T HE D R AW I N G S

The illustrative embodiments may best be described byreference to the accompanying drawings where;

FIG.1 showsa perspectiveview of a hair ornamentof a firstembodiment according to the preferred teachings of tliepresent inventionwith the hair ornament inan extended state.

FIG. 2 shows an exploded, perspective view of a connect

ing memberand two adjacent plates of the hair ornamentofFIG. 1 .FIG. 3 shows a perspective view of the liair ornament of

FIG. 1 in a collapsed state.FIG. 4 shows a schcmatic perspective view illustrating use

o f th e liair ornament o f FIG. 1.FIG. 5 shows a perspective view of a hair ornament of a

second embodiment according to the preferred teachings ofthe present invention with the hair ornament in an extendeds t a t e .

FIG. 6 shows a perspective view of the hair omament ofFIG. 5 in a collapsed state.

FIG. 7 shows a schematic perspective view illustrating useo f t h e h a i r omament o f F IG . 5 .

FIG. 8 shows a perspective view of a hair omament of athird embodiment according to the preferred teachings of thepresent inventionwith tliehairomament inan extendedstate.

FIG.9 shows a perspectiveview of the hair omament ofFIG. 8 in a collapsed state.

FIG. 10 shows a schematic perspective view illusUatingus e o f tlie h a i r o r n a m e n t o f FIG. 8.

FIG. 11 shows a perspective view of a hair omament of afourth embodiment according to the preferred teachings ofthe present invention with the hair omament in an extendeds t a t e .

FIG. 12 shows a perspective view of the hair omament ofFIG. 11 in a collapsed state.

FIG. 13 shows a schematic perspective view illustratingus e o f tlie h a i r o r n a m e n t o f F I G. 1 2 .

FIG. 14 shows a perspective view of a conventional hairo m a m e n t .

All figures are drawn for ease of explanation of the basicteachingsof the present inventiononly; theextensions of thefigures with respect to number, position, relationship, anddimensions of the parts to form the preferred embodimentswill be explained or will be within the skill of the art after thefollowing teachings of the present invention have been readand imderstood. Further, t lie exact dimensions and dimensional proportions to conform to specific force, weight,strength,and similar requirementswill likewise be within theskill of the art after the following teachings of the presenti n v en t i on h a v e b e e n r e ad an d under s tood .

D E TA I L E D D E S C R I P T I O N O F T H E I N V E N T I O N

With r efe rence to F IGS. 1-4, a hair omament of a firstembodiment according to the preferred teachings of the

present invention includes a body 1 having two clampingportions 11 tliat are pivoted together. An elastic element 10 ismounted between the clamping portions 11. Each clampingportion 11 includes a pressing portion 12 on an end thereof

5 The clamping portions 11 can be opened and released byoperating the pressing portions 12 to receive and clamp thehair of a user. Each clamping portion 11 includes an engagement section 13 f or c on ta ct w it h t he h ai r o f th e user. Each

engagementsection 13 includes a row of plates14 arrangedin10 a length direction of the body 1. Two adjacent plates 14 are

connected by a connecting member 15. Each plate 14includes firstand secondpivotal portions 141 in the form ofpins. Each connecting member 15 includes a pivotal portion15 1 in th e form o f a hole in each o f tw o ends t l iereof O n e o f

15 the pivotal portions 151 of each connecting member 15 ispivotablyengagedwith the firstpivotalportion 141of one ofthe two adjacent plates 14. The other pivotal portion 151 ofeach connecting member 15 is pivotably engaged with thesecond pivotal portion 141 of the other of the two adjacent

20 plates14.Thus,the spacing betweeneach pair of plates 14 intlielengthdirectionof thebody1 canbe increased(FIG. 1)or

rcduced (FIG. 3), adjusting the overall length of the engagement section 13. Thus, the extent of the engagement section13 extending into the hair of the user can be adjusted. The

25 pressing portions 12 are provided at centers of the clampingportions 11.An extension16 extends from each of twooppositesidesof each pressingportion 12and includesa guideslot161extendmg in the lengthdirectionand slideably receivingone ormore of the pivotal portions 141 in the form of pins.

30 Theguideslots 161providestable movementfor theplates14while adjusting the spacing between the plates 14. Furthermore, the strengthof thehair omament in the extendedposition (FIG. 1)can be increasedby the extensions16.The hairomament can easily be extended or collapsed to a desired

35 extent according to differing head sizes and differing hairamounts o f d i ff e ren t use r s .

With reference to FIGS. 5-7, a hair ornament of a second

embodiment according to the preferred teachings of thepresent invention includes a body 2 having two clamping40 portions21. The clamping portions 21 are pivoted togetherat

first ends thereof Each clamping portion 21 includes anengagingportion 22on a secondend thereof Each clampingportion 21 further includes an engagement section 23 intermediate the first a n d s e co n d e n d s fo r contac t wi th tlie hair o f

45 the user.The clamping portions 21 can be opened to receivetlie hair of the user. The engaging portions 22 can be releas-ably engaged with each other such that the engagement sections 23clamp the hair of the user.Eachengagementsection23includesa row of plates24 arrangedin a lengthdirection of

50 the body 2. Two adjacent plates 24 are connected by a connecting member 25. Similar to tlie first embodiment, eachplate 24 includes firstand second pivotal portions 241 in theform of pins. Each connecting member25 includesa pivotal

portion251 in the form of a hole ineachof twoends thereof55 One of the pivotal portions 251 of each connecting member

25 is pivotably engaged with the first pivotal portion 241 ofone of the two adjacent plates 24. The other pivotal portion251of eachconnectingmember25 is pivotablyengagedwiththe second pivotal portion 241 of the other of the two adjacent

60 plates 24.Thus, the spacing between each pair of plates24 inthe lengthdirectionof thebody2 can beincreased(FIG.5) orreduced (FIG. 6),adjusting the overall length of the engagement section 23. Thus, the extent of the engagement section23 extendingintothehair of theuser canbe adjusted.The first

65 end of each clamping portion 21 includes first and secondextensions 26 spaced in a direction perpendicular to thelength direction. Each of the first and second extensions 26



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has a guide slot 261 extending in the length direction andslideably receiving one or more of the pivotal portions 241 inthe form of pins. Each engaging portion 22 has third andfourth extensions 26spaced inthe Erection perpendiculartothe lengtli direction. One of the engagement sections 23 is 5m o u n t ed b e t w e en

th efirst a nd third

ex tens ions 26 . Th eother

engagement section 23 is mounted between the second andfourth ex tensions 26 . Each o f t h e t h i rd an d fourth extensions26 has a guide slot 261 extending in the length direction andslideably receiving one or more of the pivotal portions 241 in lOthe form of pins. The guide slots 261 provide stable movement fortheplates 24while adjusting thespacing between theplates 24. Furthermore, the strength of the hair ornament intlie extended position (FIG. 5) can be increased by tlie extensions 26. Tlie hair ornament can easily be extended or col- 15lapsed to a desired extent according to dilTering head sizesand differing hair amounts of different users.

With reference to FIGS. 8-10, a hair ornament of a tliirdembodiment according to the preferred teachings of thepresent invention includes a body 3 hav ing two gripping 20portions 31 and an engagement section 32 intermediate tlie

gripping portions 31. Tlic engagement section 32 is adaptedto extend through the hair of the user. Each engagementsection 32 includes a row of plates 33 arranged in a lengthdirection of the body 3. Twoadjacent plates 33 are connected 25by a connecting member 34. Similar to the firstembodiment,each plate 33 includes firstand second pivotal portions 331inthe form of pins. Each coimecting member 34 includes apivotal portion 341 in the form of a hole ineach of two endsthereof. One of the pivotal portions 341 of each comiecting 30member 34 is pivotably engagedwith the first pivotal portion331 of one of the two adjacent plates 33. The other pivotalportion 341 of each connect ing member 34 is pivotablyengaged with the second pivotal ponion 331 of the other ofthe two adjacent plates 33. Thus, the spacmg between each 35pair of plates 33 in the length direction of the body 3 can beincreased (FIG. 8) or reduced (FIG. 9), adjusting the overall

Icngtli of the engagement section 32. Thus, the extent of theengagement section 32 extending into the hair of theuser canbe adjusted. Each of the gripping portions 31 includes first 40and second extensions 35 spaced in a direction perpendicularto thelength direction. Each of the firstand second extensions35 has a guide slot 351 extending in tlie lengthdirection andslideably receiving one or more of thepivotal portions 331 inthe form of pins. The guide slots 351 provide stable move- 45ment forthe plates33 whileadjustingthe spacing between theplates 33. Furthermore, the strength of the hair ornament inthe extended position (FIG. 8) can be increased by the extensions 35. llie hair ornament can easily be extended or collapsed to a desired extent according to differing head sizes 50and differing hair amounts of different users.

With referenceto FIGS. 11-13,a hair ornament of a fourthembodiment according to the preferred teachings of (he

present invention includes a body 4 having two clampingplates 40 and 41 pivotably connected to each other. Tlie 55clamping plates 40 and 41 can be opened toreceive the hair ofthe user. Tlie hair of the user is c lamped by the cl ampingplates 40 and 41 when the clamping portions 40 and 41 arepivoted to a clamping position. The clamping plate 41includesan engagement section 42 forcontact with thehair of 60the user. The engagement section 42 includes a row of plates43 arranged in a length direction of the body 4. Each plate 43hasa plurality of teeth 431on a side thereofforextending intothe hair of the user. Two adjacent plates 43 are connected bya connecting member 44. Similar to the first embodiment, 65each plate 43 includes firstand second pivotal portions 431 inthe form of pins. Each connecting member 44 includes a

pivotal portion 441 in the form of a hole in each of two endsthereof.One of the pivotal portions 441 of each connectingmember44 is pivotablyengagedwith the firstpivotalportion431 of one of the two adjacent plates 43. The other pivotalportion 441 of each connecting member 44 is pivotably

engaged with the second pivotal portion 431 of the other oftlie two adjacent plates 43. Thus, the spacing between eachpairof plates43 in the lengthdirectionof the body4 can beincreased (FIG. 11) or reduced (FIG. 12), adjusting the overall length of the engagement section 42. llius, the extent ofthe engagement section 42 extending into the hair of the usercan be adjusted. The clamping plate 41 includes first andsecond ends 45 and 46. The first end 45 of the clamping plate41 is pivotably connected to the clamping plate 40. Each ofthe firetand second ends 45 and 46 of the clamping plate 41includes an extension 45, 46 having a guide slot 451, 461extending in the length direction and slideably receiving oneor moreof the pivotal portions 431 in the formof pins. Theguide slots 451 and 461 provide stable movement for theplates 43 while adjusting the spacing between the plates 43.Furthermore, the strength of the hair ornament in the

extended position (FIG. 11) can be increased by the extensions 45and 46. The hair ornament can easily beextended orcollapsedto a desiredextentaccordingto dilTering headsizesand differing hair amounts of different users. Itcan be appreciated that th e hai romament o f th e fourth embodiment in th ecollapsed state can be utilized as a comb.

Thus since the invention disclosed herein may be embodied inotherspecificformswithout departingfromthe spiritorgeneral characteristics tiiereof, some of which forms havebeen indicated, the embodiments described herein are to beconsidered in all respects illustrativeand not restrictive.Thescope of the invention is to be indicated by the appendedclaims, rather than by the foregoing description, and allcliangeswhichcome witliintliemeaningand rangeof equivalencyof the claims are intended to be embraced therein.

T h e invention c la imed is :1.A hairomament comprising a body includingan engage

mentsectionadapted tobe in contact with hair of a user,withthe engagement section including a row of plates arrangedalong a lengthdirection of the body, with two of the row ofplatesadjacentto eachotherbeingconnectedby a connectingmember having first and second ends, with the first end ofcach of tlieconnectingmembers pivotablyconncctedto oneof two adjacent plates, with the secondend of each of theconnecting members pivotablyconnected to another of thetwo adjacent plates, with a spacing between two adjacentplatesbeingadjustableby pivotingthe twoadjacentplates toadjustan overall lengthof the body in the lengthdirection ofthe body, with the body including first and second clampingportions that are pivoted together, with an elastic elementmounted between the first and second clamping portions,

with each of the firstand second clamping portions mcludinga pressing portion on anend thereof, with each of the firstandsecond clamping portions including the engagement section,with each of the plates including first and second pivotalportions, with the first and second ends of each of the connecting members including third and fourth pivotal portions,with tlie first and secondpivotal portions being one of a pinand a hole, with the third and fourtli pivotal portions beinganother of tliepin and the hole, with the third pivotal portionof each of the connecting members pivotably engaged withthe firstpivotalportion of one of two adjacent plates, with thefourth pivotal portion of each of the connecting memberspivotably engaged with the second pivotalportion of theotherof the two adjacent plates.



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7 82.Thehairornamentas claimed inclaim 1,with the press- ment section intermediatethe first and second gripping por

ingportionsprovidedatcenters ofthe firstand secondclamp- tions,witheachof theplatesincludingfirstandsecondpivotaling portions, withan extension extending fromeachof two portions, withthe first and secondends of eachof the con-opposite sides of each of the first and second pressing por- necting membersincluding thirdand fourth pivotalportions,tions, with cach of the extensions includinga guide slot ^ with the first and second pivotal portions being one ofa pinextending inthe lengthdirection and slideably receivingone and a hole, with the tliird and fourth pivotal portions beingofthe firstand second pivotal portions ofat least oneofthe anotherofUiepinand the hole,with the third pivotalportionpjates of ®achof the connecting members pivotably engagedwith

3.Thehairornamentasclaimedinclaim1.with thebody Af oft™adjacentplates, with theincludingfirstandsecondclampingportionspivotedtogether > P ™wl of theconnatmg tnemters

.P . , r -.u u r.i r , t i i pivotably engaged With the secondpivotalportionof th e OtheratflBtendsllierMr.wilheachoftheriistandsecondclaiiipingof,hetJoadjacentplates.pomonsmcludtng at.engagingportronon a second end s.Thehairornamemasclaimedinclaim4,witheachorthethei«f, w, h each of the first and second clatnptng [wrtionsfuraermcludtngtheeo^gements^tionmtetmeteethe ^ pctpenditilarto thelengthfirst and secondends with the first andsecondclamp,ng eachofthefirstands^nd extensionsindSd-portions being openable to receive t he h ai r o f th e user. With . -J t . . j- .u i . u j - . j i- j uif. 1 1.1 j -.1. L .1 ing aguideslot ex tending in the length d irecti on and s lideablyth e engaging por tions re leasab ly engaged wi th each other ® r»t. e . j j . i f »

u .u f .u . e u c a . a receiving One of the first and second pivotal portions of atsuch that the engagementsection of each of tlie first and oneofUieolatesseconddampingportionsclampsthe hairof the userwith ^ hairoriamentas claimedinclaim1,withthebodyeachofthepatestncludingflKtandsecondpiTOtalportio^^^ andsecondtwoclamping platespivotably con-wrth thefir®and^ond ™dsof eachof tte com.«,ng oectcdtocachothcr.withthcfirstaildsaondclampingplatesmemb^tncltrfing thirdandfotmhpivotal̂ rtions,with the ^ with thehairof

J r ^ >,= 8̂̂ mpedbythefirstand second clamping,lhtheU.,rdandfou,lhpj™td^ plateswhen thefirstandsiondclamping portionsarepivpmand tlieholewtth thirfpivotalpomortofead.oft^le ^co^mcctingmemberspivotablycn^gcdwiththefi«tpivoB engagement section, with eachofttiepWsportionofoneof adjacentplates,withfliefot^ pivotal ^portionofeachofUiecornianngmembcRpivota^ comiKtingmembers includingwith thesecoitd pivotalportron oftheotteof the twoadja- jc^t plates,wittithefirst̂ d ofeachol thehistandsemnd ^ ^clampingportionsincludingfirstand secondextensions Jndfourth pivotal portionsbeinganotherofthepin andthe ^1 ? P=1« >5 = a - o the'yh


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JS44 (Rev. 12/12) C I V I L C O V E R S H E E T

TheJS44civil coversheetandtheinfomiation containedhereinneitherr^lacenorsupplementthefilingandserviceofpleadingsorotherW^rs.asreguirccL^^v,exceptasprovided by local rules ofcourt. This fomi, approved by the Judicial Conferenceof the United States inSeptember 1974, is required for the useTbfthe Clerk ofCourt for thepurposeof înitiating the civil docket sheet. (SEE INSTUUCTIONSONNEXTPAGE OFTHISEORM.)

1. (a ) PLAINTIFFS

Man-Q Corp.

(b) Cou nty of Residence of First Listed PlaintifT N/ A

D E F E N D A N T S

ConairCorp. _ r- s ti. i *5Zili5OCT20 P U-I3

County o f Residence o f Firs t Listed Defendant Fairfield. C T(EXCEPTIN U.S. PlAlNTlt-T CASES)

(c) Attorneys (Firm Name,Address, andTelephone Number)Leydig, Voit&Mayer, 700 Thirteenth St. N.W., Suite 300, Washington,DC (202) 737-6770; DGKeyIP Group. 1750 Tysons Blvd.,Suite 1500,Tysons Corner, VA22102 (703) 289-5118

(INU.S PUmiFFCASESONLX),.,. p r -


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B e r n a r d j. d i m u r o

N i na J . G i n s b e r g

M i c h a e l S. L i e b e r m a n

J o n a t h a n R . M o o k

c. T h om a s H ic k s II I

S t e p h e n l. n e al , J r.

A n d r e a L . M o s e l e y

S t a g e y R o s e H a r r i s

K e n d a l l A . a l m e r i c o

Billy B . R u h l i n g , II

M . j a r r a d W r i g h t

S a r a M . Sakagami

R a c h a e l E . L u z i e t t i

H ar ve y b . C o h e n

S e n i o r C o u n s e l

Ce c i l E . K e y to f o u n s l

J a y p. K e s a n t

O F o u n s l

Teresa M. S u m m e r s t

O F C O U N S E L

DG

DiMuhoGinsberGtcATTO R N EYS A T L A W

October 20 , 2015

FiLU-: . ; \ '£D

2015 OCT 20 P ti: 13

CLERKU3 DiSiis,::TC: jRTALEXAf^DRiA,ViRGaiiA

V ia H a n d Del ive ry

Cle rk o f Cour t

U n i te d S t at e s D i st r ic t Cour t fo r th e

Eastern District of Virginia401 Courthouse SquareAlexandria, VA 22314

Re: Man-Q Corp. v. Conair Corp.

D e a r Clerk:

Enclosed please find the Complaint for filing in the above-referenced matter.We are sending a request for waiver of service to the defendant.

Please time stamp the extra copy and return it to the courier.

If there are any questions, pleasecontact me at 703-684-4333. Thank you.

Very truly yours.

Enc losu res

Diane M . Nees

Legal Assistant

cc: All Counsel of Records (w/end.)


man-q v. conair - complaint

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