Fatboy v. EMRG - Complaint

Case 3:16-cv-02520-D Document 1 Filed 08/31/16
Page 1 of 8 PageID 1
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
FATBOY THE ORIGINAL B.V. and FATBOY

USA, LLC
Plaintiffs,
v.
Civil Action No.
3:16-cv-02520
EMRG, LLC,
Defendant.
ORIGINAL COMPLAINT
Plaintiffs Fatboy the Original B.V. (Fatboy) and Fatboy USA, LLC (Fatboy USA and,
together with Fatboy, Plaintiffs), for their Complaint against Defendant EMRG, LLC (EMRG
or Defendant), allege as follows:
SUBSTANCE OF THE ACTION
1. Fatboy is the owner of all rights worldwide in the wildly popular LAMZAC THE
ORIGINALinflatable lounger (the LAMZAC Lounger), the design of which is covered by
U.S. Patent No. D764,823 (the LAMZAC Lounger Patent), and Fatboy USA has an exclusive
license from Fatboy to distribute and promote the LAMZAC Lounger in the United States. The
claim asserted herein arises out of and is based on Defendants brazen and willful infringement
of the LAMZAC Lounger Patent. Accordingly, Plaintiffs bring a claim for design patent
infringement under Section 271 of the U.S. Patent Act, 35 U.S.C. 271.
2. Plaintiffs seek injunctive relief to stop Defendants unlawful distribution and sale of
its infringing products. Plaintiffs also seek monetary relief in an amount sufficient to
compensate for their loss, an accounting and award of Defendants total profits flowing from its
infringing activities; prejudgment interest; costs and attorneys fees; and all other relief the
Court deems just and proper.
JURISDICTION AND VENUE
3. This Court has jurisdiction under Sections 1331, 1332, and 1338(a) and (b) of the
Judicial Code, 28 U.S.C. 1331, 1332, 1338(a) & (b).
4. This Court has personal jurisdiction over Defendant pursuant to Texas Civil Practice
and Remedies Code 17.042 because, upon information and belief, (i) Defendant regularly
does and solicits business within the State of Texas; (ii) Defendant has engaged in the
marketing, promotion, advertising and offering for sale of its infringing products within the
State of Texas, including via the interactive ecommerce websites at qvc.com, pouchcouch.com,
and bedbathandbeyond.com and in brick-and-mortar Bed Bath & Beyond stores located in
Texas; and (iii) Defendant has committed torts in the State of Texas, namely the marketing,
promotion, advertising, sale and/or offering for sale of its infringing products in Texas,
including through the above-referenced sales channels, in violation of Plaintiffs rights.
5.
Venue is proper under Section 1391(b) and 1400(b) of the Judicial Code, 28 U.S.C.
1391(b), 1400(b), because a substantial part of the events giving rise to the claims occurred
in this district, including Defendants marketing, promoting, advertising, selling and/or offering
for sale its infringing products in this district.
THE PARTIES
6.
Plaintiff Fatboy the Original B.V. is a limited liability company organized and
existing under the laws of the Netherlands, having a place of business at De Steenbok 19 Den
Bosch, 5215 MG Netherlands.
7.
7
Plaintifff Fatboy US
SA, LLC is a limited liabbility companny organizedd and existinng
under th
he laws of th
he State of North Carolin
na, with its prrincipal placce of businesss at 875 Weest
Sandy Lake
L
Road, #100,
#
Coppell, TX 75019
9.
8.
8
Upon in
nformation and
a belief, Defendant
D
EM
MRG, LLC iis a limited lliability com
mpany
organizeed and existiing under thee laws of thee State of Deelaware, withh its principaal place of
businesss at 1115 Bro
oadway, 5th Floor, New York, NY 1 0010.
FACTS
F
COM
MMON TO
O ALL CLA
AIMS FOR R
RELIEF
I.
THE
T
LAMZ
ZAC LOUNG
GER
9.
9
Mr. Marijn
M
Oomeen, a residentt of the Nethherlands, is th
the designer of the LAM
MZAC
Loungerr, an inflatab
ble lounger that is filled with
w air by m
means of aiir scooping. During aiir
scooping
g, an openiing reinforceed with ribs is
i held open and a scoopping movement is made, so
the bag fills with airr. The openiing is then fo
olded togethher and the aiir stays caugght in the bagg.
10.
1
Profile views of th
he LAMZAC
C Lounger aas shown in tthe LAMZA
AC Lounger
Patent are
a shown beelow:
11.
Mr. Oomen has assigned to Fatboy all of his rights in the design of the LAMZAC
Lounger, including, without limitation, the LAMZAC Lounger Patent. A copy of the
LAMZAC Lounger Patent is attached hereto as Exhibit A.
12.
Fatboy USA has an exclusive license from Fatboy to distribute and promote the
LAMZAC Lounger in the United States.

13.
The LAMZAC Lounger Patent claims a priority date of January 28, 2015, based
on Fatboys Registered European Community Design No. 002621904-0001 covering the

LAMZAC Lounger design.
14. The LAMZAC Lounger is currently available for sale in the United States on Fatboy
USAs website at www.fatboyusa.com and via various retail outlets and online channels.
II.
DEFENDANTS INFRINGING ACTIVITIES

15.
On information and belief, Defendants have manufactured, advertised, offered for
sale, sold, distributed, imported, and/or exported inflatable loungers called the PouchCouch
and Pouch Couch Deluxe (each, an Infringing Product and, together, the Infringing
Products), each with a design that is substantially the same as the LAMZAC Lounger.
Examples of images of the Infringing Products are shown below:
Pouch Couch
Pouch Couch Deluxe
16.
Upon information and belief, Defendant markets and sells its Infringing Products
online at their website, www.pouchcouch.com, and through various retailers and online
channels, including Bed Bath & Beyond and QVC.
17.
Upon information and belief, Defendant engaged and continues to engage in the
above activities willfully, with the knowledge that the design of each Infringing Product is
substantially same as the design of the LAMZAC Lounger without authorization.
18.
Defendant is not related to or affiliated with Plaintiffs in any way. Defendants
have not received a license or authorization from Plaintiffs for any purpose whatsoever,
including for the acts described herein.
19.
Defendants unauthorized acts as described herein have caused and will continue
to cause irreparable damage to Plaintiffs and their business unless restrained by this Court.
FIRST CLAIM FOR RELIEF:
DESIGN PATENT INFRINGEMENT
IN VIOLATION OF 35 U.S.C. 271 (Patent No. D764,823)
20.
Plaintiffs repeat and incorporate by reference the foregoing allegations contained
in paragraphs 1 through 19 as if fully set forth herein.
21.
The design of the LAMZAC Lounger is covered by U.S. Patent No. D764,823,
which issued on August 30, 2016 and is owned by Fatboy. Fatboy USA has an exclusive
license from Fatboy to distribute and promote the LAMZAC Lounger in the United States.
22.
U.S. Patent No. D764,823 is valid and subsisting.
23.
Upon information and belief, Defendant, without authorization from Plaintiffs,
has distributed, advertised, promoted, offered for sale and sold the Infringing Products, the
designs of which are substantially the same as the design set forth in U.S. Design Patent No.
D764,823, and embody the design protected by such patent.
24.
Defendants Infringing Products appropriate the novel ornamental features set
forth in U.S. Patent No. D764,823 such that an ordinary observer familiar with the prior art
designs, giving such attention as a purchaser usually gives, would find Plaintiffs and
Defendants designs to be substantially the same and would be deceived into believing that the
Infringing Products are the same as Fatboys patented design.
25. By the foregoing acts, Defendant has directly infringed, infringed under the
doctrine of equivalents, contributorily infringed, and/or induced infringement of, and continues
to so infringe, U.S. Patent No. D764,823.
26.
Upon information and belief, Defendants aforesaid conduct has been undertaken
knowingly, willfully, and in bad faith, and with knowledge of Plaintiffs rights.
27.
Defendants conduct violates Section 271 of the Patent Act, 35 U.S.C. 271 and
has caused, and unless enjoined by this Court, will continue to cause, Plaintiffs to sustain
irreparable damage, loss, and injury, for which Plaintiffs have no adequate remedy at law.
28. Plaintiffs have complied with 35 U.S.C. 287 to the extent it is applicable to them.
WHEREFORE, Plaintiffs pray for judgment against Defendant as follows:

1.
Permanently enjoining and restraining Defendant, its agents, servants, employees,
successors, and assigns and all those in active concert or participation with it, from:
(a)
infringing or inducing infringement of the LAMZAC Lounger Patent; or
(b)
assisting, aiding or abetting any other person or business entity in engaging in or
performing any of the activities referred to in subparagraph (a) above.

2.
Directing that Defendant turn over to Plaintiffs for impoundment and eventual
destruction, without compensation to Defendant, all materials in its possession or control that
violate the provisions of paragraph 1(a) above, along with all articles by means of which such
unauthorized copies may be reproduced.
3.
Directing that Defendant, at its own expense, recall from any distributors, retailers,
vendors, or others to whom it has distributed materials that violate the provisions of paragraph 1(a)
above, and that Defendant deliver up to Plaintiffs for destruction all materials returned to it.
4.
Directing that Defendant file with the Court and serve upon Plaintiffs, within thirty
(30) days of the entry of injunction prayed for herein, a written report under oath or affirmed under
penalty of perjury setting forth in detail the form and manner in which it has complied with the
permanent injunction.
5.
Awarding Plaintiffs all damages sustained as a result of Defendants infringement
described above, together with appropriate interest thereon and that such sums be trebled pursuant
to 35 U.S.C. 284.
6.
Awarding Plaintiffs the total profits realized by Defendant from its infringement
described above pursuant to 35 U.S.C. 289.

7.
Granting Plaintiffs their reasonable attorneys fees pursuant to 35 U.S.C. 285.
8.
Granting Plaintiffs both pre-judgment and post-judgment interest on each and every
monetary award.
9.
Granting Plaintiffs such other and further relief as the Court may consider equitable,
just and proper.

JACKSON WALKER, LLP
Dated: August 31, 2016
By: __/s/ John M. Jackson___________________

John M. Jackson
Texas State Bar No. 24002340
JACKSON WALKER, LLP
2323 Ross Avenue, Suite 600
Dallas, TX 75201
214-953-6000
214-953-5822 (Fax)
jjackson@jw.com
David Donahue (pro hac vice forthcoming)
Jason D. Jones (pro hac vice forthcoming)
FROSS ZELNICK LEHRMAN & ZISSU, P.C.
866 United Nations Plaza
New York, New York 10017
Attorneys for Plaintiffs
Case 3:16-cv-02520-D Document 1-1 Filed 08/31/16
EXHIBIT
A
JS 44 (Rev. 07/16)
CIVIL COVER
SHEET
Case 3:16-cv-02520-D Document
1-2 Filed
08/31/16
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
Fatboy The Original B.V. and Fatboy USA, LLC
(b) County of Residence of First Listed Plaintiff
EMRG, LLC,
Netherlands
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE:
(c) Attorneys (Firm Name, Address, and Telephone Number)
(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (If Known)
John M. Jackson, Jackson Walker, LLP, 2323 Ross Ave., Ste. 600,
Dallas, TX 75201, 214-953-6109; David Donahue & Jason Jones, Fross
Zelnick Lehrman & Zissu, PC, 866 United Nations Plaza, New York, NY
II. BASIS OF JURISDICTION (Place an X in One Box Only)

1
U.S. Government
Plaintiff
Federal Question
(U.S. Government Not a Party)
U.S. Government
Defendant
Diversity
(Indicate Citizenship of Parties in Item III)
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

(For Diversity Cases Only)
PTF
Citizen of This State
1
DEF
1
and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State
Citizen of Another State
Incorporated and Principal Place

of Business In Another State
5
Citizen or Subject of a
Foreign Country
Foreign Nation
6
IV. NATURE OF SUIT (Place an X in One Box Only)

CONTRACT
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
625 Drug Related Seizure

of Property 21 USC 881
690 Other
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
OTHER STATUTES
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding
2 Removed from
State Court
6 Multidistrict
Litigation -
Transfer
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
8 Multidistrict
Litigation Direct File
35 U.S.C. 271
VI. CAUSE OF ACTION Brief description of cause:
Design Patent Infringement;
CHECK IF THIS IS A CLASS ACTION

VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE
CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:
DEMAND $
DOCKET NUMBER
SIGNATURE OF ATTORNEY OF RECORD
/s/ John M. Jackson
08/31/2016
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
Print
APPLYING IFP
Save As...
JUDGE
MAG. JUDGE
Reset
JS 44-TXND Reverse (Rev. 07/16)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority for Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers
as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September
1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to
the Clerk of Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.
II.
(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government
agency, use only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify
first the agency and then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff
resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of
filing. (NOTE: In land condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an
attachment, noting in this section "(see attachment)".
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place
an "X" in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included
here. United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an
amendment to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or
defendant code takes precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked,
the citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over
diversity cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above.
Mark this section for each principal party.
IV.
Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI
below, is sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the
cause fits more than one nature of suit, select the most definitive.
V.
VI.
Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section
1441. When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as
the filing date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district
transfers or multidistrict litigation transfers.
Multidistrict Litigation Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28
U.S.C. Section 1407.
Multidistrict Litigation Direct File. (7) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant
due to changes in statue.
Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite
jurisdictional statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable
service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. Demand. In this
space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. Jury Demand. Check the
appropriate box to indicate whether or not a jury is being demanded.
VIII.
Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If a related case exists, whether pending or
closed, insert the docket numbers and the corresponding judge names for such cases. A case is related to this filing if the case: 1) involves
some or all of the same parties and is based on the same or a similar claim; 2) involves the same property, transaction, or event; 3) involves
substantially similar issues of law and fact; and/or 4) involves the same estate in a bankruptcy appeal.
Date and Attorney Signature. Date and sign the civil cover sheet.

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Case 3:16-cv-02520-D Document 1 Filed 08/31/16

UNITED STATES DISTRICT COURT

FATBOY THE ORIGINAL B.V. and FATBOY

Civil Action No.

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

LAMZAC Lounger in the United States.

on Fatboys Registered European Community Design No. 002621904-0001 covering the

DEFENDANTS INFRINGING ACTIVITIES

On information and belief, Defendants have manufactured, advertised, offered for

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

Pouch Couch Deluxe

Defendant is not related to or affiliated with Plaintiffs in any way. Defendants

Plaintiffs repeat and incorporate by reference the foregoing allegations contained

in paragraphs 1 through 19 as if fully set forth herein.

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

U.S. Patent No. D764,823 is valid and subsisting.

Upon information and belief, Defendant, without authorization from Plaintiffs,

Defendants Infringing Products appropriate the novel ornamental features set

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

WHEREFORE, Plaintiffs pray for judgment against Defendant as follows:

Permanently enjoining and restraining Defendant, its agents, servants, employees,

infringing or inducing infringement of the LAMZAC Lounger Patent; or

assisting, aiding or abetting any other person or business entity in engaging in or

performing any of the activities referred to in subparagraph (a) above.

Awarding Plaintiffs all damages sustained as a result of Defendants infringement

described above pursuant to 35 U.S.C. 289.

Granting Plaintiffs their reasonable attorneys fees pursuant to 35 U.S.C. 285.

Case 3:16-cv-02520-D Document 1 Filed 08/31/16

just and proper.

By: __/s/ John M. Jackson___________________

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Fatboy The Original B.V. and Fatboy USA, LLC

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)

(c) Attorneys (Firm Name, Address, and Telephone Number)

(IN U.S. PLAINTIFF CASES ONLY)

Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an X in One Box Only)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

and One Box for Defendant)

Citizen of Another State

Incorporated and Principal Place

IV. NATURE OF SUIT (Place an X in One Box Only)

625 Drug Related Seizure

FEDERAL TAX SUITS

V. ORIGIN (Place an X in One Box Only)

VI. CAUSE OF ACTION Brief description of cause:

By: /s/ John M. Jackson_________________