Tyger Mfg. v. Meade - Complaint

Case 1:18-cv-22846-KMW Document 1 Entered on FLSD Docket 07/14/2018 Page 1 of 7
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
TYGER MANUFACTURING LLC,
Plaintiff,
CASE NO.: ___________
v.
GREGORY MEADE d/b/a GLUNT,
Defendant.
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Tyger Manufacturing LLC, for its Complaint against the Defendant,
Gregory Meade d/b/a Glunt, alleges as follows:
PARTIES
1. Plaintiff, Tyger Manufacturing LLC, is a California limited liability company
having a principal place of business at 1528 S. El Camino Real, Suite #108, San Mateo
CA 94402 (hereinafter “Plaintiff”).
2. On information and belief, defendant Gregory Meade d/b/a Glunt resides and has
a regular and established place of business at 1508 Bay Road, Unit 1127, Miami Beach,
FL 33139 (hereinafter “Defendant”).
JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, 35 U.S.C. §1 et seq.
5. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.
§§1331 and 1338(a).
6. This Court has personal jurisdiction over the Defendant based upon his contacts
with this forum, including, residing and having a regular and established place of
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business within the State of Florida.
7. Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b) and
1400(b).
GENERAL FACTS
8. Plaintiff is the sole owner of U.S. Patent No. 9,968,127 entitled “Smoking
Device” that issued on May 15, 2018. Attached as Exhibit A is a true copy of U.S. Patent
No. 9,968,127. U.S. Patent No. 9,968,127 is valid and enforceable.
9. Plaintiff is the sole owner of U.S. Patent No. D761,487 entitled “Smoking
Device” that issued on July 12, 2016. Attached as Exhibit B is a true copy of U.S. Patent
No. D761,487. U.S. Patent No. D761,487 is valid and enforceable.
10. Plaintiff manufactures, markets, and sells a glass blunt pipe covered and protected
by the claims of U.S. Patent No. 9,968,127 and U.S. Patent No. D761,487 under the
marks 7PIPE and TWISTY that has been highly successful. Attached as Exhibit C are
true pictures of Plaintiff’s glass blunt pipe. Plaintiff’s glass blunt pipe has received
acclaims by industry professionals for its unique and elegant functional and aesthetic
design. Plaintiff’s glass blunt pipe has gone viral on the internet.
11. Upon information and belief, defendant, imports, use, offers to sell, and sells a
glass blunt pipe that infringes U.S. Patent No. 9,968,127 and U.S. Patent No. D761,487.
Attached as Exhibit D is a true copy of a web page and pictures of the Accused Product
(labeled by plaintiff with figure numbers and reference numerals) from defendant’s web
site (www.gluntofficial.com) offering for sale a glass blunt pipe (the “Accused Product”).
Plaintiff ordered the Accused Product from defendant’s web site and examined the same.
The glass blunt pipe as ordered and received by Plaintiff from Defendant is identical to
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the pictures of the Accused Product as shown by the web pages of Exhibit D.
12. On June 20, 2018, Plaintiff sent Defendant a letter advising Defendant that his
import, offer to sell, and/or sale of the Accused Product infringes U.S. Patent No.
9,968,127 and U.S. Patent No. D761,487 (the “Letter”). Attached as Exhibit E is a true
copy of the Letter. In the Letter, Plaintiff demanded, inter alia, that Defendant
immediately cease and desist from any further import, offer to sell, and/or sale of the
Accused Product, and that Defendant reply to Plaintiff or further legal action would be
commenced.
13. In Exhibit D of the Letter, Plaintiff also provided Defendant with a lab report
showing that the spiral screw or auger of the Accused Product had excessive and
unhealthy levels of lead (the “Lab Report”).
14. Plaintiff has not received any reply from Defendant to the Letter. The web site of
Defendant continues to offer for sale the Accused Product.
COUNT I - PATENT INFRINGEMENT - U.S. PATENT NO. 9,968,127
15. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-14 as if
fully alleged herein.
16. The Accused Product has each and every limitation of claim 1 of U.S. Patent No.
9,968,127. First, the Accused Product has a “glass housing comprising a lower open end
portion, an upper open end portion, and an inner portion” as required by claim 1. Next,
the Accused Product has a “mouthpiece comprising a rear body portion centrally
disposed within said lower end portion of said glass housing...” The removable mouth
stem of the Accused Product when engaged with the rear body portion (by screwing it
-3-
on) that is rotatably engaged with the lower end of the glass housing of the Accused
Product corresponds to the limitation of a “mouthpiece comprising a rear body portion”
as required by claim 1. Next, the rear body portion of the Accused Product has a “rear
surface and first and second air passage ways extending inward from said rear surface.”
In the Accused Product, the air passage ways exit a side of the rear body portion located
outside the housing. This difference between the Accused Product and claim 1 is not
relevant as the scope of claim 1 only requires that “first and second air passage ways
[extend] inward from said rear surface.” Next, the Accused Product has a “first rubber o-
ring removably attached to said rear body portion” as required by claim 1. Further, the
Accused Product clearly operates such that “said rear body portion of said mouthpiece
being rotatably and sealably engaged with said lower open end portion of said glass
housing by said first rubber o-ring...” Next, the Accused Product has “an auger
comprising a first end portion engaged with said rear body portion of said mouthpiece
and a second end portion extending within said inner portion of said housing to form a
bowl area at said upper open end portion of said glass housing...” Next, the “bowl area”
of the Accused Product is clearly “bound by said upper open end portion of said glass
housing and said second end portion of said auger.” Finally, rotation of the mouthpiece of
the Accused Product “causes rotation of said auger causing the smoking material within
said glass housing to move toward said bowl area.”
17. Defendant’s import, offer to sell, and/or sale of the Accused Product into and/or
within the United States and its territories infringes claim 1 of U.S. Patent No. 9,968,127
in violation of 35 U.S.C. §271(a).
18. Defendant had constructive and then actual knowledge of U.S. Patent No.
-4-
9,968,127. Defendant’s import, offer for sale, and/or sale of the Accused Product after
receiving actual knowledge of U.S. Patent No. 9,968,127 is and continues to be a willful
infringement of U.S. Patent No. 9,968,127.
19. There are no non-infringing substitutes for plaintiff’s pipe as the scope of
protection afforded by claim 1 of U.S. Patent No. 9,968,127 is broad.
20. As a result of Defendant’s infringement of U.S. Patent No. 9,968,127, Plaintiff
has and continues to incur irreparable harm.
21. As a result of Defendant’s infringement of U.S. Patent No. 9,968,127, Plaintiff
has and continues to incur monetary damages.
COUNT II - PATENT INFRINGEMENT - U.S. PATENT NO. D761,487
22. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-21 as if
fully alleged herein.
23. The ornamental design of the Accused Product is highly similar if not identical to
the claimed design of U.S. Patent No. D761,487. A consumer would mistake or confuse
the design of the Accused Product with the claimed design of U.S. Patent No. D761,487.
24. Defendant’s import, use, offer for sale, and/or sale of the Accused Product
infringes U.S. Patent No. D761,487 in violation of 35 U.S.C. §271(a).
25. Defendant had constructive and then actual knowledge of U.S. Patent No.
D761,487. Defendant’s import, offer for sale, and/or sale of the Accused Product after
receiving actual knowledge of U.S. Patent No. D761,487 is and continues to be a willful
infringement of U.S. Patent No. D761,487.
26. There are no non-infringing substitutes for plaintiff’s pipe as the scope of
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protection afforded by claimed design of U.S. Patent No. D761,487 is broad.
27. As a result of Defendant’s infringement of U.S. Patent No. D761,487, Plaintiff
has and continues to incur irreparable harm.
28. As a result of Defendant’s infringement of U.S. Patent No. D761,487, Plaintiff
has and continues to incur monetary damage.
REQUESTED RELIEF
Plaintiff requests this Court to enter judgment in favor of it and against the
defendant on the above counts and grant it the following relief:
1. Pursuant to 35 U.S.C. §283, an Order that Defendant be preliminary
enjoined from making, importing, using, offering for sale, and/or selling the Accused
Product or any other product that infringes U.S. Patent No. 9,968,127 and/or U.S. Patent
No. D761,487;
2. Pursuant to 35 U.S.C. §283, an Order that Defendant be permanently
enjoined from making, importing, using, offering for sale, and/or selling the Accused
Product or any other product that infringes U.S. Patent No. 9,968,127 and/or U.S. Patent
No. D761,487;
3. Pursuant to 35 U.S.C. §284, that Defendant pay plaintiff actual damages
as may be proved at trial, and in no event less than a reasonable royalty;
4. Pursuant to 35 U.S.C. §289, that Defendant pay plaintiff an amount of
damages equal to the profits realized by Defendant from the sale of the Accused Product
as may be proved at trial;
5. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded treble damages;
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6. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded interest on damages;
7. Pursuant to 35 U.S.C. §285, that Plaintiff be awarded its reasonable
attorney fees;
8. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded its costs; and
9. Such other relief as this Court deems equitable and just.
DEMAND FOR A JURY
Pursuant to the provisions of Rule 38(b) of the Federal Rules of Civil Procedure,
Plaintiff demands a trial by jury on all issues so triable in this matter.
DATED: July 14, 2018
Neil D. Kodsi___ ___

NEIL D. KODSI, ESQUIRE
Florida Bar No. 0011255
Email: nkodsi@ndkodsilaw.com
THE LAW OFFICES OF NEIL D. KODSI
1666 J.F. Kennedy Causeway, Suite 420
North Bay Village, FL 33141
Telephone: (786) 464-0841
Facsimile: 954-790-6722
Email: nkodsi@ndkodsilaw.com
Counsel for Plaintiff, Tyger Manufacturing, LLC
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Case 1:18-cv-22846-KMW Document
JS 44 (Rev. 06/17) FLSD Revised 06/01/2017 1-1 COVER
CIVIL EnteredSHEET
on FLSD Docket 07/14/2018 Page 1 of 2
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.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a) PLAINTIFFS TYGER MANUFACTURING LLC, DEFENDANTS GREGORY MEADE d/b/a GLUNT
(b) County of Residence of First Listed Plaintiff San Mateo, California County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Neil D. Kodsi, The Law Offices of Neil D. Kodsi, 1666 JF Kennedy
Causeway, Suite 420, North Bay Village, FL 33141
(d) Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH MARTIN ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff)
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729 (a))
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151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
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Student Loans 340 Marine Injury Product 840 Trademark 470 Racketeer Influenced and
(Excl. Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) 490 Cable/Sat TV
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 850 Securities/Commodities/
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RE-FILED CASE(S) JUDGE: DOCKET NUMBER:
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):
VII. CAUSE OF ACTION 35 U.S.C. §271(a)
LENGTH OF TRIAL via 2-3 days estimated (for both sides to try entire case)
VIII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION
DEMAND $ 250,000.00 CHECK YES only if demanded in complaint:
COMPLAINT: UNDER F.R.C.P. 23
JURY DEMAND: Yes No
ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE SIGNATURE OF ATTORNEY OF RECORD
July 14, 2018
FOR OFFICE USE ONLY

RECEIPT # AMOUNT IFP JUDGE MAG JUDGE
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Case 1:18-cv-22846-KMW Document 1-1 Entered on FLSD Docket 07/14/2018 Page 2 of 2
JS 44 (Rev. 06/17) FLSD Revised 06/01/2017
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. (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
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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
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Brief Description: Unauthorized reception of cable service
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Date and Attorney Signature. Date and sign the civil cover sheet.
EXHIBIT A: U.S. Patent No. 9,968,127

EXHIBIT B: U.S. Patent No. D761,4877

EXHIBIT C: Pictures of Plaintiff’s TWISTY™ Glass Blunt Pipe

ase 1:18-cv-22846-KMW Document 1-4 Entered on FLSD Docket 07/14/2018 Page 2 of
ase 1:18-cv-22846-KMW Document 1-4 Entered on FLSD Docket 07/14/2018 Page 3 of
EXHIBIT D: Web Page and Glass Blunt Pipe of GLUNT

Glunt - GLUNT Page 1 of 2
HOME SHOP SIGN IN 
Home  Products  Glunt
GLUNT
Glunt
glunt-1
$25.00 $50.00
COLOR
Jet Black
ADD TO CART
Edit Countdown Timer
50% Off Glunt. Sale Ends in...

0 0 0 :1 4 : 5 7 :5 1
Days
1 1 1 Hours
1 4 Minutes
5 7 Seconds
5 1
Product Description
The Glunt serves as both a storage and smoking tool. Stores 2 gram
tobacco. Does not need to be filled completely to use. Each package
with an extra rubber mouthpiece, and a cap so you can use your Gl
storage device. Discreet shipping available at checkout. This produc
is intended for legal tobacco use only.
Order Turnaround
Due to the high demand for this product, customers who select the
processing option may have their order take up to 10 business days
process. For faster processing, please select priority shipment optio
checkout.
Fraudulent Transactions
Buyers that use a debit or credit card to engage in fraud or an unau
transaction on our web store will be reported to authorities neares
shipping address.
Collections: Boutique Shop

Type: Glunt
CUSTOMER REVIEWS
Based on 2 reviews Write a review
GREAT PULL
R. Roten on Jun 13, 2018

I’ve had my Glunt for five months, and it’s the best investment and alternative to paper. The pull is amazing and you can fit so much inside. Only thing I would suggest is
adding cleaning tools with it. Other then that it’s an amazing investment.
Report as Inappropriate
CHEAP GLASS
Steve on Jun 11, 2018
https://www.gluntofficial.com/products/glunt 6/16/2018
RELATED ITEMS
Glunt Glass Replacement Easytwist Grinder

$10.00 $15.00
TRACK YOUR ORDER SHIPPING POLICY RETURNS & REFUNDS
MONEY BACK GUARANTEE PROTECTION PLAN FAQS
WHOLESALE PRIVACY POLICY CONTACT US
© 2018 GLUNT.
EXHIBIT E: Letter to Gregory Meade d/b/a GLUNT

FOX & ASSOCIATES

1885 Washington Street, Unit 5
South Walpole, MA 02071
Steven N. Fox, Esq. Voice: 781-821-8920
Patents, Trademarks & Copyrights Fax: 781-821-8919
sfox@foxpatent.com
______________________________________________________________________________
June 20, 2018
Via Email: info@gluntofficial.com
Mr. Gregory Meade d/b/a Glunt

P.O. Box 770
Willimantic, CT 06226
Re: Infringement of U.S. Patent Nos. 9,968,127 and D761,487
Dear Mr. Meade:
We serve as counsel to Tyger Manufacturing LLC of Walnut, California.
Our client is the owner of U.S. Patent No. 9,968,127 entitled “Smoking Device” that
issued on May 15, 2018. Attached as Exhibit A is a copy of U.S. Patent No. 9,968,127. Our
client is also the owner of U.S. Patent No. D761,487 entitled “Smoking Device” that issued on
July 12, 2016. Attached as Exhibit B is a copy of U.S. Patent No. D761,487. In this regard, our
client send you an e-mail on February 7, 2018, advising you of the design patent and asserting
that your glass blunt pipe was infringing U.S. Patent No. D761,487.
As you know, our client sells a glass blunt pipe under the marks 7PIPE and TWISTY that
has been highly successful and received acclaims by the industry for its unique and elegant
functional and aesthetic designs. Our client’s glass blunt pipe has gone viral on the internet.
Attached as Exhibit C is a copy of a web page and pictures of from your web site
(ww.gluntofficial.com) offering for sale a glass blunt pipe. Our client ordered a glass blunt pipe
from your web site and we have examined the same. For reasons that follow, your glass blunt
pipe infringes U.S. Patent Nos. 9,968,127 and D761,487.
Claim 1 of U.S. Patent No. 9,968,127 provides as follows:
1. A device for consuming a smoking material comprising:

a glass housing comprising a lower open end portion, an upper open end portion, and an
inner portion;
a mouthpiece comprising a rear body portion centrally disposed within said lower end
portion of said glass housing; said rear body portion comprises a rear surface and first and
second air passage ways extending inward from said rear surface;
a first rubber o-ring removably attached to said rear body portion; said rear body portion
of said mouthpiece being rotatably and sealably engaged with said lower open end portion of
said glass housing by said first rubber o-ring;
Page 2 of 3
an auger comprising a first end portion engaged with said rear body portion of said
mouthpiece and a second end portion extending within said inner portion of said housing to form
a bowl area at said upper open end portion of said glass housing; said bowl area being bound by
said upper open end portion of said glass housing and said second end portion of said auger; and
rotation of said mouthpiece causes rotation of said auger causing the smoking material within
said glass housing to move toward said bowl area.
Each and every limitation of claim 1 is present in your glass blunt pipe. Taking each
limitation of claim 1 in order, your glass blunt pipe clearly has a “glass housing comprising a
lower open end portion, an upper open end portion, and an inner portion” as required by claim 1.
Next, your glass blunt pipe clearly has a “mouthpiece comprising a rear body portion centrally
disposed within said lower end portion of said glass housing...” The removable mouth stem of
your glass blunt pipe when engaged with the rear body portion (by it screwing on) which is
rotatably engaged with the lower end of your pipe’s glass housing corresponds to the limitation
of a “mouthpiece comprising a rear body portion” as required by claim 1. Making the mouth
stem of your glass blunt pipe removable from the rear body portion does not avoid infringement
of this element of claim 1. Next, the rear body portion of your glass blunt pipe clearly has a “rear
surface and first and second air passage ways extending inward from said rear surface.” We note
that in your glass blunt pipe the air passage ways exit a side of the rear body portion located
outside the housing. This difference between your glass blunt pipe and claim 1 is not relevant as
the scope of claim 1 only requires that “first and second air passage ways [extend] inward from
said rear surface.” Next, your glass blunt pipe clearly has a “first rubber o-ring removably
attached to said rear body portion” as required by claim 1. Further, your glass blunt pipe clearly
operates such that “said rear body portion of said mouthpiece being rotatably and sealably
engaged with said lower open end portion of said glass housing by said first rubber o-ring...”
Next, your glass blunt pipe clearly has “an auger comprising a first end portion engaged with
said rear body portion of said mouthpiece and a second end portion extending within said inner
portion of said housing to form a bowl area at said upper open end portion of said glass
housing...” Next, the “bowl area of your glass blunt pipe is clearly “bound by said upper open
end portion of said glass housing and said second end portion of said auger.” Finally, rotation of
the mouthpiece of your glass blunt pipe “causes rotation of said auger causing the smoking
material within said glass housing to move toward said bowl area.” For all the above reasons,
your glass blunt pipe clearly infringes claim 1 of U.S. Patent No. 9,968,127.
Further, except for the shape of the mouth stem, your glass blunt pipe is virtually
identical in ornamental appearance to the claimed design of U.S. Patent No. D761,487. As such,
a consumer would clearly be deceived and confused between your glass blunt pipe and the
claimed design of U.S. Patent No. D761,487. As such, your product infringes U.S. Patent No.
D761,487. Further, our client also has a pending continuation design patent application where
the end portion of the mouthpiece outside the glass housing is not part of the claimed design. We
expect this design patent to issue soon.
For all of the above reasons, your import and sale of your glass blunt pipe infringes U.S.
Patent Nos. 9,968,127 and D761,487. Your infringement has caused my client irreparable harm
and monetary damages. Moreover, in view of our client’s prior e-mail to you and thus your prior
knowledge of U.S. Patent No. D761,487, your import and sale of your glass blunt pipe has been
and continues to be a willful infringement of U.S. Patent No. D761,487 entitling our client to
Page 3 of 3
treble damages and attorney fees.
Further, attached as Exhibit D is a test report by a company who tested the one-piece rear
body portion and spiral flange of your glass blunt pipe. As shown in the test report, the rear body
portion and spiral flange of your glass blunt pipe contain excessive amounts of lead that would
be harmful to any person smoking your glass blunt pipe. Consumers will associate your inferior
and harmful glass blunt pipe with our client’s glass blunt pipe thereby causing our client further
irreparable harm and monetary damages. Still further, the public has been and continues to be
harmed by your glass blunt pipe.
In order to settle this matter short of a civil action, our client requires the execution of a
mutually satisfactory settlement agreement that provides the following major terms and
conditions:
1. You shall immediately stop and refrain from selling the glass blunt pipe or any
other smoking device that infringes U.S. Patent No. D761,487;
2. For the period of July 12, 2016, to date, you shall provide a written accounting of
the number of units of the glass blunt pipe imported into the US by your company
and/or made in the US by or for your company;
3. For the period of July 12, 2016, to date, you shall provide a written accounting of
the number of units of the glass blunt pipe sold and gross sales;
4. Your company shall deliver all remaining units of the glass blunt pipe to our
client for destruction; and
5. Your company shall pay damages in an amount based upon the written
accounting, not to exceed your profits or our client’s lost profits.
Our client requests your reply on or before June 26, 2018. If we do not receive your
timely reply, our client shall pursue further action.
If you should have any questions, please do not hesitate to contact us.
Very truly yours,
FOX & ASSOCIATES
________________________
Steven N. Fox
cc. Jeffrey Han, Tyger Manufacturing LLC

EXHIBIT A: U.S. Patent No. 9,968,127

EXHIBIT B: U.S. Patent No. D761,4877

EXHIBIT C: Web Page and Glass Blunt Pipe of GLUNT

Home  Products  Glunt
GLUNT
Glunt
glunt-1
$25.00 $50.00
COLOR
Jet Black
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Product Description
The Glunt serves as both a storage and smoking tool. Stores 2 gram
tobacco. Does not need to be filled completely to use. Each package
with an extra rubber mouthpiece, and a cap so you can use your Gl
storage device. Discreet shipping available at checkout. This produc
is intended for legal tobacco use only.
Order Turnaround
Due to the high demand for this product, customers who select the
processing option may have their order take up to 10 business days
process. For faster processing, please select priority shipment optio
checkout.
Fraudulent Transactions
Buyers that use a debit or credit card to engage in fraud or an unau
transaction on our web store will be reported to authorities neares
shipping address.
Collections: Boutique Shop

Type: Glunt
CUSTOMER REVIEWS
Based on 2 reviews Write a review
GREAT PULL
R. Roten on Jun 13, 2018

I’ve had my Glunt for five months, and it’s the best investment and alternative to paper. The pull is amazing and you can fit so much inside. Only thing I would suggest is
adding cleaning tools with it. Other then that it’s an amazing investment.
CHEAP GLASS
Steve on Jun 11, 2018
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© 2018 GLUNT.
EXHIBIT D: Test Report of Glass Blunt Pipe by GLUNT


Tyger Mfg. v. Meade - Complaint

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Tyger Mfg. v. Meade - Complaint

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Case 1:18-cv-22846-KMW Document 1 Entered on FLSD Docket 07/14/2018 Page 1 of 7

UNITED STATES DISTRICT COURT

TYGER MANUFACTURING LLC,

GREGORY MEADE d/b/a GLUNT,

COMPLAINT AND DEMAND FOR JURY TRIAL

Gregory Meade d/b/a Glunt, alleges as follows:

1. Plaintiff, Tyger Manufacturing LLC, is a California limited liability company

CA 94402 (hereinafter “Plaintiff”).

FL 33139 (hereinafter “Defendant”).

JURISDICTION AND VENUE

§§1331 and 1338(a).

business within the State of Florida.

7. Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b) and

No. 9,968,127. U.S. Patent No. 9,968,127 is valid and enforceable.

No. D761,487. U.S. Patent No. D761,487 is valid and enforceable.

unhealthy levels of lead (the “Lab Report”).

Defendant continues to offer for sale the Accused Product.

COUNT I - PATENT INFRINGEMENT - U.S. PATENT NO. 9,968,127

fully alleged herein.

Product corresponds to the limitation of a “mouthpiece comprising a rear body portion”

said glass housing to move toward said bowl area.”

in violation of 35 U.S.C. §271(a).

infringement of U.S. Patent No. 9,968,127.

protection afforded by claim 1 of U.S. Patent No. 9,968,127 is broad.

20. As a result of Defendant’s infringement of U.S. Patent No. 9,968,127, Plaintiff

has and continues to incur irreparable harm.

21. As a result of Defendant’s infringement of U.S. Patent No. 9,968,127, Plaintiff

has and continues to incur monetary damages.

COUNT II - PATENT INFRINGEMENT - U.S. PATENT NO. D761,487

fully alleged herein.

infringes U.S. Patent No. D761,487 in violation of 35 U.S.C. §271(a).

infringement of U.S. Patent No. D761,487.

protection afforded by claimed design of U.S. Patent No. D761,487 is broad.

27. As a result of Defendant’s infringement of U.S. Patent No. D761,487, Plaintiff

has and continues to incur irreparable harm.

28. As a result of Defendant’s infringement of U.S. Patent No. D761,487, Plaintiff

has and continues to incur monetary damage.

defendant on the above counts and grant it the following relief:

1. Pursuant to 35 U.S.C. §283, an Order that Defendant be preliminary

2. Pursuant to 35 U.S.C. §283, an Order that Defendant be permanently

3. Pursuant to 35 U.S.C. §284, that Defendant pay plaintiff actual damages

as may be proved at trial, and in no event less than a reasonable royalty;

4. Pursuant to 35 U.S.C. §289, that Defendant pay plaintiff an amount of

as may be proved at trial;

5. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded treble damages;

6. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded interest on damages;

7. Pursuant to 35 U.S.C. §285, that Plaintiff be awarded its reasonable

8. Pursuant to 35 U.S.C. §284, that Plaintiff be awarded its costs; and

9. Such other relief as this Court deems equitable and just.

DEMAND FOR A JURY

Plaintiff demands a trial by jury on all issues so triable in this matter.

DATED: July 14, 2018

Neil D. Kodsi___ ___

Citizen or Subject of a 3 3 Foreign Nation 6 6

FOR OFFICE USE ONLY

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INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

EXHIBIT A: U.S. Patent No. 9,968,127

EXHIBIT B: U.S. Patent No. D761,4877

EXHIBIT C: Pictures of Plaintiff’s TWISTY™ Glass Blunt Pipe

EXHIBIT D: Web Page and Glass Blunt Pipe of GLUNT

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