Engineered by Schildmeier v. Wuhu Xuelang Auto Parts - Complaint

Case 1:18-cv-03239-RLY-MJD Document 1 Filed 10/18/18 Page 1 of 11 PageID #: 1
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF INDIANA
INDIANAPOLIS DIVISION
__________________________________________
ENGINEERED BY SCHILDMEIER, LLC ) Cause No: 1:18-cv-3239
) JURY TRIAL DEMAND
Plaintiff )
V. )
WUHU XUELANG AUTO PARTS CO., LTD )
AMAZING PARTS WAREHOUSE dba as several names )
Defendants. )
COMPLAINT
Plaintiff ENGINEERED BY SCHILDMEIER, LLC (hereinafter “Schildmeier” or “Plaintiff”)

by its attorney, John D. Ritchison, as and for its complaint against Defendants, Amazing Parts
Warehouse, dba several and Wuhu Xuelang Auto Parts Co., Ltd, (hereinafter “Defendants”
or “Named Defendants”) and alleges as follows:
Page 1 of 11
ENGINEERED BY SCHILDMEIER, LLC v Amazing Parts Warehouse dba as several
names and Wuhu Xuelang Auto Parts Co., Ltd Page 2 of 11
I. NATURE OF THE ACTION
1. This is an action under the Patent Act, 35 U.S.C. §§ 1, et seq., for patent infringement [and
more specifically under 35 U.S.C. §271 and §289] and the Lanham Act, 15 U.S.C. § 1051, et
seq., for trade dress infringement/ unfair competition.
2. As alleged in detail below, Defendants have engaged in a conscious, systematic, and willful
pattern of patent infringement as well as trade dress/ unfair competition, to the damage of the
Plaintiff.
II. JURISDICTION AND VENUE
3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 (federal question); and
28 U.S.C. § 1332 (diversity); 28 U.S.C. §1338(a) (action arising under the Patent Act); 28 U.S.C.
1338(b) (unfair competition joined with claims under the Patent Act) and 15 U.S.C. § 1121.
4. Upon information and belief, this Court has personal jurisdiction over both Defendants --
Amazing Parts Warehouse, dba as several names and Wuhu Xuelang Auto Parts Co., Ltd
(hereinafter called Named Defendants) -- because, inter alia, both named Defendants have
committed, or aided, abetted, contributed to, or participated in, acts of patent infringement and
trade dress infringement in the State of Indiana and in this Judicial District and has sold the
product complained of herein in this Judicial District.
5. Venue is proper in this district pursuant to 28 U.S.C. § 1391 because, inter alia, both Named
Defendants transact business in this Judicial District by offering for sale and selling the products
complained of herein in Indiana, both Named Defendants are subject to personal jurisdiction in
this Judicial District, and a substantial part of the events or omissions giving rise to the claim
occurred in this Judicial District, and Plaintiff ENGINEERED BY SCHILDMEIER, LLC is
located in and being damaged in this Judicial District.
III. THE PARTIES
6. Plaintiff ENGINEERED BY SCHILDMEIER, LLC or “Schildmeier” is an Indiana Limited

Liability Company with a business address of 5575 S. Shadow Lane, Anderson, IN, 46017.
7. Upon information and belief, Defendant Amazing Parts Warehouse owns and operates a
distribution warehouse business located at: Amazing Parts Warehouse, 172 Trade Street,
Lexington, KY 40511 and as USKYN Warehouse, 41 Logistics Blvd, Suite A-2, Walton, KY
41094. Amazing Parts Warehouse have several websites and offer exact copies of the Plaintiff’s
product. See comparison of products Exhibit A. Amazing Parts Warehouse appears to sell the
same product as various dba/ doing businesses with different named entities. See Exhibit B.
Most, if not all, the dbas are using the same distribution address but have various packaging
means at or near this address on Trade Street.
8. Upon information and belief, Defendant Wuhu Xuelang Auto Parts Co., Ltd is a business
entity in China with a place of business at No. 518 Third XiZhi Road, Wuhu, Anhui,241000,
People’s Republic of China. See Exhibit C.
9. Upon information and belief, Defendants Amazing Parts Warehouse may be using the same
parts sourcing as Wuhu Xuelang Auto Parts Co., Ltd. This is based on comparison of mold
markings from various parts purchased in preparation of this complaint.
IV. PLAINTIFF’S PATENT

10. Plaintiff Schildmeier’s patent is U.S. Design Patent No. D 816,584 for a “PAIR OF BED
RAIL STAKE POCKET COVERS”. The application was filed on December 2, 2015 and the
Design patent issued on May 1, 2018 from the United States Patent and Trademark Office
(hereinafter the “’584 Patent”). A copy of the ‘584 Patent is attached as Exhibit D.
11. The Named Defendants have no known similar or associated Intellectual Property. However,
a close comparison and explanation of the Plaintiff’s and Defendant’s parts are described in
Exhibit A.
V. DEFENDANTS’ INFRINGING ACTS
12. Defendants have been offering to sell product on various websites since February, 2018.
These include individual websites as well as Amazon and eBay.
13. Amazon has responded to requests to take down advertisements when shown the Design
Patent. Amazing Parts Warehouse waits a time then reinitiates the Amazon efforts under a
different dba. Then Amazon is re-informed and the alleged infringing products are again
removed. The cycle repeats almost monthly.
14. With the advertisements on eBay, the removal has been refused. They (eBay) take the
position that will not act on validity of patents without Court direction. See Exhibit E. EBay
will not remove the advertisement of the alleged infringing defendants without specific Court
direction.
15. The Named Defendants’ BED RAIL STAKE POCKET COVERS includes each and every
limitation shown in the Plaintiff’s Design Patent D ‘584. See Exhibit A. Therefore, the
Defendants’ Pocket Covers is a literal infringement of the D’584 patent.
Plaintiff’s Parts Defendants’ Parts
VI. DEFENDANTS’S NOTICE OF SCHILDMEIER’S PATENT RIGHTS
16. Plaintiff Schildmeier continues to notify the Defendants with a Cease and Desist letter sent
through the Amazon and eBay contact emails as well as direct contacts with the websites and US
Postal services. See a typical letter Exhibit F.
17. On one occasion the response was an attempt to set process which Schildmeier declined. See
Exhibit G.
18. Upon information and belief, Plaintiff Schildmeier has lost nearly $100,000 in lost profits
since February and is continuing to lose a minimum of $3,000.00 in profits per week.
COUNT I
FEDERAL PATENT INFRINGEMENT
(U.S. Patent No. D 816,584)
19. ENGINEERED BY SCHILDMEIER, LLC reincorporates the allegations contained in
paragraphs 1-18 above as if fully set forth herein.
20. Named Defendants, through their respective agents, employees, and/or servants, have been and
currently are committing acts of direct infringement of the `584 Patent by making, using, selling,
importing, and/or offering for sale in the United States the counterfeit and infringing BED RAIL
STAKE POCKET COVERS. In particular, the design claimed in the `584 Patent and the Named
Defendants’ BED RAIL STAKE POCKET COVERS are not only identical, but substantially the
same, such that an ordinary observer, giving such attention as a purchaser usually gives, would be
deceived into believing that the BED RAIL STAKE POCKET COVERS counterfeited by the
Named Defendants are the same as the design claimed in the `584 Patent, therefore inducing an
ordinary purchaser to purchase the Defendants’ BED RAIL STAKE POCKET COVERS supposing
them to be the design claimed in the Plaintiff’s `584 Patent.
21. Named Defendants have infringed and continue to infringe the `584 Patent by, inter alia,
making, using, offering to sell, or selling in the United States, including the State of Indiana and
within this District, the BED RAIL STAKE POCKET COVERS using the ornamental design
covered by the `584 Patent in violation of 35 U.S.C. § 271.
22. Named Defendants acts of infringement of the `584 Patent were undertaken without authority,
permission or license from Plaintiff Schildmeier.

23. Named Defendants infringing activities violate 35 U.S.C. § 271 and that the ‘584 patent has,
under the Patent Act, 35 U.S.C. §§ 1, et seq., a presumption of validity once the patent is examined
and issued issued by the United States Patent Office.
24. Upon information and belief, Named Defendants have deliberately and willfully infringed upon
Schildmeier’s exclusive rights under the `584 Patent, with full notice and knowledge thereof.
25. Upon information and belief, Named Defendants, from their infringing activities of the `584
Patent, have received and will continue to receive, gains, profits, and advantages, in an amount not
presently known to Schildmeier.
26. Schildmeier has been, and continues to be, greatly damaged by reasons of these acts of
infringement and, upon information and belief, Named Defendants will continue to infringe the `584
Patent.
27. Schildmeier has suffered and will continue to suffer irreparable harm in its trade and business as
a result of Named Defendants’ infringement of the `584 Patent, for which Schildmeier is entitled to
both preliminary and permanent injunctive relief pursuant to 35 U.S.C. § 283.
28. As a result of Named Defendants’ infringement of the `584 Patent, Schildmeier is entitled to
statutory relief pursuant to 35 U.S.C. § 289.
29. Schildmeier is entitled to monetary damages pursuant to 35 U.S.C. § 284 in an amount to be
proven at trial and/or Named Defendants’ profits on the BED RAIL STAKE POCKET COVERS by
Named Defendants.
30. Upon information and belief, Named Defendants have engaged and are engaged in willful and
deliberate infringement of the `584 Patent. Such willful and deliberate infringement justifies an
increase of three times the damages to be assessed pursuant to 35 U.S.C. § 284 and further qualifies
this action as an exceptional case supporting an award of reasonable attorney’s fees pursuant to 35
U.S.C. § 285.
COUNT II
TRADE DRESS INFRINGEMENT
31. Plaintiff repeats each of the allegations set forth in paragraphs 1-30 as though set forth herein in
their entirety.
32. Upon information and belief, the design of the BED RAIL STAKE POCKET COVERS offered for
sale by Named Defendants, including within the State of Indiana and within this judicial district, is
confusingly similar to the BED RAIL STAKE POCKET COVERS sold by Schildmeier, and is likely
to cause confusion, mistake, or deception to the public as to the source, origin, sponsorship, or approval
of such products.
33. Upon information and belief, Named Defendants have deliberately and willfully infringed the
trade dress rights of Schildmeier in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).
34. Schildmeier has been and will continue to be irreparably harmed by such infringement unless this
Court enjoins Named Defendants under 15 U.S.C. § 1116 from its continuing infringement.
35. As a result of Named Defendants’ deliberate and willful infringement, Schildmeier is entitled to
damages, Named Defendants’ profits, an award of attorneys’ fees and costs, and any and all relief
authorized under 15 U.S.C. § 1117.

COUNT III
Declaratory Judgment of Design Patent Validity and Trade Dress Validity
their entirety.
37. Upon information and belief, Patentee's alleged design patent in and to the design shown in the
drawings represented in Exhibit F, and covered by United States Design Patent No. D ‘584 is invalid
pursuant to the Patent Act.
38. Named Defendants products infringe Patentee's purported design patent ‘584.
39. Schildmeier is therefore entitled to a declaratory judgment of Schildmeier’s rights and,
specifically, that Named Defendants’ manufacture, use, or sale of its products infringe any patent rights
Schildmeier may have.
COUNT IV
Declaratory Judgment of Infringement and Validity of Trade Dress
their entirety.
41. Patentee Schildmeier's purported trade dress is valid and protectable in that it is distinctive, has
acquired secondary meaning, and is ornamental. Named Defendants’ sale of BED RAIL STAKE
POCKET COVERS products are likely to cause confusion, deception or mistake among consumers
as to the source, sponsorship, affiliation or authorization of such products and specifically are likely
to cause confusion among consumers vis-a-vis Patentee of any of Patentee's products. Schildmeier
is entitled to a declaratory judgment of its rights and, specifically that Named Defendants’
manufacture, promotion, advertising and sale of BED RAIL STAKE POCKET COVERS products
violate trade dress rights of Schildmeier under 15 U.S.C. § 1125.
COUNT V
Unfair Competition
their entirety.
43. The acts of Patentee described above constitute unfair competition under applicable state law.
JURY DEMAND
44. Plaintiff Schildmeier requests a trial by jury for all issues proper for a jury to decide.
PRAYER FOR RELIEF
WHEREFORE, Schildmeier prays that this Court grant the following relief:
(a) Judgment determining that United States Design Patent No. D 816,584 is valid, enforceable, and
infringed, directly and/or indirectly, by the Named Defendants;
(b) Judgment that Named Defendants have infringed Schildmeier’s trade dress and violated Section
43(a) of the Lanham Act;
(c) An Order preliminarily and permanently enjoining Named Defendants, and their affiliates and
subsidiaries, and each of their officers, agents, servants, employees, successors, and assigns, and all
others in concert and privity with them from selling or offering for sale the BED RAIL STAKE
POCKET COVERS, or any equivalent thereof, in the United States;
(d) Award Schildmeier the total profits realized by Named Defendants on the BED RAIL STAKE
POCKET COVERS, or any equivalent thereof, that infringe the `584 Patent, pursuant to 35 U.S.C. §
289;
(e) Award damages to compensate Schildmeier for Named Defendants’ infringement of the `584 Patent
pursuant to 35 U.S.C. § 284;
(f) Award Schildmeier the total profits realized by Named Defendants on the BED RAIL STAKE
POCKET COVERS, or any equivalent thereof, that infringe Schildmeier’s trade dress and otherwise
constitute unfair acts pursuant to 15 U.S.C. § 1117;
(g) Award Schildmeier enhanced damages pursuant to 35 U.S.C. § 284;
(h) Award Schildmeier pre-judgement and post-judgment interest and costs in accordance with 35
U.S.C. § 284;
(i) Declare this case to be exceptional and award Schildmeier its attorneys’ fees, costs and expenses
incurred in prosecuting this action, pursuant to 35 U.S.C. § 285 and Section 35 of the Lanham Act (15
U.S.C. § 1117); and
(j) All other just and proper relief in the premises.
Respectfully submitted,
For ENGINEERED BY SCHILDMEIER, LLC
/s/ John D. Ritchison
John D. Ritchison, Attorney No. 12066-48

Ritchison Law Offices, PC
115 East Ninth Street – Ste. A
Anderson, IN 46016
765-640-4134
jdritchison@comcast.net
A Quick review of the Product and
New Accessory
Disputed Business GM Trucks
forsituation
Amazon Communication
A New Accessory for GM Trucks
April 12, 2018
Update to Case ID 4881996831
Protected by US Design Patent D816584
Plaintiff's EXHIBIT A Page 1

Stake Pocket Covers for
GM Trucks
By
Plaintiff's Exhibit A
Eugene Schildmeier
Owner: Engineered by Schildmeier, LLC

Case 1:18-cv-03239-RLY-MJD Document 1-1 Filed 10/18/18 Page 1 of 20 PageID #: 12
Background
When GM introduced their new full size pickup trucks in 2014 they added a new feature.
An odd shaped stake pocket hole that is advertised as an “ergonomically friendly hand
hold” to grab as you put your foot on the bumper and pull yourself up into the bed.

However, many owners don’t want stake pocket holes on their truck. But, no
one has successfully designed covers for these odd shaped holes…..until now.
The Design

A friend of mine knew I had a 3D printer, and asked me if I could design a set of
covers for these holes and print a set for his truck. I told him to go buy a set and he
said that NO ONE in the world makes them, not even GM. I have decades of
experience in automotive and aerospace design. It took several tries because the
shapes and angles are all different, but I finally got it. Everyone that saw them
wanted a set. So I contacted a patent attorney to see if the design was patentable.
U.S. Patent #D816584

This is the cover of the patent I submitted to the U.S. This is the notice I received on April 12, 2018 that
Patent and Trademark Office on December 2, 2015. my U.S. Patent was issued. It is U.S. Patent
Serial No. 29/547310. #D816584
U.S. Patent #D816584

These show a couple of pictures from my issued U.S. Patent #D816584
that shows my unique design.
The Infringers - all shipped from 172 Trade St, Lexington, KY
Test Buy of iFJF Bed Rail Stake Pocket Cover
Sold by BAYEN INST

This is the test buy of the iFJF Bed Rail Stake Pocket Covers (ASIN
#B079NVDJQC). They are sold on on the
Amazon
NET by seller BAYEN INST.
Bayen shipped
Exact Copy of My Patented Design from 172 Trade St

My actual authentic Actual iFJF parts sold by
parts that I produce are BAYEN INST on Amazon
show on the left. are shown on the right.
Exact Copy of My Patented Design

My actual authentic part. Actual iFJF copy of my part.
iFJF copied my patented Stake Pocket Covers to perfection. These pictures

show that they are within one half of one thousandth of an inch. They are
sold by BAYEN INST on Amazon.
Statement
I, Eugene Schildmeier signed under penalty of perjury, that I have a good faith
belief that:
1. I have not authorized any one else to manufacture, distribute, or sell my
unique Stake Pocket Cover design covered by U.S. Patent #D816584.
2. The iFJF Stake Pocket Covers (ASIN #B079NVDJQC) shown on the previous
pages fall within the scope of my issued U.S. Patent #D816584.
3. The iFJF Stake Pocket Covers (ASIN #B079NVDJQC) sold by BAYEN INST
were never manufactured or sold in the United States by me or someone
authorized by me.

4. The seller, BAYEN INST, does not have a valid license to manufacture,
distribute, or sell my Stake Pocket Cover design covered by U.S. Patent
#D816584.
Eugene Schildmeier April 12, 2018

Illegal Proposal to FIX PRICE

This is a screen shot of an email message I received from the seller on Amazon
through my website: https://railcaps.com/
In item 1 he proposed that we collude to set the price of our Stake Pocket
Covers on Amazon at $27.99, which is totally illegal. I don’t think this is the
kind of seller you want to represent Amazon. My lawyer and I are going to
forward this and the information in presentation to the FBI and the
Department of Justice for prosecution.
Actions Requested
1. Remove the iFJF Stake Pocket Covers from the Amazon catalog.
(ASIN #B079NVDJQC) Amazon removed the units. Same requested of ebay
waiting on court decision/ direction.
2. Do not allow any other seller to sell my Stake Pocket Covers
(ASIN #B01MQVOJV0 and ASIN #B076Z6D3YJ). My company,
Engineered by Schildmeier, LLC is the only seller authorized to
sell my patented Stake Pocket Cover design.
3. Evaluate the actions of the seller BAYEN INST.

➢ They copied intellectual property that they knew was
being patented.
➢ They tried to collude to fix the price of the item they
copied on Amazon.
➢ These actions puts Amazon’s reputation at risk.
These Actions were implemented by Amazon -- However,
ebay is awaiting cout direction

Our stake pocket covers for GM trucks are the Number One “Amazon Best Seller” in
our category. And, they are the Highest Rated Item in the top 20 by verified buyers.
At ebay, we lose sales every day without a court decision

The Product
Our stake pocket covers fit flush and have a texture nearly identical to the top rail
protectors that come on every truck. This produces a custom original equipment
look that truck owners like. They also protect the stake pocket holes from rain, snow,
leaves, and mud. (Less likely to rust too.)

We designed them for a tight press fit, so you just pound them in with your fist. (See
our video at Railcaps.com.) They are made of an automotive grade ASA UV resistant
plastic that protects against color fade and degradation of mechanical properties.
The Perfect Solution
Many bed covers do not cover
these stake pocket holes, and
creates an ugly gap.

Our stake pocket covers
fixes this problem in style, &
our customers love them.
Testimonials
“Well made and perfect fit”
“The product looks great on my truck”
“excellent quality, fit perfect”
“The look and fit of these is absolutely perfect! Exactly what I had been
searching for and imagined them to be when I found the right ones!
Well here they are, great job and keep up the good work and designs!
Very pleased to buy a great quality product at a fair price.”

“Very good job on making these, look like factory”
“Just wanted to say thanks for a great product! At least someone is

thinking out there, can’t believe GM doesn’t include them with the
vehicle. Received them today and they fit perfect, thanks again!”
“Great product! Perfect fit, looks great”
These, and hundreds more can be seen on my Amazon

feedback & product review pages.
The Tooling

I had a company laser scan the stake pocket holes to ensure a perfect fit and
created a 3D computer model. Then I patented my design. We tested 3D printed
parts for over a year with no issues at all. Two years ago, we invested in a
production plastic injection mold, and now we can produce 50 sets per hour.
Manufacturing Capability

Our stake pocket covers for GM trucks are produced in a world class ISO-9001
certified manufacturing facility in Indiana that boasts an outstanding quality record.
About the Owner
Engineered by Schildmeier, LLC is owned and operated by Eugene Schildmeier.
Over 40 years experience in automotive and aerospace new product

development using statistical engineering techniques.
• 7 years at Firestone
• 26 years at GM
• 3 Years at Rolls-Royce
• 4 years at Technical Problem Solutions
• Still works part time as an international consultant solving particularly
challenging manufacturing problems for large corporations: GM, Ford,

Chrysler, VW, Rolls-Royce, Saab, GAZ, Johnson Controls, and LG Electronics.
• Publications: “Gear Noise Reduction Using Design of Experiments”, SAE
paper #981194, February 1998.
• Certified as a Master Statistical Engineer by GM
• Certified Six Sigma Black Belt – March, 2004 by American Society for Quality
• Numerous Engineering Awards from GM, 1988 through 2006
• Member of MENSA
My Patent Attorney
My patent attorney is:

John Ritchison
115 East 9th St. Suite A
Anderson, IN 46016
Email: jdritchison@comcast.net
Phone: 765-640-4134
Business Hours: Monday - Friday: 8:30 AM - 4:30 PM
Flexible appointments available
Admitted to the Southern and Northern Indiana 7th Circuit

Court of Appeals, Federal District Court, and the US Supreme
Court
Member of the Madison County and Indiana Bar Associations
John has over 30 years of experience in the patent and trademark

business. After review, he said my design was definitely patentable.
He said that Amazon is welcome to contact him.
For More Information
Visit our website at Railcaps.com
Contact information:
Eugene Schildmeier
5575 S. Shadow Lane
Anderson, IN 46017

Cell: 765-621-8342
Land: 765-779-4741
schildmeier@comcast.net
EBAY
Seller User Name Date Time Item Number Price Sold
lelecar_com 5/3/2018 6:30am 332543901739 $12.99 48
lelecar_com 5/3/2018 6:30am 332544725989 $13.99 56 Shows the customer reviews of my authentic parts on his ad.
lelecar_com 5/3/2018 6:30am 332565423148 $15.50 1 Sold
EXHIBIT B DBAs
- PAGE 1
lelecar_com 5/3/2018 6:30am 332603670426 $14.50 1 Sold Shows the customer reviews of my authentic parts on his ad.
PLAINTIFF'S EXHBIT B DBAS
FROM KENTUCKY LOCATION
lelecar_com 5/3/2018 6:30am 332633770360 $10.50 1 Auction
lelecar_com 5/3/2018 6:30am 332633082298 $12.99 7 Copied photos and text from my website
lelecar_com 5/3/2018 6:30am 332632892542 $15.99 Not Shown Copied photos and text from my website
f-autopart 5/3/2018 6:30am 202239326456 $15.99 48
f-autopart 5/3/2018 6:30am 202239370577 $12.99 43
fj-auto 5/3/2018 6:30am 202243257717 $12.99 63
fj-auto 5/3/2018 6:30am 192482314864 $15.99 49 Shows the customer reviews of my authentic parts on his ad.
fj-auto 5/3/2018 6:30am 192482275355 $10.99 22 Shows the customer reviews of my authentic parts on his ad.
jurgitan123 5/3/2018 6:30am 142707205498 $37.18 0 Could Not Find
is.autoparts 5/3/2018 6:30am 152924242887 $37.01 Not Shown
speedysales715 5/3/2018 6:30am 172589441144 $34.99 160 Copied photos and text from my website
speedysales716 5/3/2018 6:30am 391944397933 $36.99 5 Copied photos and text from my website
bestpricedeals2018 5/3/2018 6:30am 253469804199 $33.99 3 Copied photos and text from my website
packgold2015 5/3/2018 6:30am 302678755334 $38.28 Not Shown
prettypotato 5/3/2018 6:30am 173252114469 $31.99 Not Shown
102*best*deals 5/3/2018 6:30am 123089058111 $33.85 Not Shown Copied photos and text from my website
689
www.ebay.com/itm/
AMAZON
BAYEN INST 5/3/2018 6:30am B079NVDJQC $24.98 386 EST
EXHIBIT B DBAs
Total 1075 Sold $29,025.00 in lost sales
Open Websites
TiA Trubuilt 1 Automotive
- PAGE 2
www.okp.com
http://www.todtrade.top/
eBay
worldwide-needs 10/17/2018 4:00pm 332672587169 $11.99 13
qianying214 10/17/2018 4:00pm 232881716885 $11.99 75
qianying214 10/17/2018 4:00pm 232881675468 $9.99 69 ended
wanted2017 10/17/2018 4:00pm 163135376650 $12.99 94
wanted2017 10/17/2018 4:00pm 163135376895 $13.08 21
wanted2017 10/17/2018 4:00pm 163135376900 $13.04 11
wanted2017 10/17/2018 4:00pm 163135377196 $10.99 5
wanted2017 10/17/2018 4:00pm 163135377441 $9.30 1
wanted2017 10/17/2018 4:00pm 163266963586 $22.14 Not Shown Auction for 2 sets
wanted2017 10/17/2018 4:00pm 163266964239 $29.10 1 For 2 Sets
wanted2017 10/17/2018 4:00pm 163266963645 $107.62 Not Shown For 10 Sets
EXHIBIT B DBAs
- PAGE 3
nr_smile 9/24/2018 7:00am 292637582820 $24.95 10
spkbestdeal 9/24/2018 7:00am 183311120985 $34.49 2
blackbulloutpost 9/24/2018 7:00am 153115547481 $31.15 1
baywynne_0 9/24/2018 7:00am 223137370987 $29.99 Not Shown
joknip 9/24/2018 7:00am 223140719691 $27.49 Not Shown
southernexpressshipping 9/24/2018 7:00am 173482840889 $35.58 Not Shown
mar597997 10/17/2018 4:00pm 352470410947 $13.87 9
mar597997 10/17/2018 4:00pm 352470409718 $13.20 Not Shown
soyavision2017 10/17/2018 4:00pm 263957166157 $15.60 5
soyavision2017 10/17/2018 4:00pm 263957172964 $15.40 1
soyavision2017 10/17/2018 4:00pm 263992426756 $7.50 Auction
magicstore18 10/17/2018 4:00pm 113310145917 $12.96 Not Shown
digihero_us 10/17/2018 4:00pm 292769463206 $12.99 2
secretabcd 10/17/2018 4:00pm 283207723440 $12.77 Not Shown
kingstar_e 10/17/2018 4:00pm 113313170953 $12.99 Not Shown
hoverwheel 10/17/2018 4:00pm 223192117295 $12.98 Not Shown
caraccess18 10/17/2018 4:00pm 312266085622 $12.95 1
milady_store 10/17/2018 4:00pm 123430280362 $27.65 Not Shown
stardusthutaz 10/17/2018 4:00pm 292772235288 $26.94 Not Shown
thegift-spot 10/17/2018 4:00pm 323499973126 $26.95 Not Shown
pricekiller_2k 10/17/2018 4:00pm 352483823724 $14.46 Not Shown
325 $8,775.00 Lost Sales
Amazon
Amazon dropped the exact copy in mid May, 2018, but they still allow the sale of the version with the wide flange.
SUNPIE 10/17/2018 4:00PM B07D56H5V3 $20.99 Est. 6 per day
KIWI MASTER 10/17/2018 4:00PM B07HNWDGKK $19.89 Est. 6 per day
KING SNOWDEN 10/17/2018 4:00PM B07HK2KZY6 $22.99 Est. 6 per day This seller even uses my pictures
Amazing Parts Warehouse 10/17/2018 4:00PM B07DGLBNCY $22.49 Exact copy Silverado (Amazon Removed on 10/16/18)
Amazing Parts Warehouse 10/17/2018 4:00PM B07DGM2M1R $22.49 Exact copy Colorado (Amazon Removed on 10/16/18)
EXHIBIT B DBAs
- PAGE 4
Plaintiff's EXHIBIT C
Package label from set of stake pocket covers bought on eBay.
PLAINTIFF'S EXHIBIT C - PAGE 1

This is the company that makes the illegal copies of my patented parts.



Illlll llllllll Ill lllll llllll llll lllll lllll 111111111111111111111111111111111
PLAINTIFF'S EXHIBIT DUSOOD816584S
c12) United States Design Patent c10) Patent No.: US D816,584 S
Schildmeier (45) Date of Patent: ** May 1, 2018
(54) PAIR OF BED RAIL STAKE POCKET D469,956 S * 212003 Cone .............................. D3/303
COVERS 6,546,594 Bl * 4/2003 Wills .................... E05B 1/0069
16/412
(71) Applicant: Eugene Schildmeier, Anderson, IN
D550,457 S * 9/2007 Schlegel ...................... D 12/400
D593,935 S * 612009 Niwa ........................... Dl2/563
(US) D633,029 S * 2/2011 Stephanis .................... Dl2/188
D656,454 S * 3/2012 Bost ............................. D 12/401
(72) Inventor: Eugene Schildmeier, Anderson, IN D661,511 S * 6/2012 Manning ........................ D6/610
(US) D766,130 S * 9/2016 Baron ............................ Dl2/16
* cited by examiner
(**) Term: 15 Years
Primary Examiner - Katrina A Betton
(21) Appl. No.: 29/547,310
(57) CLAIM
(22) Filed: Dec. 2, 2015
I claim the ornamental design for a pair of bed rail stake
(51) LOC (11) Cl. ............................................... 12-16
pocket covers, as shown and described.
(52) U.S. Cl.
USPC . ... ... ... .. ... ... ... ... ... .. ... ... ... ... ... .. ... ... ... .. Dl2/400 DESCRIPTION
( 58) Field of Classification Search
USPC ...... D12/400, 414, 406-413, 414.1; D32/35, FIG. 1 is a Top perspective view of a pair of bed rail stake
D32/58; D6/317-319, 513-514 pocket covers showing my new design.
CPC .......................... B60R 9100; B60R 2011/0042 FIG. 2 is a Top view thereof.
See application file for complete search history. FIG. 3 is a Bottom view thereof.
FIG. 4 is a Long Side view thereof.
(56) References Cited FIG. 5 is a Short Side elevational view thereof.
U.S. PATENT DOCUMENTS FIG. 6 is a Front view thereof; and,
FIG. 7 is a Back view thereof.
D465,918 S * 11/2002 Burdine ......................... D3/262
D469,608 S * 212003 Nevins ........................... D3/300 1 Claim, 6 Drawing Sheets
I~
\.....~-------------------v----------------------~J
PLAINTIFF'S EXHIBIT D DESIGN PATENT - PAGE 1
U.S. Patent May 1, 2018 Sheet 1 of 6 US D816,584 S
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PLAINTIFF'S EXHIBIT E - eBay RESPONSE
John D Ritchison
From: EUGENE SCHILDMEIER <schildmeier@comcast.net>

Sent: Wednesday, September 26, 2018 7:11 AM
To: John D Ritchison
Subject: Fwd: RE: Notice of IP Infringement SR# 1-147217321880
---------- Original Message ----------

To: vero@ebay.com, John D Ritchison <jdritchison@comcast.net>
Date: February 12, 2018 at 6:43 PM
Subject: RE: Notice of IP Infringement SR# 1-147217321880
Hi,
I will submit the information you require as soon as I possible. In the mean time, can
you do something about his ads using the customer reviews of my authentic Stake
Pocket Covers? I'm concerned that when people start receiving his counterfeit parts
they will give bad reviews. This could harm my future business.
Also, how do I get his name and address to start legal action and issue a cease and
desist letter? Every day he is selling counterfeit parts is hurting me.
Thank you,
Eugene Schildmeier
765-621-8342
On February 12, 2018 at 6:06 PM vero@ebay.com wrote:

Right-click
here to
download
pictures. To
help protect
y our priv acy ,
Outlo ok
prev ented
auto matic
download of
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from the
In ternet.
eBay
RE: Notice of IP Infringement SR# 1-147217321880
Dear Eugene,
Thank you for contacting the eBay VeRO (Verified Rights Owner) Program
regarding items:
332544725989, 332544662657, 332545035937, 332545250623,

332544999295
1
PLAINTIFF'S EXHIBIT E - eBay RESPONSE - PAGE1
At this time, we are unable to process the report that you provided
regarding the alleged infringement of your U.S. patent rights.
eBay is committed to providing a safe and secure marketplace for all of its
buyers and sellers and to protecting the intellectual property rights of third
parties when it is possible for us to do so without guidance from a judicial
body. Unfortunately, patents are one instance where such guidance is
necessary to ensure that we provide a fair and open marketplace for all of
our sellers. Interpreting a patent requires expertise in the field of your
invention, which eBay does not have. And, eBay does not make, sell, or
possess the items you reported and so cannot in any event compare your
patent’s claims to the reported listings.
If the listings you reported are the subject of valid copyright or trademark
claims, please submit an updated Notice of Claimed Infringement (NOCI)
describing the basis of your claim. If you have secured, or in the future
secure, an injunction or other order from a U.S. Court or the International
Trade Commission that the products referenced in your NOCI infringe
your U.S. patent, please send us an updated NOCI containing the
following information:
(1) A copy of the injunction or other order enjoining the sale and/or offer
for sale of the accused product(s) in the United States on the basis that
they infringe upon a valid and enforceable U.S. patent that you own;
(1) A statement, signed under penalty of perjury, that you have a good
faith belief that:
a. the specific listing(s) on www.ebay.com referenced in your NOCI fall

within the scope of such equitable relief;
a. the products listed in the referenced listing(s) were never manufactured

or sold in the United States by you or someone authorized by you; and
a. the seller listing the item(s) does not have a valid license under the
patent(s) that form the basis of the injunctive or equitable relief.
If you have additional information, please email it to us at vero@ebay.com

and we will investigate this matter further. You can also mail the
appropriate documents to us at:
eBay Inc.
VeRO Program
583 W eBay Way
Draper, Utah 84020
2
Thank you for your concern in helping to keep eBay a safe and reputable
forum in which to conduct business. We appreciate your participation in
the VeRO Program.
Thanks,
Meagan S.
eBay VeRO Team
[THREAD ID: 1-1VMPE4JL]

Sent: 2/8/2018 3:29:44 PM
To: vero@ebay.com
CC: John D Ritchison
Subject: Notice of IP Infringement
Hi,
I found a seller on Ebay (lelecar_com) that has copied and is producing

stake pocket covers that I invented and he is selling them from China. I
created this design over two years ago and applied for a U.S. patent at the
U.S. Patent and Trademark Office Serial Number: 29/547310. This is my
design and I have not authorized anyone else to produce or sell this
item. This seller has illegally copied my design and is damaging my
company and Ebay's reputation.
He is also illegally using pictures in his Ebay ad that were copied from my
website: https://railcaps.com/
His is selling these copied stake pocket covers on five ads on Ebay:
332544725989, 332544662657, 332545035937, 332545250623,
332544999295.
Please quickly review the attached NOCI and remove this seller before he
damages my company and Ebay's reputation.
Note: My Ebay item number is: 162184645563
(I've been selling this item on Ebay for over two years.)
Thank you,
Eugene Schildmeier
3
eBay Document ID: 54214925002
eBay is committed to your privacy. Read our user agreement and privacy notice.
Learn how to recognize fake (spoof) emails.
Copyright © 2017 eBay Inc. All Rights Reserved. Designated trademarks and
brands are the property of their respective owners. eBay and the eBay logo are
trademarks of eBay Inc., 2145 Hamilton Avenue, San Jose, CA 95125.
4
RITCHISON LAW OFFICES, P.C.
Patents, Trademarks and Business Law John D. Ritchison, Attorney at Law
DEMAND TO IMMEDIATELY CEASE AND DESIST ALL

SALES, SUPPLY, DISTRIBUTION and MARKETING
June 27, 2018 Sent: By Email/ attached to EBay and Amazon
Messaging and First Class, Certified US Mail to
Last Known Address
Various Ebay offers – see listing PLAINTIFF'S EXHIBIT F

RE: FINAL DEMAND FOR YOU TO IMMEDIATELY CEASE AND DESIST SALES,
DISTRIBUTION AND SUPPLY OF Stake pocket covers you are selling which are
illegally produced and distributed without the owner’s permission or
authorization
EBAY Ref: 180095195172504014 EBAY Ref: 180095195172504014
Sirs/Madam:
I represent my clients ENGINEERED BY SCHILDMEIER, LLC and inventor Eugene Schildmeier

of Indiana. They hold United States Patent D816584 as well as Trademarks and Trade dress
for the products that you selling and distributing in various arenas (outlets including Amazon,
EBAY and the internet). As you have already been warned by Mr. Schildmeier, that means you
are doing this willfully. Committing these acts willfully can greatly impact any restitution and
repayment by a factor multiplied by three.
You may see their product on the USPTO.gov website under a patent search of D816584. It
has come to our attention that you have made an unauthorized use of my client’s proprietary
invention by the impact of lost sales to their company as well as tracking sales reported on the
various outlets. We are now fully asserting our rights that the invention and trade dress are
being infringed upon by your product shown and sold on the outlets as referenced in the title line
above. We demand that you immediately stop all sales and distribution.
On behalf of my clients, I demand you and your company immediately cease and desist the
manufacturing, distribution and/or sales of these Stake pocket covers. This includes sales via
all outlets in the United States via the internet or other manners of distribution by direct retail or
wholesale sales. As you neither asked for nor received permission to use the invention, I
believe you have willfully infringed my client’s rights.
The infringement is both in the patent and trade dress. The first step is determining the
meaning and scope of the patent claims asserted to be infringed, and the second step is
comparing the properly construed claims to the accused device. Markman v. Westview
Instruments, Inc. You product is every limitation (element) in the claim must be found in the
accused product either exactly (literally) or by a substantial equivalent (doctrine of equivalents).
You product is nearly identical to the products of my clients with the exception of a small overlap
at one edge and the markings of the Schildmeier LLC.
You appear, without question to infringe under the following legal doctrines and statutes:
115 East Ninth Street, Suite A Page 1 of 2
Anderson, IN 46016
Telephone (765) 640-4134 Fax: 928-752-8208
PLAINTIFF'S EXHIBIT F C AND D - PAGE 1

Cease and Desist - Stake pocket covers
Item Legal Basis Potential Penalties Forum

1 Trade Dress Triple damages/ Profits and State and
Attorney fees Federal
2 Patent Damages adequate to compensate Federal and
Infringement for the infringement, but in no event State
less than a reasonable royalty. Lost
profits that result from infringement
of their patent are also
compensable up to Triple Damages
and attorney fees
3 Patent Injunctive relief-stop State and
Infringement Federal
4 Patent Statutory Fine of $500.00 per sale District Court
Infringement up to $500,000.00
5 Criminal Patent Patent infringement is normally not FBI/ Federal
Infringement/ a criminal act. However, District Court
counterfeiting counterfeiting would be criminal
and be prosecuted for criminal
trademark infringement
6 Trade Dress Counterfeiting would be criminal State Police
criminal and be prosecuted for criminal and FBI
counterfeiting trademark infringement
Please understand that you are encouraged to seek your own legal counsel’s direction.
However, he or she will likely express to you that a cease and desist letter is not to be taken
lightly or ignored. In addition to disgorging your profits, willful infringement on an invention
comes with treble damages and attorney fees when a full patent has been proven. Also, the
matter is subject to follow-up and federal prosecution by the Federal Bureau of Investigation
should my client’s decide to seek prosecution beyond their civil rights for triple damages.
If I have not received an affirmative response from you by July 15, 2018 indicating that you
have fully complied with these requirements and that you immediately stopped all sales and
distribution, we shall need to take further action. Govern yourself accordingly.
Very truly yours,
/file copy/
John D. Ritchison
cc: Clients
115 East Ninth Street, Suite A Page 2 of 2

Anderson, IN 46016
Telephone (765) 640-4134 jdritchison@insightbb.com

John D Ritchison

Sent: Wednesday, September 26, 2018 7:31 AM
Subject: Fwd: Other: theohawk sent a message about Bed Rail Stake Pocket Covers for those
Odd Shaped Holes Silverado Sierra (Set of #153041925098
Flag Status: Flagged

From: eBay - theohawk <member@ebay.com>
To: schildmeier@comcast.net
Date: June 1, 2018 at 12:53 AM
Subject: Other: theohawk sent a message about Bed Rail Stake Pocket Covers for those Odd
Shaped Holes Silverado Sierra (Set of #153041925098
New message: You illegally copied my pictures and ...
Right-click here to download pictures. To help p ro tect y our priv acy , Outlook prev ented automatic download of this picture from the Internet. Right-click
eBay here to
download
pictures. To
help protect
y our priv acy ,
Outlo ok
prev ented
auto matic
download of
this pictu re
from the
In ternet.
New message to: urbantips160
You illegally copied my pictures and illegally used my registered trademark. I own the patent
for the stake pocket covers you are selling. See proof at
http://patentsgazette.uspto.gov/week18/OG/patent.html type in my patent number D816584.
The covers you are selling were illegally produced and/or distributed without my
authorization. I have not authorized anyone else to sell my patented design. My patent
attorney is beginning legal action against all sellers to protect my patent. Each day you sell
my patented design, you are risking thousands of dollars of legal expenses and fines.
President Trump said that he is going to go after people that steal intellectual property. Vice
President Pence used to represent me here in Anderson, IN before he became the Vice
President and I know he will not like the fact that someone is stealing money and jobs from
his old congressional district. Stop selling these stake pocket covers immediately and destroy
all of your inventory. Eugene Schildmeier
Dear urbantips160,
You illegally copied my pictures and illegally used my registered trademark. I own the
patent for the stake pocket covers you are selling. See proof at
http://patentsgazette.uspto.gov/week18/OG/patent.html type in my patent number
D816584. The covers you are selling were illegally produced and/or distributed without
my authorization. I have not authorized anyone else to sell my patented design. My
patent attorney is beginning legal action against all sellers to protect my patent. Each
1
day you sell my patented design, you are risking thousands of dollars of legal expenses
and fines. President Trump said that he is going to go after people that steal intellectual
property. Vice President Pence used to represent me here in Anderson, IN before he
became the Vice President and I know he will not like the fact that someone is stealing
money and jobs from his old congressional district. Stop selling these stake pocket
covers immediately and destroy all of your inventory. Eugene Schildmeier
- theohawk
Bed Rail Stake Pocket Covers for those Odd Shaped

Holes Silverado Sierra (Set of
Right-click
here to
download
pictures. To
help protect
y our priv acy ,
Outlo ok
prev ented
auto matic
download of
this pictu re
from the
In ternet.
Bed Rail
Stak e Po ck et
C ov ers for t
Price: $35.26
Buy it now
Quantity Remaining: 1
Free Shipping
Buy it now
Get to know the buyer theohawk
• Located: Anderson, IN, United States
• Member since: May 09, 2000
• Positive Feedback: 100%
2
We scan messages to enforce policies. Only purchases on eBay are covered by the eBay purchase protection
programs. Asking your trading partner to complete a transaction outside of eBay is not allowed.
Email reference id: [#a07-5urr0ocpct#]_[#248940e65786453dab4d7f4bb4db4f1c#]
We don't check this mailbox, so please don't reply to this message. If you have a question, go to Help & Contact.
eBay sent this message to Eugene Schildmeier (theohawk). Learn more about account protection. eBay is committed to
your privacy. Learn more about our privacy notice and user agreement.
©1995-2018 eBay Inc., 2145 Hamilton Avenue, San Jose, CA 95125
3
PLAINTIFF'S EXHIBIT G - DEF SET PRICES!!
John D Ritchison

Sent: Thursday, March 8, 2018 10:44 AM
Subject: Fwd: Home Page Contact Form submitted on Rail Caps
John,
This is from the seller on Amazon.
Your thoughts?
Gene

From: Rail Caps <donotreply@railcaps.com>
To: schildmeier@comcast.net
Date: March 8, 2018 at 7:26 AM
Subject: Home Page Contact Form submitted on Rail Caps
First and Last franklin

Name
Email Address wzboblin@qq.com
Message Hi,
this a byenins from amazon,
as both of us selling on amazon ,rail caps pocket cover.
I got suggests:
1. Both of us make the price as 27.99usd , don't fight a price war ,ok??
2. (a) I knew your patent is pending or may be rejected if someone protest to uspto.
so i got a question,we could give you 2 dollars per item we sold and you authorize us to sell this products,
no matter your patent approved or rejected.
for we don't argue with anyone.
(b) And you should import this products from us,since our cost is much lower than yours.
We can manufacture it , pack it up ,stick the label,send to your warehouse in us .(you could save more work and
cost)
(c) And even more,we could send this products to our warehouse in us,and when you sold,just tell us the address to
ship it.
(d) And even more,you could authorize us to operate your store on amazon or ebay or your website,what you
should do is collect money when products sold !!.
there is 2 pros, 1. we operate your stores ,you will have more time to develop products,no more
packing,shipping,after-servce etc...
2. we have a 50 person team to operate the store ,more professional,and more efficiency,
we have more people energy to publicize the products,and you could save more cost on people work.
so what you need is just collect money,and develop more products to earn more money !
1
PLAINTIFF'S EXHIBIT G - PAGE 1
If you got any questions,don't hesitate to inform me,we could dicuss further.
No matter you accept or not,we don't want to argue with anyone,
Looking forward to your reply.
Regards.
Frank.
Schildmeier, LLC, 1106 Meridian St., Anderson, IN, 46016, United States, RailCaps.com
Right-click
here to
download
pictures. To
help protect
y our priv acy ,
Outlo ok
prev ented
auto matic
download of
this pictu re
from the
In ternet.
UNSUBSCRIBE
2
PLAINTIFF'S EXHIBIT G - PAGE 2

Engineered by Schildmeier v. Wuhu Xuelang Auto Parts - Complaint

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Engineered by Schildmeier v. Wuhu Xuelang Auto Parts - Complaint

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Case 1:18-cv-03239-RLY-MJD Document 1 Filed 10/18/18 Page 1 of 11 PageID #: 1

UNITED STATES DISTRICT COURT

ENGINEERED BY SCHILDMEIER, LLC ) Cause No: 1:18-cv-3239

) JURY TRIAL DEMAND

WUHU XUELANG AUTO PARTS CO., LTD )

AMAZING PARTS WAREHOUSE dba as several names )

Plaintiff ENGINEERED BY SCHILDMEIER, LLC (hereinafter “Schildmeier” or “Plaintiff”)

I. NATURE OF THE ACTION

II. JURISDICTION AND VENUE

III. THE PARTIES

6. Plaintiff ENGINEERED BY SCHILDMEIER, LLC or “Schildmeier” is an Indiana Limited

IV. PLAINTIFF’S PATENT

V. DEFENDANTS’ INFRINGING ACTS

Plaintiff’s Parts Defendants’ Parts

VI. DEFENDANTS’S NOTICE OF SCHILDMEIER’S PATENT RIGHTS

19. ENGINEERED BY SCHILDMEIER, LLC reincorporates the allegations contained in

paragraphs 1-18 above as if fully set forth herein.

them to be the design claimed in the Plaintiff’s `584 Patent.

covered by the `584 Patent in violation of 35 U.S.C. § 271.

permission or license from Plaintiff Schildmeier.

and issued issued by the United States Patent Office.

presently known to Schildmeier.

both preliminary and permanent injunctive relief pursuant to 35 U.S.C. § 283.

statutory relief pursuant to 35 U.S.C. § 289.

29. Schildmeier is entitled to monetary damages pursuant to 35 U.S.C. § 284 in an amount to be

authorized under 15 U.S.C. § 1117.

pursuant to the Patent Act.

39. Schildmeier is therefore entitled to a declaratory judgment of Schildmeier’s rights and,

Schildmeier may have.

PRAYER FOR RELIEF

infringed, directly and/or indirectly, by the Named Defendants;

43(a) of the Lanham Act;

POCKET COVERS, or any equivalent thereof, in the United States;

pursuant to 35 U.S.C. § 284;

constitute unfair acts pursuant to 15 U.S.C. § 1117;

(g) Award Schildmeier enhanced damages pursuant to 35 U.S.C. § 284;

U.S.C. § 1117); and

(j) All other just and proper relief in the premises.

/s/ John D. Ritchison

John D. Ritchison, Attorney No. 12066-48

Plaintiff's EXHIBIT A Page 1

Owner: Engineered by Schildmeier, LLC

Plaintiff's EXHIBIT A Page 2

Plaintiff's EXHIBIT A Page 3

Plaintiff's EXHIBIT A Page 4

Plaintiff's EXHIBIT A Page 5

Plaintiff's EXHIBIT A Page 6

Plaintiff's EXHIBIT A Page 7

Plaintiff's EXHIBIT A Page 8

iFJF copied my patented Stake Pocket Covers to perfection. These pictures

Plaintiff's EXHIBIT A Page 9

Eugene Schildmeier April 12, 2018

Plaintiff's EXHIBIT A Page 10

3. Evaluate the actions of the seller BAYEN INST.

Plaintiff's EXHIBIT A Page 11

ebay is awaiting cout direction

At ebay, we lose sales every day without a court decision

Plaintiff's EXHIBIT A Page 13

Plaintiff's EXHIBIT A Page 14

“excellent quality, fit perfect”

Plaintiff's EXHIBIT A Page 15

“Just wanted to say thanks for a great product! At least someone is

These, and hundreds more can be seen on my Amazon

Plaintiff's EXHIBIT A Page 16