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Case 2:19-cv-00633-CMR Document 2 Filed 09/06/19 Page 2 of 6
THE PARTIES
a registered address of 6339 Saint Croix Trail South, Hastings, Minnesota, 55033.
Tatuyou is generally engaged in providing, inter alia, products for the tattoo
industry.
3. This is a civil action for patent infringement arising under the patent
laws of the United States 35 U.S.C. § 1 et. seq., including 35 U.S.C. § 271.
4. This Court has original jurisdiction over the subject matter of this
consistent with the Constitution of the United States, recent Supreme Court
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Case 2:19-cv-00633-CMR Document 2 Filed 09/06/19 Page 3 of 6
7. Venue is proper in this judicial district under at least 28 U.S.C. §§ 1331 and
1400.
FACTUAL BACKGROUND
portfolio of utility and design patents, including United States Design Patent No.
and has been granted all rights thereunder, including the right and standing to
selling tattoo care products. In particular, Saniderm sells and offers for sale, inter
11. The design of the Accused Product is substantially the same as the
12. An ordinary observer would conclude that the design of the Accused
Product is substantially the same as the claimed designs of the ’795 patent.
design that is the subject matter of the ’795 patent that customers are likely to be
deceived and persuaded to buy the Accused Product thinking they are actually
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Case 2:19-cv-00633-CMR Document 2 Filed 09/06/19 Page 4 of 6
16. Saniderm has had pre-suit knowledge of the ’795 patent since at
17. Since learning of the ’795 patent, at least since receiving Tatuyou’s
19. Saniderm has infringed, and continues to infringe, the ’795 patent by
offering to sell, selling, or importing, in this District, and elsewhere in the United
States, the Accused Product, the design of which is substantially the same as the
21. Tatuyou has sustained damages and will continue to sustain damages
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Case 2:19-cv-00633-CMR Document 2 Filed 09/06/19 Page 5 of 6
will continue to damage Tatuyou’s business, causing irreparable harm, for which
24. Saniderm has willfully infringed the ’795 patent, entitling Tatuyou
to increased damages under 35 U.S.C. § 284 and attorneys’ fees and costs incurred
enjoining Saniderm, its agents, servants, and any and all parties
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Case 2:19-cv-00633-CMR Document 2 Filed 09/06/19 Page 6 of 6
U.S.C. § 285;
U.S.C. § 284;
(j) An order awarding such other and further relief that this Court
JURY DEMAND
Respectfully submitted,
Dated: September 5, 2019
STRONG & HANNI, P.C.
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Case 2:19-cv-00633-CMR Document 2-1 Filed 09/06/19 Page 1 of 1
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(b) County of Residence of First Listed Plaintiff Barry County County of Residence of First Listed Defendant Utah County
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(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State
u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State