United States District Court for the Western District of North Carolina TGR Intellectual Properties, LLC, Plaintiff,

v. Danaher Corporation, Defendant. ) ) ) ) ) ) ) ) )

Civil Action No. 3:11cv640

Complaint for Patent Infringement

The Parties 1. Plaintiff TGR Intellectual Properties, LLC (TGR) is a North Carolina limited liability corporation with its principal place of business at 6060 Piedmont Drive South, Suite 150, Charlotte, North Carolina 28105. 3. Upon information and belief, Defendant Danaher Corporation is a Delaware corporation with its principal place of business at 2200 Pennsylvania Avenue, NW, Suite 800W, Washington, D.C. 20037. 4. Upon information and belief, Pelton & Crane is a business segment of Danaher Corporation with its principal place of business at 11727 Fruehauf Drive, Charlotte, NC 28273.

Jurisdiction 5. Subject matter jurisdiction is based upon 28 U.S.C. 1338. 6. Personal jurisdiction is based upon Federal Rule of Civil Procedure 4(e) and the North Carolina Long-Arm Statute, N.C. Gen. Stat. 1-75.4. 7. Venue is proper in this district pursuant to 28 U.S.C. 1391(c) and 1400.

Patent Infringement 8. On August 12, 2008, United States Letters Patent No. 7,410,138 was duly and legally issued to Shannon G. Parsons for an invention in a display adjustably positionable about a swivel and pivot axes (the 138 patent). A copy of the 138 patent is attached as Exhibit 1. 9. The 138 patent was assigned to Plaintiff TGR, and from the date of assignment through the present, TGR owns all right, title, and interest in the 138 patent. 10. On November 9, 2010, United States Letters Patent No. 7,828,252 was duly and legally issued to Shannon G. Parsons for an invention in an adjustably positionable display and lighting arrangement (the 252 patent). A copy of the 252 patent is attached as Exhibit 2. 11. The 252 patent was assigned to Plaintiff TGR, and from the date of assignment through the present, TGR owns all right, title, and interest in the 252 patent.

11. Defendant Danaher Corporation, through the actions of its business segment Pelton & Crane, has infringed and is still infringing the 138 and 252 patents by making, selling, and using what it describes as flexible monitor mount that embodies the patented invention, specifically the track flexible monitor mount that is shown in Exhibit 3. Defendant Danaher Corporation, through the actions of its business segment Pelton & Crane, and will continue to do so unless enjoined by this Court. 16. Upon information and belief, Danaher Corporation, through its business segment Pelton & Crane, knew of the 138 patent since approximately its date of issue, but Danaher Corporation, through the actions of its business segment Pelton & Crane, pursued their knowing and willful infringement of the 138 patent in flagrant disregard of the patent rights held by TGR. 17. Upon information and belief, Danaher Corporation, through its business segment Pelton & Crane, knew of the 252 patent since approximately its date of issue, but Danaher Corporation, through the actions of its business segment Pelton & Crane, pursued their knowing and willful infringement of the 252 patent in flagrant disregard of the patent rights held by TGR.

WHEREFORE, Plaintiff TGR Intellectual Properties prays for the following relief: 1. An injunction against Defendant Danaher Corporations continued infringement of the 377 patent; 3

2. An accounting for damages resulting from Defendant Danaher Corporations infringement, and the trebling of the damages because of the knowing, willful, and wanton nature of Danahers conduct; 3. An assessment of interest on the damages so computed; 4. An award of Plaintiffs attorneys fees and costs in this action; and 5. Such other and further relief as the Court deems just and equitable.

Demand for Jury Trial Plaintiffs demand trial by jury as to all issues triable by jury in this case as a matter of right. Respectfully submitted, this 16th day of December 2011.

s/Albert P. Allan Albert P. Allan N.C. Bar No. 18882 Attorney for Plaintiff TGR Intellectual Properties, LLC ALLAN LAW FIRM, PLLC 409 East Boulevard Charlotte, North Carolina 28203 (e) alallan@allaniplitigation.com (t) 704-371-5605 (f) 704-372-7411