Case 1:17-cv-00868-UNA Document 1 Filed 06/30/17 Page 1 of 14 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
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`UNIVERSITY OF MASSACHUSETTS
`MEDICAL SCHOOL and CARMEL
`LABORATORIES, LLC,
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`L’ORÉAL S.A. and L’ORÉAL USA, INC.,
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` Civil Action No.
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`JURY TRIAL DEMANDED
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`Plaintiffs,
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`v.
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`Defendants.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`1. Plaintiffs UNIVERSITY OF MASSACHUSETTS MEDICAL SCHOOL
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`(“UMass”) and CARMEL LABORATORIES, LLC (“Carmel Labs”) for their Complaint against
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`Defendants L’ORÉAL S.A. (“L’Oréál”) and L’ORÉAL USA, INC. (“L’Oréál USA”) (together,
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`“Defendants”) allege:
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`THE PARTIES
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`1. Plaintiff UMass is a public institution of higher education with its principal
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`address at 333 South Street, Suite 400, Shrewsbury, MA 01545.
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`2. Teresian Carmelites, Inc. (“Teresian Carmelites”) is a non-profit religious
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`organization with its principal address at 167 Riverlin Street, Millbury, MA 01527.
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`3. Plaintiff Carmel Labs is a limited liability company with its principal place of
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`business at 167 Riverlin Street, Millbury, MA 01527. Carmel Labs is a wholly-owned for-profit
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`subsidiary of Teresian Carmelites. Profits realized by Carmel Labs are used to support Teresian
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`Carmelites’ charitable works.
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`4. UMass is the assignee and Carmel Labs is the exclusive licensee of United States
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`Patent Numbers 6,423,327 (attached as Exhibit 1) and 6,645,513 (attached as Exhibit 2) (the
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`“patents-in-suit”).
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`5. Plaintiffs are informed and believe, and on that basis allege, that Defendant
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`L’Oréal is a French corporation with its principal place of business at 41 Rue Martre, Clichy,
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`Paris, Ile-de-France 92117, France.
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`6. Plaintiffs are informed and believe, and on that basis allege, that Defendant
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`L’Oréal USA is a Delaware corporation with its principal place of business at 10 Hudson Yards,
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`New York, NY 10001. Plaintiffs are further informed and believe that L’Oréal USA’s registered
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`agent is The Prentice-Hall Corporation System, Inc., 2711 Centerville Road Suite 400,
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`Wilmington, DE 19808.
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`7. L’Oréal USA is a wholly-owned subsidiary of L’Oréal. On information and
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`belief, L’Oréal USA is the agent of L’Oréal, which controls or otherwise directs and authorizes
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`the activities of L’Oréal USA.
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`JURISDICTION AND VENUE
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`8. The court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
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`1338(a) because this action arises under the patent laws of the United States, 35 U.S.C. §§ 1 et
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`seq. Venue is proper in this federal district pursuant to 28 U.S.C. §§ 1391(b)-(c) and 1400(b).
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`THE CLAIMED ADENOSINE TECHNOLOGY
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`9. Adenosine is a naturally occurring purine nucleoside that plays an important role
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`in a variety of biochemical processes. It is used by physicians in therapeutic and diagnostic
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`cardiac applications, for example, to treat arrthymias or during cardiac stress tests.
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`2
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`10. Dr. James G. Dobson, Jr., a renowned cardiovascular physiologist and the former
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`Chairman of the Department of Physiology at the University of Massachusetts Medical School,
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`has been conducting research on adenosine since approximately the mid 1960’s. Dr. Dobson
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`and his colleague, Dr. Michael Ethier, discovered that topical application of adenosine can be
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`used to enhance the condition of the skin by applying adenosine to the dermal cells in specified
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`concentrations without increasing dermal cell proliferation.
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`11. Their discoveries are embodied in U.S. Patent Nos. 6,423,327 (the “’327 patent”)
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`and 6,645,513 (the “’513 patent”) (collectively, the “patents-in-suit”).
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`12. Claim 1 of the ’327 patent recites, for example: “A method for enhancing the
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`condition of unbroken skin of a mammal by reducing one or more of wrinkling, roughness,
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`dryness, or laxity of the skin, without increasing dermal cell proliferation, the method comprising
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`topically applying to the skin a composition comprising a concentration of adenosine in an
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`amount effective to enhance the condition of the skin without increasing dermal cell
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`proliferation, wherein the adenosine concentration applied to the dermal cells is 10−4 M to 10−7
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`M.” Claim 1 of the ’513 patent reads identically, but provides that “the adenosine concentration
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`applied to the dermal cells is 10−3 M to 10−7 M.”
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`13. Other dependent claims of both patents add more limitations. For example,
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`dependent claims 9 of both the ’327 and ’513 patents provide additional limitations, stating that
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`“[t]he method of claim 1, wherein the composition further comprises a transdermal agent.”
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`PLAINTIFFS’ EASEAMINE PRODUCTS
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`14. Teresian Carmelites is a non-profit Christian monastery dedicated to prayer,
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`contemplation, and service to the poor and marginalized. The members of Teresian Carmelites
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`fulfill their mission through charitable works such as rehabilitation programs for the incarcerated
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`3
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`or persons with alcohol or drug addictions, inner city educational programs, and other programs
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`to benefit the disadvantaged in their surrounding community.
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`15. Through Dr. Dobson’s long-standing relationship with the religious order,
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`Teresian Carmelites became aware of the technology covered by the patents-in-suit. Teresian
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`Carmelites negotiated a license and founded Carmel Labs, a for-profit subsidiary. Carmel Labs
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`has been the exclusive licensee of the patents-in-suit for all cosmetic applications since 2008.
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`Profits realized by Carmel Labs sustain Teresian Carmelites’ financial needs, and fund its
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`charitable programs.
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`16. Carmel Labs developed “Easeamine,” a high-end anti-aging face cream using the
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`patented adenosine technology. Easeamine was initially released in 2009 and, due to its
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`innovative and unique properties, received favorable press in newspapers around the world,
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`leading to significant sales in its first year.
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`17. Based on the strength of initial sales, Carmel Labs reinvested substantial sums—
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`obtained in part by leveraging property owned by the monastery—to expand the Easeamine line.
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`Carmel Labs retained experienced cosmetic industry professionals as well as a contract
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`manufacturer and a branding and public relations firm to assist in creating and marketing a full
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`Easeamine product line, with an anticipated release date in fall of 2010.
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`DEFENDANTS’ USE OF PLAINTIFFS’ PATENTED TECHNOLOGY
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`18. Defendants comprise one of the world’s largest cosmetic companies. Defendants
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`manufacture and sell products such as hair care, skin care, make-up and perfume all over the
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`world.
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`19. Defendants have been aware of Plaintiffs’ adenosine technology and the patents-
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`in-suit since at least 2002.
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`4
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`20. For example, in U.S. Patent Application No. 10/701,495 (“Method for Softening
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`Lines and Relaxing the Skin with Adenosine and Adenosine Analogues”), filed by L’Oréal on
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`November 6, 2003, and as a provisional application on December 12, 2002, L’Oréal stated that “it
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`has been suggested, in U.S. Pat. No. 6,423,327 [i.e., the ’327 patent] and US-2003/044439 [i.e.,
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`the application that issued the ’513 patent], that adenosine or an analogue of adenosine can be
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`used in a composition that is topically applied to the skin to improve skin condition.” See Exhibit
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`3 at 2 (attached).
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`21. L’Oréal later abandoned U.S. Patent Application No. 10/701,495 after it was
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`rejected for, among other reasons, being obvious over the ’327 patent. See Exhibit 4 at 4
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`(attached).
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`22. L’Oréal has also cited the patents-in-suit in its own issued patents numerous
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`times. For example, L’Oréal cited the ’327 and ’513 patents in its U.S. Patents Nos. 9,018,177,
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`9,023,826, 9,072,919, and 9,107,853. See Exhibits 7, 8, 9, and 10 (attached).
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`23. In fall of 2003, an agent of both Defendants contacted Dr. Dobson to discuss the
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`patents-in-suit. Defendants, however, did not obtain a license to the patents-in-suit.
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`24. Nonetheless, after speaking to Dr. Dobson, and with full knowledge of the
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`technology exclusively licensed to Carmel Labs, Defendants began creating, marketing, and
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`selling cosmetic products using the patented adenosine technology.
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`25. On October 15, 2010, two weeks before the launch of Plaintiffs’ expanded
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`Easeamine product line, Defendants publicly announced their new Youth Code line of anti-aging
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`skin care, promoting its use of “adenosine, a molecule that is found in skin cells that acts at the
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`dermis level to produce collagen.” See Exhibit 5 (attached).
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`26. Defendants tout the benefits of adenosine on their brand’s website as well, stating:
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`5
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`Adenosine is the nucleoside that is most commonly associated with
`the body’s energy-transferring processes. It is present in adenosine
`triphosphate (ATP), an essential biological and chemical signaling
`molecule. Due to its high-biological profile, adenosine uses in
`skincare have grabbed the attention of cosmetic companies. As a
`result, studies have shown the use of adenosine for skin can be an
`effective method for providing anti-aging benefits. When applied
`topically, adenosine-containing products showed significant
`improvements in the visible signs of aging as well as improving
`skin smoothness. For this reason, adenosine can most commonly
`be found in moisturizing skincare products such as creams or
`serums. See Exhibit 6 at 5 (attached).
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`27. Defendants cite a 2006 article entitled “Evaluation of anti-wrinkle efficacy of
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`adenosine-containing products using the FOITS technique,” to support that proposition on their
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`website, although the article significantly post-dates the patents-in-suit. See id.
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`28. Carmel Labs launched the expanded and enlarged Easeamine line on November 1,
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`2010. Due to public focus on Defendants’ adenosine products, projected sales of Easeamine did
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`not materialize, resulting in lost revenue to Carmel Labs, and ultimately, to Teresian Carmelites.
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`29. Teresian Carmelites’ plummeting funds left it unable to pay the monastery’s
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`mortgage, and to lapse payments on obligations it undertook to finance the launch of Easeamine.
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`Teresian Carmelites was forced to sell off certain properties it owned to prevent foreclosure on
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`the monastery, and was unable to maintain health insurance for its members. The monastery was
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`unable to use the projected Easeamine profits to fund its charitable works, including efforts to
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`benefit the underprivileged through educational and outreach programs.
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`30. In March 2015, Brother Dennis Wyrzykowski, President of Teresian Carmelites
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`and Carmel Labs, sent a letter to Jean-Paul Agon, CEO of L’Oréal, stating his belief that
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`Defendants’ products infringe the patents-in-suit, and affirming that Carmel Labs is the exclusive
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`licensee of the patents-in-suit.
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`6
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`31. As indicated by product literature including ingredient lists available on
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`Defendants’ brand’s websites, a vast array of topical skincare products manufactured and sold by
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`Defendants use the adenosine technology exclusively licensed to Carmel Labs (the “Accused
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`Adenosine Products”). On information and belief, Defendants’ Accused Adenosine Products
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`include, but are not limited to, the following brands with products containing adenosine:
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`Biotherm; The Body Shop; Carita; Decleor; Garnier; Giorgio Armani; Helena Rubinstein; IT
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`Cosmetics; Kiehl’s; L’Oréal Paris; La Roche-Posay; Lancôme; Maybelline; Roger&Gallet;
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`Sanoflore; Shu Uemura; Vichy; and Yves Saint Laurent.
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`32. On information and belief, Defendants both create and design the Accused
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`Adenosine Products.
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`33. On information and belief, L’Oréal USA manufactures, markets, and sells the
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`Accused Adenosine Products across the United States, including in Delaware. L’Oréal USA’s
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`activities are controlled by its parent, L’Oréal.
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`34. On information and belief, Defendants direct their customers to apply the
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`Accused Adenosine Products topically, intending the Accused Adenosine Products to enhance
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`their customers’ skin condition using the methods claimed in the patents-in-suit. The Accused
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`Adenosine Products include, for example, L’Oréal Paris’ RevitaLift Triple Power Deep-Acting
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`Moisturizer, which Defendants instruct their customers to “Every morning and evening, smooth
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`over the face, neck and jawline until thoroughly absorbed[,] see Exhibit 11 (attached), stating,
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`“L’Oréal Paris RevitaLift presents the next generation of skincare, RevitaLift Triple Power
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`Deep-Acting Moisturizer. This powerful, luxurious moisturizer goes beyond a simple anti-aging
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`cream to address 3 dimensions that visibly age skin: 1. Repair Wrinkles. 2. Refirm Contours. 3.
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`7
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`Redensify Skin. . . . In 1 week, skin’s texture appears smoother. In 4 weeks, elasticity is
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`increased and skin looks younger, firmer and lifted[,]” see Exhibit 12 at 6 (attached).
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 6,423,327
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`35. Plaintiffs incorporate by reference Paragraphs 1 through 34 above.
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`36. On July 23, 2002, the ’327 patent was duly and legally issued for an invention
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`entitled “Treatment of Skin with Adenosine or Adenosine Analog.” UMass is the assignee of the
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`’327 patent and Carmel Labs is the exclusive licensee. Together, they hold all rights and interest
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`in the ’327 patent.
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`37. As discussed above, Defendants have infringed and continue to infringe at least
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`claims 1 and 9 of the ’327 patent in violation of 35 U.S.C. § 271, directly and/or indirectly by at
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`least making, using, selling, and/or offering to sell the Accused Adenosine Products within the
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`United States, and/or by contributing to or inducing infringement by others with the intent to
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`cause infringement of the ’327 patent.
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`38. On information and belief, use of one or more of the Accused Adenosine Products
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`constitutes direct infringement of claim 1 of the ’327 patent, as such use involves “[a] method for
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`enhancing the condition of unbroken skin of a mammal by reducing one or more of wrinkling,
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`roughness, dryness, or laxity of the skin, without increasing dermal cell proliferation, the method
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`comprising topically applying to the skin a composition comprising a concentration of adenosine
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`in an amount effective to enhance the condition of the skin without increasing dermal cell
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`proliferation, wherein the adenosine concentration applied to the dermal cells is 10−4 M to 10−7.”
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`8
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`39. On information and belief, use of one or more of the Accused Adenosine Products
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`constitutes direct infringement of claim 9 of the ’327 patent, as such use includes a “composition
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`[that] further comprises a transdermal agent.”
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`40. Where acts constituting direct infringement of the ’327 patent are not performed
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`by Defendants, such acts constituting direct infringement of the ’327 patent are performed by
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`Defendants’ customers or end-users who act at the direction and/or control of Defendants, with
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`Defendants’ knowledge.
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`41. By as early as 2002 and at least as of the filing or service of this Complaint,
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`Defendants had actual knowledge of the ’327 patent.
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`42. On information and belief, Defendants indirectly infringe one or more claims of
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`the ’327 patent by active inducement in violation of 35 U.S.C. § 271(b), by making, selling
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`and/or offering to sell the Accused Adenosine Products to their customers with the knowledge
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`and intent that use of the Accused Adenosine Products would constitute direct infringement of
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`the ’327 patent by Defendants’ customers.
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`43. On information and belief, Defendants also indirectly infringe one or more claims
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`of the ’327 patent by contributory infringement in violation of 35 U.S.C. § 271(c). The Accused
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`Adenosine Products were designed by Defendants and with Defendants’ knowledge in a manner
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`that would infringe the ’327 patent. Moreover, the Accused Adenosine Products have no known
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`substantial non-infringing use, and the infringing use of the Accused Adenosine Products is a
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`material and substantial part of the invention claimed by the ’327 patent.
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`44. Defendants’ acts of infringement have caused monetarily damage and irreparable
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`harm to Plaintiffs, and Plaintiffs are entitled to recover from Defendants the damages sustained
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`by Plaintiffs as a result of Defendants’ wrongful acts in an amount subject to proof at trial.
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`9
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`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 6,645,513
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`45. Plaintiffs incorporate by reference Paragraphs 1 through 44 above.
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`46. On November 11, 2003, the ’513 patent was duly and legally issued for an
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`invention entitled “Treatment of Skin with Adenosine or Adenosine Analog.” UMass is the
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`assignee of the ’513 patent and Carmel Labs is the exclusive licensee. Together, they hold all
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`rights and interest in the ’513 patent.
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`47. As discussed above, Defendants have infringed and continue to infringe at least
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`claims 1 and 9 of the ’513 patent in violation of 35 U.S.C. § 271, directly and/or indirectly by at
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`least making, using, selling, and/or offering to sell the Accused Adenosine Products within the
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`United States, and/or by contributing to or inducing infringement by others with the intent to
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`cause infringement of the ’513 patent.
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`48. On information and belief, use of one or more of the Accused Adenosine Products
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`constitutes direct infringement of claim 1 of the ’513 patent, as such use involves “[a] method for
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`enhancing the condition of unbroken skin of a mammal by reducing one or more of wrinkling,
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`roughness, dryness, or laxity of the skin, without increasing dermal cell proliferation, the method
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`comprising topically applying to the skin a composition comprising a concentration of adenosine
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`in an amount effective to enhance the condition of the skin without increasing dermal cell
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`proliferation, wherein the adenosine concentration applied to the dermal cells is 10−3 M to 10−7.”
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`49. On information and belief, use of one or more of the Accused Adenosine Products
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`constitutes direct infringement of claim 9 of the ’513 patent, as such use includes a “composition
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`[that] further comprises a transdermal agent.”
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`10
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`50. Where acts constituting direct infringement of claims 1 and 9 of the ’513 patent
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`are not performed by Defendants, such acts constituting direct infringement of the ’513 patent
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`are performed by Defendants’ customers or end-users who act at the direction and/or control of
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`Defendants, with Defendants’ knowledge.
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`51. By as early as 2002 and at least as of the filing or service of this Complaint,
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`Defendants had actual knowledge of the ’513 patent.
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`52. On information and belief, Defendants indirectly infringe one or more claims of
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`the ’513 patent by active inducement in violation of 35 U.S.C. § 271(b), by making, selling
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`and/or offering to sell the Accused Adenosine Products to their customers with the knowledge
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`and intent that use of the Accused Adenosine Products would constitute direct infringement of
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`the ’513 patent by Defendants’ customers.
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`53. On information and belief, Defendants also indirectly infringe one or more claims
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`of the ’513 patent by contributory infringement in violation of 35 U.S.C. § 271(c). The Accused
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`Adenosine Products were designed by Defendants and with Defendants’ knowledge in a manner
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`that would infringe the ’513 patent. Moreover, the Accused Adenosine Products have no known
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`substantial non-infringing use, and the infringing use of the Accused Adenosine Products is a
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`material and substantial part of the invention claimed by the ’513 patent.
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`54. Defendants’ acts of infringement have caused monetarily damage and irreparable
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`harm to Plaintiffs, and Plaintiffs are entitled to recover from Defendants the damages sustained
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`by Plaintiffs as a result of Defendants’ wrongful acts in an amount subject to proof at trial.
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`WILLFUL INFRINGEMENT
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`55. Plaintiffs incorporate by reference Paragraphs 1 through 54 above.
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`11
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`56. Defendants’ infringement of any or all of the above-named patents is willful and
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`deliberate, entitling Plaintiffs to increased damages under 35 U.S.C. § 284 and to attorney’s fees
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`and costs incurred in prosecuting this action pursuant to 35 U.S.C. § 285.
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`57. After speaking to Dr. Dobson about the patents-in-suit, and after abandoning
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`L’Oréal’s own patent application as rendered obvious by the patents-in-suit, Defendants
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`nonetheless launched their own infringing product lines, including the Accused Adenosine
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`Products.
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`58. Defendants have infringed and continue to infringe the patents-in-suit despite the
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`objectively high likelihood that their actions constitute patent infringement.
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`JURY DEMAND
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`59. Plaintiffs demand a trial by jury on all issues.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiffs UNIVERSITY OF MASSACHUSETTS MEDICAL SCHOOL
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`and CARMEL LABORATORIES, LLC request entry of judgment in their favor and against
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`Defendants L’ORÉAL S.A. and L’ORÉAL USA, INC. as follows:
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`a)
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`Declaration that Defendants have infringed U.S. Patents Nos. 6,423,327 and
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`6,645,513;
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`b)
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`c)
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`Declaration that Defendants’ infringement has been willful;
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`Awarding damages arising out of Defendants’ infringement of U.S. Patents Nos.
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`6,423,327 and 6,645,513, including enhanced damages pursuant to 35 U.S.C. § 284, to Plaintiffs
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`together with prejudgment and post-judgment interest, in an amount according to proof;
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`d)
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`An award of attorney’s fees pursuant to 35 U.S.C. § 285 or as otherwise permitted
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`by law; and
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`12
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`e)
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`For such other costs and further relief as the Court may deem just and proper.
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`DATED: June 30, 2017
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`Of Counsel:
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`Respectfully submitted,
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`FARNAN LLP
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`/s/ Brian E. Farnan_
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`Brian E. Farnan (Bar No. 4089)
`Michael J. Farnan (Bar No. 5165)
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`Telephone: (302) 777-0300
`Facsimile: (302) 777-0301
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw,com
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`
`
`
`William Christopher Carmody
`Tamar E. Lusztig
`SUSMAN GODFREY L.L.P.
`1301 Avenue of the Americas, 32nd Floor
`New York, NY 10019
`Telephone: (212) 336-8330
`Facsimile: (212) 336-8340
`bcarmody@susmangodfrey.com
`tlusztig@susmangodfrey.com
`
`Justin A. Nelson
`SUSMAN GODFREY L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Telephone: (713) 651-9366
`Facsimile: (713) 654-6666
`jnelson@susmangodfrey.com
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`Attorneys for University of Massachusetts
`Medical School and Carmel Laboratories,
`LLC
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`13
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`Case 1:17-cv-00868-UNA Document 1 Filed 06/30/17 Page 14 of 14 PageID #: 14
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`Matthew B. Lowrie
`Matthew A. Ambros
`FOLEY & LARDNER LLP
`111 Huntington Avenue, Suite 2600
`Boston, MA 02199
`Telephone: (617) 342-4000
`Facsimile: (617) 342-4001
`mlowrie@foley.com
`mambros@foley.com
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`COMMONWEALTH OF MASSACHUSETTS,
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`By its attorney,
`
`MAURA HEALEY
`ATTORNEY GENERAL
`
`By: William Christopher Carmody
`William Christopher Carmody
`Special Assistant Attorney General
`SUSMAN GODFREY L.L.P.
`1301 Avenue of the Americas, 32nd Floor
`New York, NY 10019
`Telephone: (212) 336-8330
`Facsimile: (212) 336-8340
`bcarmody@susmangodfrey.com
`
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`Attorneys for Carmel Laboratories, LLC
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`Attorney for University of Massachusetts
`Medical School
`
`14
`
`