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Case 2:14—cv-06546 Document 1 Filed 08/20/14 Page 1 of 5 Page ID #:1
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`Grant E. Kinsel, Bar No. 172407
`
`GKinsel@perkinscoie.com
`Christina J. McCullough, Bar No. 245944
`CMcCullough@perkinscoie.corn
`Perkins Coie LLP
`
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`
`Telephone: 206.359.8000
`Facsimile: 206.359.9000
`
`Michael Song, Bar No. 243675
`MSong@perkinscoie.com
`Perkins Coie LLP
`
`1888 Century Park East, Suite 1700
`1
`Los Angeles, CA 90067-172
`Telephone: 310.788.9900
`Facsimile: 310.788.3399
`
`Attorneys for Plaintiff
`Juno Manufacturing, LLC
`
`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRICT OF CALIFORNIA
`
`WESTERN DIVISION
`
`Juno Manufacturing, LLC,
`
`Case No. : 14-6546
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`Plaintiff,
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`V.
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`COMPLAINT FOR PATENT
`
`INFRINGEMENT; JURY TRIAL
`DEMAND
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`Nora Lighting, Inc.,
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`Defendant.
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`Complaint
`NORA EXHIBIT 1004, Page 19
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`NORA EXHIBIT 1004, Page 19
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`

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`Case 2:14—cv—06546 Document 1 Filed 08/20/14 Page 2 of 5 Page ID #:2
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`Juno Manufacturing, LLC (“Juno”) alleges:
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`JURISDICTION AND VENUE
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`1.
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`This is an action for patent infringement under Title 35 of the United
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`States Code. The Court has federal question jurisdiction under. 28 U.S.C. § 1331,
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`and exclusive original jurisdiction under 28 U.S.C. § 1338(a).
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`2.
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`Venue is proper in this district under 28 U.S.C. §§ 1391(b) and 1400
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`(a)-
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`PARTIES
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`3.
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`Juno is a limited liability company organized and existing under the
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`laws of the State of Illinois with its principal place of business in Illinois. Juno is a
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`leading provider of lighting products, including recessed lighting products.
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`4.
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`Juno is informed and believes and thereon alleges that Defendant Nora
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`Lighting, Inc. (“Nora”) is a California corporation with its principal place of
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`business in Commerce, California. Nora sells lighting products, including recessed
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`lighting products.
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`FIRST CLAIM FOR RELIEF
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`Infringement of US. Patent No. 5,505,4] 9
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`Juno incorporates paragraphs 1 through 4, above.
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`US. Patent No. 5,505,419 (the “’419 patent”), entitled “Bar Hanger
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`5.
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`6.
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`for a Recessed Light Fixture Assembly,” issued on April 9, 1996. The US. Patent
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`and Trademark Office issued an ex parte reexamination certificate confirming the
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`patentability of claims 1-6 of the ’419 patent on April 25, 2014. Juno owns all right
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`and title to the ’419 patent. A true and correct copy of the ’419 patent is attached as
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`Exhibit “A.”
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`\IO\UI
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`- l -
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`Complain
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`NORA EXHIBIT 1004, Page 20
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`NORA EXHIBIT 1004, Page 20
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`

`

`Case 2:14—cv—06546 Document 1 Filed 08/20/14 Page 3 of 5 Page ID #:3
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`7.
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`Juno is informed and believes and thereon alleges that Nora has
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`infringed one or more claims of the ’419 patent by making, using, selling, or
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`offering to sell in this country (including in this judicial district), recessed lighting
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`products that include infringing bar hangers. Examples of recessed lighting
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`products that include infringing bar hangers include, but are not limited to, Nora
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`model numbers NHIC—SOlQAT; NH-26Q; NSIC-401QAT; and NHPIC-2642ELAT.
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`8.
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`Juno is informed and believes and thereon alleges that Nora had
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`knowledge of the ’419 patent before the filing of this Complaint and that Nora’s
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`infringement of the ’419 patent was willful.
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`9.
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`Juno has complied with the statutory requirement of placing a notice of
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`the ’419 patent on recessed lighting products that include the patented bar hangers
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`that Juno manufactures and sells, and has given Nora written notice of the
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`infringement.
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`lO.
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`Juno has been damaged by Nora’s infringement of the ’419 patent.
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`PRAYER FOR RELIEF
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`Juno requests the following relief:
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`A.
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`B.
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`A judgment that Nora infringed the ”419 patent;
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`An award of damages to Juno including pre-judgment and post-
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`judgment interest in an amount adequate to compensate Juno for Nora’s
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`infringement of the ’419 patent, and, if willful infringement is shown, that the
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`damages be trebled pursuant to 35 U.S.C. § 284;
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`C.
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`D.
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`For costs and expenses in this action;
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`For a declaration that this is an exceptional case and an award of
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`attorneys’ fees, disbursements, and costs of this action; and
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`-2-
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`Complaint
`
`NORA EXHIBIT 1004, Page 21
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`NORA EXHIBIT 1004, Page 21
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`

`

`Case 2:14-cv-06546 Document 1 Filed 08/20/14 Page 4 of 5 Page ID #:4
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`E.
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`Any other further relief as the Court may deem proper.
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`DATED: August 20, 2014
`
`PERKINS COIE LLP
`
`By: /s/ Michael J. Song
`Michael J. Song
`MSong@perkinscoie.com
`
`Attorneys for Plaintiff
`JUNO MANUFACTURING, LLC
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`NORA EXHIBIT 1004, Page 22
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`Complaint
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`NORA EXHIBIT 1004, Page 22
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`

`

`Case 2:14—cv-06546 Document 1 Filed 08/20/14 Page 5 of 5 Page ID #:5
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`Jury Trial Demand
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`Juno Manufacturing, LLC demands a trial by jury on all issues so triable.
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`DATED: August 20, 2014
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`PERKINS COIE LLP
`
`
`By: /s/ Michael J. Song
`Michael J. Song
`MSong@perkinscoie.com
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`Attorneys for Plaintiff
`JUNo MANUFACTURING, LLC
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`#WN
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`\OOO\]O\
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`NORA EXHIBIT 1004, Page 23
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`Complaint
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`NORA EXHIBIT 1004, Page 23
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