IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

MONROE TRUCK EQUIPMENT, INC., Plaintiff, v. UNIVERSAL TRUCK EQUIPMENT, INC., Defendant.

Case No. 14-cv-49 TRIAL BY JURY DEMANDED

COMPLAINT

Plaintiff Monroe Truck Equipment, Inc. (MTE), by its attorneys, Quarles & Brady LLP, hereby states its Complaint against Defendant Universal Truck Equipment, Inc. (UTE) as follows: THE PARTIES 1. MTE is a Wisconsin corporation with its principal place of business at 1051 West

7th Street, Monroe, Wisconsin 53566. 2. Upon information and belief, UTE is a Wisconsin corporation with its principal

place of business at N15921 Schubert Road, Galesville, Wisconsin 54630. JURISDICTION AND VENUE 3. This is an action for patent infringement arising under the patent laws of the

United States, 35 U.S.C. 1, et seq. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 1331 and 1338(a). 4. This Court has personal jurisdiction over UTE because UTE is a domestic

corporation with its principal place of business within the Western District of Wisconsin.

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Venue in the Western District of Wisconsin is proper under 28 U.S.C. 1391

and 1400(b) because UTE resides in this judicial district and has committed acts of infringement within this judicial district. FACTS GIVING RISE TO THIS ACTION 6. United States Patent No. 8,596,376 (the 376 Patent), entitled Support

Apparatus for Securing a Wing Plow, duly and legally issued on December 3, 2013. A true and correct copy of the 376 Patent is attached hereto as Exhibit A. 7. 376 Patent. 8. The 376 Patent discloses a support apparatus for securing a material moving MTE is the owner by assignment of the entire right, title, and interest in and to the

wing plow relative to a vehicle that is used for a wing plow application, such as a truck, loader, or grader. 9. 10. 376 Patent. 11. Upon information and belief, UTE makes, uses, offers to sell, sells, and/or The claims in the 376 Patent are novel, nonobvious, and useful. There are no acceptable non-infringing alternatives to the invention claimed in the

imports, and/or has made, used, offered to sell, sold, and/or imported, within the United States products, including the Uni-Glide Wing plow support, that infringe at least Claim 1 of the 376 Patent. 12. Pursuant to 35 U.S.C. 287, MTE has provided notice to UTE of the existence of

the 376 Patent and of UTEs infringement thereof. INFRINGEMENT OF U.S. PATENT NO. 8,596,376 13. MTE realleges and incorporates by reference paragraphs 1 through 12 above as if

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By making, using, offering to sell, selling, and/or importing within the United

States the Uni-Glide Wing plow support, UTE has infringed and continues to infringe, directly and/or indirectly, at least Claim 1 of the 376 Patent, either literally or under the doctrine of equivalents. 15. Upon information and belief, UTEs infringement has been intentional, willful,

and in reckless disregard of MTEs rights. 16. UTEs infringement has caused, and unless enjoined by this Court will continue

to cause, MTE to suffer irreparable harm for which it cannot be adequately compensated by a monetary award. 17. UTEs infringement has caused MTE to suffer substantial injury, including lost

profits, for which MTE is entitled to damages adequate to compensate for the infringement. PRAYER FOR RELIEF WHEREFORE, MTE respectfully requests relief from this Court as follows: a. A judgment that UTE has directly infringed and is directly infringing the 376 Patent in violation of 35 U.S.C. 271(a); b. A judgment that UTE has actively induced and is actively inducing infringement of the 376 Patent in violation of 35 U.S.C. 271(b); c. An injunction under 35 U.S.C. 283 that temporarily and permanently enjoins UTE, including its officers, agents, employees, and representatives, and those acting in privity and/or concert therewith, from further infringement of the 376 Patent for the full term thereof; d. An award of damages to MTE under 35 U.S.C. 284 that is adequate to compensate for UTEs infringement of the 376 Patent, but in no event less than a

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reasonable royalty for the use made by UTE of MTEs invention, and that is trebled, together with pre- and post-judgment interest and costs; e. A declaration that this is an exceptional case and an award of attorneys fees, disbursements, and costs to MTE pursuant to 35 U.S.C. 285; and f. Such other and further relief as this Court may deem just and proper. JURY DEMAND MTE demands a trial by jury on all issues properly tried thereto.

Dated this 28th day of January, 2014.

/s/ Anthony A. Tomaselli Anthony A. Tomaselli aat@quarles.com Stacy A. Alexejun stacy.alexejun@quarles.com QUARLES & BRADY LLP 33 East Main Street, Suite 900 Madison, Wisconsin 53703-3095 Tel.: 608.251.5000 Fax: 608.251.9166 Attorneys for Plaintiff Monroe Truck Equipment, Inc.

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