Patent Holder LLC v. Magill - Complaint

Case 1:17-cv-22826-UU Document 1 Entered on FLSD Docket 07/27/2017 Page 1 of 9
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No.:
PATENT HOLDER, LLC.
Plaintiff,
v.
Leonard L. Magill,
Lmp/Mail Order Video, Inc., and
Magills Glockstore
Defendants.
____________________________/
COMPLAINT FOR PATENT INFRINGEMENT
PATENT HOLDER, LLC. (hereinafter PATENT HOLDER) by and through its
undersigned legal counsel, makes this Complaint against Leonard L. Magill, personally,
(hereinafter Magill), Lmp/Mail Order Video, Inc. (hereinafter LMP/MAIL), and
Magills Glockstore (hereinafter Glockstore) and alleges the following:
NATURE OF THE ACTION
1. PATENT HOLDER seeks injunctive relief and damages for acts of patent
infringement engaged in by the Defendants in violation of the laws of the United States
and the State of Florida.

THE PARTIES
2. PATENT HOLDER is a Florida Limited Liability Company having an
address at 12201 SW 131 Avenue, Miami, FL 33186.
3. On information and belief, Defendant Leonard L. Magill is an individual
residing at 4770 Ruffner Street, San Diego, CA 92111.
4. On information and belief, Defendant LMP/MAIL is a corporation
organized and existing under the laws of California, and has a principal place of business
at 4770 Ruffner Street, San Diego, CA 92111.
5. On information and belief, Defendant Glockstore is a corporation
organized and existing under the laws of California, and has a principal place of business
at 4770 Ruffner Street, San Diego, CA 92111.
JURISDICTION
6. This Court has subject matter jurisdiction over this dispute pursuant to 28
U.S.C. 1331, 1338(a), and 1367(a).
7. This Court may exercise personal jurisdiction over Defendants based upon
their contacts with this forum, and placing their infringing products into the stream of
commerce, with the knowledge or understanding that such products are sold in the State
of Florida, including in this District. The acts by Defendants have caused injury to
PATENT HOLDER within this District. Upon information and belief, Defendants derive
substantial revenue from the sale of infringing products within this District, expect their
2
actions to have consequences within this District, and derive substantial revenue from
interstate and international commerce.
VENUE
8. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b),
(c), and 1400 (b) because Defendants regularly do business, have committed acts of
infringement, and are subject to personal jurisdiction here. See enclosed Exhibit 1,
Composite Exhibit 2, and Exhibits 3 and 4 attached hereto.
BACKGROUND
9. For years, Arthur Viani, owner of Ghost, Inc. in Miami, FL, has
continuously engaged in the development, manufacture, and sale of guns parts and
accessories.
10. PATENT HOLDER owns a United States patent relating to Enhanced
Trigger Control Connector.
11. In particular, PATENT HOLDER is the owner of all right, title, and
interest to United States Patent No. 9,404,700 (hereafter, the 700 Patent). See enclosed
Exhibit 5 attached hereto.
12. The 700 Patent was duly and legally issued to Arthur Viani, inventor of
the Enhanced Trigger Control Connector.
13. The 700 Patent was assigned to PATENT HOLDER.
3
14. Ghost, Inc. manufactures, distributes, and offers for sale the patented
Enhanced Trigger Control Connector under the 700 Patent. See enclosed Exhibit 6
attached hereto.
15. PATENT HOLDERs Enhanced Trigger Control Connector was created to
improve an existing issue with trigger controls, whereas a firearm trigger bar slidably
travels generally in a rearward and downward direction establishing an undesired trigger
pull excess travel.
16. PATENT HOLDERs Enhanced Trigger Control Connector limits over
travel by extending a control tab. This way, the undesired trigger pull excess travel of the
prior art is prevented while minimizing trigger bar obstruction. See enclosed Exhibits 7, 8
and 9 attached hereto.
17. On information and belief, Defendants also do business in manufacturing
and/or distributing and/or selling of guns parts and accessories. See enclosed Exhibits
10, 11, 12, and 13 attached hereto.
18. On information and belief, and without PATENT HOLDERs
authorization, Defendants have made, used, offered to sell, sold, and/or imported into the
United States products having the assembly and components claimed in the 700 Patent.
See enclosed Exhibit 12 attached hereto.
19. Defendants infringing gun parts and accessories include an enhanced
trigger control connector identified by Defendants as a DOUBLE DIAMOND 3.5 lb.
4
CONNECTOR. See enclosed Exhibit 13 attached hereto.
20. Without a license, consent, or authorization from PATENT HOLDER,
Defendants manufactured, or had manufactured a plurality of the DOUBLE DIAMOND
3.5 lb. CONNECTORS that are sold by Defendants. See enclosed Composite Exhibit 14
attached hereto.
21. Rather than innovate and develop their own technology and a unique style
for its trigger control connectors, Defendants chose to copy PATENT HOLDERs
technology and innovative style in its infringing products.
22. On information and belief, the DOUBLE DIAMOND 3.5 lb.
CONNECTOR contains elements defined with respect to the claims of the 700 Patent.
See enclosed Exhibit 15 attached hereto.
23. On information and belief, Defendants are intentionally manufacturing
and/or selling the DOUBLE DIAMOND 3.5 lb. CONNECTOR knowing of the existence
of the 700 Patent.
24. On information and belief, Defendants have offered for sale and/or sold
the DOUBLE DIAMOND 3.5 lb. CONNECTOR knowing of the existence of the 700
Patent in Miami-Dade County.
25. On information and belief, Defendants continue to use, offer to sell, sell,
and/or import into the United States the DOUBLE DIAMOND 3.5 lb. CONNECTOR
knowing of the existence of the 700 Patent.
5
26. Defendants knowing and repeated infringement of PATENT HOLDERs
the 700 Patent have been and continues to be intentional and willful.
COUNT I: PATENT INFRINGEMENT
27. PATENT HOLDER re-alleges each and every allegation set forth in
paragraphs 1 through 26 above, inclusive, and incorporates them by reference herein.
28. Defendants have made, used, offered to sell, sold, and/or imported into the
United States, and are still making, using, offering to sell, selling, and/or importing into
the United States, the DOUBLE DIAMOND 3.5 lb. CONNECTOR knowing of the
existence of the 700 Patent without PATENT HOLDERs authorization.
29. Defendants are now, and have been, directly, contributorily and
by inducement, infringing at least one claim of the 700 Patent, literally and/or under
the doctrine of equivalents. Defendants are violating 35 U.S.C. 271 by selling, offering
to sell, making or using the patented invention in the United States, by actively
inducing others to sell, offer to sell, make or use the patented invention in the United
States, and by offering to sell or selling within the United States components of a
patented machine, manufacture, combination or composition, or a material or apparatus
for use in practicing a patented process, constituting a material part of the invention,
knowing the same to be especially made or especially adapted for use in an infringement
of such patent, and not a staple article or commodity of commerce suitable for
substantial non-infringing use.
30. Defendants infringement has been intentional and willful, making this an
6
exceptional case.
31. PATENT HOLDER has been and will continue to be irreparably harmed
by Defendants infringement of PATENT HOLDERs 700 Patent.
32. Defendants infringing activities violate 35 U.S.C. 271.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff PATENT HOLDER respectfully prays for:
A. Judgment that Defendants willfully infringed PATENT HOLDERs 700
Patent in violation of 35 U.S.C. 271;
B. An injunction against further infringement of PATENT HOLDERs 700
Patent by Defendants, their agents, servants, employees, officers, and all others controlled
by Defendants;
C. An award of damages adequate to compensate PATENT HOLDER for the
patent infringements that have occurred, including pursuant to 35 U.S.C. 284, which
shall be trebled as a result of Defendants willful patent infringement, including all pre-
judgment and post-judgment interest at the maximum rate permitted by law, and costs;
D. Actual damages suffered by PATENT HOLDER as a result of
Defendants unlawful conduct, in an amount to be proven at trial, as well as prejudgment
interest as authorized by law;
E. Awarding PATENT HOLDER additional remedy, permitted by 35 U.S.C.
289, including but not limited to Defendants' profits on its products found to infringe
7
the 700 Patent;
F. An assessment of costs, including reasonable attorney fees, pursuant to 35
U.S.C. 285, with prejudgment interest;
G. Reasonable funds for future corrective advertising;
H. Restitutionary relief against Defendants and in favor of PATENT
HOLDER, including disgorgement of wrongfully obtained profits and any other
appropriate relief; and
I. Such other and further relief as this Court deems just and proper.
DEMAND FOR JURY TRIAL
Pursuant to Fed. R. Civ. P. 38, PATENT HOLDER demands a jury trial on all
issues raised in this Complaint triable to a jury.
Respectfully submitted,
/Albert Bordas/
Albert Bordas, Esq.
FL Bar Number: 330220
Albert Bordas, P.A.
5975 Sunset Drive
Suite 705
Miami, FL 33143
Tel. (305)669-9848
Fax. (305) 669-9851
albert@bordasiplaw.com
/Augusto Perera/
Augusto Perera, Esq.
8
FL Bar Number: 117890

Albert Bordas, P.A.
5975 Sunset Drive
Suite 705
Miami, FL 33143
Tel. (305)669-9848
Fax. (305) 669-9851
tm@bordasiplaw.com
9
Case 1:17-cv-22826-UU Document 1-1 Entered on FLSD Docket 07/27/2017 Page 1 of 1
Case 1:17-cv-22826-UU Document 1-10 Entered on FLSD Docket 07/27/2017 Page 1 1/28/17,
of 3 9)27 AM
GLOCKSTORE - THE WORLD'S #1 SOURCE FOR GLOCK PARTS & ACCESSORIES STORE LOCATIONS LIVE CHAT SIGN UP/LOG IN CART: 0 CHECKOUT
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ABOUT US About Lenny Magill:

STORE LOCATION
Lenny Magill is an internationally recognized firearms authority with particular expertise in Glock handguns.
CAREERS
He has produced over 300 instructional and entertainment videos that have sold hundreds of thousands of copies
SHIPPING & RETURNS
through many distribution channels and via independent distributors worldwide. He also regularly produces
PRIVACY POLICY instructional videos for the GlockStore YouTube channel currently enjoying over 64 thousand subscribers and over
11.6 million views to date.
CONTACT US
SUPPORT In 1986, in response to overwhelming requests for access to products featured in his video productions, he founded
GlockStore.com. GlockStore currently has over 250,000 customers worldwide. The website receives over 30,000
unique visitors daily and GlockStore.com ships over 1000 packages a day from our California facility.
As GlockStore rapidly grew, to again answer overwhelming requests, Magill opened a retail showroom initially to
accommodate Law Enforcement and Military Personnel looking for a local resource to service their duty and off-duty
handguns.
Quickly, the retail showroom became a hub for San Diego police, sheriffs, military personnel and locally based DEA,
ICE, FBI and Secret Service agents all of whom carry Glock handguns. These officers enjoy and appreciate the
convenience of being able to get parts and support for their handguns immediately.
In 2011, Magill created the original Tactical Indoor Shooting Range to facilitate the testing of guns and parts. This use
has been expanded to offer one-on-one personal training in the safe and proper use of handguns for self-defense,
home protection, and competition training.
Today, law enforcement and civilians alike enjoy the convenience, customer service and superior products offered by
the GlockStore Performance & Custom. In 2016, close to 1,000,000 GlockStore catalogs will be printed and mailed to
customers nationwide.
GlockStore currently has 56 full-time employees; many of which have been with the company 10 years and longer.
GlockStore Today:
The GlockStore retail store has become a destination shopping experience people travel great distances just to
visit our store; to see and purchase our unique mix of merchandise and proprietary custom parts and services; and to
take advantage of our GUNfit shooters education program.
In addition to the superlative instructional staff, and the wide range of progressive shooting courses, GUNfit fully
utilizes our tactical style shooting ranges to offer an un-paralled shooting experience that is both unique and
challenging.
Future plans revolve around the expansion of retail/indoor range/training facilities to major metropolitan areas around
the country.
http://www.glockstore.com/lenny-magill Page 1 of 3
of 3 9)27 AM
The retail store is housed in the GlockStore World Headquarters which is over 50,000 square feet in size and also
houses all of the various Lenny Magill businesses.
GSPC & Double Diamond:
Under the brand names GSPC & Double Diamond, we manufacture a number of high performance handgun parts
exclusively for the Glock pistol. From the relatively simple (tungsten guide rods) to the cosmetic (engraved slide and
magazine cover plates) to the highly engineered (the world famous Pyramid Trigger) our parts are respected and
coveted by serious shooters around the world.
We have recently expanded into making Precision Slides and are now offering Competition Grade barrels as well.
We own and operate the CNC machining facility and all the equipment necessary to produce these extremely high
quality aftermarket parts and accessories.
UnderTech UnderCover:
In addition to the GlockStore, Lenny Magill owns the UnderTech UnderCover concealment clothing brand. He also
owns the manufacturing company that produces the clothing line, the San Diego Sewing Company.
UnderTech UnderCover sells a wide range of compression style undergarments with integral holsters. It is a very
popular line and enjoys an almost rabid following in its customer base and target market.
Sold through the GlockStore and through its own dedicated website, www.UnderTechUnderCover.com, UTUC
products are in everyday use by FBI, CIA, Secret Service, Home Land Security, and undercover law enforcement
agents around the world.
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DISCLAIMER
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ABOUT US LMP/Mail Order Video, Inc. was created in 1983 by Lenny Magill to facilitate the operation of a multi-brand
international retail and wholesale distribution network with both printed and online catalog sales covering a broad
STORE LOCATION
spectrum of industries.
CAREERS
GlockStore, one of our major brands, is The World's #1 Source for Glock Parts & Accessories. We're the world's
SHIPPING & RETURNS largest distributor of Glock parts and accessories, magazines, holsters, logo gear, apparel, concealment items, custom
PRIVACY POLICY parts and Glock custom guns.
CONTACT US We also invite you to visit our retail location at 4770 Ruffner St. in San Diego, CA and experience GUNfit, a tactical
SUPPORT style indoor range facility unlike any public shooting range you've ever experienced.
When shopping at GlockStore.com you can expect the highest level of quality and service available. Our commitment
to excellence is built upon the highest standards of customer service. We offer the best products on the market backe
by the most knowledgable professionals in the industry. We are constantly growing and we are so happy to have the
trust and loyalty of our customers.
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DISCLAIMER
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Case 1:17-cv-22826-UU Document 1-14 Entered on FLSD Docket 07/27/2017 Page 1 of
Double Diamond 3.5 Pound Connector 25 9)56 AM
1/28/17,

DOUBLE DIAMOND 3.5
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DOUBLE DIAMOND 3.5 POUND CONNECTOR

$24.99
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PRODUCT DESCRIPTION
Quite simply, the best 3.5 lb. connector on the market today! It's lighter, crisper, and more
consistent pull after pull. Guaranteed to improve accuracy and speed!
Watch the installation video online now!
Fits all Glocks including Gen3 + Gen 4 except G42 and G43 (http://www.glockstore.com/Double-
Diamond-3-5-Pound-Connector-for-G42-43).
ADDITIONAL INFORMATION
YOU MAY ALSO LIKE
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1/28/17,
(/Competition-Spring-Kit) (/Complete-Pyramid-Trigger) (/Ultimate-Pyramid-Trigger) (/Titanium-Safety-Plunger) (/Double-Diamond-3-5-Pound-

Connector-for-G42-43)
COMPETITION SPRING KIT (/COMPETITION- COMPLETE PYRAMID TRIGGER ULTIMATE PYRAMID TRIGGER (/ULTIMATE- TITANIUM COATED SAFETY PLUNGER
SPRING-KIT) (/COMPLETE-PYRAMID-TRIGGER) PYRAMID-TRIGGER) (/TITANIUM-SAFETY-PLUNGER) DOUBLE DIAMOND 3.5 POUND
CONNECTOR FOR G42/43 (/DOUBLE-
$12.99 $179.99 $249.99 $23.99 DIAMOND-3-5-POUND-CONNECTOR-FOR-
G42-43)
$24.95
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WRITE A REVIEW (PRODUCT/1158/NEWREVIEW)
Show All Reviews Sort By Most Recent
| 1/14/2017 5:44 am
3.5 CONNECTOR INSTALL

BY ROD
Just finished the 3.5 pound connector install ! Very easy to do after and during watching the video.
THANKS LENNY for the very good instructions during the vid you are the man !!! Off to the range, Cant wait to see how it works. Th
video.
(/Double-Diamond-3-5-Pound-Connector) Was this review helpful?
YES (1) NO
DOUBLE DIAMOND 3.5 POUND CONNECTOR (/DOUBLE-

DIAMOND-3-5-POUND-CONNECTOR)
| 8/1/2016 9:36 am
$24.99
A MUST HAVE !
5
BY EMAIL
5 STARS 100%
I really could not believe that just one part the Double Diamond Connector would transform a horrible stock Glock trigger pull into
9 reviews (product/1158?filter=5star) can actually concentrate on the target now rather than trying to compensate for a hard rough trigger pull... my groups have shrun
4 STARS 0% ya Mr. Magill ..!!!!
0 reviews
Was this review helpful?
3 STARS 0%
YES (28) NO (1)
0 reviews
1/28/17,
2 STARS 0% | 8/17/2016 9:45 am
0 reviews
FANTASTIC.... IT MUST BE, MY WIFE....
1 STAR 0%
BY DON
0 reviews
When I installed the Double Diamond 3.5 pound connector on my Glock 19 and pulled the trigger (after safety check in a safe dir
BELIEVE THE DIFFERENCE.... So I wrote a review BUT now I have to add to that review because my wife wanted to experience the
immediately ORDERED me, I mean REALLY ORDERED me to get one for her G-19... and so I did and installed it. She is a very very
Mr. Magill !!
YES (13) NO (3)
| 2/23/2016 10:01 pm
GLOCK CONNECTOR
BY DAVID
Best Glock connector around. I prefer these over the ghost because the Double diamond makes for a lighter smoother trigger pul
YES (73) NO (2)
| 8/2/2016 1:52 pm
GREAT CONNECTOR...
BY DON
I purchased this connector for my G-19 with some skepticism as I have tried a competitor's connector and was disappointed...
does not sell garbage so I installed it and OH MY.... My trigger is now smooth, lighter and predictable... I highly recommend the D
Connector.....
YES (25) NO (2)
| 8/4/2016 10:03 pm
GREAT TRIGGER UPGRADE!

BY GAEL
I was deciding between this and the Ghost connector and I'm very happy with this product. I have never tested the Ghost connec
but this trigger will not disappoint. I would not recommend for duty carry but absolutely perfect for range or competition shooting
YES (7) NO (5)
| 9/13/2016 10:26 pm
MUST HAVE FOR GLOCK 17

BY VIPER
1/28/17,
I put this connector in my Glock17 and finally took it to the range. What a difference! This isn't hyperbole, this connector made th
predictable and even throughout the length of the pull. It greatly increased my accuracy in two ways. First I don't have the issue o
so tight that it pulls the gun off target, and secondly it completely eliminated flinching when the gun doesn't fire when expected.
for yourself!
YES (11) NO (3)
| 9/24/2016 10:14 pm
TRIGGER RELIEF
BY BOB
I love how smooth and light the pull is now. Like a new gun all for the better. My Glock is Gen 1 and had some wear. Improvemen
part delivered.
YES (6) NO
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1/28/17,
Double Diamond 3.5 Pound Connector for G42/43 25 9)56 AM
1/28/17,

DOUBLE DIAMOND 3.5
(/)

HOME (/) / DOUBLE DIAMOND 3.5 POUND CONNECTOR FOR G42/43
DOUBLE DIAMOND 3.5 POUND CONNECTOR FOR

G42/43
$24.95
(5 Review)
SKU: #
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ADD TO CART ADD TO MY WISH LIST
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PRODUCT DESCRIPTION
Double Diamond 3.5lb Connector will let you reduce the trigger pull significantly.
This is a precision drop-in part that has been designed to improve accuracy and speed
ADDITIONAL INFORMATION
YOU MAY ALSO LIKE
http://www.glockstore.com/Double-Diamond-3-5-Pound-Connector-for-G42-43 Page 1 of 4
1/28/17,
(/Complete-Pyramid-Trigger) (/Double-Diamond-3-5-Pound-
Connector)
COMPLETE PYRAMID TRIGGER

(/COMPLETE-PYRAMID-TRIGGER) (/Ghost-Ultimate-3-5-Connector- (/Ghost-Edge-Connector-for-Glock- DOUBLE DIAMOND 3.5 POUND
drop-in) 42-43) CONNECTOR (/DOUBLE-DIAMOND-3-5-
$179.99 POUND-CONNECTOR)
GHOST ULTIMATE 3.5 CONNECTOR (DROP- GHOST EDGE CONNECTOR FOR GLOCK 42 $24.99
IN) (/GHOST-ULTIMATE-3-5-CONNECTOR- & 43 (/GHOST-EDGE-CONNECTOR-FOR-
DROP-IN) GLOCK-42-43)
$26.95 $24.95
RECENTLY VIEWED
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1/28/17,
Show All Reviews Sort By Most Recent
| 8/4/2016 7:47 am
3.5 DISCONNECTOR GLOCK 43

BY LUKE
Made stock trigger alot smoother. Thanks
YES (5) NO (3)

(/Double-Diamond-3-5-Pound-Connector-for-
G42-43)
DOUBLE DIAMOND 3.5 POUND CONNECTOR FOR G42/43 | 3/16/2016 6:40 pm

(/DOUBLE-DIAMOND-3-5-POUND-CONNECTOR-FOR-G42-
43) G43 CONNECTOR
BY DLT
$24.95
Ordered on Sunday, arrived on Wednesday.
The connector is every thing it is advertised to be.
5
Well made, nicely finished, easy to install.
No trigger gauge to measure the exact numbers, but the finger gauge
5 STARS 100%
agrees it is about 3.5 to 4 pound range. (Not my first Glock, or first connector)
5 reviews (product/5181?filter=5star)
Good product, good price, good service.
4 STARS 0% Thanks guys.
0 reviews
3 STARS 0%
YES (20) NO (2)
0 reviews
2 STARS 0%
0 reviews
1 STAR 0%
| 11/6/2016 10:42 am
0 reviews
MAKES TRIGGER PULL JUST A LITTLE MORE CRISP
BY JASON
I'm about as novice to gunsmithing as one can be, and having Lenny's video to guide me every step of the way was extremely he
crisper feeling trigger, although I wouldn't categorize the difference as earth-shattering.
I am sure the enhancement will translate well into the performance of my G43, and at the end of the day, I do recommend this pr
YES (2) NO (1)
| 10/5/2016 5:14 pm
SWEET SPOT
BY SCOTT
I ordered the Double Diamond connector on Sunday and it arrived Wednesday. I installed it in about 15 minutes and let me tell y
HUGE difference in the trigger pull. Amazing difference for a great price. Way to go GlockStore!!
YES (2) NO (1)
1/28/17,
| 3/3/2016 6:14 pm
WELL PLEASED!
BY CARROLL
Recently purchased & installed this Double Diamond 3.5 pound connector in my wife's new Glock 42. She was having trouble a
to fire after about 2/3 of a box of ammo (She's a housewife, not a brickmason with massive grip & forearms). After the very first r
Double Diamond connector, the look on her face was priceless as she said, "I LOVE IT!". Installation was so easy, just followed L
Lenny for your great performance replacement parts and massive library of videos.
YES (29) NO (2)
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se 1:17-cv-22826-UU Document 1-14 Entered on FLSD Docket 07/27/2017 Page 23 of

Patent Holder LLC v. Magill - Complaint

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Patent Holder LLC v. Magill - Complaint

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Case 1:17-cv-22826-UU Document 1 Entered on FLSD Docket 07/27/2017 Page 1 of 9

UNITED STATES DISTRICT COURT

PATENT HOLDER, LLC.

Lmp/Mail Order Video, Inc., and

COMPLAINT FOR PATENT INFRINGEMENT

PATENT HOLDER, LLC. (hereinafter PATENT HOLDER) by and through its

(hereinafter Magill), Lmp/Mail Order Video, Inc. (hereinafter LMP/MAIL), and

Magills Glockstore (hereinafter Glockstore) and alleges the following:

NATURE OF THE ACTION

and the State of Florida.

2. PATENT HOLDER is a Florida Limited Liability Company having an

address at 12201 SW 131 Avenue, Miami, FL 33186.

3. On information and belief, Defendant Leonard L. Magill is an individual

residing at 4770 Ruffner Street, San Diego, CA 92111.

4. On information and belief, Defendant LMP/MAIL is a corporation

at 4770 Ruffner Street, San Diego, CA 92111.

5. On information and belief, Defendant Glockstore is a corporation

at 4770 Ruffner Street, San Diego, CA 92111.

U.S.C. 1331, 1338(a), and 1367(a).

interstate and international commerce.

8. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b),

Composite Exhibit 2, and Exhibits 3 and 4 attached hereto.

10. PATENT HOLDER owns a United States patent relating to Enhanced

Trigger Control Connector.

Exhibit 5 attached hereto.

the Enhanced Trigger Control Connector.

13. The 700 Patent was assigned to PATENT HOLDER.

15. PATENT HOLDERs Enhanced Trigger Control Connector was created to

travels generally in a rearward and downward direction establishing an undesired trigger

pull excess travel.

16. PATENT HOLDERs Enhanced Trigger Control Connector limits over

and 9 attached hereto.

17. On information and belief, Defendants also do business in manufacturing

10, 11, 12, and 13 attached hereto.

18. On information and belief, and without PATENT HOLDERs

See enclosed Exhibit 12 attached hereto.

19. Defendants infringing gun parts and accessories include an enhanced

trigger control connector identified by Defendants as a DOUBLE DIAMOND 3.5 lb.

CONNECTOR. See enclosed Exhibit 13 attached hereto.

20. Without a license, consent, or authorization from PATENT HOLDER,

Defendants manufactured, or had manufactured a plurality of the DOUBLE DIAMOND

technology and innovative style in its infringing products.

22. On information and belief, the DOUBLE DIAMOND 3.5 lb.

See enclosed Exhibit 15 attached hereto.

23. On information and belief, Defendants are intentionally manufacturing

of the 700 Patent.

Patent in Miami-Dade County.

knowing of the existence of the 700 Patent.

26. Defendants knowing and repeated infringement of PATENT HOLDERs

COUNT I: PATENT INFRINGEMENT

paragraphs 1 through 26 above, inclusive, and incorporates them by reference herein.

existence of the 700 Patent without PATENT HOLDERs authorization.

patented machine, manufacture, combination or composition, or a material or apparatus

substantial non-infringing use.

by Defendants infringement of PATENT HOLDERs 700 Patent.

32. Defendants infringing activities violate 35 U.S.C. 271.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff PATENT HOLDER respectfully prays for:

A. Judgment that Defendants willfully infringed PATENT HOLDERs 700

Patent in violation of 35 U.S.C. 271;

B. An injunction against further infringement of PATENT HOLDERs 700

C. An award of damages adequate to compensate PATENT HOLDER for the

D. Actual damages suffered by PATENT HOLDER as a result of

Defendants unlawful conduct, in an amount to be proven at trial, as well as prejudgment