Radix Products v. Atziloose - Complaint

Case 2:17-cv-04754-GAM Document 1 Filed 10/16/17 Page 1 of 10
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l IN THE UNITED STATES DISTRICT COURT

1 FOR THE EASTERN DISTRICT OF PENNSYLVANIA
2
"RADIX PRODUCTS LLC
3
Plaintiff,
11 7 4 ~154
Civil Action No. - - - - - -
4
v.
5
ATZILOOSE LLC; AXELRAD; D04U; JURY TRIAL DEMANDED
6 CASFER;DEEZONE;EXCELTECH
DIRECT; HYPOFIRE; INDI DESI
7
STORE; KICTY; KICTY OFFICIAL;
8 KINZD; KINZD OFFICIAL; NEW BLUE
SKY; QIWANG; QIWANG LEATHER
9 II BAG INC; SOOLOON; YIXIANGQING;
YWSSS; ZHOMA US; and JOHN DOE
10 II ENTITIES 1THROUGH20 (whose true
names are unknown),
11
12 Defendants.
13 COMPLAINT FOR PATENT INFRINGEMENT

14 1. Plaintiff Radix Products LLC ("Radix" or "Plaintiff'), for its Complaint against
15 Defendant Atziloose LLC; Axelrad; Do4U; Casfer; Deezone; ExcelTech Direct; Hypofire; Indi
16 Desi Store; Kicty; Kicty Official; Kinzd; Kinzd Official; New Blue Sky; Qiwang; Qiwang
17 Leather Bag Inc; Sooloon; Yixiangqing; YWSSS; Zhoma US; and John Doe Entities 1 through
18 20 (collectively referred to as "Defendants"), alleges the following:
19 NATURE OF THE ACTION
20 2. This is an action for patent infringement arising under the Patent Laws of the
21 United States, 35 U.S.C. 1 et seq.
22 THE PARTIES
23 3. Plaintiff Radix is a company organized under the laws of the state of California.
24 Radix has its principal place of business at 10903 Hesby St Unit 13 North Hollywood CA 91601,
25 (U.S.A.).
26 4. Upon information and belief, Defendant Atziloose LLC is a company organized
27 under the laws of the state of Pennsylvania. Atziloose has its principal place of business at 50
-1-
1 II Ann St West Pittston, PA 18643. This complaint will identify Defendant by its infringing
2 II product ("Product 1"), as illustrated by Figures 1-4 in Exhibit 1 (see
3 II https://www.amazon.com/Fathers-Wallets-Carbon-Blocking-Updated/dp/BOlGVSOMHOi).
4 II 5. Upon information and belief, Axelrad is a foreign entity with no known place of
5 II business. Axelrad does not publically list any information regarding its place of business, and
6 II upon numerous requests, Axelrad has refused to release any information regarding its place of
7 II business. Axelrad sells and offers to sell products throughout the United States (via
8 11 www.amazon.com), including this judicial district. Because the Plaintiff has been unable to
9 II locate Axelrad, this complaint will identify Axelrad by its infringing product ("Product 2"), as
10 11 illustrated by Figure 1 in Exhibit 2 (see https://www.amazon.com/Axelrad-Slim-Men-Wallet-
11 II Black-Black/dp/B073WLW7CP/).
12 II 6. Upon information and belief, Do4U is a foreign entity with no known place of
13 II business. Do4U does not publically list any information regarding its place of business, and upon
14 II numerous requests, Do4U has refused to release any information regarding its place of business.
15 II Do4U sells and offers to sell products throughout the United States (via www.amazon.com),
16 II including this judicial district. Because the Plaintiff has been unable to locate Do4U, this
17 II complaint will identify Do4U by its infringing product ("Product 3"), as illustrated by Figures 1-
18 II 4 in Exhibit 3 (see https://www.amazon.com/Do4U-Minimalist-Aluminum-Pocket-
19 II :WalleJ/_clp/B072QWFZSi\1_/).
20 II 7. Upon information and belief, Casfer is a foreign entity with no known place of
21 II business. Casfer does not publically list any information regarding its place of business, and
22 11 upon numerous requests, Casfer has refused to release any information regarding its place of
23 II business. Casfer sells and offers to sell products throughout the United States (via
24 II www&mazon.com), including this judicial district. Because the Plaintiff has been unable to
25 II locate Casfer, this complaint will identify Casfer by its infringing product ("Product 4"), as
26 II illustrated by Figures 1-7 in Exhibit 4 (see https://www.amazon.com/Slim-Wallet-Pocket-tool-
27 II _I?lQckingLQp/B072M33KKJ2D.
-2-
1 II 8. Upon information and belief, Deezone is a foreign entity with no known place of
2 II business. Deezone does not publically list any information regarding its place of business, and
3 11 upon numerous requests, Deezone has refused to release any information regarding its place of
4 II busines~. Deezone sells and offers to sell products throughout the United States (via
5 II www.amazon.com), including this judicial district. Because the Plaintiffas been unable to
6 II locate Deezone, this complaint will identify Deezone by its infringing products ("Product 5") as
7 II illustrated by Figures 1-5 in Exhibit 5 (see htJ:ps://www.amazon.com/Slim-Wallet-Minimalist-
8 II Pocket-Credit/dp/B075SJ6M2C/) and ("Product 6") as illustrated by Figures 6-11 in Exhibit 5
9 11 (see https://www.amazon.com/RFID-Blocking-Slim-Wallet-Minimalist/dp/B075CVMGNQ,,').
10 II 9. Upon information and belief, ExcelTech Direct is a foreign entity with no known
11 II place of business. ExcelTech Direct does not publically list any information regarding its place
12 II of business, and upon numerous requests, ExcelTech Direct has refused to release any
13 11 information regarding its place of business. ExcelTech Direct sells and offers to sell products
14 11 throughout the United States (via www.amazon.com), including this judicial district. Because the
15 II Plaintiff has been unable to locate ExcelTech Direct, this complaint will identify ExcelTech
16 II Direct by its infringing product ("Product 3"), as illustrated by Figures 1-4 in Exhibit 3 (see
17 II https://www.amazon.com/Do4U-Minimalist-Aluminum-Pocket-Wallet/dp/B072QWFZSM,,').
18 II 10. Upon information and belief, Hypofire is a foreign entity with no known place of
19 II business. Hypo fire does not publically list any information regarding its place of business, and
20 II upon numerous requests, Hypofire has refused to release any information regarding its place of
21 II business. Hypofire sells and offers to sell products throughout the United States (via
22 II www.amazon.com), including this judicial district. Because the Plaintiff has been unable to
23 II locate Hypofire, this complaint will identify Hypofire by its infringing product ("Product 7"), as
24 II illustrated by Figures 1-4 in Exhibit 6 (see https://www.amazon.com/Aluminum-Wallet-RFID-
25 II Blocking-Holder-Silver/dp/B01NAKR92XL).
26 II 11. Upon information and belief, Indi Desi Store is a foreign entity with no known place
27 II of business. Indi Desi Store does not publically list any information regarding its place of
-3-
1 II business, and upon numerous requests, Indi Desi Store has refused to release any information
2 regarding its place of business. Indi Desi Store sells and offers to sell products throughout the
3 United States (via ~ww.amazon.com), including this judicial district. Because the Plaintiff has
4 been unable to locate Indi Desi Store, this complaint will identify Indi Desi Store by its
5 II infringing product ("Product 4"), as illustrated by Figures 1-7 in Exhibit 4 (see
6 II htt.Qs://www.amazon.com/Slim-Wallet-Pocket-tool-Blocking/dp/B072M33KKDL).
7 II 12. Upon information and belief, Kicty is a foreign entity with no known place of
8 II business. Kicty does not publically list any information regarding its place of business, and upon
9 II numerous requests, Kicty has refused to release any information regarding its place of business.
10 11 Kicty sells and offers to sell products throughout the United States (via www.amazon.com),
11 II including this judicial district. Because the Plaintiff has been unable to locate Kicty, this
12 II complaint will identify Kicty by its infringing product ("Product 8"), as illustrated by Figures l-7
13 II in Exhibit 7 (see littps://www.amazon.com/Kicty-Slim-Minimalist-Wallet-
14 II Polycarbonate/d~/B073J25HDC0.
15 11 13. Upon information and belief, Kicty Official is a foreign entity with no known place of
16 II business. Kicty Official does not publically list any information regarding its place of business,
17 II and upon numerous requests, Kicty Official has refused to release any information regarding its
18 II place of business. Kicty Official sells and offers to sell products throughout the United States
19 II (via www.amazon.com), including this judicial district. Because the Plaintiff has been unable to
20 II locate Kicty Official, this complaint will identify Kicty Official by its infringing product
21 II ("Product 8"), as illustrated by Figures 1-7 in Exhibit 7 (see https://www.amazon.com/Kicty-
22 II Slim-Minimalist-Wallet-Polycarbonate/dp/B073J25HDC0.
23 II 14. Upon information and belief, Kinzd is a foreign entity with no known place of
24 II business. Kinzd does not publically list any information regarding its place of business, and upon
25 II numerous requests, Kinzd has refused to release any information regarding its place of business.
26 II Kinzd sells and offers to sell products throughout the United States (via www.amazon.com),
27 II including this judicial district. Because the Plaintiff has been unable to locate Kinzd, this
-4-
1 II complaint will identify Kinzd by its infringing product ("Product 9"), as illustrated by Figures 1-
2 7 in Exhibit 8 (see https://www.amazon.com/Wallets-Carbon-Wallet-Credit-
3 Holder/dt>/B06Y5ZM74Q,0.
4 II 15. Upon information and belief, Kinzd Official is a foreign entity with no known place
5 II of business. Kinzd Official does not publically list any information regarding its place of
6 II business, and upon numerous requests, Kinzd Official has refused to release any information
7 regarding its place of business. Kinzd Official sells and offers to sell products throughout the
8 United States (via ~\\:'w.amazon.com), including this judicial district. Because the Plaintiff has
9 II been unable to locate Kinzd Official, this complaint will identify Kinzd Official by its infringing
10 II product ("Product 9"), as illustrated by Figures 1-7 in Exhibit 8 (see
11 https://www.amazon.com/Wallets-Carbon-Wallet-Credit-Holder/dt>fB06Y5ZM74QD.
12 16. Upon information and belief, Defendant New Blue Sky is a foreign entity with no
13 known place of business. New Blue Sky does not publically list any information regarding its
14 II place of business, and upon numerous requests, New Blue Sky, has refused to release any
15 II information regarding its place of business. New Blue Sky sells and offers to sell products
16 II throughout the United States (via www .amazon.com), including this judicial district. Because the
17 II Plaintiff has been unable to locate New Blue Sky, this complaint will identify New Blue Sky by
18 II its infringing products ("Product 1O"), as shown in Figures 1-7 in Exhibit 9 (see
19 h!!t>s://www.amazon.com/Minimalist-Carbon-Wallet-RFID-Blocking-Credit/dp/B07148WV2C/
20 and https://www.amazon.com/dt>/B071F6BLPMD.
21 II 17. Upon information and belief, Qiwang is a foreign entity with no known place of
22 II business. Qiwang does not publically list any information regarding its place of business, and
23 II upon numerous requests, Qiwang has refused to release any information regarding its place of
24 II business. Qiwang sells and offers to sell products throughout the United States (via
25 II www.amazon.com), including this judicial district. Because the Plaintiff has been unable to
26 II locate Qiwang, this complaint will identify Qiwang by its infringing product ("Product 11 "), as
27
-5-
1 II illustrated by Figures 1-5 in Exhibit 10 (see htj:ps://www.amazon.com/Carbon-Blocking-Credit-
2 II Business-Wallets/dp/BQ1~2_5QTCC/).
3 II 18. Upon information and belief, Qiwang Leather Bag Inc. is a foreign entity with no
4 II known place of business. Qiwang Leather Bag Inc.does not publically list any information
5 II regarding its place of business, and upon numerous requests, Qiwang Leather Bag Inc.has
6 II refused to release any information regarding its place of business. Qiwang Leather Bag Inc.sells
7 II and offers to sell products throughout the United States (via www.amazon.com), including this
8 II judicial district. Because the Plaintiff has been unable to locate Qiwang Leather Bag Inc., this
9 II complaint will identify Qiwang Leather Bag Inc.by its infringing product ("Product 11 "),as
10 11 illustrated by Figures 1-5 in Exhibit 10 (see h!!ps://www.amazon.com/Carbon-Blocking-Credit-
11 II Business-Wallets/dp/B01L95QTCC/).
12 II 19. Upon information and belief, Defendant Sooloon is a foreign entity with no known
13 II place of business. Sooloon does not publically list any information regarding its place of
14 II business, and upon numerous requests, Sooloon, has refused to release any information regarding
15 II its place of business. Sooloon sells and offers to sell products throughout the United States (via
16 11 www .amazon.com), including this judicial district. Because the Plaintiff has been unable to
17 II locate Sooloon, this complaint will identify Sooloon by its infringing product ("Product 12"), as
18 II shown in Figures 1-5 in Exhibit 11 (see https://www.amazon.com/C_arbon-Wallets-Blocking:_
19 II Credit-Holder/dpjB01NOSWUN4/).
20 II 20. Upon information and belief, Defendant YWSSS is a foreign entity with no known
21 II place of business. YWSSS does not publically list any information regarding its place of
22 II business, and upon numerous requests, YWSSS, has refused to release any information regarding
23 II its place of business. YWSSS sells and offers to sell products throughout the United States (via
24 II www .ama~Qrr.com ), including this judicial district. Because the Plaintiff has been unable to
25 II locate YWSSS, this complaint will identify YWSSS by its infringing product ("Product 12"), as
26 II shown in Figures 1-5 in Exhibit 11 (see https://www.amazon.com/Carbon-Wallets-Blockin_g_:_
27 II Credit-Holder/dp/B01NQS~_4l).
-6-
1 21. Upon information and belief, Defendant Yixiangqing is a foreign entity with no
2 known place of business. Yixiangqing does not publically list any information regarding its place
3 of business, and upon numerous requests, Yixiangqing, has refused to release any information
4 regarding its place of business. Yixiangqing sells and offers to sell products throughout the
5 II United States (via www.amazon.com), including this judicial district. Because the Plaintiff has
6 II been unable to locate Yixiangqing, this complaint will identify Yixiangqing by its infringing
7 product ("Product 10"), as shown in Figures 1-7 in Exhibit 9 (see
8 https://www .amazon.com/Minimalist-Carbon-Wallet-RFID-Blocking-Credit/dp/B07148WV2C/
9 and https://www.amazon.com/dp/B071F6BLPM/)).
10 22. Upon information and belief, Defendant Zhoma US is a foreign entity with no known
11 place of business. Zhoma US does not publically list any information regarding its place of
12 II business, and upon numerous requests, Zhoma US, has refused to release any information
13 II regarding its place of business. Zhoma US sells and offers to sell products throughout the United
14 II States (via www .amazon.com), including this judicial district. Because the Plaintiff has been
15 II unable to locate Zhoma US, this complaint will identify Zhoma US by its infringing products
16 II ("Product 13"), as shown in Figures 1-7 in Exhibit 12 (see https://www.amazon.com/Zhoma-
17 11 Slim-Wallet-Minimalist-Pocket/dp/B071 Y CPFMVD and ("Product 14") as shown in Figures 8-
18 11 13 in Exhibit 12 (see https://www.amazon.com/Zhoma-Slim-Wallet-Blocking-
19 II Minimalist/dp/B071L8Z44DD.
20 II JURISDICTION AND VENUE
21 II 11. This is an action for patent infringement arising under the Patent Laws of the
22 II United States, Title 35 of the United States Code.
23 II 12. This Court has subject matter jurisdiction under 28 U.S.C. 1331 and 1338(a).
24 13. Venue is proper in this judicial district under 28 U.S.C. 1391(c).
25 14. Upon information and belief, each Defendant conducts substantial business in this
26 II forum, directly or through intermediaries, including: (i) at least a portion of the infringements
27 II alleged herein; and (ii) regularly doing or soliciting business, engaging in other persistent courses
-7-
1 of conduct and/or deriving substantial revenue from goods provided to individuals and business
2 in the Commonwealth of Pennsylvania. Further, this Court has personal jurisdiction over
3 Defendants because Defendants have purposely availed itself of the privileges and benefits of the
4 laws of the Commonwealth of Pennsylvania, at least by selling and offering to sell its products
5 into the Commonwealth of Pennsylvania.
6 COUNT I- INFRINGEMENT OF U.S. PATENT NO. D768,382
7 15. The allegations set forth in the foregoing paragraphs 1 through 14 are
8 incorporated into this First Claim for Relief.
9 16. On October 11, 2016, U.S. Patent No. D768,382 ("the '382 patent"), entitled
10 "Wallet," was duly and legally issued by the United States Patent and Trademark Office. A true
11 and correct copy of the '382 patent is attached as Exhibit 13.
12 17. Radix is the assignee and owner of all right, title and interest in and to the '3 82
13 patent, including the right to assert all causes of action arising under said patent and the right to
14 any remedies for infringement of it.
15 18. Upon information and belief, each Defendant has and continues to directly
16 infringe one or more claims of the '382 patent under 35 U.S.C. 271, by making, using, selling,
17 importing and/or providing and causing to be used mounting products such as the products
18 illustrated in Exhibits 1 through 12.
19 19. Radix has been harmed by each Defendant's infringing activities.
20 COUNT II- INFRINGEMENT OF U.S. PATENT NO. D768,382
21 20. The allegations set forth in the foregoing paragraphs 1 through 14 are
22 II incorporated into this First Claim for Relief.
23 II 21. On October 11, 2016, U.S. Patent No. D768,383 ("the '383 patent"), entitled
24 II "Wallet," was duly and legally issued by the United States Patent and Trademark Office. A true
25 II and correct copy of the '383 patent is attached as Exhibit 14.

26
27
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1 22. Radix is the assignee and owner of all right, title and interest in and to the '383
2 II patent, including the right to assert all causes of action arising under said patent and the right to
3 II any remedies for infringement of it.
4 II 23. Upon information and belief, each Defendant has and continues to directly
5 II infringe one or more claims of the '383 patent under 35 U.S.C. 271, by making, using, selling,
6 II importing and/or providing and causing to be used mounting products such as the products
7 II illustrated in Exhibits 1 through 12.
8 II 24. Radix has been harmed by each Defendant's infringing activities.
9 II JURY DEMAND
10 25. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Radix demands a
11 trial by jury on all issues triable as such.
12 PRAYER FOR RELIEF
13 WHEREFORE, Plaintiff Radix demands judgment for itself and against Defendants as
14 follows:
15 A. Equitable relief in the form of a preliminary injunction against the Defendants and
16 its officers, partners, employees, agents, parents, subsidiaries, attorneys, and anyone acting or
17 participating with the Defendants, precluding the manufacture, use, sale, or offer for sale of any
18 product that infringes the '382 patent;
19 B. Equitable relief in the form of a preliminary injunction against the Defendants and
21 participating with the Defendants, precluding the manufacture, use, sale, or offer for sale of any
22 product that infringes the '383 patent;
23 C. An adjudication that the Defendants have each infringed the '382 patent;
24 D. An adjudication that the Defendants have each infringed the '383 patent;
25 E. Equitable relief in the form of a permanent injunction against the Defendants and
27
-9-
1 II participating with the Defendants, precluding the manufacture, use, sale, or offer for sale of any
2 II product that infringes the '3 82 patent;
3 F. Equitable relief in the form of a permanent injunction against the Defendants and
4 II its officers, partners, employees, agents, parents, subsidiaries, attorneys, and anyone acting or
5 II participating with the Defendants, precluding the manufacture, use, sale, or offer for sale of any
6 II product that infringes the '383 patent;
7 G. An award of damages to be paid by Defendants adequate to compensate Radix for
8 II each Defendant's past infringement of the '382 patent, and any continuing or future infringement
9 II through the date such judgment is entered, including interest, costs, expenses and an accounting
10 II of all infringing acts including, but not limited to, those acts not presented at trial;
11 H. An award of damages to be paid by Defendants adequate to compensate Radix for
12 11 each Defendant's past infringement of the '383 patent, and any continuing or future infringement
13 11 through the date such judgment is entered, including interest, costs, expenses and an accounting
14 11 of all infringing acts including, but not limited to, those acts not presented at trial;
15 I. A declaration that this case is exceptional under 35 U.S.C. 285, and an award of
16 II Plaintiffs reasonable attorneys' fees; and
17 J. An award to Radix of such further relief at law or in equity as the Court deems
1r~
18 just and proper.
19
II
Dated: 10/ 111201 7
20 Wesley E. Schwie
Pennsylvania Attorney I.D. No. 314032
21 Schwie Law, LLC
150 Monument Road, Suite 207
22 Bala Cynwyd, PA 19004
23 Telephone: 651-428-9828
Email: wes@schwielaw.com
24
Attorney for Radix Products LLC ("Plaintiff")
25
26
27
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Case 2:17-cv-04754-GAM Document 1-1 Filed 10/16/17 Page 1 of 29
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USOOD768382S
c12) United States Design Patent c10) Patent No.: US D768,382 S

Wu (45) Date of Patent: ** Oct. 11, 2016
(54) WALLET 0694,007 s .. ll/2013 O'Amore ....................... 03/247

0706,536 s .. 6/2014 Nikosey ......................... 03/247
0713,143 s .. 9/2014 Ashley ........................... 03/247
(71) Applicant: Arthur Wu, North Hollywood, CA 0716,043 s .. 10/2014 Wilk .............................. 03/247
(US) 0718,525 s .. 12/2014 Kim 03/247
0723,798 s .. 3/2015 Sha ................................ 03/247
(72) Inventor: Arthur Wu, North Hollywood, CA 0724,840 s .. 3/2015 Fridstrom ...................... 03/247
(US) 0724,841 s .. 3/2015 Schneider ...................... 03/247
2005/0279435 Al 12/2005 Coates ................. A45C ll/182
150/147
(73) Assignee: Arthur Wu, North Hollywood, CA
(US)
OTHER PUBLICATIONS
(**) Term: 15 Years Elephant Wallet-downloaded on Mar. 6, 2016 from www.
elephantwallet.com.
(21) Appl. No.: 29/545,205 Huron Wallet-downloaded on Mar. 6, 2016 from www.humnwal-
let.com.
(22) Filed: Nov. 10, 2015 Ridge Wallet-downloaded on Mar. 6, 2016 from www.ridgewallet.
( 51) LOC (10) Cl. .... ... ... .. ... .. .... ... ... .. .. .......... ... ... 03-01 com/.
Asset Wallet-downloaded on Mar. 6, 2016 from www.kickstarter.
(52) U.S. Cl. com/projects/princesation/asset-the-modem-wallet-with-nfc-tech-
USPC .......... .................................. .. ... ... ....... D3/247 nology.
(58) Field of Classification Search Cardstack Wallet-downloaded on Mar. 6, 2016 from http://
USPC ......... D2/861; D3/20, 203.6, 205, 206, 208, cardstack.co.
D3/226, 232, 245, 247-253, 303, 324; (Continued)
Dll/78.l; Dl4/250; Dl9/3, 27, 75, 86,
Dl9/91, 102
Primary Examiner - Susan E Krakower
CPC .............. A45C 1106; A45C 3/08; B68F 1/00
See application file for complete search history. Assistant Examiner - Lisa A Grabenstetter
(57) CLAIM
(56) References Cited The ornamental design for a wallet, as shown and described.
U.S. PATENT DOCUMENTS DESCRIPTION
0527,898 s .. 912006 Tavone .......................... 03/247
0553,354 s 10/2007 Kohler ........................... 03/247 FIG. 1 is a perspective view of a wallet, showing my new
0574,614 s .. 8/2008 Sanders ......................... 03/247 design;
0584,049 s .. 112009 Uzelac ........................... 03/247 FIG. 2 is a bottom plan view thereof;
0590,151 s .. 412009 Karobkina ..................... 03/247
FIG. 3 is a top plan view thereof;
0611,249 s .. 3/2010 Uzelac ........................... 03/247
0616,295 s .. 5/2010 Britt ................................. 019/9 FIG. 4 is a right side view thereof;
0620,252 s .. 7/2010 Keels ............................. 03/247 FIG. 5 is a left side view thereof;
0622,958 s .. 9/2010 Moore ........................... 03/247 FIG. 6 is a front view thereof; and,
0628,796 s .. 12/2010 Uzelac ........................... 03/247 FIG. 7 is a back view thereof.
0632,076 s .. 2/2011 Westrick ........................ 03/247
The broken lines are included to show unclaimed portions of
0638,624 s .. 5/2011 Lyons ............................ 03/247
0650,581 s .. 12/2011 Wallace ......................... 03/247 the design.
0687,630 s .. 8/2013 Warner .......................... 03/247
0690,931 s .. 10/2013 Minn ............................. 03/247 1 Claim, 6 Drawing Sheets
US D768,382 S
Page 2
(56) References Cited Silverback Wallet-----<iownloaded from Mar. 6, 2016 from www.
amazon.com/dp/BOOPN2B9TG/?tag=slimwallet-20.
Minimo Wallet-----<iownloaded from Mar. 6, 2016 from www.
OTHER PUBLICATIONS
minimostore.com.
Obstructures Wallet-----<iownloaded from Mar. 6, 2016 from http://
obstructures.org/work/thing/18/wallet-aluminum-plate. * cited by examiner
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USOOD768383S
c12) United States Design Patent c10) Patent No.: US D768,383 S

Wu (45) Date of Patent: ** Oct. 11, 2016
(54) WALLET D694,007 S * 11/2013 D' Amore ....................... D3/247

D706,536 S * 6/2014 Nikosey ......................... D3/247
(71) Applicant: Arthur Wu, North Hollywood, CA D713,143 S * 9/2014 Ashley ........................... D3/247
D716,043 S * 10/2014 Wilk .............................. D3/247
(US) D718,525 S * 12/2014 Kirn ... .. .. .. ...... .. .. .. .. .. ...... D3/247
D723,798 S * 3/2015 Sha ................................ D3/247
(72) Inventor: Arthur Wu, North Hollywood, CA D724,840 S * 3/2015 Fridstrom ...................... D3/247
(US) D724,841 S * 3/2015 Schneider ...................... D3/247
2005/0279435 Al* 12/2005 Coates ................. A45C 11/182
150/147
(73) Assignee: Arthur Wu, North Hollywood, CA
(US)
OTHER PUBLICATIONS
(**) Tenn: 15 Years Elephant Wallet-downloaded on Mar. 6, 2016 from www.
elephantwallet.com.
(21) Appl. No.: 29/545,206 Humn Wallet-downloaded on Mar. 6, 2016 from www.hwnnwal-
let.com.
(22) Filed: Nov. 10, 2015 Ridge Wallet-downloaded on Mar. 6, 2016 from www.ridgewallet.
(51) LOC (10) Cl. ............................................... 03-01 corn/.
Asset Wallet-downloaded on Mar. 6, 2016 from www.kickstarter.
(52) U.S. Cl.
corn/projects/princesation/asset-the-modem-wallet-with-nfc-tech-
USPC .......... .. ... ............................. ........ ....... D3/247 nology.
(58) Field of Classification Search Cardstack Wallet-downloaded on Mar. 6, 2016 from http://
USPC ......... D2/861; D3/20, 203.6, 205, 206, 208, cardstack.co.
D3/226, 232, 245, 247-253, 303, 324; (Continued)
Dll/78.l; Dl4/250; Dl9/3, 27, 75, 86,
Dl9/91, 102
CPC .............. A45C 1/06; A45C 3/08; B68F 1/00
Primary Examiner - Susan E Krakower
See application file for complete search history. Assistant Examiner - Lisa A Grabenstetter
(57) CLAIM
(56) References Cited
The ornamental design for a wallet, as shown and described.
U.S. PATENT DOCUMENTS
DESCRIPTION
D527,898 S * 9/2006 Tavone .......................... D3/247
D553,354 S * 10/2007 Kohler ........................... D3/247 FIG. 1 is a perspective view of a wallet, showing my new
D574,614 S * 8/2008 Sanders ......................... D3/247 design;
D584,049 S * 112009 Uzelac ........................... D3/247 FIG. 2 is a bottom plan view thereof;
D590,151 S * 412009 Karobkina ..................... D3/247
FIG. 3 is a top plan view thereof;
D611,249 S * 3/2010 Uzelac ........................... D3/247
D616,295 S * 512010 Britt ................................. Dl9/9 FIG. 4 is a right side view thereof;
D620,252 S * 7/2010 Keels ............................. D3/247 FIG. 5 is a left side view thereof;
D622,958 S * 9/2010 Moore ........................... D3/247 FIG. 6 is a front view thereof; and,
D628,796 S 12/2010 Uzelac ........................... D3/247 FIG. 7 is a back view thereof.
D632,076 S * 2/2011 Westrick ........................ D3/247
The broken lines are included to show unclaimed portions of
D638,624 S 512011 Lyons ............................ D3/247
D650,581 S * 1212011 Wallace ......................... D3/247 the design.
D687,630 S * 8/2013 Warner .......................... D3/247
D690,931 S " 10/2013 Minn ............................. D3/247 1 Claim, 6 Drawing Sheets
US D768,383 S
Page 2
(56) References Cited Silverback Wallet-downloaded from Mar. 6, 2016 from www.
amazon.com/dp/BOOPN2B9TG/?tag=slimwallet-20.
Minimo Wallet-downloaded from Mar. 6, 2016 from www.
OTHER PUBLICATIONS
minimostore.com.
Obstructures Wallet-downloaded from Mar. 6, 2016 from http://
obstructures.org/work/thing/ 18/wallet-aluminum-plate. * cited by examiner
U.S. Patent Oct. 11, 2016 Sheet 1 of 6 US D768,383 S
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CIVIL COVER SHEET \

merntormation contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
'l- Cv- \..l-154
s form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
;,~beet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM)
DRFENDANTS .... - - :i
AfziToose [[C;",ljelrad; Do4U; Caster; Deezone; Exce1TeCh Dlfect;
Hypofire; lndi Desi Store; Kicty; Kicty Official; Kinzd; Kinzd Official;
New Blue Sky; Qiwang; Sooloon; Yixiangqing; YWSSS; Zhoma US
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant _U_S_ _ _ _ _ _ _ __
(EXCEPT IN U.S. Pl.A/NT/FF CASES) (IN U.S. Pl.A/NT/FF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(C) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Schwie Law LLC
150 Monument Road, Suite 207 Bala Cynwyd, PA 19004
ZJ
651-428-9828
II. BASIS OF JURIS III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in one Box for Plaintiff
(For Diversity Cases Only) ~ and One Box for Defer>
0 I U.S. Government ederal Question
PTF DEF DEF
QIC QIC 4
~ ~"""""""""" """"''"""' "

Plaintiff (U.S. Government Not a Party) Citizen of This State I Incorporated or Principal Pia
"'""" ""''"'"" , . 0
of Business In This State
0 2 U.S. Government 0 4 Diversity

Defendant (Indicate Citizenship of Parties in Item Ill) / ) of Business In Another State 0 '
0 6 0 6
''',FORFEITIJRE/PENAL'n' ~
0 110 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 375 False Claims Act
0 120 Marine 0 310 Airplane 0 365 Personal Injury - of Property 21 use 0 376 Qui Tam (31 USC
0 130 Miller Act 0 315 Airplane Product Product Liability 0 6900ther 3729(a))
0 140 Negotiable Instrument Liability 0 367 Health Carel 0 400 State Reapportionment
0 150 Recovery of Overpayment 0 320 Assault, Libel & Pharmaceutical lt-""'.n"'n-b"'n""~""n"'~"'"'''"'n"'"""'"'~=.,,....,.,0'."'J,,-t,,,I 0 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 0 430 Banks and Banking
0 151 Medicare Act 0 330 Federal Employers' Product Liability 0 450 Commerce
0 152 Recovery of Defaulted Liability 0 368 Asbestos Personal 0 460 Deportation
Student Loans 0 340 Marine Injury Product New Drug Application 0 470 Racketeer Influenced and
(Excludes Veterans) 0 345 Marine Product Liability 840 Trademark Corrupt Organizations
0 153 Recovery of Overpayment Liability PERSONAL PROPERTY OCIAL SE<;:URITY. < 0 480 Consumer Credit
of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud 0 710 Fair Labor Standards 0 861 HIA (1395ff) 0 490 Cable/Sat TV
0 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lending Act 0 862 Black Lung (923) 0 850 Securities/Commodities/
0 190 Other Contract 0 380 Other Personal 0 720 Labor/Management 0 863 DIWC/DIWW (405(g)) Exchange
0 195 Contract Product Liability Property Damage Relations 0 864 SSID Title XVI 0 890 Other Statutory Actions
0 196 Franchise 0 385 Property Damage 0 740 Railway Labor Act 0 865 RSI (405(g)) 0 891 Agricultural Acts
Product Liability 0 751 Family and Medical 0 893 Environmental Matters
Leave Act 0 895 Freedom of Information
)REALPROPRRTY!!!:r~:.. PRISONER>PE1lTIONS ~ 0 790 Other Labor Litigation ":::FEDERAL.TA'X' SUITS::,,, Act
0 210 Land Condemnation 0 440 Other Civil Rights Habeas Corpus: 0 791 Employee Retirement 0 870 Taxes (U.S. Plaintiff 0 896 Arbitration
0 220 Foreclosure 0 441 Voting 0 463 Alien Detainee Income Security Act or Defendant) 0 899 Administrative Procedure
0 230 Rent Lease & Ejectment 0 442 Employment 0 510 Motions to Vacate 0 871 IRS-Third Party Act/Review or Appeal of
0 240 Torts to Land 0 443 Housing/ Sentence 26 USC 7609 Agency Decision
0 245 Tort Product Liability Accommodations 0 530 General 0 950 Constitutionality of
0 290 All Other Real Property 0 445 Amer. w/Disabilities - 0 535 Death Penalty IMMIGRATION'../ State Statutes
Employment Other: 0 462 Naturalization Application
0 446 Amer. w/Disabilities - 0 540 Mandamus & Other 0 465 Other Immigration
Other 0 550 Civil Rights Actions
0 448 Education 0 555 Prison Condition
0 560 Civil Detainee -
Conditions of
Confinement
V. OJ1UGIN (Placean "X"inOneBoxOnly)

J:ll: 1 O~ginal 0 2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 S Transferred from 0 6 Multidistrict 0 8 Multidistrict
- .. State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
CAUSE OF ACTION l:~~~~~~~ti~n of cause: / 7 ""\

Patent infrinaement
VII. REQUESTED IN 0 CHECK IF THIS IS A CLASS ACTION DEMAND$ CHECK YES on
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAN
VIII. RELATED CASE(S)
IF ANY
(See instructions):
JUDGE DOCKET NUMBER
CT 16 2017
DATE SIGNATURE~RECORD
10/11/2017
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP

OCT 1S' 2!tt7 MAG.JUDGE
UNITED STATES DISTRICT COURT
E.OR. THE .EA.S'@N DISTRICT OF PE. NNSYLVANIA - DESIGNATION FORM to be used by counsel to indicate the categ.ory of the case for. the purpose of
(r(a~ig~ll/~h,t to\l1~,P(i~priate
calendar. . 17 4754
\~d~~s-~frfJai~t;tf::, 10903 Hesby St Unit 13 North Hollywood CA 91601
,, !__ ,, -

Address ofDefendant: 50 Ann St West Pittston PA 18643
Place of Accident, Incident or Transaction: Patent infringement within this jurisdiction and others
(Use Reverse Side For Additional Space)
Does this civil action involve a nongovernmental corporate party with any parent corporation and any publicly held corporation owni
(Attach two copies of the Disclosure Statement Form in accordance with Fed.R.Civ.P. 7.I(a)) YesD
Does this case involve multidistrict litigation possibilities? Yeso NoDl1

RELATED CASE, IF ANY:
Case Number: Judge Date Terminated:-----~.-----.,/-------------
Civil cases are deemed related when yes is answered to any of the following questions:
I. Is this case related to property included in an earlier numbered suit pending or within one year previously terminated action in this c
YesD
2. Does this case involve the same issue of fact or grow out of the same transaction as a prior suit pending or within one year previoully terminated
action in this court?
YesD NolXI
3. Does this case involve the validity or infringement of a patent already in suit or any earlier numbered case pending or within one ar previously
terminated action in this court? YesD NoliCI
4. Is this case a second or successive habeas corpus, social security appeal, or pro se civil rights case filed by the same individual?
YesD
CIVIL: (Place t/ in ONE CATEGORY ONLY)

A Federal Question Cases: B. Diversity Jurisdiction Cases:
1. D Indemnity Contract, Marine Contract, and All Other Contracts I. D Insurance Contract and Other Contracts
2. D FELA 2. D Airplane Personal Injury
Jones Act-Personal Injury 3. D Assault, Defamation
4. D Marine Personal Injury
5. o Motor Vehicle Personal Injury
abor-Management Relations 6. D Other Personal Injury (Please specify)
ivil Rights 7. D Products Liability
o Habeas Corpus 8. D Products Liability - Asbestos
9. D Securities Act(s) Cases 9. D All other Diversity Cases
10. D Social Security Review Cases (Please specify)
11. D All other Federal Question Cases
(Please s p e c i f y ) - - - - - - - - - - - - - - - - - -
ARBITRATION CERTIFICATION
. (Check Appropriate Category)
Schw1e , counsel of record do hereby certify:
Pursuant to Local Civil Rule 53 .2, Section 3(c)(2), that to the best of my knowledge and belief, the damages recoverable in this civil action case exceed the sum of
XII Relief other than monetary damages is sought.
October 11, 2017 ~

Attorney-at-Law
314032
Attorney I.D.#
NOTE: A trial de novo will be a trial by jury only if there has been compliance with F.R.C.P. 38.
I certify that, to my knowledge, the within case is not related to any case now pending or within one year previously terminated action in this court
except as noted above.
c----:
/
OCT 16 2017"
DATE: October 11. 2017 314032
CIV. 609 (5/2012)
Attorney-at-Law
flt\ 1 r=: 2017 Attorney I.D.#
\'\
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.
flr..:'.Ai,;;:
(!
,
( " ...
.; .
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
CASE MANAGEMENT TRACK DESIGNATION FORM

CIVIL ACTION
v.
~ tRJ
NO!J ti 4754
In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for
plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of
filing the complaint and serve a copy on all defendants. (See 1:03 of the plan set forth on the reverse
side of this form.) In the event that a defendant does not agree with the plaintiff regarding said
designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on
the plaintiff and all other parties, a Case Management Track Designation Form specifying the track
to which that defendant believes the case should be assigned.
SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:
(a) Habeas Corpus - Cases brought under 28 U.S.C. 2241 through 2255. ( )
(b) Social Security - Cases requesting review of a decision of the Secretary of Health
and Human Services denying plaintiff Social Security Benefits. ( )
(c) Arbitration - Cases required to be designated for arbitration under Local Civil Rule 53.2. ( )
(d) Asbestos - Cases involving claims for personal injury or property damage from
exposure to asbestos. ( )
(e) Special Management- Cases that do not fall into tracks (a) through (d) that are
commonly referred to as complex and that need special or intense management by
the court. (See reverse side of this form for a detailed explanation of special
management cases.)
(t) Standard Management- Cases that do not fall into any one of the other tracks.
October 11 1 2017 Wes Schwie Radix Products LLC

Date Attorney-at-law Attorney for
651-428-9828 wes@schwielaw.com
Telephone FAX Number E-Mail Address
(Civ. 660) 10/02
~0 CT ~
201f'
D~X 16 201l
~Cl '\ 5 tlrwDu.4

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Case 2:17-cv-04754-GAM Document 1 Filed 10/16/17 Page 1 of 10

<""" ~">, C\~ '

l IN THE UNITED STATES DISTRICT COURT

13 COMPLAINT FOR PATENT INFRINGEMENT

2 II product ("Product 1"), as illustrated by Figures 1-4 in Exhibit 1 (see

10 11 illustrated by Figure 1 in Exhibit 2 (see https://www.amazon.com/Axelrad-Slim-Men-Wallet-

18 II 4 in Exhibit 3 (see https://www.amazon.com/Do4U-Minimalist-Aluminum-Pocket-

26 II illustrated by Figures 1-7 in Exhibit 4 (see https://www.amazon.com/Slim-Wallet-Pocket-tool-

7 II illustrated by Figures 1-5 in Exhibit 5 (see htJ:ps://www.amazon.com/Slim-Wallet-Minimalist-

8 II Pocket-Credit/dp/B075SJ6M2C/) and ("Product 6") as illustrated by Figures 6-11 in Exhibit 5

24 II illustrated by Figures 1-4 in Exhibit 6 (see https://www.amazon.com/Aluminum-Wallet-RFID-

5 II infringing product ("Product 4"), as illustrated by Figures 1-7 in Exhibit 4 (see

13 II in Exhibit 7 (see littps://www.amazon.com/Kicty-Slim-Minimalist-Wallet-

21 II ("Product 8"), as illustrated by Figures 1-7 in Exhibit 7 (see https://www.amazon.com/Kicty-

2 7 in Exhibit 8 (see https://www.amazon.com/Wallets-Carbon-Wallet-Credit-

10 II product ("Product 9"), as illustrated by Figures 1-7 in Exhibit 8 (see

1 II illustrated by Figures 1-5 in Exhibit 10 (see htj:ps://www.amazon.com/Carbon-Blocking-Credit-

10 11 illustrated by Figures 1-5 in Exhibit 10 (see h!!ps://www.amazon.com/Carbon-Blocking-Credit-

18 II shown in Figures 1-5 in Exhibit 11 (see https://www.amazon.com/C_arbon-Wallets-Blocking:_

26 II shown in Figures 1-5 in Exhibit 11 (see https://www.amazon.com/Carbon-Wallets-Blockin_g_:_

7 product ("Product 10"), as shown in Figures 1-7 in Exhibit 9 (see

16 II ("Product 13"), as shown in Figures 1-7 in Exhibit 12 (see https://www.amazon.com/Zhoma-

17 11 Slim-Wallet-Minimalist-Pocket/dp/B071 Y CPFMVD and ("Product 14") as shown in Figures 8-

18 11 13 in Exhibit 12 (see https://www.amazon.com/Zhoma-Slim-Wallet-Blocking-

20 II JURISDICTION AND VENUE

22 II United States, Title 35 of the United States Code.

24 13. Venue is proper in this judicial district under 28 U.S.C. 1391(c).

5 into the Commonwealth of Pennsylvania.

6 COUNT I- INFRINGEMENT OF U.S. PATENT NO. D768,382

8 incorporated into this First Claim for Relief.

11 and correct copy of the '382 patent is attached as Exhibit 13.

14 any remedies for infringement of it.

18 illustrated in Exhibits 1 through 12.

19 19. Radix has been harmed by each Defendant's infringing activities.

20 COUNT II- INFRINGEMENT OF U.S. PATENT NO. D768,382

22 II incorporated into this First Claim for Relief.

25 II and correct copy of the '383 patent is attached as Exhibit 14.

3 II any remedies for infringement of it.

7 II illustrated in Exhibits 1 through 12.

8 II 24. Radix has been harmed by each Defendant's infringing activities.

11 trial by jury on all issues triable as such.

12 PRAYER FOR RELIEF

18 product that infringes the '382 patent;

22 product that infringes the '383 patent;

2 II product that infringes the '3 82 patent;

6 II product that infringes the '383 patent;

7 G. An award of damages to be paid by Defendants adequate to compensate Radix for

11 H. An award of damages to be paid by Defendants adequate to compensate Radix for

16 II Plaintiffs reasonable attorneys' fees; and

14 Figure 1: Product 10.

13 Figure 5: Product 10.

13 Figure 5: Product 11.

14 Figure 1: Product 12.

21 II Figure 2: Product 12.

13 Figure 3: Product 12.

21 II Figure 4: Product 12.

14 Figure 1: Product 13.

13 Figure 5: Product 13.

15 /\Slf!COM i>aM wtlPS ~ i,wo ~t ~ w tiol4 C1i:4rt wets

25 SUM & SLEEK

13 Figure 7: Product 13.

13 Figure 9: Product 14.

Figure 12: Product 14.

13 Figure 13: Product 14.