Allway Tools v. Olympia Tools - Complaint

Case 1:20-cv-04861 Document 1 Filed 06/24/20 Page 1 of 42
UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK
ALLWAY TOOLS, INC.,
Plaintiff,
v. COMPLAINT
OLYMPIA TOOLS INTERNATIONAL, Jury Trial Demanded

INC.,
Defendant.
Plaintiff Allway Tools, Inc. (“Plaintiff” or “Allway”), by and through its attorneys
Gottlieb, Rackman & Reisman, P.C., complains and alleges against defendant Olympia Tools
International, Inc. (“Defendant” or “Olympia”) as follows:
INTRODUCTION
1. Allway is a leading manufacturer and distributor of contractor’s tools such as
paint sundries and related products, including a helictical paint mixer, a heavy-duty scrub brush,
an extendable scrub brush and a contour scraper set (collectively, the “Allway Products”).
2. Over at least 15 years of sales success, the Allway Products are recognized by the
industry, the trade, and the home improvement consumer as originating with Allway.
3. Allway owns valid design patents covering the ornamental designs of the
helictical paint mixer and the extendable scrub brush.
4. The Allway Products, which are or have been sold at retailers such as Home
Depot, are also protected by trade dress.
5. On information and belief, Olympia—with full knowledge of and complete
disregard for Allway’s rights—sourced, imported, promoted, advertised, distributed, sold, and
offered for sale products aping the distinctive design and configuration of the Allway Products.
Olympia’s products are shown below (collectively, the “Infringing Products”).
6. By importing, selling, and distributing the Infringing Products, Olympia
intentionally created and profited from its copying of the Allway Products and from consumer
confusion.
7. Accordingly, Allway brings the following action for patent infringement in
violation of 35 U.S.C. § 271, et seq., trade dress infringement and unfair competition pursuant to
Section 43(a) of the Lanham Act, 15 U.S.C. § 1051, et seq., and trademark dilution, trade dress
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infringement, and unfair competition in violation of the statutory and common laws of the State
of New York.
THE PARTIES
8. Plaintiff Allway Tools, Inc. is a corporation existing under the laws of Delaware,
having an office and factory in this judicial district at 1255 Seabury Ave, Bronx, NY 10462.
Allway also has an office at 248 Wyandanch Avenue, West Babylon, NY 11704.
9. On information and belief, defendant Olympia Tools International, Inc. is a
California corporation with a place of business located at 929 N. Grand Avenue, Covina,
California 91724.
10. On information and belief, Defendant is a distributor, marketer, importer, seller,
and retailer of private label and branded products such as storage solutions, tools, workbenches
and tumblers. Defendant is a competitor to Allway.
11. On information and belief, Defendant imports, markets, distributes, and sells
products to customers located throughout the United States and in this judicial district.
JURISDICTION AND VENUE
12. This action arises under the Patent Act, 35 U.S.C. § 101, et seq., the Lanham Act,
15 U.S.C. § 1051, et seq., and related state claims under the statutory and common law of the
State of New York.
13. This Court has jurisdiction over the subject matter of this action pursuant to 28
U.S.C. §§ 1331 and 1338 for claims arising under the patent and trademark laws of the United
States; and has supplemental jurisdiction pursuant to 28 U.S.C. §§ 1338(b) and 1367 for claims
arising from violations of the statutory and common law of the State of New York.
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14. This Court has personal jurisdiction over Defendant because Defendant sold and
offered for sale the Infringing Products to customers located in New York and in this Judicial
District. Further, on information and belief, Defendant regularly transacts business in New York,
regularly does business in New York, and has derived substantial revenues from products sold
and used in New York, including the Infringing Products.
15. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and (c).
FACTUAL BACKGROUND
Allway’s Rights and Products
16. Founded in 1935, Allway designs, manufactures, distributes and sells contractor’s
tools such as paint sundries and related products. Its line of products includes paint scraper sets
and other paint removal tools, scrub brushes, paint mixers, as well as blades and utility knives
and specialized tools for drywall, wallcoverings, ceramic tile, masonry and flooring.
17. Allway is continuously ahead of the curve in technology and tool design, and has
more than 100 patented products among the hundreds of SKUs in its line.
18. In response to the demand for ergonomic product designs to reduce fatigue and
on-the-job injuries, Allway also offers a large selection of soft-handled products, some of which
are updated items from its line and some of which are new products with ergonomic features.
19. Over the course of over eight decades, Allway and its products have become
well-known for their quality and for their usefulness in getting a job done.
20. Allway products reflect the technological innovation, high quality and
commitment to value-added products that dealers, contractors and consumers have come to
expect from Allway.
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21. Allway products are available in approximately 20,000 retail locations, which
include or have included some of the most well-known names in retail: Walmart, Ace, Do-It -
Best, TrueValue, Home Depot and Sherwin Williams. Allway also promotes and advertises its
goods to consumers in the United States and around the world via its website accessible at
allwaytools.com.
22. Emblazoned on most ALLWAY-branded products and/or their packaging is the
federally registered ALLWAY trademark. For many years Allway has also offered private label
versions of its products.
23. Allway also promotes its line of products at trade shows it attends annually
around the country, such as the National Hardware Show (currently held in Las Vegas), which
Allway has attended for at least the past 30 years: the VAL Test Show in Naples, Florida; the
PACOA Dealer Market in Flushing, New York; and the Orgill Dealer Market. Allway’s booth at
the trade shows it attends prominently displays the ALLWAY trademark, and its products, such
as the Allway Products. Photos from some of the trade shows that Allway has attended are
shown below and included in Exhibit 1.
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24. Allway products are also featured in catalogs prominently bearing the ALLWAY
mark. These catalogs are published periodically and distributed, in hard copy and electronically,
at trade shows and by sales representatives to their customers. Representative copies of Allway
catalogs are attached as Exhibit 2.
25. From time to time Allway promotes its products in advertisements. For example,
the Contour Scraper Set has been featured in such advertisements. A copy of one such
advertisement is attached as Exhibit 3. Likewise, the helictical paint mixer has appeared in an
advertisement. A copy of such an advertisement is attached as Exhibit 4.
26. Distributers and retailers selling Allway products promote them on their websites
and in circulars. Below (and attached as Exhibit 5) are screen shots from Amazon.com showing
the ALLWAY mark associated with Allway products.
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27. As shown in the image below (attached as Exhibit 6) from a Sherwin Williams
store, the ALLWAY mark is prominently displayed at the point of sale in connection with
Allway products at retailers selling ALLWAY branded products in their stores.
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28. Similarly, the images below (attached as Exhibit 7) from an Aubuchon store also
show the ALLWAY mark displayed with ALLWAY branded products at the point of sale.
29. Further, ALLWAY branded products are displayed at the point of sale in display
cases that show the ALLWAY mark, as shown below.
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Allway’s Helictical Paint Mixer
30. One of Allway’s best-selling products is its helictical paint mixer. Over 2.1
million units of the helictical paint mixer have been sold since it was introduced in 2005.
31. Allway’s helictical paint mixer is the subject of U.S. Design Patent No. D529,526
(the “D526 Patent”), attached as Exhibit 8. Allway’s helictical paint mixer bears the notice
required by the statute.
32. Allway’s helictical paint mixer has been featured in Allway catalogs and on the
Allway website since at least as early as 2005. Attached as Exhibit 9 is a printout from the
Allway website showing the helictical paint mixer. Representative samples of pages from
Allway catalogs over the years showing the helictical paint mixer can be found in Exhibit 2.
33. Since its introduction in 2005, Allway’s helictical paint mixer has been displayed
in Allway’s booth at the trade shows it attends around the country.
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34. Starting in 2005, Allway’s helictical paint mixer was sold in packaging bearing
the ALLWAY mark.
35. An image of Allway’s helictical paint mixer appears below and in Exhibit 10.
36. In 2009 Allway began selling private label versions of the helictical paint mixer.
37. The helictical paint mixer consists of the following design elements:
 a cap with a circular opening fixed atop a rod;

 a rod with a rectangular information card;
 a cylinder having 6 fins attached to the bottom of the rod, with each fin being
narrower at the top than at the bottom and curved outwardly; and
 the bottom of the cylinder with fins resembling a pinwheel.
38. Collectively, these elements cohere to form a unique, distinctive, broadly
recognized, non-functional trade dress (the “Helictical Paint Mixer Trade Dress”).
39. Paint mixers in distinctly different configurations exist and are sold by Allway’s
competitors.
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40. Since its introduction, Allway’s helictical paint mixer has been actively promoted
by Allway and its distributers and retailers, appearing in circulars and marketing materials and
their respective websites.
41. In view of the foregoing, the helictical paint mixer has become a symbol of
Allway.
Allway’s Extendable Scrub Brush
42. Allway’s extendable scrub brush has achieved sales success. Over 1.3 million
units of the extendable scrub brush have been sold since it was introduced in approximately
2008.
43. Allway’s extendable scrub brush is the subject of U.S. Design Patent No.
D619,811, attached as Exhibit 11. Allway’s extendable scrub brush bears the notice required by
the statute.
44. Allway’s extendable scrub brush has been featured in Allway catalogs and on the
Allway website since at least as early as 2008. Attached as Exhibit 12 are printouts from
Allway’s website showing the extendable scrub brush. Representative samples of pages from
Allway catalogs over the years showing the extendable scrub brush can be found in Exhibit 2 .
45. Since its introduction in 2008, Allway’s extendable scrub brush has been
displayed in Allway’s booth at the trade shows it attends around the country.
46. Starting in 2008, Allway’s extendable scrub brush was sold in packaging bearing
the ALLWAY mark, and the ALLWAY mark appeared on the bristle body.
47. An image of Allway’s extendable scrub brush appears below and in Exhibit 13.
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48. In 2011 Allway began selling private label versions of the extendable scrub brush.
49. The extendable scrub brush consists of the following design elements:
 a teardrop shaped head with bristles extending below the teardrop;

 a straight handle affixed to the head at an angle of approximately 45 degrees, such
that the handle is higher than the head;
 a groove running along the handle, from where the handle joins the head almost
until the end of the handle;
 the upper portion of the handle in a contrasting color from the body of the brush;
and
 an ergonomic grip on the handle.
Collectively, these elements cohere to form a unique, distinctive, broadly recognized, non-
functional trade dress (the “Extendable Scrub Brush Trade Dress”).
50. Extendable scrub brushes in distinctly different configurations exist and are sold
by Allway’s competitors.
51. Since its introduction, Allway’s extendable scrub brush has been actively
promoted by Allway and its distributers and retailers, appearing in circulars and marketing
materials and their respective websites.
52. In view of the foregoing, the extendable scrub brush has become a symbol of
Allway.
Allway’s Heavy-Duty Scrub Brush
53. Allway’s heavy-duty scrub brush has achieved sales success. Over 2 million units
of the heavy-duty scrub brush have been sold since it was introduced in 2002.
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54. Allway’s heavy-duty scrub brush has been featured in Allway catalogs and on the
Allway website since at least as early as 2002. Attached as Exhibit 14 is a printout from
Allway’s website. Representative samples of pages from Allway catalogs over the years showing
the heavy-duty scrub brush are attached as Exhibit 2.
55. Since its introduction in 2002, Allway’s heavy-duty scrub brush has been
displayed in Allway’s booth at the trade shows it attends around the country.
56. Starting in 2002, Allway’s heavy-duty scrub brush was sold in packaging bearing
the ALLWAY mark, and the ALLWAY mark appeared on the bristle body.
57. An image of Allway’s heavy-duty scrub brush appears below and in Exhibit 15.
58. Allway sold approximately 404,000 units of the Allway branded heavy-duty scrub
brush to Home Depot between 2007 and 2011.
59. In 2011 Allway began selling private label versions of the heavy-duty scrub
brush.
60. The heavy-duty scrub brush consists of the following design elements:
 a brush with an ovoid body shape;

 an outer ring of bristles extending below the body with an inner ring of bristles
that contrast in color with the outer ring;
 a handle above the brush body which connects to the brush at both ends; and
 the handle in a contrasting color from the body of the brush.
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functional trade dress (the “Heavy Duty Scrub Brush Trade Dress”).
61. Heavy-duty scrub brushes in distinctly different configurations exist and are sold
by Allway’s competitors.
62. Since its introduction, Allway’s heavy-duty scrub brush has been actively
promoted by Allway and its distributers and retailers, appearing in circulars and marketing
materials and their respective websites.
63. In view of the foregoing, the heavy-duty scrub brush has become a symbol of
Allway.
Allway’s Contour Scraper Set
64. Allway’s contour scraper set has achieved sales success. Over 200,000 units of
the contour scraper set have been sold since it was introduced in 2001.
65. Allway’s contour scraper set has been featured in Allway catalogs and on the
Allway website since at least as early as 2001. Attached as Exhibit 16 are printouts from
Allway’s website showing the contour scraper set. Representative samples of pages from Allway
catalogs over the years showing the contour scraper set are attached as Exhibit 2.
66. Since its introduction in 2001, Allway’s contour scraper set has been displayed in
Allway’s booth at the trade shows it attends around the country.
67. Starting in 2001, Allway’s contour scraper set was sold in packaging bearing the
ALLWAY mark, and the ALLWAY mark appeared on the handle.
68. An image of Allway’s contour scraper set appears below and in Exhibit 17.
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69. Allway sold 39,000 units of the Allway branded contour scraper set to Home
Depot between 2016 and 2018.
70. In 2011 Allway began selling private label versions of the contour scraper set.
71. The contour scraper set consists of the following design elements:
 a rectangular packaging card with the brand name and informational wording in
the upper left-hand corner and the contents affixed to the card by a plastic
overlay;
 a collection of six different blades that can be affixed to a scraper handle;
 the six blades contained in an opened carrying case on the left side of the
packaging card; and
 a handle with an ergonomic grip displayed vertically at the right side of the
packaging card.
functional trade dress (the “Contour Scraper Set Trade Dress”).
72. Contour scraper sets in distinctly different configurations exist and are sold by
Allway’s competitors.
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73. Since its introduction, Allway’s contour scraper set has been actively promoted by
Allway and its distributers and retailers, appearing in circulars and marketing materials and their
respective websites.
74. In view of the foregoing, the contour scraper set has become a symbol of Allway.
Allway’s Business with Home Depot
75. Photographs showing the Allway Products being offered for sale in Home Depot
stores are shown below and attached as Exhibit 18.
76. In about 2015 Home Depot asked Allway to provide it with Allway’s helictical
paint mixer, to be sold under a trademark owned by Home Deopt. Allway did so, and Home
Depot then sold the private label helictical paint mixer to its customers.
77. In about 2008 Home Depot asked Allway to provide it with Allway’s extendable
scrub brush, to be sold under a trademark owned by Home Depot. Allway did so, and Home
Depot then sold the private label extendable scrub brush to its customers.
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78. In about 2011 Home Depot asked Allway to provide it with Allway’s heavy-duty
scrub brush, to be sold under a trademark owned by Home Depot. Allway did so, and Home
Depot then sold the private label heavy-duty brush to its customers.
79. In about 2018 Home Depot asked Allway to provide it with Allway’s contour
scraper set, to be sold under a trademark owned by Home Depot. Allway did so, and Home
Depot then sold the private label contour scraper set to its customers.
80. As a result of Home Depot’s purchase of private labelled versions of the Allway
Products from Allway, customers familiar with the ALLWAY branded Allway Products
transitioned to the corresponding private label Allway Products, and their expectations in terms
of quality and reliability were maintained.
81. In April 2019 Home Depot advised Allway that it would stop purchasing private
label Allway Products, and Allway subsequently learned that Home Depot was purchasing the
Infringing Products from Olympia. The Infringing Products do not originate from Allway and
are not licensed by Allway.
Defendant’s Infringing Actions
82. On information and belief, Olympia distributes, markets, and sells private label
and branded products such as storage solutions, tools, workbenches and tumblers through brick
and mortar and online retailers. Olympia also maintains a website at olympiatools.com.
83. Olympia attends trade shows across the country, including many of the same trade
shows as Allway, such as the National Hardware Show in Las Vegas.
84. Upon information and belief, Olympia either purchased samples of the Allway
Products from Home Depot or was given samples of the Allway Products by Home Depot. In
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either case, upon information and belief after receiving the Allway Products Olympia designed
the Infringing Products and began selling them to Home Depot.
85. A Vietnamese website operated by Olympia or one of its affiliates features images
of Allway products which were being sold by Home Depot, apparently in an effort to convey to
third parties that Olympia or its affiliate has the ability to manufacture and sell the same products
as Allway, notwithstanding Allway’s design patent and trade dress rights. Screen shots from the
Vietnamese website (with some items enlarged for clarity) featuring images of the Allway
Products appear below and are attached as Exhibit 19.
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The copyright notice at the bottom of each page identifies “Olympia Tools” as the owner of the
copyright in the webpages; “Olympia Tools” also appears at the top of the page.
86. Since at least as early as 2019 Olympia has sold the Infringing Products, and the
Infringing Products have displaced the sale of the Allway Products. The sale of these Infringing
Products is intended to cause consumers to believe that the Infringing Products are only
rebranded versions of the Allway Products, when in fact that is not the case.
87. Olympia’s infringing version of the helictical paint mixer (Exhibit 20), for
instance, replicates the cap with a circular opening fixed atop a rod; the rod with a rectangular
information card; the cylinder having 6 fins attached to the bottom of the rod, with each fin being
narrower at the top than at the bottom and curved outwardly; and the pinwheel configuration at
the bottom of the cylinder. The image below depicts Olympia’s infringing paint mixer,
alongside the genuine Allway paint mixer that Olympia sought to mimic:
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Olympia’s Infringing Paint Mixer Genuine Allway Paint Mixer
88. Similarly, the images below compare Olympia’s infringing paint mixer with a
drawing from the D526 Patent.
Olympia’s Infringing Paint Mixer Allway D526 Patent
89. Olympia’s infringing version of the Allway extendable scrub brush (Exhibit 21),
for instance, replicates the teardrop shaped head with bristles extending below the teardrop; the
straight handle affixed to the head at an angle of approximately 45 degrees, such that the handle
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is higher than the head; the grove running along the handle, from where the handle joins the head
almost until the end of the handle; and the upper portion of the handle in a contrasting color from
the body of the brush; and the ergonomic grip on the handle. The image below depicts Olympia’s
infringing extendable scrub brush, alongside the genuine Allway extendable scrub brush that
Olympia sought to mimic:
Olympia’s Infringing Extendable Scrub Brush Genuine Allway Extendable Scrub Brush
90. Similarly, the images below compare Olympia’s infringing extendable scrub
brush with a drawing from the D811 Patent.
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Olympia’s Infringing Extendable Scrub Brush Allway D811 Patent

91. Olympia’s infringing version of the Allway heavy duty scrub brush (Exhibit 22),
for instance, replicates the ovoid shape of the body; the outer ring of bristles below the body with
an inner ring of bristles that contrast in color with the outer ring; the handle above the brush body
connecting to the brush at both ends; and the handle in a contrasting color from the body of the
brush. The image below depicts Olympia’s infringing extendable scrub brush, alongside the
genuine Allway heavy duty scrub brush that Olympia sought to mimic:
Olympia’s Infringing Heavy Duty Scrub Brush Genuine Allway Heavy Duty Scrub Brush
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92. Olympia’s infringing version of the Allway contour scraper set (Exhibit 23), for
instance, replicates the rectangular packaging card with the brand name and informational
wording in the upper left-hand corner and the contents affixed to the card by a plastic overlay;
the collection of six different blades that can be affixed to a scraper handle; the six blades
contained in an opened carrying case on the left side of the packaging card; and the handle with
an ergonomic grip displayed vertically at the right side of the packaging card. In addition, the
blades included with Olympia’s infringing contour scraper set are inscribed with the very same
part number as the blades included with Allway’s contour scraper set (CSB85, CSB84, CSB86,
etc.). The image below depicts Olympia’s infringing contour scraper set, alongside the genuine
Allway contour scraper set that Olympia sought to mimic:
Olympia’s Infringing Contour Scraper Set Genuine Allway Contour Scraper Set
93. On information and belief, Olympia distributed, sold and offered for sale
Infringing Products to customers located in New York and in this Judicial District.
94. On information and belief, Olympia sourced, imported, distributed, marketed,
offered for sale, and/or sold the Infringing Products fully intending for them to resemble the
Allway Products.
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95. On further information and belief, Olympia sourced, imported, distributed,
marketed, offered for sale, and/or sold Infringing Products with the intent to cause and profit
from confusion among consumers and the public at large.
96. On information and belief, despite being aware of Allway’s rights, Olympia
nevertheless sourced, imported, distributed, marketed, exhibited, offered for sale, and/or sold the
Infringing Products with the intent to violate Allway’s rights, or, at a minimum, did so with
reckless disregard for and willful blindness toward Allway’s rights.
97. Prior to the filing of this action, Allway raised its concerns with Home Depot, and
Home Depot then turned this matter over to Olympia for indemnification. Olympia has refused
to stop selling the Infringing Products and make any changes to them, despite its awareness of
Allway’s design patents and trade dress claims. Consequently, the parties are now at an impasse,
necessitating this action.
FIRST CLAIM FOR RELIEF
Patent Infringement in Violation of 35 U.S.C. § 271—Helictical Paint Mixer
98. Allway repeats and realleges the allegations set forth in the preceding paragraphs
as though fully set forth herein.
99. Olympia has knowingly, intentionally, and willfully infringed the D526 Patent by
manufacturing, designing, exporting, importing, shipping, distributing, promoting, displaying,
offering for sale, and selling the Infringing Product, which has a design covered by the claim of
the D526 Patent.
100. Olympia’s acts of infringement of the D526 Patent were undertaken without
permission or license from Allway. Olympia had and continues to have actual and constructive
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notice of the D526 Patent and Allway’s rights, and its actions constitute willful and intentional
infringement of the D526 Patent.
101. Accordingly, Olympia infringed the D526 Patent with reckless disregard of
Allway’s rights therein, as Olympia knew or should have known that their actions constituted
102. Moreover, Olympia has indicated that it fully intends to continue manufacturing,
promoting, selling, and distributing the Infringing Product.
103. As a direct and proximate result of their infringement of the D526 Patent,
Olympia has derived and received gains, profits, and advantages in an amount yet to be
determined.
104. Pursuant to 35 U.S.C. § 284, Allway is entitled to damages for Olympia’s
infringing acts and treble damages together with interests and costs as fixed by this Court.
105. Pursuant to 35 U.S.C. § 289, Allway is entitled to Olympia’s total profits from the
sale of the Infringing Product.
106. Pursuant to 35 U.S.C. § 285, Allway is entitled to reasonable attorneys’ fees for
the necessity of bringing this claim.
107. Due to Olympia’s infringing acts, Allway has suffered significant and irreparable
injury for which Allway has no adequate remedy at law.
108. Unless enjoined by this Court, Olympia’s infringement of Allway’s D526 Patent
is likely to continue unabated, causing further irreparable injury to Allway.
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SECOND CLAIM FOR RELIEF
Trade Dress Infringement in Violation of 15 U.S.C. § 1125 (a)—Helictical Paint Mixer
110. The Helictical Paint Mixer Trade Dress is recognized in the United States, and in
this Judicial District, as both an emblem of high quality and a symbol of the Plaintiff.
111. The Helictical Paint Mixer Trade Dress is distinctive, non-functional, and
protectable.
112. Olympia’s infringing helictical paint mixer misappropriates every element of the
Helictical Paint Mixer Trade Dress, including a cap with a circular opening fixed atop a rod; a
rod with a rectangular information card; a cylinder having 6 fins attached to the bottom of the
rod, with each fin being narrower at the top than at the bottom and curved outwardly; and the
bottom of the cylinder with fins resembling a pinwheel.
113. The design and configuration of Olympia’s infringing helictical paint mixer is
confusingly similar to Allway’s federally protected Helictical Paint Mixer Trade Dress.
114. Olympia sourced, promoted, imported, advertised, distributed, sold, and/or
offered for sale its infringing helictical paint mixer approximating the Helictical Paint Mixer
Trade Dress without seeking Plaintiff’s permission, authorization, license, or consent.
115. By sourcing, distributing, promoting, advertising, marketing, offering for sale,
and/or selling its infringing helictical paint mixer, Olympia has used Allway’s trade dress in
interstate commerce and in this Judicial District.
116. By sourcing, importing, distributing, promoting, advertising, marketing, offering
for sale, and/or selling its infringing helictical paint mixer, Olympia has and is likely to continue
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to cause confusion, mistake, or deception as to the origin of its infringing helictical paint mixer,
falsely conveying that its infringing helictical paint mixer originate from, or are endorsed or
authorized by Allway.
117. Even to the extent that buyers, whether members of the trade or ordinary
consumers, purchase the infringing helictical paint mixer with knowledge that they do not
emanate from Allway and are not genuine Allway helictical paint mixers, members of the public
encountering the infringing helictical paint mixer after the point of sale are likely to mistakenly
believe that they it is a genuine Allway helictical paint mixer, or is endorsed, sponsored, or
authorized by Allway, resulting in actionable post-sale confusion.
118. On information and belief, Olympia intended to confuse, mislead, or deceive the
public as to the source, sponsorship, or origin of its infringing helictical paint mixer, and to profit
from the goodwill invested in the Allway helictical paint mixer.
119. By reason of Olympia’s willful acts, Allway has been damaged and will continue
to suffer significant damage to its business and reputation unless Olympia are restrained by this
Court from further infringement.
120. Allway has no adequate remedy at law.
121. In light of the foregoing, Allway is entitled to and demands injunctive relief
prohibiting Olympia from using the Helictical Paint Mixer Trade Dress or any mark or design
confusingly similar thereto, and to recover all damages sustained as a result of Olympia’s willful
infringement, all profits obtained by Olympia from its sales of its infringing helictical paint
mixer, and all costs and expenses incurred by Plaintiff in connection with this action, all in an
amount to be determined.
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THIRD CLAIM FOR RELIEF
Patent Infringement in Violation of 35 U.S.C. § 271—Extendable Scrub Brush
as though fully set forth herein
123. Olympia has knowingly, intentionally, and willfully infringed the D811 Patent by
manufacturing, designing, exporting, importing, shipping, distributing, promoting, displaying,
offering for sale, and selling its infringing helictical paint mixer, which has a design covered by
the claim of the D811 Patent.
124. Olympia’s acts of infringement of the D811 Patent were undertaken without
permission or license from Allway. Olympia had and continues to have actual and constructive
notice of the D811 Patent and Allway’s rights, and its actions constitute willful and intentional
125. Accordingly, Olympia infringed the D811 Patent with reckless disregard of
Allway’s rights therein, as Olympia knew or should have known that its actions constituted
126. Moreover, Olympia has indicated that it fully intends to continue manufacturing,
promoting, selling, and distributing its infringing helictical paint mixer.
127. As a direct and proximate result of its infringement of the D811 Patent, Olympia
has derived and received gains, profits, and advantages in an amount yet to be determined.
128. Pursuant to 35 U.S.C. § 284, Allway is entitled to damages for Olympia’s
infringing acts and treble damages together with interests and costs as fixed by this Court.
129. Pursuant to 35 U.S.C. § 289, Allway is entitled to Olympia’s total profits from the
sale of the Infringing Product.
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130. Pursuant to 35 U.S.C. § 285, Allway is entitled to reasonable attorneys’ fees for
the necessity of bringing this claim.
131. Due to Olympia’s infringing acts, Allway has suffered significant and irreparable
injury for which Allway has no adequate remedy at law.
132. Unless enjoined by this Court, Olympia’s infringement of Allway’s D811 Patent
is likely to continue unabated, causing further irreparable injury to Allway.
FOURTH CLAIM FOR RELIEF
Trade Dress Infringement in Violation of 15 U.S.C. § 1125 (a)—Extendable Scrub Brush
134. The Extendable Scrub Brush Trade Dress is recognized in the United States and
in this Judicial District as both an emblem of high quality and a symbol of the Plaintiff.
135. The Extendable Scrub Brush Trade Dress has acquired distinctiveness, is non-
functional, and is protectable.
136. Olympia’s infringing extendable scrub brush misappropriates every element of
the Extendable Scrub Brush Trade Dress, including a teardrop shaped head with bristles
extending below the teardrop; a straight handle affixed to the head at an angle of approximately
45 degrees, such that the handle is higher than the head; a groove running along the handle, from
where the handle joins the head almost until the end of the handle; the upper portion of the
handle in a contrasting color from the body of the brush; and an ergonomic grip on the handle.
137. The design and configuration of Olympia’s infringing extendable scrub brush is
confusingly similar to Allway’s federally protected Extendable Scrub Brush Trade Dress.
30

offered for sale its infringing extendable scrub brush approximating the Extendable Scrub Brush
Trade Dress without seeking Plaintiff’s permission, authorization, license, or consent.
and/or selling its infringing extendable scrub brush, Olympia has used Allway’s trade dress in
for sale, and/or selling its infringing extendable scrub brush, Olympia has and is likely to
continue to cause confusion, mistake, or deception as to the origin of its infringing extendable
scrub brush, falsely conveying that the infringing extendable scrub brush originates from, or is
endorsed or authorized by Allway.
consumers, purchase Olympia’s infringing extendable scrub brush with knowledge that it does
not emanate from Allway and is not a genuine Allway extendable scrub brush, members of the
public encountering the Olympia infringing extendable scrub brush after the point of sale are
likely to mistakenly believe that it is a genuine Allway extendable scrub brush, or is endorsed,
sponsored, or authorized by Allway, resulting in actionable post-sale confusion.
public as to the source, sponsorship, or origin of the Olympia infringing extendable scrub brush,
and to profit from the goodwill invested in the Allway extendable scrub brushes.
31

prohibiting Olympia from using the Extendable Scrub Brush Trade Dress or any mark or design
infringement, all profits obtained by Olympia from its sales of its infringing extendable scrub
brush, and all costs and expenses incurred by Plaintiff in connection with this action, all in an
FIFTH CLAIM FOR RELIEF
Trade Dress Infringement in Violation of 15 U.S.C. § 1125 (a)—Heavy Duty Scrub Brush
147. The Heavy Duty Scrub Brush Trade Dress, is recognized in the United States, and
in this Judicial District as both an emblem of high quality and a symbol of Plaintiff.
148. The Heavy Duty Scrub Brush Trade Dress, has acquired distinctiveness, is non-
149. Olympia’s infringing heavy-duty scrub brush misappropriates every element of
the Heavy Duty Scrub Brush Trade Dress, including a brush with an ovoid body shape; an outer
ring of bristles extending below the body with an inner ring of bristles that contrast in color with
the outer ring; a handle above the brush body which connects to the brush at both ends; and the
handle in a contrasting color from the body of the brush.
150. The design and configuration of Olympia’s infringing heavy-duty scrub brush is
confusingly similar to Allway’s federally protected Heavy Duty Scrub Brush Trade Dress.
32

offered for sale its infringing heavy-duty scrub brush approximating the Heavy Duty Scrub
Brush Trade Dress without seeking Plaintiff’s permission, authorization, license, or consent.
and/or selling its infringing heavy-duty scrub brush, Olympia has used Allway’s trade dress in
for sale, and/or selling its infringing heavy-duty scrub brush, Olympia has and is likely to
continue to cause confusion, mistake, or deception as to the origin of the infringing heavy-duty
scrub brush, falsely conveying that the infringing heavy-duty scrub brush originates from, or is
endorsed or authorized by Allway.
consumers, purchase Olympia’s infringing heavy-duty scrub brush with knowledge that they do
not emanate from Allway and is not a genuine Allway heavy duty scrub brush, members of the
public encountering the infringing heavy-duty scrub brush after the point of sale are likely to
mistakenly believe that it is a genuine Allway heavy-duty scrub brush, or is endorsed, sponsored,
or authorized by Allway, resulting in actionable post-sale confusion.
public as to the source, sponsorship, or origin of the infringing heavy-duty scrub brush, and to
profit from the goodwill invested in the Allway heavy duty scrub brushes.
33

prohibiting Olympia from using the Heavy Duty Scrub Brush Trade Dress or any mark or design
infringement, all profits obtained by Olympia from its sales of its infringing heavy-duty scrub
brush, and all costs and expenses incurred by Plaintiff in connection with this action, all in an
SIXTH CLAIM FOR RELIEF
Trade Dress Infringement in Violation of 15 U.S.C. § 1125 (a)—Contour Scraper Set
160. The Contour Scraper Set Trade Dress is recognized around the world, in the
United States, and in this Judicial District as both an emblem of high quality and a symbol of the
Plaintiff.
161. The Contour Scraper Set Trade Dress has acquired distinctiveness, is non-
162. Olympia’s infringing contour scraper set misappropriates every element of the
Contour Scraper Set Trade Dress, including the rectangular packaging card with the brand name
and informational wording in the upper left-hand corner and the contents affixed to the card by a
plastic overlay; the collection of six different blades that can be affixed to a scraper handle; the
six blades contained in an opened carrying case on the left side of the packaging card; and the
handle with an ergonomic grip displayed vertically at the right side of the packaging card.
34

163. The design and configuration of Olympia’s infringing contour scraper set is
confusingly similar to Allway’s Contour Scraper Set Trade Dress.
offered for sale an infringing contour scraper set approximating the Contour Scraper Set Trade
Dress without seeking Allway’s permission, authorization, license, or consent.
and/or selling infringing contour scraper sets, Olympia has used Allway’s trade dress in interstate
commerce and in this Judicial District.
for sale, and/or selling infringing contour scraper sets, Olympia has and is likely to continue to
cause confusion, mistake, or deception as to the origin of the infringing contour scraper sets,
falsely conveying that the infringing contour scraper sets originates from, or is endorsed or
authorized by Allway.
consumers, purchase Olympia’s infringing contour scraper set with knowledge that it does not
emanate from Allway and is not genuine a Allway contour scraper set, members of the public
encountering the infringing contour scraper set after the point of sale are likely to mistakenly
believe that it is a genuine Allway contour scraper set, or is endorsed, sponsored, or authorized
by Allway, resulting in actionable post-sale confusion.
public as to the source, sponsorship, or origin of the infringing contour scraper set, and to profit
from the goodwill invested in the Allway contour scraper set.
35

prohibiting Olympia from using the Contour Scraper Set Trade Dress or any mark or design
infringement, all profits obtained by Olympia from its sales of its infringing contour scraper set,
and all costs and expenses incurred by Plaintiff in connection with this action, all in an amount to
be determined.
SEVENTH CLAIM FOR RELIEF
Likelihood of Injury to Business Reputation Under – N.Y. Gen. Bus. Law § 360-l—All
Products
172. Plaintiff repeats and realleges the allegations set forth in the preceding paragraphs
173. Allway is the exclusive owner of the Helictical Paint Mixer Trade Dress, the
Extendable Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour
Scraper Set Trade Dress.
174. Through prominent, long, and continuous use in commerce, including commerce
within New York, the Helictical Paint Mixer Trade Dress, the Extendable Scrub Brush Trade
Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour Scraper Set Trade Dress have
become, and continue to grow ever more famous and distinctive.
175. Long after the Helictical Paint Mixer Trade Dress, the Extendable Scrub Brush
Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour Scraper Set Trade Dress
36

became famous, Olympia, without authorization from Allway, adopted the Helictical Paint Mixer
Trade Dress, the Extendable Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade
Dress, and Contour Scraper Set Trade Dress for the design of its Infringing Products.
176. Olympia’s unauthorized use of the Helictical Paint Mixer Trade Dress, the
Extendable Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour
Scraper Set Trade Dress dilutes and is likely to continue to dilute the distinctive quality of
Allway’s Helictical Paint Mixer Trade Dress, Extendable Scrub Brush Trade Dress, Heavy Duty
Scrub Brush Trade Dress, and Contour Scraper Set Trade Dress and to lessen the capacity of the
Helictical Paint Mixer Trade Dress, the Extendable Scrub Brush Trade Dress, the Heavy Duty
Scrub Brush Trade Dress, and the Contour Scraper Set Trade Dress to distinguish Allway’s
goods.
177. Olympia’s unlawful use of the Helictical Paint Mixer Trade Dress, the Extendable
Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour Scraper Set
Trade Dress in connection with inferior goods is further likely to tarnish Allway and the the
Helictical Paint Mixer Trade Dress, the Extendable Scrub Brush Trade Dress, the Heavy Duty
Scrub Brush Trade Dress, and Contour Scraper Set Trade Dress in the minds of consumers
thereby lessening the value of the Helictical Paint Mixer Trade Dress, the Extendable Scrub
Brush Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and Contour Scraper Set Trade
Dress as a unique identifier of Allway’s products.
178. Olympia has therefore diluted the distinctive quality of the Helictical Paint Mixer
Trade Dress, the Extendable Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade
Dress, and Contour Scraper Set Trade Dress, and caused a likelihood of harm to Allway’s
business reputation in violation of Section 360–l of the New York General Business Law.
37

179. Olympia’s acts have caused, and will continue to cause, irreparable injury to
Allway. Allway has no adequate remedy at law and is thus damaged in an amount to be
determined.
EIGHTH CLAIM FOR RELIEF
Trade Dress Infringement in Violation of New York State Common Law—All Products
180. Plaintiff repeats and realleges the allegations set forth in the preceding paragraphs
181. Allway owns all right, title, and interest in and to the Helictical Paint Mixer Trade
Dress, the Extendable Scrub Brush Trade Dress, the Heavy Duty Scrub Brush Trade Dress, and
Contour Scraper Set Trade Dress, including common law rights.
182. Without Plaintiff’s authorization, Olympia misappropriated Allway’s Helictical
Paint Mixer Trade Dress, Extendable Scrub Brush Trade Dress, Heavy Duty Scrub Brush Trade
Dress, and Contour Scraper Set Trade Dress for use in connection with the Infringing Products,
which are substantially indistinguishable from and confusingly similar to the Allway Products.
183. Olympia’s sale of the Infringing Products has caused, and, unless enjoined, will
likely continue to cause consumers and the public to mistakenly conclude that the Infringing
Bags originate from and/or are sponsored, authorized, or endorsed by Longchamp.
184. Olympia’s acts therefore constitute trade dress infringement in violation of the
common law of the State of New York.
185. Upon information and belief, Olympia has profited from its unlawful actions and
was unjustly enriched to the detriment of Allway and has caused Allway damages in an amount
to be determined at trial.
38

186. Allway has been irreparably harmed and, unless enjoined by this Court, will
continue to be irreparably harmed by the sales of Infringing Bags.
NINTH CLAIM FOR RELIEF
Unfair Competition in Violation of New York State Common Law—All Products
189. By the act described above, Olympia has intentionally engaged in unfair
competition in violation of the common law of the State of New York.
190. Olympia’s acts have caused, and will continue to cause, irreparable injury to
Allway. Allway has no adequate remedy at law and is thus damaged in an amount to be
determined.
STATEMENT AS TO DAMAGES
191. As a result of the foregoing activities, and unless Olympia’s conduct is
terminated, Allway will suffer lost sales in an amount believed to be in excess of $10,000,000
(ten million dollars).
PRAYER FOR RELIEF
WHEREFORE, Allway respectfully prays:
A. For a final judgment that Olympia 1) willfully infringed Plaintiff's D526 Patent
and D811 Patent in violation of 35 U.S.C. § 271; 2) willfully infringed Plaintiff’s trade dress in
violation of Section 43 of the Lanham Act, 15 U.S.C. §1125; and 3) willfully engaged in
trademark dilution, trade dress infringement, and unfair competition in violation of the statutory
and common laws of the State of New York; and
39

B. For entry of an Order:
1. preliminarily and permanently enjoining Olympia and its parents, subsidiaries,
affiliates, officers, agents, servants, employees, attorneys, and all persons and
entities acting in concert and participation with them from manufacturing,
marketing, advertising, promoting, displaying, exhibiting, offering for sale,
selling, purchasing, importing, distributing, or otherwise trafficking in the
Infringing Products, or any other products adopting a design or configuration
substantially similar to the Infringing Products;
2. preliminarily and permanently enjoining Olympia and its parents, subsidiaries,
affiliates, officers, agents, servants, employees, attorneys, and all persons and
entities acting in concert and participation with them from manufacturing,
marketing, advertising, promoting, displaying, exhibiting, offering for sale,
selling, purchasing, importing, distributing, or otherwise trafficking in the
infringing helictical paint mixer and/or the infringing extendable scrub brush,
or any other products adopting a design or configuration which infringes the
D526 and D811 Patents;
3. ordering an accounting by Olympia to Plaintiff of any profits gained from
sales of the Infringing Products, and/or any other products misappropriating
Plaintiff’s Trade Dress;
4. awarding damages to Plaintiff, including for injury to Plaintiff’s business
reputation and goodwill, and all other damages arising out of Defendant’s acts
of, infringement, unfair competition, and dilution, in an amount to be
determined;
40

5. requiring Defendants to account for all gains, profits, and advantages derived
and accrued as a result of their infringement of the D526 and D811 Patents;
6. awarding treble damages in the amount of Plaintiff’s damages or Defendant’s
profits, whichever is greater, for willful infringement pursuant to 15 U.S.C. §
1117;
7. assessing to Plaintiff an award of its actual damages, trebled, as well as all
profits Defendants have derived from infringing the D526 and D811 Patents;
8. awarding to Plaintiff its attorneys’ fees, costs, disbursements, and applicable
interest pursuant to 15 U.S.C. § 1117;
9. awarding to Plaintiff its attorneys’ fees, expenses, and costs incurred in
connection with this action as provided by 35 U.S.C. § 285;
10. ordering Defendant to recall all units, if any, of Infringing Products from any
distributors and retailers, and to deliver to Plaintiff for destruction or other
disposition all remaining inventory, if any, of the Infringing Products in the
Defendant’s possession, as well as all advertisements and promotional or
marketing materials related thereto;
11. ordering Defendant to file with this Court and to serve on Plaintiff within ten
(10) days after the entry of injunctive relief a written report, under oath,
setting forth in detail the manner and form in which Defendant has complied
with such Order;
12. awarding to Plaintiff pre- and post-judgment interest and costs of this action
against Defendants; and
13. awarding such other and further relief as the Court may deem just and proper.
41

JS 44C/SDNY Case 1:20-cv-04861 Document 1-1 SHEET
CIVIL COVER Filed 06/24/20 Page 1 of 2
REV. 06/01/17
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.
PLAINTIFFS DEFENDANTS
ALLWAY TOOLS, INC. OLYMPIA TOOLS INTERNATIONAL, INC.
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)
George Gottlieb & Marc P. Misthal, Gottlieb, Rackman & Reisman, P.C., 270
Madison Avenue, New York, NY 10016 (212) 684-3900
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
35 U.S.C. § 271, et seq. and 15 U.S.C. § 1051, et seq.
Judge Previously Assigned

Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No ✔ Yes
If yes, was this case Vol. Invol. Dismissed. No Yes If yes, give date _______________________ & Case No. ______________________
IS THIS AN INTERNATIONAL ARBITRATION CASE? No ✖ Yes
(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

TORTS ACTIONS UNDER STATUTES
CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

[ ] 367 HEALTHCARE/
PHARMACEUTICAL PERSONAL [ ] 375 FALSE CLAIMS
[ ] 110 INSURANCE [ ] 310 AIRPLANE [ ] 625 DRUG RELATED [ ] 422 APPEAL
[ ] 120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY 28 USC 158 [ ] 376 QUI TAM
SEIZURE OF PROPERTY
[ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL [ ] 400 STATE
[ ] 140 NEGOTIABLE [ ] 320 ASSAULT, LIBEL & PRODUCT LIABILITY 28 USC 157 REAPPORTIONMENT
[ ] 690 OTHER
INSTRUMENT SLANDER [ ] 368 ASBESTOS PERSONAL [ ] 410 ANTITRUST
[ ] 150 RECOVERY OF [ ] 330 FEDERAL INJURY PRODUCT [ ] 430 BANKS & BANKING
OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS [ ] 450 COMMERCE
ENFORCEMENT LIABILITY [ ] 460 DEPORTATION
OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY [ ] 820 COPYRIGHTS [ ] 470 RACKETEER INFLU-
[ ] 151 MEDICARE ACT [ ] 345 MARINE PRODUCT [✖] 830 PATENT ENCED & CORRUPT
[ ] 152 RECOVERY OF LIABILITY [ ] 370 OTHER FRAUD ORGANIZATION ACT
[ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION
DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING (RICO)
STUDENT LOANS [ ] 355 MOTOR VEHICLE [ ] 840 TRADEMARK [ ] 480 CONSUMER CREDIT
(EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY [ ] 490 CABLE/SATELLITE TV
[ ] 153 RECOVERY OF [ ] 360 OTHER PERSONAL
OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ] 861 HIA (1395ff) [ ] 850 SECURITIES/
OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACK LUNG (923) COMMODITIES/
BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g)) EXCHANGE
[ ] 160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVI
SUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g))
[ ] 190 OTHER PRISONER PETITIONS RELATIONS [ ] 890 OTHER STATUTORY
CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABOR ACT ACTIONS
[ ] 195 CONTRACT [ ] 510 MOTIONS TO [ ] 751 FAMILY MEDICAL FEDERAL TAX SUITS [ ] 891 AGRICULTURAL ACTS
PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA)
LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S. Plaintiff or
[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEAS CORPUS [ ] 790 OTHER LABOR Defendant) [ ] 893 ENVIRONMENTAL
[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY MATTERS
[ ] 540 MANDAMUS & OTHER [ ] 791 EMPL RET INC 26 USC 7609 [ ] 895 FREEDOM OF
[ ] 440 OTHER CIVIL RIGHTS
SECURITY ACT (ERISA) INFORMATION ACT
(Non-Prisoner)
REAL PROPERTY [ ] 896 ARBITRATION
[ ] 441 VOTING IMMIGRATION [ ] 899 ADMINISTRATIVE
[ ] 210 LAND [ ] 442 EMPLOYMENT PRISONER CIVIL RIGHTS
CONDEMNATION [ ] 443 HOUSING/ [ ] 462 NATURALIZATION PROCEDURE ACT/REVIEW OR
[ ] 220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVIL RIGHTS APPLICATION APPEAL OF AGENCY DECISION
[ ] 230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION [ ] 950 CONSTITUTIONALITY OF
EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS
EMPLOYMENT STATE STATUTES
[ ] 240 TORTS TO LAND CONDITIONS OF CONFINEMENT
[ ] 245 TORT PRODUCT [ ] 446 AMERICANS WITH
LIABILITY DISABILITIES -OTHER
[ ] 290 ALL OTHER [ ] 448 EDUCATION
REAL PROPERTY
Check if demanded in complaint:

DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.
CHECK IF THIS IS A CLASS ACTION AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?
UNDER F.R.C.P. 23 IF SO, STATE:
DEMAND $______________ OTHER ______________ JUDGE _________________________________ DOCKET NUMBER_________________
Check YES only if demanded in complaint

JURY DEMAND: ✖ YES NO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
Case 1:20-cv-04861 Document 1-1 Filed 06/24/20 Page 2 of 2
EXHIBIT 1
EXHIBIT 2
SOFT GRIP
TOOLS FOR
JOBS
Innovation Since 1935

GRIP
SOFT-
CONTOUR SCRAPERS AND PAINTING ACCESSORIES

T OUR BG7HD
C O N
PER
4 WAY BUCKET GRID 7"
S C R A (17100)
Extra rigid 4 way bucket grid for
2 gal. pails, labelled
D
N TE 24/box - weight 13 lb. - .5 cubic feet
TE
PA BG9HD
(17111)
file inside Extra rigid 4 way bucket grid for
handle to keep 5 gal. pails, labelled
blades at peak 24/box - weight 17 lb. - .8 cubic feet
sharpness
CS6 CONTOUR SCRAPER SET (06600)
Soft grip handle, file inside handle,
includes 6 stainless blades in handy storage case, carded
1 set/card - 6/box - 36/master case
weight 21 lb./master case - 2.1 cubic feet
CSB1 CONTOUR BLADE (06610)

Stainless steel, for concave indents and narrow
reveals, carded
1/card - 10/box - 100/master case
weight 6 lb./master case - .5 cubic feet
BC BRUSH COMB (10012)
CSB2 CONTOUR BLADE (06620) Hardwood handle, hardened steel pins, carded
Stainless steel, for small flat and small concave 1/card - 10/box - 100/master case
molding, carded weight 12 lb./master case - .9 cubic feet

Stainless steel, for medium and large rods,
dowels and convex moldings, balusters, carded
PB1 PRY BAR (10004)
Hardened steel, removes nails, moldings,
etc., 11” long, carded
CSB4 CONTOUR BLADE (06640) weight 34 lb./master case - .9 cubic feet
Stainless steel, for flat work and large concave
moldings, crown moldings and chair rails, carded

Stainless steel, for sharp indented moldings and
concave moldings, pilasters, mantels, carded
CSB6 CONTOUR BLADE (06660) EBH

Stainless steel, for round moldings, wood curtain EXTENSION BRUSH HOLDER (11090)
rods, door and window casings, carded Handy, adjustable angle extender
1/card - 10/box - 100/master case for brushes and tools, carded
weight 6 lb./master case - .5 cubic feet 1/card - 10/box - 50/master case
weight 14 lb./master case
1.9 cubic feet
BF3 HALF ROUND FILE
(06010)
Stores inside CS handle
w/magnet, carded
CLR1
CHALKLINE REEL (11002)
100 ft. chalkline reel, with 1 oz. pkg. powdered chalk,
carded
weight 36 lb./ master case - 2.9 cubic feet
HANG-UP STORAGE CASE

CS6
COUNTER DISPLAY
11
PAINTING ACCESSORIES
CCO-50 (BUCKET) PAINT CAN
OPENER (10014)
All steel, opens, and reseals paint can
covers, carded SM5 5 GAL. SPIRAL MIXER (10053)
1/card - 50/bucket - 6 buckets/master case All steel, for H/D use, carded
weight 20 lb./master case - 1.2 cubic feet 1/card - 5/box - 25/master case
NEW
PCO 3-IN-1, PLASTIC CAN

SM1 1 GAL. SPIRAL MIXER (10025)
All steel, for H/D use, carded
▼
OPENER (11360)
Helps to grip screw off can-tops. weight 28 lb./master case - 1.0 cubic feet
For plastic 1-gallon and 1-quart paint
cans from various manufacturers.
Sherwin-Williams, Twist’N Pour, NEW
Pratt & Lambert, Kilz, etc., carded EZ CLEAN
weight 16 lb./master case - .4 cubic feet HM5 5 GAL.“HELIX” PAINT MIXER (10032)
Fastest Mixer Of Its Kind. Fits all electric drills,
with H/D 5/16” hex shaft, carded
NEW 1/card - 5/box - 25/master case
CBO CAN AND BOTTLE OPENER (11355)
Lifts up paint can lid on conventional 1-gallon NEW
and 1-quart metal cans, carded EZ CLEAN
10/box - 100/master case
weight 10 lb./master case - .3 cubic feet HM1 1 GAL. “HELIX” PAINT MIXER (10031)
Fastest Mixer Of Its Kind. Fits all electric drills, with
CBO100 (BUCKET) H/D 1/4” hex shaft, carded
CAN AND BOTTLE OPENER (11356) 1/card - 10/box - 50/master case
Bucket of 100, same as above, labelled weight 24 lb./master case - 1.0 cubic feet
100/bucket - 6 buckets/master case
NEW
HDM H/D MUD MIXER (10030)

Overall length 28", carded
1/card - 5/box - 5 boxes/master case
PPO weight 10.5 lb./master case - .6 cubic feet
PLASTIC PAIL OPENER (11350)
Removes lid from 3 to 5 gal. plastic pails
of paint, drywall compound, roofing tar,
etc. carded
weight 20 lb./master case - 1.0 cubic feet PM 1 GAL. PAINT MIXER (10010)
Fits all electric drills, carded
SPH SWIVEL PAIL HOOK (10050) weight 20 lb./master case - .8 cubic feet
Pointed ladder hook with swivel for paint can pail handle, carded
CPS
PH PAIL HOOK (10011) NEW 1 GAL. “DELUXE”
Ladder hook for paint cans, etc., carded POURING SPOUT
2/card - 10 cards/box - 100 cards/master case and CAN COVER (10022)
weight 21 lb./master case - .8 cubic feet Brush wiping edge,
magnetic brush holder,
neon colors,display boxed,
labelled
NEW 12/box - 72/master case
1.7 cubic feet
GPS1 1 GAL. “BASIC”

GPS5 POURING SPOUT (10026)
5 GAL. POURING SPOUT (10024) No cover, magnetic brush
Pulls apart to fit all threaded and tint plug holder or wiping edge,
type of metal or plastic 5-gallon paint display boxed, labelled
cans, labelled 12/box - 72/master case
25/display box - 4 boxes/master case weight 9 lb./master case
weight 10 lb./master case - 1.4 cubic feet 1.7 cubic feet
15
Case 1:20-cv-04861 Document 1-3 W
Filed 06/24/20 Page 5 of 24
NE GRIP HES
SOFT WIRE BRUS
WIRE BRUSHES AND ACCESSORIES
SB319 SOFT GRIP

CARBON STEEL WIRE
BRUSH w/SCRAPER (12319)
3 x 19 row, long narrow structural foam handle w/finger grips, solvent
proof, hardened & ground steel scraper, 14" L, carded
SB319/SS SOFT GRIP STAINLESS STEEL WIRE BRUSH (12219)
Same as above, w/scraper end, carded
SB319/BB SOFT GRIP BRASS WIRE BRUSH (12229)
1/card - 6/box - 36/master case - weight 19 lb./case - 1.4 cubic feet
SB411 SOFT GRIP

CARBON STEEL WIRE
4 x 11 row, H/D brush structural foam handle w/finger grips, solvent
NEW T GRIP
weight 21 lb./case - 1.0 cubic feet
SOF BRUSHES SB416 SOFT GRIP

MINI CARBON STEEL SHOE
HANDLE WIRE BRUSH (12416)
AMB 4 x 16 row, shoe handle brush structural foam handle w/finger grips,
SOFT GRIP MINI BRUSH SET (13710) solvent proof, 10" L, carded
1 of each, nylon, brass, stainless steel, mini brushes for 1/card - 6/box - 36/master case
paint and corrosion removal, carded weight 18 lb./case - 1.0 cubic feet
1 set/card - 12 cards/clip strip - 1/clip strip/box - 12 clip strips/ master case
SB619 SOFT GRIP
CARBON STEEL H/D SCRUB
SP3 BRUSH STYLE WIRE BRUSH (12619)
ABRASIVE STRIPPING PADS (10035) 6 x 19 row, structural foam block, threaded
3/pak nylon mesh pads 3” x 5” for use with opening accepts mop stick, 7" L x 2 1/2" W, carded
or in place of chemical paint strippers, for 1/card - 6/box - 36/master case
corrosion removal, display box weight 24 lb./case - 1.2 cubic feet
1 - 3/pak/box - 20 pak/display carton
SB4D WIRE BRUSH MERCHANDISER (12324)
Refer to Page 29 S
G B R USHE
PIN
STRIP
GB SOFT GRIP NARROW NYLON
STRIPPER/GROUT BRUSH (12125)
SP3 Narrow handle, solvent proof, GB
nylon bristles, 7" L x 3/4" W, carded
DSHDISPOSABLE PAINT
REMOVER TOOL (08750) BB1 SOFT GRIP NARROW BRASS STRIPPER BRUSH (12126)
Solvent proof CELCON plastic for use DSH Narrow handle, solvent proof, brass bristles, 7" L x 3/4" W, carded
with paint-removing chemical strippers. 1/card - 10/box - 100/master case - weight 22 lb./case - 1.7 cubic feet
Scoops up residue for disposal, labelled
SB1 SOFT GRIP NARROW STAINLESS STRIPPER BRUSH (12127)
weight 11 lb./master case - .4 cubic feet Narrow handle, solvent proof, stainless steel bristles, 7" L x 3/4" W, carded
DSH40 (DISPLAY)
DISPOSABLE PAINT PBS SOFT GRIP WIDE NYLON
REMOVER TOOL (08750) STRIPPER BRUSH (12128)
Same as above, display box Wide handle, solvent proof, nylon bristles,
40/display box - 40/master case scraper end, 7" L x 1 1/4" W, carded PBS
weight 5 lb./master case - .7 cubic feet 1/card - 10/box - 100/master case
BB2 SOFT GRIP WIDE
RIP BRASS STRIPPER BRUSH (12129)
W S OFT G USH Wide handle, solvent proof, brass bristles,
NE CRUB B R scraper end, 7" L x 1 1/4" W, carded
S 1/card - 10/box - 100/master case
SBR SOFT GRIP SCRUB BRUSH (12140)
Structural foam block, crimped polypropylene SB2 SOFT GRIP WIDE STAINLESS
bristles, display box, labelled STRIPPER BRUSH (12130)
6/box - 36/master case Wide handle, solvent proof, stainless bristles
weight 18 lb./master case - 1.0 cubic feet scraper end, 7" L x 1 1/4" W, carded
BM6 STRIPPING BRUSH MERCHANDISER (12124)

Refer to Page 29
18
1255 Seabury Avenue, PO Box 777

Bronx, New York 10462 USA
Phone: 1-718-792-3636
Toll Free: 1-800-422-5592
Fax: 1-718-823-9640
sales@ allwaytools.com
www.allwaytools.com
SKU CAT05 30 / 1-05

Copyright 2005 — Allway Tools Inc.— all rights reserved.
Soft Grip Tools for Hard Hat Jobs

GRIP

OFT
S OUR
CONT
A PER
SCR BTM12
MERCHANDISER
ED (81915)
E NT Bucket tree floor rack holds
P AT 12 buckets
Free with orders of
12 or more buckets
file inside
handle to keep
blades at peak
sharpness
includes 6 hardened and ground stainless blades
in handy storage case, carded
1 set/card - 6/box - 36/master case - weight 21 lb./master case - 2.1 cubic feet

reveals, carded
weight 6 lb./master case - .5 cubic feet BR1
BUCKET RING
CSB2 CONTOUR BLADE (06620) (82250)
Stainless steel, for small flat and small concave Holds 1 bucket
molding, carded



CSB6 CONTOUR BLADE (06660) PSM53

Stainless steel, for round moldings, wood curtain MERCHANDISER (05300)
rods, door and window casings, carded Featuring Complete Paint,
Wallcovering, Drywall Tool Center
with Free Tool Tower
Contains 5 each: T15F, T15S, T30F,
BF3 HALF ROUND FILE T30S, T45, T100, RB1, PS1, BF1,
(06010) X11/4F, X11/4S, XCH1 1/4, X3F, X3S,
Stores inside CS handle X4F, X5F, X6F, XG1, TK10, LS3, PH,
w/magnet, carded 1B, 22B, 42B, F1, FE2, F4, UPS, WPS,
1/card - 10/box - 100/master case EBH, GT, GC, GP1, DSS, DJS,
weight 6 lb./master case - .8 cubic feet Contains 10 each: DS15, DS30, DS60,
K700, K130, K7B, TS10, T60, WT, GS,
GTS, WSB, RK4, RKB5, MC, MF,
SEB10, SNB
1/ box - including revolving pegboard
display 24" x 74" - weight 120 lb./ box
6.0 cubic feet
CS6
COUNTER DISPLAY
11
T GRIP
BRUSHES
SOFT OF
NEWCSRUB BRUS
H
GRIPES S
H ANDL SBR2
SOFT GRIP SCRUB BRUSH
(12142)
5" long structural foam block, cantelever
handle, crimped polypropylene bristles,
display box, labelled
PWB weight 11 lb./master case - .8 cubic feet
PASTE BRUSH (14030)
Soft Grip structural foam handle 6" wide, polypropylene
bristles, labelled SBR
SOFT GRIP SCRUB BRUSH (12140)
weight 32 lb./master case - 1.9 cubic feet 7" long structural foam block, crimped
polypropylene bristles, display box,
labelled
SWB weight 18 lb./master case - 1.0 cubic feet
WALLPAPER SMOOTHER (14040)
Soft Grip structural foam handle,
12" X 11/2" out, polypropylene bristles,
labelled
10/box
50/master case
1.9 cubic feet
SBR4
SOFT GRIP LONG 6 " HANDLE
VWB SCRUB BRUSH (12144)
VINYL SMOOTHER (14050) 12" long threaded to accept mop stick or
Soft Grip structural foam handle, extension handle, crimped polypropylene
12" X 3/4" out, polypropylene bristles, bristles, display box, labelled
labelled 6/box - 36/master case
10/box
50/master case
1.9 cubic feet
SWB VWB
SSB
SWIVEL SCRUB BRUSH
(12135)
7 1/2" H/D scrub brush with universal swivel to accept mop stick or
extension handle, crimped polypropylene bristles, carded
BMT weight 18 lb./master case - 1.21 cubic feet
6 1/2 "
MASONRY BRUSH (14035)
Natural tampico bristles, H/D structural
foam handle, labelled
BMTS
41/2 " MASONRY BRUSH (14036)
Natural Tampico bristles, fits inside a 1 gallon can,
labelled
BM6
MERCHANDISER
(12124)
Featuring all small
scratch brushes
Contains 5 each: GB, BB1,
SB1, PBS, BB2, SB2
1/ box - including wire rack
9" x 20"
weight 7 lb./ box
6 cubic feet
DB12
H/D DECK SCRUB BRUSH (12812)
12" long w/stiff polypropylene bristles,
threaded to accept mop stick or extension
pole, display box, labelled
20
EW SM5 5 GAL. SPIRAL MIXER (10053)

N All steel, for drywall mud, paint or cement,
etc., carded

All steel, for drywall mud, paint or cement,
etc., carded
SS36 Pole fits inside shield
36" x 9 " ALUMINUM SPRAY SHIELD weight 28 lb./master case - 1.0 cubic feet
for easy storage.
(10036)
Adjustable angle, acme threaded pole for
extension pole, includes 18” threaded pole,
labelled EZ CLEAN
weight 18 lb./master case - 1.8 cubic feet HM5 5 GAL.“HELIX” PAINT MIXER (10032)
polypropylene blade with H/D 5/16” hex shaft,
carded
BG7HD 1/card - 5/box - 25/master case
4 WAY BUCKET GRID 7" weight 29 lb./master case - 1.0 cubic feet
(17100)
2 gal. pails, labelled EZ CLEAN
24/box - weight 13 lb. - .5 cubic feet
BG9HD HM1 1 GAL. “HELIX” PAINT MIXER (10031)

4 WAY BUCKET GRID 9" polypropylene blade with H/D 1/4” hex shaft,
(17111)
carded

All steel,overall length 28", labelled
5/master case
BC BRUSH COMB (10012) weight 10 lb./box - .6 cubic feet
Hardwood handle, hardened steel pins, carded
PM 1 GAL. PAINT MIXER (10010)

Fits all electric drills, polypropylene blade
carded
EW 1/card - 10/box - 100/master case

N
W
NE
TB12 APM 5 GAL. ALUMINUM BLADE

14" NYLON TOOL BAG w/20 POCKETS (11008) HELIX MIXER, HEAVY DUTY (10033)
H/D ballistic nylon tool bag with 20 inside and outside pockets to hold Fits all electric drills, aluminum blade with
tools for any job, H/D metal frame and zipper, durable, labelled 5/16" hex shaft, for drywall mud or paint,
3/shelf pak - 3/master case carded
weight 6.5 lb./master case - .5 cubic feet 1/card - 5/box - 25/master case
22
1255 Seabury Avenue, PO Box 777 • Bronx, New York 10462 USA
Phone: 1-718-792-3636
Toll Free: 1-800-422-5592 • Fax: 1-718-823-9640
sales@ allwaytools.com www.allwaytools.com
SKU CAT08 30 / 4-08

Soft Grip Tools for Hard Hat Jobs

GRIP

O F T
S O UR
CONT A PER
S C R BTM12
MERCHANDISER
(81915)
TED
PAT E N Bucket tree floor rack holds
12 buckets
Free with orders of
12 or more buckets
file inside
handle to keep
blades at peak
sharpness

reveals, carded
weight 6 lb./master case - .5 cubic feet BR1
BUCKET RING
CSB2 CONTOUR BLADE (06620) (82250)
Stainless steel, for small flat and small concave Holds 1 bucket
molding, carded




Stainless steel, for round moldings, wood curtain MERCHANDISER (05300)
rods, door and window casings, carded Featuring Complete Paint,
Wallcovering, Drywall Tool Center
with Free Tool Tower
Contains 5 each: T15F, T15S, T30F,
BF3 HALF ROUND FILE T30S, T45, T100, RB1, PS1, BF1,
(06010) X11/4F, X11/4S, XCH1 1/4, X3F, X3S,
Stores inside CS handle X4F, X5F, X6F, XG1, TK10, LS3, PH,
w/magnet, carded 1B, 22B, 42B, F1, FE2, F4, UPS, WPS,
1/card - 10/box - 100/master case EBH, GT, GC, GP1, DSS, DJS,
weight 6 lb./master case - .8 cubic feet Contains 10 each: DS15, DS30, DS60,
K700, K130, K7B, TS10, T60, WT, GS,
GTS, WSB, RK4, RKB5, MC, MF,
SEB10, SNB
1/ box - including revolving pegboard
display 24" x 74" - weight 120 lb./ box
6.0 cubic feet
CS6
COUNTER DISPLAY
11
BRUSHES GRIP
SOFT NEW SOFT RUSH
B B
GRIPES SCRU
HANDL SBR2 SOFT GRIP SCRUB BRUSH
(12142)
PWB 5" long structural foam block, cantelever
PASTE BRUSH (14030) handle, crimped polypropylene bristles,
Soft Grip structural foam display box, labelled
handle 6" wide, polypropylene 6/box - 36/master case
bristles, 2 row thick, labelled weight 11 lb./master case - .8 cubic feet
weight 32 lb./master case - 1.9 cubic feet SBR
SOFT GRIP SCRUB BRUSH (12140)
SWB 7" long structural foam block, crimped
WALLPAPER SMOOTHER (14040) polypropylene bristles, display box, labelled
Soft Grip structural foam handle, 6/box - 36/master case
12" X 11/2" out, polypropylene bristles, weight 18 lb./master case - 1.0 cubic feet
labelled
weight 32 lb./master case - 1.9 cubic feet SBR4
VWB SCRUB BRUSH (12144)
VINYL SMOOTHER (14050) 12" long threaded to accept mop
Soft Grip structural foam handle, stick or extension handle,
12" X 3/4" out, polypropylene bristles, crimped polypropylene bristles,
labelled display box, labelled
10/box - 50/master case 6/box - 36/master case
weight 32 lb./master case - 1.9 cubic feet weight 21 lb./master case - 1.4 cubic feet
SWB VWB NEW

SBR6 H/D SCRUB BRUSH
(12823)
Crimped polypropylene bristles,
pole socket - 6 x 19 rows,
BMTS 7”L x 21/2”W block, soft grip, labelled
41/2 " MASONRY BRUSH (14036) 1/card - 6/box - 36/master case
Natural Tampico bristles, 5 row thick, fits inside a 1 weight 22 lb./master case
gallon can, labelled 1.2 cubic feet
BMT SSB
6 1/2 " MASONRY BRUSH (14035) SWIVEL SCRUB BRUSH
Natural tampico bristles, 5 row thick, H/D (12135)
structural foam handle, labelled 7 1/2" H/D scrub brush with universal swivel to accept mop stick or
weight 25 lb./master case - 1.1 cubic feet 5/box - 25/master case
DB12
H/D DECK SCRUB BRUSH (12812)
12" long w/stiff polypropylene bristles,
threaded to accept mop stick or extension
pole, display box, labelled
BM6
MERCHANDISER
NEW (12124)
Featuring all small
TGB TIN-HANDLE GLUE BRUSH
scratch brushes
(12300)
Contains 5 each: GB, BB1,
5 disposable brushes, use for applying glue, SB1, PBS, BB2, SB2
flux, grease, etc. 1/ box - including wire rack
5/pack - 10 packs/box 9" x 20"
100 packs/master case weight 7 lb./ box
6 cubic feet
20
EW SM5 5 GAL. SPIRAL MIXER (10053)

N All steel, for drywall mud, paint or cement,
etc., carded

etc., carded
36" x 9 " ALUMINUM SPRAY SHIELD weight 28 lb./master case - 1.0 cubic feet
for easy storage.
(10036)
extension pole, includes 18” threaded pole, EZ CLEAN
labelled
6/box - 6/master case HM5 5 GAL.“HELIX” PAINT MIXER (10032)
weight 18 lb./master case - 1.8 cubic feet Fastest Mixer Of Its Kind. Fits all electric drills,
polypropylene blade with H/D 5/16” hex shaft,
carded
BG7HD weight 29 lb./master case - 1.0 cubic feet
(17100)
Extra rigid 4 way bucket grid for EZ CLEAN
24/box - weight 13 lb. - .5 cubic feet HM1 1 GAL. “HELIX” PAINT MIXER (10031)
BG9HD polypropylene blade with H/D 1/4” hex shaft,
4 WAY BUCKET GRID 9" carded
(17111)

All steel,overall length 28", labelled
5/master case
weight 10 lb./box - .6 cubic feet

PM 1 GAL. PAINT MIXER (10010)
carded
W
NE
MARK FELT TIP MARKER SET

(11305)
Contains 2 - chisel tip, permanent felt
markers - also included is a 9mm snap
TB12 knife as a bonus, carded
14" NYLON TOOL BAG w/20 POCKETS (11008) 1 set/card - 10 cards/box
H/D ballistic nylon tool bag with 20 inside and outside pockets to hold 100 cards/master case
tools for any job, H/D metal frame and zipper, durable, labelled weight 10 lb./master case - .9 cubic feet
3/shelf pak - 3/master case
weight 6.5 lb./master case - .5 cubic feet
22
ALLWAY TOOLS, INC.

1255 Seabury Avenue, P.O. Box 777, Bronx, New York 10462 USA
Phone: 1-718-792-3636 • Toll Free: 1-800-422-5592 • Fax: 1-718-823-9640
sales@allwaytools.com www.allwaytools.com
SKU CAT2012 30 / 4-12

Innovation
Since 1935
Better-Faster-Easier
www.allwaytools.com
F T GRIP

S O R
OU BTM12 MERCHANDISER (81915)
CONT PER
Bucket tree floor rack holds 12 buckets
SCRA
Free with orders of
12 or more buckets
BR1 BUCKET RING

(82250)
Holds 1 bucket
file inside
handle to keep
blades at peak
CS6 CONTOUR SCRAPER SET (06600) sharpness

reveals, carded

Stainless steel, for small flat and small concave
molding, carded

Stainless steel, for medium and large rods, MERCHANDISER (05300)
dowels and convex moldings, balusters, carded Featuring Complete Paint, Wallcovering,
Drywall Tool Center with Free Tool Tower
CSB4 CONTOUR BLADE (06640) Contains 5 each: T15F, T15S, T30F, T30S, T45,
Stainless steel, for flat work and large concave T100, RB1, PS1, BF1, X11/4F, X11/4S, XCH1 1/4,
moldings, crown moldings and chair rails, carded X3F, X3S, X4F, X5F, X6F, XG1, TK10, LS3, PH,
1B, 22B, 42B, F1, FE2, F4, UPS, WPS, EBH, GT,
CSB5 CONTOUR BLADE (06650) GC, GP1, DSS, DJS
Stainless steel, for sharp indented moldings and Contains 10 each: DS15, DS30, DS60, K700,
concave moldings, pilasters, mantles, carded K130, K7B, TS10, T60, WT, GS, GTS, WSB, RK4,
RKB5, MC, MF, SEB10, SNB
CSB6 CONTOUR BLADE (06660) 1/ box - including revolving pegboard
Stainless steel, for round moldings, wood curtain display 24" x 74" - weight 120 lb./ box
rods, door and window casings, carded 6.0 cubic feet
1/card - 10/box - 100/master case - weight 6 lb./master case - .5 cubic feet
WPS
WALLCOVERING AND FLOORING
STRIPPER (07200)
New snap off blade guard and new soft-grip
handle with blade storage. Locks and unlocks
with just a twist of the wrist. 4 inch wide
blade, 12 inch long handle, carded NOW!
1/card - 5/box LIGHTER,
50/master case STRONGER,
weight 24 lb./ master case ALUMINUM
2.8 cubic feet
HEAD
1/4 turn
to unlock 1/4 turn to GREAT
the blade
for changing
securely lock
the blade in
MULTI-
or storage. place. PURPOSE
SCRAPER
CS6 WPSZ 4 INCH WIDE,

COUNTER DISPLAY WALLCOVERING STRIPPER, (07255)
ZINC HEAD, 12 inch tubular steel shaft, w/ soft
grip and blade guard, carded
GSK3 SCRAPER WPSZ- L CD 4 INCH WIDE,

COMBO PAK (07470), WALLCOVERING STRIPPER, (81690)
Contains: SGS, GTS, WSB and ZINC HEAD, 21 inch tubular steel shaft, w/ soft
SEB5, carded grip and blade guard, carded
blade storage
1 set/card - 12 cards/box 1/card - 10/box
12 cards/master case weight 20 lb./ master case - 1.2 cubic feet
weight 10 lb.
master case - 0.8 cubic feet
FOR REPLACEMENT BLADES
Refer to Pages 2 & 3
11
SIVE BLE L
PUTTY KNIVES, WALL SCRAPERS & TAPE KNIVES EXCLU E A K A
UNBR ALL STEE
TG1 5-IN-1 PUTTY KNIFE

(08008)
All steel 5-IN-1 tool, labelled
TG1-25 (BUCKET) PW8 MERCHANDISER

5-IN-1 PUTTY KNIFE (08009) (08016)
All steel 5-IN-1 tool, labelled Featuring all steel
25/bucket - 1 bucket/box putty knives,
6 buckets/master case wall scrapers
weight 24 lb. and tape knives
master case - .5 cubic feet Contains 10 each:
TG1-25
T15F, T15S, TG1,
T30F, T30S, T45, T60, T100
1/ box - including wire rack - 16" x 21"
weight 21 lb./ box - 1.2 cubic feet
T15F 11/2" FLEXIBLE PUTTY KNIFE (08001), labelled ENGTH

T15S 11/2" STIFF PUTTY KNIFE (08002), labelled SUPER STR OOF PLASTIC
R
1/card - 10/box - 100/master case SOLVENT P
weight 16 lb./master case - .4 cubic feet DS-3PK MULTI-PAK/3 DISPOSABLE TOOLS (08835)
Contains 1 each: DS15, DS30, DS60, solvent proof CELCON
plastic putty knives, carded
1 set/card - 10 cards/box - 50 cards/master case DS-3PK
DS-3PKL 3 PAK (08838) Same as above. Made of

polypropylene, contains 1 1/2”, 3”, 6” tools, carded
T30F 3" FLEXIBLE WALL SCRAPER (08003), labelled DS-3PKS 3 PAK (08834) Same as above. Made of
T30S 3" STIFF PUTTY KNIFE (08004), labelled polypropylene, contains 1 1/2”, 2”, 3” tools, carded
1/card - 10/box - 100/master case 1/card - 12/box - 144/master case
weight 24 lb./master case - .7 cubic feet weight 16 lb./master case - .8 cubic feet
DS15 (BUCKET) PLASTIC PUTTY KNIFE (08115)

11/2" CELCON plastic putty knives, solvent proof, labelled
25/bucket - 1 bucket/box - 12 buckets/master case
DS20 (BUCKET) PLASTIC PUTTY KNIFE (08120)
2" CELCON plastic putty knives, solvent proof, labelled DS-30
DS30 (BUCKET) PLASTIC WALL SCRAPER (08113)
T45 41/2" FLEXIBLE TAPE KNIFE (08005), labelled 3" CELCON plastic wall scraper, solvent proof, labelled DS30
1/card - 10/box - 100/master case 25/bucket - 1 bucket/box - 12 buckets/master case
weight 29 lb./ master case - .9 cubic feet weight 24 lb./master case - 2.9 cubic feet
T60 6" FLEXIBLE TAPE KNIFE (08006), labelled DS30U-10 PLASTIC U-NOTCH SPREADER (08134)
3" CELCON plastic u-notch adhesive spreader, solvent proof, labelled
1/card - 10/box - 100/master case 10/box - 100/master case - weight 8.20 lb./master case - .6 cubic feet
DS30V (BUCKET) PLASTIC VEE-NOTCH SPREADER (08133)
3" CELCON plastic vee-notch adhesive spreader,
solvent proof, labelled
DS40 (BUCKET) PLASTIC WALL SCRAPER (08140)
4" CELCON plastic wall scraper, solvent proof, labelled
T60 DS60
DS60 (BUCKET) PLASTIC TAPE KNIFE (08600)
6" CELCON plastic tape knife, solvent proof, labelled
DSH DISPOSABLE PAINT REMOVER TOOL (08750)

Solvent proof CELCON plastic for use with paint-removing
chemical strippers. Scoops up residue for disposal, labelled
T100 10" FLEXIBLE TAPE KNIFE 10/box - 100/master case - weight 11 lb./master case - .4 cubic feet
(08007), labelled DSH
EW
weight 20 lb./master case - 1.3 cubic feet SD3
N SD3 DETAIL SCRAPER SET (08213)
Solvent proof, engineering grade plastic putty
knife set, 5/16”, 5/8”, 15/16”, 3 piece set, labelled
weight 3 lb. /master case - .4 cubic feet
12
P
T GRI SH
BRUSHES
GRIP OF
SOF TDLES NEWCSRUB B R U
HAN S
SBR2 SOFT GRIP SCRUB BRUSH
NEW (12142)
5" long structural foam block, cantelever
WWB handle, crimped polypropylene bristles,
WINDOW WASH/ VEHICLE BRUSH display box, labelled
(12145) 6/box - 36/master case
4 1/2" round window/vehicle brush w/soft weight 11 lb./master case - .8 cubic feet
grip for hand use and 3 pole sockets (2
threaded and 1 tapered) for use with SBR
extension poles. Polypropylene bristles, SOFT GRIP SCRUB BRUSH (12140)
FLOW-THROUGH capable, carded 7" long structural foam block, crimped
3/box - 12/master case polypropylene bristles, display box, labelled
weight 12 lb./master case - 1.0 cubic feet 6/box - 36/master case
SBR4
SCRUB BRUSH (12144)
12" long threaded to accept mop
stick or extension handle,
crimped polypropylene bristles,
BMTS 41/2 " MASONRY BRUSH (14036) display box, labelled
Natural Tampico bristles, 5 row thick, fits inside a 1 6/box - 36/master case
gallon can, labelled weight 21 lb./master case - 1.4 cubic feet
NEW
SBR6 H/D SCRUB BRUSH
(12823)
Crimped polypropylene bristles,
pole socket - 6 x 19 rows,
7”L x 21/2”W block, soft grip, labelled
BMT 6 1/2 "
MASONRY BRUSH (14035) 1.2 cubic feet
Natural tampico bristles, 5 row thick, H/D structural
foam handle, labelled
SSB
weight 25 lb./master case - 1.1 cubic feet SWIVEL SCRUB BRUSH
(12135)
7 1/2" H/D scrub brush with universal swivel to accept mop stick or
DB12 H/D DECK SCRUB BRUSH (12812) 5/box - 25/master case
12" long w/stiff polypropylene bristles, threaded to accept weight 18 lb./master case - 1.21 cubic feet
mop stick or extension pole,
display box, labelled
.6 cubic feet
NEW BM6
TGB TIN-HANDLE GLUE BRUSH (12300) MERCHANDISER
5 disposable brushes, use for applying glue, (12124)
flux, grease, etc., bagged Featuring all small
5/bag - 10 bag/box - 100 bags/master case scratch brushes
weight 9 lb./master case - .6 cubic feet Contains 5 each: GB, BB1,
SB1, PBS, BB2, SB2
TGB20 TIN-HANDLE GLUE BRUSH (12301) 1/ box - including wire rack
Box of 20 tin handle glue brushes, boxed 9" x 20"
20/pak - 10 box - 72/master case weight 7 lb./ box
weight 19 lb./master case - .9 cubic feet 6 cubic feet
20
NEW FT GRIP HES
WIRE BRUSHES
SO BRUS
WIRE
SB319 SOFT GRIP
CARBON STEEL WIRE
3 x 19 row, long narrow structural foam handle w/finger grips, solvent
SB319/SS SOFT GRIP STAINLESS STEEL WIRE BRUSH (12219)
SB319/BB SOFT GRIP BRASS WIRE BRUSH (12229)
SB411 SOFT GRIP

CARBON STEEL WIRE
4 x 11 row, H/D brush structural foam handle w/finger grips, solvent
SB4D
MERCHANDISER (12324)
Featuring all Large scratch brushes
SB416 SOFT GRIP Contains 6 each: SB319, SB411,
CARBON STEEL SHOE SB416, SB619
HANDLE WIRE BRUSH (12416) 1/ box - including wire rack 16" x 16"
4 x 16 row, shoe handle brush structural foam handle w/finger grips, weight 14 lb./ box - 1.3 cubic feet
solvent proof, 10" L, carded
NEW GRIP
SOFT BRUSHES
SB619 SOFT GRIP CARBON STEEL MINI
H/D SCRUB BRUSH STYLE WIRE BRUSH
(12619) 6 x 19 row, structural foam block, AMB SOFT GRIP MINI BRUSH SET (13710)
threaded opening accepts mop stick, 7" L x 2 1/2" W, carded 1 of each, nylon, brass, stainless steel, mini brushes
1/card - 6/box - 36/master case for paint and corrosion removal, carded
weight 24 lb./case - 1.2 cubic feet 1 set/card - 12 cards/clip strip
SB619SS SOFT GRIP, STAINLESS STEEL, H/D SCRUB BRUSH 1/clip strip/box - weight 2 lb./master case - .35 cubic feet
STYLE WIRE BRUSH (12629) Same as above, labelled NMB3 3 PACK, SOFT GRIP,
SB4D WIRE BRUSH MERCHANDISER (12324) NYLON MINI BRUSH SET (13719), carded
1 set/card - 72 cards/box - weight 12 lb.- .95 cubic feet
HES
I N G BRUS BMB3 3 PACK, SOFT GRIP,
P
STRIP
BRASS MINI BRUSH SET (13715), carded
1 set/card - 72 cards/box - weight 12 lb.- .95 cubic feet
GB SOFT GRIP NARROW NYLON SMB3 3 PACK, SOFT GRIP,

STRIPPER/GROUT BRUSH (12125) STAINLESS MINI BRUSH SET (13717), carded
Narrow handle, solvent proof, GB 1 set/card - 72 cards/box - weight 12 lb.- .95 cubic feet
nylon bristles, 7" L x 3/4" W, carded
BB1 SOFT GRIP NARROW BRASS STRIPPER BRUSH (12126)
Narrow handle, solvent proof, brass bristles, 7" L x 3/4" W, carded
SB1 SOFT GRIP NARROW STAINLESS STRIPPER BRUSH (12127) NMB (BUCKET)
Narrow handle, solvent proof, stainless steel bristles, 7" L x 3/4" W, carded
SOFT GRIP NYLON
MINI-BRUSH (13712)
uncarded
PBS SOFT GRIP WIDE NYLON 25/bucket - 1 bucket/box
STRIPPER BRUSH (12128) 6 buckets/master case
Wide handle, solvent proof, nylon bristles,
scraper end, 7" L x 1 1/4" W, carded PBS
1/card - 10/box - 100/master case BMB (BUCKET)
weight 26 lb./case - 1.9 cubic feet SOFT GRIP BRASS
BB2 SOFT GRIP WIDE MINI-BRUSH (13714)
BRASS STRIPPER BRUSH (12129) uncarded
Wide handle, solvent proof, brass bristles, scraper end,
7" L x 1 1/4" W, carded
1/card - 10/box - 100/master case SMB (BUCKET)
weight 26 lb./case - 1.9 cubic feet SOFT GRIP STAINLESS STEEL
SB2 SOFT GRIP WIDE STAINLESS MINI-BRUSH (13716)
STRIPPER BRUSH (12130) uncarded
Wide handle, solvent proof, stainless bristles scraper end, 25/bucket - 1 bucket/box - 6 buckets/master case
7" L x 1 1/4" W, carded weight 30 lb./master case - 2.9 cubic feet
➞ weight 26 lb./case - 1.9 cubic feet
BM6 STRIPPING BRUSH MERCHANDISER (12124) 21

PAINTING ACCESSORIES AND SAWS SD41 4-IN-1 COMPOSITE,
SHOCKPROOF SCREWDRIVER (18041)
Fiberglass reinforced nylon construction,
electrically safe, UL tested 2000 volts. Rare
earth magnet retains both bits and screws,
includes 2 phillips and 2 slotted standard
power bits, all are retained in handle, carded
1/card - 10/display - 50/master case
Weight 12 lb./master case - .9 cubic feet
HSN
THE INAL
ORIG D Y SAW
H A N
NOW WITH SOFT GRIP HANDLE
COUNTER
DISPLAY
HS HANDY SAW (04005)
With 1 metal cutting blade, pistol grip keyhole
PB1 PRY BAR (10004) saw w/ 71/2" blade, for metal cutting. Blade
Hardened and ground high carbon steel, removes mounts in 4 positions - cuts flush, uncarded
nails, moldings, etc., 11” long, carded 10/box - 100/master case
1/card - 10/box - 100/master case weight 23 lb./master case - 1.0 cubic feet
HSN HANDY SAW NEST (04001)
With 2 - 71/2" blades (1 - 24 TPI and 1 - 10 TPI) for metal
and wood cutting, carded
EBH HBA HANDY BLADE ASSORTMENT (04003)

EXTENSION BRUSH HOLDER (11090) Replacement blade set for Allway Handy Saw and similar saws
Handy, adjustable angle extender Contains: 1 HB10T Wood Cutting Blade
for brushes and tools, acme threaded for 1 HB24T Metal Cutting Blade, carded
extension pole, carded 2 blades/card - 10 cards/box - 100/master case
1/card - 10/box - 50/master case weight 8 lb./master case - .3 cubic feet
HB10T REPLACEMENT BLADE 10 TPI FOR WOOD (04006)
W 1.9 cubic feet
NE HB24T REPLACEMENT BLADE 24 TPI FOR METAL (04008)
Fits Allway HS and similar saws, 71/2" long, uncarded
10/box (uncarded) - 100/master case
RIT
IDE G ES
BC5 5 IN 1 PAINTER”S TOOL (10112) CARB SAW BLAD
Can rim cleaner, dual roller cleaner, brush comb, HA C K
can cover lifter, carded
RS10 10" ROD SAW BLADE (03050)

Cuts glass, tile, marble, cast iron, etc., carded
weight 12 lb./master case - .9 cubic feet CH12 12 " HACKSAW BLADE (03080)
Cuts glass, tile, marble, cast iron, etc., carded
26
EW
etc., carded
N 1/card - 5/box - 5/master case

etc., carded
36" x 9 " ALUMINUM SPRAY SHIELD for easy storage.
(10036) EZ CLEAN
extension pole, includes 18” threaded pole, HM5 5 GAL.“HELIX” PAINT MIXER (10032)
labelled Fastest Mixer Of Its Kind. Fits all electric drills,
6/box - 6/master case polypropylene blade with H/D 5/16” hex shaft,
weight 18 lb./master case - 1.8 cubic feet carded
BG7HD
4 WAY BUCKET GRID 7" (17100)
Extra rigid 4 way bucket grid for EZ CLEAN
24/box - weight 13 lb. - .5 cubic feet HM1 1 GAL. “HELIX” PAINT MIXER (10031)
BG9HD polypropylene blade with H/D 1/4” hex shaft,
4 WAY BUCKET GRID 9" (17111) carded
Extra rigid 4 way bucket grid for 1/card - 10/box - 50/master case
5 gal. pails, labelled weight 24 lb./master case - 1.0 cubic feet
W
NE HDM H/D MUD MIXER (10030)
PC1 All steel,overall length 28", labelled
EZ PAINT CUP (10033) 5/master case
1 QT. ramp/mini roller, magnetic weight 10 lb./box - .6 cubic feet
brush holder, pouring spout,
makes painting neater and easier,
labelled
weight 3.5 lb./master case - .8 cubic feet
W PM 1 GAL. PAINT MIXER (10010)

NE Fits all electric drills, polypropylene blade
carded
PC2 1/card - 10/box - 100/master case
EZ PAINT PAIL (10039) weight 20 lb./master case - .8 cubic feet
1 1/2 QT. soft grip handle,
magnetic brush holder,nestable
for compact store display,
W
NE
can use disposable liners
(PCL6 - PKD 6/pak) for quick
color change and easy clean-up,
labelled
63.5 lb./master case - 1.0 cubic feet
Nest and stack for compact

store display.
PT10
PCL6 PAINTERS TRIPODS (10043)
DISPOSABLE LINERS FOR PC2 PAINT Non stick points allow painting one side of project and, without wait-
PAILS (10041) ing to dry, turn over and paint other side. No waiting, carded
Allows quick and easy color change and
10/card - 5 cards/box - 36/master case
clean-up. Fits most similar pails now on the weight 10 lb./master case - 1.25 cubic feet
market, labelled
6/pack - 8 packs/box - 48 packs/master case
16 lb./master case - 2.5 cubic feet
27
ALLWAY TOOLS, INC.

1255 Seabury Avenue, P.O. Box 777, Bronx, New York 10462 USA
Phone: 1-718-792-3636 • Toll Free: 1-800-422-5592 • Fax: 1-718-823-9640
sales@allwaytools.com www.allwaytools.com
SKU CAT2017 20 / 8-17

EXHIBIT 3
EXHIBIT 4
EXHIBIT 5
Allway Tools Series Allway 10032 HM5 5 Gallon Helix Paint Mixer, Red - Hand Mixers - Amazon.com
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Tools & Home Improvement › Paint, Wall Treatments & Supplies › Paint & Primer › Interior & Exterior House Paint
Allway Tools Series Allway 10032 HM5 5 $12.99

Gallon Helix Paint Mixer, Red
by Allway Tools
& FREE Shipping
187 ratings | 16 answered questions
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ION TOOL Paint and ION TOOL Paint Mixer, 13" Paint & Drywall Mud DEWALT Drywall Mud and Add to Wedding Registry
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Mortar Mixer 15in length, 2.5in mixing Mixer - LEVEL5 | 13" Paint Mixer | 13" Shaft and
67 head Shaft, 2" Head | Pro- 2" Head | DXTT-2-293
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From the manufacturer
https://www.amazon.com/Allway-Tool-10032-Gallon-Helix/dp/B000I210I6/ref=sr_1_2?dchild=1&keywords=allway+paint+mixer&qid=1589126621&sr=8-2[5/10/2020 12:06:02 PM]

Allway Tool Series Allway 10031 HM1 1

Gallon"Helix" Paint Mixer Silver
EZ Clean paint mixer fits all electric drills, polypropylene blade with H/D
1/4” hex shaft, carded.
Read more
Product description
HM5 5G HELIX PAINT MIXER
Product information
Technical Details Additional Information
ASIN B000I210I6
Part Number 10032
Customer Reviews 187 ratings
Item Weight 7.2 ounces
4.7 out of 5 stars
Product Dimensions 3.2 x 18 x 3.5 inches

Best Sellers Rank #5,090 in Tools & Home Improvement
(See Top 100 in Tools & Home
Item model number 10032
Improvement)
Size 5 Gallon #22 in Interior & Exterior House Paint
Color Red Shipping Weight 7.2 ounces (View shipping rates and
policies)
Item Package Quantity 1
Date First Available March 4, 2013
Certification Not Applicable
Included Components Painting Supplies, Paint & Stains,

house-paint
Feedback
Batteries Included? No
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Batteries Required? No support?
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4.7 out of 5
187 customer ratings
5 star 82%
4 star 9%
3 star 5%
2 star 2%
1 star 2% See all customer images
How does Amazon calculate star ratings?

TopReviews
Top Reviews
Gary R Zarback
Great for mixing chemicals together in backpack sprayer

Reviewed in the United States on June 23, 2018
Verified Purchase
I purchased this for mixing up my herbicide chemical mix for my 4-gallon backpack sprayers. I didn't really know
what to expect, but wow! This thing is incredibly good at mixing liquids, creating a violent high-speed torrent of
swirling water yet not causing much splashing or sloshing. It works far better than I hoped.
I'mRead
usingmore
a cheap ryobi 18v drill on this and it's crazy how well it mixes.
7 people found this helpful
Helpful Comment Report abuse
Mike Anderson
Beer making too!

Reviewed in the United States on March 10, 2019
Verified Purchase
I own two of these. One for paint and one for beer. Best way to mix home brew, 2min and I can mix powder or
liquid malt. Would work for any any mixing. I would not use it for concrete or mortar as the plastic is soft.
For pair more

Read it works on both 1 and 5 gallon buckets.
Jeremy Buck
I thought the plastic wings would be easier to clean ...

Verified Purchase
I thought the plastic wings would be easier to clean but they have a rough texture - its difficult to get dried paint
off (but flakes always make it into my pain bucket). The metal ones are only a bit more at the hardware store and
I would
Read go with one of them next time
more

Customer TOP 1000 REVIEWER VINE VOICE
Thorough job mixing old 5 gallon bucket of paint - cleaned easily

Verified Purchase
This paint mixer worked perfectly. I chose the 5 gallon size and it fit my 5 gallon bucket of paint with room to
spare. The end attached easily to my drill. It did a great job mixing the paint. My bucket was pretty old and had
settled long ago. It mixed smoothly without any issues. The mixer was very easy to rinse clean and store for next
time. I was
Read a little concerned due to the budget price, but it worked out very well.
more
Alex S
Does a good job mixing joint compound with less air

Reviewed in the United States on April 2, 2019
Verified Purchase
Does a good job mixing joint compound, though a paddle might reduce needing to move the drill around. The
plastic
Readtip also avoids scraping off plastic that might clog spray tips.
more
Kindle Customer
Great tool, work perfectly

Reviewed in the United States on February 13, 2019
Verified Purchase
Bought one each for 1 gallon and 5 gallon use and have used them multiple times while preparing my house for
sale. Easy to use and clean up is quick and painless. Well constructed and should last a long time.
I have used these for textured ceiling pain and sheetrock mud as well. no problems.
I'dRead
buy them
moreagain.
Roadside Rick
Greatest thing for paint only *

Reviewed in the United States on September 1, 2018
Verified Purchase
Mixes a 5 gallon bucket of paint fast! Makes a whirlpool without a mess. It durable plastic and won't chip off
pieces of the bucket like the metal ones can and that just makes your job a lot easier and worry free pluss it
don't
Readrustmore
or have any paint or other materials to chip off into your mix. Great product!
Don
Terrific Value
Reviewed in the United States on November 7, 2019

Verified Purchase
This particular paddle really mixes up whatever is in a 5gal bucket! Be careful when you first use it. Start at a
slow speed first then increase the speed as you get used to it. The depth in the bucket makes a difference too.
Will fit a more
Read 3/8in drill or larger fine. Was easy to clean off water based paint.
See all reviews from the United States
Top international reviews
Robert
just what i expected

Reviewed in Canada on July 21, 2019
Verified Purchase
fast delivery
Read more,good price, great mixer.
Helpful
Mark this review as helpful BUTTON Report abuse
Amazon Customer
one of the best.

Reviewed in Canada on July 14, 2019
Verified Purchase
Perfect.
Read more
Helpful
Kindle Customer
works well
Reviewed in Canada on January 6, 2020
Verified Purchase
works
Readwell
more
Helpful
Sylvain Ricard
Good product
Reviewed in Canada on September 20, 2018
Verified Purchase
Vert
Readgood mixer that i use for epoxy.
more
One person found this helpful
Helpful
You've read the top international reviews

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Allway Tools Soft Grip Contour Scraper Set with 6 Blades - Power Saw Blades - Amazon.com
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Tools & Home Improvement › Paint, Wall Treatments & Supplies › Painting Supplies & Tools › Putty Knives
Allway Tools Soft Grip $13.97

Contour Scraper Set with
6 Blades FREE Shipping on orders over
by Allway Tools $25.00 shipped by Amazon or get
147 ratings Fast, Free Shipping with Amazon
| 5 answered questions Prime & FREE Returns
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Submit Submit Item Weight: 8.8 lb

Country of Origin: United States
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Brand name: AllwayTools
Item Dimensions: 1.5"L x 5.75"W x
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10.25"H
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WORKPRO 24-Piece Putty Knife Set 3-Pack, DFM Blue Curved Cabinet WEKOIL Mini Plastic
Oscillating Accessory Kit, Putty Knife 2 Inch 3 Inch 5 Scraper Card Set Razor Blade Scraper High
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Mixed Multitool Saw Inch Drywall Taping Knife 93 Visibility Bright Yellow
Blades for Sanding,... Knive... $16.97 Window Scrape...
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https://www.amazon.com/...ades/dp/B000BQMZ9C/ref=sr_1_1?crid=3LOY55SYO7LFD&dchild=1&keywords=allway+contour+scraper&qid=1589126379&sprefix=allway+cont%2Caps%2C151&sr=8-1[5/10/2020 12:03:47 PM]

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Dumond Chemicals, Inc. Dumond Chemicals, Inc.

3332 Smart Strip 3301 Smart Strip
Advanced Paint Remover, Advanced Paint Remover,
1 Quart 1 Gallon,White
265 161
#1 Best Seller in Paint $47.19
Strippers
$15.43
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3332 Smart Strip
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1 Quart
265
#1 Best Seller in Paint
Strippers
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This item Allway Tools Soft Grip Red Devil 3010 1" Single-Edge HYDE 10540 Paint Scraper, Warner ProGrip 5-in 1 Stiff
Contour Scraper Set with 6 Paint Scraper Silver Painters Tool, American
Blades Craftsman, 10971
Add to Cart
Submit Add to Cart
Submit Add to Cart
Submit Add to Cart
Submit
Customer Rating (147) (111) (24) (193)
Price $
13 97 $
640 $
11 35 $
710
Sold By Amazon.com EXALTED Amazon.com Amazon.com

Item Dimensions 1.50 x 5.75 x 10.25 inches 0.94 x 2.88 x 8.88 inches 8.00 x 7.00 x 3.00 inches 1.00 x 2.25 x 8.13 inches
Product description
Product Description
Master Painter, Contour Scraper Kit, Includes Soft Grip Handle & 6 Different Contour Blades, Half Round Blade File Inside The Handle, Plus A Handy Hinged, Blade Holding
Package.
From the Manufacturer

This soft grip contour scraper kit includes soft grip handle and 6 hardened and ground stainless different contour blades. Half round blade file inside the handle. Available in
handy storage case. Comes in carded pack.
Product information
Technical Details Additional Information
ASIN B000BQMZ9C
Part Number CS6
Customer Reviews 147 ratings
Item Weight 8.8 ounces
4.3 out of 5 stars
Product Dimensions 1.5 x 5.8 x 10.2 inches
Best Sellers Rank #22,328 in Tools & Home
Improvement (See Top 100 in Tools
Item model number CS6
& Home Improvement)
Color .... #37 in Putty Knives
Item Package Quantity 1 Shipping Weight 9.6 ounces (View shipping rates and
policies)
Included Components ....
Domestic Shipping Item can be shipped within U.S.
Batteries Included? No
International Shipping This item can be shipped to select
Batteries Required? No countries outside of the U.S. Learn
More
Date First Available August 17, 2005
Feedback
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Videos
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4.3 out of 5
147 customer ratings
5 star 66%
4 star 15%
3 star 9%
2 star 5%
1 star 4% See all customer images
How does Amazon calculate star ratings?

TopReviews
Top Reviews
Michele T. Greene
It's a wonder for removing paint on 6 panel doors

Verified Purchase
I've been slaving over stripping a 6 panel steel door that had at least 8 coats of paint. The flat parts were tedious
but generally easy, but the panels themselves were a nightmare. I did some looking on the internet and found
someone recommended tackling the panels with contour scrapers. Holy crap, were they right! I just sailed
through the panels in less than a hour (it took about 6 hours for the rest of the door over 2 days). I only wish I
had known about this earlier. BTW, I ordered these Sunday night and they arrived on Monday afternoon via
Prime.
Read more
Larry in FL
Mostly a wonderful tool!

Reviewed in the United States on November 27, 2019
Verified Purchase
I really have a lot good to say about this thing, especially the broad choice of scraper shapes it offers. I first used
it on an old painted cafe chair, which had a lot of complex curvy places to get paint off of, including rungs, round
tapered legs, etc. I mostly used it with a heat gun, and the outcome was great!
I knocked it down a star because, having read other reviews, I did realize it probably could be damaged by a
heat gun, so I wrapped the blade holder in one layer of aluminum foil, shiny side out. The tool survived quite
well, despite the blade getting quite hot! maybe it all would have been fine without the foil, but the fear that the
plastic would melt warranted a star off it.
But mostly:
Read more Buy this!!!!
J. Trudeau
Not Optimal Where Woodwork Will Use Stain or Other Fine Finishes
Reviewed in the United States on May 7, 2020
Verified Purchase

As other's have mentioned the blades are not accurately ground and some blades will take a lot of effort to
prepare. Issues include nicks, very rough grind (seemingly by an unsteady hand in some cases, curved profile
blades are not cut with a uniform grind at the radius, making those two blades in need of a heavy regrind (see
image). The effort to correct these scraper profiles will take more time than is reasonable considering the initial
cost and health issues related to grinding stainless. If you are using these to remove rust or other
coarse/insignificant work maybe that's OK. I bought the scraper to work on urethane removal on finished wood
and these blades will not do if you are going to be using stain on the wood. More concerning than the quality
issues was the Amazon page. The advertisement/description bullets several items: When I see "Country of
Origin: United States", I expect to get a quality tool. Not the case here and so Item number 2: a quick look at the
reverse side of the packaging shows "China/Chine" printed on it (see pic). This is not commentary on China, as
the manufacturer they are just delivering the minimum product that they are contracted to deliver. It’s the importer
and reseller that need to assure quality. There is also a premium placed on weight when it comes to durable
hand tools such as this is expected to be, however this item is advertised as weighing 8.8lb. No one believes this
is going to be 8.8 lbs but if you consider 6 heavy duty stainless steel plates… well then it just seems like good -
ole fashioned quality tools. Don’t be fooled, I weighted this on my postal scale and it comes in at 9.2 oz… only a
Readthe
1/10th more
advertised weight. Speaking of packaging, the item was delivered with the bottom half of the
Rodney Pope
This is an awesome tool!

Reviewed in the United States on December 16, 2019
Verified Purchase
Very good concept and design! I would still like some other sized blade though. There are some types of curved
trim that are smaller than the tools provided, and it take a while to adjust the smallest curved blade to clean
those areas, but it works well after a little practice. It worked well for cleaning the panels of the 60 years old door
that had about 6 layers of paint, and it now is as good as new! Be careful when using with a heat gun though,
the handle is fabricated with hard rubber and, or plastic. I was lucky to notice the melting problem quick enough
that I did not ruin the tool, and it solidified back, so it was still in perfect shape. Though a little scarred.
R.Read more
Charles C. Dean
Sharpen before using

Verified Purchase
The best part of this is the handle and, perhaps, the shape of the blades. The blades are poorly machined: the
backs are not flat and the ground side is so crudely done and rough that it would severely scratch the wood
surface. I spent a good deal of time sharpening the edge of the convex round blade with a diamond sharpener to
get a razor smooth edge in order to remove the coarse grinding marks. It will be much tougher to do with the
concave shapes. As is, it might be tolerable for removing paint but the surface below will be badly scratched.
Read more
spiderman
Not the quality I was looking for.

Reviewed in the United States on April 17, 2013
Verified Purchase
While the over product is good, I was quite disappointed in the quality, therefore the quality control of the
manufacturer or the company selling the product. Every single blade had burrs on both sides. That in itself almost
got me to return the item. After de-burring each blade, which took 15 or 20 minutes, I had to also re-sharpen the
blades.
The package understandably states "caution, razor sharp blades". Not too truthfully stated. The instructions also
state that the file is stored in the handle. Yes it is. You need to use a screwdriver or a scratch awl to push it out
and hold out. It only comes out a half inch or so. It wont stay exposed unless you keep the tool(screwdriver etc.
in place. It will snap right back into the handle. Actually I found this more of an annoyance than a convenience.
Once I finally got everything cleaned, sharpened and figured out, the tool was performing as I expected. So it

isn't a total loss, just a bit of a pain in the ass to get it set up right. I'm really not sure if I would purchase another
item from this company. As they say, you get what you pay for. Again, once I got it set up, it worked as well as I
expected.
Read more
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Simon Alick Moore
Great grip, easy to use and great range of blades

Reviewed in the United Kingdom on May 8, 2020
Verified Purchase
This tool is so much better than most scrapers. It took ages to find a scraper that can do all that this one can.
The handle is made of easy-grip material, the working angle is just right and the blades provided are what you
need for flat surfaces as well as difficult to reach and molded finishings. Changing blades is simple if a little basic
- remove one large screw, change blade and replace screw. Blades come in a basic case that fell apart first day,
which is a bit disappointing. There is a simple flat and round file stored, and secured with a magnet, inside the
handle of the scrapper to use to sharpen blades. It’s too small really but it does the job. Scraper works fine with
heat gunmore
Read too but the tool head is made of plastic so don’t get too close with the gun.
Helpful
AmazonCustomer
Second hand?
Reviewed in the United Kingdom on April 21, 2020
Verified Purchase
Seems
Read like
morea decent tool. However package arrived opened so I don't think it's brand new hence 2 stars.
Helpful
SD
Nifty tool
Reviewed in the United Kingdom on April 30, 2020
Verified Purchase
I love this tool for scraping paint off with or without a heat gun.
SoRead
manymore
attachments for awkward areas. Makes the job really easy.
Helpful
Cristiano
Raschietto Allway
Reviewed in Italy on December 7, 2018
Verified Purchase
Uso questo prodotto da anni, sono un restauratore di infissi e portoni.. é molto resistente, efficace e facile da

usare ci vuole magari un po di manualità e qualche ora di lavoro per prendere confidenza con l'attrezzo.. saper
affilare
Read lemore
lame con la limetta e semplice e molto comoda.. insomma lo consiglio a tutti..
Helpful
Translate review to English
Juli
Reviewed in Canada on May 15, 2019

Verified Purchase
Belle
Read qualité
more
Helpful
Translate review to English
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EXHIBIT 6
EXHIBIT 7
EXHIBIT 8
EXHIBIT 9
1 Gal. “Helix” Paint Mixer, 1/card – HM1 | Allway Tools, Inc. http://allwaytools.com/product/1-gal-helix-paint-mixer-1card-hm1/
1 of 2 6/3/2020, 8:39 AM
2 of 2 6/3/2020, 8:39 AM
1 of 2 6/3/2020, 8:39 AM
2 of 2 6/3/2020, 8:39 AM
EXHIBIT 10

EXHIBIT 11
EXHIBIT 12
Long Handle Scrub Brush, labelled – SBR4 | Allway Tools, Inc. http://allwaytools.com/product/long-handle-scrub-brush-labelled-sbr4/
1 of 2 6/3/2020, 9:31 AM
Long Handle Scrub Brush, labelled – SBR4 | Allway Tools, Inc. http://allwaytools.com/product/long-handle-scrub-brush-labelled-sbr4/
2 of 2 6/3/2020, 9:31 AM
EXHIBIT 13

EXHIBIT 14
scrub brush | Search Results | Allway Tools, Inc. http://allwaytools.com/?s=scrub+brush&search_term=product
1 of 2 6/3/2020, 9:36 AM
scrub brush | Search Results | Allway Tools, Inc. http://allwaytools.com/?s=scrub+brush&search_term=product
2 of 2 6/3/2020, 9:36 AM
EXHIBIT 15

EXHIBIT 16
Soft Grip Contour Scraper Set with 6 Blades 1 Set-Card – CS6 | Allway ... http://allwaytools.com/product/soft-grip-contour-scraper-set-with-6-blad...
1 of 2 6/3/2020, 9:39 AM
Soft Grip Contour Scraper Set with 6 Blades 1 Set-Card – CS6 | Allway ... http://allwaytools.com/product/soft-grip-contour-scraper-set-with-6-blad...
2 of 2 6/3/2020, 9:39 AM
contour scraper | Search Results | Allway Tools, Inc. http://allwaytools.com/?s=contour+scraper&search_term=product
1 of 2 6/3/2020, 9:39 AM
contour scraper | Search Results | Allway Tools, Inc. http://allwaytools.com/?s=contour+scraper&search_term=product
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EXHIBIT 17
EXHIBIT 18
EXHIBIT 19
BRUSH http://olympiatools.com.vn/Dang-cap-nhat-1559715866
(http://olympiatools.com.vn/)
Search
(Home)
Home (Home) Catalogue (Catalogue) BRUSH (Dang-cap-nhat-1559715866)
(Dang-cap-nhat-1559895430)
HEAVY DUTY SCRUB BRUSH SMALL (DANG-CAP-NHAT-1559895430)
HEAVY DUTY SCRUB BRUSH LARGE (DANG-CAP-NHAT-1560247087)
Copyright © 2019 OLYMPIA TOOLS. All Rights Reserved.
1 of 1 6/3/2020, 10:00 AM
SCRAPER http://olympiatools.com.vn/Dang-cap-nhat-1559199012
(http://olympiatools.com.vn/)
Search
(Home)
Home (Home) Catalogue (Catalogue) SCRAPER (Dang-cap-nhat-1559199012)
CONTOUR SCRAPER WITH 6 STAINLESS-STEEL BLADES (DANG-CAP-NHAT-1559199132)
Copyright © 2019 OLYMPIA TOOLS. All Rights Reserved.
1 of 1 6/3/2020, 10:07 AM
EXHIBIT 20
EXHIBIT 21

EXHIBIT 22

EXHIBIT 23

Allway Tools v. Olympia Tools - Complaint

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Allway Tools v. Olympia Tools - Complaint

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Case 1:20-cv-04861 Document 1 Filed 06/24/20 Page 1 of 42

UNITED STATES DISTRICT COURT

ALLWAY TOOLS, INC.,

OLYMPIA TOOLS INTERNATIONAL, Jury Trial Demanded

International, Inc. (“Defendant” or “Olympia”) as follows:

1. Allway is a leading manufacturer and distributor of contractor’s tools such as

helictical paint mixer and the extendable scrub brush.

Depot, are also protected by trade dress.

5. On information and belief, Olympia—with full knowledge of and complete

Olympia’s products are shown below (collectively, the “Infringing Products”).

6. By importing, selling, and distributing the Infringing Products, Olympia

7. Accordingly, Allway brings the following action for patent infringement in

9. On information and belief, defendant Olympia Tools International, Inc. is a

10. On information and belief, Defendant is a distributor, marketer, importer, seller,

and tumblers. Defendant is a competitor to Allway.

JURISDICTION AND VENUE

State of New York.

and used in New York, including the Infringing Products.

Allway’s Rights and Products

expect from Allway.

22. Emblazoned on most ALLWAY-branded products and/or their packaging is the

versions of its products.

shown below and included in Exhibit 1.

catalogs are attached as Exhibit 2.

advertisement. A copy of such an advertisement is attached as Exhibit 4.

the ALLWAY mark associated with Allway products.

Allway products at retailers selling ALLWAY branded products in their stores.

cases that show the ALLWAY mark, as shown below.

Allway’s Helictical Paint Mixer

required by the statute.

in Allway’s booth at the trade shows it attends around the country.

the ALLWAY mark.

 a cap with a circular opening fixed atop a rod;

38. Collectively, these elements cohere to form a unique, distinctive, broadly

their respective websites.

Allway’s Extendable Scrub Brush

 a teardrop shaped head with bristles extending below the teardrop;

functional trade dress (the “Extendable Scrub Brush Trade Dress”).

materials and their respective websites.

Allway’s Heavy-Duty Scrub Brush

the heavy-duty scrub brush are attached as Exhibit 2.

brush to Home Depot between 2007 and 2011.

 a brush with an ovoid body shape;

materials and their respective websites.

Allway’s Contour Scraper Set

Allway’s booth at the trade shows it attends around the country.

ALLWAY mark, and the ALLWAY mark appeared on the handle.

Depot between 2016 and 2018.

functional trade dress (the “Contour Scraper Set Trade Dress”).

Allway’s Business with Home Depot

stores are shown below and attached as Exhibit 18.

of quality and reliability were maintained.

are not licensed by Allway.

Defendant’s Infringing Actions

shows as Allway, such as the National Hardware Show in Las Vegas.

the Infringing Products and began selling them to Home Depot.

Products appear below and are attached as Exhibit 19.

Olympia’s Infringing Paint Mixer Genuine Allway Paint Mixer

drawing from the D526 Patent.

Olympia’s Infringing Paint Mixer Allway D526 Patent

Olympia sought to mimic:

brush with a drawing from the D811 Patent.

Olympia’s Infringing Extendable Scrub Brush Allway D811 Patent

Allway contour scraper set that Olympia sought to mimic: