DMF v. Lotus LED Lighting - Complaint

Case 2:20-cv-05893 Document 1 Filed 06/30/20 Page 1 of 14 Page ID #:1
DAVIDSON LAW GROUP, ALC

1 Ben M. Davidson (CASB #181464)
ben@dlgla.com
2 4500 Park Granada Blvd, Suite 202
Calabasas, California 91302
3 Office: (818) 918-4622
Fax: (310) 473-2941
4
ERGONIQ LLC
5 Robert A. Gutkin (CASB # 119781)
gutkinra@ergoniq.com
6 8200 Greensboro Dr. Suite 900
McLean, VA 22102
7 Office: (202) 847-6853
8 Attorneys for Plaintiff DMF, Inc.
9
IN THE UNITED STATES DISTRICT COURT
10 FOR THE CENTRAL DISTRICT OF CALIFORNIA
11
DMF, Inc.,
12
a California corporation
13
Plaintiff,
14 Civil Action No. 2:20-cv-0893
v.
15
LOTUS LED LIGHTING LTD., JURY TRIAL DEMAND
16 a Canadian company
17 Defendant.
18
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Complaint For Patent Infringement
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This is a patent infringement action arising out of the copying of the
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ornamental design of Plaintiff DMF Inc.’s (“DMF’s) award winning OneFrame LED
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housing by Defendant Lotus LED Lighting Ltd. (“Lotus”) to make imitation LED
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housing products. DMF seeks damages and injunctive relief based on the
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infringement by Lotus of DMF’s U.S. Patent No. D848,375 (“the ‘375 Patent”) and
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U.S Patent No. D833,977 (“the 977 Patent”), entitled “Electrical Junction Box”
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(collectively the “patents-in-suit”).
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Complaint For Patent Infringement -1-

1 I. Parties
2 1. Plaintiff DMF is headquartered and has manufacturing facilities within
3 this District at 1118 East 223rd Street, Carson, California 90745.
4 2. On information and belief, Defendant Lotus is incorporated in Canada,
5 and has a principal place of business located at 1080 Cliveden Ave, Unit 7, Delta,
6 BC, V3M 6G6.
7 II. Jurisdiction and Venue
8 3. This action arises under the patent laws of the United States, Title 35 of
9 the United States Code. Accordingly, this Court has subject matter jurisdiction
10 under 28 U.S.C. §§ 1331, 1332 and 1338(a).
11 4. This Court has personal jurisdiction over Defendant Lotus in this action
12 because, among other reasons, on information and belief, Lotus has committed and
13 continues to commit direct acts of infringement within the Central District of
14 California giving rise to this action, and has established minimum contacts with the
15 forum state of California, by placing infringing products into the stream of
16 commerce with the knowledge, understanding and expectation that such products
17 will be sold in the state of California and in this judicial district. Lotus additionally
18 has offered products in this judicial district, including through its website, which
19 includes an interactive tab for customers to “Find Your Nearest Store,” including in
20 this judicial district, as well as an “Agent Locator” in Los Angeles. Moreover, on
21 information and belief, Lotus has committed and continues to commit acts of indirect
22 infringement in this judicial district by, among other things, while having
23 knowledge, inducing others such as Agents West, a manufacturer’s representative
24 with its principal place of business in Irvine, California, to commit direct acts of
25 infringement by offering for sale and/or selling to customers in this judicial district
26 products that infringe the patents-in-suit. Lotus therefore has purposefully availed
27 itself of the benefits of doing business in the state of California, and the exercise of
28 jurisdiction over Lotus would not offend traditional notions of fair play and
1 substantial justice. On information and belief the President and CEO of Lotus is
2 Georgi Georgiev, a resident of Canada, is a dominant and active force behind the
3 wrongful acts complained of herein.
4 5. Venue is proper in this District under 28 U.S.C. §§ 1391(c)(3) and
5 1400(b) because Lotus has committed acts of patent infringement in this District.
6 III. The Patents-In-Suit
7 6. On May 14, 2019, the ‘375 Patent, entitled “Electrical Junction Box,”
8 was duly and legally issued by the U.S. Patent and Trademark Office (“USPTO”) to
9 DMF’s inventors Michael D. Danesh and Xinzhi Peng. A true and correct copy of
10 the ‘375 Patent is attached as Exhibit 1. The ‘375 Patent is valid, enforceable and in
11 full force and effect.
12 7. DMF is the owner and assignee of all rights, title and interest in the
13 ‘375 Patent, including the right to bring this action and enforce the ‘375 Patent
14 against infringers, and to collect damages for all relevant times.
15 8. On November 20, 2018, the ‘977 Patent, entitled “Electrical Junction
16 Box,” was duly and legally issued by the U.S. Patent and Trademark Office
17 (“USPTO”) to DMF’s inventors Michael D. Danesh and Xinzhi Peng. A true and
18 correct copy of the ‘977 Patent is attached as Exhibit 2. The ‘977 Patent is valid,
19 enforceable and in full force and effect.
20 9. DMF is the owner and assignee of all rights, title and interest in the
21 ‘977 Patent, including the right to bring this action and enforce the ‘977 Patent
22 against infringers, and to collect damages for all relevant times.
23 IV. Factual Background
24 10. DMF is a leading manufacturer of residential and commercial
25 downlighting. DMF’s products stand out for their forward-thinking industrial
26 designs, and are selected by specifiers for prestigious new constructions throughout
27 the United States. DMF’s headquarters and manufacturing facilities in Carson,
28 California include a state-of-the-art research and development laboratory where

1 engineers and product designers work to improve existing products and develop new
2 ones. DMF invests substantially in its continuing efforts to develop leading
3 innovations in the LED lighting industry and has been awarded a number of industry
4 awards as well as United States patents on its innovations.
5 11. DMF developed a rigorous quality control program for its products that
6 has earned and maintained DMF’s reputation as a leading supplier of LED lighting
7 products that can be trusted to perform as advertised. All DMF products undergo a
8 rigorous, multi-tiered testing process to ensure that they meet DMF’s stringent
9 performance standards. DMF employs a number of U.S. military veterans in its
10 operation and performs quality-control testing procedures developed by the U.S.
11 military. As a result, DMF’s lighting fixtures have an industry leading success rate.
12 12. DMF makes, sells, and promotes LED housings for whose ornamental
13 designs are protected by the ‘375 Patent and the ‘977 Patent. These housings
14 include the OneFrame – a revolutionary LED junction box housing created for
15 multifamily construction, an image of which is shown below:
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25 13. DMF started marketing and selling its OneFrame – LED junction box
26 housing products in 2014. By early 2015, the OneFrame – LED junction box was a
27 prominent part of DMF’s public website.
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1 14. DMF showcased its OneFrame – LED junction box at many industry
2 tradeshows since at least June 2014, including:
3 ● LIGHTFAIR International 2014, Las Vegas, NV (June 3-5, 2014)
4 ● LIGHTFAIR International 2015, New York, NY (May 5-7, 2015)
5 ● LIGHTFAIR International 2016, San Diego, CA (April 26-28, 2016)
6 ● LIGHTFAIR International 2017, Philadelphia, PA (May 7-9, 2017)
7 ● LIGHTFAIR International 2018, Chicago, IL (May 8-10, 2018)
8 ● LIGHTFAIR International 2019, Philadelphia, PA (May 19-23, 2019)
9 15. On information and belief, Defendant Lotus is a commodity-grade
10 supplier of lighting fixtures that owns the website at www.lotusledlights.com. (the
11 “Lotus website”). After seeing the success of DMF’s OneFrame – LED housing,
12 Lotus decided to make an imitation and sell it under names including at least Lotus
13 Model No. LBL-FRB products (“the Lotus Products”). Lotus makes, uses, sells,
14 offers for sale and promotes the Lotus Products on its website, and places infringing
15 products into the stream of commerce with the knowledge, understanding and
16 expectation that such products will be sold in the state of California and in this
17 judicial district. Additionally, with knowledge and through the assistance of agents
18 and/or representatives, such as Agents West, a manufacturer’s representative based
19 in Irvine, California, Lotus sells and/or offers for sale, and or induces others to sell
20 and/or offer for sale the Lotus Products in the state of California and in this judicial
21 district.
22 An image of the Lotus LBL-FRB junction box obtained from a specification
23 sheet available on the Lotus website at:
24 https://www.lotusledlights.com/resources/Spec-Sheet-LBL-FRB.pdf is shown
25 below:
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9 A true and correct copy of the Lotus website page is attached hereto as Exhibit 3. A
10 true and correct copy of the Lotus specification sheet is attached hereto as Exhibit 4.
11 16. On May 27, 2020, DMF’s counsel sent a letter to Mr. Georgiev, the
12 President and CEO of Lotus, informing Lotus of its infringement of the ‘375 and
13 ‘977 Patents and attaching copies of the Patents to the letter (the “May 27 Letter”).
14 DMF’s counsel demanded that Lotus, and those acting in concert with Lotus, cease
15 and desist from further infringement and that Lotus provide a sample of its products.
16 A true and correct copy of the May 27 Letter is attached hereto as Exhibit 5.
17 17. On June 12, 2020, DMF’s counsel received a reply from Canadian
18 counsel representing Lotus (the “June 12 Response Letter”). Lotus’ counsel did not
19 confirm that Lotus would stop further infringement of the ‘375 and ‘977 Patents or
20 provide a sample of its products. Lotus instead argued through its counsel that its
21 ornamental design did not infringe DMF’s design patents because Lotus used inward
22 facing tangs for attaching a light fixture.
23 18. On information and belief, as of June 25, 2020, Lotus not only has
24 offered and sold and induced others to offer and sell infringing LBL-FRB products,
25 but it currently continues to offer and sell and induce others to offer and sell
26 infringing LBL-FRB products.
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28

1 CLAIMS FOR RELIEF

2 COUNT I: INFRINGEMENT OF THE ’375 PATENT
3 19. DMF hereby incorporates paragraphs 1 - 18 as if fully set forth herein.
4 20. The claimed design of the ‘375 Patent is shown in the patent and
5 described in the accompanying figure descriptions. See Exhibit 1. Representative
6 images of the claimed design of the electrical junction box are shown below:
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1 21. Lotus sells and/or offers LBL-FRB products for sale, including through
2 its website and, on information and belief, through manufacturer’s representatives
3 such as Agents West, acting in concert with and/or induced by Lotus.
4 Representative images of LBL-FRB products from the Lotus website are shown
5 below:
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22. On information and belief Lotus also sells and/or offers to sell the LBL-
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FRB products through distributors, including online distributors and, on information
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and belief, multiple brick and mortar distributors that do not publicly show the
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products they sell, for example on a website.
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1 23. In the eye of the ordinary observer familiar with the relevant prior art,
2 giving such attention as a purchaser usually gives, the claimed design of the’375
3 Patent and the design of the LBL-FRB products are substantially the same, such that
4 the ordinary observer would be deceived into believing that the design of the LBL-
5 FRB products is the design claimed in the ’375 Patent.
6 24. DMF did not give Lotus authorization or license to make, use, offer
7 to sell, or sell the infringing products, and as set forth above has specifically asked
8 Lotus, and those acting in concert with Lotus to cease and desist from further
9 infringement.
10 25. Lotus has directly infringed, and continues to directly infringe, the’375
11 Patent by making, using, importing, offering to sell and/or selling the LBL-FRB
12 products having substantially the same ornamental design as the design claimed in
13 the’375 Patent. Lotus has indirectly infringed, and continues to indirectly infringe,
14 the’375 Patent by, with knowledge, inducing others, such as Agents West to sell
15 and/or offer for sale the LBL-FRB products having substantially the same
16 ornamental design as the design claimed in the’375 Patent. As a result of Lotus’s
17 infringement, DMF is entitled to damages of at least a reasonable royalty for the
18 infringement, lost profits, disgorgement of Lotus’s profits and/or at least $250 for
19 each infringing product.
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21 COUNT II: INFRINGEMENT OF THE ’977 PATENT
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26. DMF hereby incorporates paragraphs 1 - 25 as if fully set forth herein.
23
27. The claimed design of the ‘977 Patent is shown in the patent and
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described in the accompanying figure descriptions. Representative images of the
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claimed design are shown below:
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28. In the eye of the ordinary observer familiar with the relevant prior art,
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giving such attention as a purchaser usually gives, the claimed design of the ’977
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Patent and the design of the the LBL-FRB products shown above are substantially
23
the same, such that the ordinary observer would be deceived into believing that the
24
design of the LBL-FRB products is the design claimed in the ’977 Patent.
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29. DMF did not give Lotus authorization or license to make, use, offer
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Complaint For Patent Infringement - 10 -

1 to sell, or sell the infringing products, and as set forth above has specifically asked
2 Lotus, and those acting in concert with Lotus to cease and desist from further
3 infringement.
4 30. Lotus has directly infringed, and continues to directly infringe, the’977
5 Patent by making, using, importing, offering to sell and/or selling the LBL-FRB
6 products having substantially the same ornamental design as the design claimed in
7 the’977 Patent. Lotus has indirectly infringed, and continues to indirectly infringe,
8 the’977 Patent by, with knowledge, inducing others, such as Agents West to sell
9 and/or offer for sale the LBL-FRB products having substantially the same
10 ornamental design as the design claimed in the’977 Patent. As a result of Lotus’s
11 infringement, DMF is entitled to damages of at least a reasonable royalty for the
12 infringement, lost profits, disgorgement of Lotus’s profits and/or at least $250 for
13 each infringing product.
14 35 U.S.C. § 284 Willful Infringement
15 31. Lotus has been aware of the ‘375 Patent and the ‘977 Patent at least as
16 of the time it received the May 27, 2020 letter from DMF’s Counsel notifying Lotus
17 of the infringement. On information and belief, Lotus knew about these patents
18 earlier, since at least shortly after its attendance at a 2019 trade show where it
19 studied DMF’s patented products and indicated its intention to copy them. On
20 information and belief, Lotus knew that it copied DMF’s patented products and that
21 there was a high likelihood that its copies of these products would be found to
22 infringe.
23 32. Lotus’ actions have been willful. Lotus, with knowledge of the patents
24 and their infringement, and despite having copied its competitor’s patented product,
25 not only failed to take remedial action after receiving DMF’s letter, but, on
26 information and belief, continued to offer the product to DMF’s customers and
27 potential customers.
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PRAYER FOR RELIEF

1
Plaintiff DMF respectfully requests the following relief from the Court:
2
A. A judgment that Lotus has infringed the ‘375 Patent;
3
B. A judgment that Lotus has infringed the ‘977 Patent;
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C. A judgment and order requiring Lotus to pay DMF its damages, costs,
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expenses, prejudgment interest and post-judgment interest for Lotus’s acts of
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infringement;
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D. Injunctive relief;
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E. An accounting for all profits derived by Lotus from its unlawful acts;
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F. An award to DMF of its reasonable attorney fees, and
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G. Any and all other relief to which DMF may show itself to be entitled.
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12
Respectfully submitted,
13
14 Dated: June 29, 2020 By: /s/ Ben M. Davidson
DAVIDSON LAW GROUP, ALC
15 Ben M. Davidson (State Bar No. 181464)
ben@dlgla.com
16 4500 Park Granada Blvd, Suite 202
17 Office: (818) 918-4622
Fax: (310) 473-2941
18
Attorneys for Plaintiff DMF, Inc.
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1 DEMAND FOR JURY TRIAL
2 Pursuant to Rule 38 of the Federal Rules of Civil Procedure, DMF requests a

3 trial by jury of any issues so triable by right.
4
Dated: June 29, 2020 By: /s/ Ben M. Davidson
5 DAVIDSON LAW GROUP, ALC
Ben M. Davidson (State Bar No. 181464)
6 ben@dlgla.com
4500 Park Granada Blvd, Suite 202
7 Calabasas, California 91302
Office: (818) 918-4622
8 Fax: (310) 473-2941
9
Attorneys for Plaintiff DMF, Inc.
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Exhibits
1
2 Ex. No. Description
3 1 ......... U.S. Patent No. D848,375
4 2 ......... U.S. Patent No. D833,977
5 3 ......... Lotus website for LBL-FRB
6 4 ......... Lotus specification sheet for LBL-FRB
7 5 ......... May 27, 2020 letter from DMF’s Counsel to Lotus
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Case 2:20-cv-05893 Document 1-1 Filed 06/30/20 Page 1 of 100 Page ID #:15
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EXHIBIT 3 - PAGE 52
EXHIBIT 4
EXHIBIT 4 - PAGE 53
LBL-FRB
Fire Rated 4" Octagon Box
Project:
Location:
Qty:
Notes:
SPECIFICATION
Applications Multi-Family Residential & Commercial
Fire Rating 2 Hour
DESCRIPTION Air-Tight Yes
3
Code-compliant new construction 2 hour fire rated Box Volume 33.7 in
standard size octagon junction box. Box Weight 1.33 lbs
Designed for surface mount ceiling light fixtures 5" diameter & up Truss Span 16" to 24"
Weight Limit 50 lbs
FEATURES & BENEFITS Certification c ETL us, file # 3193488
Fire & Air-Tight rated Safety Standards UL-514A, CAN/CSA-C22.2 No. 18.1
Innovative design allows for versatile installation while Fire Standard UL 263
retaining key features that are easy to specify, install & maintain Warranty 3 Year
Mounts on 1/2" to 1" 1/2 thick drywall (pre-adjusted for 5/8")
Fits in 2" ceiling space - ideal for limited plenum areas
Expandable bars fit 16" to 24" spaced joists
ORDERING GUIDE model LBL-FRB Compatible fixtures supplied by Lotus LED Lights
Package contains box and mounting bars
LL4RBX, CSC3017, CSC3025, ADS7R9, ADS12R8
Case quantity 24 pieces
Lotus LED Lights USA www.LotusLEDLights.com Lotus LED Lights CANADA

250 H Street # 301, Blaine WA 98230 tel 360-200-5500 800-15355 24 Ave Box 200, Surrey BC V4A 2H9 tel 604-538-3090
Hainesport NJ, Naples FL, Dallas TX, Vancouver WA Delta BC & Mississauga ON
EXHIBIT 4 - PAGE 54
EXHIBIT 5
EXHIBIT 5 - PAGE 55
4500 Park Granada Blvd, Suite 202

Telephone: 818.918-4622
Facsimile: 310.473.2941
May 27, 2020
VIA EMAIL AND CERTIFIED MAIL – RETURN RECEIPT REQUESTED
Mr. Georgi Georgiev

President
Lotus LED Lights
800 – 15355 24th Ave, Box 200
Surrey, BC V4A 2H9
(office@lotusledlights.com
support@lotusledlights.com)
RE: Infringement of DMF Inc.’s Intellectual Property Rights
Dear Mr. Georgiev:
This firm represents DMF Inc. dba DMF Lighting (“DMF”) in intellectual property
litigation matters. As you know, DMF is an award-winning and engineering-driven company
known for products that deliver exceptional performance and aesthetics, while saving time and
money. DMF invests substantial resources in developing its proprietary technology and designs.
DMF’s OneFrame products incorporating its technology have earned DMF a reputation for
providing high quality LED products that undergo rigorous safety and performance testing.
DMF has a number of issued United States patents protecting its award-winning
innovations, including, for example, U.S. Patent No. 10,139,059 (“the ‘059 Patent”) entitled
“Adjustable Compact Recessed Lighting Assembly With Hanger Bars” (attached as Exhibit A),
U.S. Patent No. D848,375 (“the ‘375 Patent”) (attached as Exhibit B), and U.S Patent No.
D833,977 (“the 977 Patent”) entitled “Electrical Junction Box” (attached as Exhibit C).1
We write to you because we have learned that Lotus LED Lights (“Lotus”) has copied
one of DMF’s products and is infringing DMF’s patented technology in order to usurp the
goodwill that comes from the innovative technology that customers associate with DMF. We
demand that Lotus, along with their officers, and those acting in concert with them, immediately
cease and desist their infringing sales and other activities designed to unfairly compete with
DMF, and take the steps set forth at the end of this letter.
DMF’s award-winning products include the OneFrame – a revolutionary LED junction

box housing created for multifamily construction. Among other things, the OneFrame system
includes a junction box that eliminates the need to construct a fire rated box requiring specialized
1
You can easily access the U.S. Patent & Trademark Office’s public Patent Application Information Retrieval
(“PAIR”) website (https://portal.uspto.gov/pair/PublicPair) to obtain their records on the ‘059, ‘977, and ‘375
Patents, including documents from the “file wrapper” (or “file history”) which has communications with the U.S.
Patent & Trademark Office during the examination of these patents.
EXHIBIT 5 - PAGE 56
Mr. Georgi Georgiev

May 27, 2020
Page 2
labor and extra material costs. The OneFrame junction box has a unique low profile and small
aperture that enables high quality, cost effective recessed LED lighting.
DMF introduced its OneFrame system, including its DRD2HNJ junction box products in
2014. As you doubtless know from attending DMF’s booth at industry trade shows, these
products have garnered numerous prestigious awards, including the LIGHTFAIR International
Technical Innovation Award, Illuminating Engineering Society’s Progress Report Selection, and
Architectural SSL Magazine’s Product Innovation Award.
The OneFrame junction box is also commercially successful and has created a new
product category that disrupted the recessed lighting business. Lotus has taken note of this
success, and has recently started offering for sale an imitation of the OneFrame DRDHNJD,
including at least Lotus Model No. LBL-FRB products (“the Lotus Products”). Based on the
information currently available to us, the Lotus Products infringe at least DMF’s ‘977 and ‘375
Patents. The table below compares figures from these patents with DMF’s OneFrame and the
Lotus Products, which are copies of DMF’s OneFrame.
DMF ‘375 Patent
DMF ‘977 Patent
EXHIBIT 5 - PAGE 57
Mr. Georgi Georgiev

May 27, 2020
Page 3
DMF’s OneFrame
The Lotus Products
The Lotus Products infringe at least DMF’s ‘375 and ‘977 Patents because they use
substantially the same designs. That is, in the eye of an ordinary observer, giving such attention
as a purchase usually gives, the resemblance between the designs is such as to deceive such an
observer, inducing one design to be purchased supposing it to be the other.
EXHIBIT 5 - PAGE 58
Mr. Georgi Georgiev

May 27, 2020
Page 4
As a company built on innovation and engineering, DMF is committed to protecting its

intellectual property rights. Within seven calendar days from the receipt of this letter, we request
that Lotus or its legal counsel confirm that Lotus has discontinued all sale, distribution, and
promotion of the infringing Lotus Products. We also request that Lotus or its legal counsel
contact us so that we can determine whether it is possible to reach an amicable resolution of the
issue of patent infringement and damages to DMF. To do so, we will require Lotus to provide a
sample of its Lotus Products, along with an accounting of all sales that have taken place to date
and the identity of the manufacturer of this product. We further advise Lotus that it has an
obligation to take immediate steps to gather and/or maintain as evidence any Lotus products and
to preserve any and all documents relating to this matter, including electronic documents such as
emails and electronic copies of accounting records, in any way related to the purchase, sale,
marketing, promotion, profits, revenues, costs, or disposal of the infringing products, the
manufacture of these products, and knowledge of and copying of DMF’s products, designs, and
patents.
This is not a full statement of DMF’s rights and should not be so construed. DMF is
continuing to investigate the issues raised in this letter and potential additional issues of patent
infringement and unfair competition. DMF specifically reserves, and does not waive, any and all
of its rights with respect to this matter, including but not limited to seeking all legal and equitable
remedies available for the harm that Lotus and those acting in concert with and/or on its behalf
or instruction, have caused DMF.
Thank you for your immediate attention to this matter. I look forward to hearing from
you or attorneys for Lotus.
Very truly yours,
Ben M. Davidson
cc: David W. Long, Esq.

Ergoniq, LLC
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Exhibit A
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Exhibit B
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Exhibit C
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DMF v. Lotus LED Lighting - Complaint

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Case 2:20-cv-05893 Document 1 Filed 06/30/20 Page 1 of 14 Page ID #:1

DAVIDSON LAW GROUP, ALC

Complaint For Patent Infringement -1-

24 10. DMF is a leading manufacturer of residential and commercial

25 downlighting. DMF’s products stand out for their forward-thinking industrial

27 the United States. DMF’s headquarters and manufacturing facilities in Carson,

28 California include a state-of-the-art research and development laboratory where

Complaint For Patent Infringement -3-

Complaint For Patent Infringement -4-

Complaint For Patent Infringement -5-

Complaint For Patent Infringement -6-

1 CLAIMS FOR RELIEF

Complaint For Patent Infringement -7-

Complaint For Patent Infringement -8-

Complaint For Patent Infringement -9-

Complaint For Patent Infringement - 10 -

Complaint For Patent Infringement - 11 -

PRAYER FOR RELIEF

Complaint For Patent Infringement - 12 -

1 DEMAND FOR JURY TRIAL

2 Pursuant to Rule 38 of the Federal Rules of Civil Procedure, DMF requests a

Complaint For Patent Infringement - 13 -

Complaint For Patent Infringement - 14 -

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Lotus LED Lights USA www.LotusLEDLights.com Lotus LED Lights CANADA

4500 Park Granada Blvd, Suite 202

May 27, 2020

VIA EMAIL AND CERTIFIED MAIL – RETURN RECEIPT REQUESTED

Mr. Georgi Georgiev

RE: Infringement of DMF Inc.’s Intellectual Property Rights

Dear Mr. Georgiev:

DMF’s award-winning products include the OneFrame – a revolutionary LED junction

Mr. Georgi Georgiev

DMF ‘375 Patent

DMF ‘977 Patent

Mr. Georgi Georgiev

The Lotus Products

Mr. Georgi Georgiev

As a company built on innovation and engineering, DMF is committed to protecting its

Very truly yours,

cc: David W. Long, Esq.

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