Skull Shaver v. Rayenbarny - Complaint

Case 6:20-cv-00951 Document 1 Filed 10/13/20 Page 1 of 52
UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
WACO DIVISION
SKULL SHAVER, LLC,
Plaintiff,
v.
RAYENBARNY INC., BALD SHAVER INC.,

SUZHOU KAIDIYA GARMENTS TRADING
CO., LTD., SHENZHEN AIWEILAI
TRADING CO., LTD., WENZHOU Civil Action No. 6:20-cv-00951
WENDING ELECTRIC APPLIANCE CO.,
LTD., SHENZHEN NUKUN TECHNOLOGY JURY TRIAL DEMANDED
CO., LTD., YIWU XINGYE NETWORK
TECHNOLOGY CO. LTD., MAGICFLY LLC,
YIWU CITY QIAOYU TRADING CO., LTD.,
SHENZHEN WANTONG INFORMATION
TECHNOLOGY CO., LTD., SHENZHEN
JUNMAO INTERNATIONAL
TECHNOLOGY CO., LTD.,
Defendants.
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Skull Shaver, LLC (“Skull Shaver” or “Plaintiff”) files this Complaint and demand
for a jury trial seeking relief for patent infringement by Rayenbarny Inc., Bald Shaver Inc., Suzhou
Kaidiya Garments Trading Co., Ltd., Shenzhen Aiweilai Trading Co., Ltd., Wenzhou Wending
Electric Appliance Co., Ltd., Shenzhen Nukun Technology Co., Ltd., Yiwu Xingye Network
Technology Co. Ltd., Magicfly LLC, Yiwu City Qiaoyu Trading Co., Ltd., Shenzhen Wantong
Information Technology Co., Ltd., Shenzhen Junmao International Technology Co., Ltd.,
(collectively “Defendants”). Plaintiff states and alleges the following:
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THE PARTIES
1. This case for patent infringement is brought by Skull Shaver, a company founded
by two United States veterans who brought together their ingenuity and talents to invent, develop,
and launch novel and highly effective electric shavers. Recognizing the value of their creation,
the founders of Skull Shaver applied for and were awarded numerous patents protecting their work.
However as time went on and Skull Shaver saw its sales grow, companies like the Defendants,
many from overseas, began to knock-off Skull Shaver’s products and offend its intellectual
property.
2. Skull Shaver is a limited liability company organized and existing under the law of
the state of New Jersey, with its principal place of business at 1503 Glen Avenue, Suite 160,
Moorestown, New Jersey 08057, USA. Skull Shaver is in the business of designing and selling
patented horizontal electric shavers in the United States and abroad, including in this judicial
district.
3. Skull Shaver owns a portfolio of numerous issued United States patents related to
and embodied by various of its successful shaving products. The designs and devices claimed in
those patents have changed the way consumers view and use handheld electric shaving devices,
particularly when shaving curved parts of the body.
4. Before Skull Shaver’s inventions, prevailing handheld electric shaver devices were
limiting in grip orientation and versatility of use, particularly when shaving hair on curved parts
of the body. Most designs incorporated a vertical handle and did not provide the user with firm
gripping in order to achieve a consistent and uniform shave over curved portions of the body.
Furthermore, prior electric shavers did not fit in the user’s hand in a comfortable manner
particularly when the shaver was oriented with the grip above the cutter surface, such as when
reaching upward to shave the head.
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5. Skull Shaver’s patents solve these issues, since the shape and design of the shaver
housings fits the hand in a comfortable manner, especially when shaving curved parts of the body
or when the shaver is held in an orientation where the housing is above the cutter. When the shaver
is oriented in this manner, it is then possible to either grip the shaver with two fingers as between
the thumb and index finger, or between the index and middle fingers, or between the middle and
ring fingers, while resting the remainder of the hand against the skin. This helps the user properly
orient and place the cutting surface of the shaver against the skin while being able to feel whether
the skin has been sufficiently shaved, providing the user with sensory feedback.
6. Skull Shaver was founded in 2010, and shortly after it began offering the unique
and effective electric shavers for sale, its products became a hit. Since then, Skull Shaver has been
featured in local and national newspapers, radio stations, websites, and blogs.
7. On information and belief, Rayenbarny Inc. (“Rayenbarny”) is a New York
corporation with its principal place of business at 299 Park Avenue, Floor 6, New York, NY.
8. On information and belief, Defendant Bald Shaver Inc. (“Bald Shaver”) is a
Canadian corporation with its principal place of business at 540 King Street W, Toronto, Ontario,
Canada.
9. On information and belief, Defendant Suzhou Kaidiya Garments Trading Co., Ltd.
(“Suzhou Kaidiya”) is a Chinese corporation with its principal place of business at Room 50,
Building 16-52, Shihui Fang Industrial Park, Suzhou, Jiangsu, 215000, China.
10. On information and belief, Defendant Shenzhen Aiweilai Trading Co., Ltd.
(“Shenzhen Aiweilai”) is a Chinese corporation with its principal place of business at Room 302,
Building 39, Shuiwei No.1, Minzhi Street, Longhua New District, Shenzhen, Guangdong, 518000,
China.
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11. On information and belief, Defendant Wenzhou Wending Electric Appliance Co.,
Ltd. (“Wenzhou Wending”) is a Chinese corporation with its principal place of business at 502,
Building 8, West Street, Lecheng Street, Yueqing City, Zhejiang Province, 325600, China.
12. On information and belief, Defendant Shenzhen Nukun Technology Co., Ltd.
(“Shenzhen Nukun”) is a Chinese corporation with its principal place of business at A2-405,
Zhongbaotong Technology Park, No. 34, Changfa West Road, Wuhe Metro Station, Longgang
District, Shenzhen, Guangdong, 518000, China.
13. On information and belief, Defendant Yiwu Xingye Network Technology Co. Ltd.
(“Yiwu Xingye”) is a Chinese corporation with its principal place of business at Choujiang Street,
Chengzhongxilu No.93, Yiwu, Zhejiang, 322000, China.
14. On information and belief, Defendant Magicfly LLC (“Magicfly”) is a Hong Kong
corporation with its principal place of business at Room 1501, Grand Millennium Plaza, Lower
Blk, 181 Queen’s Road, Center Hong Kong.
15. On information and belief, Defendant Yiwu City Qiaoyu Trading Co., Ltd. (“Yiwu
City”) is a Chinese corporation with its principal place of business at 401, 2 Hao, 33 Zhuang
Duyuan Cun, Houzhai, Jiedao, Yiwu, Zhejiang, 322000, China.
16. On information and belief, Defendant Shenzhen Wantong Information Technology
Co., Ltd (“Shenzhen Wantong”) is a Chinese corporation with its principal place of business at
B1330, Chuangwei Chuangxin Valley, No. 8, Tangtou No.1 Road, Tangtou Community, Shiyan
Street, Baoan District, Shenzhen, Guangdong, 518000, China.
17. On information and belief, Defendant Shenzhen Junmao International Technology
Co., Ltd (“Shenzhen Junmao”) is a Chinese corporation with its principal place of business at
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Minle Gongyeyuan Erdong 401, Longhua Xinqu Minzhi Jiedao, Shenzhen, Guangdong, 518000,
China.
JURISDICTION AND VENUE
18. This is a civil action for patent infringement under the patent laws of the United
States, 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331
and 1338.
19. The Court has personal jurisdiction over Rayenbarny because it has continuous
business contacts in the State of Texas in this District. Rayenbarny has engaged in business
activities including transacting business in this District and purposefully directing its business
activities, including the use, marketing, sale or offer for sale of electric shavers, such as the Men’s
5-in-1 Electric Shaver & Grooming Kit by AsaVea. Rayenbarny, selling its products through
Internet retail channels, was aware that its electric shavers are sold and delivered nationwide,
including in this judicial District, and should reasonably anticipate being haled into court in this
judicial District.
20. The Court has personal jurisdiction over Bald Shaver because it has continuous
business contacts in the State of Texas in this District. Bald Shaver has engaged in business
activities, including the use, marketing, sale or offer for sale of electric shavers, such as the LK-
1800 Shaver. Bald Shaver, selling its products through Internet retail channels, was aware that its
electric shavers are sold and delivered nationwide, including in this judicial District, and should
reasonably anticipate being haled into court in this judicial District.
21. The Court has personal jurisdiction over Suzhou Kaidiya because it has continuous
business contacts in the State of Texas in this District. Suzhou Kaidiya has engaged in business
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activities, including the use, marketing, sale or offer for sale of electric shavers, such as the Kibiy
Bald Head Shaver LED Mens Electric Shaving Razor by Digimator. Suzhou Kaidiya, selling its
products through Internet retail channels, was aware that its electric shavers are sold and delivered
nationwide, including in this judicial District, and should reasonably anticipate being haled into
court in this judicial District.
22. The Court has personal jurisdiction over Shenzhen Aiweilai because it has
continuous business contacts in the State of Texas in this District. Shenzhen Aiweilai has engaged
in business activities including transacting business in this District and purposefully directing its
business activities, including the use, marketing, sale or offer for sale of electric shavers, such as
the Teamyo 5D Floating Deep Clean Head Shaver for Bald Men. Shenzhen Aiweilai, selling its
products through Internet retail channels, was aware that its electric shavers are sold and delivered
23. The Court has personal jurisdiction over Wenzhou Wending because it has
continuous business contacts in the State of Texas in this District. Wenzhou Wending has engaged
the PaiTree 5 in 1 Head and Face Electric Rotary Shaver. Wenzhou Wending, selling its products
through Internet retail channels, was aware that its electric shavers are sold and delivered
24. The Court has personal jurisdiction over Shenzhen Nukun because it has continuous
business contacts in the State of Texas in this District. Shenzhen Nukun has engaged in business
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activities, including the use, marketing, sale or offer for sale of electric shavers, such as the OriHea
5 in 1 Head Shavers for Bald Men Electric Rotary Razor. Shenzhen Nukun, selling its products
25. The Court has personal jurisdiction over Yiwu Xingye because it has continuous
business contacts in the State of Texas in this District. Yiwu Xingye has engaged in business
activities, including the use, marketing, sale or offer for sale of electric shavers, such as the
Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver. Yiwu Xingye, selling its products
26. The Court has personal jurisdiction over Magicfly because it has continuous
business contacts in the State of Texas in this District. Magicfly has engaged in business activities
including transacting business in this District and purposefully directing its business activities,
including the use, marketing, sale or offer for sale of electric shavers, such as the Magicfly
Rechargeable Waterproof Shaver for Women. Magicfly, selling its products through Internet retail
channels, was aware that its electric shavers are sold and delivered nationwide, including in this
judicial District, and should reasonably anticipate being haled into court in this judicial District.
27. The Court has personal jurisdiction over Yiwu City because it has continuous
business contacts in the State of Texas in this District. Yiwu City has engaged in business activities
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including transacting business in this District and purposefully directing its business activities,
including the use, marketing, sale or offer for sale of electric shavers, such as the Surker 6 in 1
Electric Shavers for Men Bald Head. Yiwu City, selling its products through Internet retail
channels, was aware that its electric shavers are sold and delivered nationwide, including in this
judicial District, and should reasonably anticipate being haled into court in this judicial District.
28. The Court has personal jurisdiction over Shenzhen Wantong because it has
continuous business contacts in the State of Texas in this District. Shenzhen Wantong has engaged
the Electric Razor Grooming Kit for Men 4 in 1 Dry Wet Waterproof Rotary Bald Head Shaver
by WTONG. Shenzhen Wantong, selling its products through Internet retail channels, was aware
that its electric shavers are sold and delivered nationwide, including in this judicial District, and
should reasonably anticipate being haled into court in this judicial District.
29. The Court has personal jurisdiction over Shenzhen Junmao because it has
continuous business contacts in the State of Texas in this District. Shenzhen Junmao has engaged
the Homeasy Men Electric Razor Bald Head Shaver. Shenzhen Junmao, selling its products
30. Venue is therefore proper in this judicial District pursuant to 28 U.S.C. § 1400(b)
because Defendants transact business in this District and purposefully direct their business
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activities to this District, including the sale and offer for sale of infringing products in this judicial
District.
31. Venue is likewise proper in this judicial District pursuant to 28 U.S.C. 1391(c)(3)
because at least defendants Bald Shaver, Suzhou Kaidiya, Shenzhen Aiweilai, Wenzhou Wending,
Shenzhen Nukun, Yiwu Xingye, Magicfly, Yiwu City, Shenzhen Wantong, and Shenzhen Junmao,
are foreign corporations residing and operating outside of the United States, and therefore may be
sued in any judicial district. See TC Heartland LLC v. Kraft Foods Grp. Brands LLC, 137 S. Ct.
1514, 1520 n.2 (2017) (declining to address venue implications on foreign corporations); see also
In re HTC Corp., 889 F.3d 1349, 1361 (Fed. Cir. 2018) (upholding alien-venue rule in declining
foreign defendant’s venue challenge).
ASSERTED PATENTS
32. The patents-at-issue in this action are U.S. Patent Nos. 8,726,528 (“the ’528
Patent”) and D672,504 (“the ’504 Patent”), (collectively, the “Asserted Patents”).
33. On May 20, 2014, the U.S. Patent Office duly and legally issued the ’528 Patent
entitled “Electric Head Shaver.” Skull Shaver is the assignee of all right, title, and interest in and
to the ’528 Patent. A true and correct copy of the ’528 Patent is attached hereto as Exhibit A.
34. On December 11, 2012, the U.S. Patent Office duly and legally issued the ’504
Patent entitled “Electric Head Shaver.” Skull Shaver is the assignee of all right, title, and interest
in and to the ’504 Patent. A true and correct copy of the ’504 Patent is attached hereto as Exhibit
B.
BACKGROUND
35. Since Skull Shaver introduced its patented products, numerous companies,
including the Defendants, began to copy the Skull Shaver Devices’ designs in their shaver products
and incorporate Skull Shaver’s patented inventions.
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36. These infringing products are manufactured abroad by foreign companies and
advertised and sold on websites to customers in the United States across the Internet, including on
Amazon.com, eBay.com, and Alibaba.com, among other websites.
37. On information and belief, sellers of foreign infringing counterfeit electric shavers,
including the Defendants, direct advertising and marketing efforts for the accused products to
customers searching for and purchasing Skull Shaver’s products through, for example, targeted
and sponsored advertisements.
38. For example, through Skull Shaver’s own product pages on Amazon.com, potential
Skull Shaver customers are targeted with sponsored marketing efforts directly aimed at promoting
infringing products, including on information and belief, numerous of the Defendants’ accused
devices. Similarly, when searching for Skull Shaver products on Amazon.com, potential
customers are presented with search results that include infringing knock-offs that are offered at
considerably cheaper prices, including on information and belief, numerous of the Defendants’
accused devices.
39. The Defendants represent only a small portion of the online sellers and brands
offering infringing electric shavers for purchase by customers in the United States. Over recent
years, Skull Shaver has become aware of numerous foreign companies intending to manufacture
and sell counterfeit infringing shavers to customers in the United States. However, in many cases
the entities quickly disappear and nearly identical products subsequently reappear and are sold
under different seller and brand names.
40. In view of the foregoing, and in an effort to curb the extensive intellectual property
abuses Skull Shaver has become aware of by foreign manufacturers importing and selling
counterfeit electric shavers to U.S. customers, Skull Shaver has no choice but to seek relief against
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the Defendants for infringement of its patented innovations. Simultaneous with the filing of this
complaint, Skull Shaver has also filed an investigation before the International Trade Commission
against the Defendants named in this suit for the importation and sale of the infringing electric
shavers.
COUNT I
(Patent Infringement of United States Patent No. 8,726,528 by Rayenbarny)
41. Skull Shaver realleges and incorporates by reference the preceding paragraphs of
this Complaint.
42. Rayenbarny has directly infringed, and continues to directly infringe, literally
and/or under the doctrine of equivalents, one or more claims of the ’528 patent by making, using,
testing, selling, offering for sale and/or importing into the United States Rayenbarny’s Men’s 5-
in-1 Electric Shaver & Grooming Kit by AsaVea pursuant to 35 U.S.C. § 271(a).
43. The claim chart attached hereto as Exhibit C describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Rayenbarny’s accused electric
shaver.
44. Rayenbarny’s accused electric shaver practices all of the limitations of claim 1 of
the ’528 patent. For example, Rayenbarny’s accused electric shaver comprises a housing for
containing an electrical source and drive-related components, said housing having a length and a
width, and including two substantially opposed and substantially parallel sides along said length,
said housing further including a bottom; a cutter mechanism located beneath said bottom of said
housing and spaced therefrom; a central hub extending from said bottom of said housing to said
cutter mechanism and connecting said cutter mechanism to said housing; said cutter mechanism
including a cutting surface defining a plane; a first pair of elongated recesses formed on said sides
of said housing, said first pair of elongated recesses being substantially parallel to each other and
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lying in a plane that is spaced apart from but parallel to the plane of said cutting surface, and a
second set of elongated spaced apart recesses formed in said bottom of said housing along said
width entirely, and extending upwardly into said bottom, said recesses of said second set being
located on opposite sides of said hub and extending perpendicular to said first pair of recesses.
45. Rayenbarny also indirectly infringes the ʼ528 patent by actively inducing the direct
infringement by third parties under 35 U.S.C. § 271(b). Rayenbarny has knowledge that its
activities concerning its accused Men’s 5-in-1 Electric Shaver & Grooming Kit by AsaVea
infringes one or more claims of the ’528 patent based on the patent marking Skull Shaver includes
on its product packaging and on its company website, and further based on at least the filing and
service of this Complaint. On information and belief, Rayenbarny is aware of the patent marking
Skull Shaver includes on its product packaging and on its company website based on Rayenbarny’s
manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers. On
information and belief, Rayenbarny will continue to encourage, aid, or otherwise cause third
parties to import, sell, offer for sale, and use the accused electric shaver (which are acts of direct
infringement of the ’528 patent) and Rayenbarny has and will continue to encourage those acts
with the specific intent to infringe one or more claims of the ’528 patent. Further, Rayenbarny
provides information and support to its customers, including at least product user manuals,
instructing its customers to use Rayenbarny’s accused electric shaver (which are acts of direct
infringement of the ’528 patent). Alternatively, Rayenbarny knows and/or will know that there is
a high probability that the importation, sale, offer for sale, and use of the accused electric shaver
constitutes direct infringement of the ’528 patent but took deliberate actions to avoid learning of
these facts.
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46. Rayenbarny also indirectly infringes the ʼ528 patent by contributing to the direct
infringement by third parties under 35 U.S.C. § 271(c). Rayenbarny has or will have knowledge
that its activities concerning the accused electric shaver indirectly infringe at least claim 1 of the
’528 patent based on the patent marking Skull Shaver includes on its product packaging and on its
company website, and further based on at least the filing and service of this Complaint. On
information and belief, Rayenbarny is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Rayenbarny’s manufacture, use, sale,
offer for sale, and/or importation of knock-off Electric Shavers. On information and belief,
Rayenbarny specifically designed and configured the accused electric shaver to be used by third
parties to directly infringe at least claim 1 of the ʼ528 patent. Moreover, on information and belief,
third parties have and will continue to use Rayenbarny’s accused electric shaver (which directly
infringes at least claim 1 of the ’528 patent) based on Rayenbarny’s ongoing activities, including
its support and provision of product user manuals. On information and belief, Rayenbarny’s
accused electric shavers have no substantial noninfringing uses. Further, Rayenbarny’s accused
electric shavers constitute a material part of the invention claimed in at least claim 1 of the ʼ528
patent.
47. Rayenbarny has engaged in deliberate and willful behavior with knowledge of the
’528 patent and knew or should have known that its actions constituted direct and/or indirect
infringement of the ’528 patent. Based on information and belief, such as Rayenbarny’s copying
of Skull Shavers products, including the design, look and feel and overall functionality,
Rayanbarny knew about the patented inventions embodied in Skull Shavers products such that
Rayenbarny acted with deliberate and willful behavior and deliberate indifference and willfully
infringed the ’528 patent.
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48. On information and belief, Rayenbarny’s accused electric shavers are available to
individuals throughout the United States and in the State of Texas, including in this District.
49. Skull Shaver has been damaged as the result of Rayenbarny’s infringement. Upon
information and belief, Rayenbarny will continue to infringe one or more claims of the ’528 patent
unless and until they are enjoined by this Court.
50. Rayenbarny has caused and will continue to cause Skull Shaver irreparable injury
and damage by infringing one or more claims of the ’528 patent. Skull Shaver will suffer further
irreparable injury, for which it has no adequate remedy at law, unless and until Rayenbarny is
enjoined from infringing the claims of the ’528 patent.
COUNT II
(Patent Infringement of United States Patent No. 8,726,528 by Bald Shaver)
this Complaint.
52. Bald Shaver has directly infringed, and continues to directly infringe, literally
testing, selling, offering for sale and/or importing into the United States Bald Shaver’s LK-1800
Shaver pursuant to 35 U.S.C. § 271(a).
53. The claim chart attached hereto as Exhibit D describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Bald Shaver’s accused electric
shaver.
54. Bald Shaver’s accused electric shaver practices all of the limitations of claim 1 of
the ’528 patent. For example, Bald Shaver’s accused electric shaver comprises a housing for
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55. Bald Shaver also indirectly infringes the ʼ528 patent by actively inducing the direct
infringement by third parties under 35 U.S.C. § 271(b). Bald Shaver has knowledge that its
activities concerning its accused LK-1800 Shaver by infringes one or more claims of the ’528
patent based on the patent marking Skull Shaver includes on its product packaging and on its
information and belief, Bald Shaver is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Bald Shaver’s manufacture, use, sale,
offer for sale, and/or importation of knock-off Electric Shavers. On information and belief, Bald
Shaver will continue to encourage, aid, or otherwise cause third parties to import, sell, offer for
sale, and use the accused electric shaver (which are acts of direct infringement of the ’528 patent)
and Bald Shaver has and will continue to encourage those acts with the specific intent to infringe
one or more claims of the ’528 patent. Further, Bald Shaver provides information and support to
its customers, including at least product user manuals, instructing its customers to use Bald
Shaver’s accused electric shaver (which are acts of direct infringement of the ’528 patent).
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Alternatively, Bald Shaver knows and/or will know that there is a high probability that the
importation, sale, offer for sale, and use of the accused electric shaver constitutes direct
infringement of the ’528 patent but took deliberate actions to avoid learning of these facts.
56. Bald Shaver also indirectly infringes the ʼ528 patent by contributing to the direct
infringement by third parties under 35 U.S.C. § 271(c). Bald Shaver has or will have knowledge
information and belief, Bald Shaver is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Bald Shaver’s manufacture, use, sale,
offer for sale, and/or importation of knock-off Electric Shavers. On information and belief, Bald
Shaver specifically designed and configured the accused electric shaver to be used by third parties
to directly infringe at least claim 1 of the ʼ528 patent. Moreover, on information and belief, third
parties have and will continue to use Bald Shaver’s accused electric shaver (which directly
infringes at least claim 1 of the ’528 patent) based on Bald Shaver’s ongoing activities, including
its support and provision of product user manuals. On information and belief, Bald Shaver’s
accused electric shavers have no substantial noninfringing uses. Further, Bald Shaver’s accused
patent.
57. Bald Shaver has engaged in deliberate and willful behavior with knowledge of the
infringement of the ’528 patent. Based on information and belief, such as Bald Shaver’s copying
of Skull Shavers products, including the design, look and feel and overall functionality, Bald
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Shaver knew about the patented inventions embodied in Skull Shavers products such that Bald
Shaver acted with deliberate and willful behavior and deliberate indifference and willfully
58. On information and belief, Bald Shaver’s accused electric shavers are available to
59. Skull Shaver has been damaged as the result of Bald Shaver’s infringement. Upon
information and belief, Bald Shaver will continue to infringe one or more claims of the ’528 patent
60. Bald Shaver has caused and will continue to cause Skull Shaver irreparable injury
irreparable injury, for which it has no adequate remedy at law, unless and until Bald Shaver is
COUNT III
(Patent Infringement of United States Patent No. 8,726,528 by Suzhou Kaidiya)
this Complaint.
62. Suzhou Kaidiya has directly infringed, and continues to directly infringe, literally
testing, selling, offering for sale and/or importing into the United States Suzhou Kaidiya’s Kibiy
Bald Head Shaver LED Mens Electric Shaving Razor by Digimator pursuant to 35 U.S.C. § 271(a).
63. The claim chart attached hereto as Exhibit E describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Suzhou Kaidiya’s accused
electric shaver.
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64. Suzhou Kaidiya’s accused electric shaver practices all of the limitations of claim 1
of the ’528 patent. For example, Suzhou Kaidiya’s accused electric shaver comprises a housing
for containing an electrical source and drive-related components, said housing having a length and
a width, and including two substantially opposed and substantially parallel sides along said length,
65. Suzhou Kaidiya also indirectly infringes the ʼ528 patent by actively inducing the
direct infringement by third parties under 35 U.S.C. § 271(b). Suzhou Kaidiya has knowledge that
its activities concerning its accused Kibiy Bald Head Shaver LED Mens Electric Shaving Razor
by Digimator infringes one or more claims of the ’528 patent based on the patent marking Skull
Shaver includes on its product packaging and on its company website, and further based on at least
the filing and service of this Complaint. On information and belief, Suzhou Kaidiya is aware of
the patent marking Skull Shaver includes on its product packaging and on its company website
based on Suzhou Kaidiya’s manufacture, use, sale, offer for sale, and/or importation of knock-off
Electric Shavers. On information and belief, Suzhou Kaidiya will continue to encourage, aid, or
otherwise cause third parties to import, sell, offer for sale, and use the accused electric shaver
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(which are acts of direct infringement of the ’528 patent) and Suzhou Kaidiya has and will continue
to encourage those acts with the specific intent to infringe one or more claims of the ’528 patent.
Further, Suzhou Kaidiya provides information and support to its customers, including at least
product user manuals, instructing its customers to use Suzhou Kaidiya’s accused electric shaver
(which are acts of direct infringement of the ’528 patent). Alternatively, Suzhou Kaidiya knows
and/or will know that there is a high probability that the importation, sale, offer for sale, and use
of the accused electric shaver constitutes direct infringement of the ’528 patent but took deliberate
actions to avoid learning of these facts.
66. Suzhou Kaidiya also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Suzhou Kaidiya has or will have
knowledge that its activities concerning the accused electric shaver indirectly infringe at least
claim 1 of the ’528 patent based on the patent marking Skull Shaver includes on its product
packaging and on its company website, and further based on at least the filing and service of this
Complaint. On information and belief, Suzhou Kaidiya is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Suzhou Kaidiya’s
information and belief, Suzhou Kaidiya specifically designed and configured the accused electric
shaver to be used by third parties to directly infringe at least claim 1 of the ʼ528 patent. Moreover,
on information and belief, third parties have and will continue to use Suzhou Kaidiya’s accused
electric shaver (which directly infringes at least claim 1 of the ’528 patent) based on Suzhou
Kaidiya’s ongoing activities, including its support and provision of product user manuals. On
information and belief, Suzhou Kaidiya’s accused electric shavers have no substantial
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noninfringing uses. Further, Suzhou Kaidiya’s accused electric shavers constitute a material part
of the invention claimed in at least claim 1 of the ʼ528 patent.
67. Suzhou Kaidiya has engaged in deliberate and willful behavior with knowledge of
the ’528 patent and knew or should have known that its actions constituted direct and/or indirect
infringement of the ’528 patent. Based on information and belief, such as Suzhou Kaidiya’s
copying of Skull Shavers products, including the design, look and feel and overall functionality,
Suzhou Kaidiya knew about the patented inventions embodied in Skull Shavers products such that
Suzhou Kaidiya acted with deliberate and willful behavior and deliberate indifference and willfully
68. On information and belief, Suzhou Kaidiya’s accused electric shavers are available
to individuals throughout the United States and in the State of Texas, including in this District.
69. Skull Shaver has been damaged as the result of Suzhou Kaidiya’s infringement.
Upon information and belief, Suzhou Kaidiya will continue to infringe one or more claims of the
’528 patent unless and until they are enjoined by this Court.
70. Suzhou Kaidiya has caused and will continue to cause Skull Shaver irreparable
injury and damage by infringing one or more claims of the ’528 patent. Skull Shaver will suffer
further irreparable injury, for which it has no adequate remedy at law, unless and until Suzhou
Kaidiya is enjoined from infringing the claims of the ’528 patent.
COUNT IV
(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Aiweilai)
this Complaint.
72. Shenzhen Aiweilai has directly infringed, and continues to directly infringe,
literally and/or under the doctrine of equivalents, one or more claims of the ’528 patent by making,
20
using, testing, selling, offering for sale and/or importing into the United States Teamyo 5D
Floating Deep Clean Head Shaver for Bald Men by Teamyo pursuant to 35 U.S.C. § 271(a).
73. The claim chart attached hereto as Exhibit F describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Shenzhen Aiweilai’s accused
electric shaver.
74. Shenzhen Aiweilai’s accused electric shaver practices all of the limitations of claim
1 of the ’528 patent. For example, Shenzhen Aiweilai’s accused electric shaver comprises a
housing for containing an electrical source and drive-related components, said housing having a
length and a width, and including two substantially opposed and substantially parallel sides along
said length, said housing further including a bottom; a cutter mechanism located beneath said
bottom of said housing and spaced therefrom; a central hub extending from said bottom of said
housing to said cutter mechanism and connecting said cutter mechanism to said housing; said
cutter mechanism including a cutting surface defining a plane; a first pair of elongated recesses
formed on said sides of said housing, said first pair of elongated recesses being substantially
parallel to each other and lying in a plane that is spaced apart from but parallel to the plane of said
cutting surface, and a second set of elongated spaced apart recesses formed in said bottom of said
housing along said width entirely, and extending upwardly into said bottom, said recesses of said
second set being located on opposite sides of said hub and extending perpendicular to said first
pair of recesses.
75. Shenzhen Aiweilai also indirectly infringes the ʼ528 patent by actively inducing the
direct infringement by third parties under 35 U.S.C. § 271(b). Shenzhen Aiweilai has knowledge
that its activities concerning its accused Teamyo 5D Floating Deep Clean Head Shaver for Bald
Men by Teamyo infringes one or more claims of the ’528 patent based on the patent marking Skull
21
Shaver includes on its product packaging and on its company website, and further based on at least
the filing and service of this Complaint. On information and belief, Shenzhen Aiweilai is aware
of the patent marking Skull Shaver includes on its product packaging and on its company website
based on Shenzhen Aiweilai’s manufacture, use, sale, offer for sale, and/or importation of knock-
off Electric Shavers. On information and belief, Shenzhen Aiweilai will continue to encourage,
aid, or otherwise cause third parties to import, sell, offer for sale, and use the accused electric
shaver (which are acts of direct infringement of the ’528 patent) and Shenzhen Aiweilai has and
will continue to encourage those acts with the specific intent to infringe one or more claims of the
’528 patent. Further, Shenzhen Aiweilai provides information and support to its customers,
including at least product user manuals, instructing its customers to use Shenzhen Aiweilai’s
accused electric shaver (which are acts of direct infringement of the ’528 patent). Alternatively,
Shenzhen Aiweilai’s knows and/or will know that there is a high probability that the importation,
sale, offer for sale, and use of the accused electric shaver constitutes direct infringement of the
’528 patent but took deliberate actions to avoid learning of these facts.
76. Shenzhen Aiweilai also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Shenzhen Aiweilai has or will have
Complaint. On information and belief, Shenzhen Aiweilai is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Shenzhen
Aiweilai’s manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers.
On information and belief, Shenzhen Aiweilai specifically designed and configured the accused
22
electric shaver to be used by third parties to directly infringe at least claim 1 of the ʼ528 patent.
Moreover, on information and belief, third parties have and will continue to use Shenzhen
Aiweilai’s accused electric shaver (which directly infringes at least claim 1 of the ’528 patent)
based on Shenzhen Aiweilai’s ongoing activities, including its support and provision of product
user manuals. On information and belief, Shenzhen Aiweilai’s accused electric shavers have no
substantial noninfringing uses. Further, Shenzhen Aiweilai’s accused electric shavers constitute a
material part of the invention claimed in at least claim 1 of the ʼ528 patent.
77. Shenzhen Aiweilai has engaged in deliberate and willful behavior with knowledge
of the ’528 patent and knew or should have known that its actions constituted direct and/or indirect
infringement of the ’528 patent. Based on information and belief, such as Shenzhen Aiweilai’s
Shenzhen Aiweilai knew about the patented inventions embodied in Skull Shavers products such
that Shenzhen Aiweilai acted with deliberate and willful behavior and deliberate indifference and
willfully infringed the ’528 patent.
78. On information and belief, Shenzhen Aiweilai’s accused electric shavers are
available to individuals throughout the United States and in the State of Texas, including in this
District.
79. Skull Shaver has been damaged as the result of Shenzhen Aiweilai’s infringement.
Upon information and belief, Shenzhen Aiweilai will continue to infringe one or more claims of
the ’528 patent unless and until they are enjoined by this Court.
80. Shenzhen Aiweilai has caused and will continue to cause Skull Shaver irreparable
23
further irreparable injury, for which it has no adequate remedy at law, unless and until Shenzhen
Aiweilai is enjoined from infringing the claims of the ’528 patent.
COUNT V
(Patent Infringement of United States Patent No. 8,726,528 by Wenzhou Wending)
this Complaint.
82. Wenzhou Wending has directly infringed, and continues to directly infringe,
using, testing, selling, offering for sale and/or importing into the United States PaiTree 5 in 1 Head
and Face Electric Rotary Shaver by Wenzhou Wending pursuant to 35 U.S.C. § 271(a).
83. The claim chart attached hereto as Exhibit G describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Wenzhou Wending’s accused
electric shaver.
84. Wenzhou Wending’s accused electric shaver practices all of the limitations of claim
1 of the ’528 patent. For example, Wenzhou Wending’s accused electric shaver comprises a
24
pair of recesses.
85. Wenzhou Wending also indirectly infringes the ʼ528 patent by actively inducing
the direct infringement by third parties under 35 U.S.C. § 271(b). Wenzhou Wending has
knowledge that its activities concerning its accused PaiTree 5 in 1 Head and Face Electric Rotary
Shaver by Paitree infringes one or more claims of the ’528 patent based on the patent marking
Skull Shaver includes on its product packaging and on its company website, and further based on
at least the filing and service of this Complaint. On information and belief, Wenzhou Wending is
aware of the patent marking Skull Shaver includes on its product packaging and on its company
website based on Wenzhou Wending’s manufacture, use, sale, offer for sale, and/or importation
of knock-off Electric Shavers. On information and belief, Wenzhou Wending will continue to
encourage, aid, or otherwise cause third parties to import, sell, offer for sale, and use the accused
electric shaver (which are acts of direct infringement of the ’528 patent) and Wenzhou Wending
has and will continue to encourage those acts with the specific intent to infringe one or more claims
of the ’528 patent. Further, Wenzhou Wending provides information and support to its customers,
including at least product user manuals, instructing its customers to use Wenzhou Wending’s
Wenzhou Wending knows and/or will know that there is a high probability that the importation,
sale, offer for sale, and use of the accused electric shaver constitutes direct infringement of the
’528 patent but took deliberate actions to avoid learning of these facts.
86. Wenzhou Wending also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Wenzhou Wending has or will have
25
Complaint. On information and belief, Wenzhou Wending is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Wenzhou
Wending’s manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers.
On information and belief, Wenzhou Wending specifically designed and configured the accused
Moreover, on information and belief, third parties have and will continue to use Wenzhou
Wending’s accused electric shaver (which directly infringes at least claim 1 of the ’528 patent)
based on Wenzhou Wending’s ongoing activities, including its support and provision of product
user manuals. On information and belief, Wenzhou Wending’s accused electric shavers have no
substantial noninfringing uses. Further, Wenzhou Wending’s accused electric shavers constitute
a material part of the invention claimed in at least claim 1 of the ʼ528 patent.
87. Wenzhou Wending has engaged in deliberate and willful behavior with knowledge
infringement of the ’528 patent. Based on information and belief, such as Wenzhou Wending’s
Wenzhou Wending knew about the patented inventions embodied in Skull Shavers products such
that Wenzhou Wending acted with deliberate and willful behavior and deliberate indifference and
26
88. On information and belief, Wenzhou Wending’s accused electric shavers are
District.
89. Skull Shaver has been damaged as the result of Wenzhou Wending’s infringement.
Upon information and belief, Wenzhou Wending will continue to infringe one or more claims of
90. Wenzhou Wending has caused and will continue to cause Skull Shaver irreparable
further irreparable injury, for which it has no adequate remedy at law, unless and until Wenzhou
Wending is enjoined from infringing the claims of the ’528 patent.
COUNT VI
(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Nukun)
this Complaint.
92. Shenzhen Nukun has directly infringed, and continues to directly infringe, literally
testing, selling, offering for sale and/or importing into the United States OriHea 5 in 1 Head
Shavers for Bald Men Electric Rotary Razor by OriHea pursuant to 35 U.S.C. § 271(a).
93. The claim chart attached hereto as Exhibit H describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Shenzhen Nukun’s accused
electric shaver.
94. Shenzhen Nukun’s accused electric shaver practices all of the limitations of claim
1 of the ’528 patent. For example, Shenzhen Nukun’s accused electric shaver comprises a housing
for containing an electrical source and drive-related components, said housing having a length and
27
a width, and including two substantially opposed and substantially parallel sides along said length,
95. Shenzhen Nukun also indirectly infringes the ʼ528 patent by actively inducing the
direct infringement by third parties under 35 U.S.C. § 271(b). Shenzhen Nukun has knowledge
that its activities concerning its accused OriHea 5 in 1 Head Shavers for Bald Men Electric Rotary
Razor by Shenzhen Nukun infringes one or more claims of the ’528 patent based on the patent
marking Skull Shaver includes on its product packaging and on its company website, and further
based on at least the filing and service of this Complaint. On information and belief, Shenzhen
Nukun is aware of the patent marking Skull Shaver includes on its product packaging and on its
company website based on Shenzhen Nukun’s manufacture, use, sale, offer for sale, and/or
importation of knock-off Electric Shavers. On information and belief, Shenzhen Nukun will
continue to encourage, aid, or otherwise cause third parties to import, sell, offer for sale, and use
the accused electric shaver (which are acts of direct infringement of the ’528 patent) and Shenzhen
Nukun has and will continue to encourage those acts with the specific intent to infringe one or
more claims of the ’528 patent. Further, Shenzhen Nukun provides information and support to its
28
customers, including at least product user manuals, instructing its customers to use Shenzhen
Nukun’s accused electric shaver (which are acts of direct infringement of the ’528 patent).
Alternatively, Shenzhen Nukun knows and/or will know that there is a high probability that the
96. Shenzhen Nukun also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Shenzhen Nukun has or will have
Complaint. On information and belief, Shenzhen Nukun is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Shenzhen Nukun’s
information and belief, Shenzhen Nukun specifically designed and configured the accused electric
shaver to be used by third parties to directly infringe at least claim 1 of the ʼ528 patent. Moreover,
on information and belief, third parties have and will continue to use Shenzhen Nukun’s accused
electric shaver (which directly infringes at least claim 1 of the ’528 patent) based on Shenzhen
Nukun’s ongoing activities, including its support and provision of product user manuals. On
information and belief, Shenzhen Nukun’s accused electric shavers have no substantial
noninfringing uses. Further, Shenzhen Nukun’s accused electric shavers constitute a material part
of the invention claimed in at least claim 1 of the ʼ528 patent.
97. Shenzhen Nukun has engaged in deliberate and willful behavior with knowledge of
the ’528 patent and knew or should have known that its actions constituted direct and/or indirect
29
infringement of the ’528 patent. Based on information and belief, such as Shenzhen Nukun’s
Shenzhen Nukun knew about the patented inventions embodied in Skull Shavers products such
that Shenzhen Nukun acted with deliberate and willful behavior and deliberate indifference and
98. On information and belief, Shenzhen Nukun’s accused electric shavers are
District.
99. Skull Shaver has been damaged as the result of Shenzhen Nukun’s infringement.
Upon information and belief, Shenzhen Nukun will continue to infringe one or more claims of the
’528 patent unless and until they are enjoined by this Court.
100. Shenzhen Nukun has caused and will continue to cause Skull Shaver irreparable
Nukun is enjoined from infringing the claims of the ’528 patent.
COUNT VII
(Patent Infringement of United States Patent No. 8,726,528 by Yiwu Xingye)
this Complaint.
102. Yiwu Xingye has directly infringed, and continues to directly infringe, literally
testing, selling, offering for sale and/or importing into the United States Yiwu Xingye’s Roziapro
Electric Razor for Men 6 in 1 Bald Head Shaver pursuant to 35 U.S.C. § 271(a).
30
103. The claim chart attached hereto as Exhibit I describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Yiwu Xingye’s accused
electric shaver.
104. Yiwu Xingye’s accused electric shaver practices all of the limitations of claim 1 of
the ’528 patent. For example, Yiwu Xingye’s accused electric shaver comprises a housing for
105. Yiwu Xingye also indirectly infringes the ʼ528 patent by actively inducing the
direct infringement by third parties under 35 U.S.C. § 271(b). Yiwu Xingye has knowledge that
its activities concerning its accused Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver
infringes one or more claims of the ’528 patent based on the patent marking Skull Shaver includes
on its product packaging and on its company website, and further based on at least the filing and
service of this Complaint. On information and belief, Yiwu Xingye is aware of the patent marking
Skull Shaver includes on its product packaging and on its company website based on Yiwu
31
Xingye’s manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers.
On information and belief, Yiwu Xingye will continue to encourage, aid, or otherwise cause third
parties to import, sell, offer for sale, and use the accused electric shaver (which are acts of direct
infringement of the ’528 patent) and Yiwu Xingye has and will continue to encourage those acts
with the specific intent to infringe one or more claims of the ’528 patent. Further, Yiwu Xingye
provides information and support to its customers, including at least product user manuals,
instructing its customers to use Yiwu Xingye’s accused electric shaver (which are acts of direct
infringement of the ’528 patent). Alternatively, Yiwu Xingye knows and/or will know that there
is a high probability that the importation, sale, offer for sale, and use of the accused electric shaver
constitutes direct infringement of the ’528 patent but took deliberate actions to avoid learning of
these facts.
106. Yiwu Xingye also indirectly infringes the ʼ528 patent by contributing to the direct
infringement by third parties under 35 U.S.C. § 271(c). Yiwu Xingye has or will have knowledge
information and belief, Yiwu Xingye is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Yiwu Xingye’s manufacture, use, sale,
offer for sale, and/or importation of knock-off Electric Shavers. On information and belief, Yiwu
Xingye specifically designed and configured the accused electric shaver to be used by third parties
to directly infringe at least claim 1 of the ʼ528 patent. Moreover, on information and belief, third
parties have and will continue to use Yiwu Xingye’s accused electric shaver (which directly
infringes at least claim 1 of the ’528 patent) based on Yiwu Xingye’s ongoing activities, including
32
its support and provision of product user manuals. On information and belief, Yiwu Xingye’s
accused electric shavers have no substantial noninfringing uses. Further, Yiwu Xingye’s accused
patent.
107. Yiwu Xingye has engaged in deliberate and willful behavior with knowledge of the
infringement of the ’528 patent. Based on information and belief, such as Yiwu Xingye’s copying
of Skull Shavers products, including the design, look and feel and overall functionality, Yiwu
Xingye knew about the patented inventions embodied in Skull Shavers products such that Yiwu
Xingye acted with deliberate and willful behavior and deliberate indifference and willfully
108. On information and belief, Yiwu Xingye’s accused electric shavers are available to
109. Skull Shaver has been damaged as the result of Yiwu Xingye’s infringement. Upon
information and belief, Yiwu Xingye will continue to infringe one or more claims of the ’528
patent unless and until they are enjoined by this Court.
110. Yiwu Xingye has caused and will continue to cause Skull Shaver irreparable
further irreparable injury, for which it has no adequate remedy at law, unless and until Yiwu
Xingye is enjoined from infringing the claims of the ’528 patent.
COUNT VIII
(Patent Infringement of United States Patent No. 8,726,528 by Magicfly)
this Complaint.
33
112. Magicfly has directly infringed, and continues to directly infringe, literally and/or
under the doctrine of equivalents, one or more claims of the ’528 patent by making, using, testing,
selling, offering for sale and/or importing into the United States Magicfly’s Rechargeable
Waterproof Shaver for Women pursuant to 35 U.S.C. § 271(a).
113. The claim chart attached hereto as Exhibit J describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Magicfly’s accused electric
shaver.
114. Magicfly’s accused electric shaver practices all of the limitations of claim 1 of the
’528 patent. For example, Magicfly’s accused electric shaver comprises a housing for containing
an electrical source and drive-related components, said housing having a length and a width, and
including two substantially opposed and substantially parallel sides along said length, said housing
further including a bottom; a cutter mechanism located beneath said bottom of said housing and
spaced therefrom; a central hub extending from said bottom of said housing to said cutter
mechanism and connecting said cutter mechanism to said housing; said cutter mechanism
115. Magicfly also indirectly infringes the ʼ528 patent by actively inducing the direct
infringement by third parties under 35 U.S.C. § 271(b). Magicfly has knowledge that its activities
concerning its accused Rechargeable Waterproof Shaver for Women infringes one or more claims
34
of the ’528 patent based on the patent marking Skull Shaver includes on its product packaging and
on its company website, and further based on at least the filing and service of this Complaint. On
information and belief, Magicfly is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Magicfly’s manufacture, use, sale, offer
for sale, and/or importation of knock-off Electric Shavers. On information and belief, Magicfly
will continue to encourage, aid, or otherwise cause third parties to import, sell, offer for sale, and
use the accused electric shaver (which are acts of direct infringement of the ’528 patent) and
Magicfly has and will continue to encourage those acts with the specific intent to infringe one or
more claims of the ’528 patent. Further, Magicfly provides information and support to its
customers, including at least product user manuals, instructing its customers to use Magicfly’s
Magicfly knows and/or will know that there is a high probability that the importation, sale, offer
for sale, and use of the accused electric shaver constitutes direct infringement of the ’528 patent
but took deliberate actions to avoid learning of these facts.
116. Magicfly also indirectly infringes the ʼ528 patent by contributing to the direct
infringement by third parties under 35 U.S.C. § 271(c). Magicfly has or will have knowledge that
its activities concerning the accused electric shaver indirectly infringe at least claim 1 of the ’528
patent based on the patent marking Skull Shaver includes on its product packaging and on its
information and belief, Magicfly is aware of the patent marking Skull Shaver includes on its
product packaging and on its company website based on Magicfly’s manufacture, use, sale, offer
for sale, and/or importation of knock-off Electric Shavers. On information and belief, Magicfly
specifically designed and configured the accused electric shaver to be used by third parties to
35
directly infringe at least claim 1 of the ʼ528 patent. Moreover, on information and belief, third
parties have and will continue to use Magicfly’s accused electric shaver (which directly infringes
at least claim 1 of the ’528 patent) based on Magicfly’s ongoing activities, including its support
and provision of product user manuals. On information and belief, Magicfly’s accused electric
shavers have no substantial noninfringing uses. Further, Magicfly’s accused electric shavers
constitute a material part of the invention claimed in at least claim 1 of the ʼ528 patent.
117. Magicfly has engaged in deliberate and willful behavior with knowledge of the ’528
patent and knew or should have known that its actions constituted direct and/or indirect
infringement of the ’528 patent. Based on information and belief, such as Magicfly’s copying of
Skull Shavers products, including the design, look and feel and overall functionality, Magicfly
knew about the patented inventions embodied in Skull Shavers products such that Magicfly acted
with deliberate and willful behavior and deliberate indifference and willfully infringed the ’528
patent.
118. On information and belief, Magicfly’s accused electric shavers are available to
119. Skull Shaver has been damaged as the result of Magicfly’s infringement. Upon
information and belief, Magicfly will continue to infringe one or more claims of the ’528 patent
120. Magicfly has caused and will continue to cause Skull Shaver irreparable injury
irreparable injury, for which it has no adequate remedy at law, unless and until Magicfly is
36
COUNT IX
(Patent Infringement of United States Patent No. 8,726,528 by Yiwu City)
this Complaint.
122. Yiwu City has directly infringed, and continues to directly infringe, literally and/or
under the doctrine of equivalents, one or more claims of the ’528 patent by making, using, testing,
selling, offering for sale and/or importing into the United States Yiwu City’s Surker 6 in 1 Electric
Shavers for Men Bald Head pursuant to 35 U.S.C. § 271(a).
123. The claim chart attached hereto as Exhibit K describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Yiwu City’s accused electric
shaver.
124. Yiwu City’s accused electric shaver practices all of the limitations of claim 1 of the
’528 patent. For example, Yiwu City’s accused electric shaver comprises a housing for containing
an electrical source and drive-related components, said housing having a length and a width, and
including two substantially opposed and substantially parallel sides along said length, said housing
further including a bottom; a cutter mechanism located beneath said bottom of said housing and
spaced therefrom; a central hub extending from said bottom of said housing to said cutter
mechanism and connecting said cutter mechanism to said housing; said cutter mechanism
37
125. Yiwu City also indirectly infringes the ʼ528 patent by actively inducing the direct
infringement by third parties under 35 U.S.C. § 271(b). Yiwu City has knowledge that its activities
concerning its accused Surker 6 in 1 Electric Shavers for Men Bald Head infringes one or more
claims of the ’528 patent based on the patent marking Skull Shaver includes on its product
Complaint. On information and belief, Yiwu City is aware of the patent marking Skull Shaver
includes on its product packaging and on its company website based on Yiwu City’s manufacture,
use, sale, offer for sale, and/or importation of knock-off Electric Shavers. On information and
belief, Yiwu City will continue to encourage, aid, or otherwise cause third parties to import, sell,
offer for sale, and use the accused electric shaver (which are acts of direct infringement of the ’528
patent) and Yiwu City has and will continue to encourage those acts with the specific intent to
infringe one or more claims of the ’528 patent. Further, Yiwu City provides information and
support to its customers, including at least product user manuals, instructing its customers to use
Yiwu City’s accused electric shaver (which are acts of direct infringement of the ’528 patent).
Alternatively, Yiwu City knows and/or will know that there is a high probability that the
126. Yiwu City also indirectly infringes the ʼ528 patent by contributing to the direct
infringement by third parties under 35 U.S.C. § 271(c). Yiwu City has or will have knowledge
information and belief, Yiwu City is aware of the patent marking Skull Shaver includes on its
38
product packaging and on its company website based on Yiwu City’s manufacture, use, sale, offer
for sale, and/or importation of knock-off Electric Shavers. On information and belief, Yiwu City
specifically designed and configured the accused electric shaver to be used by third parties to
directly infringe at least claim 1 of the ʼ528 patent. Moreover, on information and belief, third
parties have and will continue to use Yiwu City’s accused electric shaver (which directly infringes
at least claim 1 of the ’528 patent) based on Yiwu City’s ongoing activities, including its support
and provision of product user manuals. On information and belief, Yiwu City’s accused electric
shavers have no substantial noninfringing uses. Further, Yiwu City’s accused electric shavers
constitute a material part of the invention claimed in at least claim 1 of the ʼ528 patent.
127. Yiwu City has engaged in deliberate and willful behavior with knowledge of the
infringement of the ’528 patent. Based on information and belief, such as Yiwu City’s copying of
Skull Shavers products, including the design, look and feel and overall functionality, Yiwu City
knew about the patented inventions embodied in Skull Shavers products such that Yiwu City acted
with deliberate and willful behavior and deliberate indifference and willfully infringed the ’528
patent.
128. On information and belief, Yiwu City’s accused electric shavers are available to
129. Skull Shaver has been damaged as the result of Yiwu City’s infringement. Upon
information and belief, Yiwu City will continue to infringe one or more claims of the ’528 patent
130. Yiwu City has caused and will continue to cause Skull Shaver irreparable injury
39
irreparable injury, for which it has no adequate remedy at law, unless and until Yiwu City is
COUNT X
(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Wantong)
this Complaint.
132. Shenzhen Wantong has directly infringed, and continues to directly infringe,
using, testing, selling, offering for sale and/or importing into the United States Shenzhen
Wantong’s Electric Razor Grooming Kit for Men 4 in 1 Dry Wet Waterproof Rotary Bald Head
Shaver by WTONG pursuant to 35 U.S.C. § 271(a).
133. The claim chart attached hereto as Exhibit L describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Shenzhen Wantong’s accused
electric shaver.
134. Shenzhen Wantong’s accused electric shaver practices all of the limitations of claim
1 of the ’528 patent. For example, Shenzhen Wantong’s accused electric shaver comprises a
40
pair of recesses.
135. Shenzhen Wantong also indirectly infringes the ʼ528 patent by actively inducing
the direct infringement by third parties under 35 U.S.C. § 271(b). Shenzhen Wantong has
knowledge that its activities concerning its accused Electric Razor Grooming Kit for Men 4 in 1
Dry Wet Waterproof Rotary Bald Head Shaver by WTONG infringes one or more claims of the
information and belief, Shenzhen Wantong is aware of the patent marking Skull Shaver includes
on its product packaging and on its company website based on Shenzhen Wantong’s manufacture,
use, sale, offer for sale, and/or importation of knock-off Electric Shavers. On information and
belief, Shenzhen Wantong will continue to encourage, aid, or otherwise cause third parties to
import, sell, offer for sale, and use the accused electric shaver (which are acts of direct
infringement of the ’528 patent) and Shenzhen Wantong has and will continue to encourage those
acts with the specific intent to infringe one or more claims of the ’528 patent. Further, Shenzhen
Wantong provides information and support to its customers, including at least product user
manuals, instructing its customers to use Shenzhen Wantong’s accused electric shaver (which are
acts of direct infringement of the ’528 patent). Alternatively, Shenzhen Wantong knows and/or
will know that there is a high probability that the importation, sale, offer for sale, and use of the
accused electric shaver constitutes direct infringement of the ’528 patent but took deliberate
41
136. Shenzhen Wantong also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Shenzhen Wantong has or will have
Complaint. On information and belief, Shenzhen Wantong is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Shenzhen
Wantong’s manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers.
On information and belief, Shenzhen Wantong specifically designed and configured the accused
Wantong’s accused electric shaver (which directly infringes at least claim 1 of the ’528 patent)
based on Shenzhen Wantong’s ongoing activities, including its support and provision of product
user manuals. On information and belief, Shenzhen Wantong’s accused electric shavers have no
substantial noninfringing uses. Further, Shenzhen Wantong’s accused electric shavers constitute
a material part of the invention claimed in at least claim 1 of the ʼ528 patent.
137. Shenzhen Wantong has engaged in deliberate and willful behavior with knowledge
infringement of the ’528 patent. Based on information and belief, such as Shenzhen Wantong’s
Shenzhen Wantong knew about the patented inventions embodied in Skull Shavers products such
that Shenzhen Wantong acted with deliberate and willful behavior and deliberate indifference and
42
138. On information and belief, Shenzhen Wantong’s accused electric shavers are
District.
139. Skull Shaver has been damaged as the result of Shenzhen Wantong’s infringement.
Upon information and belief, Shenzhen Wantong will continue to infringe one or more claims of
140. Shenzhen Wantong has caused and will continue to cause Skull Shaver
irreparable injury and damage by infringing one or more claims of the ’528 patent. Skull Shaver
will suffer further irreparable injury, for which it has no adequate remedy at law, unless and until
Shenzhen Wantong is enjoined from infringing the claims of the ’528 patent.
COUNT XI
(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Junmao)
this Complaint.
142. Shenzhen Junmao has directly infringed, and continues to directly infringe, literally
testing, selling, offering for sale and/or importing into the United States Shenzhen Junmao’s
Homeasy Men Electric Razor Bald Head Shaver pursuant to 35 U.S.C. § 271(a).
143. The claim chart attached hereto as Exhibit M describes and demonstrates how the
elements of exemplary claim 1 from the ’528 patent are practiced by Shenzhen Junmao’s accused
electric shaver.
144. Shenzhen Junmao’s accused electric shaver practices all of the limitations of claim
1 of the ’528 patent. For example, Shenzhen Junmao’s accused electric shaver comprises a
43
pair of recesses.
145. Shenzhen Junmao also indirectly infringes the ʼ528 patent by actively inducing the
direct infringement by third parties under 35 U.S.C. § 271(b). Shenzhen Junmao has knowledge
that its activities concerning its accused Homeasy Men Electric Razor Bald Head Shaver infringes
one or more claims of the ’528 patent based on the patent marking Skull Shaver includes on its
product packaging and on its company website, and further based on at least the filing and service
of this Complaint. On information and belief, Shenzhen Junmao is aware of the patent marking
Skull Shaver includes on its product packaging and on its company website based on Shenzhen
Junmao’s manufacture, use, sale, offer for sale, and/or importation of knock-off Electric Shavers.
On information and belief, Shenzhen Junmao will continue to encourage, aid, or otherwise cause
third parties to import, sell, offer for sale, and use the accused electric shaver (which are acts of
direct infringement of the ’528 patent) and Shenzhen Junmao has and will continue to encourage
those acts with the specific intent to infringe one or more claims of the ’528 patent. Further,
44
Shenzhen Junmao provides information and support to its customers, including at least product
user manuals, instructing its customers to use Shenzhen Junmao’s accused electric shaver (which
are acts of direct infringement of the ’528 patent). Alternatively, Shenzhen Junmao knows and/or
will know that there is a high probability that the importation, sale, offer for sale, and use of the
accused electric shaver constitutes direct infringement of the ’528 patent but took deliberate
146. Shenzhen Junmao also indirectly infringes the ʼ528 patent by contributing to the
direct infringement by third parties under 35 U.S.C. § 271(c). Shenzhen Junmao has or will have
Complaint. On information and belief, Shenzhen Junmao is aware of the patent marking Skull
Shaver includes on its product packaging and on its company website based on Shenzhen Junmao’s
information and belief, Shenzhen Junmao specifically designed and configured the accused
Junmao’s accused electric shaver (which directly infringes at least claim 1 of the ’528 patent)
based on Shenzhen Junmao’s ongoing activities, including its support and provision of product
user manuals. On information and belief, Shenzhen Junmao’s accused electric shavers have no
substantial noninfringing uses. Further, Shenzhen Junmao’s accused electric shavers constitute a
material part of the invention claimed in at least claim 1 of the ʼ528 patent.
45
147. Shenzhen Junmao has engaged in deliberate and willful behavior with knowledge
infringement of the ’528 patent. Based on information and belief, such as Shenzhen Junmao’s
Shenzhen Junmao knew about the patented inventions embodied in Skull Shavers products such
that Shenzhen Junmao acted with deliberate and willful behavior and deliberate indifference and
148. On information and belief, Shenzhen Junmao’s accused electric shavers are
District.
149. Skull Shaver has been damaged as the result of Shenzhen Junmao’s infringement.
Upon information and belief, Shenzhen Junmao will continue to infringe one or more claims of
150. Shenzhen Junmao has caused and will continue to cause Skull Shaver irreparable
Junmao is enjoined from infringing the claims of the ’528 patent.
COUNT XII
(Patent Infringement of United States Design Patent No. D672,504 by Yiwu Xingye)
this Complaint.
152. In contravention of 35 U.S.C. §§ 271 and 289, Yiwu Xingye has willfully and
deliberately infringed the ’504 patent by making, using, testing, selling, offering for sale and/or
importing into the United States, or causing others to make, use, test, sell, offer for sale and/or
46
import into the United States Yiwu Xingye’s Roziapro Electric Razor for Men 6 in 1 Bald Head
Shaver.
153. The claim chart attached hereto as Exhibit N demonstrates how Yiwu Xingye’s
accused electric shaver embodies the invention claimed in the ’504 patent.
154. Yiwu Xingye’s accused electric shavers are relatively inexpensive costing only
about $39.99. On information and belief, Yiwu Xingye’s accused electric shavers are sold only
through online retail channels, and are not available in stores. As a result of the manner in which
Yiwu Xingye’s accused electric shavers are sold, a prospective consumer does not have an
opportunity to closely examine the same. He or she can see only what is shown online.
155. The overall appearance of Yiwu Xingye’s accused electric shaver is substantially
the same as the claimed design in the ’504 patent or is at least a colorable imitation thereof. By
way of example, both designs have an essentially rounded and flat-topped shaver housings, and
both designs have elongated and concave recesses along the sides and bottom of the shaver
housings.
156. The ordinary observer, seeing Yiwu Xingye’s accused electric shaver online, would
be deceived into believing that Yiwu Xingye’s accused electric shaver is the same as the patented
design.
157. On information and belief, Yiwu Xingye’s accused electric shavers are available to
158. Yiwu Xingye has engaged in deliberate and willful behavior with knowledge of the
’504 patent and knew or should have known that its actions constituted infringement of the ’504
patent. Based on information and belief, such as Yiwu Xingye’s copying of Skull Shavers
products, including the design, look and feel and overall functionality, Yiwu Xingye knew about
47
the patented inventions embodied in Skull Shavers products such that Yiwu Xingye acted with
deliberate and willful behavior and deliberate indifference and willfully infringed the ’504 patent.
159. Skull Shaver has been damaged as the result of Yiwu Xingye’s infringement. Upon
information and belief, Yiwu Xingye will continue to infringe the ’504 patent unless and until they
are enjoined by this Court.
160. Yiwu Xingye has caused and will continue to cause Skull Shaver irreparable injury
and damage by infringing the ’504 patent. Skull Shaver will suffer further irreparable injury, for
which it has no adequate remedy at law, unless and until Yiwu Xingye is enjoined from infringing
the ’504 patent.
COUNT XIII
(Patent Infringement of United States Design Patent No. D672,504 by Yiwu City)
this Complaint.
162. In contravention of 35 U.S.C. §§ 271 and 289, Yiwu City has willfully and
deliberately infringed the ’504 patent by making, using, testing, selling, offering for sale and/or
importing into the United States, or causing others to make, use, test, sell, offer for sale and/or
import into the United States Yiwu City’s Surker 6 in 1 Electric Shavers for Men Bald Head.
163. The claim chart attached hereto as Exhibit O demonstrates how Yiwu City’s
accused electric shaver embodies the invention claimed in the ’504 patent.
164. Yiwu City’s accused electric shavers are relatively inexpensive costing only about
$39.99. On information and belief, Yiwu City’s accused electric shavers are sold only through
online retail channels, and are not available in stores. As a result of the manner in which Yiwu
City’s accused electric shavers are sold, a prospective consumer does not have an opportunity to
closely examine the same. He or she can see only what is shown online.
48
165. The overall appearance of Yiwu City’s accused electric shaver is substantially the
same as the claimed design in the ’504 patent or is at least a colorable imitation thereof. By way
of example, both designs have an essentially rounded and flat-topped shaver housings, and both
designs have elongated and concave recesses along the sides and bottom of the shaver housings.
166. The ordinary observer, seeing Yiwu City’s accused electric shaver online, would
be deceived into believing that Yiwu City’s accused electric shaver is the same as the patented
design.
167. On information and belief, Yiwu City’s accused electric shavers are available to
168. Yiwu City has engaged in deliberate and willful behavior with knowledge of the
’504 patent and knew or should have known that its actions constituted infringement of the ’504
patent. Based on information and belief, such as Yiwu City’s copying of Skull Shavers products,
including the design, look and feel and overall functionality, Yiwu City knew about the patented
inventions embodied in Skull Shavers products such that Yiwu City acted with deliberate and
willful behavior and deliberate indifference and willfully infringed the ’504 patent.
169. Skull Shaver has been damaged as the result of Yiwu City’s infringement. Upon
information and belief, Yiwu City will continue to infringe the ’504 patent unless and until they
are enjoined by this Court.
170. Yiwu City has caused and will continue to cause Skull Shaver irreparable injury
and damage by infringing the ’504 patent. Skull Shaver will suffer further irreparable injury, for
which it has no adequate remedy at law, unless and until Yiwu City is enjoined from infringing
the ’504 patent.
49
PRAYER FOR RELIEF
Wherefore, Plaintiff Skull Shaver respectfully requests that this Court:
A. Enter judgment that Defendants Rayenbarny, Bald Shaver, Suzhou Kaidiya,
Shenzhen Aiweilai, Wenzhou Wending, Shenzhen Nukun, Yiwu Xingye, Magicfly, Yiwu City,
Shenzhen Wantong, and Shenzhen Junmao have infringed one or more claims of the ’528 patent;
B. Enter judgment that Defendants Yiwu Xingye and Yiwu City have infringed the
’504 patent;
C. Enter an order for equitable relief under 35 U.S.C. § 283, including, but not limited
to, an injunction that enjoins Defendants and their officers, agents, employees, attorneys, and all
persons in active concert or participation with any of the foregoing, from infringing the claims of
the Asserted Patents;
D. Award Skull Shaver damages in an amount sufficient to compensate it for
Defendants’ infringement of one or more claims of the Asserted Patents, together with
prejudgment and post-judgment interest costs, and all other damages permitted under 35 U.S.C. §
284;
E. Perform an accounting of each Defendants’ infringing activities through trial and
judgment;
F. Treble the damages awarded to Skull Shaver under 35 U.S.C. § 284 by reason of
each Defendants’ willful infringement of the Asserted Patents;
G. Declare this case to be “exceptional” under 35 U.S.C. § 285 and award Skull Shaver
its attorneys’ fees, expenses, and costs incurred in this action;
50
H. Enter judgment pursuant to 35 U.S.C. § 289 requiring Defendants to pay to Skull
Shaver the extent of Defendants’ total profits realized and derived from their infringement of the
Asserted Patents; and
I. Award Skill Shaver such other and further relief as this Court deems just and
proper.
DEMAND FOR JURY TRIAL
Plaintiff Skull Shaver hereby demands a trial by jury on all issues so triable.
Dated: October 13, 2020 Respectfully submitted,
FISH & RICHARDSON P.C.
By: /s/ Betty Chen

Betty Chen
Texas Bar No. 24056720 | bchen@fr.com
Fish & Richardson P.C.
One Congress Plaza, Suite 810
Austin, TX 78701
Tel: 512-472-5070 | Fax: 512-320-8935
Benjamin C. Elacqua
Texas Bar No. 24055443 | elacqua@fr.com
1221 McKinney Street, Suite 2800
Houston, TX 77010
Tel: 713-654-5300 | Fax: 713-652-0109
Thomas S. Fusco (to be admitted)

DC Bar No. 1007209 | fusco@fr.com
Tracea Rice (to be admitted)
Virginia Bar No. 95239 | trice@fr.com
1000 Maine Ave, S.W., 10th Floor
Washington, DC 20024
Tel: 202-783-5070 | Fax: 202-783-2331
Jeremy T. Saks (to be admitted)

NY Reg. No. 5302542 | saks@fr.com
51

7 Times Square, 20th Floor
New York, NY 10036
Tel: 212-765-5070 | Fax: 212-258-2291
Attorneys for Plaintiff Skull Shaver, LLC
52
JS 44 (Rev. 10/20) Case 6:20-cv-00951 Document
CIVIL COVER 1-1 SHEET
Filed 10/13/20 Page 1 of 2
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 the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Rayenbarny Inc., Bald Shaver Inc., Suzhou Kaidiya
Skull Shaver, LLC
Garments Trading Co., Ltd., et al.
(b) County of Residence of First Listed Plaintiff Burlington (NJ) County of Residence of First Listed Defendant New York (NY)
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Betty Chen, Fish & Richardson P.C., One Congress

Plaza, Suite 810, Austin, TX 78701, 512-472-5070
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government ✖ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
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✖ 1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
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(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. § 271
VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ✖ Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
Oct 13, 2020 Betty Chen Digitally signed by Betty Chen
Date: 2020.10.13 16:51:15 -07'00'
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

JS 44 Reverse (Rev. 10/20) Case 6:20-cv-00951 Document 1-1 Filed 10/13/20 Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
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Date and Attorney Signature. Date and sign the civil cover sheet.
Case 6:20-cv-00951 Document 1-2 Filed 10/13/20 Page 1 of 10
USOO8726528B2
(12) United States Patent (10) Patent No.: US 8,726,528 B2

Lyles (45) Date of Patent: May 20, 2014
(54) ELECTRIC HEAD SHAVER 4,709.475 A * 12/1987 Phung ............................... 30/31
5,520,616 A 5/1996 Hofmeister
6,018,877 A * 2/2000 Greene ........................... 30.526
(75) Inventor: John Lyles, Cherry Hill, NJ (US) 6,550,148 B2 * 4/2003 Cecil ............................... 30.526
D601,301 S * 9/2009 Bao ... ... D28.50
(73) Assignee: Skull Shaver, LLC, Mount Holly, NJ 2005/0246906 A1* 11/2005 Greene ........................... 3O/527
(US) 2008/0072430 A1 3/2008 Cafaro et al. ..................... 3Of 45
2008/0092393 A1* 4, 2008 Van Der Meer ... ... 30/43.6
(*) Notice: Subject to any disclaimer, the term of this 2009/0025234 A1 1/2009 Carlucci ......................... 3O/527
patent is extended or adjusted under 35 2011/003O220 A1 2/2011 Shimizu ......................... 30, 43.6
U.S.C. 154(b) by 310 days. FOREIGN PATENT DOCUMENTS
(21) Appl. No.: 13/136,692 DE 3320290 A1 * 12/1984
(22) Filed: Aug. 8, 2011 * cited by examiner
(65) Prior Publication Data
US 2013/0212885 A1 Aug. 22, 2013 Primary Examiner — Ghassem Alie
Assistant Examiner — Bharat C Patel
(51) Int. Cl.
B26B 27/00 (2006.01)
(74) Attorney,y Agent,y or Firm — Norman E. Lehrer
B26B 2/00 (2006.01)
(52) U.S. Cl. (57) ABSTRACT
USPC ............................................... 30/526:30/298
(58) Field of Classification Search An electric shaver includes a housing and a cutter head
USPC .................... 30/526–529,539, 43.6-46, 298; extending down from the housing. The housing contains the
D28750 motor and is shaped to provide a grip that includes a pair of
See application file for complete search history. concave surfaces on the sides. An additional pair of concave
surfaces is formed in the undersurface of the housing that
(56) References Cited accommodates the backs of the user's fingers when the cutter
U.S. PATENT DOCUMENTS head is held for shaving.
2,279.682. A * 4, 1942 Jackson ....... ... 30/43.6

2,720,696 A * 10, 1955 Wadsworth .................... 30, 41.5 3 Claims, 6 Drawing Sheets
110 -o
114
U.S. Patent May 20, 2014 Sheet 1 of 6 US 8,726,528 B2
110 to
114
Figure 1
110
Figure 2
110 1
vary v AAA tia
116
Figure 3
124
118
Figure 4
Figure 5
124
118
US 8,726,528 B2
1. 2
ELECTRICHEAD SHAVER BRIEF DESCRIPTION OF THE DRAWINGS
BACKGROUND OF THE INVENTION For the purpose of illustrating the invention, there is shown
in the accompanying drawings one form that is presently
The present invention is directed toward electric shavers 5 preferred; it being understood that the invention is not
and, more particularly, toward electric shavers for shaving intended to be limited to the precise arrangements and instru
hair on curved parts of the body, specifically, the head. mentalities shown.
Electric shavers generally include a hand-held housing that FIG. 1 is a front top perspective view of an electric head
contains motor and power Supply-related components that razor of the invention;
drive one or more cutters or cutting heads. The housing also 10 FIG. 2 is a bottom perspective view of the razor of FIG. 1;
provides a form that fits the user's hand Sufficiently as a grip FIG. 3 is an end elevational view thereof;
So as to allow the user to manipulate the shaver, especially FIG. 4 is a top perspective view of the electric head razor
when reaching upward to shave the head. Various types of illustrating one way of holding the same to shave one's head;
cutters are well known in the art. In general, the cutter com FIG. 5 is a top perspective view of the electric head razor
prises an outer, stationary, apertured surface and an inner 15 illustrating a second way of holding the same to shave one’s
array of reciprocating or rotating blades that operate in a head, and
shearing engagement with the outer apertured Surface. The FIG. 6 is a top perspective view of the electric head razor
motor is mechanically coupled to the cutter and provides illustrating a third way of holding the same.
motion to the array of blades. Hairs that extend through the
apertures in the outer surface are sheared by the inner array of DETAILED DESCRIPTION OF THE PREFERRED
blades. EMBODIMENT
The present disclosure relates to such electric shavers and
particularly to compact electric shavers of a particular struc A more complete understanding of the components, pro
ture, specifically to agrip configuration and housing form that cesses, and apparatuses disclosed herein can be obtained by
is appropriately Suited for shaving curved portions of the 25 reference to the accompanying figures. These figures are
body, especially the head. intended to demonstrate the present disclosure and are not
intended to show relative sizes and dimensions or to limit the
SUMMARY OF THE INVENTION Scope of the exemplary embodiments.
Although specific terms are used in the following descrip
The present disclosure relates to features that are particular 30 tion, these terms are intended to refer only to particular struc
to the shaving of the head, though not in a limiting manner. As tures in the drawings and are not intended to limit the scope of
understood by one skilled in the art, the principles of an the present disclosure. It is to be understood that like numeric
electric shaver are not restricted to the shaving of a specific designations refer to components of like function.
part of the body, and may apply to any skin Surface. Electric The term “about when used with a quantity includes the
shavers designed more particularly for shaving the face have 35 stated value and also has the meaning dictated by the context.
a grip portion that is configured, predominantly, to be held in For example, it includes at least the degree of error associated
Such a manner so as to orient the grip below the cutting with the measurement of the particular quantity. When used in
surface. Shaving the head, however, requires the shaver to be the context of a range, the term “about should also be con
held in Such a manner so as to orient the grip above the cutting sidered as disclosing the range defined by the absolute values
surface. Note, for example, Published Application No. 2009/ 40 of the two endpoints. For example, the range “from about 2 to
0025234 to Carlucci and, particularly, FIGS. 7 and 8 thereof. about 4' also discloses the range “from 2 to 4.
An example embodiment relates in general to an electric In one embodiment, the present disclosure relates to a
shaver comprising a housing that provides a container for the shaver that comprises a gripping means and a cutting means,
motor and power source components and further provides a configured in Such a manner that allows the shaver to be
form, also referred to as a grip, that fits the hand in a com 45 oriented with the grip portion above the cutter portion, thus
fortable manner when the shaver is oriented with the grip making it anatomically convenient to hold the shaver against
above the cutter surface. In other words, in this orientation the the top and sides of the head.
cutter faces downward so as to meet the skin surface of the Referring now to the drawings in detail wherein like refer
Scalp, and the grip is above the cutter. The cutter Surface may ence numerals have been used throughout the various figures
comprise flexible members that allow the cutter surface to 50 to designate like elements, there is shown in FIGS. 1-6 an
meet the complex curvilinear surface of the head. The grip electric head razor constructed in accordance with the prin
portion of the housing comprises a pair of Substantially con ciples of the present invention and designated generally as
cave surfaces each comprising a central axis that is parallel to 1OO.
the cutter Surface and, therefore, tangent to the curved surface As pointed out above, FIG. 1 is a top perspective view of
being shaved. 55 one exemplary embodiment of an electric shaver of the
When the shaver of the present invention is oriented in the present invention. FIG. 2 is a bottom perspective view of the
above manner, it is possible to either grip the shaver with two shaver of FIG. 1. FIG. 3 is an end view of the shaver of FIG.
fingers as between the thumb and index finger, or between the 1. FIG. 4 is a front, perspective view of the shaver of FIG. 1
index and middle fingers, while resting the remainder of the depicting the shaver held between the index and middle finger
hand against the skin. This helps the user properly orient and 60 with the cutter surface held against the top of the head. FIG.
place the cutting Surface of the shaver against the skin while 5 is a front perspective view of the shaver of FIG. 1 depicting
being able to feel whether the skin has been sufficiently the shaver held between the thumb and index finger and held
shaved. with the cutter surface against the top of the head. FIG. 6 is a
Other objects, features, and advantages of the invention front perspective view of the shaver of FIG. 1 depicting an
will be readily apparent from the following detailed descrip 65 alternate way of holding the same between the index and
tion of a preferred embodiment thereof taken in conjunction middle fingers with the cutter surface against the top of the
with the drawings. head.
US 8,726,528 B2
3 4
As shown in FIG. 1 through FIG. 3, the shaver 100 com ing the preceding detailed description. It is intended that the
prises an upper portion 110 that provides a substantially rect present disclosure be construed as including all Such modifi
angularly shaped housing for a power source and motor cations and alterations insofar as they come within the scope
related components, and a cutter head 114 that further com of the appended claims or the equivalents thereof.
prises at least one rotating or oscillating cutter or array of 5
cutters 116. The connection between the motor and the cutter I claim:
head passes through the central hub 115 which may have an 1. An electric shaver comprising:
enlarged lower portion 117. The cutter head 114 may be a housing for containing an electrical source and drive
comprised of a flexible or semi-flexible material such as related components, said housing having a length and a
castable elastomer allowing the cutter heads to flex when 10
width, and including two Substantially opposed and Sub
meeting the curved surface of the head. The motor (not stantially parallel sides along said length, said housing
shown) is mechanically coupled to the cutters 116 in a known
a. further including a bottom;
The motor, power Supply and other related components a cutter mechanism located beneath said bottom of said
along with the rotating or oscillating cutters are not, per se, 15 housing and spaced therefrom;
part of the present inventive concept. They are all individually a central hub extending from said bottom of said housing to
common and well known in the art. Accordingly, detailed said cutter mechanism and connecting said cutter
descriptions of the same are not believed to be necessary. As mechanism to said housing:
is also known, and as can be seen, the rotating or oscillating said cutter mechanism including a cutting Surface defining
cutters meet rounded as well as flat Surfaces, appropriately for a plane;
shaving. a first pair of elongated recesses formed on said sides of
The housing 110 further comprises a particular form that said housing, said first pair of elongated recesses being
provides a gripping means, and fits the hand in a comfortable Substantially parallel to each other and lying in a plane
manner, especially when the shaver is held in an orientation that is spaced apart from but parallel to the plane of said
wherein the housing is above the cutter. The gripping means 25
cutting Surface, and
includes a pair of elongated recesses in the form of parallel a second set of elongated spaced apart recesses formed in
concave surfaces 112a and 112b formed on either side of the
housing 110. The concave surfaces are parallel to the plane said bottom of said housing along said width entirely,
defined by the cutting surface of the cutters 116. A second pair and extending upwardly into said bottom, said recesses
of elongated recesses in the form of concave surfaces 113a 30 of said second set being located on opposite sides of said
and 113b are formed in the under surface of the housing above hub and extending perpendicular to said first pair of
CCCSSS.
the cutters 116. The second pair of concave surfaces 113a and 2. The electric shaveras claimed inclaim 1 wherein each of
113b are arranged to be perpendicular to the first pair of
concave surfaces 112a and 112b and also parallel to the plane said recesses is defined by a concave surface adapted to
defined by the cutting surface of the cutters 116. 35 accommodate a portion of a user's fingers therein.
Referring to FIG.3 and FIG.4, concave surfaces 112a and 3. An electric shaver comprising:
112b (FIG. 3) are configured to allow the shaver 100 to be a housing for containing an electrical source and drive
gripped in the manner illustrated in FIG.4, wherein the shaver related components, said housing having a length and a
is gripped between the index finger 122 and middle finger width, and including two Substantially opposed and Sub
124, and held against the scalp 118 with the user's palm 40 stantially parallel sides along said length, said housing
facing downwardly. The remainder of the hand may rest further including a bottom surface, and a bottom surface,
against the scalp in a manner that allows the user to feel the said bottom Surface defining a first plane;
a cutter mechanism located beneath said bottom surface of
surface of the scalp, which helps the user guide the shaver said housing and spaced therefrom;
cutting Surface as well as inspect the quality of the shave by
feel. 45 a central hub extending from said bottom Surface of said
Referring to FIG.3 and FIG. 5, concave surfaces 112a and housing to said cutter mechanism and connecting said
112b (FIG. 3) are configured to allow the razor 100 to be cutter mechanism to said housing:
gripped as illustrated in FIG. 5, in which the shaver is gripped said cutter mechanism including a cutting Surface defining
between the thumb 126 and index finger 122, and held against a second plane, said second plane being parallel to but
the skull 118. The remainder of the hand may rest against the 50 spaced from said first plane;
Scalp as in the aforementioned gripping manner. a first pair of elongated recesses formed on said sides of
Referring to FIG. 6, concave surfaces 113a and 113b are said housing, said first pair of elongated recesses being
configured to allow the razor 100 to be gripped as illustrated Substantially parallel to each other and lying in a third
in FIG. 6, in which the shaver is gripped between the index plane that is spaced apart from but parallel to said first
finger 122 and middle finger 124 with the tops of the fingers 55 and second planes;
lying within the concave surfaces or recesses 113a and 113b. a second set of elongated spaced apart recesses formed in
and held against the skull 118. In this position, the inside said bottom Surface of said housing along said width
surfaces of the fingers 122 and 124 grip either side of the entirely, and extending upwardly into said bottom Sur
central hub 115 and the lower part of the fingers press down face, said recesses of said second set being located on
wardly, at least in part, on the enlarged lower portion 117 of 60 opposite sides of said hub and extending perpendicular
the hub 115. The remainder of the hand may rest against the to said first pair of recesses, and
Scalp as in the aforementioned gripping manner. wherein each of said recesses is defined by a concave
The present disclosure has been described with reference Surface adapted to accommodate a portion of a users
to an exemplary embodiment. Obviously, modifications and fingers therein.
alterations will occur to others upon reading and understand
USOOD672504S
(12) United
Lyles
States Design Patent (10) Patent No.: US D672,504 S
(45) Date of Patent: . Dec. 11, 2012
(54) ELECTRICHEAD SHAVER D601,301 S 9, 2009 Bao
D663,897 S * 7/2012 Aulwes et al. ................. D28,54
2009 OO25234 A1 1/2009 Carlucci
(76) Inventor: John Lyles, Mount Ephraim, NJ (US)
* cited by examiner
(**) Term: 14 Years
Primary Examiner — Jennifer Rivard
(21) Appl. No.: 29/374,431 (74) Attorney, Agent, or Firm — Norman E. Lehrer
(57) CLAM
(22) Filed: Aug. 11, 2011
The ornamental design for an “electric head shaver, as shown
(51) LOC (9) Cl. .................................................. 28-03 and described.
(52) U.S. Cl. ........................................................ D28/SO DESCRIPTION
(58) Field of Classification Search ................... D28/44,
D28/44.1, 49–54; 30/34.05, 34.1, 34.2, 43–43.92, FIG. 1 is a top perspective view of an electric head shaver
30/526, 527, 44-45, 341, 195-223, 272.1, showing my new design;
30/226 227, 231, 233 233.5 FIG. 2 is a bottom perspective view thereof;
See application file for complete search history. FIG. 3 is a front elevational view thereof
FIG. 4 is a right side elevational view thereof;
(56) References Cited
FIG. 5 is a rear elevational view thereof;
U.S. PATENT DOCUMENTS FIG. 6 is a left side elevational view thereof;
FIG. 7 is a top plan view thereof; and,
5,520,616 A 5, 1996 Hofmeister FIG. 8 is a bottom plan view thereof.
D426,918 S * 6/2000 Greene .......................... D28/48 The broken lines shown in the drawings illustrate portions of
6,112,421 A * 9/2000 Greene ... ... 30.526
D446,351 S * 8/2001 Greene . ... D28/46 the article and form no part of the claimed design.
D528,701 S * 9/2006 Oh ........... ... D28.50
D558,924 S * 1/2008 Cafaro et al. .................. D28,52 1 Claim, 8 Drawing Sheets
U.S. Patent Dec. 11, 2012 Sheet 1 of 8 US D672,504 S
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
igure 8
EXHIBIT C
Exhibit C – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Men’s 5-in-1 Electric Shaver & Grooming Kit by AsaVea
1(pre): An electric shaver comprising: The Men’s 5-in-1 Electric Shaver & Grooming Kit by AsaVea (“AsaVea Shaver”) is
an electric shaver with an electric charging port.
1
1(a): a housing for containing an electrical The AsaVea Shaver comprises a housing for containing an electrical source and drive-
source and drive-related components, said related components, said housing having a length and a width, and including two
housing having a length and a width, and substantially opposed and substantially parallel sides along said length, said housing
including two substantially opposed and further including a bottom:
substantially parallel sides along said
length, said housing further including a
bottom;
2
Substantially opposed and substantially

parallel sides along said length
3
1(b): a cutter mechanism located beneath The AsaVea Shaver comprises a cutter mechanism located beneath said bottom of
said bottom of said housing and spaced said housing and spaced therefrom:
therefrom;
4
1(c): a central hub extending from said The AsaVea Shaver comprises a central hub extending from said bottom of said
bottom of said housing to said cutter housing to said cutter mechanism and connecting said cutter mechanism to said
mechanism and connecting said cutter housing:
mechanism to said housing;
5
1(d): said cutter mechanism including a The AsaVea Shaver cutter mechanism includes a cutting surface defining a plane:
cutting surface defining a plane;
6
1(e): a first pair of elongated recesses The AsaVea Shaver comprises a first pair of elongated recesses formed on said sides
formed on said sides of said housing, said of said housing, said first pair of elongated recesses being substantially parallel to
first pair of elongated recesses being each other and lying in a plane that is spaced apart from but parallel to the plane of
substantially parallel to each other and said cutting surface:
lying in a plane that is spaced apart from
but parallel to the plane of said cutting
surface, and
7
8
9
Alternatively, the AsaVea Shaver meets this limitation under the doctrine of
equivalents.
U.S. Patent No. 8,726,528 (“the ’528 patent”) describes a shaver “that fits the hand in
a comfortable manner when the shaver is oriented with the grip above the cutter
surface.” (1:45-47.) This is made possible, in part, by a first pair of elongated
recesses formed on said sides of said housing, said first pair of elongated recesses
being substantially parallel to each other and lying in a plane that is spaced apart from
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The AsaVea Shaver
is similarly designed and configured to be held from the sides of the shaver housing
and to be gripped by the user along the sides of the housing, allowing the user to
comfortably hold the shaver when the shaver is oriented with the grip above the cutter
surface, such as when shaving the head.
10
Further, when the shaver is oriented in this manner and being held by the first pair of
elongated recesses formed on said sides of said housing, “it is possible to either grip
the shaver with two fingers as between the thumb and index finger, or between the
index and middle fingers, while resting the remainder of the hand against the skin.
This helps the user properly orient and place the cutting surface of the shaver against
the skin while being able to feel whether the skin has been sufficiently shaved. (Id. at
1:56-63; see also id. at 3:36-51.) In other words, the remainder of the user’s hand
“may rest against the scalp in a manner that allows the user to feel the surface of the
scalp,” which permits sensory feedback and “helps the user guide the shaver cutting
surface as well as inspect the quality of the shave by feel.” (Id. at 3:41-45; see also id.
at Figs. 4, 5).
The design and configuration of the sides of the AsaVea Shaver housing, including
the recesses in the sides of the shaver housing, permits the user to perform this same
function—allowing the user’s hand to rest against the scalp in a manner that allows
the user to feel the surface of the scalp, in the same way—by comfortably handling
the shaver from the sides of the shaver housing, to achieve the same result—
11
providing the user with sensory feedback and helping the user guide the shaver cutting
surface as well as inspect the quality of the shave by feel. Moreover, any differences
between the first pair of elongated recesses formed on said sides of said housing and
the recesses in the sides of the shaver housing of the AsaVea Shaver are insubstantial.
1(f): a second set of elongated spaced apart The AsaVea Shaver comprises a second set of elongated spaced apart recesses formed
recesses formed in said bottom of said in said bottom of said housing along said width entirely, and extending upwardly into
housing along said width entirely, and said bottom, said recesses of said second set being located on opposite sides of said
extending upwardly into said bottom, said hub and extending perpendicular to said first pair of recesses:
recesses of said second set being located on
opposite sides of said hub and extending
perpendicular to said first pair of recesses.
Alternatively, the AsaVea Shaver meets this limitation under the doctrine of
equivalents.
The ’528 patent describes a shaver “that fits the hand in a comfortable manner when
the shaver is oriented with the grip above the cutter surface.” (1:45-47.) This is made
possible, in part, by a second set of elongated spaced apart recesses formed in said
bottom of said housing along said width entirely, and extending upwardly into said
bottom, said recesses of said second set being located on opposite sides of said hub
12
and extending perpendicular to said first pair of recesses. (Id. at 3:52-62.) The
AsaVea Shaver is similarly designed and configured to be held from the bottom side
of the shaver housing and to be gripped by the user along the bottom of the housing
on either side of the central hub, allowing the user to comfortably hold the shaver
when the shaver is oriented with the grip above the cutter surface, such as when
shaving the head.
Further, when the shaver is oriented in this manner and being held by the second set
of elongated spaced apart recesses formed in the bottom of the shaver housing, “it is
possible to either grip the shaver with two fingers as between the thumb and index
finger, or between the index and middle fingers, while resting the remainder of the
hand against the skin. This helps the user properly orient and place the cutting
surface of the shaver against the skin while being able to feel whether the skin has
13
been sufficiently shaved. (Id. at 1:56-63; see also id. at 3:52-62.) In other words, the
remainder of the user’s hand “may rest against the scalp in a manner that allows the
user to feel the surface of the scalp,” which permits sensory feedback and “helps the
user guide the shaver cutting surface as well as inspect the quality of the shave by
feel.” (Id. at 3:41-45; see also id.at Fig. 6).
The design and configuration of the bottom of the AsaVea shaver housing, including
the recesses in the bottom of the shaver housing on either side of the central hub,
permits the user to perform this same function—allowing the user’s hand to rest
against the scalp in a manner that allows the user to feel the surface of the scalp, in the
same way—by comfortably handling the shaver from the sides of the shaver housing,
to achieve the same result— providing the user with sensory feedback and helping the
user guide the shaver cutting surface as well as inspect the quality of the shave by feel.
Moreover, any differences between a second set of elongated spaced apart recesses
formed in said bottom of said housing and the recesses in the bottom of the shaver
housing on either side of the central hub of the AsaVea Shaver are insubstantial.
14
EXHIBIT D
Exhibit D – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 LK-1800 Shaver

1(pre): An electric shaver comprising: The LK-1800 Shaver (“Bald Shaver”) is an electric shaver with an electric charging
port.
1
1(a): a housing for containing an electrical The Bald Shaver comprises a housing for containing an electrical source and drive-
bottom;
2

3
1(b): a cutter mechanism located beneath The Bald Shaver comprises a cutter mechanism located beneath said bottom of said
said bottom of said housing and spaced housing and spaced therefrom:
therefrom;
4
1(c): a central hub extending from said The Bald Shaver comprises a central hub extending from said bottom of said housing
bottom of said housing to said cutter to said cutter mechanism and connecting said cutter mechanism to said housing:
mechanism and connecting said cutter
5
1(d): said cutter mechanism including a The Bald Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The Bald Shaver comprises a first pair of elongated recesses formed on said sides of
formed on said sides of said housing, said said housing, said first pair of elongated recesses being substantially parallel to each
first pair of elongated recesses being other and lying in a plane that is spaced apart from but parallel to the plane of said
substantially parallel to each other and cutting surface:
surface, and
7
8
9
Alternatively, the Bald Shaver meets this limitation under the doctrine of equivalents.
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Bald Shaver is
similarly designed and configured to be held from the sides of the shaver housing and
to be gripped by the user along the sides of the housing, allowing the user to
10
at Figs. 4, 5).
The design and configuration of the sides of the Bald Shaver housing, including the
recesses in the sides of the shaver housing, permits the user to perform this same
11
the recesses in the sides of the shaver housing of the Bald Shaver are insubstantial.
1(f): a second set of elongated spaced apart The Bald Shaver comprises a second set of elongated spaced apart recesses formed in
recesses formed in said bottom of said said bottom of said housing along said width entirely, and extending upwardly into
Alternatively, the Bald Shaver meets this limitation under the doctrine of equivalents.
12
and extending perpendicular to said first pair of recesses. (Id. at 3:52-62.) The Bald
Shaver is similarly designed and configured to be held from the bottom side of the
shaver housing and to be gripped by the user along the bottom of the housing on either
side of the central hub, allowing the user to comfortably hold the shaver when the
shaver is oriented with the grip above the cutter surface, such as when shaving the
head.
13
The design and configuration of the bottom of the Bald Shaver housing, including the
recesses in the bottom of the shaver housing on either side of the central hub, permits
the user to perform this same function—allowing the user’s hand to rest against the
scalp in a manner that allows the user to feel the surface of the scalp, in the same
way—by comfortably handling the shaver from the sides of the shaver housing, to
achieve the same result— providing the user with sensory feedback and helping the
housing on either side of the central hub of the Bald Shaver are insubstantial.
14
EXHIBIT E
Exhibit E – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Kibiy Bald Head Shaver LED Mens Electric Shaving Razor
1(pre): An electric shaver comprising: Kibiy Bald Head Shaver LED Mens Electric Shaving Razor (“Kibiy Shaver”) is an
electric shaver with an electric charging port.
1
1(a): a housing for containing an electrical The Kibiy Shaver comprises a housing for containing an electrical source and drive-
bottom;
2

3
1(b): a cutter mechanism located beneath The Kibiy Shaver comprises a cutter mechanism located beneath said bottom of said
therefrom;
4
1(c): a central hub extending from said The Kibiy Shaver comprises a central hub extending from said bottom of said housing
bottom of said housing to said cutter to said cutter mechanism and connecting said cutter mechanism to said housing:
mechanism and connecting said cutter
1(d): said cutter mechanism including a The Kibiy Shaver cutter mechanism includes a cutting surface defining a plane:
5
1(e): a first pair of elongated recesses The Kibiy Shaver comprises a first pair of elongated recesses formed on said sides of
surface, and
6
7
Alternatively, the Kibiy Shaver meets this limitation under the doctrine of equivalents.
8
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Kibiy Shaver is
9
at Figs. 4, 5).
The design and configuration of the sides of the Kibiy Shaver housing, including the
the recesses in the sides of the shaver housing of the Kibiy Shaver are insubstantial.
1(f): a second set of elongated spaced apart The Kibiy Shaver comprises a second set of elongated spaced apart recesses formed in
recesses formed in said bottom of said said bottom of said housing along said width entirely, and extending upwardly into
10
Alternatively, the Kibiy Shaver meets this limitation under the doctrine of equivalents.
and extending perpendicular to said first pair of recesses. (Id. at 3:52-62.) The Kibiy
Shaver is similarly designed and configured to be held from the bottom side of the
shaver housing and to be gripped by the user along the bottom of the housing on either
side of the central hub, allowing the user to comfortably hold the shaver when the
shaver is oriented with the grip above the cutter surface, such as when shaving the
head.
11
The design and configuration of the bottom of the Kibiy shaver housing, including the
recesses in the bottom of the shaver housing on either side of the central hub, permits
the user to perform this same function—allowing the user’s hand to rest against the
scalp in a manner that allows the user to feel the surface of the scalp, in the same
way—by comfortably handling the shaver from the sides of the shaver housing, to
achieve the same result— providing the user with sensory feedback and helping the
12
housing on either side of the central hub of the Kibiy Shaver are insubstantial.
13
EXHIBIT F
Exhibit F – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Teamyo 5D Floating Deep Clean Head Shaver for Bald Men
1(pre): An electric shaver comprising: Teamyo 5D Floating Deep Clean Head Shaver for Bald Men (“Teamyo Shaver”) is an
1
1(a): a housing for containing an electrical The Teamyo Shaver comprises a housing for containing an electrical source and
source and drive-related components, said drive-related components, said housing having a length and a width, and including
housing having a length and a width, and two substantially opposed and substantially parallel sides along said length, said
including two substantially opposed and housing further including a bottom:
bottom;
2

3
1(b): a cutter mechanism located beneath The Teamyo Shaver comprises a cutter mechanism located beneath said bottom of
therefrom;
4
1(c): a central hub extending from said The Teamyo Shaver comprises a central hub extending from said bottom of said
5
1(d): said cutter mechanism including a The Teamyo Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The Teamyo Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
7
8
Alternatively, the Teamyo Shaver meets this limitation under the doctrine of
equivalents.
surface.” (1:45-47.) This is made possible, in part, by a first pair of elongated recesses
formed on said sides of said housing, said first pair of elongated recesses being
substantially parallel to each other and lying in a plane that is spaced apart from but
parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Teamyo Shaver is
9
at Figs. 4, 5).
The design and configuration of the sides of the Teamyo Shaver housing, including
the recesses in the sides of the shaver housing of the Teamyo Shaver are insubstantial.
1(f): a second set of elongated spaced apart The Teamyo Shaver comprises a second set of elongated spaced apart recesses formed
10
Alternatively, the Teamyo Shaver meets this limitation under the doctrine of
equivalents.
Teamyo Shaver is similarly designed and configured to be held from the bottom side
shaving the head.
11
feel.” (Id. at 3:41-45; see also id. at Fig. 6).
12
The design and configuration of the bottom of the Teamyo shaver housing, including
to achieve the same result—providing the user with sensory feedback and helping the
housing on either side of the central hub of the Teamyo Shaver are insubstantial.
13
EXHIBIT G
Exhibit G – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 PaiTree 5 in 1 Head and Face Electric Rotary Shaver
1(pre): An electric shaver comprising: PaiTree 5 in 1 Head and Face Electric Rotary Shaver (“Paitree Shaver”) is an electric
shaver with an electric charging port.
1
1(a): a housing for containing an electrical The Paitree Shaver comprises a housing for containing an electrical source and drive-
bottom;
2

3
1(b): a cutter mechanism located beneath The Paitree Shaver comprises a cutter mechanism located beneath said bottom of said
therefrom;
4
1(c): a central hub extending from said The Paitree Shaver comprises a central hub extending from said bottom of said
5
1(d): said cutter mechanism including a The Paitree Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The Paitree Shaver comprises a first pair of elongated recesses formed on said sides of
surface, and
7
8
Alternatively, the Paitree Shaver meets this limitation under the doctrine of
equivalents.
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Paitree Shaver
9
at Figs. 4, 5).
The design and configuration of the sides of the Paitree Shaver housing, including the
the recesses in the sides of the shaver housing of the Paitree Shaver are insubstantial.
1(f): a second set of elongated spaced apart The Paitree Shaver comprises a second set of elongated spaced apart recesses formed
10
Alternatively, the Paitree Shaver meets this limitation under the doctrine of
equivalents.
Paitree Shaver is similarly designed and configured to be held from the bottom side of
the shaver housing and to be gripped by the user along the bottom of the housing on
either side of the central hub, allowing the user to comfortably hold the shaver when
the shaver is oriented with the grip above the cutter surface, such as when shaving the
head.
11
12
The design and configuration of the bottom of the Paitree shaver housing, including
housing on either side of the central hub of the Paitree Shaver are insubstantial.
13
EXHIBIT H
Exhibit H– Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 OriHea 5 in 1 Head Shavers for Bald Men Electric Rotary Razor
1(pre): An electric shaver comprising: The OriHea 5 in 1 Head Shavers for Bald Men Electric Rotary Razor (“OriHea
Shaver”) is an electric shaver with an electric charging port.
1(a): a housing for containing an electrical The OriHea Shaver comprises a housing for containing an electrical source and drive-
bottom;
1
Exhibit H – Infringement Claim Chart for U.S. Patent No. 8,726,528
2

3
1(b): a cutter mechanism located beneath The OriHea Shaver comprises a cutter mechanism located beneath said bottom of said
therefrom;
4
1(c): a central hub extending from said The OriHea Shaver comprises a central hub extending from said bottom of said
5
1(d): said cutter mechanism including a The OriHea Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The OriHea Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
7
8
Alternatively, the OriHea Shaver meets this limitation under the doctrine of
equivalents.
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The OriHea Shaver
9
at Figs. 4, 5).
The design and configuration of the sides of the OriHea Shaver housing, including the
the recesses in the sides of the shaver housing of the OriHea Shaver are insubstantial.
1(f): a second set of elongated spaced apart The OriHea Shaver comprises a second set of elongated spaced apart recesses formed
10
Alternatively, the OriHea Shaver meets this limitation under the doctrine of
equivalents.
OriHea Shaver is similarly designed and configured to be held from the bottom side of
the shaver housing and to be gripped by the user along the bottom of the housing on
either side of the central hub, allowing the user to comfortably hold the shaver when
the shaver is oriented with the grip above the cutter surface, such as when shaving the
head.
11
The design and configuration of the bottom of the OriHea shaver housing, including
12
housing on either side of the central hub of the OriHea Shaver are insubstantial.
13
EXHIBIT I
Exhibit I – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver
1(pre): An electric shaver comprising: The Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver (“Roziapro Shaver”) is
1
1(a): a housing for containing an electrical The Roziapro Shaver comprises a housing for containing an electrical source and
bottom;
2

3
1(b): a cutter mechanism located beneath The Roziapro Shaver comprises a cutter mechanism located beneath said bottom of
therefrom;
4
1(c): a central hub extending from said The Roziapro Shaver comprises a central hub extending from said bottom of said
5
1(d): said cutter mechanism including a The Roziapro Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The Roziapro Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
7
8
9
1(f): a second set of elongated spaced apart The Roziapro Shaver comprises a second set of elongated spaced apart recesses
recesses formed in said bottom of said formed in said bottom of said housing along said width entirely, and extending
housing along said width entirely, and upwardly into said bottom, said recesses of said second set being located on opposite
extending upwardly into said bottom, said sides of said hub and extending perpendicular to said first pair of recesses:
10
3(pre): An electric shaver comprising: The Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver (“Roziapro Shaver”) is
11
3(a): a housing for containing an electrical The Roziapro Shaver comprises a housing for containing an electrical source and
including two substantially opposed and housing further including a bottom surface, and a bottom surface, said bottom surface
substantially parallel sides along said defining a first plane:
bottom surface, and a bottom surface, said
bottom surface defining a first plane;
12
13

14
3(b): a cutter mechanism located beneath The Roziapro Shaver comprises a cutter mechanism located beneath said bottom
said bottom surface of said housing and surface of said housing and spaced therefrom:
spaced therefrom;
15
3(c): a central hub extending from said The Roziapro Shaver comprises a central hub extending from said bottom surface of
bottom surface of said housing to said said housing to said cutter mechanism and connecting said cutter mechanism to said
cutter mechanism and connecting said housing:
cutter mechanism to said housing;
16
3(d): said cutter mechanism including a The Roziapro Shaver cutter mechanism includes a cutting surface defining a second
cutting surface defining a second plane, plane, said second plane being parallel to but spaced from said first plane;
said second plane being parallel to but
spaced from said first plane;
17
18
3(e): a first pair of elongated recesses The Roziapro Shaver comprises a first pair of elongated recesses formed on said sides
first pair of elongated recesses being each other and lying in a third plane that is spaced apart from but parallel to said first
substantially parallel to each other and and second planes:
lying in a third plane that is spaced apart
from but parallel to said first and second
planes;
19
20
21
3(f): a second set of elongated spaced apart The Roziapro Shaver comprises a second set of elongated spaced apart recesses
recesses formed in said bottom surface of formed in said bottom surface of said housing along said width entirely, and extending
said housing along said width entirely, and upwardly into said bottom surface, said recesses of said second set being located on
extending upwardly into said bottom opposite sides of said hub and extending perpendicular to said first pair of recesses:
surface, said recesses of said second set
being located on opposite sides of said hub
and extending perpendicular to said first
pair of recesses, and
22
3(g): wherein each of said recesses is The Roziapro Shaver’s each of said recesses is defined by a concave surface adapted
defined by a concave surface adapted to to accommodate a portion of a user's fingers therein:
accommodate a portion of a user's fingers
therein.
23
24
25
EXHIBIT J
Exhibit J – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Magicfly Rechargeable Waterproof Shaver for Women

1(pre): An electric shaver comprising: Magicfly Rechargeable Waterproof Shaver for Women (“Magicfly Shaver”) is an
1(a): a housing for containing an electrical The Magicfly Shaver comprises a housing for containing an electrical source and
bottom;
1
2

3
1(b): a cutter mechanism located beneath The Magicfly Shaver comprises a cutter mechanism located beneath said bottom of
therefrom;
4
1(c): a central hub extending from said The Magicfly Shaver comprises a central hub extending from said bottom of said
1(d): said cutter mechanism including a The Magicfly Shaver cutter mechanism includes a cutting surface defining a plane:
5
1(e): a first pair of elongated recesses The Magicfly Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
6
7
Alternatively, the Magicfly Shaver meets this limitation under the doctrine of
equivalents.
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Magicfly Shaver
8
at Figs. 4, 5).
The design and configuration of the sides of the Magicfly Shaver housing, including
9
the recesses in the sides of the shaver housing of the Magicfly Shaver are
insubstantial.
1(f): a second set of elongated spaced apart The Magicfly Shaver comprises a second set of elongated spaced apart recesses
Alternatively, the Magicfly Shaver meets this limitation under the doctrine of
equivalents.
10
Magicfly Shaver is similarly designed and configured to be held from the bottom side
shaving the head.
11
The design and configuration of the bottom of the Magicfly shaver housing, including
housing on either side of the central hub of the Magicfly Shaver are insubstantial.
12
EXHIBIT K
Exhibit K – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Surker 6 in 1 Electric Shavers for Men Bald Head
1(pre): An electric shaver comprising: The Surker 6 in 1 Electric Shavers for Men Bald Head (“Surker Shaver”) is an electric
shaver with an electric charging port.
1
1(a): a housing for containing an electrical The Surker Shaver comprises a housing for containing an electrical source and drive-
bottom;
2

3
1(b): a cutter mechanism located beneath The Surker Shaver comprises a cutter mechanism located beneath said bottom of said
therefrom;
4
1(c): a central hub extending from said The Surker Shaver comprises a central hub extending from said bottom of said
5
1(d): said cutter mechanism including a The Surker Shaver cutter mechanism includes a cutting surface defining a plane:
6
1(e): a first pair of elongated recesses The Surker Shaver comprises a first pair of elongated recesses formed on said sides of
surface, and
7
8
9
1(f): a second set of elongated spaced apart The Surker Shaver comprises a second set of elongated spaced apart recesses formed
10
3(pre): An electric shaver comprising: The Surker Electric Razor for Men 6 in 1 Bald Head Shaver (“Surker Shaver”) is an
11
3(a): a housing for containing an electrical The Surker Shaver comprises a housing for containing an electrical source and drive-
including two substantially opposed and further including a bottom surface, and a bottom surface, said bottom surface defining
substantially parallel sides along said a first plane:
bottom surface, and a bottom surface, said
bottom surface defining a first plane;
12
13

14
3(b): a cutter mechanism located beneath The Surker Shaver comprises a cutter mechanism located beneath said bottom surface
said bottom surface of said housing and of said housing and spaced therefrom:
spaced therefrom;
15
3(c): a central hub extending from said The Surker Shaver comprises a central hub extending from said bottom surface of said
bottom surface of said housing to said housing to said cutter mechanism and connecting said cutter mechanism to said
cutter mechanism and connecting said housing:
cutter mechanism to said housing;
16
3(d): said cutter mechanism including a The Surker Shaver cutter mechanism includes a cutting surface defining a second
cutting surface defining a second plane, plane, said second plane being parallel to but spaced from said first plane:
said second plane being parallel to but
spaced from said first plane;
17
18
3(e): a first pair of elongated recesses The Surker Shaver comprises a first pair of elongated recesses formed on said sides of
first pair of elongated recesses being other and lying in a third plane that is spaced apart from but parallel to said first and
substantially parallel to each other and second planes:
lying in a third plane that is spaced apart
from but parallel to said first and second
planes;
19
20
21
3(f): a second set of elongated spaced apart The Surker Shaver comprises a second set of elongated spaced apart recesses formed
recesses formed in said bottom surface of in said bottom surface of said housing along said width entirely, and extending
said housing along said width entirely, and upwardly into said bottom surface, said recesses of said second set being located on
extending upwardly into said bottom opposite sides of said hub and extending perpendicular to said first pair of recesses:
surface, said recesses of said second set
being located on opposite sides of said hub
and extending perpendicular to said first
pair of recesses, and
22
3(g): wherein each of said recesses is The Surker Shaver’s each of said recesses is defined by a concave surface adapted to
defined by a concave surface adapted to accommodate a portion of a user's fingers therein:
accommodate a portion of a user's fingers
therein.
23
24
25
EXHIBIT L
Exhibit L – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Electric Razor Grooming Kit for Men 4 in 1 Dry Wet Waterproof Rotary Bald
Head Shaver by WTONG
1(pre): An electric shaver comprising: The Electric Razor Grooming Kit for Men 4 in 1 Dry Wet Waterproof Rotary Bald
Head Shaver by WTONG (“WTONG Shaver”) is an electric shaver with an electric
charging port.
1
1(a): a housing for containing an electrical The WTONG Shaver comprises a housing for containing an electrical source and
bottom;
2

3
1(b): a cutter mechanism located beneath The WTONG Shaver comprises a cutter mechanism located beneath said bottom of
therefrom;
1(c): a central hub extending from said The WTONG Shaver comprises a central hub extending from said bottom of said
4

1(d): said cutter mechanism including a The WTONG Shaver cutter mechanism includes a cutting surface defining a plane:
5
1(e): a first pair of elongated recesses The WTONG Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
6
Alternatively, the WTONG Shaver meets this limitation under the doctrine of
equivalents.
7
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The WTONG
Shaver is similarly designed and configured to be held from the sides of the shaver
housing and to be gripped by the user along the sides of the housing, allowing the user
to comfortably hold the shaver when the shaver is oriented with the grip above the
cutter surface, such as when shaving the head.
8
at Figs. 4, 5).
The design and configuration of the sides of the WTONG Shaver housing, including
the recesses in the sides of the shaver housing of the WTONG Shaver are
insubstantial.
1(f): a second set of elongated spaced apart The WTONG Shaver comprises a second set of elongated spaced apart recesses
9
Alternatively, the WTONG Shaver meets this limitation under the doctrine of
equivalents.
WTONG Shaver is similarly designed and configured to be held from the bottom side
shaving the head.
10
The design and configuration of the bottom of the WTONG shaver housing, including
11
housing on either side of the central hub of the WTONG Shaver are insubstantial.
12
EXHIBIT M
Exhibit M – Infringement Claim Chart for U.S. Patent No. 8,726,528
U.S. 8,726,528 – Claim 1 Homeasy Men Electric Razor Bald Head Shaver
1(pre): An electric shaver comprising: The Homeasy Men Electric Razor Bald Head Shaver (“Homeasy Shaver”) is an
1
1(a): a housing for containing an electrical The Homeasy Shaver comprises a housing for containing an electrical source and
bottom;
2

3
1(b): a cutter mechanism located beneath The Homeasy Shaver comprises a cutter mechanism located beneath said bottom of
therefrom;
4
1(c): a central hub extending from said The Homeasy Shaver comprises a central hub extending from said bottom of said
1(d): said cutter mechanism including a The Homeasy Shaver cutter mechanism includes a cutting surface defining a plane:
5
1(e): a first pair of elongated recesses The Homeasy Shaver comprises a first pair of elongated recesses formed on said sides
surface, and
6
7
Alternatively, the Homeasy Shaver meets this limitation under the doctrine of
equivalents.
but parallel to the plane of said cutting surface. (Id. at 3:36-51.) The Homeasy
Shaver is similarly designed and configured to be held from the sides of the shaver
housing and to be gripped by the user along the sides of the housing, allowing the user
to comfortably hold the shaver when the shaver is oriented with the grip above the
cutter surface, such as when shaving the head.
8
at Figs. 4, 5).
The design and configuration of the sides of the Homeasy Shaver housing, including
9
the recesses in the sides of the shaver housing of the Homeasy Shaver are
insubstantial.
1(f): a second set of elongated spaced apart The Homeasy Shaver comprises a second set of elongated spaced apart recesses
Alternatively, the Homeasy Shaver meets this limitation under the doctrine of
equivalents.
10
Homeasy Shaver is similarly designed and configured to be held from the bottom side
shaving the head.
11
The design and configuration of the bottom of the Homeasy shaver housing, including
housing on either side of the central hub of the Homeasy Shaver are insubstantial.
12
EXHIBIT N
Exhibit N – Infringement Claim Chart for U.S. Design Patent No. D672,504
U.S. D672,504 Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver
Claim: The ornamental design for an The Roziapro Electric Razor for Men 6 in 1 Bald Head Shaver (“Roziapro”) is an
“electric head shaver,” as shown and electric head shaver with an electric charging port.
described.
1
FIG. 1 is a top perspective view of an

electric head shaver showing my new
design;
2
FIG. 2 is a bottom perspective view thereof;
3
FIG. 3 is a front elevational view thereof;
4
FIG. 4 is a right side elevational view

thereof;
5
6
FIG. 6 is a left side elevational view thereof;
7
8
FIG. 8 is a bottom plan view thereof.
9
EXHIBIT O
Exhibit O – Infringement Claim Chart for U.S. Design Patent No. D672,504
U.S. D672,504 Surker 6 in 1 Electric Shavers for Men Bald Head

Claim: The ornamental design for an The Surker 6 in 1 Electric Shavers for Men Bald Head (“Surker”) is an electric head
“electric head shaver,” as shown and shaver with an electric charging port.
described.
1
FIG. 1 is a top perspective view of an

electric head shaver showing my new
design;
2
FIG. 2 is a bottom perspective view thereof;
3
FIG. 3 is a front elevational view thereof;
4
FIG. 4 is a right side elevational view

thereof;
5
6
FIG. 6 is a left side elevational view thereof;
7
8
FIG. 8 is a bottom plan view thereof.

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Case 6:20-cv-00951 Document 1 Filed 10/13/20 Page 1 of 52

UNITED STATES DISTRICT COURT

SKULL SHAVER, LLC,

RAYENBARNY INC., BALD SHAVER INC.,

COMPLAINT FOR PATENT INFRINGEMENT

(collectively “Defendants”). Plaintiff states and alleges the following:

particularly when shaving curved parts of the body.

reaching upward to shave the head.

7. On information and belief, Rayenbarny Inc. (“Rayenbarny”) is a New York

8. On information and belief, Defendant Bald Shaver Inc. (“Bald Shaver”) is a

District, Shenzhen, Guangdong, 518000, China.

Chengzhongxilu No.93, Yiwu, Zhejiang, 322000, China.

Blk, 181 Queen’s Road, Center Hong Kong.

Duyuan Cun, Houzhai, Jiedao, Yiwu, Zhejiang, 322000, China.

16. On information and belief, Defendant Shenzhen Wantong Information Technology

Street, Baoan District, Shenzhen, Guangdong, 518000, China.

17. On information and belief, Defendant Shenzhen Junmao International Technology

JURISDICTION AND VENUE

reasonably anticipate being haled into court in this judicial District.

court in this judicial District.

court in this judicial District.

court in this judicial District.

court in this judicial District.

court in this judicial District.

court in this judicial District.

foreign defendant’s venue challenge).

and incorporate Skull Shaver’s patented inventions.

Amazon.com, eBay.com, and Alibaba.com, among other websites.

and sponsored advertisements.

under different seller and brand names.

(Patent Infringement of United States Patent No. 8,726,528 by Rayenbarny)

infringed the ’528 patent.

unless and until they are enjoined by this Court.

enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Bald Shaver)

Shaver pursuant to 35 U.S.C. § 271(a).

infringed the ’528 patent.

unless and until they are enjoined by this Court.

enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Suzhou Kaidiya)

actions to avoid learning of these facts.

of the invention claimed in at least claim 1 of the ʼ528 patent.

infringed the ’528 patent.

Kaidiya is enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Aiweilai)

willfully infringed the ’528 patent.

Aiweilai is enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Wenzhou Wending)

willfully infringed the ’528 patent.

Wending is enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Shenzhen Nukun)

of the invention claimed in at least claim 1 of the ʼ528 patent.

willfully infringed the ’528 patent.

Nukun is enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Yiwu Xingye)

infringed the ’528 patent.

patent unless and until they are enjoined by this Court.

Xingye is enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Magicfly)

Waterproof Shaver for Women pursuant to 35 U.S.C. § 271(a).

but took deliberate actions to avoid learning of these facts.

unless and until they are enjoined by this Court.

enjoined from infringing the claims of the ’528 patent.

(Patent Infringement of United States Patent No. 8,726,528 by Yiwu City)