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Salsnes Filter AS (Salsnes) alleges: JURISDICTION AND VENUE 1. This is an action for patent infringement under Title 35 of the United

States Code. The Court has federal question jurisdiction under 28 U.S.C. 1331, and exclusive original jurisdiction under 28 U.S.C. 1338(a). 2. Venue properly lies in this district pursuant to 28 U.S.C. 1391(b),

1391(c) and 1400(b). The defendants are subject to personal jurisdiction in this judicial district. Salsnes is informed and believes and thereon alleges that defendant M2 Renewables, Inc.s (M2R) principal place of business is within this judicial district, that defendant M2R has systematic and not isolated activities within this judicial district, and that defendant M2R has committed acts of patent infringement, as set forth in the First Claim for Relief herein, within this judicial district. Salsnes is informed and believes and thereon alleges that defendant Nepsus Environmental LLC (Nepsus) has systematic and not isolated activities within this judicial district and that defendant Nepsus has committed acts of patent infringement, as set forth in the Second Claim for Relief herein, within this judicial district. PARTIES 3. Salsnes is a corporation organized and existing under the laws of

Norway with its principal place of business in Namsos, Norway. Salsnes is a leading provider of filter technology for primary wastewater treatment and sludge dewatering. 4. Salsnes is informed and believes and thereon alleges that Defendant

M2R is a Delaware corporation with its principal place of business in Lake Forest, California. 5. Salsnes is informed and believes and thereon alleges that Defendant

Nepsus is an Arizona limited liability company with its principal place of business in Tempe, Arizona.
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Complaint

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FIRST CLAIM FOR RELIEF (Infringement of U.S. Patent No. 6,942,786 by M2R) 6. U.S. Patent No. 6,942,786 (the 786 patent), entitled Cleaning

Device for Waste Water, issued on September 13, 2005. Salsnes owns all right and title to the 786 patent. A true and correct copy of the 786 patent is attached as Exhibit 1. 7. Salsnes is informed and believes and thereon alleges that M2R has

infringed, and will continue to infringe, one or more claims of the 786 patent directly, contributorily, or by inducement by making, using, selling, or offering to sell in this country (including this judicial district), a cleaning device for waste water. Examples of cleaning devices for waste water that infringe include, but are not limited to, the M2R Microscreen. 8. Salsnes is informed and believes and thereon alleges that M2R has

committed the aforementioned acts of infringement of the 786 patent in connection with the installation identified as the City of Adelanto, California waste water treatment plant that includes the M2R Microscreen. 9. Salsnes is informed and believes and thereon alleges that M2R has

committed the aforementioned acts of infringement of the 786 patent in connection with the installation identified as the ProLogis-Fontana, California Kaiser Steel waste water treatment plant that includes the M2R Microscreen. 10. Salsnes is informed and believes and thereon alleges that M2Rs

infringement of the 786 patent is willful. As a result, Salsnes is entitled to increased damages under 35 U.S.C. 284 and to its attorneys fees incurred in prosecuting this action under 35 U.S.C. 285. 11. Salsnes has been, and will continue to be damaged by M2Rs

infringement of the 786 patent, and has been and will be, irreparably harmed unless M2Rs infringement is enjoined.

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Complaint

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SECOND CLAIM FOR RELIEF (Infringement of U.S. Patent No. 6,942,786 by Nepsus) Salsnes incorporates paragraphs 1 through 6, above. Salsnes is informed and believes and thereon alleges that Nepsus has

infringed, and will continue to infringe, one or more claims of the 786 patent directly, contributorily, or by inducement by making, using, selling, or offering to sell in this country (including this judicial district), a cleaning device for waste water. Examples of cleaning devices for waste water that infringe include, but are not limited to, the Preliminary Separator as used in the Nepsus CBUM Process. 14. Salsnes is informed and believes and thereon alleges that Nepsus has

committed the aforementioned acts of infringement of the 786 patent in connection with an installation identified as the City of Adelanto, California waste water treatment plant that includes the Preliminary Separator as used in the Nepsus CBUM Process. 15. Salsnes is informed and believes and thereon alleges that Nepsus

infringement of the 786 patent is willful. As a result, Salsnes is entitled to increased damages under 35 U.S.C. 284 and to its attorneys fees incurred in prosecuting this action under 35 U.S.C. 285. 16. Salsnes has been, and will continue to be damaged by Nepsus

infringement of the 786 patent, and has been and will be, irreparably harmed unless Nepsus infringement is enjoined. PRAYER FOR RELIEF WHEREFORE, Salsnes requests the following relief: On the First Claim for Relief, A. B. A judgment that M2R infringes the 786 patent; A permanent injunction enjoining and restraining M2R and its officers,

agents, attorneys, and employees, and those acting in privity or concert with them from infringing the 786 patent for its full term;
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Complaint

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C.

An award of damages to Salsnes including pre-judgment and post-

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judgment interest in an amount adequate to compensate Salsnes for M2R's infringement of the '786 patent, and, if willful infringement is shown, that the damages be trebled pursuant to 35 U.S.C. 284; On the Second Claim for Relief,
D.
E.

A judgment that Nepsus infringes the '786 patent; A permanent injunction enjoining and restraining Nepsus and its

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officers, agents, attorneys, and employees, and those acting in privity or concert with them from infringing the '786 patent for its full term;
F.

An award of damages to Salsnes including pre-judgment and post-

judgment interest in an amount adequate to compensate Salsnes for Nepsus' infringement of the '786 patent, and, if willful infringement is shown, that the damages be trebled pursuant to 35 U.S.C. 284; On all Claims for Relief,
G.

For a declaration that this is an exceptional case and an award of

Salsnes' costs, disbursements, and attorneys' fees incurred in this action, including attorneys' fees pursuant to 35 U.S.C. 285; and
H.

Any other and further relief this Court may deem just and proper.

DATED: August 18,2011

h a ilton, Bar No. 211544 mi on@perkinscoie.com Attorneys for Plaintiff SALSNES FILTER AS

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Complaint

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DEMAND FOR JURY TRIAL

Salsnes hereby demands a jury trial.

DATED: August 18,2011

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Attorneys for Plaintiff SALSNES FILTER AS

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Complaint

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Exhibit 1

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