IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

MARINE TECHNOLOGIES, INC, an Illinois corporation, Plaintiff, v. ATWOOD MOBILE PRODUCTS LLC, a Delaware Limited Liability Company, Defendant.

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Case No.

COMPLAINT FOR PATENT INFRINGEMENT AND OTHER RELIEF Plaintiff, MARINE TECHNOLOGIES, INC, by counsel, Kevin K. McQuillan of MCQUILLAN LAW OFFICE LLC, for its Complaint against ATWOOD MOBILE PRODUCTS LLC, alleges as follows: COUNT I (Patent Infringement) The Parties 1. MARINE TECHNOLOGIES, INC, (MTI) is an Illinois corporation, with its

principal place of business at 31632 N. Ellis Drive, No. 301, Volo, Illinois. MTI is engaged in the design, manufacture, packaging, distributing and selling of recreational vehicle safety devices, including a unique Combination Airborne Substance Detector for use in recreational vehicles. 2. ATWOOD MOBILE PRODUCTS LLC (ATWOOD) is a Delaware Limited

Liability Company, with its principal place of business at 1120 N. Main Street, Elkhart, IN. 3. ATWOOD is engaged in the design, manufacture, packaging, importing,

distributing and selling of recreational vehicle components to customers and its dealers and

service centers throughout the United States, specifically including dealers and service centers within the Northern District of Illinois. 4. ATWOOD is a competitor of MTI in the area of certain recreational vehicle

safety devices, including detectors and has begun selling what it refers to as an LP & CO Gas Detector. Jurisdiction and Venue 5. This is an action for patent infringement arising under the patent laws of the

United States, 35 U.S.C. 1-376. 6. 1331 and 1338. 7. This Court has personal jurisdiction over the defendant. Venue in this Judicial This Court has jurisdiction of the subject matter of this action under 28 U.S.C.

District is proper under 28 U.S.C. 1391(b) and (c) and 1400(b), and 735 ILCS 5/2-209. MTIs Patent Rights 8. MTI is the owner of U.S. Patent No. 7,248,156, (the 156 Patent) issued on

July 24, 2007 and entitled Combination Airborne Substance Detector. Attached hereto as Exhibit A is a written assignment (the Assignment) to MTI of the entire right, title and interest in the invention or improvements disclosed in the 156 Patent confirming all prior assignments and nunc pro tunc November 4, 2004. The Assignment gave MTI the right to recover any and all damages for past infringement of the 156 Patent. Attached as Exhibit B is the Notice of Recordation of the Assignment that confirms that the Assignment was recorded in the U.S. Patent and Trademark Office on February 20, 2012, at Reel 027732, Frame 0243.

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Pursuant to 35 U.S.C. 287, MTI had placed, and continues to place, the required

statutory notice of its 156 Patent on its devices falling within the scope of the claims of the 156 Patent. 10. ATWOODs liability for patent infringement damages commenced to accrue on

the date that the 156 Patent was first infringed. 11. In addition, MTI has previously provided written notice to ATWOOD of its

infringement of the 156 Patent. Defendants Infringement 12. Pursuant to 35 U.S.C. 271, ATWOOD has directly infringed, actively induced

infringement of, and contributorily infringed the 156 Patent, and is still doing so, by designing, manufacturing, packaging, importing, distributing, using and selling and offering for sale within the United States, and within this Judicial District, LP & CO Gas Detectors that employ the inventions of the 156 Patent, and will continue to do so if not enjoined by this Court. 13. ATWOOD has had both actual and constructive notice of the 156 Patent before

the present suit was filed, but nonetheless continues to infringe, thus committing willful and deliberate infringement of the 156 Patent in complete disregard of MTIs rights. 14. The infringing acts in this Judicial District and elsewhere with the United States

are without authorization or license from MTI. 15. As a result of the foregoing infringing activity of ATWOOD, MTI will suffer

irreparable harm unless ATWOOD is enjoined by this Court. 16. ATWOODS conduct renders this an exceptional case under 35 U.S.C. 285

thereby entitling MTI to an award of reasonable attorney fees.

Relief Requested MTI prays for judgment against ATWOOD as follows and for the following relief: 1. 2. A finding that ATWOOD has infringed the 156 Patent. 35 U.S.C. 271. A preliminary injunction prohibiting ATWOODs continuing infringement of the

156 Patent during the pendency of this action. 35 U.S.C. 283. 3. A permanent injunction, after adjudication on the merits, prohibiting ATWOODs

future infringement of the 156 Patent. 35 U.S.C. 283. 4. An award of damages adequate to compensate for ATWOODs infringement of

the 156 Patent. 35 U.S.C. 284 5. An award of prejudgment interest on the infringement damages, accruing from the

date of ATWOODs individual acts of infringement. 35 U.S.C. 284. 6. 7. An award of treble damages. 35 U.S.C. 284. An award of MTIs attorneys fees and costs incurred in pursuing this action. 35

U.S.C. 284 and 285. 8. An accounting of all gains, profits, advantages and unjust enrichment derived by

ATWOOD from its violations of law. 9. An order requiring ATWOOD to deliver to MTI, for destruction at MTIs option,

all products that infringe the 156 Patent. 10. evidence. DEMAND FOR JURY TRIAL MTI demands a trial by jury as to all issues triable by jury in this action. Dated: May 30, 2012 Such other and further relief as is warranted and justified by the pleadings and the

Respectfully submitted: By: /s/ Kevin K. McQuillan Kevin K. McQuillan

MCQUILLAN LAW OFFICE LLC

1155 S. Washington St., Suite 202 Naperville, IL 60540 Ph: 630-355-5950 Fax: 630-596-0862 IL ARDC No. 1869825 Counsel for Plaintiff Marine Technologies, Inc.