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1 purposely transacted business involving its accused products in this judicial district, 2 has committed acts of infringement in this judicial district, and continues to commit 3 acts of infringement in this district. 4 5 3. THE PARTIES SASCO is a corporation organized and existing under the laws of the

6 State of California, having its principal place of business at 2750 Moore Avenue, 7 Fullerton, California 92833. SASCO provides electrical contracting services and 8 has its primary operations in California. 9 4. On information and belief, REEL-O-MATIC is a corporation organized 10 and existing under the laws of the State of Delaware, having its principal place of 11 business at 6408 S. Eastern Avenue, Oklahoma City, Oklahoma 73149. On 12 information and belief, REEL-O-MATIC is engaged in the business of providing 13 companies, distributors, wholesalers and contractors with electrical and wire 14 handling equipment. 15 5. On information and belief, REEL-O-MATIC has committed acts of 16 infringement alleged herein within this judicial district. 17 18 6. SASCOS PATENT-IN-SUIT SASCO is the owner of the entire right, title and interest in United

19 States Patent No. 6,435,450 (the 450 patent), entitled Multi-Compartment 20 Paralleling Reel Having Independent Compartments which was duly and legally 21 issued by the United States Patent and Trademark Office on August 20, 2002. A 22 true and correct copy of the 450 patent is attached as Exhibit A to this Complaint 23 and is incorporated herein by reference. 24 7. SASCO has the right to exclude others from making, using, offering for 25 sale, or selling in the United States and importing into the United States 26 embodiments of the inventions claimed in the 450 patent. SASCO also has the 27 right to sue and recover damages for any and all infringements thereof. 8.
4840-8879-5157.1

LEWIS

28

SASCO has owned the entire right, title and interest in and to the 450
SASCOS COMPLAINT FOR PATENT INFRINGEMENT AGAINST REEL-O-MATIC, INC.

BRISBOIS
ATTORNEYS AT LAW

BISGAARD & SMITH LLP

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1 patent throughout the period of REEL-O-MATICs infringing acts and still owns the 2 patent. 3 9. The 450 patent describes a multi-compartment paralleling reel that 4 allows different sets of electrical wire to be drawn from the paralleling reel 5 independently of each other and to permit loading of the reel with electrical wire by 6 rotating the compartments of the reel in unison. The 450 patent claims, inter alia, a 7 multi-compartment paralleling reel that includes a reel securing bar insertable 8 transversely through aligned holes of each of the independent compartments to 9 secure the independent compartments to one another. The 450 patent also claims, 10 inter alia, a method for allowing a plurality of different sets of wire to be drawn 11 from a paralleling reel independently of each other, and a method for loading 12 different sets of wire onto the independent compartments after securing the 13 independent compartments to one another. 14 15 16 10. CLAIM FOR RELIEF (Infringement of the 450 Patent 35 U.S.C. 271(a)) SASCO incorporates by reference the allegations of the preceding

17 paragraphs, as if fully repeated herein. 18 11. REEL-O-MATIC, without authority or license from SASCO, has 19 unlawfully and wrongfully made, used, offered for sale, sold in the United States, 20 and/or imported into the United States, and is now making, using, offering for sale, 21 selling in the United States, and/or importing into the United States multi22 compartment reels that are covered by one or more claims of the 450 patent, 23 including but not limited to the RPR 15 paralleling reel and the CRS-RPR-45 24 paralleling reel (the Accused Products). 25 12. REEL-O-MATICs unauthorized and wrongful making, using, selling, 26 offering for sale or, selling the Accused Products in the territory of the United States 27 and/or importing the Accused Products into the United States and within this 28 judicial district, constitutes infringement of at least one claim of the 450 patent,
4840-8879-5157.1

LEWIS

BRISBOIS
ATTORNEYS AT LAW

BISGAARD & SMITH LLP

SASCOS COMPLAINT FOR PATENT INFRINGEMENT AGAINST REEL-O-MATIC, INC.

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1 under 35 U.S.C. 271 et seq. 2 13. SASCO is entitled to damages resulting from REEL-O-MATICs 3 infringing activities under 35 U.S.C. 287. 4 14. By reason of REEL-O-MATICs infringing activities, SASCO has 5 suffered, and will continue to suffer, substantial damages in an amount to be proven 6 at trial. 7 15. REEL-O-MATICs continuing acts of infringement are irreparably 8 harming and causing damage to SASCO, for which SASCO has no adequate remedy 9 at law, and will continue to suffer such irreparable injury unless REEL-O-MATICs 10 continuing acts of infringement are enjoined by the Court. 11 12 13 A. PRAYER FOR RELIEF WHEREFORE, SASCO respectfully requests that this Court: Enter judgment in favor of SASCO that REEL-O-MATIC has infringed

14 the 450 patent; 15 B. Declare that REEL-O-MATICs acts and conduct infringe the 450 16 patent and the exclusive rights in said patent held by SASCO; 17 18 C. Pursuant to 35 U.S.C. 283, enter a permanent injunction which: i. Enjoins REEL-O-MATIC, its officers, directors, agents,

19 employees, privies, subsidiaries, affiliates, divisions, branches, successors, and 20 assigns, and all others acting in concert or privity therewith, and all those acting for 21 them or in their behalf, from infringing upon the 450 patent; and 22 ii. Enjoins REEL-O-MATIC, its directors, officers, agents, 23 employees, representatives, and all other persons in active participation with them, 24 to recall from all distributors, and all others known to REEL-O-MATIC, all products 25 which infringe upon the 450 patent, and requires REEL-O-MATIC to file with this 26 court and to serve upon SASCO, within thirty (30) days after service of the Courts 27 Order as herein prayed, a report in writing under oath setting forth in detail the 28 manner and form in which REEL-O-MATIC has complied with the Courts order;
4840-8879-5157.1

LEWIS

BRISBOIS
ATTORNEYS AT LAW

BISGAARD & SMITH LLP

SASCOS COMPLAINT FOR PATENT INFRINGEMENT AGAINST REEL-O-MATIC, INC.

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