UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION ) ) ) ) Civil Action No.

: _________________ ) ) Judge: ) ) ) JURY TRIAL DEMANDED ) ) )

ALFDEX AB and ALFA LAVAL CORPORATE AB Plaintiffs, v. PACCAR, INC. Defendant.

COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs Alfdex AB (Alfdex) and Alfa Laval Corporate AB (Alfa Laval) (collectively, Plaintiffs), for their Complaint against Defendant Paccar, Inc. (Paccar), allege as follows: 1. This is an action for patent infringement that arises out of Defendant Paccars

infringement of U.S. Patent Nos. 6,821,319 and 6,755,896 (the patents-in-suit) related to products and methods of cleaning crankcase gases emitted from the diesel engines used in medium and heavy-duty commercial trucks. PARTIES 2. Plaintiff Alfa Laval is a corporation organized and existing under the laws of

Sweden, having its headquarters and principal place of business at Rudeboksvgen 1, SE-226 55 Lund, Sweden. 3. Plaintiff Alfdex is a corporation organized under the laws of Sweden, having its

headquarters and principal place of business at Instrumentgatan 15, SE-261 24 Landskrona,

Sweden. Alfdex manufactures and sells Alfdex separators that practice the inventions of the patents-in-suit and cleans crankcase gas of diesel engines. 4. On information and belief, Defendant Paccar is a corporation organized under the

laws of Delaware, having its headquarters and principal place of business at 777 106th Avenue N.E., Bellevue, Washington 98004. JURISDICTION AND VENUE 5. Plaintiffs repeat and incorporate by reference paragraphs 1-4 above as though

fully restated herein. 6. This is an action for patent infringement arising under the Patent Laws of the

United States, 35 U.S.C. 1 et seq., including 35 U.S.C. 271. 7. 1338(a). 8. On information and belief, Paccar regularly transacts business in a substantial, This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and

continuous, and systematic way within the state of Illinois and the Northern District of Illinois, including, but not limited to, the distribution and sales of products and the offering of support and services that give rise to the instant action for patent infringement. 9. On information and belief, Paccar maintains offices and facilities within the state

of Illinois and the Northern District of Illinois, specifically including, but not limited to, a distribution center located at 1041 Simpson Road, Rockford, Illinois 61102, from which infringing products are offered for sale and sold. On information and belief, Paccar employs Illinois residents, including residents of this judicial district who work at Paccars distribution center in Rockford. 10. On information and belief, Paccar has placed infringing products, including

separators, engines, and trucks, that form the basis of this Complaint into the stream of 2

commerce with the expectation that such products will be purchased within the United States, the state of Illinois, and the Northern District of Illinois. 11. On information and belief, Paccar is primarily engaged in the manufacture,

distribution, and sales of medium and heavy-duty commercial trucks throughout the world, including substantial sales within the United States, the state of Illinois, and the Northern District of Illinois. 12. On information and belief, Paccar has offered for sale and sold within the United

States, the state of Illinois, and the Northern District of Illinois trucks that include separators and engines that practice and thereby infringe the patents-in-suit. 13. On information and belief, Paccar offers for sale and sells within the United

States, the state of Illinois, and the Northern District of Illinois separators, engines, and trucks that practice and thereby infringe the patents-in-suit. 14. On information and belief, Paccar has, within the United States, the state of

Illinois, and the Northern District of Illinois, used separators, engines, and trucks that practice and thereby infringe the patents-in-suit. 15. On information and belief, Paccar is subject to personal jurisdiction in this Court,

consistent with the principles of due process and the Illinois Long Arm Statute, by virtue of Paccars above-referenced activities and contacts within the state of Illinois and the Northern District of Illinois, and further because Paccar purposefully availed and avails itself of the privileges of doing business in Illinois. 16. On information and belief, a substantial part of the acts giving rise to the instant

action occurred in the state of Illinois and Northern District of Illinois. 17. Venue in this Court is proper under 28 U.S.C. 1391(b)-(d) and 1400(b).

FACTUAL BACKGROUND 18. Plaintiffs repeat and incorporate by reference paragraphs 1-17 above as though

fully restated herein. 19. Alfa Laval owns U.S. Patent No. 6,821,319 (the 319 patent), entitled Method

and an Apparatus for Cleaning of Gas (attached as Exhibit A), a patent duly and properly issued by the U.S. Patent and Trademark Office on November 23, 2004. 20. 21. Alfdex is a licensee under the 319 patent. Alfdex owns U.S. Patent No. 6,755,896 (the 896 patent), entitled Method of

Cleaning Crankcase Gas and a Gas Cleaning Separator (attached as Exhibit B), a patent duly and properly issued by the U.S. Patent and Trademark Office on June 29, 2004. The 896 patent has been assigned from Alfa Laval to Alfdex. 22. Plaintiffs collectively have owned the patents-in-suit throughout the period of

Paccars infringing acts, still own the patents, and have the right to pursue the claims of infringement and requests for relief set forth in this Complaint, from the time of Paccars first infringement of the patents-in-suit forward. 23. Paccar has directly infringed, induced others to infringe, and/or contributed to the

infringement of the 319 and 896 patents, by making, using, offering to sell, and/or selling in the United States, and/or importing into the United States, products that infringe the 319 and 896 patents; by practicing processes that practice one or more inventions claimed in the 319 and 896 patents; and by causing others to infringe the 319 and 896 patents. COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,821,319 24. Plaintiffs repeat and incorporate by reference paragraphs 1-23 above as though

fully restated herein.

25.

Paccar had knowledge of the 319 patent since at least July 2010, when Alfdex

notified Paccar of the 319 patent. 26. Paccar has directly infringed the 319 patent, both literally and under the doctrine

of equivalents, by making, using, selling, offering for sale, and/or importing into the United States, products, or by practicing processes, that are covered by one or more claims of the 319 patent. 27. With knowledge of the 319 patent, Paccar has indirectly, through induced and/or

contributory infringement, infringed the 319 patent within the United States by knowingly, or with willful blindness, causing others to infringe the 319 patent by making, using, offering to sell, or selling products that practice the 319 patent and by practicing methods covered by the 319 patent. Paccar has taken active steps to induce others to infringe the 319 patent, with knowledge that the others would practice and thereby infringe the 319 patent. In addition, Paccar has sold and offered to sell within the United States products, including separators, engines, and trucks, that practice, or are for uses that practice the 319 patent, while knowing that such products are made and/or especially adapted for use in infringement of the 319 patent, and are not staple articles of commerce suitable for substantial noninfringing use. 28. Paccars direct and indirect infringement of the 319 patent has been and

continues to be willful and deliberate. With notice and knowledge of the 319 patent and notice that the Alfdex separators practice the 319 patent, Paccar replaced the Alfdex separators, which it had purchased and used for years, with a copy of the separators from an alternative source. In infringing the 319 patent, Paccar acted despite an objectively high likelihood that its actions constituted infringement of a valid patent, a likelihood that was either known or so obvious that Paccar should have known of this high likelihood of infringement.

29.

Paccar has profited through its infringement of the 319 patent, while Alfdex has

suffered and will continue to suffer losses and damages. 30. As a consequence of Paccars infringement, Plaintiffs have been damaged in an

amount not yet determined. 31. As a consequence of Paccars willful and deliberate infringement, Plaintiffs are

entitled to awards of enhanced damages and reasonable attorney and expert fees and costs. 32. Plaintiffs will suffer and are suffering irreparable harm from Paccars

infringement of the 319 patent. Plaintiffs have no adequate remedy at law and are entitled to a preliminary and permanent injunction against Paccars continuing infringement of the 319 patent. On information and belief, unless enjoined, Paccar will continue its infringing conduct. COUNT II: INFRINGEMENT OF U.S. PATENT NO. 6,755,896 33. Plaintiffs repeat and incorporate by reference paragraphs 1-32 above as though

fully restated herein. 34. Paccar had knowledge of the 896 patent since at least July of 2010, when Alfdex

notified Paccar of the 896 patent. 35. Paccar has directly infringed the 896 patent, both literally and under the doctrine

of equivalents, by making, using, selling, offering for sale, and/or importing into the United States, products, or by practicing processes, that are covered by one or more claims of the 896 patent. 36. With knowledge of the 896 patent, Paccar has indirectly, through induced and/or

contributory infringement, infringed the 896 patent within the United States by knowingly, or with willful blindness, causing others to infringe the 896 patent by making, using, offering to sell, or selling products that practice the 896 patent and by practicing methods covered by the 896 patent. Paccar has taken active steps to induce others to infringe the 896 patent, with 6

knowledge that the others would practice and thereby infringe the 896 patent. In addition, Paccar has sold and offered to sell within the United States products, including separators, engines, and trucks, that practice, or are for uses that practice the 896 patent, while knowing that such products are made and/or especially adapted for use in infringement of the 896 patent, and are not staple articles of commerce suitable for substantial noninfringing use. 37. Paccars direct and indirect infringement of the 896 patent has been and

continues to be willful and deliberate. With notice and knowledge of the 896 patent and notice that the Alfdex separators practice the 896 patent, Paccar replaced the Alfdex separators, which it had purchased and used for years, with a copy of the separators from an alternative source. In infringing the 896 patent, Paccar acted despite an objectively high likelihood that its actions constituted infringement of a valid patent, a likelihood that was either known or so obvious that Paccar should have known of this high likelihood of infringement. 38. Paccar has profited through its infringement of the 896 patent, while Alfdex has

suffered and will continue to suffer losses and damages. 39. As a consequence of Paccars infringement, Plaintiffs have been damaged in an

amount not yet determined. 40. As a consequence of Paccars willful and deliberate infringement, Plaintiffs are

entitled to awards of enhanced damages and reasonable attorney and expert fees and costs. 41. Plaintiffs will suffer and are suffering irreparable harm from Paccars

infringement of the 896 patent. Plaintiffs have no adequate remedy at law and are entitled to a preliminary and permanent injunction against Paccars continuing infringement of the 896 patent. On information and belief, unless enjoined, Paccar will continue its infringing conduct.

PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray for the following relief: A. B. Judgment that the 319 and 896 patents are valid and enforceable; Judgment that Paccar has infringed and is infringing one or more claims of each of the 319 and 896 patents; C. Judgment awarding Plaintiffs damages, in the form of lost profits, or in the alternative, not less than a reasonable royalty, together with pre-judgment and post-judgment interest; D. Judgment that Paccars infringement of the 319 and 896 patents has been willful and deliberate; E. Judgment awarding Plaintiffs treble damages as a result of Paccars willful and deliberate infringement of the 319 and 896 patents; F. Judgment that this case is exceptional and awarding Plaintiffs their attorney fees, expert expenses, and costs, in accordance with 35 U.S.C. 284 and 285 and Rule 54(d) of the Federal Rules of Civil Procedure; G. Entry of a preliminary and permanent injunction pursuant to 35 U.S.C. 283 and Rule 65 of the Federal Rules of Civil Procedure, enjoining Paccar and its officers, agents, attorneys, and employees, and those acting in privacy or concert with them, from any further acts of infringement until the expiration of each of the 319 and 896 patents or until such later date as the Court may determine; and H. Awards of such further and other relief as the Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiffs request a jury trial on any and all issues properly so triable.

Dated: February 20, 2014

Respectfully submitted,

/s/ Stephen E. Balogh Stephen E. Balogh Attorney for plaintiff, ALFA LAVAL CORPORATE AB & ALFDEX AB WilliamsMcCarthy LLP 120 W. State St., Suite 400 P.O. Box 219 Rockford, IL 61105-0219 Telephone: (815) 987-8946 Facsimile: (815) 968-0019 E-mail: sbalogh@wilmac.com

Of Counsel: Richard L. Stroup Timothy J. May Cecilia Sanabria Mark S. Zhai FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, DC 20001-4413 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 richard.stroup@finnegan.com timothy.may@finnegan.com cecilia.sanabria@finnegan.com mark.zhai@finnegan.com

CERTIFICATE OF SERVICE I, Stephen E. Balogh, hereby certify that a true and correct copy of the foregoing document entitled COMPLAINT FOR PATENT INFRINGEMENT was electronically filed with the Clerk of the Court for the Northern District of Illinois using the CM/ECF System on February 20, 2014.

/s/ Stephen E. Balogh Stephen E. Balogh Attorney for plaintiff, ALFA LAVAL CORPORATE AB & ALFDEX AB WilliamsMcCarthy LLP 120 W. State St., Suite 400 P.O. Box 219 Rockford, IL 61105-0219 Telephone: (815) 987-8946 Facsimile: (815) 968-0019 E-mail: sbalogh@wilmac.com

Of Counsel: Richard L. Stroup Timothy J. May Cecilia Sanabria Mark S. Zhai FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue, N.W. Washington, DC 20001-4413 Telephone: (202) 408-4000 Facsimile: (202) 408-4400 richard.stroup@finnegan.com timothy.may@finnegan.com cecilia.sanabria@finnegan.com mark.zhai@finnegan.com