Plate v. RCTENN - Complaint

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE

Nashville Division
PLATE LLC,
Case No. ______________________
Plaintiff,
v. PATENT CASE
RCTENN, LLC JURY TRIAL DEMANDED

Defendant.
COMPLAINT
Plaintiff Plate, LLC, a Florida limited liability company (“Plate”) by and through
undersigned counsel, for its Complaint alleges as follows:
NATURE OF THE ACTION
1. Founded in 2014, Plate is reinventing the way military, law enforcement,
and civilians operate firearms. One of Plate’s flagship products lines are its popular
ACEM® magazine loading devices. Among the ACEM’s many innovations, the most
significant is the ability to successively load center feed pistol magazines, a challenge
previously unmet for over a century. Christopher Plate (“Chris”) is the founder and
president of Plate, as well as the named inventor on all patents subject to this action.
2. RCTENN, LLC (“RCTENN”) is a manufacturing company specializing in
plastic molding, including, injection molding of plastics onto metal parts, design
molding, hot stamping, and sonic welding. RCTENN, through a contractual relationship
with Elite Tactical Systems, LLC (“ETS”), manufactures certain ETS products that are
subject to a patent infringement action filed by Plate against ETS and its officers in the
1
Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 1 of 18 PageID #: 1

Eastern District of Tennessee, Case Number, 3:18-CV-265. As the manufacturer of the
infringing ETS products, RCTENN also faces liability for patent infringement.
PARTIES
3. Plate is a Florida limited liability company with its principal place of
business at 4235 SE 20th, Unit B402, Place Cape Coral, FL 33904.
4. Defendant RCTENN is a Tennessee limited liability company. On
information and belief its principal place of business is located at 241 Commerce Way,
Gallatin, TN 37066.
JURISDICTION AND VENUE
5. This action arises under the patent laws of the United States, Title 35 of the
United States Code. This Court has exclusive subject matter jurisdiction over this case for
patent infringement under 28 U.S.C. §§ 1331 and 1338(a).
6. This Court has personal jurisdiction over RCTENN because upon
information and belief, RCTENN’s principle place of business is located in Tennessee.
7. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(1), and 1400.
THE ASSERTED PATENTS
8. On August 22, 2017, the USPTO duly and legally issued U.S. Patent No.
9,739,552 (“the ‘552 Patent”), entitled “Magazine loader,” to Chris. A true and correct
copy of the ‘552 Patent is attached as “Exhibit A.” Plate is the owner by the Assignment
of the ‘552 Patent and holds all rights and interest in that patent. A true and correct copy
of the Assignment is attached as “Exhibit B.”

9. On October 24, 2017, the USPTO duly and legally issued U.S. Patent No.
copy of the ‘669 Patent is attached as “Exhibit C.” Plate is the owner by the Assignment
of the ‘982 Patent and holds all rights and interest in that patent. A true and correct copy
of the Assignment is attached as “Exhibit B.”
10. On April 3, 2018, the USPTO duly and legally issued U.S. Patent No.
copy of the ‘220 Patent is attached as “Exhibit D.” Plate is the owner of the ‘220 Patent
by the Assignment of United States Patent Application 15/713,395. United States Patent
Application 15/713,295 was issued as the ‘220 Patent. As such, Plate holds all rights and
interest in the ‘220 Patent. A true and correct copy of the Assignment is attached as
“Exhibit B.”
11. The ‘552 Patent, ‘669 Patent, and the ‘220 Patent are collectively referred
to herein as the “Asserted Patents.”
12. The Asserted Patents are continuations-in-part; the Asserted Patents contain
both method and device claims. The ‘552 Patent and the ‘669 Patent contain method
claims. The ‘220 Patent contains device and method claims.
FACTUAL BACKGROUND
13. Prior to the issuance of the Asserted Patents, Plate took great efforts to
protect its confidential and proprietary information concerning the designs and mechanics
of its pistol magazine ammunition loading devices (the “Magazine Loader/s”). Plate did
not share confidential and proprietary information regarding the Magazine Loaders with

individuals and entities outside of Plate without executing non-disclosure agreements.
Plate properly labeled all confidential information as such. Plate took these efforts
because the confidential and proprietary information concerning the Magazine Loaders
has independent economic value and to avoid disclosures of prior art.
14. Upon information and belief, RCTENN is engaged as a contract
manufacturer for ETS.
15. Prior to the Asserted Patents being issued, Plate granted ETS access to
Plate’s propriety and confidential information regarding the Magazine Loaders, subject to
a non-disclosure and non-compete agreement (the “Plate NDA”). ETS executed the Plate
NDA on July 29, 2016. A true and correct copy of the Plate NDA is attached as “Exhibit
E.”
16. The Plate NDA indicated that its purpose was for Plate to share confidential
information with ETS so ETS may evaluate the Magazine Loaders. The Plate NDA also
stated that ETS may provide Plate with feedback and information on the Magazine
Loaders.
17. After the Plate NDA was executed, Plate provided ETS confidential
information regarding the Magazine Loaders, including drawings and designs of the
Magazine Loaders, videos of the Magazine Loaders functioning, a Magazine Loader
prototype, and one of the patent applications filed with the USPTO.
18. On or about October 4, 2016, an ETS officer contacted Chris regarding the
Magazine Loaders. The ETS officer informed Chris that ETS made improvements on
Plate’s loader design and ETS desired to make a deal for Plate’s intellectual property.

Prior to further discussions regarding the deal, ETS requested Plate execute a mutual non-
disclosure agreement (the “ETS Mutual NDA”). A true and correct copy of the ETS
Mutual NDA is attached as “Exhibit F.”
19. On or about October 5, 2016, Plate executed the ETS Mutual NDA.
Shortly thereafter, ETS stopped returning Plate’s calls, text messages, emails, and other
attempts to communicate.
20. On or about December 23, 2016, ETS released a promotional video for an
ETS pistol magazine loader, which ultimately would be produced and sold as the C.A.M.
Loader for Pistol Mags 9mm/.40 (the “ETS Pistol Loader 9mm”).
21. Prior to December of 2016, ETS had never advertised magazine
ammunition loaders.
22. On or about June 30, 2017, ETS began selling the ETS Pistol Loader 9mm
on the ETS website.
23. Prior to June of 2017, ETS had never sold magazine ammunition loaders.
24. On or about January 23, 2018, ETS began selling ETS pistol Magazine
Loader models for .380 caliber and .45 caliber bullets, in addition to the second
generation model for 9mm and .40 caliber. The ETS products’ names are as follows:
C.A.M. Loader for All Pistol Mags .380 caliber (“ETS Pistol Loader .380”); C.A.M.
Loader for All Pistol Mags .45 caliber (“ETS Pistol Loader .45”); GEN II - C.A.M.
Loader for All Pistol Mags 9mm/.40 caliber (“ETS Pistol Loader Gen II 9mm”).

25. The ETS Pistol Loader 9mm, ETS Pistol Loader Gen II 9mm, ETS Pistol
Loader .380, and ETS Pistol Loader .45 are collectively referred to herein as the
“Infringing ETS Products.”
26. The Infringing ETS Products consist of the same core elements, which
equally infringe on the Asserted Patents. The minor differences among each of the
Infringing ETS Products primarily consist of those needed for the different caliber sizes,
as well as other superficial variations.
27. Upon information and belief, as a contract manufacturer for ETS, RCTENN
manufactured all or nearly all of the Infringing ETS Products that have been sold and
distributed into interstate commerce.
28. Upon information and belief, as a contract manufacturer for ETS, RCTENN
continues to manufacture all or nearly all of the Infringing ETS Products that ETS sells
and distributes into interstate commerce.
29. Upon information and belief, RCTENN has manufactured, and ETS has
sold, approximately 40,000-50,000 units of the Infringing ETS Products since June 2017.
30. Upon information and belief, RCTENN has received substantial financial
consideration from ETS for manufacturing the Infringing ETS Products.
31. Upon information and belief, RCTENN has received written notice from
Plate that RCTENN is infringing the Asserted Patents by manufacturing the Infringing
ETS Products for ETS.
32. On or about January 23, 2018, Plate mailed a cease and desist letter to
RCTENN’s principle place of business at 241 Commerce Way, Gallatin, TN 37066

(“Plate Cease and Desist 1”). Plate Cease and Desist 1, informed its recipients about the
patents issued to Plate at the time, specifically including the ‘552 Patent and the ‘669
Patent. Plate Cease and Desist 1 also informed its recipients that the Infringing ETS
Products infringed Plate’s then issued patents. Finally, Plate Cease and Desist 1 included
copies of the ‘552 Patent and the ‘669 Patent, including the patents’ claims and drawing
sheets. A true and correct copy of Plate Cease and Desist 2 is attached as “Exhibit G.”
33. On or about April 6, 2018, Plate mailed a second cease and desist letter to
RCTENN’s principle place of business at 241 Commerce Way, Gallatin, TN 37066
(“Plate Cease and Desist 2”). Plate Cease and Desist 2, informed its recipients that the
‘220 Patent was issued. Plate Cease and Desist 2 reaffirmed Plate’s demand that its
recipients stop infringing the Asserted Patents as originally demanded in Plate Cease and
Desist 1. Finally, Plate Cease and Desist 2 included copies of all the Asserted Patents,
including the Asserted Patents’ claims and drawing sheets. A true and correct copy of
Plate Cease and Desist 3 is attached as “Exhibit H.”
34. Plate brings this action to recover the just compensation it is owed for
RCTENN’S past infringement, and to prevent RCTENN from continuing to benefit from
infringing the Asserted Patents in the future without authorization or compensation to
Plate.
COUNT I – INFRINGEMENT OF THE ‘552 PATENT
35. Plate incorporates and realleges all preceding paragraphs as if set forth fully
hereinafter.

36. RCTENN has directly infringed and continues to directly infringe, literally
or under the doctrine of equivalents, claims 1-6 of the ‘552 Patent in violation of 35
U.S.C. §271(a) by making, manufacturing, using, marketing, offering to sell, and selling,
directly and through intermediaries, in this District and elsewhere in the United States,
the Infringing ETS Products.
37. For example, the Infringing ETS Products infringe claim 1 of the ‘552
Patent, which provides as follows:
1. A method of using an ammunition magazine loader to load a plurality of

ammunition rounds into an ammunition magazine having a follower, a
spring providing a spring force biasing the follower upwardly, and a
magazine shape, with each round respectively including first and second
case ends and a pivot point, and with the magazine loader comprising a main
body having a first main body end, a second main body end, and a main
body length, a rounds recess, extending along the main body length, and
having first and second rounds recess ends, a rounds recess bottom, first and
second rounds recess sides, and first and second rounds recess ledges, with
the rounds recess bottom, first rounds recess side, and first rounds recess
ledge defining a first rounds cavity between the rounds recess bottom and
the first rounds recess ledge, with the rounds recess bottom, second rounds
recess side, and second rounds recess ledge defining a second rounds cavity
between the rounds recess bottom and the second rounds recess ledge, the
rounds recess being shaped to hold the rounds therein with each first case
end positioned within the first rounds cavity and under the first rounds
recess ledge and with each second case end positioned within the second
rounds cavity and under the second rounds recess ledge, the second rounds
recess end being positioned at the second main body end, and at least a
portion of the rounds recess being shaped to accept each round into the
rounds recess, a rounds abutment, connected to the loader, and at least
partially positioned within the rounds recess and at the first rounds recess
end, a magazine recess, in communication with the rounds recess, and
positioned at the first main body end, the magazine recess being
complementarily shaped to the magazine shape to retain the magazine in a
fixed position within the magazine recess and the first rounds recess end
opens into the magazine recess, said method comprising:
a. positioning the magazine within the magazine recess;

b. introducing the rounds into the rounds recess; and
c. with a structure, pushing the rounds, via a last round, towards and into the
magazine, such that as the rounds are slidably moved out of the rounds
recess through the second rounds recess end, the pivot point of each round
contacts the rounds abutment to angle each second case end towards the
magazine recess, and when an exiting round exits the rounds recess, the
exiting round abuts and forces at least one of the follower and a pre-loaded
round in the magazine downwardly into the magazine against the spring
force as the exiting round enters the magazine.
38. The Infringing ETS Products are ammunition magazine loaders that load a
plurality of ammunition rounds into an ammunition magazine having a follower, a spring
biasing the follower upwardly, and a magazine shape.
39. The Infringing ETS Products main body includes a first main body end, a
second main body end, a main body length, and an upper surface.
40. The Infringing ETS Products include a rounds recess that extends along
main body length. The Infringing ETS Products have first and second rounds recess ends.
The Infringing ETS Products have a rounds recess bottom, first and second rounds recess
sides, first and second rounds recess ledges, and first and second cavities. Specifically
note that The Infringing ETS Products ledges meet and are formed into each other. The
Infringing ETS Products rounds recess is shaped to hold rounds exactly in the same
claimed positions. The Infringing ETS Products second rounds recess end is positioned at
second main body end. The Infringing ETS Products second rounds recess end is shaped
to accept each round into rounds recess.

41. The Infringing ETS Products include a rounds abutment that is connected
to the loader and is at least partially positioned within rounds recess and at first rounds
recess end.
42. The Infringing ETS Products include a magazine recess in communication
with the rounds recess and positioned at first main body end. The Infringing ETS
Products magazine recess is complementarily shaped to magazine shape to retain
magazine in fixed position within magazine recess. The Infringing ETS Products first
rounds recess end opens into their magazine recess.
43. Use directions for the Infringing ETS Products instruct users to seat
magazine all the way into the loader.
44. When the Infringing ETS Products plunger is compressed towards
magazine, a plurality of rounds are introduced into the rounds recess.
45. The Infringing ETS Products plunger pushes the rounds, via a last round,
towards and into magazine. With the Infringing ETS Products, as rounds are slidably
moved out of rounds recess through first rounds recess end, the pivot point of each round
contacts rounds abutment to angle each second case end towards magazine recess, and
when an exiting round exits rounds recess, the exiting round abuts and forces the follower
or a pre-loaded round downwardly into magazine against spring force.
46. By way of the Plate Cease and Desist 1 letter, Plate has properly provided
written notice to RCTENN of the ‘552 Patent Plate holds and how the ETS Infringing
Products infringe the ‘552 Patent.
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COUNT II – INFRINGEMENT OF THE ‘669 PATENT
hereinafter.
or under the doctrine of equivalents, claims 1, 22, and 23 of the ‘669 Patent in violation
of 35 U.S.C. §271(a) by making, manufacturing, using, marketing, offering to sell, and
selling, directly and through intermediaries, in this District and elsewhere in the United
States, the Infringing ETS Products.

magazine shape, with each round respectively including first and second
rounds ends and a pivot point, and with the magazine loader comprising a
main body having a first main body end, a second main body end, and a
main body length, a rounds recess, extending along the main body length,
and having first and second rounds recess ends, a rounds recess bottom,
first and second rounds recess sides, and first and second rounds recess
ledges, with the rounds recess bottom, first rounds recess side, and first
rounds recess ledge defining a first rounds cavity between the rounds recess
bottom and the first rounds recess ledge, with the rounds recess bottom,
second rounds recess side, and second rounds recess ledge defining a
second rounds cavity between the rounds recess bottom and the second
rounds recess ledge, and with the rounds recess being shaped to hold the
plurality of rounds therein with each respective first rounds end positioned
within the first rounds cavity and under the first rounds recess ledge and
with each second rounds end positioned within the second rounds cavity
and under the second rounds recess ledge, at least a portion of the rounds
recess being shaped to accept each round into the rounds recess, the second
rounds recess side terminating at a first downwardly angled portion, and the
first rounds recess side including a second downwardly angled portion, and
a magazine recess in communication with the rounds recess and positioned
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at the first main body end, the magazine recess being complementarily
shaped to the magazine shape to retain the magazine in a fixed position
within the magazine recess, said method comprising:
a. positioning the magazine within the magazine recess;
b. introducing the rounds into the rounds recess; and
c. with a structure, pushing the rounds, via a last round, towards and into
the magazine, such that as the plurality of rounds are moved towards the
magazine, the pivot point of each round successively contacts the second
downwardly angled portion to pivot the second rounds end of each
successive round towards the magazine, the second rounds end of each
successive round passes over the first downwardly angled portion, and
when an exiting round exits the rounds recess, the exiting round abuts and
forces at least one of the follower and a pre-loaded round in the magazine
downwardly into the magazine against the spring force as the exiting round
enters the magazine.
biasing the follower upwardly, and a magazine shape. The Infringing ETS Products
interact with each round based on the round’s first case end, second case end, and pivot
point.
51. The Infringing ETS Products main body includes a first main body end, a
second main body end, and a main body length.
52. The Infringing ETS Products include a rounds recess that extends along
main body length. The Infringing ETS Products have first and second rounds recess ends.
The Infringing ETS Products have a rounds recess bottom, first and second rounds recess
sides, first and second rounds recess ledges, and first and second cavities. Specifically
note that The Infringing ETS Products ledges meet and are formed into each other. The
12

Infringing ETS Products first and second cavities are defined with the same structure as
claimed. As per the immediately preceding note, The Infringing ETS Products ledges
meet and are formed into each other in a continuous manner. The Infringing ETS
Products rounds recess is shaped to hold rounds exactly in the same claimed positions.
The Infringing ETS Products second rounds recess end is shaped to accept each round
into rounds recess. The Infringing ETS Products second rounds recess side terminates at a
first downwardly angled portion that opens in the said magazine recess. The Infringing
ETS Products first rounds recess side includes a second downwardly angled portion.
53. The Infringing ETS Products include a magazine recess in communication
with the rounds recess and positioned at first main body end. The Infringing ETS
Products magazine recess is complementarily shaped to magazine shape to retain
magazine in fixed position within magazine recess.
magazine, a plurality of rounds are introduced into the rounds recess.
towards the magazine, the pivot point of each round successively contacts the second
downwardly angled portion to pivot the second rounds end of each successive round
towards the magazine, the second rounds end of each successive round passes over the
first downwardly angled portion, and when an exiting round exits rounds recess, the
13

exiting round abuts and forces the follower or a pre-loaded round downwardly into
magazine against spring force.
COUNT III – INFRINGEMENT OF THE ‘220 PATENT
hereinafter.
or under the doctrine of equivalents, claims 1-38 of the ‘220 Patent in violation of 35
U.S.C. §271(a) by making, manufacturing, using, marketing, offering to sell, and selling,
directly and through intermediaries, in this District and elsewhere in the United States,
the Infringing ETS Products.

magazine shape, with each round respectively including a first case end, a
second case end opposite the first case end, and a pivot point, and with the
magazine loader comprising a main body having first and second main body
ends, a magazine cavity, formed within the main body end, and
complimentarily shaped to the magazine shape to retain the magazine in a
fixed position within the magazine cavity, a rounds cavity, formed within
the main body, and having first and second rounds cavity ends, the first
rounds cavity end being in communication with the magazine cavity, the
rounds cavity being defined in part by first and second rounds cavity slides,
at lead one upper rounds cavity abutment, and at least one lower rounds
14

cavity abutment being positioned to abbutingly limit movement of the
rounds along a movement place when the rounds exit the rounds cavity, and
at least a portion of the rounds cavity being shaped to accept each round into
the rounds cavity, and a rounds abutment, at least partially positioned,
within the rounds cavity, and at the first rounds cavity end, said method
comprising:
a. positioning the magazine within the magazine cavity;
b. introducing the rounds into the rounds cavity; and
c. with a structure, pushing the rounds, via a last round, towards and into the
magazine, such that as the rounds are moved towards the magazine, the
pivot point of each round successively contacts the rounds abutment to angle
the second rounds end of each successive round towards the magazine, and
when an existing round exits the rounds cavity, the exiting round abuts and
forces at least one of the follower and a pre-loaded round in the magazine
into the magazine against the spring force as the existing round enters the
magazine.
biasing the follower upwardly, and a magazine shape. The Infringing ETS Products
interact with each round based on the round’s first case end, second case end, and pivot
point.
62. The Infringing ETS Products main body includes a first main body end and
a second main body end.
63. The Infringing ETS Products include a magazine cavity positioned at first
main body end. The Infringing ETS Products magazine cavity is complementarily shaped
to magazine shape to retain magazine in fixed position within magazine cavity.
64. The Infringing ETS Products include a rounds cavity formed within the
main body. The Infringing ETS Products have first and second rounds cavity ends. The
15

Infringing ETS Products include a magazine cavity in communication with the rounds
cavity end. The Infringing ETS Products have first and second rounds cavity sides, upper
and lower rounds cavity abutments, and first and second cavities. The Infringing ETS
Products rounds cavity is shaped to hold rounds exactly in same claimed positions. The
Infringing ETS Products have a rounds abutment positioned within said rounds cavity
and at the first rounds cavity end.
magazine, a plurality of rounds are introduced into the rounds cavity.
towards the magazine, the pivot point of each round successively contacts the rounds
abutment to pivot the second rounds end of each successive round towards the magazine,
and when an exiting round exits rounds recess, the exiting round abuts and forces the
follower or a pre-loaded round downwardly into magazine against spring force.
PRAYER FOR RELIEF
WHEREFORE Plate prays for relief, as follows:
A. A judgment that each of Plate’s Asserted Patents is valid and enforceable;
16

B. A judgment that Defendant has directly and indirectly infringed one or
more claims of each of Plate’s Asserted Patents;
C. An order and judgment permanently enjoining Defendant and Defendant’s
officers, directors, agents, servants, employees, affiliates, attorneys, and all others acting
in privity or concert with them, and their parents, subsidiaries, divisions, successors and
assigns from further acts of infringement of Plate’s Asserted Patents;
D. A judgment awarding Plate all damages adequate to compensate for
Defendant’s infringement of Plate’s Asserted Patents, and in no event less than a
reasonable royalty for Defendant’s acts of infringement, including all pre-judgment and
post-judgment interest at the maximum rate permitted by law;
E. A judgment awarding Plate all damages, including treble damages, based
on any infringement found to be willful, pursuant to 35 U.S.C. § 284, together with pre-
judgment interest;
F. A judgment awarding Plate all of Defendant’s profits, pursuant to 35
U.S.C. § 289 together with pre-judgment interest;
G. Actual damages suffered by Plate as a result of Defendant’s unlawful
conduct, in an amount to be proven at trial, as well as pre-judgment interest as authorized
by law;
H. A judgment that this is an exceptional case and an award to Plate of its
costs and reasonable attorneys’ fees incurred in this action as provided for by 35 U.S.C. §
285;
17

I. A judgment awarding punitive damages against the Defendants in an
amount sufficient to deter similar behavior in the future by the Defendants and to deter
others from similar behavior;
J. Such other relief as this Court deems just and proper.
DEMAND FOR JURY TRIAL
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plate hereby
demands trial by jury on all issues raised by the Compliant.
RESPECTFULLY SUBMITTED this __th day of August, 2018.
By: __s/Van R. Irion________________

Van R. Irion
TN Bar Number 024519
Law Office of Van R. Irion
800 South Gay Street, Suite 700
Knoxville, TN 37929
Attorney for Plaintiff, Pro Hac Vice
William M. Fischbach
Arizona Bar Number: 019769
Tiffany & Bosco, P.A.
2525 East Camelback Road, Seventh Floor
Phoenix, AZ 85016
Attorney for Plaintiff, Pro Hac Vice
18

JS 44 (Rev. 11/15) CIVIL COVER SHEET
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

Plate LLC RCTenn LLC
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant Sumner
(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)
Law Office of Van R. Irion, PLLC
800 S. Gay St., Ste. 700
Knoxville, TN 37929 (865) 766-4040
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(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
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Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

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Proceeding State Court Appellate Court Reopened Another District Litigation
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 USC 1391
VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement
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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
08/25/2018 s/Van R. Irion
FOR OFFICE USE ONLY
RECEIPT # Case 3:18-cv-00806 Document

AMOUNT 1-1 Filed 08/29/18
APPLYING IFP JUDGEPage 1 of 2 PageID #: 19
MAG. JUDGE
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Case 3:18-cv-00806 Document 1-1 Filed 08/29/18 Page 2 of 2 PageID #: 20

CONFIDENTIAL INFORMATION
ACCESS AUTHORIZATION REQUIRED FROM PLATE, LLC PRESIDENT
PLATE™, LLC
CLAIMS CHART
Analysis of Elite Tactical Systems Group, LLC “CAM Loader” products and their infringement of PLATE patents.
DOCKET NUMBER STATUS ISSUE DATE USPN/USPAN
CHRPLA-PT02 Issued 04/11/17 9,618,286
CHRPLA-PT03 Issued 06/27/17 9,689,633
CHRPLA-PT04 Issued 08/22/17 9,739,522
CHRPLA-PT05 Issued 10/24/17 9,797,669
CHRPLA-PT06 Notice of Allowance 03/01/18 (ESTIMATE) 15/713,395
PRODUCT NAME (COLLECTIVELY “ETS”) PART NUMBER RETAIL DATE UPC
C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 06/30/17 854094005492
GEN II- C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 12/31/17 854094005492
C.A.M. Loader For All Pistol Mags .45 Caliber ETSCAM45 12/31/17 854094005546
C.A.M. Loader For All Pistol Mags .380 Caliber ETSCAM380 12/31/17 854094005553
Rev. 1 …………………………………10-08-2017
Rev. 2 …………………………………10-24-2017 (added 9,797,669)
Rev. 3 …………………………………01-10-2018 (added 15/713,395, UPC 854094005546 (ETSCAM-45), & UPC 854094005553 (ETSCAM-380))
Rev. 4 …………………………………01-15-2018 (added images, See pages 2-3)
Page 0 of 41
CLAIMS CHART
REV-4 (01-15-2018)
PREAMBLE
While four different ETS products are included in this analysis, one model is used in all figures. It should be noted all four
products contain all of the same elements. “C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber” was launched first and is
sized for 9mm/40 S&W rounds. “GEN II- C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber” is the second generation of
the 9mm model and includes all of the elements of the first generation with more exaggerated features of the rounds
abutment area. Pages 2-3 contain pictures of the various ETS models concerning this analysis.
All patents are continuations-in-part; the family contains both method and device claims. PT02 and PT03 contain device
claims, PT04 and PT05 contain method claims, and PT06 contains both device and method claims. PT06 is currently
pending and has been allowed; the estimated issue date is March 2018.
CONTENTS
CHRPLA-PT02 - USPN 9,618,296 .......................................................................................................................................................................................... 4
CHRPLA-PT03 - USPN 9,689,633 .......................................................................................................................................................................................... 8
CHRPLA-PT04 - USPN 9,739,552 ........................................................................................................................................................................................ 10
CHRPLA-PT05 - USPN 9,797,669 ........................................................................................................................................................................................ 13
CHRPLA-PT06 - USPAN 15/713,395 ................................................................................................................................................................................... 16
Page 1 of 41
CLAIMS CHART
REV-4 (01-15-2018)
Page 2 of 41
CLAIMS CHART
REV-4 (01-15-2018)
Page 3 of 41
CLAIMS CHART
REV-4 (01-15-2018)
CHRPLA-PT02 - USPN 9,618,286 ETS

1. An ammunition magazine loader configured to load at least ETS is an ammunition magazine loader that loads at least one ammunition
one ammunition round into round into a pistol magazine (They advertise Glock Mag compatible.)
a magazine having, a follower, a spring providing a spring ETS operates with pistol magazines that have a follower, a spring biasing the
force biasing the follower upwardly, and a magazine shape, follower upwardly, and a magazine shape.
with each round 3 respectively including first and second ETS interacts with each round based on the round’s first case end 4, second
case ends 4, 5 and a pivot point 6 (See Fig 3b and 5a) case end 5, and pivot point 6. (See I-4 and I-7)
said ammunition magazine loader comprising:

a main body 110 having a first main body end 111, a second ETS main body 110 includes a first main body end 111, a second main body
main body end 112, a main body length 113, and an upper end 112, a main body length 113, and an upper surface 114. (See I-1.)
surface 114; (See Fig 1b)
a rounds recess 120, extending into said main body from the ETS includes a rounds recess 120 that extends into the main body from
upper surface and along the main body length, and having upper surface 114 [See I-1: from upper surface 114 towards and into main
first and second rounds recess ends 121, 122, a rounds recess body at second rounds recess end 122] and along main body length 113.
bottom 123, first and second rounds recess sides 124, 125, and (See I-1).
first and second rounds recess ledges 126, 127, It has first and second rounds recess ends 121, 122 (See I-6).
with the rounds recess bottom, first rounds recess side 124, It has a rounds recess bottom 123, first and second rounds recess sides 124,
and first rounds recess ledge 126 defining a first case cavity 128 125, first and second rounds recess ledges 126, 127, and first and second
between the rounds recess bottom and the first rounds recess cavities 128, 129 (See I-3, and note: ETS ledges 126, 127 meet and are
ledge, formed into each other.)
with the rounds recess bottom, second rounds recess side 125,
and second rounds recess ledge 127 defining a second case
cavity 129 between the rounds recess bottom and the second
rounds recess ledge, and
said rounds recess being shaped to hold the at least one round ETS rounds recess 120 is shaped to hold rounds exactly in same claimed
3 therein with each first case end 4 positioned within the first positions (See I-3 and I-4)
case cavity and under the first rounds recess ledge and with each
second case end 5 positioned within the second case cavity and
under the second rounds recess ledge; (See Figs 3b and 5a)
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CLAIMS CHART
REV-4 (01-15-2018)
a rounds abutment 150, connected to the loader, and at least ETS includes a rounds abutment 150 (the angled surface at first rounds
partially positioned within said rounds recess 120 and at the first recess end 121) positioned within rounds recess 120. (See I-5)
rounds recess end 121; (See Fig 5a)
a magazine recess 130, extending into said main body from ETS includes a magazine recess 130 that extends into main body from upper
the upper surface 114, and positioned at the first main body end, surface 114 [from upper surface 114 towards and into main body at first
said magazine recess being complementarily shaped to the main body end 111] (See I-1).
magazine shape to retain the magazine 6 in a fixed position ETS magazine recess 130 is complementarily shaped to hold a magazine 1 in
within said magazine recess; (See Figs 2a and 4) a fixed position. (See I-7)
wherein the second rounds recess end 122 is, positioned at the ETS second rounds recess end 122 is positioned at second main body end
second main body end 112, and shaped to accept each of the at 112, and it is clearly shaped to accept each of the at least one round into its
least one round into said rounds recess, rounds recess 120 (See I-4).
and the first rounds recess end opens into said magazine ETS first rounds recess end 121 opens into its magazine recess 130 (See I-6)
recess,
such that with the magazine positioned within said magazine ETS in operation manipulates the rounds exactly as claimed; in particular,
recess and as the at least one round is slidably moved out of said pivot point 6 contacts rounds abutment 150 to angle second case end 5 of
rounds recess through the first rounds recess end, each respective round towards magazine recess 130, such that when an
the pivot point 6 of the one or more rounds contacts said exiting round exits the rounds recess, the exiting round abuts and forces the
rounds abutment 150 to angle the second case end 5 of each follower or a pre-loaded round in magazine 1 downwardly into the magazine
respective round towards said magazine recess, against the spring force as the exiting round enters the magazine (See I-7).
and when an exiting round 3 exits said rounds recess, the
exiting round abuts and forces at least one of the follower and a
pre-loaded round 3a in the magazine 1 downwardly into the
magazine against the spring force as the exiting round enters the
magazine. (See Figs 5c and 5d)
5. The ammunition magazine loader of claim 1, wherein said ETS magazine recess 130 has magazine recess bottom that has
magazine recess 130 includes a magazine recess bottom having has a magazine retention depression 133 and a magazine retention abutment
at least one of a magazine retention depression 133 and a 134. (See I-8)
magazine retention abutment 134. (See Fig. 1a)
6. The ammunition magazine loader of claim 1, further ETS has a rounds retention recess 140 that extends into main body 110 from
comprising a rounds retention recess 140, extending into said upper surface 114, positioned at second main body end 112, and opens into
main body from the upper surface, positioned at the second main second rounds recess end 122, such that one or more of the at least one round
body end, and opening into the second rounds recess end, such 3 are moveable from rounds retention recess to second rounds recess end.
that one or more of the at least one round 3 are moveable from (See I-9 and I-15)
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CLAIMS CHART
REV-4 (01-15-2018)
said rounds retention recess to the second rounds recess

end. (See Fig. 2a)
7. The ammunition magazine loader of claim 1, wherein one of Blank same dimension of live round.
the at least one round is a blank round, and another of the at least
one round is an active round.
8. The ammunition magazine loader of claim 1, wherein the ETS designed to work with Glock magazines, so its magazine recess length
magazine 1 has a magazine length 2, and said magazine recess 131 is less than a magazine length 2. (See I-10)
130 has a magazine recess length 131 less than the magazine
length 2. (See Fig. 1b)
9. The ammunition magazine loader of claim 8, wherein each of Claims as above.
the at least one round is positioned within said rounds recess, and
each first case end if positioned between the first rounds recess
ledge and the rounds recess bottom.
10. The ammunition magazine loader of claim 8, wherein each of Claims as above.
the at least one round is positioned within said rounds recess, and
each first case end if positioned between the second rounds
recess ledge and the rounds recess bottom.
11. The ammunition magazine loader of claim 10, wherein each Claims as above.
of the at least one round is positioned within said rounds recess,
and each first case end if positioned between the first rounds
12. The ammunition magazine loader of claim 8, wherein said Claims as above.
magazine recess includes having at least one of a magazine
retention depression and a magazine retention abutment.
13. The ammunition magazine loader of claim 8, further Claims as above.
comprising a rounds retention recess, extending into said man
body from the upper surface, positioned at the second main body
end, and opening into the second rounds recess end, such that
one or more of the at least one round is movable from said
rounds retention recess to the second rounds recess end.
14. The ammunition magazine loader of claim 8, wherein one of Claims as above.
the at least one round is a blank round, and another of the at least
one round is an active round.
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CLAIMS CHART
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15. The ammunition magazine loader of claim 1, wherein the ETS first rounds recess side 124 includes an inwardly curved shape 150 that
first rounds recess side 124 includes an inwardly curved shape provides a rounds abutment 150 that manipulates rounds as per claim 1. (See
that provides said rounds abutment 150. I-14) Note: ETS technically has two (2) rounds abutments (cf. 150 in I-5)
and each first case end is positioned between the first rounds
and each first case end is positioned between the second rounds
and each first case end is positioned between the first rounds
19. The ammunition magazine loader of claim 15, wherein said Claims as above.
magazine recess includes a magazine recess bottom having at
least one of a magazine retention depression and a magazine
retention abutment.
20. The ammunition magazine loader of claim 15, further Claims as above.
comprising a rounds retention recess, extending into said main
body from the upper surface, positioned at the second main body
end, and opening into the second rounds recess end, such that
one or more of the at least one round is movable from said
rounds retention recess of the second rounds recess end.
21. The ammunition magazine loader of claim 15, wherein one Claims as above.
of the at least one round is a blank round, and another of the at
least one round is an active round.
Page 7 of 41
CLAIMS CHART
REV-4 (01-15-2018)

1. An ammunition magazine loader configured to load a ETS is an ammunition magazine loader that loads at least one ammunition
plurality of ammunition rounds into round into a pistol magazine (They advertise Glock Mag compatible.)
a magazine having, a follower, a spring providing a spring ETS operates with pistol magazines that have a follower, a spring biasing the
force biasing the follower upwardly, and a magazine shape, follower upwardly, and a magazine shape.
with each round 3 respectively including first and second ETS interacts with each round based on the round’s first case end 4, second
case ends 4, 5 and a pivot point 6 (See Fig 3b and 5a) case end 5, and pivot point 6. (See I-4 and I-7)

a main body 110 having a first main body end 111, a second ETS main body 110 includes a first main body end 111, a second main body
main body end 112, a main body length 113, and an upper end 112, a main body length 113, and an upper surface 114. (See I-1.)
surface 114; (See Fig 1b)
a rounds recess 120, extending into said main body from ETS includes a rounds recess 120 that extends into the main body from
the upper surface and along the main body length, and having upper surface 114 [See I-1: from upper surface 114 towards and into main
first and second rounds recess ends 121, 122, a rounds recess body at second rounds recess end 122] and along main body length 113.
bottom 123, first and second rounds recess sides 124, 125, and (See I-1).
first and second rounds recess ledges 126, 127, It has first and second rounds recess ends 121, 122 (See I-6).
with the rounds recess bottom, first rounds recess side 124, It has a rounds recess bottom 123, first and second rounds recess sides 124,
and first rounds recess ledge 126 defining a first case cavity 128 125, first and second rounds recess ledges 126, 127, and first and second
between the rounds recess bottom and the first rounds recess cavities 128, 129 (See I-3, and note: ETS ledges 126, 127 meet and are
ledge, formed into each other.)
with the rounds recess bottom, second rounds recess side 125,
and second rounds recess ledge 127 defining a second case
cavity 129 between the rounds recess bottom and the second
rounds recess ledge, and
said rounds recess being shaped to hold the at least one round ETS rounds recess 120 is shaped to hold rounds exactly in same claimed
3 therein with each first case end 4 positioned within the first positions (See I-3 and I-4)
case cavity and under the first rounds recess ledge and with each
second case end 5 positioned within the second case cavity and
under the second rounds recess ledge; (See Figs 3b and 5a)
a magazine recess 130, extending into said main body from ETS includes a magazine recess 130 that extends into main body from upper
the upper surface 114, and positioned at the first main body end, surface 114 [from upper surface 114 towards and into main body at first
main body end 111] (See I-1).
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CLAIMS CHART
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said magazine recess being complementarily shaped to the ETS magazine recess 130 is complementarily shaped to hold a magazine 1 in
magazine shape to retain the magazine 6 in a fixed position a fixed position. (See I-7)
within said magazine recess; (See Figs 2a and 4)
wherein the first rounds recess end 121 opens into said ETS first rounds recess end 121 opens into magazine recess 130 (See I-11)
magazine recess 130 (See Fig 4),
the second rounds recess side 125 terminates at a first ETS second rounds recess side 125 terminates at a first downwardly angled
downwardly angled portion E that opens into said magazine portion E that opens in the said magazine recess 130 (See I-11).
recess 130 (See Fig. 8), and
the first rounds recess side 124 includes a second downwardly ETS first rounds recess side 124 includes a second downwardly angled
angled portion A (See Fig. 8), portion A (See I-11).
such that with magazine 1 positioned within magazine recess With magazine 1 positioned within magazine recess 130 and as the plurality
130 and as plurality of rounds 1 are moved towards magazine 1, of rounds are moved towards the magazine 1,
the pivot point 6 of each round 3 successively contacts the the pivot point 6 of each round successively contacts the second
second downwardly angled portion A to pivot the second rounds downwardly angled portion A to pivot the second rounds end 5 of each
end 5 of each successive round towards the magazine (See Figs successive round towards the magazine (See I-16),
5c, 5d, and 8),
the second rounds end 5 of each successive round passes over the second rounds end 5 of each successive round passes over the first
the first downwardly angled portion E (See Figs. 5c, 5d, and 8), downwardly angled portion E (See I-16), and
and
when an exiting round 3 exits said rounds recess 120, the when an exiting round 3a exits rounds recess 120, the exiting round
exiting round abuts and forces at least one of the follower 1a abuts and forces at least one of the follower 1a and a pre-loaded round 3a in
and a pre-loaded round 3a in the magazine 1 downwardly into the magazine 1 downwardly into the magazine against the spring force SF as
the magazine against the spring force SF as the exiting round the exiting round enters the magazine. (See I-16)
enters the magazine (See Figs. 5c, 5d, and 8).
22. The loader of claim 1, wherein the first rounds recess side ETS first rounds recess side 124 includes a third downwardly angled portion
124 includes a third downwardly angled portion D positioned D positioned between magazine recess 130 and second downwardly angled
between said magazine recess 130 and the second downwardly portion A. (See I-13)
angled portion A. (See Fig. 8)
23. The loader of claim 22, wherein the third downwardly angled ETS third downwardly angled portion D has a concave shape. (See I-13)
portion D is provided with a concave shape. (See Fig. 8)
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CLAIMS CHART
REV-4 (01-15-2018)

1. A method of using an ammunition magazine loader to load a ETS is an ammunition magazine loader that loads a plurality of ammunition
plurality of ammunition rounds 3 into an ammunition magazine round 3 into an ammunition magazine (advertised as Glock Magazine
1 having a follower 1a, a spring S providing a spring force SF compatible) having a follower, a spring biasing the follower upwardly, and a
biasing the follower upwardly, and a magazine shape, magazine shape.
with each round respectively including first and second case ETS interacts with each round based on the round’s first case end 4, second
ends and a pivot point, case end 5, and pivot point 6. (See I-4 and I-7)
and with the magazine loader comprising
a main body having a first main body end, a second main body ETS main body 110 includes a first main body end 111, a second main body
end, and a main body length, end 112, a main body length 113, and an upper surface 114. (See I-1)
a rounds recess 120, extending along the main body length, ETS includes a rounds recess 120 that extends along main body length 113.
and having (See I-1).
first and second rounds recess ends 121, 122, a rounds recess It has first and second rounds recess ends 121, 122 (See I-6).
bottom 123, first and second rounds recess sides 124,125, and It has a rounds recess bottom 123, first and second rounds recess sides 124,
first and second rounds recess ledges 126, 127, 125, first and second rounds recess ledges 126, 127, and first and second
cavities 128, 129 (See I-3, and note: ETS ledges 126, 127 meet and are
formed into each other.)
with the rounds recess bottom, first rounds recess side, and ETS first and second cavities 128, 129 are defined with same structure as
first rounds recess ledge defining a first rounds cavity 128 claimed. And as per note above, ETS ledges 126, 127 meet and are formed
between the rounds recess bottom and the first rounds recess into each other in a continuous manner.
ledge, (See Fig. 3a)
with the rounds recess bottom, second rounds recess side, and “
second rounds recess ledge defining a second rounds cavity 129 “
between the rounds recess bottom and the second rounds recess “
ledge, (See Fig. 3a)
the rounds recess being shaped to hold the rounds therein with ETS rounds recess 120 is shaped to hold rounds exactly in same claimed
each first case end positioned within the first rounds cavity and positions (See I-3 and I-4)
under the first rounds recess ledge and with each second case
end positioned within the second rounds cavity and under the
second rounds recess ledge, (See Fig. 3b)
the second rounds recess end 122 being positioned at the ETS second rounds recess end 122 is positioned at second main body end
second main body end 112 (See Fig. 1a), and 112. (See I-1)
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CLAIMS CHART
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at least a portion of the rounds recess 120 being shaped to ETS second rounds recess end 122 is shaped to accept each round into
accept each round into the rounds recess (See Fig. 1a), rounds recess 120 (See I-4)
a rounds abutment 150, connected to the loader, and at least ETS includes a rounds abutment 150 (the angled surface 150) that is
partially positioned within the rounds recess 120 and at the first connected to the loader and is at least partially positioned within rounds
rounds recess end 121 (See Fig. 5a), recess 120 and at first rounds recess end 121 (See I-5)
a magazine recess 130, in communication with the rounds ETS includes a magazine recess 130 in communication with the rounds
recess 120, and positioned at the first main body end 111, recess 120 and positioned at first main body end 111. (See I-1)
the magazine recess being complementarily shaped to the ETS magazine recess 130 is complementarily shaped to magazine shape to
magazine shape to retain the magazine 1 in a fixed position retain magazine 1 in fixed position within magazine recess (See I-7)
within the magazine recess (See Figs 2a and 4) and
the first rounds recess end 121 opens into the magazine recess ETS first rounds recess end 121 opens into its magazine recess 130 (See I-6)
said method comprising:

a. positioning the magazine within the magazine recess; “Seat magazine all the way into the loader.” (See Step 1 in ETS
DIRECTIONS; attached and at https://www.etsgroup.us/ETS-Group-C-
A-M-Loader-p/etscam-9-40.htm)
b. introducing the rounds into the rounds recess; and When ETS plunger is compressed towards magazine, a plurality of rounds
are introduced into the rounds recess. (See Step 3 in ETS DIRECTIONS)
c. with a structure, pushing the rounds, via a last round, towards ETS plunger pushes the rounds 3, via a last round, towards and into
and into the magazine, magazine 1
such that as the rounds are slidably moved out of the rounds With ETS, as rounds 3 are slidably moved out of rounds recess 120 through
recess through the FIRST (CC) rounds recess end, first rounds recess end 121, the pivot point 6 of each round 1 contacts rounds
the pivot point of each round contacts the rounds abutment to abutment 150 to angle each second case end towards magazine recess 130
angle each second case end towards the magazine recess, and (See Step 3 in ETS DIRECTIONS and I-7), and
when an exiting round exits the rounds recess, the exiting when an exiting round exits rounds recess 120, the exiting round abuts and
round abuts and forces at least one of the follower and a pre- forces the follower 1a or a pre-loaded round 3a downwardly into magazine 1
loaded round in the magazine downwardly into the magazine against spring force SF (See I-16).
against the spring force as the exiting round enters the magazine.
2. The method of claim 1, wherein each round is positioned Same as pt02
within the rounds recess, and each first case end is positioned
between the first rounds recess ledge and the rounds recess
bottom.
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CLAIMS CHART
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between the second rounds recess ledge and the rounds recess
bottom.
between the first rounds recess ledge and the rounds recess
bottom.
5. The method of claim 1, wherein the magazine recess includes Same as pt02
a magazine recess bottom having at least one of a magazine
retention depression and a magazine retention abutment.
6. The method of claim 1, wherein the magazine loader further Same as pt02
comprises a rounds retention recess,
extending into the main body from the upper surface,
positioned at the second main body end,
and opening into the second rounds recess end, such that one
or more of the rounds are moveable the rounds retention recess
to the second rounds recess end.
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CLAIMS CHART
REV-4 (01-15-2018)

plurality of ammunition rounds 3 into an ammunition magazine 1 round 3 into an ammunition magazine (advertised as Glock Magazine
having a follower 1a, a spring S providing a spring force SF compatible) having a follower, a spring biasing the follower upwardly, and a
with each round respectively including first and second rounds ETS interacts with each round based on the round’s first case end 4, second
ends and a pivot point 6, case end 5, and pivot point 6. (See I-4 and I-7)
a main body having a first main body end, a second main body ETS main body 110 includes a first main body end 111, a second main body
end, and a main body length, end 112, a main body length 113. (See I-1)
a rounds recess 120, extending along the main body length, and ETS includes a rounds recess 120 that extends along main body length 113.
having (See I-1).
first and second rounds recess ends 121, 122, a rounds recess It has first and second rounds recess ends 121, 122 (See I-6).
bottom 123, first and second rounds recess sides 124,125, and first It has a rounds recess bottom 123, first and second rounds recess sides 124,
and second rounds recess ledges 126, 127, 125, first and second rounds recess ledges 126, 127, and first and second
cavities 128, 129 (See I-3, and note: ETS ledges 126, 127 meet and are
formed into each other.)
with the rounds recess bottom, first rounds recess side, and first ETS first and second cavities 128, 129 are defined with same structure as
rounds recess ledge defining a first rounds cavity 128 between the claimed. And as per note above, ETS ledges 126, 127 meet and are formed
rounds recess bottom and the first rounds recess ledge, (See Fig. into each other in a continuous manner.
3a)
with the rounds recess bottom, second rounds recess side, and “
second rounds recess ledge defining a second rounds cavity 129 “
between the rounds recess bottom and the second rounds recess “
ledge, (See Fig. 3a) and
with the rounds recess being shaped to hold the plurality of ETS rounds recess 120 is shaped to hold rounds exactly in same claimed
rounds therein with each first rounds end positioned within the positions (See I-3 and I-4)
first rounds cavity and under the first rounds recess ledge and with
each second rounds end positioned within the second rounds
cavity and under the second rounds recess ledge, (See Fig. 3b) ETS second rounds recess end 122 is shaped to accept each round into rounds
at least a portion of the rounds recess 120 being shaped to recess 120 (See I-4)
accept each round into the rounds recess (See Fig. 1a),
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the second rounds recess side 125 terminating at a first ETS second rounds recess side 125 terminates at a first downwardly angled
downwardly angled portion E, portion E that opens in the said magazine recess 130 (See I-11).
and the first rounds recess side including a downwardly angled ETS first rounds recess side 124 includes a second downwardly angled portion
portion A (See Fig. 8), and A (See I-11).
a magazine recess 130, in communication with the rounds ETS includes a magazine recess 130 in communication with the rounds recess
recess 120, and positioned at the first main body end 111, 120 and positioned at first main body end 111. (See I-1)
the magazine recess being complementarily shaped to the ETS magazine recess 130 is complementarily shaped to magazine shape to
magazine shape to retain the magazine 1 in a fixed position within retain magazine 1 in fixed position within magazine recess (See I-7)
the magazine recess (See Figs 2a and 4)

a. positioning the magazine within the magazine recess; “Seat magazine all the way into the loader.” (See Step 1 in ETS
b. introducing the rounds into the rounds recess; and When ETS plunger is compressed towards magazine, a plurality of rounds are
introduced into the rounds recess. (See Step 3 in ETS DIRECTIONS)
c. with a structure, pushing the rounds, via a last round, towards ETS plunger pushes the rounds 3, via a last round, towards the magazine 1
and into the magazine,
such that as the plurality of rounds are moved towards the
magazine,
the pivot point of each round contacts the second downwardly the pivot point 6 of each round successively contacts the second downwardly
angled portion to pivot the second rounds end of each successive angled portion A to pivot the second rounds end 5 of each successive round
round towards the magazine, the second rounds end of each towards the magazine (See I-16),
successive round passes over the first downwardly angled portion, the second rounds end 5 of each successive round passes over the first
and downwardly angled portion E (See I-16), and (See Step 3 in ETS
DIRECTIONS and I-7), and
when an exiting round exits the rounds recess, the exiting when an exiting round exits rounds recess 120, the exiting round abuts and
round abuts and forces at least one of the follower and a pre- forces the follower 1a or a pre-loaded round 3a downwardly into magazine 1
loaded round in the magazine downwardly into the magazine against spring force SF (See I-16).
against the spring force as the exiting round enters the magazine.
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22. The method of claim 1, wherein the first rounds recess side ETS first rounds recess side 124 includes a third downwardly angled portion
124 includes a third downwardly angled portion D positioned D positioned between magazine recess 130 and second downwardly angled
between said magazine recess 130 and the second downwardly portion A. (See I-13)
angled portion A. (See Fig. 8)
23. The method of claim 22, wherein the third downwardly angled ETS third downwardly angled portion D has a concave shape. (See I-13)
portion D is provided with a concave shape. (See Fig. 8)
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CHRPLA-PT06 - USPAN 15/713,395 ETS

plurality of ammunition rounds 3 into an ammunition magazine 1 round 3 into an ammunition magazine (advertised as Glock Magazine
having a follower 1a, a spring S providing a spring force SF compatible) having a follower, a spring biasing the follower upwardly, and a
with each round respectively including a first case end, a second ETS interacts with each round based on the round’s first case end 4, second
case end opposite the first case end, and a pivot point 6, case end 5, and pivot point 6. (See I-4 and I-7)
a main body having first and second main body ends, ETS main body 110 includes a first main body end 111, a second main body
end 112. (See I-1)
a magazine cavity 130, formed within the main body end, and ETS includes a magazine cavity 130 positioned at first main body end 111.
(See I-1)
complementarily shaped to the magazine shape to retain the ETS magazine cavity 130 is complementarily shaped to magazine shape to
magazine in a fixed position within the magazine cavity, retain magazine 1 in fixed position within magazine cavity. (See I-7)
a rounds cavity 120, formed within the main body, ETS includes a rounds cavity 120 formed within the main body 110. (See I-
1).
and having first and second rounds cavity ends 121, 122, ETS has first and second rounds cavity ends 121, 122. (See I-6).
the first rounds cavity end being in communication with the ETS includes a magazine cavity 130 in communication with the rounds cavity
magazine cavity, end 121.
the rounds cavity being defined in part by first and second ETS has first and second rounds cavity sides 124, 125, upper and lower rounds
rounds cavity sides 124, 125, at least one upper rounds cavity cavity abutments 126, 127, and first and second cavities 128, 129 (See I-3)
abutment 126, and at least one rounds lower cavity abutment 127,
the rounds cavity sides, the at least one upper rounds cavity
abutment, and the at least one lower rounds cavity abutment being
positioned to abbutingly limit movement of the rounds along a ETS rounds cavity 120 is shaped to hold rounds exactly in same claimed
movement plane when the rounds exit the rounds cavity, and at positions (See I-3 and I-4)
least a portion of the rounds cavity being shaped to accept each
round into the rounds cavity, and (See Fig. 1a, 3a)
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a rounds abutment 150, at least partially positioned, within the ETS has a rounds abutment 150, positioned within said rounds cavity 120 and
rounds cavity 120, and at the first rounds cavity end 121, at the first rounds cavity end 121. (See I-5 and I-7)

a. positioning the magazine within the magazine cavity; “Seat magazine all the way into the loader.” (See Step 1 in ETS
b. introducing the rounds into the rounds cavity; and When ETS plunger is compressed towards magazine, a plurality of rounds are
introduced into the rounds cavity. (See Step 3 in ETS DIRECTIONS)
c. with a structure, pushing the rounds, via a last round, towards ETS plunger pushes the rounds 3, via a last round, towards the magazine 1
and into the magazine,
such that as the rounds are moved towards the magazine,
the pivot point of each round successively contacts the rounds the pivot point 6 of each round successively contacts the rounds abutment
abutment to angle the second rounds end of each successive round 150 to pivot the second rounds end 5 of each successive round towards the
towards the magazine, and when an existing round exits the magazine (See I-16) (See Step 3 in ETS DIRECTIONS), and
rounds cavity, the exiting round abuts and forces at least one of when an exiting round exits rounds recess 120, the exiting round abuts and
the follower and a pre-loaded round in the magazine into the forces the follower 1a or a pre-loaded round 3a downwardly into magazine 1
magazine against the spring force as the existing round enters the against spring force SF (See I-16).
magazine.
.
2. The method of claim 1, wherein the at least one upper cavity (See I-3, and note: ETS ledges 126, 127 meet and are formed into each other.)
abutment includes a ledge.
3. The method of claim 1, wherein the at least one upper cavity (See I-3, and note: ETS ledges 126, 127 meet and are formed into each other.)
abutment includes first and second ledges.
4. The method of claim 1, wherein the magazine cavity includes ETS magazine cavity 130 has a magazine retention depression 133 and a
at least one of a magazine retention depression and a magazine magazine retention abutment 134. (See I-8)
retention protrusion.
5. The method of claim 1, wherein the at least one lower cavity ETS rounds cavity 120 lower abutment is a rounds cavity floor (A.K.A.
abutment is a rounds cavity floor. “bottom”) 123. (See I-3)
6. The method of claim 5, wherein the magazine cavity includes ETS magazine cavity 130 has a magazine retention depression 133 and a
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7. The method or claim 1, wherein the magazine loader further ETS has a rounds retention cavity 140 that opens into rounds cavity end 122,
comprises a rounds retention cavity in communication with the such that one or more of the at least one rounds 3 are moveable from rounds
rounds cavity, retention cavity to rounds cavity 120.
(See I-9 and I-15)
8. The method of claim 1, wherein the first rounds cavity side ETS first rounds cavity side 124 includes an inwardly curved shape 150 that
includes a curved shape that provides the rounds abutment. provides a rounds abutment 150 that manipulates rounds as per claim 1. (See
I-14) Note: ETS technically has two (2) rounds abutments (cf. 150 in I-5)
9. The method of claim 1, wherein the loader further comprises a ETS has a magazine cavity cover 135 that covers the rounds cavity 120 and
magazine cavity cover that covers at least a portion of at least one magazine cavity 130.
of the magazine cavity and the rounds cavity. (See I-1)
10. The method of claim 1, wherein the loader further comprises ETS has a magazine cavity cover 135 that covers the rounds cavity 120 and
a magazine cavity cover that covers at least a portion of the magazine cavity 130.
magazine cavity and the rounds cavity. (See I-1)
11. The method of claim 1, wherein the first rounds cavity side ETS first rounds cavity side 124 includes a downwardly angled portion A that
includes a downwardly angled portion that provides the rounds provides the rounds abutment (See I-11).
abutment.
12. The method of claim 11, wherein the downwardly angled ETS first rounds cavity side 124 includes a downwardly angled portion A that
portion includes a linear shape. is linear. (See I-11)
portion includes one of a concave and a convex shape. forms a concave shape, ETS second rounds cavity side 125 includes a
downwardly angled portion E that forms a convex shape. (See I-11)
14. The method of claim 1, wherein the second rounds cavity side ETS first rounds cavity side 124 includes a second downwardly angled portion
includes a first downwardly angled portion, and the first rounds A that provides the rounds abutment, ETS second rounds cavity side 125
cavity side includes a second downwardly angled portion that includes a first downwardly angled portion E. (See I-11)
provides the rounds abutment, and
In said step of pushing, as the rounds are moved towards the As the rounds are pushed toward the magazine, the second rounds end 5 of
magazine, the second rounds end of each round successively each successive round passes over the first downwardly angled portion E (See
passes over the first downwardly angled portion. I-16 and See Step 3 in ETS DIRECTIONS).
portion includes a linear shape. is linear (See I-11).
16. The method of claim 15, wherein the downwardly angled ETS second rounds cavity side 125 includes a downwardly angled portion E
portion includes another linear shape. that is linear (See I-11).
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17. The method of claim 14, wherein the second rounds cavity ETS first rounds recess side 124 includes a third downwardly angled portion
side includes a third downwardly angled portion positioned D positioned between second main body end 130 and second downwardly
between the first downwardly angled portion and the second main angled portion A. (See I-13)
body end.
a magazine cavity cover that covers at least a portion of at least magazine cavity 130.
one of the magazine cavity and the rounds cavity. (See I-1)
a magazine cavity cover that covers at least a portion of the magazine cavity 130.
magazine cavity and the rounds cavity. (See I-1)
20. An ammunition magazine loader configured to load a plurality ETS is an ammunition magazine loader that loads a plurality of ammunition
of ammunition rounds 3 into an ammunition magazine 1 having a round 3 into an ammunition magazine (advertised as Glock Magazine
follower 1a, a spring S providing a spring force SF biasing the compatible) having a follower, a spring biasing the follower upwardly, and a
follower upwardly, and a magazine shape, magazine shape.
with each round respectively including first and second case ETS interacts with each round based on the round’s first case end 4, second
ends and a pivot point, case end 5, and pivot point 6. (See I-4 and I-7)
a main body having first and second main body ends, ETS main body 110 includes a first main body end 111, a second main body
end 112. (See I-1)
a magazine cavity 130, formed within the main body end, and ETS includes a magazine cavity 130 positioned at first main body end 111.
(See I-1)
complementarily shaped to the magazine shape to retain the ETS magazine cavity 130 is complementarily shaped to magazine shape to
magazine in a fixed position within the magazine cavity, retain magazine 1 in fixed position within magazine cavity. (See I-7)
a rounds cavity 120, formed within the main body, and having ETS includes a rounds cavity 120 formed within the main body 110. (See I-
1).
a first rounds cavity end in communication with said magazine ETS has first and second rounds cavity ends 121, 122. (See I-6).
cavity and a second rounds cavity end positioned at the second ETS includes a magazine cavity 130 in communication with the rounds cavity
main body end, said rounds cavity being defined at least in part by end 121.
first and second rounds cavity sides, at least one upper cavity
abutment, and at least one lower cavity abutment, the rounds ETS has first and second rounds cavity sides 124, 125, upper and lower rounds
cavity sides, the at least one upper cavity abutment, and the at least cavity abutments 126, 127, and first and second cavities 128, 129 (See I-3)
one lower cavity abutment being positioned to abbutingly limit
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movement of the rounds along a movement plane as the rounds

exit said rounds cavity, and at least a portion of said rounds cavity ETS rounds cavity 120 is shaped to hold rounds exactly in same claimed
being shaped to accept each round into said rounds cavity, and positions (See I-3 and I-4)
a rounds abutment 150 at least partially positioned within said ETS has a rounds abutment 150, positioned within said rounds cavity 120 and
rounds cavity 120 at the first rounds cavity end 121, at the first rounds cavity end 121. (See I-5 and I-7)
Wherein with the magazine positioned within said magazine With magazine 1 positioned within magazine cavity 130 and as the plurality
cavity and as the plurality of rounds slidably move out of said of rounds are moved out of rounds cavity 120,
rounds cavity,
the pivot point of each round successively contacts said rounds the pivot point 6 of each round successively contacts the rounds abutment
abutment to angle the second case end of each respective round 150 to pivot the second rounds end 5 of each successive round towards the
towards said magazine cavity, magazine cavity 130 (See I-7 and I-16),
and when an exiting round exits said rounds cavity, the exiting when an exiting round 3a exits rounds cavity 120, the exiting round
round abuts at least one of the follower and a preloaded round in abuts and forces at least one of the follower 1a and a pre-loaded round 3a in
the magazine downwardly into the magazine against the spring the magazine 1 downwardly into the magazine against the spring force SF as
force as the exiting round enters the magazine. the exiting round enters the magazine. (See I-7 and I-16)
21. The loader of claim 20, wherein the at least one upper cavity See I-3, and note: ETS ledges 126, 127 meet and are formed into each other.
abutment includes a ledge.
22. The loader of claim 20, wherein the at least one upper cavity See I-3, and note: ETS ledges 126, 127 meet and are formed into each other.
abutment includes first and second ledges.
23. The loader of claim 20, wherein said magazine cavity includes ETS magazine cavity 130 has a magazine retention depression 133 and a
24. The loader of claim 20, wherein the at least one lower cavityETS rounds cavity 120 has a lower cavity abutment that is a rounds cavity
abutment is a rounds cavity floor. floor when the device magazine retention depression 133 and a magazine
retention abutment 134. (See I-8)
25. The loader of claim 24, wherein the magazine cavity includes ETS magazine cavity 130 has a magazine retention depression 133 and a
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26. The loader of claim 20, wherein the magazine loader further ETS has a rounds retention cavity 140 that opens into rounds cavity end 122,
comprises a rounds retention cavity in communication with said such that one or more of the at least one rounds 3 are moveable from rounds
rounds cavity, retention cavity to rounds cavity 120.
(See I-9 and I-15)
27. The loader of claim 20, wherein the first rounds cavity side ETS first rounds cavity side 124 includes an inwardly curved shape 150 that
includes a curved shape that provides said rounds abutment. provides a rounds abutment 150 that manipulates rounds as per claim 1. (See
I-14) Note: ETS technically has two (2) rounds abutments (cf. 150 in I-5)
28. The loader of claim 20, further comprising a magazine cavity ETS has a magazine cavity cover 135 that covers the rounds cavity 120 and
cover that covers at least a portion of at least one of said magazine magazine cavity 130.
cavity and said rounds cavity. (See I-1)
cover that covers at least a portion of said magazine cavity and magazine cavity 130.
said rounds cavity. (See I-1)
30. The loader of claim 20, wherein the first rounds cavity side ETS rounds cavity 120 lower abutment is a rounds cavity floor (A.K.A.
includes a downwardly angled portion that provides said rounds “bottom”) 123. (See I-3)
abutment.
31. The loader of claim 30, wherein the downwardly angled ETS first rounds cavity side 124 includes a downwardly angled portion A that
portion includes a linear shape. is linear. (See I-11)
portion includes one of a concave and a convex shape. forms a concave shape, ETS second rounds cavity side 125 includes a
downwardly angled portion E that forms a convex shape. (See I-11)
33. The loader of claim 20, wherein the second rounds cavity side ETS first rounds cavity side 124 includes a second downwardly angled portion
includes a first downwardly angled portion, and the first rounds A that provides the rounds abutment, ETS second rounds cavity side 125
cavity side includes a second downwardly angled portion that includes a first downwardly angled portion E. (See I-11)
provides said rounds abutment, and
as the at least one round is moved towards the magazine, the As the rounds are pushed toward the magazine, the second rounds end 5 of
second rounds end of each round successively passes over the first each successive round passes over the first downwardly angled portion E (See
downwardly angled portion. I-16).
portion includes a linear shape. is linear (See I-11).
35. The loader of claim 34, wherein the downwardly angled ETS second rounds cavity side 125 includes a downwardly angled portion E
portion includes another linear shape. that is linear (See I-11).
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36. The loader of claim 33, wherein the second rounds cavity side ETS first rounds recess side 124 includes a third downwardly angled portion
includes a third downwardly angled portion positioned between D positioned between second main body end 130 and second downwardly
the first downwardly angled portion and the second main body angled portion A. (See I-13)
end.
cover that covers at least a portion of at least one of said magazine magazine cavity 130.
cavity and said rounds cavity. (See I-1)
cover that covers at least a portion of said magazine cavity and magazine cavity 130.
said rounds cavity. (See I-1)
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Law Office of Ken Hoffmeister
7924 Ashley Road
Powell, Tennessee 37849
(865) 399-4404
ken@865ip.com
February 8, 2018
Christopher Plate
4235 SE 20th Place Unit B402
Cape Coral, FL 33904
Re: Notice of Patent Infringement dated 01/23/2018
Dear Mr. Plate:
We have received your letter regarding “Notice of Patent Infringement” dated January 23, 2018.
You have made a direct, unambiguous charge that the four accused Elite Tactical Systems Group
products listed in your letter are infringing one or more of U.S. Patent Number 9,618,286; U.S.
Patent Number 9,689,633; U.S. Patent Number 9,739,552; and U.S. Patent Number 9,797,669.
We affirmatively deny that the accused Elite Tactical Systems products infringe the patents
mentioned above.
Elite Tactical Systems respects the intellectual property rights of others and would not knowingly
engage in infringement. While we have a good faith belief that there is no infringement, we take
your claim seriously and are investigating your allegation. Please understand that a meaningful
investigation of any allegation of infringement takes time. It would greatly speed up our analysis if
you would provide us with specifics as to which claim(s) of which patent(s) cover which of the
accused product(s) and any analysis that you or your attorney, if any, have done related to
allegations against Elite Tactical Systems.
We will notify you when we complete our investigation into this matter.
Sincerely,
Ken Hoffmeister
Patent Attorney

GENERAL KNOX LAW, P.C.
ATTORNEYS AT LAW
MAIL TO:
ROGER D. HYMAN*# LEGACY SQUARE OFFICE PARK
105 Legacy View Way
P.O. Box 26072
C. PHILIP CAR TER, M.D.*
Knoxville, Tennessee Knoxville, TN 37912
MITAL D. PATEL*+
*Tenn. Sup. Ct. Rule 31 Listed Telephone: (865) 686-7789
General Civil and Family Mediators Fax: (865) 686-7792 Of Counsel:
#Specially Trained in Domestic
Violence Issues; also Trained in
J. KENNETH HOFFMEISTER
Elder Mediation
+ Also Licensed in Mississippi
January 27, 2017
E-mail Address | ken@865ip.com

David E. Weslow, Esq.
Wiley Rein LLP
1776 K Street NW
Washington, DC 20006
Re: Elite Tactical System Group LLC / Plate Design Corp.

Controversy
File Number 0011.00100GM
Dear Mr. Weslow:
We are currently conducting a preliminary investigation of your client’s accusations against Elite Tactical Systems
Group, LLC (“ETS”). As explained below, it is not entirely clear as to the basis of the conclusion that the
magazine loader designed by ETS incorporates confidential information obtained from your client. At this time,
ETS denies that it has breached the agreement.
First, the confidentiality agreement dated July 29, 2016 was superseded by the Mutual Confidentiality Agreement
dated October 5, 2016, a copy of which is attached. Regardless of which confidentiality agreement is in place, there
is a question as to what confidential information is alleged to have been misappropriated.
About August 2016, your client provided ETS with a copy of a pending patent application (“the Plate
Application”) and a rough prototype. Subsequently, your client also shared prior art in the form of U.S. Published
Patent Application 2014/0033592 (“Fiorucci”) and expressed concern with Fiorucci. Investigation of Fiorucci
led to discovery U.S. Published Patent Application Number 2003/0046854 (“Urchek”). We trust that you can
readily obtain copies of these references, but will gladly provide them if requested. Upon review, Fiorucci and
Urchek appear to anticipate or render obvious the subject matter of the Plate Application. ETS was still interested
in exploring the opportunity to work with your client, the parties could not reach mutually satisfactory financial
terms. However, ETS remains open to opportunities to work with your client.
The ETS magazine loader design significantly departs from the design shared by Plate Design. ETS asserts that
it has not incorporated any confidential information obtained from your client in its design. As ETS has not
disclosed and is not disclosing any of your client's confidential information, ETS agrees to continue to abide by its
obligation to maintain your client’s confidences.
www.northknoxlaw.com
January 27, 2017
ETS / Plate Design Controversy
Our File Number 0011.00100GM
Page 2 of 2
ETS further contends that it is not prohibited from producing and has no obligation to assign a magazine loader
that does not incorporate any confidential information obtained from your client. Accordingly, ETS must
respectfully refuse your demands to discontinue development, manufacturing, marketing, and sales of the ETS
loader, to withdraw from competition, and provide information about its pending patent application at this time.
Please understand that our investigation into this matter is ongoing. You may assist us with this investigation by
clearly and distinctly identifying the information that Plate Design believes is confidential and not found in the
prior art. We look forward receiving your more detailed statement of the allegations against ETS.
Finally, it has come to the attention of ETS that your client is and has been attempting to stifle publication of
information about of the ETS loader by making unfounded accusations to third parties, including others having
ties to the firearm industry, that ETS has stolen your client’s invention. ETS cannot allow your client to continue
to make these false and defamatory statements. We demand that your client cease making any defamatory
statements concerning ETS and provide assurance that no future defamatory statements concerning ETS will be
made. ETS will consider any further violations to be willful on the part of your client.
Sincerely yours,
Ken Hoffmeister

David E. Weslow
1776 K STREET NW January 10, 2017 202.719.7525
WASHINGTON, DC 20006
dweslow@wileyrein.com
PHONE 202.719.7000
FAX 202.719.7049
VIA EMAIL – jhansen@etsgroup.us
AND FEDEX
www.wileyrein.com Mr. James P. Hansen

d/b/a Elite Tactical Systems Group
d/b/a ETS Group
6039 S. Gotham Drive

South Bend, IN 46614
4113 New Hwy 96 W

Franklin, TN 37064 USA
Re: Breach of Non-Disclosure and Non-Compete Agreement
Dear Mr. Hansen:
We are counsel to Christopher Plate and Plate Design Corp. (collectively “Plate
Design”) and are writing regarding your obligations under the Non-Disclosure
Agreement and Non-Compete Agreement that you entered into with Plate Design
on July 29, 2016 (the “Agreement”).
It has come to Plate Design’s attention that you are advertising a universal 9mm
magazine loader based on, and incorporating, confidential information that was
disclosed to you by Plate Design pursuant to the Agreement. As you know, the
Agreement prohibits use of Plate Design’s confidential information in this manner.
See Agreement ¶¶ 1-2. The Agreement also bars you from engaging directly or
indirectly in any competitive business such as the marketing and sale of a universal
9mm magazine loader. See Agreement ¶¶ 3-4. Moreover, Plate Design understands
that you are apparently referring to this loader product as “patent pending”
notwithstanding your assignment in the Agreement of any and all intellectual
property rights associated with your receipt of confidential information from Plate
Design. See Agreement ¶ 13.
Please be advised that Plate Design will not permit you to willfully violate your
non-disclosure and non-compete obligations as set forth in the Agreement. Plate
Design’s willingness to resolve this matter amicably is conditioned upon your
immediate response and written agreement to (1) discontinue all development,
manufacturing, marketing, and sales of the aforementioned universal 9mm
magazine loader, (2) refrain from any and all further disclosure or use of Plate

Mr. James P. Hansen
January 10, 2017
Page 2 of 2
Design’s confidential information, and (3) comply with your non-compete

obligations as set forth in the Agreement. Plate Design also requires that you (4)
provide us with the patent application number related to your promotion of the 9mm
magazine loader as “patent pending.”
In light of your apparent intention to market the 9mm magazine loader at the
upcoming NSSF SHOT Show in Las Vegas, we shall look forward to receiving your
written response to this correspondence within forty-eight (48) hours confirming
your compliance with our requests. All documents and electronic records must be
retained relating to this matter, including email and computer records that otherwise
may be erased or overwritten.
Your failure to comply with the foregoing demands will leave us with no choice but
to advise Plate Design to protect its rights through appropriate legal action. As you
know, in addition to monetary damages and injunctive relief, you will be required to
reimburse Plate Design for its attorneys’ fees if it is forced to pursue legal action to
obtain your compliance with the Agreement. See Agreement ¶ 12. Moreover, given
your personal involvement in the violation of Plate Design’s rights, as well as the
apparent lack of a formal corporate structure for Elite Tactical Systems Group / ETS
Group, you may be held personally liable to Plate Design for monetary damages and
attorneys’ fees.
This letter is not a complete statement of Plate Design’s rights in connection with
this matter, and nothing contained herein constitutes an express or implied waiver of
any rights, remedies, or defenses, all of which are expressly reserved.
We look forward to your timely response.
Sincerely,
WILEY REIN LLP
By: /s/ David E. Weslow

David E. Weslow
Scott A. Felder
cc: Plate Design Corp.

First Party Initials _rI__ SecondParty Initi~
NON-DISCLOSURE AGREEMENT
Christopher Plate; an individual (hereinafter "First Party") located at 423S'SE 20th
tee> ~~ ~ ~()~ n
Place' Apt B402 Cape Cora], Florida and ,!:fS ~trO!*f?'
~:rlr z.~ffI)
. . Iocated at
J._/V (/u(~reInafter "Second Party"} WIsh to enter
into a confidential Beta- Testing arrangement relating to the First Party's.provisioning of pre-
market and.market access to Confidential Information of the Second Party, said Confidential
Information being directed to one or more of the following; functional software means? business
plans, methods, systems, devices, components, individually and in combination, being covered
or coverable by one or more intellectual property rights including patent, trademark, trade secret,
and copyright,
WHEREAS, it is necessary for said Second Party to receive said 'Confidential

Information and access from said First Party for the sole purpose of Product. Evaluation, with
said Second Party potentially providingfeedback on the same.'
NOW THEREFORE, in consideration of the foregoing, the mutual promises contained

herein, and other good and valuable consideration, the receipt. and sufficiency of which are
acknowledged,the First and Second Parties, intending legally to be bound; agree as follows:
1. Confidential Information. The First and Second Parties acknowledge that the
technical information, including drawings, specifications, distinctive business format, plans,
methods, data, processes, supply systems, marketing systems, formulas, techniques, designs,
operating procedures, trademarks, proprietary marks andinformation and know-how of the First
Party are and/or have been developed and/or utilized in connection with the actual 'and/or
anticipated operation of Business by the First Party. Such Confidential Information is the unique,
excjusive property, and a trade secretis), of the First Patty. The Second Party -acknowledges that
any unauthorized'disclosure 'or use-of the Confidential Information would be wrongful anq would
cause irreparable irijury and harm to the. First Party. The Second Party further acknowledges that
Q1e First Party has taken numerous precautions to guard the secrecy of the Confidential Information
and that it would be very costly or remotelypossible for competitors to acquire or duplicate the
Confidential Information.
The obligations of the Second Party hereunder shall not apply to any Confidential Information of
the First Patty which:
a. was in the public domain at the time it was disclosed;

b. enters the public domain other than by breach of this Agreement by the Second
Party;
c. is known to the Second Party at the time of its disclosure to the Second Party by
the First Party;
d. is disclosed to the Second Party bya.third party who has the right to do so;
e. is developed by the.Second Party independently of any disclosure by the First
Party hereunder; ,
f. is disclosed by the Second Party when required by law, provided that the Second
Page 1 of4

First Party Initials _c! _ Second Party Initials ~
Party first notifies the Provider of such requirement and cooperates, at no expense
to the Second Party, with respect to any reasonable steps available for: the
protection of such Confidential Information.
2. Nondisclosure of Confidential Information. The Second Party shall not at any time,
publish, disclose, divulge 01' in any manner communicate to any person, firm, corporation,
association, partnership Or any other entity whatsoever; or usc, directly or indirectly, for its own
benefit or for the benefit of any person, finn, corporation or other entity, other than for the use of
the First Party, any of the Confidentiallnformation of the First Party.
3. Non-Competition Covenant. The Second Party acknowledges that the Confidential

Information, in whole or in part, includes commercially valuable information, which comprises,
and is a part of, a System, Device, and Method, including without limitation, proprietary aspects,
elements; combinations, processes, operations, marketing, and related information and materials,
and that the value of this information derives not only from the time, effort, and money which went
into its derivation and/or compilation, but from the licensed usage of the same by so licensed
entities of the First Party. The Second Party therefore agrees that neither the Second Party nor any
manager, officer, director, shareholder, partner, nor any member of his, her or their immediate
families, will during the term of this Agreement:
a. have any direct or indirect controlling interest as a disclosed or beneficial owner in

a Competitive Business;
b. perform services as a director, partner, officer, manager, employee, consultant,
representative, agent or otherwise for a Competitive Business; or
c. divert or attempt to divert any business related to, or any customer or account of
the First Party, the First Party's Business, affiliates or any Associate, by direct
inducement or otherwise, or divert or attempt to divert the employment of any
employee of the First Party or its affiliates or associates to any Competitive
Business by any direct inducement or otherwise.
The term 'Competitive Business" as used in this Agreement means any business offering
engaged, directly or indirectly, in the manufacture, marketing, sale, lease, or service relating to a
directly competing product. If the Second Party is, at the time of execution of this Agreement,
actively engaged in a Competitive Business, then this prohibition extends only to the extent that
such Competitive Business utilizes any unique, proprietary, or other competitively advantageous
aspect learned from the First Party. However, the Second Party, its owners, members, partners,
principals, and if an individual, members of its immediate family, will not be prohibited from
owning securities in a Competitive Business if such securities are listed on a stock exchange or
traded on the over-the-counter market and represent in the aggregate five percent (5%) or less of
that class of securities issued and outstanding,
4. Termination and P0st-Tenuination Covenant Not to Compete. Either Party may

terminate this Agreement upon written notice to the other Patty. Upon termination or expiration
of this Agreement for any reason, the Second Party, and its officers, directors, shareholders, and
partners agree that, for a period of five (5) years commencing on the effective date of termination
or expiration, or the date on which the Second Party ceases to conduct business whichever is
later, neither the Second Party nor any of its officers, directors, shareholders, managers,
Page 2 of4
PO -GTSC

First Party Initials _rI _
members, or partners will have any direct or indirect interest (through any immediate family
member ofthe Second Party, Franchisee, or its owners or otherwise) as a disclosed or beneficial
owner, investor, partner, director, officer, employee, consultant, representative or agent or in any
other capacity in any Competitive Business, as defined above, (i) on the Internet; and (ii) on any
other marketing channel, either of which extending on a world-wide basis. The restrictions of
this Section will not be applicable to the ownership of shares of a class of securities listed on a
stock exchange or traded on the over-the-counter market that represent five percent (5%) or less
of the number of shares of that class of securities issued and outstanding. The Second Party, and
its officers, directors, shareholders .• managers, members and partners. expressly acknowledge that
they possess skills and abilities of a.general nature and have other opportunities for exploiting
such skills. Consequently, enforcement of the covenants made in this Section will not deprive
them of their personal goodwill or ability to earn a living. Insofar as any court of competent
jurisdiction finds the period of five (5) years contrary to public policy or otherwise
unenforceable, both Parties hereby agreeto step down the prim by six (6) month increments until
such period is deemed enforceable by such court.
5. Injunction. The Second Party hereby acknowledges and agrees that in the event of
any breach or threatened breach of this Agreement, the First Party shall be authorized and entitled
to seek, from any court of competent jurisdiction, preliminary and permanent injunctive relief in
addition to any other rights or remedies to which the First Party may be entitled. The Second Party
agrees that the First Party may obtain such injunctive relief, without posting a bond or bonds.
totaling $500 or more, but upon due notice, and the Second Party's sole remedy in the event of the
entry of such injunctive relief shall be dissolution of such injunctive relief, if warranted, upon
hearing duly had; provided, however, that all claims for damages by reason of the wrongful
issuance of any such injunction are hereby expressly waived by the Second Party.
6. Effect of Waiver. The waiver by the First Party of a breach of any provision ofthis
Agreement shall not operate or be construed as a waiver of any subsequent breach thereof.
7. Binding Effect. This Agreement shall be binding upon and inure to the benefit of
the First and Second Parties .and their respective heirs, executors, representatives, successors and
assigns.
8. Entire Agreement. This instrument contains the entire agreement of the First and
Second Parties relating to the matters set forth herein. It may not be changed verbally, but only
by an, agreement in writing, signed by the party against whom enforcement of any waiver, change,
modification, extension or discharge is sought.
9. Governing Law. This instrument shall be governed by and construed under the
laws of the state of Florida.
10. Judsdiction and Venue. In the event of a breach or threatened breach by either
Party to this Agreement, the Parties hereby irrevocably submit to the jurisdiction of the state and
federal courts of Florida, and irrevocably agree that venue for any action or proceeding shall be in
the state and federal courts of Lee County. Florida. Both parties waive any objection to the
jurisdiction of these courts or to venue in the state and federal.courts as set forth. Notwithstanding
Page 3 of 4
OC GTSC-

First Party Initials _c! _ '?!ff
Second Party Initia~
the foregoing, in the event that the laws of the state where the Second Party resides prohibit the
aforesaid designation of jurisdiction ana venue! then such other state's laws shall control.
11. Severability. If any provision of this Agreement shall be held, declared or

pronounced void, voidable, invalid, unenforceable or inoperative for any reason, by any court of
competent jurisdiction, government authority or otherwise, such holding, declaration or
pronouncement shall not affect adversely any other provisions of this Agreement which shall
otherwise remain in full force and effect.
1.2. Attorneys' Fees. In any action at law-or in equity to enforce any of the provisions
or rights under this Agreement, the unsuccessful party in such litigation.as determined by the OOUli
in a final judgment or decree, shall pay the successful party or parties all costs, expenses and
reasonable attorneys' fees incurred therein by such party or parties (including without limitation
such costs, expenses and fees on any appeals), and if such successful party shall recover judgment
in any such action or proceeding? such costs, expenses and attorneys' fees shall be included as part
of such judgment.
13. Assignment otlntellectual Property. The Second Party expressly agrees to

immediately disclose to the First Party, and by this very document hereby assigns in full and
without condition or further consideration therefore, any and all intellectual property created,
invented, or otherwise generated by the Second Party in conjunction with and arising from its
evaluation andlor use of the Confidential Information provided to the Second Party by or on
behalf of'the First.Party, where such intellectual property arises subsequent to or
contemporaneous with this Agreement, during the validity period of this Agreement and the
period of the Post-Termination Covenant Not to. Compete specified above, whichever is longer.
IN WIlNESS
WHEREOF, the parties have
signed thj?r)~liLa==
Christopher Plate. ~ ~
President [Signature
Plate Design Gorp.
3430 Willard Street 06/10/2016
Fort Myers, Florida 33916 [Pate]
C;;;~5~'5~
(Insert full legal name) [Signature]
. 7/29 /z_e;; fry,

7 [Date]
Page 4 of4
POC-IET c:-m lUll

PLATE, LLC | WWW.PLATE.US | 1.877.78.PLATE | CAGE 7XR52
CHRISTOPHER PLATE
th
4235 SE 20 Place Unit B402; Cape Coral, Florida 33904
239.872.1371; cplate@plate.us
January 23, 2018

VIA EMAIL-jhansen@etsgroup.us | eloveday@etsgroup.us | info@etsgroup.us
AND USPS
Mr. James P. Hansen & Mr. George E. Loveday IV
d/b/a ETS Group
6039 S. Gotham Dr. PO Box 18511 241 Commerce Way 1251 North Eddy St.
South Bend, IN 46614 Knoxville, TN 37928 Gallatin, TN 37066 Suite 200
Re: Notice of Patent Infringement
Dear Mr. Hansen, Mr. Loveday, and other representatives of Elite Tactical Systems Group LLC:
As you know, these are my currently issued U.S. patents:
• 9,618,286 “Ammunition Magazine Loader”

• 9,689,633 “Magazine Loader”
It has come to my attention that you are advertising, manufacturing and selling the following products:
ITEM # PRODUCT NAME PART # UPC
1 C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 854094005492
2 GEN II- C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 854094005492
3 C.A.M. Loader For All Pistol Mags .45 Caliber ETSCAM45 854094005546
Your products (Items 1-4) are infringing upon one or more of my four U.S. patents listed above. See attached
patents.
Please immediately stop infringing my patents.
You are hereby instructed to retain all documents and electronic records relating to this matter, including email
and computer records that otherwise may be erased or overwritten.
Page 1 of 2
REV-0 (01-23-2018)
This letter is not a complete statement of my rights in connection with this matter, and nothing contained herein
constitutes an express or implied waiver of any rights, remedies, or defenses, all of which are expressly reserved.
Included with this correspondence are:
• Copies of U.S. patents 9,618,286; 9,689,633; 9,739,552; 9,797,669.
Sincerely,
_/s/ Christopher Plate_
Christopher Plate
PRESIDENT | PLATE, LLC
Page 2 of 2
REV-0 (01-23-2018)
CHRISTOPHER PLATE
th
4235 SE 20 Place Unit B402; Cape Coral, Florida 33904
239.872.1371; cplate@plate.us
April 6, 2018
VIA EMAIL-jhansen@etsgroup.us | eloveday@etsgroup.us | info@etsgroup.us
AND USPS
Mr. James P. Hansen, Mr. George E. Loveday IV & Mr. George E. Loveday III
d/b/a ETS Group
6039 S. Gotham Dr. PO Box 18511 241 Commerce Way 1251 North Eddy St.
South Bend, IN 46614 Knoxville, TN 37928 Gallatin, TN 37066 Suite 200
Dear Mr. Hansen, Mr. Loveday, and other representatives of Elite Tactical Systems Group LLC:
As you know, these are my currently issued U.S. patents:
• 9,618,286 “Ammunition Magazine Loader”

Be advised of my recently issued patent:

It has come to my attention that you are advertising, manufacturing and selling the following products:
ITEM # PRODUCT NAME PART # UPC
1 C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 854094005492
2 GEN II- C.A.M. Loader For All Pistol Mags 9mm/.40 Caliber ETSCAM940 854094005492
Your products (Items 1-4) are infringing upon one or more of my five U.S. patents listed above. See attached
patents.
Page 1 of 2
REV-0 (04-06-2018)
Please immediately stop infringing my patents.

You are hereby instructed to retain all documents and electronic records relating to this matter, including email
and computer records that otherwise may be erased or overwritten.
This letter is not a complete statement of my rights in connection with this matter, and nothing contained herein
constitutes an express or implied waiver of any rights, remedies, or defenses, all of which are expressly reserved.
Included with this correspondence are:
• Copies of U.S. patents 9,618,286; 9,689,633; 9,739,552; 9,797,669; 9,933,220.
Sincerely,
_/s/ Christopher Plate_
Christopher Plate
PRESIDENT | PLATE, LLC
Page 2 of 2
REV-0 (04-06-2018)

Plate v. RCTENN - Complaint

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Plate v. RCTENN - Complaint

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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE

RCTENN, LLC JURY TRIAL DEMANDED

undersigned counsel, for its Complaint alleges as follows:

NATURE OF THE ACTION

1. Founded in 2014, Plate is reinventing the way military, law enforcement,

2. RCTENN, LLC (“RCTENN”) is a manufacturing company specializing in

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 1 of 18 PageID #: 1

3. Plate is a Florida limited liability company with its principal place of

business at 4235 SE 20th, Unit B402, Place Cape Coral, FL 33904.

4. Defendant RCTENN is a Tennessee limited liability company. On

JURISDICTION AND VENUE

patent infringement under 28 U.S.C. §§ 1331 and 1338(a).

6. This Court has personal jurisdiction over RCTENN because upon

information and belief, RCTENN’s principle place of business is located in Tennessee.

7. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(1), and 1400.

THE ASSERTED PATENTS

of the Assignment is attached as “Exhibit B.”

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 2 of 18 PageID #: 2

of the Assignment is attached as “Exhibit B.”

to herein as the “Asserted Patents.”

claims. The ‘220 Patent contains device and method claims.

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 3 of 18 PageID #: 3

has independent economic value and to avoid disclosures of prior art.

14. Upon information and belief, RCTENN is engaged as a contract

manufacturer for ETS.

Magazine Loaders, videos of the Magazine Loaders functioning, a Magazine Loader

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 4 of 18 PageID #: 4

Mutual NDA is attached as “Exhibit F.”

21. Prior to December of 2016, ETS had never advertised magazine

on the ETS website.

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 5 of 18 PageID #: 5

“Infringing ETS Products.”

as well as other superficial variations.

distributed into interstate commerce.

and distributes into interstate commerce.

consideration from ETS for manufacturing the Infringing ETS Products.

ETS Products for ETS.

RCTENN’s principle place of business at 241 Commerce Way, Gallatin, TN 37066

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 6 of 18 PageID #: 6

RCTENN’s principle place of business at 241 Commerce Way, Gallatin, TN 37066

Plate Cease and Desist 3 is attached as “Exhibit H.”

infringing the Asserted Patents in the future without authorization or compensation to

COUNT I – INFRINGEMENT OF THE ‘552 PATENT

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 7 of 18 PageID #: 7

the Infringing ETS Products.

Patent, which provides as follows:

1. A method of using an ammunition magazine loader to load a plurality of

a. positioning the magazine within the magazine recess;

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 8 of 18 PageID #: 8

plurality of ammunition rounds into an ammunition magazine having a follower, a spring

biasing the follower upwardly, and a magazine shape.

to accept each round into rounds recess.

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 9 of 18 PageID #: 9

42. The Infringing ETS Products include a magazine recess in communication

Products magazine recess is complementarily shaped to magazine shape to retain

rounds recess end opens into their magazine recess.

magazine all the way into the loader.

44. When the Infringing ETS Products plunger is compressed towards

magazine, a plurality of rounds are introduced into the rounds recess.

or a pre-loaded round downwardly into magazine against spring force.

Products infringe the ‘552 Patent.

Case 3:18-cv-00806 Document 1 Filed 08/29/18 Page 10 of 18 PageID #: 10

of 35 U.S.C. §271(a) by making, manufacturing, using, marketing, offering to sell, and

By: s/Van R. Irion______________