Case 1:18-cv-01741-UNA Document 1 Filed 11/05/18 Page 1 of 10 PageID #: 1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELAWARE

WESSEL-WERK GMBH and )

WESSEL-WERK USA, Inc. )
)
Plaintiffs, )
) C.A. No. _________________
v. )
) DEMAND FOR JURY TRIAL
INTELLICLEAN SOLUTIONS, LLC, )
)
Defendant. )

COMPLAINT

Plaintiffs Wessel-Werk GmbH (“Wessel-Werk”) and Wessel-Werk USA, Inc. (“Wessel-

Werk USA”), by their undersigned attorneys, bring this action for patent infringement against

Defendant Intelliclean Solutions, LLC (“Intelliclean”), and allege as follows:

THE PARTIES

1. Intelliclean is a limited liability company organized and existing under the laws of

Delaware, with a place of business at 100 Second Ave N., Suite 350, St. Petersburg, Florida

33701. Defendant may be served with process at The Corporation Trust Company, Corporation

Trust Center 1209 Orange Street, Wilmington, Delaware 19801. Upon information and belief,

Intelliclean sells, via their website (www.quantumvac.com), a variety of vacuum cleaners that

include particular front brush attachments, in Delaware and elsewhere throughout the United

States.

2. Wessel-Werk GmbH is a German company, with a principal place of business at

Im Bruch 2 51580 Reichshof-Wildbergerhütte, Germany.

3. Wessel-Werk USA is a North Carolina company with a principal place of

business at 128 Gasoline Alley Mooresville, NC 28117. Wessel-Werk USA is a wholly-owned

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subsidiary of Wessel-Werk GmbH and sells vacuum cleaner parts and accessories, such as front

brush attachments, in the United States.

JURISDICTION AND VENUE

4. This is an action for patent infringement arising under the patent laws of the

United States, Title 35, United States Code. This Court has subject matter jurisdiction pursuant

to 28 U.S.C. §§1331 and 1338(a).

5. This Court has personal jurisdiction over the Defendant at least because

Defendant is incorporated in Delaware and has established sufficient minimum contacts with

Delaware such that the exercise of jurisdiction would not offend traditional notions of fair play

and substantial justice.

6. Venue is proper in this district under 28 U.S.C. § 1400(b). Defendant is

incorporated in and thus resides in the State of Delaware and this judicial district.

COUNT I: INFRINGEMENT OF U.S. PATENT NO. 6,823,559

7. Plaintiff Wessel-Werk GmbH is the owner of U.S. Patent No. 6,823,559 (the "559

Patent"), which legally issued on November 30, 2004 to Plaintiff Wessel-Werk GmbH who,

since that date, has been and still is the owner of the 559 Patent. A true and correct copy of the

559 Patent is attached as Exhibit 1.

8. The 559 patent is titled “FRONT BRUSH ATTACHMENT DEVICE FOR

VACUUM CLEANER” and is directed to a front brush attachment that has a lockable joint. By

way of example, claim 5 of the 559 Patent reads as follows:

A front brush attachment device for a vacuum cleaner comprising:

a. a housing;

b. a rotating and tilting joint, connecting said housing to a vacuum cleaner;

2
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c. a first locking device that prevents said rotating and tilting joint from rotating,

and that locks said housing and said rotating and tilting joint when said rotating

and tilting joint is in a substantially vertical position; and

d. a second locking device for detachably coupling said rotating and tilting joint

to said housing that prevents said rotating and tilting joint from tilting when said

rotating and tilting joint is in a substantially vertical position.

9. Defendant has been and is infringing the 559 Patent directly at least by importing,

using, having made, selling and offering to sell in the United States front brush vacuum cleaner

attachments depicted in Fig. 1A below (the "Quantum Vac Attachment").

10. The Quantum Vac Attachment infringes all claims of the 559 Patent.

11. By way of example, and as demonstrated below, the Quantum Vac Attachment

has all the features recited in claim 5 of the 559 Patent in that such Quantum Vac Attachment is a

front brush attachment device for a vacuum cleaner.

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12. The Quantum Vac Attachment includes a housing and a rotating and tilting joint,

connecting the housing to the vacuum cleaner, which are illustrated below.

housing

Portion that
connects to a
vacuum cleaner

rotating and
tilting joint

Fig. 1A Fig. 1B

13. The Quantum Vac Attachment also includes a first locking device that prevents

the rotating and tilting joint from rotating, and that locks the housing and the rotating and tilting

joint when the rotating and tilting joint is in a substantially vertical position.

protrusion Fig. 2B
on housing protrusion prevents the
serving as an The rotating and rotating and tilting joint
exemplary tilting joint is and locks the housing
first locking Fig. 2A shown in a and the rotating and
device vertical position tilting joint

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As shown in Fig. 2A, the housing has a protrusion that extends toward the rotating and tilting

joint. Fig. 2B shows the rotating and tilting joint extended in a substantially vertical position,

and when the rotating and tilting joint is rotated in this position, the protrusion (e.g., the first

locking device) inserts into the rotating and tilting joint, which prevents the rotating and tilting

joint from rotating about a vertical axis and locks the housing and the rotating and tilting joint.

14. The Quantum Vac Attachment also includes a second locking device for detachably

coupling the rotating and tilting joint to the housing that prevents the rotating and tilting joint

from tilting when the rotating and tilting joint is in a substantially vertical position. As shown in

Figs. 3A and 3C below, the Quantum Vac Attachment has a spring-loaded locking lever that may

be disposed within the housing when the front brush attachment is fully assembled. In the

Quantum Vac Attachment, the spring-loaded locking lever is the second locking device.

a spring-loaded locking lever is

illustrated and serves as an
exemplary second locking device

shoulder of
rotating and tilt
joint

Fig. 3A Fig. 3B

5
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shoulder of
spring-loaded
rotating and tilt
locking lever
joint
engaged with
the rotating and
tilting joint’s
shoulder (within
the housing in
Fig. 3D)
spring-loaded
locking lever
Fig. 3C Fig. 3D

As illustrated in Figs. 3A-3D of the Quantum Vac Attachment above, when the rotating

and titling joint reaches a vertical position, the spring-loaded locking lever (e.g., second locking

device) engages a shoulder of the rotating and tilt joint to couple the second locking device to the

housing, thereby preventing the rotating and tilt joint from titling (until a release button is

depressed to detach the spring-loaded locking lever from the rotating and titling joint’s shoulder).

15. Thus, the Quantum Vac Attachment meets each and every element of claim 5 of

the 559 patent and thus Defendant is infringing at least claim 5 of the 559 Patent.

16. Defendant was notified of its infringement of the 559 Patent at least as early as

August 9, 2018 by a letter dated August 9, 2018 to Justin Miller, who was the attorney for

Defendant at that time. Defendant is continuing to sell at least the above-referenced Quantum

Vac Attachment, and thus, is continuing to infringe the 559 Patent willfully and deliberately.

COUNT II: INFRINGEMENT OF U.S. DESIGN PATENT NO. D619,772

17. Plaintiff Wessel-Werk GmbH is the owner of U.S. Design Patent No. D619,772 S

(the "772 Patent"), which issued on July 13, 2010. A true and correct copy of the 772 Patent is

attached as Exhibit 2.

18. The scope of the design claimed in the 772 Patent is as follows:

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19. Defendant has been and is infringing the 772 Patent at least by offering for sale a

front brush vacuum cleaner (“Quantum Vac Pet Hair Remover”) as depicted in Figs. 4A and 4B.

Fig. 4A

Fig. 4B

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20. The image of Defendant's Quantum Vac Pet Hair Remover presented in

connection with the Quantum Vac Pet Hair Remover offered for sale on Defendant's website has

the same appearance as the images shown in the 772 Patent, as shown in the below comparison

in Figs. 5A with 5B.

Fig. 5A – Images from the 772 Patent Claim Fig. 5B - Defendant's Quantum
Vac Pet Hair Remover

21. As shown above via a comparison of Fig. 5A with Fig. 5B, each of the distinct

features from the image of Defendant's Quantum Vac Pet Hair Remover has the same appearance

as the claimed design of the 772 Patent, including the same raised portion on top of the front

brush attachment, the same general shape of the base, and the same bevel of the raised portion on

the base. There are no apparent differences between the look of the product in Defendant's

image used in offering the Quantum Vac Pet Hair Remover and the design claimed in the 772

Patent.

22. Thus, Defendant infringes the design claimed in the 772 Patent at least by offering

for sale the Quantum Vac Pet Hair Remover on the Defendant's website which has an appearance

that has the same scope as claimed in the 772 Patent.

23. Defendant was notified of its infringement of the 772 Patent at least as early as

August 9, 2018 by a letter dated August 9, 2018 to Justin Miller, who was the attorney for

Defendant at that time. Defendant is continuing to offer for sale on its website at least the

8
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Quantum Vac Pet Hair Remover, and thus, is continuing to infringe the 772 Patent willfully and

deliberately.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment and relief as follows:

A. Adjudge and decree that Defendant has and continues to infringe one or

more claims of the 559 Patent under 35 U.S.C. § 271;

B. Adjudge and decree that Defendant has and continues to infringe the

design claimed in the 772 Patent under 35 U.S.C. § 271;

C. Preliminarily and permanently enjoin Defendant, its officers, directors,

servants, agents, employees, successors, and assigns, and all those in active concert or

participation with them, from further acts of infringement of the 559 and 772 Patents

under 35 U.S.C. § 283;

D. Order that Defendant immediately destroy, discard and not make any

further use of any products determined to infringe the 559 and 772 Patents;

E. Order Defendant to pay damages adequate to compensate Plaintiffs for

Defendant's infringement of the 559 and 772 Patents, including lost profits and/or a

reasonable royalty, together with interest under 35 U.S.C. § 284;

F. Order Defendant to pay all of Plaintiffs’ costs and attorneys’ fees

associated with this action;

G. Adjudge and decree that Defendant's infringement of the 559 and 772

Patents has been and continues to be willful and deliberate, and award Plaintiffs enhanced

damages under 35 U.S.C. § 284;

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H. Find that this is an exceptional case under 35 U.S.C. § 285 and award

Plaintiffs their reasonable attorneys’ fees and expenses; and

I. Award Plaintiffs such further relief as this Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiffs hereby demand, pursuant to Fed. R. Civ. P. 38, a trial by jury on all issues so

triable.

MORRIS, NICHOLS, ARSHT & TUNNELL LLP

/s/ Michael J. Flynn

____________________________________
Jack. B. Blumenfeld (#1024)
Michael J. Flynn (#5333)
1201 North Market Street
P.O. Box 1347
OF COUNSEL: Wilmington, DE 19899
(302) 658-9200
Aaron L. Webb jblumenfeld@mnat.com
William J. Utermohlen mflynn@mnat.com
Peter T. Ewald
OLIFF PLC Attorneys for Plaintiffs
277 South Washington Street
Suite 500
Alexandria, Virginia 22314
(703) 836-6400

R. Brian Drozd
OLIFF PLC
South Tryon Square
201 S. Tryon Street, Suite 1200
Charlotte, NC 28202
(704) 375-9249

November 5, 2018

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EXHIBIT 1
Case 1:18-cv-01741-UNA Document 1-1 Filed 11/05/18 Page 2 of 14 PageID #: 12
USOO6823559B2

(12) United States Patent (10) Patent No.: US 6,823,559 B2

Kaffenberger et al. (45) Date of Patent: Nov.30, 2004

(54) FRONT BRUSH ATTACHMENT DEVICE FOR 4,700.429 A * 10/1987 Martin et al. ................. 15/377
WACUUM CLEANER 5,537,710 A * 7/1996 Selewski et al. .............. 15/377
2001/0027586 A1 10/2001 Lee .................. ... 15/377
(75) Inventors: Dieter Kaffenberger, Wiehl (DE); 2001/0037536 A1 11/2001 Kim ............................ 15/361
Klaus-Dieter Riehl, Drolshagen (DE) FOREIGN PATENT DOCUMENTS
(73) Assignee: Wessel-Werk GmbH, JP 10328098 * 12/1998
Reichshof-Wildbergerhütte (DE) * cited by examiner
(*) Notice: Subject to any disclaimer, the term of this Primary Examiner Terrence R. Till
patent is extended or adjusted under 35 (74) Attorney, Agent, or Firm-Collard & Roe, PC
U.S.C. 154(b) by 326 days.
(57) ABSTRACT
(21) Appl. No.: 10/156,776 A front brush attachment device for a vacuum cleaner
(22) Filed: May 22, 2002 comprises a multi-component housing, a rotationally driven
brush roller, and a rotating and tilting joint for connecting
(65) Prior Publication Data the vacuum cleaner. The rotating and tilting joint has a tilting
US 2003/0145422 A1 Aug. 7, 2003 joint piece inserted in a Suction duct of the housing, as well
as a short, rotatable joint tube, which is connected with the
(30) Foreign Application Priority Data tilting joint piece in a rotating manner. The tilting joint piece
Feb. 7, 2002 (DE) ..................................... 2O2 O1881 U
is Supported in the housing in a manner permitting it to
revolve about an axle aligned transversely in relation to the
(51) Int. Cl. .............................. A47L 9/32; A47L 5/32 Suction duct. The short, rotatable joint tube is mounted on a
(52) U.S. Cl. ............................................ 15/410; 15/377 cylindrical connector piece with rotational mobility. A pro
(58) Field of Search ............................. 15/327.1, 327.2, trusion on the housing and a receSS on the rotatable joint tube
15/327.3, 327.4, 327.5, 327.6, 327.7, 377, engage each other in the locking position and Secure the
410 Short, rotatable joint tube against rotation. A spring-loaded
locking lever is Supported on the housing, which, in the
(56) References Cited locking position, engages a shoulder located on the periph
ery of the tilting joint piece.
U.S. PATENT DOCUMENTS
4,423.534 A * 1/1984 Lyman et al. ................. 15/410 7 Claims, 2 Drawing Sheets

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U.S. Patent Nov.30, 2004 Sheet 1 of 2 US 6,823,559 B2

Case 1:18-cv-01741-UNA Document 1-1 Filed 11/05/18 Page 4 of 14 PageID #: 14

U.S. Patent Nov.30, 2004 Sheet 2 of 2 US 6,823,559 B2

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Case 1:18-cv-01741-UNA Document 1-1 Filed 11/05/18 Page 5 of 14 PageID #: 15
US 6,823,559 B2
1 2
FRONT BRUSH ATTACHMENT DEVICE FOR
WACUUM CLEANER
BACKGROUND
The invention relates to a front brush attachment device
for a vacuum cleaner that acts as a Suction head. The housing
of the suction head has a brush roller chamber that is open
on its bottom Side, and a Suction duct that feeds into the
brush roller chamber. A rotationally driven brush roller is
rotatably Supported in the brush roller chamber. A rotating
and tilting joint connects a vacuum cleaner to the housing.
The joint has a tilting joint piece inserted in the Suction duct,
as well as a short, rotating joint tube connected in a
rotational manner with the tilting joint piece. When pivoted
upward, the rotating and tilting joint is moved into a locked
position at a stop Surface on the housing.
The frontbrush attachment device is intended for vacuum
cleaners with a blower, a dust bag for receiving dirt, and a
handle on its back Side. The vacuum cleaner may be
connected with the rotating and tilting joint of the front
brush attachment device by a fixed or releasable connection.
Vacuum cleaners having a front brush attachment device
connected in a fixed manner are often referred to as upright
Vacuum cleaners.
The short, rotatable joint tube of the rotating and tilting
joint is frequently angled, which permits Steering of the
Suction head as it is moved. By rotating the handle con
nected with the vacuum cleaner, it is possible to Steer the
Suction head to the right or left, allowing for vacuum
cleaning in poorly accessible areas. After the vacuum
cleaner has been used, it is Stored in an upright position.
However, the mobility of a rotating and tilting joint poses the
risk that a vacuum cleaner may tilt over to the right or left.
The present invention has a rotating and tilting joint that
can lock preventing movement in all directions. When in the
locked position, the vacuum cleaner can be stored in the
upright position without being Supported by a wall.
The locking device has a simple Structure and is easily
handled. Furthermore, clamping devices projecting from the
outer side of the front brush attachment device are avoided.
SUMMARY
In the present invention, a front brush attachment device
for a vacuum cleaner comprises a multi-component housing
in the form of a suction head. The housing has a brush roller
chamber that is open on its bottom Side, and a Suction duct
feeding into the brush roller chamber. A rotationally driven
brush roller is rotatably supported in the brush roller cham
ber. A rotating and tilting joint connects a vacuum cleaner to
the housing. The rotating and tilting joint has a tilting joint
piece that is inserted in the Suction duct, as well as a short
rotatable joint tube that is connected in a rotating manner
with the tilting joint piece. Pivoting the rotating and tilting
joint tube upward moves it into a locked position at a stop
Surface on the housing.
The tilting joint piece is Supported in the housing and
rotates about an axle that is aligned transversely in relation
to the Suction duct. The tilting joint piece is adapted to the
croSS Section of the Suction duct and is shaped like a short
pipe. It has a cylindrical peripheral Surface, against which
the housing is Sealed. The tilting joint piece also comprises
a cylindrical connector piece, on which the Short, rotating
tube of the joint is mounted in a rotating manner.
Form-locking moldings exist in the form of a protrusion
on the housing and a receSS in the joint tube. The protrusion
and receSS engage in the locked position and Secure the
Short, rotatable joint tube against rotation. The Second lock
ing element is a Spring-loaded locking lever that is Supported
on the housing. When in the locked position, the locking
lever engages a shoulder located on the periphery of the
tilting joint piece. This prevents the tilting of the tilting joint
piece. However, the tilting joint piece is only in the fully
upright position when the protrusion and receSS engage. This
prevents the Spring-loaded locking lever from engaging the
shoulder until the protrusion and receSS engage, Simulta
neously locking the joint from tilting and rotating.
The Spring-loaded locking leverlockS automatically when
the rotating and tilting joint is pivoted upward against the
Stop Surface on the housing. When it is in the locked
15 position, the rotating and tilting joint is effectively Secured
not only against pivotal movements, but also against rota
tional movement. When the rotating and tilting joint is
released from the locking lever, the joint has mobility in all
directions.
According to a preferred embodiment of the invention,
the housing is comprised of a bottom dish, an upper part
connected with the bottom dish in a fixed manner, and a
cover extending over the upper part. The bottom dish and the
upper part jointly form the brush roller chamber and the
25 Suction duct. The bottom dish and upper part also encapsu
late installation chambers where an electric motor for driv
ing the brush roller, as well as electrical components are
accommodated. The locking lever is Supported in a rotating
manner on the upper part and covered by the cover, except
for a Switching area that is accessible outside the housing.
The cover may be plastic with thin walls.
The locking lever is U-shaped with journal pins molded
onto its legs. The Switching Surface is molded to the end of
at least one of the legs. The underside of this Surface is acted
35 upon by a pressure Spring Supported on the upper part. A
locking tooth is molded onto the bridge of the U-shaped
lever. The locking tooth is guided through a slot-like open
ing of the upper part of the housing where it engages the
rotating and tilting joint in the locked position by locking
40 into the shoulder.
According to a preferred embodiment of the invention,
the upper part of the housing and the cover comprise cavities
that are adapted to the range of Swivel of the rotating and
tilting joint, and are rounded at the Sides. The cover has a
45 protrusion in the rounded area of the cavity. When the
rotating and tilting joint is in the locked position, the
protrusion engages a receSS provided on the periphery of the
Short joint tube, Securing the joint against rotation.
50 BRIEF DESCRIPTION OF THE DRAWINGS
Other objects and features of the present invention will
become apparent from the following detailed description
considered in connection with the accompanying drawings
which disclose one embodiment of the present invention. It
55 should be understood, however, that the drawings are
designed for the purpose of illustration only and not as a
definition of the limits of the invention.
In the drawings, wherein Similar reference characters
denote similar elements through the Several views:
60 FIG. 1 shows an exploded view of a front brush attach
ment device for vacuum cleaners, and
FIG. 2 shows a longitudinal cross-section through the
object shown in FIG. 1.
65 DETAILED DESCRIPTION
Referring now in detail to the drawings, FIG. 1 shows a
front brush attachment device having a multi-component
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US 6,823,559 B2
3 4
housing 1 in the form of a Suction head. Housing 1 has a
bottom dish 2, an upper part 3 connected with bottom dish
2 in a fixed manner, and a cover 4 that extends over upper
part 3. Housing 1 contains a brush roller chamber 5, which
is open on the bottom Side, and a Suction duct 6 feeding into 5 1. A front brush attachment device for a vacuum cleaner
brush roller chamber 5. Suction duct 6 and brush roller
chamber 5 are formed by the walls of upper part 3 and
bottom dish 2. A brush roller 7 is supported in a rotating
manner in brush roller chamber 5. Brush roller 7 is driven by
an electric motor 8 via a toothed belt 9.
A connector device connects a vacuum cleaner to housing
1. The connector device is a rotating and tilting joint 10.
Rotating and tilting joint 10 has a tilting joint piece 11,
which is inserted in Suction duct 6. Rotating and tilting joint
10 also has a short, rotatable joint tube 12 that is connected 15
with tilting joint piece 11 with rotational mobility. Short,
rotatable joint tube 12 is an angled tube. Pivoting it upward
moves it into a locked position at a stop Surface 13 on
housing 1. Tilting joint piece 11 is Supported in housing 1 in
a rotating manner and rotates about an axle 14 aligned
transversely in relation to Suction duct 6. Tilting joint piece
11 has the shape of a short pipe and comprises a cylindrical
peripheral Surface. Housing 1 is Sealed against the cylindri
cal peripheral Surface. Tilting joint piece 11 comprises a
cylindrical connector piece 25, on which short, rotating joint 25
tube 12 is mounted in a rotating manner.
Upper part 3 and cover 4 comprise cavities 24, which are
adapted to the range of Swivel of rotating and tilting joint 10
and are rounded on the Sides. A protrusion 15 projecting
from the rounded area of cavity 24 is molded onto cover 4.
In the locked position, protrusion 15 engages a correspond
ing receSS 16 located on the periphery of Short, rotatable
joint tube 12, Securing joint tube 12 against rotation. A
Spring-loaded locking lever 17 is Supported on housing 1. In 35
the locked position, locking lever 17 engages a shoulder 18
located on the cylindrical periphery of tilting joint piece 11,
thereby preventing the movement of tilting joint piece 11.
However, tilting joint piece 11 is only in the fully upright
position when protrusion 15 and receSS 16 engage. This 40
prevents Spring-loaded locking lever 17 from engaging
shoulder 18 until protrusion 15 and recess 16 engage,
Simultaneously locking rotating and tilting joint 10 from
tilting and rotating.
FIG. 1 shows that locking lever 17 is substantially 45
U-shaped and Supported on upper part 3 of housing 1 in a
rotating manner. Journal pins 19 are molded on the legs of
locking lever 17 and clipped into fork-shaped bearings 20 of
upper part 3. A Switching Surface 21 is molded at the end of
one of the legs, and acted upon from below by a pressure 50
Spring 22 Supported on upper part 3. A locking tooth 23 is
molded onto the bridge of U-shaped locking lever 17 and
guided through a slot-like aperture of upper part 3. In the
locked position, locking tooth 23 locks onto shoulder 18 of
rotating and tilting joint 10. 55
In the locked position, pivotal movements of rotating and
tilting joint 10 are blocked by locking lever 17, which
engages shoulder 18 of tilting joint piece 11 from behind.
Short, rotatable joint tube 12 is effectively secured against
rotation at the same time. By actuating Switching Surface 21, 60
locking tooth 23 is lifted by a pivotal movement of locking
lever 17, and rotating and tilting joint 10 is released. The
locking System as defined by the invention does not com
prise any locking elements projecting from the Outer Side of
the front brush attachment device. 65
Accordingly, while one embodiment of the present inven
tion has been shown and described, it is to be under Stood
that many changes and modifications may be made there
unto without departing from the Spirit and Scope of the
invention as defined in the appended claims.
What is claimed is:
comprising:
a. a multi component housing having a bottom Side, a stop
Surface, and a protrusion;
b. a brush roller chamber disposed within said multi
component housing and open on Said bottom Side of
Said multi-component housing,
c. a Suction duct disposed within Said multi-component
housing that feeds into Said brush roller chamber;
d. a rotationally driven brush roller Supported in a rotating
manner in Said brush roller chamber;
e. a Spring-loaded locking lever, Supported on Said multi
component housing, and
f. a rotating and tilting joint, connecting Said multi
component housing to a vacuum cleaner, comprising:
i.a tilting joint piece having a shoulder on its periphery,
wherein Said tilting joint piece is inserted into Said
Suction duct and Supported in a rotational manner
about an axle aligned transversely in relation to Said
Suction duct;
ii. a rotatable joint tube coupled to Said tilting joint
piece with rotational mobility, wherein a receSS is
disposed on the connection end of Said Short rotat
able joint tube, and
iii. a cylindrical connector piece that couples Said
rotatable joint tube to Said tilting joint piece and
permits rotation of Said rotatable joint tube;
wherein Said rotating and tilting joint may be directed into
a locked position at Said Stop Surface of Said multi
component housing by an upwardly directed pivotal
movement, and wherein in Said locked position Said
protrusion engages Said receSS locking and Securing
Said short rotatable joint tube against rotation, while
Said Spring-loaded locking lever engages Said shoulder,
preventing tilting of Said tilting joint piece.
2. The front brush attachment device according to claim
1, wherein Said multi-component housing comprises a bot
tom dish, an upper part connected with Said bottom dish in
a fixed manner, and a cover extending over Said upper part;
wherein Said bottom dish and Said upper part form Said brush
roller chamber and Said Suction duct, and wherein Said
locking lever is Supported on Said upper part in a rotating
C.
3. The front brush attachment device according to claim
2, wherein Said locking lever is Substantially U-shaped with
two legs and comprises:
a plurality of journal pins molded onto Said legs of Said
U-shaped lever;
a Switching Surface molded onto the end of at least one of
Said legs,
a pressure Spring Supported by Said upper part, wherein
Said pressure Spring acts on the underSide of Said
Switching Surface; and
a locking tooth molded onto a bridge of Said U-shaped
lever, wherein Said locking tooth is guided through a
slot-like aperture of Said upper part, engaging Said
shoulder of Said tilting joint piece in Said locked
position.
4. The front brush attachment device according to claim
2, wherein Said upper part and Said cover comprise cavities
adapted to the range of pivoting of Said rotating and tilting
joint and wherein Said protrusion is disposed in Said cavity.
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US 6,823,559 B2
S 6
5. A front brush attachment device for a vacuum cleaner Said rotating and tilting joint from tilting when Said
comprising: rotating and tilting joint is in a Substantially vertical
a. a housing, position.
b. a rotating and tilting joint, connecting Said housing to 6. The front brush attachment according to claim 5
a vacuum cleaner; wherein Said Second locking device comprises a Spring
c. a first locking device that prevents Said rotating and loaded locking device Supported on Said housing.
tilting joint from rotating, and that lockS Said housing 7. The front brush attachment according to claim 5
and Said rotating and tilting joint when Said rotating and wherein Said first locking device comprises a protrusion and
tilting joint is in a Substantially vertical position; and 10 a receSS.
d. a Second locking device for detachably coupling Said
rotating and tilting joint to Said housing that prevents
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EXHIBIT 2
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USOOD619772S

(12) United States Design Patent (10) Patent No.: US D619,772S

Kaffenberger (45) Date of Patent: Jul. 13, 2010
(54) VACUUM CLEANER HEAD D520,694 S * 5/2006 Choi ........................... D32.32
D590,112 S * 4/2009 Sun ........ ... D32/32
(75) Inventor: Dieter Kaffenberger, Wiehl (DE) D590,554 S * 4, 2009 Griffin ... ... D32/32
2006/0042041 A1* 3/2006 Kim ............................ 15,387
(73) Assignee: Wessel-Werk GmbH, * cited b
Reichshof-Wildbergerhuette (DE) cited by examiner
ck Primaryy Examiner Ruth McInroy
(**) Term: 14 Years (74) Attorney, Agent, or Firm—Collard & Roe, P.C.
(21) Appl. No.: 29/315,169 (57) CLAM
(22) Filed: Jun. 2, 2009 The ornamental design for a vacuum cleaner head, as shown
(30) Foreign Application Priority Data aCd described.
CSC1)
Dec. 15, 2008 (EM) ..................... OO1 O56907-OOO1 DESCRIPTION
FIG. 1 shows a top, front and right side perspective view of a
3. Ip Cl. .................................................. p. vacuum cleaner head, showing my new design;
(58) Field of Classification Search ............ Das FIG. 2 shows a front view thereof.
15/414–422.1, 236.04, 1444, 144.3, 406, FIG. 3 shows a rear view thereof;
15/104.05, 383,377,412,400 402, 387, FIG. 4 shows a top view thereof;
15/322,344 - 0
See application file for complete search history. FIG. 5 shows a right side view thereof;
FIG. 6 shows a left side view thereof, and,
(56) References Cited FIG. 7 shows a bottom view thereof.
U.S. PATENT DOCUMENTS The areas shown in broken lines form no part of the claimed
D290,418 S * 6/1987 Strohmeyer .................. D32/32 design.
D443,741 S * 6/2001 Parr et al. .................... D32/32
D508,154 S 8/2005 Carr ............................ D32/32 1 Claim, 5 Drawing Sheets
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U.S. Patent Jul. 13, 2010 Sheet 3 of 5 US D619,772S

FIG. 4
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U.S. Patent Jul. 13, 2010 Sheet 5 of 5 US D619,772S

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FIG. 7
 Case 1:18-cv-01741-UNA Document 1-2 Filed 11/05/18 Page 1 of 1 PageID #: 25
JS 44 (Rev. 06/17) 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

WESSEL-WERK GMBH and WESSEL-WERK USA, INC. INTELLICLEAN SOLUTIONS, LLC

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(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)
Michael J. Flynn, Esquire; Morris, Nichols, Arsht & Tunnell LLP
1201 North Market Street, Wilmington, DE 19801
(302) 658-9200

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(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
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u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
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(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
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VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement
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VIII. RELATED CASE(S)
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DATE SIGNATURE OF ATTORNEY OF RECORD
11/5/2018 /s/ Michael J. Flynn
FOR OFFICE USE ONLY

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