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COMPLAINT - 1
MANN LAW GROUP 1289 Third Avenue, Suite 1809 Seattle, WA 98101 TELEPHONE: 206.436-0900

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN LAUGHING GAS ENTERPRISES, LLC, Plaintiff, v. ANHEUSER-BUSCH COMPANIES, LLC.; AMSTEL BREWERY (a division of Heineken International), BROWN-FORMAN CORPORATION, d/b/a Jack Daniels Beverage Company, DIAGEO - GUINNESS USA INC., HEINEKEN USA, Incorporated, LINDEMAN'S and MILLER COORS, LLC, Defendants. Plaintiff Laughing Gas Enterprises, LLC (LGE) complains of Defendants as follows: NATURE OF LAWSUIT 1. This is a claim for patent infringement arising under the patent laws of the Cause No.11-cv-813 COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED

United States, Title 35 of the United States Code. THE PARTIES 2. Plaintiff LGE is a Washington State Limited Liability Company engaged in the

development and licensing of mobile multimedia technologies. LGE is the named assignee of duly issued U.S. Patent 7,697,945 (the 945 Patent) (Exhibit A).

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3.

Upon information and belief, Defendant Anheuser-Busch Companies, LLC, is

a Delaware company, with a registered agent at CT Corporation System, 120 South Central Avenue, Clayton, MO 63105 and has a principal place of business at One Busch Place. St. Louis, MO 63118. 4. Upon information and belief, Defendant Amstel Brewery, is a division of

Heineken International, a company formed under the laws of The Netherlands, and has a principal place of business at Heineken N.V., P.O. Box 28, 1000 AA Amsterdam, The Netherlands. 5. Upon information and belief, Defendant Brown-Forman Corporation, d/b/a

Jack Daniels Beverage Company, is a Delaware corporation and has a registered agent and principal place of business at William A. Blodgett, Jr., VP, 850 Dixie Highway, Louisville, Kentucky 40210. 6. Upon information and belief, Defendant DIAGEO - GUINNESS USA INC., is

a Delaware corporation and has a registered agent at Corporate Creations Network, Inc., Silverside Road Rodney Building #104, Wilmington, DE 19810 and a principal place of business at 801 Main Ave., Norwalk, CT 06851. 7. Upon information and belief, Defendant Miller Coors LLC is a Delaware

Limited Liability Company and has a principal place of business at 250 South Wacker Drive, Chicago, IL 60606-5888. 8. Upon information and belief, Defendant Heineken USA Incorporated is a

New York corporation and has a registered agent at Corporation Service Company, 80 State Street, Albany, New York, 12207-2543 and a principal place of business at 360 Hamilton Avenue Suite 1103, White Plains, New York 10601.
9. Upon information and belief, Defendant Lindeman's is a company formed

under the laws of Australia, and transacts business at 77 Southbank Boulevard, Southbank, Victoria Australia.

COMPLAINT - 2

MANN LAW GROUP 1289 Third Avenue, Suite 1809 Seattle, WA 98101 TELEPHONE: 206.436-0900

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COMPLAINT - 3

JURISDICTION AND VENUE 10. This is an action for patent infringement arising under the patent laws of the

United States of America, Title 35 U.S.C. Accordingly, this Court has jurisdiction over the subject matter of the Complaint under 28 U.S.C. 1331 and 1338(a). 11. Personal Jurisdiction over the defendants is proper in this Court. Venue in this

judicial district is proper under 28 U.S.C. 1391(b), (c) and/or 1400(b) in that a substantial part of the events giving rise to the patent infringement claims herein have taken place and may still be taking place in this judicial district. DEFENDANTS ACTS OF PATENT INFRINGEMENT 12. LGE restates and incorporates by reference paragraphs 1 through 7 above as if

fully re-stated herein. 13. Defendants Anheuser-Busch Companies, Inc. et al, have been and are

infringing the 945 Patent by making, using, offering for sale, selling and/or importing a method of conducting a promotion in accord with the claims of the 945 Patent. Attached to this Complaint as Exhibits B-H are preliminary claim charts that detail LGEs initial infringement contentions for each named Defendant. LGE reserves the right to amend, alter, and/or add to these initial infringement contentions as this matter proceeds through litigation, and in accordance with any Orders set by this Court. 14. Defendants infringement, contributory infringement and inducement to

infringe have been willful and have deliberate injured and will continue to injure LGE unless and until the Court enters an injunction prohibiting further infringement and, specifically, enjoining further manufacture, use, importation, sale and/or offer for sale of products that fall within the scope of the '945 patent. PRAYER FOR RELIEF WHEREFORE, LGE asks this Court to enter judgment against Defendants and against their subsidiaries, affiliates, agents, servants, employees and all persons in active concert or participation with them, granting the following relief:
MANN LAW GROUP 1289 Third Avenue, Suite 1809 Seattle, WA 98101 TELEPHONE: 206.436-0900

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A.

An award of damages adequate to compensate LGE for the infringement that

has occurred, together with prejudgment interest from the date infringement of the '945 patent began; B. C. Increased damages as permitted under 35 U.S.C. 284; A finding that this case is exceptional and an award to LGE of their attorneys

fees and costs as may be appropriate and as provided by 35 U.S.C. 285; D. A permanent injunction prohibiting further infringement, inducement and

contributory infringement of the 945 patent; E. Pre-judgment interest calculated from the time of the first occurrence of any

infringing activity through and until entry of judgment; and, F. Such other and further relief as this Court or a jury may deem proper and just.

JURY DEMAND LGE demands a trial by jury on all issues presented in this Complaint.

Dated: December 5, 2011.

Respectfully submitted, /Philip P. Mann Philip P. Mann, WSBA No: 28860 MANN LAW GROUP John Whitaker, WSBA No. 28868 WHITAKER LAW GROUP 1420 Fifth Avenue, Suite 2200 Seattle, Washington 98101 Phone (206) 224-3553 Fax (206) 224-2880 phil@mannlawgroup.com john@wlawgrp.com Attorneys for Plaintiff Laughing Gas Enterprises, LLC

COMPLAINT - 4

MANN LAW GROUP 1289 Third Avenue, Suite 1809 Seattle, WA 98101 TELEPHONE: 206.436-0900