IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA RESHARE COMMERCE, LLC, Plaintiff, v.

PURE ROMANCE, INC., Defendant. Civil Case No. ________________

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Reshare Commerce, LLC (Reshare), by way of its complaint against Defendant Pure Romance, Inc. (Pure Romance or Defendant), demands a jury trial and alleges as follows: NATURE OF THE ACTION 1. This is an action for patent infringement arising under the patent laws of the

United States, 35 U.S.C. 1 et seq., brought against Defendant for violations of those laws. 2. Plaintiff Reshare is a Minnesota corporation with its principal place of business at

5051 Highway 7, Minneapolis, Minnesota 55416. 3. Upon information and belief, Defendant Pure Romance is an Ohio corporation

with its principal place of business at 161 Commerce Blvd., Loveland, OH 45140. JURISDICTION AND VENUE 4. This action arises under the patent laws of the United States, Title 35 of the

United States code, 1, et seq. 5. 1338(a). This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and

6.

Pure Romance has contacts that are sufficiently continuous and systematic to

constitute doing business within the State of Minnesota and within this District and has engaged and continues to engage in sales and other conduct with respect to Pure Romances products and services within this District, including conduct that infringes the Patent-in-Suit. Pure Romance uses, and/or directs, induces or instructs its agents, employees, customers, or contracting entities to engage in infringing conduct within this District. FACTUAL BACKGROUND 7. Reshare is a leading software and strategy company. Reshare offers a complete

range of consulting and development services along with its software solutions. Reshare provides software and strategies to its customers that resolve channel conflict, guarantee complete brand control, and enhance relationships between all channel partners and end users. 8. On July 15, 2003, the United States Patent and Trademark Office duly and legally

issued U.S. Patent No. 6,594,641 (the 641 patent), entitled Computer Facilitated Product Selling System. 9. Complaint. 10. 641 patent. PURE ROMANCE 11. Pure Romance is a direct-selling company that sells a variety of products, Reshare is the owner by assignment of all right, title, and interest in and to the A true and correct copy of the 641 patent is attached as Exhibit A to this

primarily relationship and intimacy aids.1

SeethePureRomanceAboutUspageathttp://pureromance.com/aboutus/.

12.

Pure Romance offers its products for resale through consultants. Pure Romance

infringes the 641 patent through the operation of its website, www.pure romance.com, and the manner in which it associates sales of products on the website to consultants. COUNT 1 INFRINGEMENT OF U.S. PATENT NO. 6,594,641 13. Reshare realleges and incorporates herein by reference the allegations contained

in Paragraphs 1 through 12. 14. Defendant has been, and/or continues to be, knowingly and intentionally, literally

or equivalently infringing the 641 patent, directly and/or indirectly, by making, using, marketing, selling, offering to sell, licensing and/or supporting systems, websites, products and/or services covered by one or more claims of the 641 patent. 15. Reshare has been damaged by the Defendants infringement, and will continue to

suffer damage and irreparable injury until the infringement is enjoined by this Court. 16. Reshare is entitled to injunctive relief and damages in accordance with 35 U.S.C.

271, 281, 283, and 284. JURY DEMAND 17. Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Reshare hereby

respectfully requests a jury trial on all issues and claims so triable. PRAYER FOR RELIEF WHEREFORE, Reshare prays for judgment as follows: A. Permanently enjoin Defendant, its officers, agents, servants, employees,

attorneys, successors, assigns, and anyone acting in concert therewith or on its behalf, from infringing the 641 patent, pursuant to 35 U.S.C. 283;

B.

Award Reshare compensatory damages for Defendants infringement,

together with interest and costs pursuant to 35 U.S.C. 284; C. Award treble damages to Reshare, pursuant to 35 U.S.C. 284 for

continued willful infringement by defendant to the extent that Defendant continues infringement after receiving notice of infringement of the 641 Patent through service of this complaint; D. Find this case exceptional and award Reshare reasonable attorneys fees

pursuant to 35 U.S.C. 285; E. Award such other and further relief as this Court deems just and proper.

Respectfully submitted, Dated: April 11, 2012 /s/ Dwight G. Rabuse Dwight G. Rabuse (209429) Joshua P. Brotemarkle (386581) Erin E. Neils (390381) RABUSE LAW FIRM, P.A. The Historic Rand Tower 527 Marquette Avenue, Suite 1530 Minneapolis, MN 55402 Tel.: 612-843-3333 Fax: 612-843-3330 Email: dwight@rabuselaw.com Email: josh@rabuselaw.com Email: erin@rabuselaw.com Steven R. Daniels FARNEY DANIELS, LLP 800 S. Austin Avenue, Suite 200 Georgetown, Texas 78626 Tel: 512-582-2828 Fax: 512-582-2829 Email: sdaniels@farneydaniels.com ATTORNEYS FOR PLAINTIFF RESHARE COMMERCE, LLC