IN THE UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND _____________________________________________ ) Freyssinet, Inc.

, ) 44880 Falcon Place, Suite 100 ) Sterling, VA, 20166 ) ) Civil Action No. Plaintiff, ) ) v. ) Jury Trial Demanded ) VSL International AG ) Saegestrasse 76, ) Kniz CH-3098, Switzerland ) ) and ) ) VStructural LLC, ) 7455 New Ridge Road, Suite T ) Hanover, Anne Arundel County, MD 21076 ) ) ) Defendants. ) ___________________________________________ ) COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Freyssinet, Inc. (Freyssinet), by and through its attorneys, hereby demands a jury trial and complains of Defendants, VSL International AG and VStructural LLC (collectively VSL), 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., to enjoin infringement and obtain damages resulting from VSLs infringement of one or more claims of United States Patent No. 6,748,708 (the 708 patent) based on activities related to VSLs systems for anchoring structural cable. Freyssinet seeks injunctive relief to

prevent VSL from continuing to infringe Freyssinets 708 patent. In addition, Freyssinet seeks a recovery of monetary damages resulting from VSLs past infringement of Freyssinets 708 patent. THE PARTIES 2. Plaintiff Freyssinet, Inc. is a Delaware company having its principal place of business at

44880 Falcon Place, Suite 100, Sterling, VA, 20166. 3. Upon information and belief, Defendant VSL International AG is a Swiss company

having a principal place of business at Saegestrasse 76, Kniz CH-3098, Switzerland. On information and belief, VSL International AG is also known as VSL International Ltd. and VSL International SA. 4. Upon information and belief, Defendant VStructural LLC is a corporation organized and

existing under the laws of the State of Maryland, with a place of business at 7455 New Ridge Road, Suite T, Hanover, MD 21076. JURISDICTION AND VENUE 5. This action is for patent infringement under the patent laws of the United States, 35

U.S.C. 1 et seq. 6. and 1338(a). 7. Upon information and belief, this Court has personal jurisdiction over VSL International This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C. 1331

AG and VStructural LLC at least because both defendants have engaged in infringing activities within this judicial district and have continuously and systematically engaged in business activities in Maryland and purposefully availed themselves of the privilege of conducting activities within Maryland, one or

more defendants reside in this judicial district and VStructural LLC is organized and existing under the laws of the State of Maryland. 8. Venue is proper in this district pursuant to 28 U.S.C. 1391(b), 1391(c), and 1400(b).

Upon information and belief, VStructural LLC and VSL International AG reside in this judicial district. GENERAL ALLEGATIONS 9. On June 15, 2004, the United States Patent and Trademark Office duly and legally issued

the 708 patent to Jean-Philippe Fuzier and Jrme Stubler. Freyssinet is the owner by assignment of the 708 patent. A true and correct copy of the 708 patent is attached as Exhibit A. COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,748,708 10. Freyssinet incorporates by reference the allegations set forth in paragraphs 1 through 9 as

though fully set forth herein. 11. VSL International AG and VStructural LLC have been and continue to be infringing,

inducing infringement of, and/or contributorily infringing the 708 patent by making, using, offering to sell, and/or selling in the United States, and/or importing into the United States, and/or actively inducing others to make, use, sell or offer to sell products and systems that are covered by one or more claims of the 708 patent, including, but not limited to the VSL systems for anchoring structural cable. On information and belief, VStructural LLC has made, used, offered to sell, and/or sold in the United Stated and/or imported into the United States the VSL infringing systems for anchoring structural cable for at least the Ironton Russell Bridge in Ironton, Ohio and Russell, Kentucky, the John James Audubon Bridge in St. Francisville, Louisiana, the kcICON Bridge in Kansas City, Missouri, the Main Street Bridge in Columbus, Ohio, the Margaret Hunt Hill Bridge in Dallas, Texas, the New Mississippi River 3

Bridge in St. Louis, Missouri, and the U.S. Grant Bridge in Portsmouth, Ohio and South Shore, Kentucky. On information and belief, VSL International AG licensed the VSL infringing systems for manufacture, use, sale and/or offer to sell in the United States for the bridges noted above and/or made, used, offered to sell, and/or sold in the United Stated and/or imported into the United States the VSL infringing systems. On information and belief, VSL International AG also provided engineering

drawings and schematics to others to induce them to make, use, sell, offer to sell, and/or import systems for anchoring structural cable that are covered by one or more claims of the 708 patent. 12. On information and belief, VSL has engaged in a deliberate course of action to copy

Freyssinet technology protected by intellectual property owned by Freyssinet. 13. 14. Freyssinet has been damaged by VSLs infringement. VSLs acts of infringement have been without an express or implied license by

Freyssinet, are in violation of Freyssinets rights, and will continue unless enjoined by this Court. 15. Freyssinet has been and will continue to be irreparably harmed by VSLs infringement of

the 708 patent. 16. Upon information and belief, VSLs acts of infringement have been undertaken with

knowledge of the 708 patent and with knowledge that the VSL infringing systems are covered by one or more claims of the 708 patent. VSLs acts establish willful infringement and make this case exceptional pursuant to 35 U.S.C. 284 and 285, and entitle Freyssinet to enhanced damages and reasonable attorneys fees. JURY DEMAND 17. Trial by jury is hereby demanded. 4

RELIEF SOUGHT WHEREFORE, Freyssinet prays: A. 708 patent; B. For injunctive relief against further infringement of the 708 patent by VSL, its officers, For this Court to adjudge and decree that VSL has been and is currently infringing the

agents, servants, employees, attorneys, subsidiaries, parents, affiliates and all those persons in active concert or participation with anyone or more of them; C. That this Court orders that VSL notifies purchasers and users of the infringing VSL

systems that the VSL systems infringe the 708 patent owned by Freyssinet; D. For an award of damages to compensate Freyssinet for the infringement of the 708

patent, together with pre-judgment and post-judgment interest; E. For an award of enhanced damages up to three times the amount found or assessed based

on VSLs willful infringement, pursuant to 35 U.S.C. 284; F. For this Court to declare this case exceptional and direct VSL to pay Freyssinets

attorneys fees incurred in connection with this lawsuit pursuant to 35 U.S.C. 285; G. H. That Freyssinet be awarded its fees and costs; and For all such other and further relief as this Court deems just and proper.

Dated: August 1, 2012 By:

Respectfully submitted, /s/ Christopher B. Roth Christopher B. Roth (16658) BANNER & WITCOFF, LTD. 1100 13th Street, NW, Suite 1200 Washington, DC 20009 Tel: (202) 824-3000 Fax: (202) 824-3001 croth@bannerwitcoff.com Of Counsel: Jon O. Nelson Joseph J. Berghammer Bradley J. Van Pelt BANNER & WITCOFF, LTD. 10 South Wacker Drive Suite 3000 Chicago, Illinois 60606 Telephone: (312) 463-5000 Facsimile: (312) 463-5001 jnelson@bannerwitcoff.com jberghammer@bannerwitcoff.com bvanpelt@bannerwitcoff.com Attorneys for Plaintiff Freyssinet, Inc.