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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF NORTH CAROLINA Civil Action No.

: 1:12-cv-941 PRECISION FABRICS GROUP, INC., Plaintiff, v. TIETEX INTERNATIONAL, LTD., Defendant. COMPLAINT

Plaintiff PRECISION FABRICS GROUP, INC. (PFG or Plaintiff) hereby files this Complaint for Patent Infringement against Defendant TIETEX INTERNATIONAL, LTD. (Tietex or Defendant), and shows the Court the following: 1. PFG is a corporation formed under the laws of the State of North Carolina,

having a principal place of business at 301 North Elm St., Suite 600, Greensboro, North Carolina 27401. 2. Tietex, upon information and belief, is a corporation formed under the laws

of the State of South Carolina, having a principal place of business at 3010 North Blackstock Road, Spartanburg, South Carolina 29304. Tietex is subject to suit in this district as it has been offering for sale and selling, and presently is offering for sale and selling, through established streams of commerce throughout the United States, including to customers and potential customers in this judicial district, products which infringe PFGs rights as alleged herein.

3.

This is an action for federal patent infringement pursuant to 35 U.S.C. 1

et seq. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 1331 and 1338(a), and venue has been properly laid in this district pursuant to 28 U.S.C. 1391 and 1400(b). 4. On information and belief, Tietex is a manufacturer of a broad and diverse

range of fabrics, including fabrics that are used to construct mattresses and fabrics that are fire resistant. 5. PFG is the owner, by assignment, of all right, title, and interest in and to

United States Patent No. 8,236,712 (the 712 patent) entitled Flame Resistant Filler Cloth and Mattresses Incorporating Same. A true and correct copy of the 712 patent is attached hereto as Exhibit A. 6. The 712 patent was duly and lawfully issued by the United States Patent

and Trademark Office on August 7, 2012. 7. PFG properly marks the products that it sells that meet the limitations of the

claims of the 712 patent pursuant to 35 U.S.C. 287. 8. Tietex has actual notice of the 712 patent as PFG has met with Tietex and

specifically discussed the 712 patent. Moreover, PFG has shared with Tietex the fact that PFG has conducted tests on the products that Tietex has been offering for sale and selling, and presently is offering for sale and selling, which prove that Tietex is infringing the 712 patent. Nonetheless, Tietex has continued to offer for sale and sell, and it is presently offering for sale and selling, through established streams of commerce

throughout the United States, including to customers and potential customers in this judicial district, products that infringe, literally and/or by and through the doctrine of equivalents, one or more claims of the 712 patent. In addition, PFG is informed and believes that Tietex has contributed to and/or induced others to infringe the 712 patent by selling fabric that meets the limitations of the claims of the 712 patent, literally and/or by and through the doctrine of equivalents, to third parties that Tietex knows will use such fabric to manufacture mattresses. 9. Tietex has committed the acts of infringement complained of herein

without the consent or authorization of PFG and in derogation of 35 U.S.C. 271. Tietexs acts of infringement are willful and, upon information and belief, will continue unabated unless and until enjoined by this Court. 10. patent. 11. PFG is entitled to damages, including treble damages, from Tietex pursuant Tietex has harmed PFG by virtue of Defendants acts of infringing the 712

to 35 U.S.C. 284, attorneys fees pursuant to 35 U.S.C. 285, and injunctive relief pursuant to 35 U.S.C. 283.

PRAYER FOR RELIEF WHEREFORE, PFG prays for the entry of a judgment: 1. 2. Holding that Tietex has infringed the 712 patent; Awarding PFG all available damages pursuant to 35 U.S.C. 284,

including treble damages, for Tietexs willful infringement of the 712 patent; 3. Declaring this case as exceptional pursuant to 35 U.S.C. 285 and

awarding PFG its attorneys fees and other costs and expenses; 4. 5. 6. proper. JURY TRIAL DEMAND PFG demands a trial by jury on all issues so triable. This the 22nd day of August 2012. /s/Richard A. Coughlin Richard A. Coughlin NC State Bar No. 19894 Kimberly B. Gatling NC State Bar No. 27234 SMITH MOORE LEATHERWOOD LLP 300 N. Greene Street, Suite 1400 PO Box 21927 (27420) Greensboro, NC 27401 Telephone: 336.378.5200 Facsimile: 336.378.5400 rick.coughlin@smithmoorelaw.com Attorneys for Plaintiff Awarding PFG interest to the extent permitted by law; Permanently enjoining Tietex from any further acts of infringement; and Awarding such other and further relief as this Court may deem just and