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A. Eric Bjorgum (State Bar No. 198392) Marc A. Karish (State Bar No. 205440) KARISH & BJORGUM, PC 16 N. Marengo Ave., Suite 307 Pasadena, California 91101 Telephone: (213) 785-8070 Facsimile: (213) 995-5010 E-Mail: eric.bjorgum@kb-ip.com Attorneys for Plaintiff SEVILLE CLASSICS, INC. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) ) ) ) Plaintiff, ) ) vs. ) ) TARGET CORPORATION, a ) Minnesota corporation; NEATFREAK ) GROUP, INC., a Canada corporation; ) ) NEATFREAK GROUP CORP., a Delaware corporation; and DOES 1 ) ) 10, inclusive, ) ) Defendants. ) SEVILLE CLASSICS, INC., a California corporation, Case No. COMPLAINT FOR: Patent Infringement REQUEST FOR JURY TRIAL

COMPLAINT

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Plaintiff SEVILLE CLASSICS, INC. (SEVILLE CLASSICS), by and through its attorneys, Karish & Bjorgum, PC, files this Complaint against NEATFREAK GROUP, INC., NEATFREAK GROUP CORP. (collectively, NEATFREAK), and TARGET CORPORATION (TARGET) and DOES 1-10 (collectively Defendants) as follows: JURISDICTION AND VENUE 1. 2. This is an action for patent infringement arising under the acts of Upon information and belief, Defendants have transacted business and Congress relating to patents, 35 U.S.C. 1 et. seq. committed acts of infringement within the State of California, and the Central District of California, and are subject to the personal jurisdiction of this Court. 3. 1400(b). 4. Upon information and belief, Defendants reside in this District for the purposes of venue, insofar as they are subject to the personal jurisdiction in this District, have committed acts of infringement in this District, solicit business in this District, and conduct other business in this District. THE PARTIES AND GENERAL ALLEGATIONS 5. 6. SEVILLE CLASSICS is a corporation organized under the laws of SEVILLE CLASSICS is informed and believes and based thereon California with its principal place of business located in Torrance, California. alleges that Defendant TARGET is a corporation organized under the laws of the State of Minnesota with its principal place of business located in Minneapolis, Minnesota. 7. SEVILLE CLASSICS is informed and believes and based thereon alleges that Defendant NEATFREAK is a corporation organized under the laws of Ontario, Canada, with offices in Long Valley, New Jersey, using the corporate Venue is proper in this district pursuant to 28 U.S.C. 1391 and

COMPLAINT

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entity NEATFREAK GROUP CORP. On information and belief, NEATFREAK has warehouse space in Long Beach, California. 8. SEVILLE CLASSICS is informed and believes and based thereon alleges that Defendant NEATFREAK GROUP CORP. is a corporation organized under the laws of the State of Delaware with a principal place of business in New Jersey. 9. SEVILLE CLASSICS is informed and believes and based thereon alleges that the defendants sued herein as Does 1-10 are individuals and entities who are customers or suppliers of NEATFREAK or TARGET whose names and identities are currently unknown to SEVILLE CLASSICS and who are engaged in the acts described below. SEVILLE CLASSICS will amend the Complaint to identify these individuals or entities as soon as their identities become known. SEVILLE CLASSICSS RELEVANT PATENTS 10. On September 3, 2013, the United States Patent and Trademark Office duly and legally issued U.S. Patent No. 8,522,987 (the 987 Patent) to Gary M. Lim. Plaintiff SEVILLE CLASSICS, is the assignee and owner of all right, title and interest in and to the 987 Patent, has the right to assert causes of action arising under the 987 Patent and the right to any remedies for infringement thereof. A true and correct copy of the 987 Patent is attached hereto as Exhibit A. The 987 Patent claims a rack for holding articles. The elements of the rack are shown and described in the 987 Patent. 11. On November 2, 2010, the United States Patent and Trademark Office duly and legally issued U.S. Patent No. D626,356 (the 356 Patent) to Edwin Ho. Plaintiff SEVILLE CLASSICS, is the assignee and owner of all right, title and interest in and to the 356 Patent, has the right to assert causes of action arising under the 356 Patent and the right to any remedies for infringement thereof. A true and correct copy of the 356 Patent is attached hereto as Exhibit B.

COMPLAINT

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The 356 Patent claims a modular design for a modular utility rack as shown in the drawings in the 356 Patent. FIRST CLAIM FOR RELIEF (Infringement of U.S. Pat. No. 8,522,987 Against All Defendants) 12. 13. SEVILLE CLASSICS realleges and incorporates the allegations in Defendants have infringed and continue to infringe one or more paragraphs 1 through 11 as if set forth fully herein. claims of the 987 Patent by making, using, importing, providing, offering to sell, and selling (directly or through intermediaries) infringing products, in this District and elsewhere in the United States. Upon information and belief, Defendants have also contributed to the infringement of one or more claims of the patent-in-suit and/or actively induced others to infringe one or more claims of the patents-in-suit in this District and elsewhere in the United States. On information and belief, a true and correct copy of photographs showing an infringing bookshelf manufactured by NEATFREAK and sold by TARGET are attached hereto as Exhibit C. 14. SEVILLE CLASSICS is entitled to recover from the Defendants the damages sustained by SEVILLE CLASSICS as a result of the Defendants wrongful acts in an amount subject to proof at trial. 15. On information and belief, Defendants infringement of the 987 Patent continued after SEVILLE CLASSICS notified Defendants of the infringement and has been and is willful, wanton and deliberate, without license and with full knowledge of SEVILLE CLASSICSs rights in the 987 Patent. 16. By the infringing activities, Defendants have damaged SEVILLE CLASSICS. Unless this Court enjoins Defendants acts of infringement, SEVILLE CLASSICS will continue to suffer irreparable injury.

COMPLAINT

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SECOND CLAIM FOR RELIEF (Infringement of U.S. Pat. No. D626,356 -- Against All Defendants) 17. 18. SEVILLE CLASSICS realleges and incorporates the allegations in Defendants have infringed and continue to infringe the claim of the paragraphs 1 through 11 as if set forth fully herein. 356 Patent by making, using, importing, providing, offering to sell, and selling (directly or through intermediaries) infringing products, in this District and elsewhere in the United States. Upon information and belief, Defendants have also contributed to the infringement of one or more claims of the patent-in-suit and/or actively induced others to infringe one or more claims of the patents-in-suit in this District and elsewhere in the United States. On information and belief, a true and correct copy of photographs showing an infringing bookshelf manufactured by NEATFREAK and sold by TARGET are attached hereto as Exhibit C. 19. SEVILLE CLASSICS is entitled to recover from the Defendants the damages sustained by SEVILLE CLASSICS as a result of the Defendants wrongful acts in an amount subject to proof at trial. 20. On information and belief, Defendants infringement of the 356 Patent continued after SEVILLE CLASSICS notified Defendants of the infringement and has been and is willful, wanton and deliberate, without license and with full knowledge of SEVILLE CLASSICSs rights in the 356 Patent. 21. By the infringing activities, Defendants have damaged SEVILLE CLASSICS. Unless this Court enjoins Defendants acts of infringement, SEVILLE CLASSICS will continue to suffer irreparable injury. PRAYER FOR RELIEF WHEREFORE, SEVILLE CLASSICS prays for judgment against NEATFREAK and TARGET as follows: 1. That Defendants have infringed and continue to infringe the 987 Patent and the 356 Patent;
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