Kryptek v. Salt Armour - Complaint

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 1 of 47 PageID #: 1
UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS
BEAUMONT DIVISION
KRYPTEK OUTDOOR GROUP, LLC,
Plaintiff,
v.
SALT ARMOUR, INC.,
ALPHA DEFENSE, INC., and
THOMAS J. DE SERNIA, an individual,
Defendants.
CIVIL ACTION NO. 1:15-cv-348
PLAINTIFFS ORIGINAL COMPLAINT

COMES NOW Plaintiff Kryptek Outdoor Group, LLC (Kryptek) by and through the
undersigned counsel, and files this Complaint against Defendants Salt Armour, Inc., Alpha
Defense, Inc., and Thomas J. De Sernia (Defendants) and alleges the following:
I.
1.
NATURE OF THE ACTION
Plaintiff brings this action seeking to put an immediate stop to, and to obtain
redress for, Defendants willful infringement of Plaintiffs patents, copyrights, trademark, and
trade dress as well as Defendants unlawful unfair competition and unjust enrichment under the
United States Trademark (Lanham) Act 15 U.S.C. 1051, et seq, under the common law, and
under the laws of this State.
2.
Plaintiff Kryptek is a highly successful veteran-owned company in the business of
designing, creating and selling customized and performance based apparel that is specifically
tailored to the environment and that incorporates proven tactical gear concepts. Krypteks
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apparel consistently delivers the performance expectations, comfort, function and durability
required by customers in the hunting and outdoor adventure markets.
3.
Kryptek has developed camouflage patterns that are the leader in the industry.
These patented designs have even been tested by the Department of Defense using laser-retinaltracking to prove the effectiveness and superiority of Krypteks designs.
4.
Kryptek markets its goods and services to customers throughout the United States
by way of extensive media advertising, including on radio, television, Facebook, Twitter, e-mail
promotions,
and
on
Krypteks
websites,
including
www.kryptek.com
and
www.kryptekstore.com.
5.
Kryptek has invested significantly in its business as well as its branding, including
use of its five separate trademarks for KRYPTEK. Kryptek has further obtained patent
protection and copyright registrations for its one-of-a-kind camouflage patterns. As a result of its
extensive advertising, provision of goods and services, sound business practices, and operations,
Kryptek has developed enforceable statutory and/or common law trademark, trade name, and
trade dress rights in the marks and has established strong relationships with customers who have
come to recognize and respect the goods and services identified by Kryptek and identified by
Krypteks trademarks, patents, copyrights, and trade dress. Accordingly, Kryptek has developed
substantial goodwill and a reputation for integrity in its market, both of which are inextricably
intertwined with Krypteks trademarks, patents, copyrights, and trade dress.
6.
Krypteks trademarks (Kryptek Marks) and trade dress (Kryptek Trade
Dress) are distinctive and well known as used in connection with the goods and services offered
by Kryptek, resulting in recognition that the goods and services offered under the marks and
trade dress emanate under a single source namely Kryptek. There is a likelihood of confusion
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with respect to the above-mentioned customers unless Defendants are enjoined against further
unlawful conduct.
7.
The goodwill embodied in the Kryptek Marks and Kryptek Trade Dress, and
consequently Krypteks valuable reputation and credibility in the industry, depends on the
integrity of its goods and services as being identified exclusively with Kryptek and not any
other source.
8.
This lawsuit is brought to stop Defendants infringement of valuable intellectual
property rights, including Krypteks trademarks, patents, copyrights, and trade dress relating to
Krypteks business, from passing off Defendants operations as those of Kryptek, including
engaging in activities likely to cause confusion, or to cause mistake, or to deceive as to the
affiliation, connection, or association of such person with another person, or as to the origin,
sponsorship, or approval of his or her goods, services, or commercial activities by another
person.
9.
Recognizing Krypteks popularity, superiority and quality, Defendants have
brazenly created, offered for sale, and sold counterfeit copies of Krypteks camouflage patterns
and products incorporating Krypteks camouflage patterns in an attempt to capitalize on
Krypteks hard-earned success through the following websites: www.saltarmour.com;
www.sateam.company;
www.defensearmour.com;
www.spgapparel.com;
and
www.safishing.com. Defendants products are nearly an exact copy of Krypteks patented and
copyrighted designs, as well as nearly an exact copy of Krypteks goods and services.
10.
Defendants have further brazenly copied the Kryptek Marks, and co-opted its
good name by displaying products under the moniker KRYTEK KRONOS on the website
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www.spgapparel.com. Such activity falsely represents to the relevant public that there is an
association with Plaintiff Kryptek.
11.
Defendants products and services are identical-or confusingly similar to the
Kryptek Marks and Kryptek Trade Dress. Defendants actions are an apparent intentional effort
to imitate and/or cause confusion with respect to Krypteks successful business.
12.
On information and belief, Plaintiff and Defendants have a direct overlap in
customers insofar as they both draw from, and thus compete for, the same pool of customers
(e.g., customers who purchase hunting and outdoor apparel and other items).
13.
Defendants infringement of Krypteks intellectual property rights harms Kryptek,
Krypteks customers, and potential customers of Kryptek who may be confused and deceived by
Defendants business and/or Defendants unauthorized reproduction and/or imitation of
Krypteks trademarks and patented and copyrighted camouflage designs.
14.
Defendants unauthorized use of the Kryptek Marks, Kryptek Patents, Kryptek
Copyrights, and Kryptek Trade Dress unjustly enriches Defendants at Plaintiffs expense.
Defendants have been and continue to be unjustly enriched, obtaining a benefit from Plaintiff by
taking undue advantage of Plaintiff and its extensive goodwill. Specifically, Defendants have
taken unfair advantage of Plaintiff by trading on and profiting from the goodwill in the marks
developed and owned by Plaintiff, resulting in Defendants wrongfully obtaining a monetary and
reputational benefit for their own business and services.
15.
Defendants unauthorized use of Krypteks Intellectual Property removes from
Plaintiff the ability to control the nature and quality of services provided under Krypteks
Intellectual Property and places the valuable reputation and goodwill of Plaintiff in the hands of
Defendants, over whom Plaintiff has no control.
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16.
Defendants conduct has caused, and is causing, unless immediately enjoined,
enormous and irreparable harm to Kryptek. Plaintiff respectfully seeks intervention of this Court
to stop Defendants from continuing their present activities and for monetary damages. Kryptek
will be promptly seeking injunctive relief.
II.
17.
THE PARTIES
Plaintiff Kryptek Outdoor Group, LLC (Kryptek or Plaintiff) is a Limited
Liability Company organized in Delaware and having a principal place of business at 291 E.
Shore Dr., Suite 150, Eagle, Idaho, 83616.
18.
On information and belief, Defendant Salt Armour, Inc. (Salt Armour) is a
Florida corporation with its principal place of business at 21526 Sweetwater LN S, Boca Raton,
Florida, 33428. Salt Armour can be served with process at its registered agent, Kevin P.
Kassebaum, 7015 Beracasa Way, Suite 105, Boca Raton, Florida, 33433.
19.
On information and belief, Defendant Salt Armour operates the following
websites located at www.saltarmour.com; www.sateam.company; www.defensearmour.com;

www.safishing.com; www.spgapparel.com; and www.sellmyoutdoorstuff.com.
20.
On information and belief, Defendant Salt Armour owns, operates, and/or has a
controlling interest in www.sateam.company; and http://safishing.com; as well as the products

sold on these websites, labeled SA Co. and SA Co. by Salt Armour, in addition to the fact
that Salt Armour is the registrant of www.sateam.company. On information and belief,
Defendant
Salt
Armour
owns,
operates,
and/or
has
controlling
interest
in
http://sellmyoutdoorstuff.com because the site proclaims that it is Powered By SA Co.

21.
On information and belief, Defendant Salt Armour owns, operates, and/or has a
controlling interest in Defendant Alpha Defense, Inc. (Alpha Defense) because Salt Armour is
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the registrant of the website that promotes and sells the products of Alpha Defense, Inc.,
www.defensearmour.com, under the moniker Defense Armour. (See Exhibit A). Further, the
companies share the same director, Thomas J. De Sernia. (See Exhibit B).
22.
On information and belief, Defendant Salt Armour owns, operates and/or has a
controlling interest in www.spgapparel.com and the products sold on the website, labeled
Swamp Slayer because Salt Armour is the registrant of www.spgapparel.com, a website that
promotes and sells products similar to those sold by Salt Armour and Alpha Defense. (See
Exhibit C)
23.
On information and belief, Defendant Alpha Defense is a Florida corporation with
its principal place of business at 21526 Sweetwater LN S, Boca Raton, Florida, 33428. Alpha
Defense can be served with process at its registered agent, Kevin P. Kassebaum, 7015 Beracasa
Way, Suite 105, Boca Raton, Florida, 33433.
24.
On information and belief, Defendant Thomas J. De Sernia is the incorporator,
President, and majority shareholder of both Salt Armour and Defense Armour. Defendant
Thomas J. De Sernia can be served personally at his place of business, located at 21526
Sweetwater LN S, Boca Raton, Florida, 33428.
25.
On information and belief, Defendants Salt Armour, Alpha Defense, and Thomas
J. De Sernia (Defendants) have committed the acts alleged herein within this judicial district.
III.
26.
THE PATENTS
On April 2, 2013, United States Design Patent No. D679,099, titled Sheet
Material With Camouflage Pattern (the 099 Patent) was duly and legally issued by the
United States Patent and Trademark Office (USPTO). A true and correct copy of the 099
Patent is attached as Exhibit D.
Page 6
27.
On July 16, 2013, United States Design Patent No. D685,999, titled Sheet
Patent is attached as Exhibit E.
28.
On July 16, 2013, United States Design Patent No. D686,000, titled Sheet
Patent is attached as Exhibit F.
29.
Kryptek is the owner by assignment of the 099 Patent, the 999 Patent, and the
000 Patent (the Kryptek Patents). Kryptek has all substantial rights in and to the Kryptek
Patents, including the right to sue and collect damages for past, present and future infringement
of the Kryptek Patents. Kryptek has owned the Kryptek Patents throughout the period of
Defendants infringing acts and is the current owner of the Kryptek Patents.
IV.
30.
THE TRADEMARKS
Plaintiff re-alleges and incorporates by reference the foregoing allegations as
though fully set forth herein.

31.
Plaintiff has registered KRYPTEK as U.S. Trademark Registration No.
4,342,885 on the Principal Register of the United States Patent and Trademark Office, a true and
correct copy of the Certificate of Registration is attached in Exhibit G.
32.
Page 7
33.
34.
Plaintiff has registered KRYPTEK HIGHLANDER as U.S. Trademark
Registration No. 4,478,518 on the Principal Register of the United States Patent and Trademark
Office, a true and correct copy of the Certificate of Registration is attached in Exhibit G.
35.
IV.
36.
THE COPYRIGHTS

37.
Kryptek is the copyright owner and legal claimant in and to various camouflage
patterns as seen below:
38.
Kryptek is the owner of the following Copyright Registrations, duly and legally
issued by the United States Copyright Office (the Kryptek Copyrights). Copies of these
registrations are attached as Exhibit H.
Page 8
Registration No.
Title
Date Issued
VA0001783604
Highlander Camouflage
July 25, 2011
VA0001783605
Mandrake Camouflage
July 25, 2011
VA0001783606
Kryptek Camouflage Patterns
July 25, 2011
VA0001783608
Nomad Camouflage
July 25, 2011
VA0001829638
Kryptek Typhon Camouflage
June 26, 2012
VA0001829646
Kryptek Raid Camouflage
June 26, 2012
VA0001833727
Kryptek Yeti Camouflage
September 25, 2012
VA0001931269
Kryptek Neptune Camouflage
October 14, 2014
VA0001931271
Kryptek Altitude Camouflage
October 14, 2014
VA0001931338
Kryptek Banshee Camouflage
October 14, 2014
VA0001950891
Kryptek Inferno Camouflage
February 20, 2015
VA0001951037
Kryptek Universal Camouflage
February 20, 2015
V.
39.
JURISDICTION AND VENUE

40.
The Court has subject matter jurisdiction over this case because the action arises
under the patent laws of the United States, Title 35 United States Code, 101 et seq. This Court
also has subject matter jurisdiction under 17 U.S.C. 501, 15 U.S.C. 1125, and under 28
U.S.C. 1331, and 1338, and has supplemental jurisdiction over the state law claims under 28
U.S.C. 1367(a).
41.
This Court has specific personal jurisdiction over Defendants because they have
purposefully availed themselves of the privilege of conducting business in Texas. By doing

business in Texas, Defendants have consented to the jurisdiction of Texas and are therefore
subject to jurisdiction in this state as set forth under Texas Civil Practices and Remedies Code
17.042. Defendants offer, market, and promote their goods and services which infringe the
Page 9
patents and copyrights that are the subject of this lawsuit through their websites and other means
to consumers located in Texas and use their infringing goods and services to promote and
advertise their goods and services in Texas and elsewhere.
42.
This Court has specific personal jurisdiction over Defendants because they have
sold infringing goods to customers in this district and have shipped infringing goods to
customers in this district. Krypteks causes of action arise directly from Defendants business
contacts and other activities in this state and in this district.
43.
On information and belief, Defendant has willfully and voluntarily committed the
acts complained of herein in at least this State.

44.
On information and belief, venue is proper under 28 U.S.C. 1391 and 1400(b).
VI.
FACTUAL ALLEGATIONS
A. KRYPTEKS INTELLECTUAL PROPERTY

45.

46.
Since at least as early as 2011 and continuing into the present, Kryptek has been
marketing and selling goods and services that incorporate Krypteks patented and copyrighted
camouflage designs, as well as that embody Krypteks trade dress. Krypteks use of its
intellectual property has been continuous and continues today.
Krypteks Patents
47.
Kryptek is the sole assignee of the Kryptek Patents. Examples of the designs
covered under the Kryptek Patents are reproduced below.
Page 10
-the 099 Patent
-the 000 Patent
-the 999 Patent
Page 11
Krypteks Trademarks
48.
Krypteks trademarks (the Kryptek Marks) protect not only the term
KRYPTEK but various design/word trademarks that also contain the term KRYPTEK. The
chart below identifies each of Krypteks registered trademarks.
Trademark/
Goods and Services
Reg. No.
Owner
Register
Kryptek
Outdoor
Group, LLC
Principal
Kryptek
Outdoor
KRYPTEK
Group, LLC
International Class 016 - Printed or painted camouflage patterns for hard surfaces.
Principal
4342885
Date
Registered
5/28/2013
International Class 042 - Custom design of camouflage patterns for others.

4463207
1/7/2014
International Class 018 - Bags, namely, backpacks, duffel bags, waist bags, slings, luggage and
satchels, including camouflage, military, tactical, hunting and outdoor-recreation styles and
combinations thereof.
International Class 024 - Textiles, namely, cotton, wool yarn, silk, hemp yarn, and synthetic fabrics
in solid colors or in patterns, including camouflage patterns.
4411623
10/1/2013
Kryptek
Outdoor
Group, LLC
Principal
International Class 016 - Printed and painted paper materials, namely, paper patterns featuring
camouflage patterns.
International Class 018 - Bags, namely, backpacks, leather and/or textile ammo pouches, duffel bags,
waist bags, sling bags, luggage and satchels, all featuring camouflage, military, tactical, hunting and
outdoor-recreation styles.
International Class 024 - Textiles, namely, cotton, wool, silk, hemp and synthetic fabrics in solid
colors, patterns, and camouflage patterns.
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International Class 042 - Custom design of camouflage patterns for others.

4478518
2/4/2014
Kryptek
Principal
Outdoor
KRYPTEK HIGHLANDER
Group, LLC
International Class 025 - Clothing, namely, shirts, pants, coats, jackets, caps, hats, foul weather gear,
rainwear, gloves, shorts, sweaters, fleece tops, fleece bottoms, hooded pullovers, sweatshirts, tee
shirts, vests, belts, blouses, headwear, balaclavas, face masks, namely, knit face masks and ski
masks, coveralls, overalls, jeans, footwear, socks, undergarments, insulating layers and shells,
namely, thermal underwear, including camouflage, military, tactical, hunting, outdoor-recreation,
thermal, and moisture-wicking styles and combinations thereof.
4683587
2/10/2015
KRYPTEK
Kryptek
Outdoor
Group, LLC
Principal
International Class 025 - Clothing, namely, shirts, pants, coats, jackets, caps, hats, foul weather gear,
rainwear, gloves, shorts, sweaters, fleece tops, fleece bottoms, hooded pullovers, sweatshirts, tee
shirts, vests, belts, blouses, headwear, balaclavas, face masks, namely, knit face masks and ski
masks, coveralls, overalls, jeans, footwear, socks, undergarments, insulating layers and shells,
namely, thermal underwear, including camouflage, military, tactical, hunting, outdoor-recreation,
thermal, and moisture-wicking styles and combinations thereof.
Krypteks Copyrights
49.
Krypteks copyrighted designs protect various color variations of Krypteks
camouflage designs. The chart below provides further detail of the Kryptek Copyrights.
Registration
No. & Title
Example Design
VA0001783604
Highlander
Camouflage
VA0001783605
Mandrake
Camouflage
Page 13
VA0001783608
Nomad
Camouflage
VA0001829638
Kryptek Typhon
Camouflage
VA0001829646
Kryptek Raid
Camouflage
VA0001833727
Kryptek Yeti
Camouflage
VA0001931269
Kryptek
Neptune
Camouflage
Page 14
VA0001931271
Kryptek
Altitude
Camouflage
VA0001931338
Kryptek
Banshee
Camouflage
VA0001950891
Kryptek Inferno
Camouflage
50.
Under Section 106 of the Copyright Act of 1976, 17 U.S.C. 101 et seq. (the
Copyright Act), Kryptek has the distinct, severable, and exclusive rights to, among other
things, reproduce and distribute their copyrighted works and to prepare derivative works.
Page 15
Defendants have not received any authorization, permission, or consent to use or create
derivative works of the copyrighted works at issue in this lawsuit.
Krypteks Trade Dress
51.
Since at least 2011, Plaintiff has continually used the Kryptek Trade Dress
throughout the United States in commerce. As a result, the Kryptek Trade Dress has acquired
inherent distinctiveness. The Kryptek Trade Dress serves to identify and indicate the source of
Krypteks goods and services to those in the relevant market. The Kryptek Trade Dress is
embodied in the products that it sells using its patented and copyrighted designs.
examples are provided below.
Page 16
A few
52.
Kryptek has extensively advertised and promoted its goods and services and has
developed substantial recognition in the marketplace for its goods and services bearing the
Page 17
Kryptek Trade Dress. Krypteks advertising has included radio, television, Facebook, Twitter,
brochures, correspondence, e-mail, the Internet, and in other manners customary to the trade.
Kryptek also regularly interacts and conducts business with its clients via the telephone,
facsimile, mail and/or e-mail using the Kryptek Trade Dress.
53.
As a result of Krypteks use and promotion, the Kryptek Trade Dress has become
distinctive to designate Kryptek, to distinguish Kryptek and its goods and services from those of
others, and to distinguish the source or origin of Krypteks goods and services. As a result of
these efforts by Kryptek, consumers in the relevant market throughout the United States widely
recognize and associate the trade dress with Kryptek.
54.
As a result of Plaintiffs long use and promotion of the Kryptek Trade Dress in
the United States, Plaintiff has acquired valuable common law rights in the Kryptek Trade Dress.
55.
Through its consistent and continuous use, advertising, and third-party media
attention, Kryptek has developed enforceable statutory and/or common law trade dress rights in
the Kryptek Trade Dress. Kryptek has established fame and substantial goodwill with its
customers via the Kryptek Trade Dress and has developed an excellent reputation throughout the
United States. In addition, Plaintiff has invested significantly in advertising the Kryptek Trade
Dress, in association with its business.
B. DEFENDANTS INFRINGING ACTIVITIES
56.
Upon information and belief, Defendants were and are knowledgeable about
Krypteks intellectual property rights, including the Kryptek Marks, Patents, Copyrights and the
Kryptek Trade Dress. Consequently, Defendants are intentionally infringing Plaintiffs
intellectual property rights in order to steal and/or capitalize upon Krypteks intellectual property
and goodwill.
Page 18
57.
On August 20, 2015, Kryptek sent Defendants a letter that provided notice to
Defendants of the Kryptek Patents, the Copyrighted designs and the Kryptek Trade Dress and
identified the infringing products. (See Exhibit I). Kryptek requested that Defendants
immediately cease all infringing activity but to date, Defendants continue to infringe.
58.
Upon information and belief, by at least August 20, 2015 Defendants have had
actual notice of the Kryptek Patents, the Copyrighted designs and the Kryptek Trade Dress, and
that their actions constitute willful and intentional infringement of the intellectual property
59.
Despite the knowledge that its products and services infringe Krypteks
intellectual property, Defendants refused to cease their infringing activity and continue such
activity to this day.
60.
Defendants have infringed, and continue to directly infringe, at least claim 1 in
each of the Kryptek Patents by making, using, selling, offering for sale, and/or importing one or
more of the infringing products identified in Exhibit J (Defendants Infringing Products). An
ordinary observer, familiar with the prior art, would be deceived into believing that the infringing
designs utilized by Defendants are the same as Krypteks patented designs.
61.
Defendants have further induced and contributed to infringement of the Kryptek
Patents. Defendants intentionally and actively induce infringement the Kryptek Patents by the
public, by Defendants manufacturers, Defendants distributors, Defendants retailers,
Defendants partners and by Defendants website users, customers, and/or end users who import,
make, use, sell, and/or offer to sell at least one or more of Defendants Infringing Products.
62.
At least as early as August 20, 2015, Defendants have had actual knowledge of
the Kryptek Patents as a matter of law.
Page 19
63.
At least as early as August 20, 2015, Defendants have been willfully blind toward
the existence of the Kryptek Patents.

64.
Upon information and belief, since becoming aware of the Kryptek Patents,
Defendants have continued to intentionally, knowingly, and actively advertise, sell, and offer to
sell
Defendants
Infringing
Products
at
least
through
Defendants
websites,
www.saltarmour.com; www.sateam.company; www.defensearmour.com; www.safishing.com;

and www.spgapparel.com.
65.
Upon information and belief, since becoming aware of the Kryptek Patents,
Defendants have continued to intentionally, knowingly, and actively cause and/or influence the
public, Defendants manufacturers, Defendants distributors, Defendants retailers, Defendants
partners, and Defendants website users, customers, and/or end users to import, make, use, sell,
and/or offer to sell at least one or more of Defendants Infringing Products, and/or practice the
inventions claimed in the Kryptek Patents.
66.
Defendants have directly infringed the Kryptek Marks through their use of
Krypteks marks on the website www.spgapparel.com to sell infringing products. (See Exhibit
K). Defendants intentionally label their infringing products as Kryptek Kronos, a deliberate
attempt to associate their infringing goods with Plaintiffs established marks and goodwill. The
services offered under Defendants moniker Kryptek Kronos are identical to or closely related
to the services offered under the Kryptek Marks.
67.
The Kryptek Marks were first used in interstate commerce in the United States
before Defendants Kryptek Kronos was first used anywhere.

68.
Given that the parties operate in the same industry and targeting the same market,
Defendants unauthorized use of the Kryptek Marks is likely to cause confusion, to cause mistake,
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and/or to deceive customers and potential customers of the parties, as least as to some affiliation,
connection, or association of Defendants with Plaintiff, or as to the origin, sponsorship, or
approval of Defendants infringing products by Plaintiff.
69.
Defendants unauthorized use of the marks falsely designates the origin of its goods
and services, and falsely and misleadingly describes and represents facts with respect to its goods and
services.
70.
Defendants unauthorized use of the Kryptek Marks enables Defendants to trade on
and receive the benefit of goodwill built up at great labor and expense by Plaintiff, and to gain
acceptance for its goods and services not solely on its own merits, but on the reputation and goodwill
of Plaintiff, its Marks, and its services.
71.
Defendants unauthorized use of the moniker Kryptek Kronos is likely to cause
dilution of the Kryptek Marks under 15 U.S.C. 1125(c) and in violation of Texas Business and
Commercial Code 16.103.
72.
Defendants have further directly infringed, and continue to directly infringe
Krypteks copyrighted designs by, without permission or authorization, making and selling exact
copies of Krypteks copyrighted designs, as well as by making and selling derivative works
based on Krypteks copyrighted designs without permission or authorization on the websites
www.saltarmour.com; www.sateam.company; www.defensearmour.com; www.safishing.com;
www.spgapparel.com and www.sellmystuff.com.
73.
Defendants have further induced and contributed to infringement of Krypteks
copyrighted designs, by intentionally inducing and/or causing Defendants manufacturers,

distributers, retailers, partners, Defendants website users, customers and/or end users to create
unauthorized reproductions and/or derivative works of Krypteks copyrighted designs.
Page 21
74.
Defendant Thomas J. De Sernia, as an officer of both Defendants Salt Armour
and Alpha Defense, has the right and ability to supervise and control the infringing conduct of
Defendants Salt Armour and Alpha Defense. De Sernia has refused to exercise such supervision
and control to prevent the infringing activities of Defendants Salt Armour and Alpha Defense.
Further, De Sernia derives a direct financial benefit from the infringing activity as an officer of
both companies, including obtaining a financial benefit that directly flows from the sale of
infringing goods and services by Defendants Salt Armour and Alpha Defense.
75.
Defendants Infringing Products further infringe the Kryptek Trade Dress because
Defendants Infringing Products are confusingly similar to Krypteks goods and services sold
with the Kryptek Trade Dress. Defendants use of the Kryptek Trade Dress in connection with
the infringing products is likely to cause confusion, mistake, or to deceive as to the affiliation,
connection, or association of Defendants with Kryptek.
76.
Defendants unauthorized use of the Kryptek Trade Dress falsely designates the
origin of its goods and services, and falsely and misleadingly describes and represents facts with
respect to its goods and services.
77.
Defendants unauthorized use of the Kryptek Trade Dress, as well the Kryptek
Patents and Copyrighted designs, enables Defendants to trade on and receive the benefit of
goodwill built up at great labor and expense by Kryptek, and to gain acceptance for its goods and
services not solely on its own merits, but on the reputation and goodwill of Kryptek, the Kryptek
Trade Dress, and its goods and services.
78.
Defendants unauthorized use of the Kryptek Trade Dress is likely to cause
dilution of the Kryptek Trade Dress under 15 U.S.C. 1125(c) and in violation of Texas
Business and Commerce Code 16.103.
Page 22
79.
Patents and Copyrighted designs, unjustly enriches Defendants at Krypteks expense. Defendants
have been and continue to be unjustly enriched, obtaining a benefit from Kryptek by taking
unfair advantage of Plaintiff and its extensive goodwill. Specifically, Defendants have taken
unfair advantage of Kryptek by trading on and profiting from the goodwill in Krypteks
intellectual property developed and owned by Kryptek, resulting in Defendants wrongfully
obtaining a monetary and reputational benefit for its own business as well as goods and services.
80.
Patents and Copyrighted designs, removes from Kryptek the ability to control the nature and
quality of goods and services provided under its intellectual property, and places the valuable
reputation and goodwill of Kryptek in the hands of Defendants, over whom Kryptek has no
control.
81.
Unless Defendants acts are restrained by this Court, they will continue, and they
will continue to cause irreparable injury to Kryptek and to the relevant public for which there is
no adequate remedy at law.
VII.
CAUSES OF ACTION
Count 1: Direct Patent Infringement of U.S. Patent D679,099 Under 35 U.S.C. 271(a)
82.
Plaintiff repeats the allegations above as if fully set forth herein.
83.
This is a claim for direct patent infringement under 35 U.S.C. 271(a).
84.
Defendants, directly and through their agents, employees and servants, have and
continue to knowingly, intentionally, and willfully directly infringe U.S. Patent No. D679,099
(the 099 Patent) by making, using, selling, offering for sale, and/or importing products,
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including Defendants Infringing Products, which have camouflage designs that are covered by
the claim of the 099 Patent.
85.
Defendants acts of infringement of the 099 Patent were undertaken without
permission or license from Kryptek. Upon information and belief, Defendants have actual
knowledge of the 099 Patent, including knowledge that its actions constitute willful and
intentional infringement of the 099 Patent.
86.
As a direct and proximal result of Defendants patent infringement, Defendants
have derived and received gains, profits, and advantages in an amount not presently known to
Kryptek.
87.
Pursuant to 35 U.S.C. 284, Kryptek is entitled to damages for Defendants
infringing acts and treble damages together with interests and costs as fixed by this Court.
88.
Pursuant to 35 U.S.C. 289, Kryptek is entitled to Defendants total profits from
the sale of Defendants goods that infringe the 099 Patent.

89.
Pursuant to 35 U.S.C. 285, Kryptek is entitled to reasonable attorneys fees for
the necessity of bringing this claim.

90.
Due to the aforesaid infringing acts, Kryptek has suffered great and irreparable
injury, for which Kryptek has no adequate remedy at law.

91.
Defendants will continue to directly infringe the 099 Patent to the great and
irreparable injury of Kryptek, unless enjoined by this Court.

Count 2: Inducement of Infringement of U.S. Patent D679,099 Under 35 U.S.C. 271(b)
92.
93.
This is a claim for inducing patent infringement under 35 U.S.C. 271(b).
Page 24
94.
continue to knowingly, intentionally, and willfully induced others to infringe the 099 Patent.
Defendants induced Defendants manufacturers to infringe the 099 Patent by causing to be
made or manufactured products, including Defendants Infringing Products, which have
camouflage designs that are covered by the claim of the 099 Patent. Defendants, because of
their prior knowledge of the 099 Patent, intended to cause Defendants manufacturers to
infringe the 099 Patent by inducing the manufacture of infringing goods. Defendants further
induced Defendants distributors, retailers, partners and customers to infringe the 099 Patent by
using, selling, offering for sale, and/or importing products, including Defendants Infringing
Products, which have camouflage designs that are covered by the claim of the 099 Patent.
95.
Defendants had actual knowledge of the 099 Patent because Kryptek informed
Defendants of the 099 Patent and of Defendants infringement on August 20, 2015. Because
they knew of the 099 Patent and had been warned that their actions were infringing, by
continuing in those infringing acts to the present day, Defendants had knowledge that their
actions and the actions they induced others to perform constitute patent infringement.
96.
Upon information and belief, since becoming aware of the 099 Patent,
Defendants have been willfully blind, knew, or should have known that the acts of Defendants
manufacturers, distributors, retailers, and customers relative to the making, using, selling,
offering for sale, and/or importing goods containing camouflage design, including Defendants
Infringing Products, practice the invention claimed in the 099 Patent and directly infringe at
least claim 1 of the 099 Patent.
97.
Page 25
98.
Defendants will continue to indirectly infringe the 099 Patent to the great and

Count 3: Contributory Infringement of U.S. Patent D679,099 Under 35 U.S.C. 271(c)
99.
100.
This is a claim for contributory patent infringement under 35 U.S.C. 271(c).
101.
The camouflage designs of Defendants goods, including Defendants Infringing
Products, constitute a material part of the invention claimed in the 099 Patent. The camouflage
designs are not staple articles and are not commodities of commerce suitable for a non-infringing
use because the camouflage designs have no use other than as part of the patented design.
102.
Defendants have been willfully blind, knew, or should have known that Defendants goods
containing camouflage design, including Defendants Infringing Products, and the components
thereof were especially made and/or especially adapted for use in infringing the 099 Patent.
103.
thereof were not staple articles or commodities of commerce suitable for substantial
noninfringing use.
104.
By selling, offering to sell, and/or importing into the United States goods
thereof, Defendants have contributed to the infringement of distributors, retailers, and/or
customers who sell, offer for sale, purchase, make, and/or use Defendants goods containing
Page 26
camouflage design, including Defendants Infringing Products, to practice the invention claimed
in the 099 Patent, and thus directly infringes the 099 Patent.
105.

106.

107.
108.
109.
110.
111.
Kryptek.
112.
Page 27
113.

114.

115.

116.

117.
118.
119.
120.
Page 28
121.
122.

123.

124.
125.
126.
127.
Page 29
128.
noninfringing use.
129.
130.

131.

132.
133.
134.
Page 30
135.
136.
Kryptek.
137.
138.

139.

140.

141.

142.
143.
Page 31
144.
145.
146.
147.
Page 32
148.

149.
150.
151.
152.
153.
noninfringing use.
154.
Page 33
155.

156.

Count 10: Federal Trademark Infringement under 15 U.S.C. 1114(1).
157.
158.
The acts of Defendants complained of herein constitute infringement of Plaintiffs
federally registered trademarks, Nos. 4342885, 4463207, 4411623, 4478518, and 4683587 in
violation of 15 U.S.C. 1114(1).
159.
Defendants acts complained of herein have been deliberate, willful, intentional,
and in bad faith, with full knowledge and conscious disregard of Plaintiffs rights in the Kryptek
Marks, and with intent to cause confusion and to trade on Plaintiffs extensive goodwill in the
Kryptek Marks. In view of the egregious nature of Defendants infringement, this is an
exceptional case within the meaning of 15 U.S.C. 1117(a).
Count 11: Common Law Trademark Infringement
160.
161.
The acts of Defendants complained of herein constitute trademark infringement in
violation of the common law of this State.

Count 12: Direct Copyright Infringement Under 17 U.S.C. 501
162.
Page 34
163.
Defendants have directly infringed the Kryptek Copyrights by reproducing the
Krypteks copyrighted works, by preparing derivative works based on Krypteks copyrighted

works, and by distributing the copies and/or derivative works to the public by sale without
authorization in violation of 17 U.S.C. 106 et seq and 501.
164.
Each infringement of the Kryptek Copyrights by Defendants constitutes a separate
and distinct act of infringement.

165.
Defendants acts of infringement were willful, and in disregard to Krypteks
166.
As a direct and proximate result of Defendants infringements, Kryptek is entitled
rights.
to damages and Defendants profits.

167.
Alternatively, Kryptek is entitled to the maximum statutory damages in the
amount of $150,000 with respect to each work infringed, or for such other amounts as may be
proper un 17 U.S.C. 504.
168.
Kryptek is further entitled to recover its attorneys fees and costs pursuant to 17
U.S.C. 505.
169.
Defendants are each jointly and severally liable for damages resulting from the
acts of infringement, as well as for Krypteks attorneys fees and costs.

170.
As a direct and proximate result of Defendants infringements, Kryptek has
sustained and will continue to sustain substantial, immediate and irreparable injury, for which
there is no adequate remedy at law. Unless enjoined and restrained by this Court, Defendants
will continue to infringe Krypteks rights in the Kryptek Copyrights and thus Kryptek is entitled
to injunctive relief.
Count 13: Contributory Copyright Infringement Under 17 U.S.C. 501
Page 35
171.
172.
Defendants have infringed the Kryptek Copyrights by knowingly and materially
contributing to, intentionally inducing, and/or causing Defendants manufacturers, distributors,

retailers, and/or customers to infringe the Kryptek Copyrights. Defendants have materially
contributed to, intentionally induced, and/or caused unauthorized reproductions, derivative
works, distributions, and/or public display of the Kryptek Copyrights without authorization in
violation of 17 U.S.C. 106 et seq and 501. Notwithstanding such knowledge, Defendants
have failed to take any measures, including measures readily available to Defendants, to prevent
further damage to the Kryptek Copyrights.
173.

174.
Defendants acts of infringement were willful, and in disregard to Krypteks
175.
rights.

176.
177.
U.S.C. 505.
178.
Page 36
179.
Count 14: Inducing Copyright Infringement Under 17 U.S.C. 501
180.
181.
Defendants have infringed the Kryptek Copyrights by inducing Defendants
manufacturers, distributors, retailers, and/or customers to reproduce, prepare derivative works,

and/or distribute to the public copies and/or derivative works based on the Kryptek Copyrights
without authorization in violation of 17 U.S.C. 106 et seq and 501.
182.

183.

184.
185.
U.S.C. 505.
186.
Page 37
187.
Count 15: Vicarious Copyright Infringement Under 17 U.S.C. 501
188.
189.
Defendant Thomas J. De Sernia, as President and majority shareholder of both
Defendants Salt Armour and Apha Defense, has vicariously infringed the Kryptek Copyrights
because he has the right and ability to supervise and/or control the infringing conduct of
Defendants Salt Armour and Apha Defense. De Sernia has directly participated in and/or refused
to exercise his ability to supervise and control Defendants Salt Armour and Apha Defense to the
extent required by law. De Sernia was and is a moving active conscious force behind the
infringement of Defendants Salt Armour and Apha Defense. As a direct and proximate result of
such refusal, Defendants Salt Armour and Apha Defense, as well as Defendants manufacturers,
distributors, retailers, and/or customers have infringed the Kryptek Copyrights, including by
reproducing, preparing derivative works, and/or distributing to the public copies and/or
derivative works based on the Kryptek Copyrights without authorization in violation of 17
U.S.C. 106 et seq and 501.
190.
Defendant De Sernia derives a direct financial benefit and has a direct financial
interest in the infringing activity, including but not limited to obtaining financial compensation
from Defendants Salt Armour and Apha Defense, including financial compensation flowing from
the sale of infringing goods, including Defendants Infringing Products by Defendants. Upon
Page 38
information and belief, Defendant De Sernia is the majority and/or sole shareholder in both
corporations, Salt Armour and Apha Defense. Accordingly, his financial interest in Defendants
Salt Armour and Apha Defense is directly related to the infringing activity.
191.
Based on the above, Defendant De Sernia is vicariously and joint and severally
liable for an award of damages based on the infringement of himself, and/or the infringement of
Defendants Salt Armour and Apha Defense.
Count 16: Federal Trade Dress Infringement Under 15 U.S.C. 1125(a)
192.
193.
This is a claim for trade dress infringement under 15 U.S.C. 1125(a).
194.
After the use and adoption of the Kryptek Trade Dress, without authorization
Defendants have designed, developed, manufactured, imported, advertised and/or sold products,
including Defendants Infringing Products, which directly copy the Kryptek Trade Dress, and/or
use trade dress confusingly similar to the Kryptek Trade Dress. See below for an example:
Krypek Trade Dress
195.
Defendants Infringing Product
Defendants use of the Kryptek Trade Dress in connection with its goods is likely
to cause confusion, or to cause mistake, or to deceive as to the affiliation, connection, or

association of Defendants with Kryptek.
Page 39
196.
Kryptek is informed and believes, and thereon alleges, that Defendants acts of
trade dress infringement were undertaken willfully with the express intent to cause confusion,
and to mislead and deceive the purchasing public.
197.
Kryptek is informed and believes, and thereon alleges, that Defendant has derived
and received, and will continue to derive and receive, gains, profits, and advantages from
Defendants trade dress infringement in an amount that is not presently known to Kryptek. By
reason of Defendants actions, constituting trade dress infringement, Kryptek has been damaged
and is entitled to monetary relief in an amount to be determined at trial.
198.
Due to Defendants actions, constituting trade dress infringement, Kryptek has
suffered and continues to suffer great and irreparable injury, for which Kryptek has no adequate
remedy at law.
199.
In view of the egregious nature of Defendants infringement, this is an
exceptional case within the meaning of 15 U.S.C. 1117(a) and Kyptek is entitled to damages
for Defendants infringing acts, up to three times actual damages, and its attorneys fees.
Count 17: Federal Unfair Competition, Passing Off, and False Designation
Of Origin Under 15 U.S.C. 1125(a)
200.
201.
This is a claim for unfair competition, passing off, and false designation of origin
under Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a).

202.
Defendants use of the Kryptek Marks and Kryptek Trade Dress without
Krypteks consent constitutes a false designation of origin, which is which is likely to cause
confusion, or to cause mistake, or to deceive as to the affiliation, connection, or association of
Defendants with Kryptek, or as to the origin, sponsorship, or approval of Defendants goods
Page 40
and/or commercial activities by Kryptek in violation of 15 U.S.C. 1125(a) and constitutes

unfair competition with Kryptek.
203.
Defendants use of the Kryptek Marks
and Kryptek Trade Dress without
Krypteks consent constitutes a false designation of origin, which in commercial advertising or

promotion, misrepresents the nature, characteristics, qualities, or geographic origin of
Defendants goods or commercial activities in violation of 15 U.S.C. 1125(a) and constitutes
204.
Such conduct by Defendants is likely to confuse, mislead, and deceive
Defendants customers, purchasers, and members of the public as to the origin of the Kryptek
Marks and/or Kryptek Trade Dress or cause said persons to believe that Defendants and/or its
products have been sponsored, approved, authorized, or licensed by Kryptek or are in some way
affiliated or connected with Kryptek, all in violation of 15 U.S.C. 1125(a) and constitutes
205.
Kryptek is informed and believes, and thereon alleges, that Defendants actions
were undertaken willfully with full knowledge of the falsity of such designation of origin and
false descriptions or representations.
206.
Kryptek is informed and believes, and thereon alleges, that Defendants have
derived and received, and will continue to derive and receive, gains, profits, and advantages from
Defendants unfair competition and false designation of origin in an amount that is not presently
known to Kryptek. By reason of Defendants actions, constituting unfair competition and false
designation of origin, Kryptek has been damaged and is entitled to monetary relief in an amount
to be determined at trial.
Page 41
207.
Due to Defendants actions, constituting unfair competition and false designation
of origin, Kryptek has suffered and continues to suffer great and irreparable injury, for which
Kryptek has no adequate remedy at law.
208.
Pursuant to 15 U.S.C. 1117, Kryptek is entitled to damages for Defendants acts
constituting false designation of origin and unfair competition, up to three times actual damages,
and reasonable attorneys fees.
Count 18: Common Law Trade Dress Infringement
209.
210.
The acts of Defendants complained of herein constitute trade dress infringement
in violation of the common law of this State.

211.
As a direct and proximate result of Defendants conduct, Kryptek has suffered
damages to its valuable Kryptek Trade Dress, and other damages in an amount to be proved at
trial.
Count 19: Common Law Unfair Competition
212.
213.
The acts of Defendants complained of herein constitute unfair competition in
violation of the common law of this State.

Count 20: Federal Trademark Dilution
214.
215.
The acts of Defendants complained of herein constitute dilution of the Kryptek
Marks and Kryptek Trade Dress in violation of 15 U.S.C. 1125(c).
Page 42
216.
Defendants willfully intended to trade on the recognition of the Kryptek Marks
and/or the Kryptek Trade Dress and/or to harm the reputation of the Kryptek Marks and Kryptek
Trade Dress.
217.
damages to its valuable Kryptek Marks and Kryptek Trade Dress, and other damages in an
amount to be proved at trial.
Count 21: Texas Trademark Law
218.
219.
The acts of Defendants complained of herein are in violation of Texas Business
and Commerce Code 16.103.

220.
damages to its valuable Kryptek Marks and Kryptek Trade Dress, and other damages permitted
by Texas Business and Commerce Code 16.104, in an amount to be proved at trial.
Count 22: Unjust Enrichment
221.
222.
The acts of Defendants complained of herein constitute unjust enrichment of
Defendants at the expense of Kryptek.

223.
Defendants acts complained of herein have caused and continue to cause damage
to Kryptek.
VIII. DEMAND FOR A JURY TRIAL
224.
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Kryptek
respectfully requests a trial by jury of all issues properly triable by jury.

IX.
PRAYER FOR RELIEF
Page 43
225.
WHEREFORE, Plaintiff requests entry of judgment in its favor and against
Defendants including the following:

a. A judgment declaring that Defendants infringe the 099 Patent;
b. A judgment declaring that Defendants infringe the 999 Patent;
c. A judgment declaring that Defendants infringe the 000 Patent;
d. Enter a preliminary and permanent injunction to enjoin Defendants and their
officers, agents, attorneys and employees, and those acting in privity or concert
with them, from infringing the 099 Patent for the full term thereof;
e. Enter a preliminary and permanent injunction to enjoin Defendants and their
f. Enter a preliminary and permanent injunction to enjoin Defendants and their
g. Award Plaintiff damages against Defendants adequate to compensate Plaintiff for
the infringement of the 099 Patent pursuant to 35 U.S.C. 284 and/or 35 U.S.C.
289;
h. Award Plaintiff damages against Defendants adequate to compensate Plaintiff for
289;
i. Award Plaintiff damages against Defendants adequate to compensate Plaintiff for
289;
Page 44
j. Find that the Defendants infringement is deliberate and willful, and that the
damages awarded to Plaintiff be trebled pursuant to 35 U.S.C. 284;
k. A declaration that this is an exceptional case and an award of attorneys fees,
disbursements, and costs of this action pursuant to 35 U.S.C. 285;
l. A judgement declaring that Defendants have infringed Plaintiffs trademarks
under state and federal law;
m. A judgement awarding Plaintiff damages as a result of Defendants trademark
infringement with interests and costs;
n. A judgment declaring that Defendants infringement of the marks has been willful
and deliberate;
o. A judgment holding Defendants joint and severally liable;
p. A grant of permanent injunction enjoining the Defendants from further acts of
trademark infringement and unfair competition;
q. A judgement declaring that Defendants have infringed Plaintiffs copyrights;
r. A judgment declaring that Defendants infringement of Plaintiffs copyrights is
intentional and willful;
s. A judgment awarding Plaintiff damages and Defendants profits, in such amount
as may be found; alternatively, for maximum statutory damages with respect to
each copyrighted work infringed either directly or indirectly, or for such other
amounts as may be proper under 17 U.S.C. 504(c);
t. Enter a preliminary and permanent injunction pursuant to 17 U.S.C. 502 to
enjoin Defendants and their officers, agents, attorneys and employees, and those
acting in privity or concert with them, from (a) directly or indirectly reproducing,
Page 45
preparing derivative works, or distributing to the public copies and/or derivative

works based on the Kryptek Copyrights, whether now in existence or hereinafter
created; (b) causing, contributing to, inducing, facilitating, enabling, or
participating in the infringement of the Kryptek Copyrights;
u.
Issue and order pursuant to 17 U.S.C. 503 directing the United States Marshals
Service to (a) impound all copies of goods that infringe the Kryptek Copyrights in
possession of Defendants, their agents or contractors during the pendency of this
lawsuit; and (b) upon final disposition of this case, to destroy or otherwise dispose
of those copies.
v. A judgment declaring that Defendants use of the Kryptek Trade Dress constitutes
trademark infringement under 15 U.S.C. 1125, is prohibited under 15 U.S.C.
1125 and Texas Business and Commerce Code 16.103, constitutes unfair
competition under state and federal law, and also that Defendants acts constitute
willful infringement under 15 U.S.C. 1117;
w. A judgment ordering that Defendant be ordered to pay any and all damages
available under 15 U.S.C. 1117, including court costs, expenses, enhanced
damages, statutory damages to the extent permissible, and attorneys fees;
x. A grant of a permanent injunction enjoining the Defendant from further acts of
trade dress infringement and unfair competition as well as use of the Kryptek
Trade Dress;
y. A judgement for Plaintiff on all other counts asserted herein;
z. Any other accounting for damages;
aa. Any other appropriate interest and costs; and
Page 46
bb. For such other and further relief as the Court deems just and proper.
DATED this 9th day of September, 2015.
Respectfully submitted,
/s/ Stewart N. Mesher

Stewart N. Mesher
TX Bar No. 24032738
smesher@conleyrose.com
Darlene F. Ghavimi
TX Bar No. 24072114
dghavimi@conleyrose.com
CONLEY ROSE, P.C.
13413 Galleria Circle, Suite 100
Austin, TX 78738
Kristin Jordan Harkins
TX Bar No. 00787795
kharkins@dfw.conleyrose.com
CONLEY ROSE, P.C.
5601 Granite Parkway, Suite 500
Plano, TX 75024
Attorneys For Kryptek Outdoor Group, LLC
Page 47
JS 44 (Rev. 12/12)
Case 1:15-cv-00348-RC Document 1-1 Filed 09/09/15 Page 1 of 2 PageID #: 48
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
Salt Armour, Inc., Alpha Defense, Inc., and Thomas J. de Sernia
Kryptek Outdoor Group, LLC

(b) County of Residence of First Listed Plaintiff
County of Residence of First Listed Defendant
Ada County, Idaho
(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE:
Palm Beach County, FL
(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Attorneys (If Known)
(c) Attorneys (Firm Name, Address, and Telephone Number)

Stewart N. Mesher, Darlene Ghavimi, Conley Rose,P.C., 13413 Galleria
Circle, Austin, TX 78738; Kristin Jordan Harkins, Conley Rose, P.C.,
5601 Granite Pkwy, Ste. 500, Dallas, TX 75024
II. BASIS OF JURISDICTION (Place an X in One Box Only)

1
U.S. Government
Plaintiff
Federal Question
(U.S. Government Not a Party)
U.S. Government
Defendant
Diversity
(Indicate Citizenship of Parties in Item III)
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

(For Diversity Cases Only)
PTF
Citizen of This State
1
DEF
1
and One Box for Defendant)

PTF
DEF
Incorporated or Principal Place
4
4
of Business In This State
Citizen of Another State
Incorporated and Principal Place

of Business In Another State
Citizen or Subject of a
Foreign Country
Foreign Nation
IV. NATURE OF SUIT (Place an X in One Box Only)

CONTRACT
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
625 Drug Related Seizure

of Property 21 USC 881
690 Other
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609
OTHER STATUTES
375 False Claims Act

400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding
2 Removed from
State Court
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. 271(a); 17 U.S.C. 501; 15 U.S.C. 1114
VI. CAUSE OF ACTION Brief description of cause:
Patent infringement, copyright infringement, trademark infringement, and trade dress infringement
CHECK IF THIS IS A CLASS ACTION

VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE
CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:
DEMAND $
DOCKET NUMBER
SIGNATURE OF ATTORNEY OF RECORD
/s/ Darlene F. Ghavimi
09/09/2015
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
Print
APPLYING IFP
Save As...
JUDGE
MAG. JUDGE
Reset
JS 44 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a)
(b)
(c)
Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
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Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
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III.
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When this box is checked, do not check (5) above.
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statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII.
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Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
EXHIBIT A
Whois Lookup | Domain Availability - Registration Information - GoDaddy

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EXHIBIT B
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Florida Profit Corporation
DEFENSE ARMOUR, INC.
Filing Information
Document Number
FEI/EIN Number
Date Filed
State
Status
Effective Date
Last Event
Event Date Filed
Event Effective Date
P14000035594
NONE
04/21/2014
FL
INACTIVE
04/21/2014
VOLUNTARY DISSOLUTION
01/16/2015
NONE
Principal Address
21526 SWEETWATER LANE SOUTH
BOCA RATON, FL 33428
Mailing Address
Registered Agent Name & Address
KASSEBAUM, KEVIN P
7015 BERACASA WAY
105
Officer/Director Detail
Name & Address
Title PSD
DE SERNIA, THOMAS J
Title TDVP
DE SERNIA, THOMAS
Annual Reports
No Annual Reports Filed
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01/16/2015 -- VOLUNTARY DISSOLUTION
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EXHIBIT C

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Registrant Name: Thomas DeSernia
Registrant Organization: Salt Armor Inc.
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Registrant City: Boca Raton
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EXHIBIT D
The Director of the United States

Patent and Trademark Office
Has received an application for a patent for
a new, original, and ornamental design for
an article of manufacture. The title and
description of the design are enclosed. The
requirements of law have been complied
with, and it has been determined that a
patent on the design shall be granted under
the law.
Therefore, this
United States Patent

Grants to the person(s) having title to this
patent the right to exclude others from making, using, offering for sale, or selling the
design throughout the United States of
America or importing the design into the
United States of America for the term of
fourteen years from the date ofgrant of this
patent, subject to any disclaimer under 35
usc 253.
_:/~
Acting Director ofthe United States Patent and Trademark Office
111111
(12)
USOOD679099S
United States Design Patent
(10)
Johnson et al.
(45)
(54)
SHEET MATERIAL WITH CAMOUFLAGE

PATTE RN
(75)
Inventors: David J ohnson, Knoxville, T (US);

Reid Phillips, Helenwood, T (US);
Ha rry F. Whiting, Fairbanks, AK (US );
Joshua Da le Cleghorn, Enterprise, AL
(US ); Gr egory Scott Love, Knoxville,
T (US )
(73)
1111111111111111111111111111111111111111111111111111111111111
As ignee: Kryptek Outdoor Group, LLC ,

Houston , TX (US )
Term:
(21 )
Appl.
(22)
Filed:
(51 )
(52)
(58)
LOC (9) Cl. .. ... ..... ..... .......... ................. ........ 05-05
.S. Cl. ...... .................. ....... .. ............... .......... D5/62
Field of Classificati on Sear ch ........ .... ..... 05/6, II ,
05/12, 16, 17, 19, 23, 24, 48, 32, 36, 39,
05/53, 55 , 57, 59, 61 , 62, 63 , 66, 99 ; 06/588 ,
06/592, 600, 602 , 613 , 617 ; 019/6; 024/124,
024/126; 032/43 ; 2/900; 5/490, 495 ; 15/208;
I 12/40 I, 416, 439; 139/383 R, 383 B; 428/32,
428/37 , 39,66.5, 79, 153, 190, 919; 604/384,
604/385.01
See application file for complete search history.
14 Years
o.: 29/406,042
Nov. 9, 2011
U.S. PATENT OOCUME TS

S
S
S
S
S
* 12/ 1884 Horan ........................ .. ... . 05/32

311888
311929
411929
I0/1932
S
S
S
S
S
S
S
S
S
S
S
S
S
**
Apr. 2, 2013
* 3/1933 Megroz ............................ 05/32
*
*
*
*
*
511933
511933
8/1933
411940
711940
611996
311998
312003
212004
712011
3/2012
712012
Reiman ............................
Reiman ... .... ... ... ... .. ... ... ....
Willheim ......... ................
Kluesing ... .......................
Ullman .............. .. .. ... .......
Spadacini ... .... ... .... ... .......
Josephs ... .....
.... .. ..
Simmons .........................
Zupkofska et al. ... ...........
Valenteetal .
........ ... .. ..
Key .. .. ... .. .... .. ... ....... .... .. ..
Brookman .......................
05/32
05/32
05/62
05/32
05/62
05/32
05/58
05/32
05/62
05/62
05/32
05/62
Primary Examiner - Karen SAcker

(74) Auomey, Agent, or Firm - Karen Bryant Tripp
References Cited
0 I 5,6 15
018,149
077,964
078,243
088,121
089,404
089,999
090,050
090,466
011 9,920
0121,644
0370,350
0391 ,402
0471,720
0485,992
0641 ,557
0655,094
0663,959
US D679,099 S
* cited by examiner
(**)
(56)
Patent No.:
Date of Patent:
Folsom ... ... ................... ...

Kahrmann .... .... .... .. ... ... ...
Willheim ... .. ...... ..............
Vogel man .. ........ ..... .........
05/39
05/62
05/32
05/32
(57)
CLAIM
The ornamental design for a sheet material with camouflage
pattern, as shown and described.
DESCRIPTION
The file of this patent contains at least one drawing executed
in color. Copies of this patent with color drawings will be
provided by the U.S . Patent and Trademark Office upon
request and payment of the necessary fee.
RG. 1 is a top plan view of a first embodiment of a heet
material with camouflage pattern according to our new
design; and ,
RG . 2 i a top plan view of a second embodiment of a heet
material with camouflage pattern.
The broken lines urrounding the sheet material with camouflage pattern represent unclaimed boundaries. The thicknes
of the sheet material with camouflage pattern form no part of
the claimed design .
1 Claim, 2 Dra wing Sheets
(1 of 2 Drawing Sheet(s) Filed in Color )
U.S. Patent
Apr. 2, 2013
Sheet 1 of2
FIG. 1
US D679,099 S
U.S. Patent
Apr. 2, 2013
Sheet 2 of2
FIG. 2
US D679,099 S
EXHIBIT E

the law.
Therefore, this

usc 253.
~~
Acting Director ofthe United States Potent and Trademark O(!ice

111111
1111111111111111111111111111111111111111111111111111111111111
USOOD685999S
( 12)
(10)
Johnson et al.
(45)
(54)

PATTERN
(71)
Applicant: Kryptek Outdoor Group, LLC,

Houston, TX ( S)
Patent No.:
Date of Patent:
(56)
US D685,999 S
**
Jul. 16, 2013
References Cited
U.S. PATE T DOCUMENTS
(72)
Inventors: David Johnson, Knoxvi lle, T (US);

Reid Phillips, Helenwood, T (US) ;
Harry F. Whiting, Fairbanks, AK (US );
Joshua Dale Cleghorn, Enterprise, AL
( S); Gregory Scott Love, Knoxville,
T ( S)
(73)
Assignee: Kryptek Outdoor Group, LLC ,

Houston , TX (US )
(** )
Term:
(2 1)
Appl.
(22)
Filed:
01 9,054
1,561 ,324
077 ,964
078,243
0 90,466
0370,350
0391 ,402
0530,027
0 64 1,557
0 655,094
0663,959
0 670,085
0675,030
S
A
S
S
S
S
S
S
S
S
S
S
S
*
*
*
*
*
*
*
*
*
*
*
*
*
411889
1111925
311929
411929
8/ 1933
611996
311998
10/2006
7/201 1
3/2012
7/2012
11 /2012
1/201 3
Bunler ...... ...

0 2511 11
Guenot et al ................. 427/262
Kahrmann .... .... ...... .. .. .. ... 05/62
Willheim ....................
05/32
Willheim .. .. .... .......... ....... 0 5/62
Spadacini .................... .... 0 5/32
Josephs ...... .. ...... .. .. ...... .... 05/58
Yu ........................ .. ...... 025/ 103
Valenteetal .................... 05/62
Key .. ............................... 05/32
Brookman ............ .. .... .. .. . 05/62
Brookman et al ............... 05/62
Borders ........................... 05/62
* cited by examiner
14 Years
Prima ry Examiner - Karen S Acker

(74) Attorney, Agent, or Firm - Karen Bryant Tripp
o.: 29/443,396
(57)
CLAIM
The ornamental design for a sheet material with camouflage
pattern, as shown and described.
Jan. 16, 2013
DESCRIPTION
Related
.S. Application Data
(62)
Di vision of application o. 29/406,042, filed on

9, 201 1, now Pat. o. Des. 679,099.
(51 )
(52)
LOC (9) CI. ......... .. ................................. ...... 05-05

U.S. Ct.
SPC ..... .... .... ... .... ......... ........ ............. ...... ..... D5/62
Field of Classification Search
US PC .................. .. D5/6 , II , 12, 16, 17, 19, 23, 24,
D5/48 , 32, 36, 39, 53 , 55 , 57 , 59 , 61 , 62,
D5/63 , 66, 99 ; D6/588, 592, 600, 602, 613,
D6/617 ; Dl9/6; D24/1 24, 126; D32/43; 2/900;
5/490, 495 ; 15/208; 112/401 , 416, 439; 1391383
R, 383 B; 428/32,37,39, 66.5 , 79, 153 , 190,
428/9 19; 604/384, 385.01
See application file for complete search hi story.
(58)
ov.
The file of this patent contains at least one drawing executed

in color. Copies of thi s patent wi th color drawings will be
provided by the United States Patent and Trademark Office
upon request and payment of the necessary fee.
FIG. 1 is a top plan view of a first embodiment of a heet
material with camouflage pattern according to our new
design; and,
FIG. 2 is a top plan view of a second embodiment of a sheet
material with camouflage pattern.
The broken lines surrounding the sheet material with camouflage pattern represent unclaimed boundaries. The thickness
of the sheet material with camouflage pattern forms no part of
the claimed design.
1 Claim, 2 Drawing Sheets
(1 of 2 Drawing Sheet(s) Filed in Color)
U.S. Patent
Jul. 16, 2013
Sheet 1 of2
FIG. 1
us 0685,999 s
U.S. Patent
Jul. 16, 2013
Sheet 2 of2
FIG. 2
US D685,999 S
EXHIBIT F

the law.
Therefore, this

usc 253.
~~
Acting Director ofthe United States Patent and Trademark: Office

IIIIII
111111111111111111111111111111111 11111111111111111 II IIIII 1111
USOOD686000S
(12)
(10)
Johnson et al.
(45)
(54)

PATTERN
(7 1)
Applicant : Kryptek Outdoor Group, LLC,

Houston, TX (US )
(72)
Inventors: David Johnson, Knoxville, T (US);

Reid Phillips, Helenwood, T (US);
Harry F. Whiting, Fairbanks, AK (US);
Joshua Dale Cleghorn, Enterprise, AL
(US ); Gregory Scott Love, Knox ville,
T (US )
(73)
Assignee: Kryptek Outdoor Group, LLC,

Houston, TX (US )
(**)
Term :
(2 1)
Appl.
(22)
Filed :
US D686,000 S
Patent No.:
Date of Patent:
(56)
**
Jul. 16, 2013
References Cited
U.S. PATENT DOCUMENTS

S
A
S
S
S
S
S
S
S
S
S
S
S
*
*
*
*
*
*
*
*
*
*
*
*
*
4/1889
11/ 1925
311929
4/ 1929
8/1933
6/1996
3/ 1998
10/2006
7/20 11
3/20 12
7/20 12
11 /20 12
1/20 13
Bun1er ......................... 0 2511 11

Guenot et a! ................. 427/262
Kahrmann ... .. ............. ..... 05/62
Willheim .................. ....... 05/32
Willheim .... ...... ........ ... ... . 05/62
Spadaci ni ............ ........... 05/32
Josephs ........................... 05/58
Yu ... .. ......................... 0251103
Valente eta! .
... 05/62
Key ................
..... 05/32
Brookman ...................... 05/62
Brookman eta! .
..... 05/62
Borders ....... ........ .. ... ... . 0 5/62
* cited by examiner
14 Years
o.: 29/443,397
Jan. 16, 2013
Related U.S. Application Data
(62)
Divi sion of application o. 29/406,042, fi led on Nov.

9, 201 1, now Pat. No. Des. 679,099.
(51 )
(52)
LOC (9) Cl. .. ... .... ..... ... ...... ...... .. .. .. .... ... ... ..... 05-05
(58)
0 19,054
1,561 ,324
077,964
078,243
090,466
0370,350
0 391 ,402
0530,027
0641 ,557
0655,094
0663 ,959
0670,085
0675,030
U.S. CI.
USPC .................. .. ... ....... .............. ... .. .... ... .... . D5/62
Field of Classification Search
USPC .......... .......... D5/6 , II , 12, 16, 17, 19, 23 , 24,
D5/48, 32, 36 , 39 , 53 , 55 , 57 , 59, 6 1, 62,
D5/63 , 66, 99 ; D6/588 , 592, 600, 602, 6 13,
D6/6 17; Dl 9/6; D24/124 , 126; D32/43; 2/900;
5/490, 495; 15/208; 112/40 1, 4 16, 439;
139/383 R, 383 B; 428/32, 37 , 39 , 66.5 , 79 ,
4281153, 190, 919; 604/384, 385.0 I
See application fi le fo r compl ete search hi story.
Prima ry Examiner - Karen SAcker

(74) Attorney, Agent, or Firm - Karen Bryant Tripp
(57)
CLAIM
The ornamental design for a sheet materi al with camoufl age

pattern , as shown and descri bed.
DESCRIPTION
The fi le of thi s patent contains at least one drawing executed

in color. Copies of thi s patent with color drawings wi ll be
provided by the U.S. Patent and Trademark Office upon
request and pay ment of the necessary fee.
The sole FIGURE is a top plan view of a sheet materi al wi th
camouflage pattern according to our new design.
The broken lines surrounding the sheet material with camoufl age pattern represent unclai med boundaries. The thi ckness
ofthe sheet materi al with camoufl age pattern fo rms no part of
the claimed design.
1 Claim, 1 Drawing Sheet
(1 of 1 Drawing Sheet(s) Filed in Color)
U.S. Patent
Jul. 16, 2013
US D686,000 S
EXHIBIT G
EXHIBIT H
Certificate of Registration
ThisCertificate issued under the seal of the Copyright

Office in accordance with title 17, United States Code,
attests that registration has been made for the work
identified below. The information on this certificatehas
. been made a part of the Copyright Office records.
Registration Number
VA 1-783-604
Effective date of
registration:
Register of Copyrights, United States of America
'~----,
July 25, 2011
--
-_'Title-------------------"""-------------------Title of Work: Highlander Can10uflage _
Completion/Publication - - - - - - - - - - - - - - - - - - - Year of Completion: 2011

Date oflst Publication: Jmie 15, 2011
Nation of 1st Publication: United States
-_Author
.Author: Kryptek Outdoor Group, LLC

Author Created: 2-D artwork-
Work made for hire: Yes

Domiciled in: United States
-
"
..
--' CQpvright claimant'
_Copyright Claimant: Kryptek Outdoor Group, LLC

440 Louisiana, SUite 2100, Houston, TX, 77002; United States
-Rights arid Permissions

-Organization Name: Bailey-Perrin Bailey
Name: .Camp Bailey
Email: cbailey@bpblaw.com _
Telephone:
713-425~ 7100
Address: 440 Louisiana, Ste: 2100

Houston, TX 77002 United States
certification
Name: Joby Allen Hughes
Date: July 25; 2011
Page 1 of 1 _
Registration#: VAOOOl783604
Service Request#: 1-625368122
Joby Allen Hughes

440 Louisiana
Suite2100
Houston, TX 77002
Certi~cate
of Registration
This Certificate issued under the seal of the Copyright

identified below. The information on this certificate has
been made a part of the Copyright Office records.
Registration Number
VA 1-783-606
Effective date of
registration: .
July 25, 2011
-Title---------------------------------------------------~~Title of Work: Kryptek Camouflage Patterns
Completion/Publication
.............._ ........_ _ _ _ _......_ _................_
---~_
Year of Completion: 2011

Date oflstPublication: Jurie 15, 2011
Author
Author: KryptekOutdoor Group, LLC

Author Created: 2-D _artwork
Work made fo~ hire: Yes

Domiciled .in: United States
. Copyright claimant
Copyright Cblimant: MJ>tek Outdoor Group, LLC

440 Louisiana, Suite2100, Houston, TX, 77002, United States
. Rights_and .Permissions
Org~nizatiolrName:
--Bailey Perrin:Bailey.
Name: Camp Bailey

Email: . cbailey@bpblaw.com
.
.
Telephone:
713..:425-7100.
Address: 440 Louisiana

Suite 2100
Houston, TX77002 United States
. Certification
Name: Joby AllenHughes
Date: Jtlly 25, 2011
Page _1 of 2.
.R~~stratimi #: VA0001783606
s:enacel{equ~st #:
.
1-625117081
'
'.:;
:: .- :. ~
. ,
.',
..
Bailey Peri-in Bailey

Camp Bailey
.. 440 Lo1Jisi~tmi
..
-~..
Suitehoo
Hptiston,TX: 77002 United States

Correspondence: Yes
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0
);
0
0
0
....
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Ol
0
.....
Page 2 of 2
Case 1:15-cv-00348-RC Document 1-9

Certificate
of Registration
Filed 09/09/15 Page 7 of 27 PageID #: 87

Office in accordance With title 17, United States Code,
Registration Number
..VA
1-783~605
Effective-date of
registration:
July 25, 2011
-------=----------------- - - - - .----. . ---------------------
--- '"- -'"ritte-----------~----------------=--
Title ofWork: Mandrake Camouflage
completion/Publication - - - - - - - - - - - - - - - - - - - Year ofCompletion: 2011

Date of 1st Publication: June 15, 2011
Author
Author: Kryptek Outdoor Group, LLC

Author Created: 2-D artwork
Workmade for hire: Yes

DoJ;Diciled in: United States
.. Copyright Cl~;timant: Kryptek Outdoor Group, LLC
440 Louisiana, Suite 2100, Hou8ton, TX,.77002, United States -
Rjghts and Permissions

_ Organization Name: Bailey Perrin Bailey .. Name: Camp Bailey
Email: cbailey@bpblaw.com
Telephone:
713-425-7100
Address:- 440 Louisiana, Ste. 2100

-Certification.
Name: Joby AllenHugbes
Date: July25, 2011
. Page 1 of 1
Registration#: VA0001783605
Service Reqnest #: 1-625368149
-----------~---'
Bailey Perrin Bailey

Joby Allen Hu&}les.
440 Louisiaria
Suite 2100
Houston, TX 77002 l]nited States
-----C-0'-------~---o-.-_--
--
-~------..------.;,

Certificate
of Registration

Registration Number
VA
1-783~608
Effective date of
registration:
July 25, 2011
Title of Work: Nomad Camouflage
.Completion/Publication
Year of Completion: 2011
Date of 1st Publication: June 15, 2011
Author
Author: Kryptek Outdoor Group, LLC

Author Created: 2-D artwork
Work ~atle fo~ hire: Yes

Domiciled .in: United States
Copyright Claimant: . Kryptek Outdoor Group; LLC ..

440 Louisiana, Suite 2100, Houston, TX, 77002, United States
. Rlghts and Permissi()i'IS

OrganizationName: BaileyPerrinBailey
>
Na111e: Camp Bailey .

. Email: . cbailey@bpblaw.com
Telephone:
713~425-JlOO
Address: 440 Louisiana, Ste. 2100

_Houston, TX 77002 United States
certification ~
Name:
Joby Allen Hughes
Date: July 25,2011
Page 1 of 1
. Registration#: VA0001783608
Joby Allen Hughes

440 Louisiana
Suite2100
Houston;TX 77002
Case 1:15-cv-00348-RC
Certificate
of RegistrationDocument 1-9

beenni.;1de a part of the Copyright Office records.
. Registration Number
VAl-829-646
Effective. date Of
re~ti-ation:
'
. .June 26, 2012 _
,,
Title---~--~--~~~...............-~-~~~-~--~........,.._-...___.
.. -.
. Title of Work: Kryptek !{aid CamoUflage
Completion/PubliCation--------------------------------------
..
Year of Completion: 2011 >
Date oflst Publication:
. .
.
December 7, 2011 .
.
..
--
... Nation oflstPublication: United States
-Author
Author:
Author Created:
2~n artwork.
Work madefot hire:_ .Yes-

nopliciled in:- United States -
Citizen of: Uruted States
----~.Copyrightdaimaf1t.-_......._~---...........""!'... --~------.~-~-- - - - - - - - - - - - - copyright Cla_iinant~ _ Kiyptek Outdoor Gr()up, LLC
440Louisiami. St., Suite 2100, Houston, TX; 77002, "United States
---
~-c-e:
.Limifatiorrof-copy-right claim ..........""!'.-----~~--~-~----------~~-
-;-- ---;,; ..-,-:,-- :~~ ' .--\.. _ . -;',-- - ~
,,1. o..,.:-_T}
-~ ,''""'""':'-' , ' - ,: ~,;---:- ::
-< ,;-.---,:;- '"--:'
-;~------:
';~
; Matenal excludedfromthis elaim: - . 2~D artWork .. -
'
Prev:i,ous ~e~tratioJI and yeat: . VAtl7sJ-6o6 2011

New Qiaterlal inei~ded i~ ch)im: - 2~0artwork
:Rights anci-Permissions - -
.OrgimizationN
arne:
-. Bail~y
Perriri
Bailey,
PLLC
-
---
.
Name: . K Cat11P Baile
--
'
Email:
'
cbailey@bpblaw;coin
Telephone:
713-425~7100
.Address: 440 Loujsiip,a St. .
-_ sUite210<>
. H{)~stpri,rx'77002- tillit~d States -
Pagel of2

Name: K. Camp Bailey
Date:
June 26,2012
Page 2 of 2
Service Request #: 1-786673178
Bailey Perrin Bailey, PLLC

K. Camp Bailey
440 Louisiana St.
Suite 2100

Certificate
of Registration

Office in accordance With title 17, United States Code,
identified below.. The information on this certificate has
. been made a part of the Copyright Office records.
Registnttion Number
VA 1-829-638
Effective date of
registration:
June26, 2012
Title of Work: Kryptek twhon Camouflage
. Completion/Publication - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Year of Completimi:
2011
.
bate oflst Publication: December 7, 2011
'
Nation oUst Publication: United States
Author:
2-D artwork .
Author Created:
.
.
\Vork in~d(d'o:r hire: ~Yes
CitiZen-of: Uirited States
Domiciled in: U:irited States
Copyrightdail11a.nt ~...:'".!"' ~---~""'-;-'!""'.
..
-~-----------------
........
CQpyright Clahnant: : I<Iyptek. Outdoor: Grottp, LLC
. .
.440 Louisiana St.; Suite 2100,Houston, TX, 77002, Unit~dStates
.Lhnltation ofcopyright claim . --~~........- - - - - - - - - - - - - - Material exclunedfrom tlii~ :craw:. 2~oaitWork

.
.-
'.
..
'
'
VA1..:783-6o6 . 20il'
. Previous registration and yea:t:: ..
. New mate~aUndudl(d in claim: .. 2~D artwpf1<

.
.-.
Rights and Pf!rmissions

.Organizatlo~ N11me:.
:B,atley J>erriti Bailey,PtLC
. Na~e:. ~.'CampBa:iley
. Email... cbailey@bpblaw.coin
Telephone:
713-425~7100
44Q Louisi~a St..
.Add_ress
: .. scite 2100
'
'
.. Houston,TX77002 United States

.
..
. ::Certification .
Page 1 of 2
____.-:::....o.>...
---........
--..._.._ _ _ _ _ _ _ _ __

Name:
Date:
-----<---
K. Camp Bailey
June 26, 2012
--.--------------~------
~----------
Page 2 of 2

. K. Camp Bailey
440 Louisiana St.

Suite 2100

Certificate
of Registration
ThisCertificate issued under the seal ofthe Copyright

identified below. The inforniationon this certificate has
been made a part ofthe Copyright Office records.
Registration Number
VA 1-833-727
Effective date of
registration:
Register of Copyrights,United States of America
September25, 2012
- Title ..............----------------------------------------___,;
. . .
Title of Work: Kriptek Yeti Camouflage
_completion/Publication - - - - - - - - -.......- - - - - - - - - - - - - - - - Year of Completion: 2011

Date of 1st Publication: December '7 ,2011
Nation Of 1st Publication: United States
;--
..
Author
Author: Kryptek Outdoor Group, LLC ..

Author Created: 2-D artWork
.Work made for hire: Yes

. Domiciled in: United States
Citizim of:- . United States

'
'
'
'
: copyright daimant ---------~----........- - - - - - - - - - - -.......
- Copyright Glaiinant: Kryptek OutdooF Group, LLC
: . 440 Louisiana St,, S~ite 2100; Houston, TX, 77002, United States .
Limitation of copyright ~~~Int
_....__
.. -----~~~~~~-------------
. ~;~~Ji.si~~~~ti~n;nd-~e~r: .-yA.r.:783-606 . 2011
. : Rig~ts and P,~rmission-s
organizitio~ Name:.. Bailey ~e~ Bailey,_ PLLC .

. ~ .: N;lme: -!(. Camp Bailey
.
;-:
Tel~phone: : 713-425-noo
A,ddress: .. 440 Louisiana St..
--
_. ___ ;
Email: . cpailc;:y@bpblaw:com
..
.. -,
: Suite2100
_/
,\
'"
,\
"\
.... H6).lston;TX770Qi United States

\
. certific:ation.~.
'< _':
Page 1 of 2

Name: K. Camp Bailey
Date:
June 22,2012
Correspondence: Yes
0
0
0
0
0
0
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.....
Page 2 of 2
._/
. Se:fviceRequest #: 1-785056171.

K. Camp Bailey
440 Louisiana St.
Suit~ 2100 .
Houston,TX 77002 United States
EXHIBIT I
EXHIBIT J
Krono Camo Defense Armour

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RavenFaceShieldwithExclusiveSACamoS.A.Company
Case 1:15-cv-00348-RC Document
1-11 Filed 09/09/15 Page 14 of 31 PageID #: 163
WANTTOTRYAFACESHIELDFORFREE?CLICKHEREFOR
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S.A. COMPANY
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SA CLASSIFIEDS
SA CHANGE | CHANGE THE WORLD
BACKTOSALTWATERCOOLFISHINGGEAR|PERFORMANCEFISHINGCLOTHES
RAVENFACESHIELDWITH
EXCLUSIVESACAMO
$19.99
SaCo.FaceShieldsofferstyleandsunprotectionwithoutweighingyou
down.Lightweightandcomfortable,ourfaceshieldswickaway
moisture,dryquicklyandbreathewell.
Wearoneasyoufish.You'llbeamazedbyhoweffectivelyitreducesskin
temperatureandhelpsmaintainhydrationtokeepyoufreshandreadyto
fish.
PRODUCTSPECIFICATIONS:
DRI-Fit
SPF40
Stainresistant
Helpsmaintainhydration
Onesizefitsmost
Machinewash
Airdry
Donotiron
SKU:50060
Quantity:
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RavenFaceShieldwithExclusiveSACamoS.A.Company
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RavenSkullwithExclusiveSACamoSilverPROActiveFaceShieldS.A.Company
Case 1:15-cv-00348-RC
Document 1-11 Filed 09/09/15 Page 16 of 31 PageID #: 165
MOREDETAILS.
DAILY DEALS
FACE SHIELDS
HATS & VISORS
PACK DEALS
GAME DAY GEAR
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
WHOLESALE
+ MENS
+ LADIES
SA CLASSIFIEDS
BACKTOSILVERPROACTIVETECHNOLOGY
RAVENSKULLWITH
SOLDOUT
EXCLUSIVESACAMO
SILVERPROACTIVEFACE
SHIELD
$29.99
SA&Co.SilverPROActiveFaceShieldskeepyouatthepeakof
performanceallday.Lightweightandcomfortable,ourSA
SilverPROActiveFaceShieldsareodorresistant,bacteriafree,wickaway
SilverPROActiveTechnologyhelpstoprotectyourskinfromtheharmful
effects,whilekeepingyoucoolandfresh!
PRODUCTFEATURES&BENEFITS:
Temperaturecontrol:ensurescomfortinalltemperatures
MadewithAntibacterialFabric
SelfCleaning:NeverNeedsToBeWashed
UV&RFISafe:ReducesHarmfulRays
EliminatesOdorOnTheProduct
QuickDry
ReducesMuscleRecoveryTime
ReducesMuscleSoreness
ImprovesCirculation
UltravioletProtection
Increasesskinhydrationandprotectsfromsundamage
Onesizefitsmost
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Case 1:15-cv-00348-RC
Donotiron
SKU:50078-Silver
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Case 1:15-cv-00348-RC 5FaceShieldsPack|PickYourPack|PromoEligibleS.A.Company

MOREDETAILS.
S.A. COMPANY
DAILY DEALS
FACE SHIELDS
GAME DAY GEAR
REBELS
SKULL TECH
COOKING RUBS
HATS & VISORS PACK DEALS + GEAR KIDS MILITARY APPRECIATION

BACKTOSALTWATERCOOLFISHINGGEAR|PERFORMANCEFISHINGCLOTHES
WHOLESALE
+ MENS
+ LADIES
SA CLASSIFIEDS
5FACESHIELDSPACK|PICK
SALE
YOURPACK|PROMOELIGIBLE
$75.00$100.00
CLICK"ADDTOCART"FORTHEFACESHIELD
OPTIONSTOAPPEAR
5FACESHIELDSPACK|A$100.00value,allfor$75.00
SACo.FaceShieldsofferstyleandsunprotectionwithoutweighingyou
down.Lightweightandcomfortable,ourfaceshieldswickaway
Wearoneasyoufish.Youllbeamazedbyhoweffectivelyitreducesskin
temperatureandhelpsmaintainhydrationtokeepyoufreshandreadyto
fish.
100%moisture-wickingpolyestermicrofiber
SPF40
Stainresistant
Helpsmaintainhydration
Onesizefitsmost
Machinewash
Airdry
Donotiron
SKU:5PACK
Quantity:
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SACAMOFISHINGTEAMMEMBER,SWEATSHIRT:BLACKS.A.Company
Case 1:15-cv-00348-RC
MOREDETAILS.
S.A. COMPANY
DAILY DEALS
FACE SHIELDS
HATS & VISORS
GAME DAY GEAR
PACK DEALS
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
+ MENS
WHOLESALE
+ LADIES
SA CLASSIFIEDS
BACKTOSWEATSHIRTS
SACAMOFISHINGTEAM
MEMBER,SWEATSHIRT:BLACK
from$29.99
TheSACo.hoodedsweatshirtisgreatforoutdoorsbecauseitprovides
warmthandinsulationagainsttheelementswithoutbulk.Thishoodiehas
ourclassicstylingandconstructionforfunctionandstyle.Thishoodie
featuresanattachedhoodwithanadjustabledrawcordclosure,onefront
pouchpocketandastretchablespandex-reinforcedbottombandandrib-
knitcuffs.
PRODUCTDESCRIPTION:
7.75-ounce,50/50cotton/poly;no-pillairjetyarn
Double-needlestitching
1x1athleticribknitcuffsandwaistband,withspandex
Attachedhoodwithadjustabledrawcordclosure
Frontpouchpocket
Machinewashable
SKU:70010
Size:
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SACAMOFISHINGTEAMMEMBERCOTTONLONGSLEEVE:CAROLINABLUES.A.Company
Case 1:15-cv-00348-RC
MOREDETAILS.
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FACE SHIELDS
HATS & VISORS
GAME DAY GEAR
PACK DEALS
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
+ MENS
WHOLESALE
+ LADIES
SA CLASSIFIEDS
BACKTOCOTTONSHIRTS
SACAMOFISHINGTEAM
MEMBERCOTTONLONG
SLEEVE:CAROLINABLUE
from$19.99
Whetheronlandoratsea,SACo.cottonshirtsprovidequalitycomfort
duringyourbusyday.Jointheteamandlookgooddoingwhatyoulove.
PRODUCTDESCRIPTION:
Highqualitycotton
Machinewashable
SKU:20090
Size:
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WANTTOTRYAFACESHIELDFORFREE?CLICKHEREFORMORE

DETAILS.
DAILY DEALS
FACE SHIELDS
HATS & VISORS
PACK DEALS
GAME DAY GEAR
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
WHOLESALE
+ MENS
+ LADIES
SA CLASSIFIEDS
BACKTOSALADIES
SACAMOFISHINGTEAM
MEMBERPERFORMANCELONG
SLEEVE|BLACK
from$29.99
SAPerformanceshirtsprovideflatlockstitchingandseam-freeplacementtoallow
youtomovefreelyandeasilyinagarmentthatfitsclosely,butnottightly.Inadditionto
wickingmoistureawayfromskin,anti-odortechnologyhelpscontrolscent.
WithSPF30shieldingthoseharmfulUVrays,youcanrestassuredthatyou
willbeprotectedduringthosedaytimefishingadventures.
PRODUCTDESCRIPTION:
SPF30
100%microfiberperformancepolyester
Screen-Tekmoisturemanagementandanti-microbialfinish
Selffabricroundneckandcuffs
Raglanshoulderinsert
Double-needleneckandbottomhem
Nounderarmseams
Flatlockstitching
Machinewashable
SKU:20091
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SACamoFishingTeamMemberPerformanceLongSleeve|WhiteS.A.Company
Case 1:15-cv-00348-RC
MOREDETAILS.
DAILY DEALS
FACE SHIELDS
HATS & VISORS
PACK DEALS
GAME DAY GEAR
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
WHOLESALE
+ MENS
+ LADIES
SA CLASSIFIEDS
BACKTOSALADIES
SACAMOFISHINGTEAM
SLEEVE|WHITE
from$29.99
youtomovefreelyandeasilyinagarmentthatfitsclosely,butnottightly.Inadditionto
wickingmoistureawayfromskin,anti-odortechnologyhelpscontrolscent.
PRODUCTDESCRIPTION:
SPF30
Nounderarmseams
Flatlockstitching
Machinewashable
SKU:20092
Size:
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Quantity:
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Case 1:15-cv-00348-RC
MOREDETAILS.
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HATS & VISORS
PACK DEALS
GAME DAY GEAR
+ GEAR
KIDS
REBELS
SKULL TECH
COOKING RUBS
+ MENS
WHOLESALE
+ LADIES
SA CLASSIFIEDS
BACKTOPERFORMANCESHIRTS
SACAMOFISHINGTEAM
SLEEVE:WHITE
from$29.99
youtomovefreelyandeasilyinagarmentthatfitsclosely,butnottightly.Inaddition
towickingmoistureawayfromskin,anti-odortechnologyhelpscontrolscent.
PRODUCTDESCRIPTION:
SPF30
Nounderarmseams
Flatlockstitching
Machinewashable
SKU:20092
*Ifyouareunsureofyoursize,werecommendthenextsizeup.
Size:
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Quantity:
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Case 1:15-cv-00348-RC Document RavenHeadbandS.A.Company

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GAME DAY GEAR
+ GEAR
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REBELS
SKULL TECH
COOKING RUBS
WHOLESALE
+ MENS
+ LADIES
SA CLASSIFIEDS
BACKTOSABANDS
RAVENHEADBAND
$14.99
SABandsaremulti-useheadbandsthatcanbewornasyoufish,during
outdooractivities,atthegymorasastyleaccessory.You'llbeamazedby
howeffectivelyitkeepshairawayfromyourfaceandstaysfirmlyinplace.
Multi-UseHeadband:CanBeWorn5+Ways
100%Moisture-WickingPolyesterMicrofiber
SPF40
StainResistant
OneSize
Machinewash
AirDry
DoNotIron
SKU:22004
NORETURNSIFHEADBANDISOPENED
Quantity:
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Case 1:15-cv-00348-RC Document RavenHeadbandS.A.Company

saltarmour 2 months ago
Follow
New Ladies HeadBands SA Bands Specs: Multi-Use Headband: Can Be Worn 5+ Ways - 100%
Moisture-Wicking Polyester Microfiber - SPF 40 - Stain Resistant - One Size fits most - Machine
washable - -Link in our bio!- ONLY AT @saltarmour @SA_Ladies
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Shop Swamp Slayer

Page 1 of 1
DAILY DEALS
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DECAL S
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+ H ATS, VISORS & BEANIES
KRYPTEK KRONOS
FLAGS
+ GEAR
PACK DEALS
SOLD OUT
NAVY KRONOS CAMO ADJUSTABLE HAT
MILITARY GREEN KRONOS CAMO ADJUSTABLE
KRONOS CAMO BACKPACK
$24.99
HAT
$49.99
$24.99
TAN KRONOS CAMO ADJUSTABLE HAT

$24.99
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EXHIBIT K
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+ FOOTWEAR
REBEL
DECAL S
+ MENS
KRYPTEK KRONOS
FLAGS
+ GEAR
PACK DEALS
SOLD OUT
NAVY KRONOS CAMO ADJUSTABLE HAT
MILITARY GREEN KRONOS CAMO ADJUSTABLE
KRONOS CAMO BACKPACK
$24.99
HAT
$49.99
$24.99
TAN KRONOS CAMO ADJUSTABLE HAT

$24.99
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TOP SELLING PRODUCTS
Green Digital Camo Face

Shield
Forest Camo Face Shield
The Joker Face Shield
Verdurous Face Shield
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Kryptek v. Salt Armour - Complaint

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Kryptek v. Salt Armour - Complaint

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Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 1 of 47 PageID #: 1

UNITED STATES DISTRICT COURT

CIVIL ACTION NO. 1:15-cv-348

PLAINTIFFS ORIGINAL COMPLAINT

NATURE OF THE ACTION

Plaintiff Kryptek is a highly successful veteran-owned company in the business of

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 2 of 47 PageID #: 2

Krypteks trademarks (Kryptek Marks) and trade dress (Kryptek Trade

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 3 of 47 PageID #: 3

This lawsuit is brought to stop Defendants infringement of valuable intellectual

Recognizing Krypteks popularity, superiority and quality, Defendants have

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 4 of 47 PageID #: 4

Defendants products and services are identical-or confusingly similar to the

On information and belief, Plaintiff and Defendants have a direct overlap in

Defendants infringement of Krypteks intellectual property rights harms Kryptek,

Defendants unauthorized use of the Kryptek Marks, Kryptek Patents, Kryptek

Defendants unauthorized use of Krypteks Intellectual Property removes from

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 5 of 47 PageID #: 5

Defendants conduct has caused, and is causing, unless immediately enjoined,

Plaintiff Kryptek Outdoor Group, LLC (Kryptek or Plaintiff) is a Limited

On information and belief, Defendant Salt Armour, Inc. (Salt Armour) is a

On information and belief, Defendant Salt Armour operates the following

websites located at www.saltarmour.com; www.sateam.company; www.defensearmour.com;

controlling interest in www.sateam.company; and http://safishing.com; as well as the products

http://sellmyoutdoorstuff.com because the site proclaims that it is Powered By SA Co.

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 6 of 47 PageID #: 6

On information and belief, Defendant Alpha Defense is a Florida corporation with

On information and belief, Defendant Thomas J. De Sernia is the incorporator,

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 7 of 47 PageID #: 7

Plaintiff re-alleges and incorporates by reference the foregoing allegations as

though fully set forth herein.

Plaintiff has registered KRYPTEK as U.S. Trademark Registration No.

Plaintiff has registered KRYPTEK as U.S. Trademark Registration No.

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 8 of 47 PageID #: 8

Plaintiff has registered KRYPTEK as U.S. Trademark Registration No.

Plaintiff has registered KRYPTEK HIGHLANDER as U.S. Trademark

Plaintiff has registered KRYPTEK as U.S. Trademark Registration No.

Plaintiff re-alleges and incorporates by reference the foregoing allegations as

though fully set forth herein.

patterns as seen below:

Case 1:15-cv-00348-RC Document 1 Filed 09/09/15 Page 9 of 47 PageID #: 9

July 25, 2011

July 25, 2011

Kryptek Camouflage Patterns

July 25, 2011

July 25, 2011

Kryptek Typhon Camouflage

June 26, 2012

Kryptek Raid Camouflage

June 26, 2012

Kryptek Yeti Camouflage

September 25, 2012

Kryptek Neptune Camouflage

October 14, 2014

Kryptek Altitude Camouflage

October 14, 2014

Kryptek Banshee Camouflage

October 14, 2014

Kryptek Inferno Camouflage

February 20, 2015

Kryptek Universal Camouflage

February 20, 2015

JURISDICTION AND VENUE

Plaintiff re-alleges and incorporates by reference the foregoing allegations as