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Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 1 of 54

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF NEW YORK

GENERAL ELECTRIC COMPANY

Plaintiff,
CIVIL ACTION NO.
V.
________________
GAS TURBINE CONTROLS CORPORATION

Defendant.

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Plaintiff General Electric Company (GE or Plaintiff) states and alleges as

follows for its Complaint against Defendant Gas Turbine Controls Corporation (GTC

or Defendant), a New York corporation:

NATURE OF THE ACTION

1. This is an action for trademark infringement, counterfeiting, dilution, false

advertising, unfair competition, deceptive trade practices, and related causes of action

under federal and state law.

2. Without GEs authorization, GTC is using GEs famous trademarks, logo

and trade name (collectively, the GE Trademark) in connection with the marketing and

sale of modified and used turbine control systems and services that GTC is falsely

promoting and advertising as unmodified and new GE products, tricking customers and

causing irreparable harm to GEs name and reputation. GTC has gone so far as to have

counterfeit GE nameplates, labels, and packaging created so as to make the modified and

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used products look unmodified and new, deceiving customers into thinking they are

getting legitimate new GE products, when they in fact are getting old and modified

products. GE brings this lawsuit to stop GTCs willful infringing, counterfeiting, false

advertising, dilution, and deceptive trade practices conduct and seeks all available

monetary remedies and injunctive relief available under the law.

PARTIES & JURISDICTION

3. Plaintiff GE is a New York corporation having its principal place of

business at 41 Farnsworth Street, Boston, MA 02210.

4. On information and belief, Defendant GTC is a New York corporation with

its principal place of business at 466 Saw Mill River Road, Ardsley, New York 10502.

5. This is an action for federal trademark infringement and counterfeiting in

violation of 32 and 43(a) of the Lanham Act (15 U.S.C. 1114, 1125(a)(1)(A)),

dilution in violation of 43(c) of the Lanham Act (15 U.S.C. 1125(c)), unfair

competition and false advertising in violation of 43(a) of the Lanham Act (15 U.S.C.

1114, 1125(a)(1)(B)), deceptive trade practices in violation of N.Y. Gen. Bus. Law 349,

dilution in violation of N.Y. Gen. Bus. Law 360-l, and infringement and unfair

competition in violation of the common law of New York.

6. This Court has original jurisdiction over the federal claims (Counts I - IV)

under 15 U.S.C. 1121(a) and 28 U.S.C. 1331 and 1338(a). This case presents well-

pleaded federal questions arising under the Lanham Act, 15 U.S.C. 1051 et seq.

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7. This Court has supplemental jurisdiction over the state claims of this action

(Counts V IX) under 28 U.S.C. 1367 because they are so related to claims within the

Courts original jurisdiction that they form part of the same case or controversy under

Article III of the United States Constitution.

8. The exercise of in personam jurisdiction over GTC comports with the laws

of the State of New York and the constitutional requirements of due process because

GTC and/or its agents have their U.S. headquarters in New York and have advertised and

sold and shipped their infringing products from New York and this District.

GENERAL ALLEGATIONS

GES TRADEMARK AND REGISTRATIONS

9. GE is one of the largest manufacturers in the world. Founded in 1892, and

one of the original 12 companies listed on the newly formed Dow Jones Industrial

Average, GE has grown over 125 years to become ranked number 13 in the U.S. Fortune

500 in terms of revenue, which exceeded $120 billion in 2016.

10. GE commenced use of the GE Trademark in commerce at least as early as

1899 in connection with dynamo-electric machines, induction devices, electric translating

devices, electric regulating and controlling devices, electric lamps, electric measuring

instruments, electric protective devices, switchboards, switchboard appliances, wiring

devices and supplies. Since that time, GE has continuously used the GE Trademark in

commerce.

11. GE is one of the best known and most highly-regarded companies in the

world. For example, GE is consistently ranked on Fortune magazines list of the Worlds

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Most Admired Companies, compiled based on interviews with more than 3,000 business

executives and stock analysts; GE is consistently ranked on Bloomberg

BusinessWeek/Boston Consulting Groups annual listing of the worlds most innovative

companies, based on a survey of 1,000 global senior executives; GE is consistently

ranked on Barrons magazines list of the Worlds Most Respected Companies; GE was

named as one of the Worlds 10 Most Enduring Institutions of the last 100 years in a

2004 study conducted by the global strategy and technology consulting firm Booz Allen

Hamilton, putting GE in the company of the U.S. Constitution, Oxford University, the

Olympic Games and the Rolling Stones; and GE is the only company that has been

included in the Dow Jones Industrial Average, representing the largest and most widely

held public companies in the United States, continuously since it was first published more

than 100 years ago.

12. Over the years, GE has expanded use of the GE Trademark and currently

offers thousands of products and services in a wide variety of fields in connection with

the GE Trademark. GE is one of the worlds leading multinational energy, technology

and industrial companies, consisting of the following businesses: GE Capital; Baker

Hughes, A GE Company; GE Renewable Energy; GE Power; GE Aviation; GE

Transportation; GE Digital; GE Healthcare; GE Energy Connections; and CURRENT

Powered By GE.

13. GEs website is located at www.ge.com. GE registered the domain name

ge.com in 1986. The GE Trademark is used extensively on that website (and in related

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social media). GE markets its products and services in connection with the GE

Trademark through its website (and social media).

14. For 125 years, GE has made large investments in the promotion and

advertising of the GE Trademark and the products and services sold in connection with

the GE Trademark. GE has spent millions of dollars in advertising the GE Trademark.

GE has advertised the GE Trademark in every conceivable type of available media,

including national television, radio, magazines, newspapers, Internet and social media.

15. The enormous magnitude of sales and advertising of GE brand products

and services over the last 125 years has given the GE Trademark the highest level of

commercial recognition and strength.

16. The GE Trademark is inherently distinctive and serves to identify and

indicate the source of GEs products and services to relevant purchasers.

17. GE has developed an enormous amount of goodwill in its GE Trademark.

This mark is extremely well-known and respected by consumers, customers and the

general public. The GE Trademark represents GEs commitment to providing high

quality products.

18. As a result of the long use and promotion of the GE Trademark by GE, the

GE Trademark has become distinctive to designate GE, to distinguish GE and its

products and services from the products and services of other businesses, and to

distinguish the source or origin of GEs products and services. As a result of these efforts

by GE, relevant consumers, relevant customers and the general public in New York and

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throughout the United States widely recognize and associate the GE Trademark

exclusively with GE and its products and services.

19. As a result of GEs long use and promotion of the GE Trademark in New

York and throughout the United States, GE has acquired valuable common law rights in

the GE Trademark.

20. In accordance with federal law, GE has registered the GE Trademark on the

Principal Register of the United States Patent and Trademark Office, as follows:

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

70035089 24-JUL-1899 0035089 18-SEP-1900 U.S. Cl. 21 Dynamo-electric machines, induction devices,
electric translating devices, electric regulating and controlling
devices, electric lamps, electric measuring instruments, electric
protective devices, switchboards, switchboard appliances,
wiring devices, and supplies
First Use: May 1899

72306439 03-SEP-1968 0867114 25-MAR-1969 U.S. Cl. 21 Complete line of materials, appliances, machinery,
components, parts, systems and plants for the generation,
transformation, conversion, transmission, distribution, control
and utilization of electricity
First Use: 1925

72321790 14-MAR-1969 0878049 07-OCT-1969 U.S. Cl. 14 Metals and alloys, in raw, sheet, wire, pellets, rod,
foil, strip, liquid, castings, sintered, pressed, and fabricated
form
First Use: 1928

72364418 06-JUL-1970 0916982 27-JUL-1971 U.S. Cl. 4 Cleaning and polishing preparations for metals,
appliances and television sets
First Used: August 1929

72396531 06-JUL-1971 0929056 15-FEB-1972 U.S. Cl. 21 Complete line of materials, appliances, machinery,
components, parts, systems and plants for the generation,
transformation, conversion, transmission, distribution, control
and utilization of electricity
First Use: 1899

72404063 01-OCT-1971 0947395 14-NOV-1972 U.S. Cl. 103 Services rendered in the repair and maintenance
of machinery, instruments, electrical equipment and appliances
First Use: 1912

GE 72455739 27-APR-1973 0983013 30-APR-1974 U.S. Cl. 100 Computer time sharing services; research,
consultation and advisory services relating to engineering,
design and development problems encountered by utility,
industrial and commercial companies, governments and

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

individuals
First Use: 1955

GE 72455729 27-APR-1973 0983140 07-MAY-1974 U.S. Cl. 12 Silicone sealants for a variety of uses such as for
bath tub caulking, sealing boats and automobiles; silicone
traffic and weather topping, silicone rubber roof coating,
plastic panels for building construction purposes; and plastic
glazing compound
First Use: 1927

GE 72455733 27-APR-1973 0986362 18-JUN-1974 U.S. Cl. 21 Complete line of materials, appliances, machinery,
components, parts, systems and plants for the generation,
transformation, conversion, transmission, distribution, control
and utilization of electricity
First Use: 1899

GE 72455730 27-APR-1973 0995765 15-OCT-1974 U.S. Cl. 14 Metals and alloys in raw sheet, wire pellets, rod,
foil, strip, liquid, castings, sintered, and pressed form
First Use: 1928

73036924 12-NOV-1974 1017393 05-AUG-1975 Int. Cl. 12 Electric motors and diesel engines for land vehicles
First Use: 1900

73022192 23-MAY-1974 1017222 05-AUG-1975 Int. Cl. 1 Synthetic resins; thermosetting synthetic resins in the
form of liquids, pastes, for general use in the industrial arts;
chemical intermediates; organosilicon compounds-namely,
polysiloxanes and silanes in the form of resins, pastes, fluids,
elastomers; antifoaming agents; chemicals for developing and
fixing xray films and other chemicals associated with the
development of said films; phosphors; chemical substances for
use as nuclear fissionable material; fuel for nuclear reactors;
adhesive substances used in industry; thermosetting adhesives
First Use: 1928

73027012 17-JUL-1974 1027955 23-DEC-1975 Int. Cl. 17 Electric insulation material, electric insulators such
as insulating varnish; silicone rubber compounds; thermal
insulating material
First Use: 1918

73036922 12-NOV-1974 1035724 16-MAR-1976 Int. Cl. 11 electric lamps of all kinds; electric lighting fixtures
First Use: 1925

73071173 08-DEC-1975 1045777 10-AUG-1976 Int. Cl. 7 Electric motors of all kinds, steam and gas turbines
and parts thereof, electric generators and their parts, aircraft
engines. compressors; washing machines, dryers, dishwashers,
garbage disposers and compactors
First Use: 1915

73082141 30-MAR-1976 1051200 26-OCT-1976 Int. Cl. 11 Electric lamps of all kinds and their parts; electric
lighting fixtures and their parts; electric refrigerators, freezers,
air conditioning apparatus, and dehumidifiers; electric ovens,
ranges
First Use: 1899

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

73102821 12-OCT-1976 1078109 22-NOV-1977 Int. Cl. 41 Conducting study courses in management
First Use: October 30, 1970

73158497 13-FEB-1978 1110019 26-DEC-1978 Int. Cl. 16 House organs, trade magazines, books of general
interest, reports, pencils, pens, calendars and notebooks
First Use: 1924

GE 73158498 13-FEB-1978 1110020 26-DEC-1978 Int. Cl. 16 House Organs, Books Of General Interest, Reports,
Pencils, Pens, Calendars And Notebooks
First Use: 1924

73162520 16-MAR-1978 1111110 09-JAN-1979 Int. Cl. 42 Research, consultation, and advisory services
relating to engineering, design, and development problems
encountered by utility, industrial, and commercial companies,
governments, and individuals
First Use: 1955

GE 73162522 16-MAR-1978 1111065 09-JAN-1979 Int. Cl. 36 Extension of credit to others


First Use: 1948

GE 73254151 17-MAR-1980 1188448 02-FEB-1982 Int. Cl. 9 Electronic, nuclear, industrial and laboratory testing,
measuring, computing and control instruments, apparatus and
parts thereof; radios; mobile radios; transceivers; walkie-
talkies; antennas; tape recorders, tape players and recording
tape; videotape recorders; television transmitting and receiving
sets, electronic communication apparatus; electric curling
irons, electric flatirons, electric kettles for domestic use,
electric smoke alarms, electric door chimes; batteries, battery
chargers; fuel cells for converting chemical energy into
electrical energy, electrochemical gas generating and sensing
apparatus; flash lamps for photographic purposes; electrical
wires, cables and conductors; electrical wiring fixtures and
fittings; lightning arrestors; electrical resistors, capacitors,
rectifiers, transformers, vacuum tubes, diodes, condensers,
connectors; radar and acoustic apparatus; computer terminals
and printers; and parts thereof
First Use: 1909

GE 73254227 17-MAR-1980 1197111 08-JUN-1982 Int. Cl. 7 Electric motors of all kinds, steam and gas turbines
and parts thereof, electric generators and their parts, aircraft
engines, electric alternators, gas compressors, air-conditioning
compressors, washing machines, gas and electric clothes
drying machines, dishwashers
First Use: 1915

GE 73265230 06-JUN-1980 1203475 03-AUG-1982 Int. Cl. 11 Electric lamps of all kinds and their parts; electric
lighting fixtures and their parts; electric refrigerators and
freezers, air conditioners, humidifiers and dehumidifiers,
electric heaters, heat pumps, gas and oil burning furnaces, gas
and liquid coolers for use in industry; and air condensers and
electric ovens, and ranges, electric cooking utensils-namely,
toasters, skillets, coffee makers, griddles

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

First Use: 1899

GE 73392928 29-SEP-1982 1250353 06-SEP-1983 Int. Cl. 16 Playing cards, paperweights, letter openers and
desk organizers
First Use: March 1973

73392935 29-SEP-1982 1258673 22-NOV-1983 Int. Cl. 28 Golf tees, golf ball markers, golf balls, golf clubs,
flying discs
First Use: June 1969

GE 73392929 29-SEP-1982 1259944 06-DEC-1983 Int. Cl. 14 Scarf pins, stick pins, tie pins, tie bars, cuff links,
tie slides, pendants, charms, brooches and clocks
First Use: 1930

73392923 29-SEP-1982 1263388 10-JAN-1984 Int. Cl. 6 Key chains and key rings
First Use: October 17, 1962

73392930 29-SEP-1982 1263622 10-JAN-1984 Int. Cl. 18 Business CARD CASES, UMBRELLAS,
BRIEFCASE-TYPE PORTFOLIOS [ , TOILETRY CASES
SOLD EMPTY, ] AND LUGGAGE TAGS
First Used: JUN-1959 (IC 18)
In Commerce: JUN-1959

GE 73392933 29-SEP-1982 1265733 31-JAN-1984 Int. Cl. 18 Business card cases, umbrellas, briefcase-type
portfolios and luggage tags
First Use: June 1959

73392932 29-SEP-1982 1272821 03-APR-1984 Int. Cl. 25 Neckties, scarves, jackets and caps
First Use: August 1970

GE 73392934 29-SEP-1982 1272822 03-APR-1984 Int. Cl. 25 Neckties, scarves, jackets and caps
First Use: August 1970

73392926 29-SEP-1982 1273445 10-APR-1984 Int. Cl. 14 Scarf pins, stick pins, tie pins, tie bars, cuff links,
tie slides, pendants, charms and brooches
First Use: 1940

GE 73392927 29-SEP-1982 1283076 26-JUN-1984 Int. Cl. 8 Utility knives and pocket knives
First Use: April 1967

73392924 29-SEP-1982 1285847 17-JUL-1984 int. cl. 8 Utility knives and pocket knives
First Use: April 1967

GE 73451397 04-NOV-1983 1317546 05-FEB-1985 Int. Cl. 3 Cleaning and polishing preparations for metals,
appliances and television sets; abrasive preparations
First Use: August 1929

GE 74120403 04-DEC-1990 1679636 17-MAR-1992 Int. Cl. 36 Insurance brokerage services, credit agency
services in the fields of consumer and commercial credit,

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

credit card services, real estate loan financing services, and


banking and financial services First Use: December 31,
1948
Int. Cl. 37 Construction equipment leasing - First Use:
December 31, 1962
Int. Cl. 38 Telecommunications equipment leasing - First
Use: December 31, 1978
Int. Cl. 39 Automobile, aircraft, railcar and marine vessel
leasing - First Use: December 31, 1962
Int. Cl. 42 Computer equipment and medical systems leasing -
First Use: December 31, 1969

GE CAPITAL 74120415 04-DEC-1990 1679637 17-MAR-1992 Int. Cl. 36 Insurance brokerage services, credit agency
services in the fields of consumer and commercial credit,
credit card services, real estate loan financing services, and
banking and financial services
Int. Cl. 37 Construction equipment leasing
Int. Cl. 38 Telecommunications equipment leasing
Int. Cl. 39 Automobile, aircraft, railcar and marine vessel
leasing
Int. Cl. 42 Computer equipment and medical systems leasing
First Use: November 16, 1987

74120418 04-DEC-1990 1689275 26-MAY-1992 Int. Cl. 36 Insurance brokerage services, credit agency
services in the fields of consumer and commercial credit,
credit card services, real estate loan financing services, and
banking and financial services First Use: December 31,
1948
Int. Cl. 37 Construction equipment leasing - First Use:
December 31, 1962
Int. Cl. 38 Telecommunications equipment leasing - First
Use: December 31, 1978
Int. Cl. 39 Automobile, aircraft, railcar and marine vessel
leasing - First Use: December 31, 1962
Int. Cl. 42 Computer equipment and medical systems leasing -
First Use: December 31, 1969

74274901 10-APR-1992 1790247 31-AUG-1993 Int. Cl. 10 Medical diagnostic apparatus for displaying
diagnostic images; namely, spot film apparatus, x-ray
fluoroscopes, mobile x-ray units, computerized tomography
scanners, nuclear resonance scanners, ultra sound scanners,
magnetic resonance scanners, positron emission tomography
(PET) scanners, and parts thereof and attachments thereto
including tables and pads
First Use: 1933

GE90 78036148 21-NOV-2000 2561930 16-APR-2002 Int. Cl. 7 Gas turbines, namely, jet engines, and replacement
parts thereof
First Use: July 13, 1995

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

78067124 04-JUN-2001 2612853 27-AUG-2002 Int. Cl. 21 Glass mugs; porcelain mugs; beer mugs;
earthenware mugs; coffee cups; coasters, not of paper and not
being table linen; plastic coasters; beverage glassware;
insulated containers for food or beverage; portable beverage
coolers; water bottles; stadium cups; portable ice chests for
food and beverages; vases, containers for food, glass bowls
First Used: December 31, 1955

78067122 04-JUN-2001 2615488 03-SEP-2002 Int. Cl. 25 Pullovers, shirts, sweatshirts, golf shirts, polo
shirts, sport shirts, tee-shirts
First Use: December 31, 1955

GE 78067128 04-JUN-2001 2621463 17-SEP-2002 Int. Cl. 17 Silicone and adhesive sealing and caulking
compound; silicone and adhesive sealants for general use
First Used: December 31, 1955

78067152 04-JUN-2001 2628371 01-OCT-2002 Int. Cl. 42 Computer consultation services; maintenance and
updating of computer software and computer systems for
others; installation of computer software; computer systems
analysis and design services for others
First Use: December 31, 1955

GE 78067121 04-JUN-2001 2631837 08-OCT-2002 Int. Cl. 39 Leasing of shipping containers


First Used: December 31, 1962

78067137 04-JUN-2001 2635351 15-OCT-2002 Int. Cl. 39 Leasing of shipping containers


First Used: December 31, 1962

GE 78067149 04-JUN-2001 2635353 15-OCT-2002 Int. Cl. 42 Computer programming services; computer
software design and analysis services; computer consultation
services; maintenance and installation of computer software;
computer systems and network analysis and design services;
designing, implementing and maintaining web sites and web
pages for others; providing computer search engines for
obtaining data on a global computer network
First Use: September 30, 1985

78067141 04-JUN-2001 2635352 15-OCT-2002 Int. Cl. 41 Providing training services in management and the
medical field through the use of instructions and
demonstrations provided online, through the internet, intranet
and extranets; education services, namely, conducting practical
training workshops, classes and seminars featuring
demonstrations in the field of management and medicine
First Use: October 30, 1970

78067126 04-JUN-2001 2639654 22-OCT-2002 Int. Cl. 35 Inventory control services; consultation in the field
of inventory control services; acquisition integration services;
direct marketing advertising for others featuring database
marketing; consultation in the field of direct marketing
advertising for others featuring database marketing; business
reorganization consulting services; truck and automobile fleet

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

management services, namely voyage reporting and invoicing


via a global computer network; consultation in the field of
truck and automobile fleet management services; business
administration consulting services; operation and management
of power plants of others; consultation in the field of operation
and management of power plants; on-line retail services
featuring general consumer goods; consultation in the field of
on-line retail services featuring general consumer goods
First Use: December 31, 1955

GE 78067123 04-JUN-2001 2639653 22-OCT-2002 Int. Cl. 41 Providing training services in management and the
medical field through the use of instructions and
demonstrations provided online, through the internet, intranet
and extranets; education services, namely, conducting practical
training workshops, classes and seminars featuring
demonstrations in the field of management and medicine
First Use: October 30, 1970

78067155 04-JUN-2001 2642946 29-OCT-2002 Int. Cl. 9 computer software for, persons who troubleshoot
and maintain programmable controllers, for analyzing blood
vessels including cardiac vessels which also provides
calculation functions with respect to blood vessels, for use
with medical patient monitoring equipment, for receiving,
processing , transmitting and displaying data, for use in
developing personalized asset allocation programs; for use on-
line which enables office equipment dealers to submit
applications, for collecting data involving vital medical signs,
for use in electrical power systems analyses and instructional
manual sold as a unit therewith, for regulating and managing
vehicle fleet maintenance services, for use by customers to
obtain lease portfolio information, for a radiology information
system for use by radiologists and radiology department in the
database management of employee and patient information, for
patient monitoring and archival purposes installed on and used
in connection with pcs and medical monitoring equipment, for
graphical user interface, and for underground navigation,
namely, for navigation of down hole probe assembly for oil
drilling and drilling assemblies for routing underground
utilities
First Use: March 1, 1987

GE 78067113 04-JUN-2001 2642943 29-OCT-2002 Int. Cl. 36 Asset based and private label financing services;
financial analysis and consultation; credit card financial
services; credit card services, namely, extension of credit to
others; financial asset management for others; a full line of
equity investment services; personal loan financing; mortgage
banking services; acquisition financing services; commercial
financing services; commercial real estate agency services;
mutual fund investment; private equity and debt investment;
consultancy, advisory and information services relating to all
the foregoing services
First Use: December 31, 1948

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

78067129 04-JUN-2001 2642945 29-OCT-2002 Int. Cl. 36 Asset based and private label financing services;
financial analysis and consultation; credit card financial
services; credit card services, namely, extension of credit to
others; financial asset management for others; [ insurance and
re-insurance services, namely, underwriting services for all
types of insurance; ] equity investment services; [ insurance
underwriting services in the field of bonds; financial guarantee
assurance underwriting services; ] personal loan financing;
mortgage banking services; acquisition financing services;
commercial financing services; commercial real estate agency
services; mutual fund investment; private equity and debt
investment; consultancy, advisory and information services
relating to all the forgoing services
First Use: December 31, 1984

GE 78067148 04-JUN-2001 2652010 19-NOV-2002 Int. Cl. 9 Computer software for, persons who troubleshoot
and maintain programmable controllers, for analyzing blood
vessels including cardiac vessels which also provides
calculation functions with respect to blood vessels, for use
with medical patient monitoring equipment, for receiving,
processing, transmitting and displaying data, for use in
developing personalized asset allocation programs; for use on-
line which enables office equipment dealers to submit
applications, for collecting data involving vital medical signs,
for use in electrical power systems analyses and instructional
manuals sold as a unit therewith, for regulating and managing
vehicle fleet maintenance services, for use by customers to
obtain lease portfolio information, for a radiology information
system for use by radiologists and radiology departments in the
database management of employee and patient information, for
patient monitoring and archival purposes installed on and used
in conjunction with pc's and medical monitoring equipment,
for graphical user interface, and for underground navigation,
namely, for navigation of downhole probe assembly for oil
drilling and drilling assemblies for routing underground
utilities
First Use: March 1, 1987

78067111 04-JUN-2001 2663243 17-DEC-2002 Int. Cl. 11 Microwave ovens for cooking; wall cooking ovens
for domestic use; food warming drawers; convection ovens,
electric and gas cook tops; electric and gas cooking ovens and
ranges; ventilation hoods for stoves; and ventilating exhaust
fans; water filters; water softening units, clothes dryers;
electric fans, ceiling fans, flashlights; lamps and lights for
vehicle; electric lights for christmas trees
First Use: December 31, 1912

GE 78067108 04-JUN-2001 2669168 31-DEC-2002 Int. Cl. 35 Inventory control services; acquisition integration
services, namely business consultation with respect to the
acquisition and integration of information technologies within
a business; database marketing and information management
services, namely computerized database management services;
business reorganization services, namely providing business
consultation in the field of business reorganizations; business
management services, namely vehicle fleet management
services; business administration services, namely

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Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

administration of business payroll for others; operation and


business management of power plants; business consultancy
and advisory services and providing business information for
others relating to all of the foregoing services
First Use: December 31, 1955

78067104 04-JUN-2001 2700342 25-MAR-2003 Int. Cl. 10 Gradient coils; namely, magnetic gradient coils
used in magnetic resonance imaging; medical diagnostic
devices, namely, bone denisitometers; fetal monitoring
apparatus, namely, fetal pulse and vital signs monitors; patient
monitoring apparatus, namely, heart and vital signs monitors
medical imaging systems, namely, ultrasounds, medical
diagnostic imaging machine, imaging devices for screening
and diagnostic applications for use in planning intervention
and surgery, and parts thereof and attachments thereto
First Use: 1933

GE 78067098 04-JUN-2001 2700341 25-MAR-2003 Int. Cl. 10 Gradient coils, namely, magnetic gradient coils
used in magnetic resonance imaging; medical diagnostic
devices, namely, bone densitometers; fetal monitoring
apparatus, namely, fetal pulse and vital signs monitors; patient
monitoring apparatus, namely, heart and vital signs monitors
medical imaging systems, namely, ultrasounds, medical
diagnostic imaging machines, imaging devices for screening
and diagnostic applications for use in planning intervention
and surgery, and parts thereof and attachments thereto
First Use: 1933

78067131 04-JUN-2001 2724121 10-JUN-2003 Int. Cl. 35 Business services, namely he administration of
repair and services contracts
Int. Cl. 37 Remote monitoring and diagnostic repair and
maintenance services rendered in the repair and maintenance
of aircraft engines, turbines, electrical equipment, medical
equipment, locomotives including accessories and component
parts of all the foregoing
First Use: December 31, 1912

75758357 30-OCT-1999 2767059 23-SEP-2003 Int. Cl. 7 Machines for domestic and household use, namely,
electronic power operated coffee grinders, mechanical mixing
machines, electric food blenders for domestic use, electric
juice extractors, electric food processors, and electric food
preparation machines, vegetable grinders and slicers - First
Use: February 15, 2000
Int. Cl. 9 Electric domestic and household apparatus and
instruments, namely, electric steam irons for clothes - First
Use: October 20, 1999
Int. Cl. 11 Domestic electric and gas cooking appliances,
namely, cooking rings, gas and electric stoves, gas and electric
ovens and cooktops; electric coffee makers for domestic use;
electric coffee percolators; electric tea makers and component
parts; electric toasters; electric toaster ovens; electric cooking
crockery cookers and casserole dishes; electric hot plates;
electric deep fryers; domestic electric frypans; domestic
electric rotisserie ovens; electric hot air cooking ovens for
domestic use; electric roaster ovens; electric waffle irons;
electric kettles - First Use: December 31, 1890

28732832.1 - 14 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 15 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

76426504 01-JUL-2002 2804187 13-JAN-2004 Int. Cl. 9 Electronic, nuclear, industrial and laboratory testing,
measuring, computing and control instruments and apparatus,
telephones; caller id boxes; telephone answering machines;
cordless telephones, cordless headset telephones; digital
messaging systems, televisions, television remote controls, vcr
players; VCR remote controls; DVD players; DVD remote
controls; combination TV and VCR sets; batteries; electrical
goods, electrical power generation and distribution products
and electrical voltage and overvoltage surge products, namely,
arresters, busways, capacitors, lighting contactors, controllers
and input/output devices, fuses, lighting controllers, switch
boxes, LEDS, namely, light emitting diodes, voltage regulators
for electric power, voltage surge protectors, voltage surge
suppressors, voltmeters, electrical circuit boards, relays and
timers, solenoids and limit switches, full-voltage manual
starters, reduced voltage starters, electrical switches and
disconnects, circuit board terminal blocks and pumping panels,
circuit breakers and disconnects, transformers, electrical
lighting and power circuit boards, electrical wires, cables,
cords, and conductors, electrical wiring and fixtures, lightning
arrestors, electricity meters, power meters, grounding resistors,
humidity and temperature sensors; building and wood sensors;
industrial calibration sensors, push buttons, motor control
centers, electrical resistance heating wires and electrical
controllers therefore and voltage regulators
First Use: 1899

GE 78067118 04-JUN-2001 2831792 13-APR-2004 Int. Cl. 37 Diagnostic repair and maintenance services
rendered in the repair and maintenance of aircraft engines,
turbines, electrical equipment, medical equipment,
locomotives and accessories and component parts of all the
foregoing - First Use: December 31, 1912
Int. Cl. 42 Remote monitoring of aircraft engines, turbines,
electrical equipment, medical equipment, locomotives and
accessories and component parts of all the foregoing - First
Use: September 1989

78257724 03-JUN-2003 2877396 24-AUG-2004 Int. Cl. 11 Electric light bulbs


First Use: May 22, 1992

GE 78067101 04-JUN-2001 2890028 28-SEP-2004 Int. Cl. 9 Electric luminaries


Int. Cl. 11 Microwave ovens for cooking; wall cooking ovens;
food warming drawers; convection ovens, electric and gas
cook tops; electric and gas cooking ovens and ranges;
ventilation hoods for stoves; and ventilating exhaust fans;
water filters; water softening units; clothes dryers; electric
fans, [ ceiling fans, ] flashlights; lamps and lights for vehicle;
electric lights for christmas trees
First Used: December 31, 1912

GE 78067095 04-JUN-2001 2949455 10-MAY-2005 Int. Cl. 9 Electrical devices and electrical power distribution

28732832.1 - 15 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 16 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

products, namely, capacitors, circuit breakers, circuit breaker


load centers, circuit closers, circuit interrupters, commutators,
contactors, current rectifiers, current limiters, electric contacts,
electric collectors, electric conductors, electric connectors,
electric controllers, electric inductors, electric power supplies,
electricity distribution boards and boxes, electricity
distribution consoles, electricity switchboards and switchboxes
First Use: 1909

78067099 04-JUN-2001 2968024 12-JUL-2005 Int. Cl. 9 Electrical devices and electrical power distribution
products, namely, capacitors, circuit breakers, circuit breaker
load centers, circuit closers, circuit interrupters, commutators,
contractors, current rectifiers, current limiters, electric
contacts, electric collectors, electric conductors, electric
connectors, electric controllers, electric inductors, electric
power supplies, electricity distribution boards and boxes,
electricity distribution consoles, electricity switchboards and
switchboxes
First Use: September 11, 2004

GE MULTILIN 78118021 28-MAR-2002 2972664 19-JUL-2005 Int. Cl. 7 Industrial protection and control equipment,
electrical equipment and parts and accessories therefor
Int. Cl. 9 Equipment for monitoring, controlling and
protecting industrial systems, namely, digital and
electromechanical protection relays, power quality meters, test
blocks, electrical switches and indicator-lamps; fiber optic
multiplexers and interface equipment, namely, synchronous
optical networks, synchronous digital hierarchy modules and
ethernet telecommunications terminals
First Use: December 1, 1999

78660614 29-JUN-2005 3166695 31-OCT-2006 Int. Cl. 39 Chemical delivery, storage and handling services in
the field of water treatment and pulp and paper making
systems
First Use: January 31, 2003

78660628 29-JUN-2005 3166696 31-OCT-2006 Int. Cl. 40 Water treatment services, namely, desalination,
purification, conditioning, identifying and controlling
microbiological organisms, cleaning of ion exchange resins;
membrane regeneration services; chemical control system
services relating to the feeding of treatment chemicals to
industrial water systems
First Use: January 31, 2003

78660640 29-JUN-2005 3166697 31-OCT-2006 Int. Cl. 41 Educational services in the field of medical
imaging and diagnostics, namely, holding seminars,
conferences, symposiums or workshops relating to the
pharmaceutical industry, for medical practitioners and
employees of pharmaceutical companies; educational services,
namely holding seminars, conferences, symposiums or
workshops in the field of life science and biotechnology for
scientists and researchers; conducting seminars related to
industrial water treatment problems; providing training
services for all the aforesaid
First Use: January 31, 2003

GE 78657507 24-JUN-2005 3166688 31-OCT-2006 Int. Cl. 40 Water treatment services, namely, desalination,

28732832.1 - 16 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 17 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

purification, conditioning, identifying and controlling


microbiological organisms, cleaning of ion exchange resins;
membrane regeneration services; chemical control system
services relating to the feeding of treatment chemicals to
industrial water systems
First Use: January 31, 2003

GE 78657495 24-JUN-2005 3166687 31-OCT-2006 Int. Cl. 39 Chemical delivery, storage and handling services in
the field of water treatment and pulp and paper making
systems
First Use: January 31, 2003

GE 78657515 24-JUN-2005 3166689 31-OCT-2006 Int. Cl. 41 Educational services in the field of medical
imaging and diagnostics, namely, holding seminars,
conferences, symposiums or workshops relating to the
pharmaceutical industry, for medical practitioners and
employees of pharmaceutical companies; educational services,
namely, holding seminars, conferences, symposiums or
workshops in the field of life science and biotechnology for
scientists and researchers; conducting seminars related to
industrial water treatment problems; providing training
services for all the aforesaid
First Use: January 31, 2003

GE 78657618 24-JUN-2005 3178503 28-NOV-2006 Int. Cl. 35 Consulting services in the areas of chemical
product and service sourcing and procurement, product
inventory and supply management and cost containment;
consulting, relating to electrochemical liquid purification units
for use in the industrial sector
First Use: January 31, 2003

78660448 29-JUN-2005 3184890 12-DEC-2006 Int. Cl. 3 Cleaning agents containing chemicals and chemical
compositions for use in industry to remove contaminants from
industrial process systems
First Use: January 31, 2003

GE 78657671 24-JUN-2005 3184883 12-DEC-2006 Int. Cl. 3 Cleaning agents containing chemicals and chemical
compositions for use in industry to remove contaminants from
industrial process systems
First Use: January 31, 2003

78660452 29-JUN-2005 3214102 27-FEB-2007 Int. Cl. 5 Pharmaceutical preparations for use in diagnosis;
veterinary pharmaceutical preparations for use in diagnosis;
pharmaceutical and veterinary substances for medical
purposes; diagnostic reagents and preparations for medical
purposes; diagnostic substances for medical purposes; contrast
media for medical imaging; diagnostic scanning agents for in
vivo use; diagnostic imaging agents for magnetic resonance
imaging; radiopharmaceutical products for clinical, medical,
scientific and research use; radiopharmaceutical sources and
standards for use in nuclear medicine; radioactive
pharmaceutical preparations and non-radioactive reagents for
producing radiopharmaceuticals for in vivo diagnostic or
therapeutic use; gases and gas mixtures for medical imaging
First Use: July 31, 2005

GE 78657688 24-JUN-2005 3214100 27-FEB-2007 Int. Cl. 5 Pharmaceutical preparations for use in diagnosis;
veterinary pharmaceutical preparations for use in diagnosis;

28732832.1 - 17 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 18 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

pharmaceutical and veterinary substances for medical


purposes; diagnostic reagents and preparations for medical
purposes; diagnostic substances for medical purposes; contrast
media for medical imaging; diagnostic scanning agents for in
vivo use; diagnostic imaging agents for magnetic resonance
imaging; radiopharmaceutical products for clinical, medical,
scientific and research use; radiopharmaceutical sources and
standards for use in nuclear medicine; radioactive
pharmaceutical preparations and non-radioactive reagents for
producing radiopharmaceuticals for in vivo diagnostic or
therapeutic use; gases and gas mixtures for medical imaging
First Use: July 31, 2005

GE 78657487 24-JUN-2005 3231290 17-APR-2007 Int. Cl. 37 Chemical cleaning services for glass-lined reactor
vessels used in the chemical and pharmaceutical processing
industries; maintenance services for heat transfer systems and
condensers; maintenance and repair services in the field of
computerized cooling system equipment
Int. Cl. 40 Water and wastewater treatment services
First Use: January 31, 2003

78660604 29-JUN-2005 3235011 24-APR-2007 Int. Cl. 37 Chemical cleaning services for glass-lined reactor
vessels used in the chemical and pharmaceutical processing
industries; maintenance services for heat transfer systems and
condensers; maintenance and repair services in the field of
computerized cooling system equipment
Int. Cl. 40 Water and wastewater treatment services
First Use: January 31, 2003

78660445 29-JUN-2005 3243004 15-MAY-2007 Int. Cl. 2 Corrosion inhibitants in the nature of a coating for
use in cooling water systems
First Use: January 31, 2003

GE 78657663 24-JUN-2005 3242998 15-MAY-2007 Int. Cl. 2 Corrosion inhibitants in the nature of a coating for
use in cooling water systems
First Use: January 31, 2003

GE 78657483 24-JUN-2005 3248414 29-MAY-2007 Int. Cl. 1 Chemicals, biochemicals and reagents for use in
industry, science and research; chemical preparations, kits and
reagents for analysis or diagnosis used for scientific purposes,
namely, chemical preparations for cell separation and culture,
nucleic acid purification, nucleotides, fluorescent nucleotides,
oligonucleotides, peptides, proteins, amino acids, organic
molecules, and markers for dna/rna synthesis; reagents for
luminescence; reagents for gene expression quantification;
reagents for use with the polymerase chain reaction process;
reagents for use with the rolling circle amplification process;
reagents for cdna cloning and vectors, modifying and
restriction enzymes; reagents for labeling, sequencing and
fragment analysis of nucleic acids, proteins and custom
synthesis; reagents for recombinant protein expression
purification; chromatography media; reagents for
electrophoresis, bioinformatics, spectrophotometry and
fluorometry; radiochemicals for scientific research use;
reagents for scintillating proximity assays; high through put
screening assays for drug development; reagents for high

28732832.1 - 18 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 19 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

resolution laser fluorescence confocal microscopy; specialty


chemicals for use in industry, science and research; gases and
gas mixtures for industrial, research and scientific purposes;
chemical preparations and substances for use in the
manufacture of pharmaceutical products, diagnostic
preparations and substances; chemical test reagents, saline
solution and reagent-coated paper all for scientific and
laboratory use; fissionable chemical elements for scientific
research use; radioactive elements and isotopes for industrial,
scientific and research purposes; radioactive sources and
standards for use in radiographic techniques; radioactive
sources for use in non-destructive testing, purification and
sterilizing techniques; radionuclides for scientific research use;
chemicals and chemical compositions for use in the treatment
of water systems, wastewater treatment systems, cooling water
systems, boiler water and steam generating systems, boiler
condensate systems, fluid separation systems, water
clarification and dewatering in aqueous systems, conditioning
systems, gas cleaning systems, industrial process systems,
fuels and fuel processing systems, hydrocarbon and gas
processing systems, oil and gas processing and petrochemical
systems, and metal processing systems; chemical gasoline
additives and distillate fuel additives; chemical additives for
fuels used in turbine engines; bacteria cultures and nutrients
for wastewater and sludge treatment; polymeric chemicals
used to disperse particulate matter in steam generating
equipment; chemicals and chemical compositions as
antifoulants and demulsifiers in coke-making and by-product
operations of iron and steel industries
First Use: January 31, 2003

78660567 29-JUN-2005 3280635 14-AUG-2007 Int. Cl. 11 Fluid separation units for industrial use in a wide
variety of industries; fluid concentration units for industrial use
in a wide variety of industries; fluid recycling units for
industrial use in a wide variety of industries; polymeric
membrane material for use in the separation of fluids for a
wide variety of industries; filter apparatus used for filtering
solids from gases and liquids or filtering liquids from gases,
and for filtering one immiscible liquid from another for
industrial use in a wide variety of industries; spirally-wound
elements or cartridges contained within a tubular plastic sleeve
for concentrating products and removing impurities in fluid
treatment systems for industrial use in a wide variety of
industries; water conditioning units for residential purposes;
reverse osmosis modules and membranes therefore for
industrial use in a wide variety of industries; water purification
units and systems consisting of clarifiers, electro deionization
systems, condensate polishers, vacuum degasification units,
ultra filtration units, ultraviolet sterilizers, ion exchangers, acid
and caustic regeneration systems, reverse osmosis systems,
forced draft decarbonator units, filters, chemical feed systems
and bulk storage units, sold with automatic controls and
instruments to monitor operating parameters of the units and
systems electrochemical liquid purification units for use in the
industrial, commercial and municipal sectors

28732832.1 - 19 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 20 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

First Use: January 31, 2003

GE 78658647 27-JUN-2005 3280631 14-AUG-2007 Int. Cl. 11 Fluid separation units for industrial use in a wide
variety of industries; fluid concentration units for industrial use
in a wide variety of industries; fluid recycling units for
industrial use in a wide variety of industries; polymeric
membrane material for use in the separation of fluids for a
wide variety of industries; filter apparatus used for filtering
solids from gases and liquids or filtering liquids from gases,
and for filtering one immiscible liquid from another for
industrial use in a wide variety of industries; spirally-wound
elements or cartridges contained within a tubular plastic sleeve
for concentrating products and removing impurities in fluid
treatment systems for industrial use in a wide variety of
industries; water conditioning units for residential purposes;
reverse osmosis modules and membranes therefore for
industrial use in a wide variety of industries; water purification
units and systems consisting of clarifiers, electro deionization
systems, condensate polishers, vacuum degasification units,
ultra filtration units, ultraviolet sterilizers, ion exchangers, acid
and caustic regeneration systems, reverse osmosis systems,
forced draft decarbonator units, filters, chemical feed systems
and bulk storage units, sold with automatic controls and
instruments to monitor operating parameters of the units and
systems electrochemical liquid purification units for use in the
industrial, commercial and municipal sectors
First Use: January 31, 2003

77028245 24-OCT-2006 3292816 18-SEP-2007 Int. Cl. 7 Apparatus, equipment and instruments for the
generation of power, namely, electric generators and wind
powered electricity generators; turbines; turbines for power
generation; wind turbines for power generation; turbine
generating installations, namely, power generating
installations; engines for the generation of electricity; and parts
and fittings for all the aforesaid
Int. Cl. 37 Construction, installation, repair, replacement,
overhaul and maintenance of power plants, engines, turbines,
wind turbines, motors and apparatus, equipment and
instruments for the generation of power and electricity and
their component parts, fittings and accessories
Int. Cl. 42 Services, relating to wind and wind power, namely,
engineering services and professional technology consulting
services; design for others in the field of wind power;
industrial design services; design of power, wind power and
electric power generating equipment and installations
First Use: January 1, 2005

GE 77028249 24-OCT-2006 3296336 25-SEP-2007 Int. Cl. 7 Apparatus, equipment and instruments for the
generation of power, namely, electric generators and wind
powered electricity generators; turbines; turbines for power
generation; wind turbines for power generation; turbine
generating installations, namely, power generating
installations; engines for the generation of electricity; and parts
and fittings for all the aforesaid
Int. Cl. 37 Construction, installation, repair, replacement,
overhaul and maintenance of power plants, engines, turbines,

28732832.1 - 20 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 21 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

wind turbines, motors and apparatus, equipment and


instruments for the generation of power and electricity and
their component parts, fittings and accessories
Int. Cl. 42 Services relating to wind and wind power, namely,
engineering services and professional technology consulting
services; design for others in the field of wind power;
industrial design services; design of power, wind power and
electric power generating equipment and installations
First Use: January 1, 2005

78769157 08-DEC-2005 3304220 02-OCT-2007 Int. Cl. 9 Apparatus for electrophoresis not for medical
purposes; chromatography columns and pumps; apparatus for
conformations systems, namely computer hardware and
software for processing biological information; scintillation
counter to measure beta-emitting nuclides; imaging apparatus
for radioactive and luminescent emissions, namely cd cameras
and scanners; synthesis and purification integrated systems,
namely chromatography columns, cartridges, fraction
collectors, mixers, monitors, pumps, recorders and analysis
software; apparatus for micro arrays, namely probes, slides,
buffers, bacterial controls, racks and trays; laboratory
glassware; vials and micro vials; nicotine plates; computer
software for hospital operating room management; computer
software for critical care information management; industrial
process control software; computer software programs and
program manuals sold as a unit for use in factory management;
graphical user interface based computer programs for
controlling machines in industrial automation applications;
software for creating graphics displays and editing dynamic
data interfaces for real time graphics applications for industrial
and business applications; communications software for
connecting computer network users; industrial process
software for plastic injection molding; factory automation
software for control, monitoring, simulation, communications,
data logging and collection, and factory automation; software
to integrate manufacturing machine operations, control
processes, provide data for visualization, track problems and
generate production reports; packaged software for use in the
operation and programming of grinding machines in the
manufacturing industry; industrial process control hardware,
namely, computer monitors; laptop computers, ether net cards
and cables; computer networking hardware, memory cards;
microchips; microprocessors; computer network hubs,
switches and routers; computer displays and terminals;
computer white boards; system boards and processors;
industrial process controller featuring call control, operator
interface, gage interfaces and data collectors; manufacturing
execution systems and document management software; digital
signal processing products and systems, namely industrial
automation controls and programmable logic controllers;
machine tools, namely, an adaptive control product in the
nature of an external controller to optimize machine tool
cutting performance of rough and semi-rough cuts; power
supplies and mounting hardware; intrusion and burglar alarm
systems; security devices, namely, programming logic

28732832.1 - 21 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 22 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

computers, control panels, electronic intrusion detectors,


electronic glass break sensors, electronic vibration sensors,
magnetic contacts for use in security systems, electronic switch
plates, electronic motion sensors for alarm systems, electronic
motion sensitive switches, hardwire sirens, audio speakers,
electronic speaker drivers, access control and alarm monitoring
systems; fire, heat and smoke detecting and alarm units;
computer card operated access control systems; card readers,
card encoders, and encoded cards for use with card operated
access control systems; video cameras; video object
recognizers; video object trackers; video license plate readers;
video alarm verifiers; video face recognizers; video vehicle
recognizers; video traffic detectors; video access door
controllers; video intrusion detectors; processing hardware and
software that analyzes digital video images to automatically
extract, record and report intelligence, and remote video
monitoring systems for security and surveillance applications;
central video monitors; video recorders; cameras; closed
circuit video systems; closed circuit video system comprising
one or more cameras, and a camera housing; short range,
wireless, radio frequency transceivers; power line transceivers;
communication control hardware, namely keypad controllers,
matrix switchers, multiplexes, digital video recorders,
integrated pan-tilt-zoom domes, remote video controllers,
receivers, electronic alarm, management controls and triggers,
and video transmission devices in the nature of video
transmitters sold separately or as part of a system for operating
closed circuit cameras; personal digital assistant devices
configured for use by real estate professionals; fiber-optic
transmission systems, namely, fiber optic transmitters,
receivers and transceivers used in the transmission of video,
audio, and data signals over optical fiber; electrical switches;
electron mechanical locks; magnetic locks; electric keys;
handheld electronic hardware, namely handheld programmable
units and handheld computers for receiving, controlling,
storing, manipulating, displaying and transmitting data and for
operating electronic locks; electronic access cards and readers
and encoders therefor; magnetic access cards and readers and
encoders therefor; smart access cards and readers and encoders
therefor; proximity cards and readers and encoders therefor;
electronic key fobs and readers and encoders therefor; bar code
access cards and readers, encoders, access card lamination
machines not for home or office use; access keypads; radio
frequency tracking tags; tracking and control system
comprising one or more radio frequency tags, transceivers, and
sensors used to determine and monitor the location and
movement of tangible assets, inventory and individuals;
infrared sensors; computer hardware and software for facilities
management and controlling facility access systems and
components therefor, namely, control panels, access card
readers, and equipment and systems for video imaging, video
monitoring, digital hard drive recording, network transmission
and remote access; networked digital video storage servers for
access control and surveillance applications, alarm monitoring
and security; computer software and hardware for controlling

28732832.1 - 22 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 23 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

and operating security and access system comprising locks,


doors, access, and identification; devices and security
enclosures in the nature of electronic boxes safes for securing
keys; surveillance equipment sold individually as components
or together as a system comprising one or more surveillance
cameras, covert cameras, close circuit television cameras,
camera housings, camera mounts, camera lenses, video
monitors, video recorders, digital recorders, video storage
media, video switches, control panels, keypad controllers,
joystick controllers, transceivers, receivers, transmitters, signal
processors, multiplexes, matrix switches, controllers, control
panel housing, switch housing, transformers switches, splitters,
coaxial cables, connectors, motion detectors, microphones and
speakers; computer user interface software and control
software for managing security, fire and access systems;
electric locks; hand-held electronic computer and
communication hardware for receiving, controlling, storing,
manipulating, displaying and transmitting data for operating
electronic locks; pre-recorded magnetic data carriers featuring
identification and security information; data processing
software and computer hardware; power supplies, namely
batteries, voltage and current rectifiers, regulators and
transformers; control panels - namely, electronic apparatuses
adapted to electrically monitor a pre-determined activity and
activate a burglar alarm; siren speakers; and electronic siren
drivers - namely, tone generators and amplifiers adapted to be
used for sirens; computer software to control communication
hardware for operating and controlling closed circuit cameras;
switch units incorporating magnetically actuated reed switches
for use in burglary and fire sensing alarm systems, in industrial
position sensing apparatus, in revolution counters, in
equipment cabinet safety interlock systems, in industrial
position controlling apparatus, in electrical cables and in pump
and valve controlling apparatus and home security alarm
systems; electrical and electronic checking apparatus, namely
detectors, scanners and monitors for screening individuals,
baggage, and cargo for the presence of particular substances;
electrical and electronic checking apparatus, namely detectors,
scanners and monitors for screening individuals, baggage, and
cargo for the presence of explosives and/or narcotics;
detectors, scanners and monitors for detecting presence of
explosives and other contraband; time or condition sensing
apparatus for initiating and controlling regeneration or
backwash cycles for water treatment equipment; control valves
for water conditioning and water filtration equipment; bio
reactors for culturing cells; portable analytical instruments,
namely, a probe with a microprocessor based data conversion
logger for measurement of organic and inorganic chemicals in
water; filters and filter housings for laboratory use; fluid
separation apparatus for laboratory use; membrane filters for
laboratory use; silt density measuring device; de ionization
units for laboratory use; fluid flow control devices, namely,
pumps, valves, flow meters and regulators for laboratory use;
ozone monitors; laboratory equipment, namely, porous micro
titer plates for use in cell biology and other life science

28732832.1 - 23 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 24 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

applications; electronic water and process treatment controls,


namely, apparatus for use in the treatment of commercial and
industrial water systems, boiler water systems, cooling water
systems, and closed water systems, pulp and paper processing
systems, fuel processing systems, and metal processing
systems to analyze the chemistry of the system, determine the
proper treatment program, apply the desired treatment and
monitor the effectiveness of the treatment; computer software
for data management in the water treatment and pulp and paper
fields; electronic controllers used for processing information in
the water treatment and pulp and paper fields; apparatus for
use in industrial water systems to measure and control PH and
conductivity; electronic apparatus for feeding chemical to an
industrial, commercial or municipal water system in measured
amounts; laboratory testing equipment, namely, deposition and
corrosion rate testers; mobile laboratory equipped with
equipment and instrumentation to monitor and measure PH,
conductivity, and chromate concentration of industrial and
domestic waters, to conduct inorganic analysis of water and to
conduct microbiological testing of water
First Used: January 31, 2003

GE 78657993 24-JUN-2005 3303773 02-OCT-2007 Int. Cl. 7 Pumps, namely, centrifugal pumps, diaphragm
pumps, bellows pumps and process and transfer pumps; fluid
control devices, namely, pump control valves; regulators being
parts of machines; filter cartridges for various industrial
machines for filtration applications, namely for the filtration of
potable water, beer in the brewing industry, and other specialty
chemicals; machines for the feeding and application of
chemicals for industrial uses
First Use: January 31, 2004

GE 78658077 24-JUN-2005 3308707 09-OCT-2007 Int. Cl. 9 Apparatus for electrophoresis not for medical
purposes; chromatography columns and pumps; apparatus for
bioinformatics systems, namely, computer hardware and
software for processing biological information; scintillation
counter to measure beta-emitting nuclides; imaging apparatus
for radioactive and luminescent emissions, namely, CCD
cameras and scanners; synthesis and purification integrated
systems, namely, chromatography columns, cartridges, fraction
collectors, mixers, monitors, pumps, recorders and analysis
software; apparatus for microarrays, namely, probes, slides,
buffers, bacterial controls, racks and trays; laboratory
glassware; vials and microvials; microtitre plates; computer
software for hospital operating room management; computer
software for critical care information management; industrial
process control software; computer software programs and
program manuals sold as a unit for use in factory management;
graphical user interface based computer programs for
controlling machines in industrial automation applications;
software for creating graphics displays and editing dynamic
data interfaces for real time graphics applications for industrial
and business applications; communications software for
connecting computer network users; industrial process
software for plastic injection molding; factory automation
software for control, monitoring, simulation, communications,

28732832.1 - 24 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 25 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

data logging and collection, and factory automation; software


to integrate manufacturing machine operations, control
processes, provide data for visualization, track problems and
generate production reports; packaged software for use in the
operation and programming of grinding machines in the
manufacturing industry; industrial process control hardware,
namely, computer monitors; laptop computers, ethernet cards
and cables; computer networking hardware, memory cards;
microchips; microprocessors; computer network hubs,
switches and routers; computer displays and terminals;
computer whiteboards; system boards and processors;
industrial process controller featuring call control, operator
interface, gage interfaces and data collectors; manufacturing
execution systems and document management software; digital
signal processing products and systems, namely, industrial
automation controls and programmable logic controllers;
machine tools, namely, an adaptive control product in the
nature of an external controller to optimize machine tool
cutting performance of rough and semi-rough cuts; power
supplies and mounting hardware; intrusion and burglar alarm
systems; security devices, namely, programming logic
computers, control panels, electronic intrusion detectors,
electronic glassbreak sensors, electronic vibration sensors,
magnetic contacts for use in security systems, electronic switch
plates, electronic motion sensors for alarm systems, electronic
motion sensitive switches, hardwire sirens, audio speakers,
electronic speaker drivers, access control and alarm monitoring
systems; fire, heat and smoke detecting and alarm units;
computer card operated access control systems; card readers,
card encoders, and encoded cards for use with card operated
access control systems; video cameras; video object
recognizers; video object trackers; video license plate readers;
video alarm verifiers; video face recognizers; video vehicle
recognizers; video traffic detectors; video access door
controllers; video intrusion detectors; processing hardware and
software that analyzes digital video images to automatically
extract, record and report intelligence, and remote video
monitoring systems for security and surveillance applications;
central video monitors; video recorders; cameras; closed
circuit video systems; closed circuit video system comprising
one or more cameras, and a camera housing; short range,
wireless, radio frequency transceivers; power line transceivers;
communication control hardware, namely, keypad controllers,
matrix switchers, multiplexers, digital video recorders,
integrated pan-tilt-zoom domes, remote video controllers,
receivers, electronic alarm, management controls and triggers,
and video transmission devices in the nature of video
transmitters sold separately or as part of a system for operating
closed circuit cameras; personal digital assistant devices
configured for use by real estate professionals; fiber-optic
transmission systems, namely, fiber optic transmitters,
receivers and transceivers used in the transmission of video,
audio, and data signals over optical fiber; electrical switches;
electro mechanical locks; magnetic locks; electric keys;
handheld electronic hardware, namely, handheld

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programmable units and handheld computers for receiving,


controlling, storing, manipulating, displaying and transmitting
data and for operating electronic locks; electronic access cards
and readers and encoders therefor; magnetic assess cards and
readers and encoders therefor; smart access cards and readers
and encoders therefor; proximity cards and readers and
encoders therefor; electronic key fobs and readers and
encoders therefor; bar code access cards and readers, encoders,
access card lamination machines not for home or office use;
access keypads; radio frequency tracking tags; tracking and
control system comprising one or more radio frequency tags,
transceivers, and sensors used to determine and monitor the
location and movement of tangible assets, inventory and
individuals; infrared sensors; computer hardware and software
for facilities management and controlling facility access
systems and components therefor, namely, control panels,
access card readers, and equipment and systems for video
imaging, video monitoring, digital hard drive recording,
network transmission and remote access; networked digital
video storage servers for access control and surveillance
applications, alarm monitoring and security; computer
software and hardware for controlling and operating security
and access system comprising locks, doors, access, and
identification; devices and security enclosures in the nature of
electronic boxes safes for securing keys; surveillance
equipment sold individually as components or together as a
system comprising one or more surveillance cameras, covert
cameras, close circuit television cameras, camera housings,
camera mounts, camera lenses, video monitors, video
recorders, digital recorders, video storage media, video
switches, control panels, keypad controllers, joystick
controllers, transceivers, receivers, transmitters, signal
processors, multiplexers, matrix switches, controllers, control
panel housing, switch housing, transformers switches, splitters,
coaxial cables, connectors, motion detectors, microphones and
speakers; computer user interface software and control
software for managing security, fire and access systems;
electric locks; hand-held electronic computer and
communication hardware for receiving, controlling, storing,
manipulating, displaying and transmitting data for operating
electronic locks; pre-recorded magnetic data carriers featuring
identification and security information; data processing
software and computer hardware; power supplies, namely,
batteries, voltage and current rectifiers, regulators and
transformers; control panels - namely, electronic apparatuses
adapted to electrically monitor a pre-determined activity and
activate a burglar alarm; siren speakers; and electronic siren
drivers - namely, tone generators and amplifiers adapted to be
used for sirens; computer software to control communication
hardware for operating and controlling closed circuit cameras;
switch units incorporating magnetically actuated reed switches
for use in burglary and fire sensing alarm systems, in industrial
position sensing apparatus, in revolution counters, in
equipment cabinet safety interlock systems, in industrial
position controlling apparatus, in electrical cables and in pump

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and valve controlling apparatus and home security alarm


systems; electrical and electronic checking apparatus, namely,
detectors, scanners and monitors for screening individuals,
baggage, and cargo for the presence of particular substances;
electrical and electronic checking apparatus, namely, detectors,
scanners and monitors for screening individuals, baggage, and
cargo for the presence of explosives and/or narcotics;
detectors, scanners and monitors for detecting presence of
explosives and other contraband; time or condition sensing
apparatus for initiating and controlling regeneration or
backwash cycles for water treatment equipment; control valves
for water conditioning and water filtration equipment;
bioreactors for culturing cells; portable analytical instruments,
namely, a probe with a microprocessor based data conversion
logger for measurement of organic and inorganic chemicals in
water; filters and filter housings for laboratory use; fluid
separation apparatus for laboratory use; membrane filters for
laboratory use; silt density measuring device; deionization
units for laboratory use; fluid flow control devices, namely,
pumps, valves, flow meters and regulators for laboratory use;
ozone monitors; laboratory equipment, namely, porous
microtiter plates for use in cell biology and other life science
applications; electronic water and process treatment controls,
namely, apparatus for use in the treatment of commercial and
industrial water systems, boiler water systems, cooling water
systems, and closed water systems, pulp and paper processing
systems, fuel processing systems, and metal processing
systems to analyze the chemistry of the system, determine the
proper treatment program, apply the desired treatment and
monitor the effectiveness of the treatment; computer software
for data management in the water treatment and pulp and paper
fields; electronic controllers used for processing information in
the water treatment and pulp and paper fields; apparatus for
use in industrial water systems to measure and control PH and
conductivity; electronic apparatus for feeding chemical to an
industrial, commercial or municipal water system in measured
amounts; laboratory testing equipment, namely, deposition and
corrosion rate testers; mobile laboratory equipped with
equipment and instrumentation to monitor and measure PH,
conductivity, and chromate concentration of industrial and
domestic waters, to conduct inorganic analysis of water and to
conduct microbiological testing of water
First Use: January 31, 2003

GE 78658660 27-JUN-2005 3326351 30-OCT-2007 Int. Cl. 44 Consultancy and advisory services relating to
medical and diagnostic imaging; consultancy and advisory
services relating to diagnostic, prophylactic and therapeutic
properties of pharmaceuticals; medical information and
medical information advisory services; medical imaging and
medical imaging advisory services; medical diagnostic and
medical diagnostic advisory services
First Use: January 31, 2004

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78660472 29-JUN-2005 3336278 13-NOV-2007 Int. Cl. 7 Pumps, namely, centrifugal pumps, diaphragm
pumps, bellows pumps and process and transfer pumps for
water and wastewater treatment systems; regulators being parts
of machines; filter cartridges for various industrial machines
for filtration applications, namely, for the filtration of potable
water, beer in the brewing industry, and other specialty
materials; machines for the feeding and application of
chemicals for industrial uses
First Use: January 31, 2004

78660663 29-JUN-2005 3336280 13-NOV-2007 Int. Cl. 44 Consultancy services relating to medical and
diagnostic imaging; consultancy services relating to diagnostic,
prophylactic and therapeutic properties of pharmaceuticals;
medical information services; medical imaging services;
medical diagnostic services; advisory services related to all the
aforesaid
First Use: January 31, 2004

GE 78658593 27-JUN-2005 3336273 13-NOV-2007 Int. Cl. 5 Pre-filled vials containing medical diagnostic
reagents; pre-filled cylinders containing gases and gas
mixtures for medical use
Int. Cl. 10 Medical specimen collection vials; medical
cannulas; medical syringes; injection devices for
pharmaceuticals; disposable cartridge for holding and
transferring encapsulated radioisotope brachytherapy sources
for use in treating prostate and other cancers; pre-filled
cartridges containing contrast media for medical imaging;
infusion pumps for intravenous administration of fluids;
needles for medical purposes; implantable radiation therapy
devices consisting of encapsulated radioisotope brachytherapy
sources for use in treating prostate and other cancers; radiation
therapy delivery system consisting of radioactive seeds and a
bio-absorbable carrier assembly; cardiac output monitors;
bacteria filters for medical use; gas analyzers for medical
purposes; anesthesia record keeping and data management
systems and patient monitoring systems, namely, gas monitors,
pulse oximeters, multiparameter monitors, ECG monitors,
invasive and non-invasive blood pressure monitors,
neuromuscular transmission monitors, metabolic monitors and
spirometers for anesthesia, intensive care and diagnostic
applications; anesthesia machines and ventilators; intensive
care and anesthesia accessories for single patient use, namely,
gas sampling lines, airway adapters, breathing circuits,
spirometry sensors and tubes, tubes, water traps, pulse
oximetry sensors, non-invasive blood pressure cuffs,
intravenous flushing sets, anesthesia masks, carbon dioxide
absorbers, temperature probes, nebulizers; central nervous
system monitors; gastrointestinal tonometers
First Use: July 31, 2005

78805757 02-FEB-2006 3363508 01-JAN-2008 Int. Cl. 7 Boat engines, turbochargers for engines, and fuel
injectors; vehicle engine parts, namely, high frequency motor
spindles with high frequency electric converters and power
supply units, rocker arms, push rods, oil coolers, crankcase
breathers, oil tanks, ignition parts for internal combustion
engines, namely, points, radiators, water pumps, starter motors,

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pumps for cooling engines, engine bearings, engine camshafts,


engine rods and engine mufflers - First Use: December 31,
1977
Int. Cl. 9 Navigation apparatus for vehicles in the nature of
on-board computers; optical inspection apparatus for railway
system use; railway signals, namely, crossing warning
systems; high-frequency switching power supplies; electrical
engine controllers; and global positioning system (GPS)
consisting of computers, computer software, transmitters,
receivers, and network interface devices for the rail and transit
industries First Use: January 14, 2002
Int. Cl. 12 Locomotives and engines for land vehicles First
Use: December 31, 1900
Int. Cl. 41 Training in the use and operation of signaling and
crossing-warning systems for the rail and transit industries
First Use: January 14, 2002
Int. Cl. 42 Information technology consultation services in the
field of global railroad and transit industries; and remote
monitoring of aircraft engines, turbines, electrical equipment,
medical equipment, locomotives and accessories and
component parts of all the foregoing
First Use: January 14, 2002

GE 78805773 02-FEB-2006 3363509 01-JAN-2008 Int. Cl. 7 Boat engines, turbochargers for engines, and fuel
injectors; vehicle engine parts, namely, high frequency motor
spindles with high frequency electric converters and power
supply units, rocker arms, push rods, oil coolers, crankcase
breathers, oil tanks, ignition parts for internal combustion
engines, namely, points, radiators, water pumps, starter motors,
pumps for cooling engines, engine bearings, engine camshafts,
engine rods and engine mufflers - First Use: December 31,
1977
Int. Cl. 9 Navigation apparatus for vehicles in the nature of
on-board computers; optical inspection apparatus for railway
system use; railway signals, namely, crossing warning
systems; high-frequency switching power supplies; electrical
engine controllers; and global positioning system (GPS)
consisting of computers, computer software, transmitters,
receivers, and network interface devices for the rail and transit
industries - First Use: January 14, 2002
Int. Cl. 12 Locomotives and engines for land vehicles - First
Use: December 31, 1900
Int. Cl. 41 Training in the use and operation of signaling and
crossing-warning systems for the rail and transit industries -
First Use: January 14, 2002
Int. Cl. 42 Information technology consultation services in the
field of global railroad and transit industries; and remote
monitoring of aircraft engines, turbines, electrical equipment,
medical equipment, locomotives and accessories and
component parts of all the foregoing - First Use: January 14,
2002

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78660645 29-JUN-2005 3370329 15-JAN-2008 Int. Cl. 40 Consulting services in the fields of water treatment
for aqueous systems, cooling water systems, industrial boiler
water systems, industrial water and process systems,
consulting services in the fields of industrial fuel processing
system treatment, pulp and papermaking system treatment, and
metal and plastic processing system treatment; providing
information to others, over a global computer network, relating
to industrial water purification systems
Int. Cl. 42 Consulting services relating to chemical research;
research and testing on high through put screening assays for
drug development services; biotechnological services in the
nature of development of new technology for others in the
field of biotechnology; technical support services for factory
automation software, namely, providing maintenance of
computer software and providing periodic upgrades of the
software; custom design of security access systems; custom
design and consulting services in connection with the
configuration of computer systems used in applications
supporting fiber optic technology; technical support services,
namely, troubleshooting of problems with computer hardware,
video and electronic communication hardware and software;
technical consultation services for hardware and software used
in connection with security and access systems; technical
consultation services for surveillance cameras; custom design
services for others in the fields of security systems, access
systems, and tangible asset and inventory monitoring systems;
laboratory research and testing services for fluid separation
and membrane testing; engineering services in the fields of
aqueous systems, cooling water systems, industrial boiler
water systems, industrial water and process systems, industrial
fuel processing system treatment, pulp and papermaking
system treatment, and metal and plastic processing system
treatment; engineering services and technical support services
in the nature of troubleshooting problems and monitoring
network systems related to the design and configuration of
computer software and hardware systems to be used in the
treatment of aqueous systems and in the treatment of pulp and
papermaking systems, petroleum and petrochemical processing
systems, and metal and plastic finishing operations
First Use: January 31, 2003

GE 78658654 27-JUN-2005 3376484 29-JAN-2008 Int. Cl. 40 Consulting services in the fields of water treatment
for aqueous systems, cooling water systems, industrial boiler
water systems, industrial water and process systems,
consulting services in the fields of industrial fuel processing
system treatment, pulp and papermaking system treatment, and
metal and plastic processing system treatment; providing
information to others, over a global computer network, relating
to industrial water purification systems
Int. Cl. 42 Consulting services relating to chemical research;
research and testing on high through put screening assays for
drug development services; biotechnological services in the
nature of development of new technology for others in the
field of biotechnology; technical support services for factory
automation software, namely, providing maintenance of

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computer software and providing periodic upgrades of the


software; custom design of security access systems; custom
design and consulting services in connection with the
configuration of computer systems used in applications
supporting fiber optic technology; technical support services,
namely troubleshooting of problems with computer hardware,
video and electronic communication hardware and software;
technical consultation services for hardware and software used
in connection with security and access systems; technical
consultation services for surveillance cameras; custom design
services for others in the fields of security systems, access
systems, and tangible asset and inventory monitoring systems;
laboratory research and testing services for fluid separation
and membrane testing; engineering services in the fields of
aqueous systems, cooling water systems, industrial boiler
water systems, industrial water and process systems, industrial
fuel processing system treatment, pulp and papermaking
system treatment, and metal and plastic processing system
treatment; engineering services and technical support services
in the nature of troubleshooting problems and monitoring
network systems related to the design and configuration of
computer software and hardware systems to be used in the
treatment of aqueous systems and in the treatment of pulp and
papermaking systems, petroleum and petrochemical processing
systems, and metal and plastic finishing operations
First Use: January 31, 2003

78660434 29-JUN-2005 3386370 19-FEB-2008 Int. Cl. 1 Chemicals, biochemicals and reagents for use in
industry, science and research; chemical preparations, kits and
reagents for analysis or diagnosis used for scientific purposes,
namely, chemical preparations for cell separation and culture,
nucleic acid purification, nucleotides, fluorescent nucleotides,
oligonucleotides, peptides, proteins, amino acids, organic
molecules, and markers for DNA/RNA synthesis; reagents for
luminescence; reagents for gene expression quantification;
reagents for use with the polymerase chain reaction process;
reagents for use with the rolling circle amplification process;
reagents for cdna cloning and vectors, modifying and
restriction enzymes; reagents for labeling, sequencing and
fragment analysis of nucleic acids, proteins and custom
synthesis; reagents for recombinant protein expression
purification; chromatography media; reagents for
electrophoresis, bioinformatics, spectrophotometry and
fluorometry; radiochemicals for scientific research use;
reagents for scintillating proximity assays; high through put
screening assays for drug development; reagents for high
resolution laser fluorescence confocal microscopy; specialty
chemicals for use in industry, science and research; gases and
gas mixtures for industrial, research and scientific purposes;
chemical preparations and substances for use in the
manufacture of pharmaceutical products, diagnostic
preparations and substances; chemical test reagents, saline
solution and reagent-coated paper all for scientific and
laboratory use; fissionable chemical elements for scientific
research use; radioactive elements and isotopes for industrial,

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scientific and research purposes; radioactive sources and


standards for use in radiographic techniques; radioactive
sources for use in non-destructive testing, purification and
sterilizing techniques; radionuclides for scientific research use;
chemicals and chemical compositions for use in the treatment
of water systems, wastewater treatment systems, cooling water
systems, boiler water and steam generating systems, boiler
condensate systems, fluid separation systems, water
clarification and dewatering in aqueous systems, conditioning
systems, gas cleaning systems, industrial process systems,
fuels and fuel processing systems, hydrocarbon and gas
processing systems, oil and gas processing and petrochemical
systems, pulp and papermaking systems, metal and plastic
coating systems, and metal processing systems; chemical
gasoline additives and distillate fuel additives; chemical
additives for fuels used in turbine engines; bags of chemically-
treated water-absorbing granular materials for placement into
fuel tanks; test kit consisting of reagents used for determining
the presence of algae and active organic organisms in diesel
fuel; bacteria cultures and nutrients for wastewater and sludge
treatment; polymeric chemicals used to disperse particulate
matter in steam generating equipment; chemicals and chemical
compositions as antifoulants and demulsifiers in coke-making
and by-product operations of iron and steel industries
First Used: January 31, 2003

GE 78343029 18-DEC-2003 3399353 18-MAR-2008 int. CL. 7 AXIAL and centrifugal compressors; reciprocating
compressors; screw and vane compressors; rotary, vacuum,
electric, submersible and centrifugal pumps; turbo expanders,
namely, compressors; cng refueling machines for land vehicles
and industrial equipment and accessories and parts for all the
foregoing, namely, pumps, valves, fuel filters, filter casings,
distributor rotors, blades, bearings and mechanical seals; gas
turbines; steam turbines; steam condensers
Int. Cl. 11 Heat exchangers; chemical heavy wall reactors and
nuclear reactors and accessories and component parts thereof,
namely, heat pumps, steam valves and vales for regulating the
flow of gases and liquids
Int. Cl. 37 Installation, maintenance and repair services for
compressors and pumps, namely, machines, turbo expanders,
fuel pumps and fuel distribution equipment, cng refueling
equipment, gas turbines, steam turbines, air cooled heat
exchangers, steam condensers, heavy wall reactors and tubular
reactors; oil and gas pipeline maintenance and repair services;
oil well casing, tubing and drill pipe installation; rental of oil
and gas well drilling tools
Int. Cl. 42 Engineering services; technical consultation and
research services in the oil and gas industries; oil and gas
exploration services; geophysical exploration for the oil and
gas industries; analysis of oil and gas fields; oil and gas
prospecting, namely, well logging and testing; oil and gas well
testing; oil and gas pipeline inspection; remote monitoring and
diagnostic services for compressors and pumps, namely,
machines, turbo expanders, fuel pumps and fuel distribution
equipment, cng refueling equipment, gas turbines, steam

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turbines, air cooled heat exchangers, steam condensers, heavy


wall reactors and tubular reactors
First Use: December 31, 1996

78343326 19-DEC-2003 3406484 01-APR-2008 Int. Cl. 7 Axial and centrifugal compressors; reciprocating
compressors; screw and vane compressors; rotary, vacuum,
electric, submersible and centrifugal pumps; turboexpanders,
namely, air and electric compressors; CNG refueling machines
for land vehicles and industrial equipment and accessories and
parts for all the foregoing, namely, pumps, valves, fuel filters,
filter casings, distributor rotors, blades, bearings and
mechanical seals; gas turbines, steam turbines; steam
condensers
Int. Cl. 11 Heat exchangers; chemical heavy wall reactors and
nuclear reactors and accessories and component parts thereof,
namely, heat pumps, steam valves and valves for regulating the
flow of gases and liquids
Int. Cl. 42 Engineering services; technical consultation and
research services in the oil and gas industries; oil and gas
exploration services; geophysical exploration for the oil and
gas industries; analysis of oil and gas fields; oil and gas
prospecting, namely, well logging and testing; oil and gas well
testing; oil and gas pipeline inspection; remote monitoring and
diagnostic services for compressors, pumps, turboexpanders,
fuel pumps and fuel distribution equipment, CNG refueling
equipment, gas turbines, steam turbines, air cooled heat
exchangers, steam condensers, heavy wall reactors and tubular
reactors
First Use: December 31, 1996

GE 77424861 18-MAR-2008 3624272 19-MAY-2009 Int. Cl. 37 Consulting in the field of building construction
First Use: May 2007

77424898 18-MAR-2008 3624273 19-MAY-2009 Int. Cl. 37 Consulting in the field of building construction
First Use: May 2007

77184722 18-MAY-2007 3775123 13-APR-2010 Int. Cl. 7 Apparatus, equipment and instruments for the
generation of power, namely, electric generators and wind
powered electricity generators; turbines; turbines for power
generation; wind turbines for power generation; wind turbines
in association with wind farms; engines for the generation of
electricity; and structural parts therefore for all the aforesaid;
and solar-powered electricity generators First Use: May
2005
Int. Cl. 37 Construction, installation, repair, replacement,
overhaul and maintenance of power plants, engines, turbines,
wind turbines, motors and apparatus, equipment and
instruments for the generation of power and electricity and
their component parts, fittings and accessories - First Use:
November 2004

GE 77184621 18-MAY-2007 3775122 13-APR-2010 Int. Cl. 7 Apparatus, equipment and instruments for the
generation of power, namely, electric generators and wind
powered electricity generators; turbines; turbines for power
generation; wind turbines for power generation; wind turbines

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in association with wind farms; engines for the generation of


electricity; and structural parts therefor for all the aforesaid;
and solar-powered electricity generators First Use: May
2005
Int. Cl. 37 Construction, installation, repair, replacement,
overhaul and maintenance of power plants, engines, turbines,
wind turbines, motors and apparatus, equipment and
instruments for the generation of power and electricity and
their component parts, fittings and accessories - First Use:
November 2004

GE 85103320 09-AUG-2010 4176229 17-JUL-2012 Int. Cl. 9 Avionic sensor systems, namely, navigation systems;
computer hardware and software, for use with medical patient
monitoring equipment, for receiving, processing, transmitting
and displaying data; computer software for accessing
information directories that may be downloaded from the
global computer network; computer software for controlling
and managing patient medical information; electric control
devices for heating and energy management; electrical
apparatus, namely, charging stations for charging electric
vehicles; electrical power distribution units; electronic
signaling mechanism, namely, a train control system used in
the railway industry for detecting and controlling trains,
ground faults, broken rails, power failures, track switches and
lights
First Use: April 30, 2011

GE 85103345 09-AUG-2010 4176230 17-JUL-2012 Int. Cl. 37 Charging station services for electric vehicles;
installation of wiring and power supply equipment for
transmission and distribution of electricity suitable for electric
vehicle recharging stations
First Use: February 28, 2012

85103339 09-AUG-2010 4179979 24-JUL-2012 Int. Cl. 9 Avionic sensor systems, namely, navigation systems;
battery chargers; computer hardware and software, for use with
medical patient monitoring equipment, for receiving,
processing, transmitting and displaying data; computer
software for accessing information directories that may be
downloaded from the global computer network; computer
software for controlling and managing patient medical
information; electric control devices for heating and energy
management; electrical apparatus, namely, charging stations
for charging electric vehicles; electronic signaling mechanism,
namely, a train control system used in the railway industry for
detecting and controlling trains, ground faults, broken rails,
power failures, track switches and lights
First Use: April 30, 2011

85241246 14-FEB-2011 4191472 14-AUG-2012 Int. Cl. 10 Blood glucose monitors, analyzers, and meters;
blood glucose monitoring combination kits comprised of
lancets, control solution, and test strips all sold as a unit;
medical lancets
First Use: January 17, 2012

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85103775 10-AUG-2010 4206544 11-SEP-2012 Int. Cl. 37 Charging station services for electric vehicles;
installation of wiring and power supply equipment for
transmission and distribution of electricity suitable for electric
vehicle recharging stations
First Use: February 28, 2012

GE 85240536 11-FEB-2011 4214749 25-SEP-2012 Int. Cl. 10 Blood glucose monitors, analyzers, and meters;
blood glucose monitoring combination kits comprised of
lancets, control solution, and test strips all sold as a unit;
medical lancets
First Use: January 17, 2012

GE 85746803 05-OCT-2012 4467542 14-JAN-2014 Int. Cl. 35 Business consulting and information services;
consulting services in the field of energy usage management
and energy efficiency; energy usage management; energy
usage management information services
First Use: October 5, 2012

85764767 26-OCT-2012 4482261 11-FEB-2014 Int. Cl. 10 Incubators for babies; warming device for
stabilizing infant body temperature for medical purposes
First Use: March 24, 2000

GE 85764770 26-OCT-2012 4482262 11-FEB-2014 Int. Cl. 10 Incubators for babies; warming device for
stabilizing infant body temperature for medical purposes
First Use: March 24, 2000

85751767 11-OCT-2012 4482192 11-FEB-2014 Int. Cl. 44 Medical testing for diagnostic or treatment
purposes; providing a web site featuring medical information;
providing medical information; rental of medical equipment
First Use: October 11, 2012

GE 85751772 11-OCT-2012 4482193 11-FEB-2014 Int. Cl. 44 Medical testing for diagnostic or treatment
purposes; providing a web site featuring medical information;
providing medical information; rental of medical equipment
First Use: October 11, 2012

85747238 05-OCT-2012 4482171 11-FEB-2014 Int. Cl. 39 Consultation in the field of energy distribution;
technical consultation in the field of energy distribution and
storage; transportation consulting
First Use: October 5, 2012

GE 85746777 05-OCT-2012 4482156 11-FEB-2014 Int. Cl. 7 Electric coffee grinders; electric food blenders;
electric food grinders; electric food processors; electric food
slicers; electric juice extractors; mechanical mixing machines
First Use: October 5, 2012

GE 85746799 05-OCT-2012 4482157 11-FEB-2014 Int. Cl. 11 Convection ovens; cooking rings; domestic cooking
ovens; domestic electric appliances, namely, frypans; electric
cooking pots; electric cooktops; electric deep fryers; electric
hot plates; electric kettles; electric roasters; electric rotisseries;
electric slow cookers; electric stoves; electric tea pots; electric
toaster ovens; electric toasters; electric waffle irons; gas
cooktops; gas stoves; led and hid light fixtures; led luminaires;
solar collectors; solar heat collection panels; solar light
fixtures, namely, indoor and outdoor solar powered lighting
units and fixtures; solar thermal installations, namely, solar
thermal modules
First Use: October 5, 2012

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GE 85746807 05-OCT-2012 4482158 11-FEB-2014 Int. Cl. 37 Installation and maintenance of equipment and
systems in the field of transportation and traffic control;
maintenance and/or repair of traffic control equipment;
technical support services, namely, technical advice related to
the installation of advanced train control and traffic
supervision systems and subsystems; technical support
services, namely, technical advice related to the repair of
advanced train control and traffic supervision systems and
subsystems
First Use: October 5, 2012

GE 85746808 05-OCT-2012 4482159 11-FEB-2014 Int. Cl. 39 Consultation in the field of energy distribution;
technical consultation in the field of energy distribution and
storage; transportation consulting
First Use: October 5, 2012

85747228 05-OCT-2012 4482167 11-FEB-2014 Int. Cl. 11 Electric radiant heaters; gas water heaters;
humidifiers; hybrid water heater; led and hid light fixtures; led
luminaires; solar collectors; solar heat collection panels; solar
light fixtures, namely, indoor and outdoor solar powered
lighting units and fixtures; solar thermal installations, namely,
solar thermal modules; water heaters
First Use: October 5, 2012

85747229 05-OCT-2012 4482168 11-FEB-2014 Int. Cl. 12 Airplane propellers; railway bogies; railway cars;
railway couplings; screw propellers for vehicles; torque
converters for land vehicles; vehicle propellers
First Use: October 5, 2012

85747236 05-OCT-2012 4482170 11-FEB-2014 Int. Cl. 37 Installation, maintenance and repair of equipment
and systems in the field of transportation and traffic control;
maintenance and/or repair of traffic control equipment;
technical support services, namely, technical advice related to
the installation of advanced train control and traffic
supervision systems and subsystems; technical support
services, namely, technical advice related to the repair of
advanced train control and traffic supervision systems and
subsystems
First Use: October 5, 2012

85747233 05-OCT-2012 4482169 11-FEB-2014 Int. Cl. 35 Business consulting and information services;
consultation in the field of energy efficiency; consulting
services in the field of energy usage management and energy
efficiency; energy usage management; energy usage
management information services
First Use: October 5, 2012

GE 85746800 05-OCT-2012 4495725 11-MAR-2014 Int. Cl. 12 Airplane propellers; railway bogies; railway
couplings; screw propellers for vehicles; torque converters for
land vehicles; vehicle propellers
First Use: October 5, 2012

GE IDEA WORKS 85858696 25-FEB-2013 4507573 01-APR-2014 Int. Cl. 45 Licensing of intellectual property
First Use: March 18, 2013

GE 85746780 05-OCT-2012 4511675 08-APR-2014 Int. Cl. 9 Electronic sensors for monitoring energy utilization,
temperatures, positions, distances, speed, and acceleration;
electrical substations comprised of transformers, circuit

28732832.1 - 36 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 37 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

breakers, circuit switchers, voltage regulators, fuses,


capacitors, relays, rectifiers, and electric power converters;
power inverters; electronic control devices for energy
management; electronic automation products, namely,
electrical routers and electrical hubs; computer software and
hardware for energy management, energy distribution, energy
monitoring, and energy control; automated systems, namely,
software, hardware and communications devices for planning,
scheduling, controlling, monitoring and providing information
on transportation assets and parts thereof; automation systems,
namely, computer hardware for embedded operating systems
and pc based computer software, for monitoring specified
conditions and controlling respective innovative devices within
a designated area; computer hardware and software systems
for automated train control and traffic supervision, namely,
location tracking, vehicle monitoring, vehicle controlling,
dispatching, signaling, communication, and data transmission;
computer software for management of railway networks;
wireless communication devices for voice, data or image
transmission; traffic management equipment, namely, display
monitors, computers, auto compasses, and software to manage
traffic; industrial batteries for uninterrupted power supply;
computer software for interfacing and interacting with remote
control locomotives and locomotive hardware; led traffic and
rail signals; electronic fuel level gauges; automated fuel station
management systems comprising of computer operating
software, metered fuel pumps, rate control panels, fuel lines,
and dispensing nozzles for fueling land, marine and aircraft
vehicles; gas meters; electrical and scientific apparatus,
namely, general purpose high precision electric computer
controlled valves for use in high precision flow applications;
optical imaging apparatus for biological research; microscopes
and high accuracy electro-mechanical actuators; automated
dna optical scanners; automated microscopy systems
comprising microscopes, computer hardware and software for
high content imaging of microtiter plates, microscope slides
and biological samples; electromechanical hardware and
software systems comprising of computers, computer software,
electromechanical positioners for micro-positioning control, all
for use in the fields of photonics, digital flow control, analysis
of biological samples, semiconductor testing and inspection,
microscopy, optical scanning, and the field of scanning
systems for lasers; computer software for microscopy,
imaging, and informatics in the field of clinical and diagnostic
testing; electric actuators; electric valve actuators; precision
positioning systems comprised of optical indexers, namely, an
optical train with a camera and a filter wheel that enables
image data to be digitized, microscopy stages, electronic
control circuitry, motion control chassis, linear actuators,
screw actuators, linear slider, electric motors, and tunable
lasers for digitizing images in the fields of photonics, bio-
medical imaging, fluidics, mass flow valves, life sciences,
semiconductor manufacturing, and clinical diagnostics;
modular biologics manufacturing system used for growing,
purifying, concentrating, isolating, and packaging biological

28732832.1 - 37 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 38 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

materials in chemical, biotechnological and pharmaceutical


processes, consisting of a bioreactor used to grow cell cultures
and fermentations, a mechanical mixing machine for agitating
biological media, a filler machine used for packaging
pharmaceutical products, a separation machine used for
isolating, purifying and concentrating biological materials, and
connecting computer hardware and software; computer
hardware and software for use in monitoring and controlling
the treatment of industrial process systems, namely,
hydrocarbon refining and petrochemical processing systems, in
industrial processing plants and refineries in the chemical
petrochemical and processing industries
First Use: May 2, 2012

GE 85746797 05-OCT-2012 4511676 08-APR-2014 Int. Cl. 10 Medical diagnostic apparatus for displaying
diagnostic images, namely, spot film apparatus, x-ray image
intensifiers, x-ray fluoroscopes, mobile x-ray units, radio-
graphic film viewers, computerized tomography scanners,
nuclear resonance scanners, ultra sound scanners, magnetic
resonance scanners, positron emission tomography (pet)
scanners, and parts thereof and attachments thereto, namely,
tables and pads; medical devices, namely, valves to regulate
pressure of medical gases for the purpose of delivering
controlled and pressure limited ventilation of the lungs;
medical apparatus and instruments, namely, medical
respiratory apparatus to enhance breathing; sleep screening
apparatus and accessories thereto for use with medical
respiratory apparatus and with sleep monitoring devices,
namely, remote controls, remote alarms, and nasal masks;
medical apparatus for intravenous administration of fluids,
namely, fluid warmers; medical apparatus and surgical
devices, namely, face masks, breathing circuits, manual
resuscitators, pressure infusers used to control the pressure of
infusion bag fluids in administering intravenous fluids,
laryngoscopes, and anesthesia systems comprised of hoses,
breathing bags, and y-elbow fittings
First Use: November 30, 1993

85747214 05-OCT-2012 4515552 15-APR-2014 Int. Cl. 10 Medical devices, namely, valves to regulate
pressure of medical gases for the purpose of delivering
controlled and pressure limited ventilation of the lungs;
medical apparatus and instruments, namely, medical
respiratory apparatus to enhance breathing; sleep screening
apparatus and accessories thereto for use with medical
respiratory apparatus and with sleep monitoring devices,
namely, remote controls, remote alarms, and nasal masks;
medical apparatus for intravenous administration of fluids,
namely, fluid warmers; medical apparatus and surgical
devices, namely, face masks, breathing circuits, manual
resuscitators, pressure infusers used to control the pressure of
infusion bag fluids in administering intravenous fluids,
laryngoscopes, and anesthesia systems comprised of hoses,
breathing bags, and y-elbow fittings
First Use: December 15, 1999

28732832.1 - 38 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 39 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

86114358 08-NOV-2013 4522046 29-APR-2014 Int. Cl. 7 Clothes washing machines; dish washing machines
Int. Cl. 11 Baking ovens; clothes dryers; convection ovens;
cooking ovens; electric cooking ovens; electric cooking stoves;
electric ranges; gas cooking ovens; gas ranges; gas stoves;
microwave ovens for household purposes; refrigerators
First Use: October 1, 2013

85747207 05-OCT-2012 4568974 15-JUL-2014 Int. Cl. 9 Electronic sensors for monitoring energy utilization,
temperatures, positions, distances, speed, and acceleration;
electrical substations comprised of transformers, circuit
breakers, circuit switchers, voltage regulators, fuses,
capacitors, relays, rectifiers, and electric power converters;
power inverters; electronic control devices for energy
management; electronic automation products, namely,
electrical routers and electrical hubs; computer software and
hardware for energy management, energy distribution, energy
monitoring, and energy control; automated systems, namely,
software, hardware and communications devices for planning,
scheduling, controlling, monitoring and providing information
on transportation assets and parts thereof; automation systems,
namely, computer hardware for embedded operating systems
and pc based computer software, for monitoring specified
conditions and controlling respective innovative devices within
a designated area; computer hardware and software systems
for automated train control and traffic supervision, namely,
location tracking, vehicle monitoring, vehicle controlling,
dispatching, signaling, communication, and data transmission;
computer software for management of railway networks;
wireless communication devices for voice, data or image
transmission; traffic management equipment, namely, display
monitors, computers, auto compasses, and software to manage
traffic; industrial batteries for uninterrupted power supply;
computer software for interfacing and interacting with remote
control locomotives and locomotive hardware; led traffic and
rail signals; electronic fuel level gauges; automated fuel station
management systems comprising of computer operating
software, metered fuel pumps, rate control panels, fuel lines,
and dispensing nozzles for fueling land, marine and aircraft
vehicles; gas meters; electrical and scientific apparatus,
namely, general purpose high precision electric computer
controlled valves for use in high precision flow applications;
optical imaging apparatus for biological research; microscopes
and high accuracy electro-mechanical actuators; automated
DNA optical scanners; automated microscopy systems
comprising microscopes, computer hardware and software for
high content imaging of microtiter plates, microscope slides
and biological samples; electromechanical hardware and
software systems comprising of computers, computer software,
electromechanical positioners for micro-positioning control, all
for use in the fields of photonics, digital flow control, analysis
of biological samples, semiconductor testing and inspection,
microscopy, optical scanning, and the field of scanning
systems for lasers; computer software for microscopy,
imaging, and informatics in the field of clinical and diagnostic
testing; electric actuators; electric valve actuators; precision

28732832.1 - 39 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 40 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

positioning systems comprised of optical indexers, namely, an


optical train with a camera and a filter wheel that enables
image data to be digitized, microscopy stages, electronic
control circuitry, motion control chassis, linear actuators,
screw actuators, linear slider, electric motors, and tunable
lasers for digitizing images in the fields of photonics, bio-
medical imaging, fluidics, mass flow valves, life sciences,
semiconductor manufacturing, and clinical diagnostics;
modular biologics manufacturing system used for growing,
purifying, concentrating, isolating, and packaging biological
materials in chemical, biotechnological and pharmaceutical
processes, consisting of a bioreactor used to grow cell cultures
and fermentations, a mechanical mixing machine for agitating
biological media, a filler machine used for packaging
pharmaceutical products, a separation machine used for
isolating, purifying and concentrating biological materials, and
connecting computer hardware and software; computer
hardware and software for use in monitoring and controlling
the treatment of industrial process systems, namely,
hydrocarbon refining and petrochemical processing systems, in
industrial processing plants and refineries in the chemical
petrochemical and processing industries
First Use: May 2, 2012

GE 85746835 05-OCT-2012 4653368 09-DEC-2014 Int. Cl. 40 Manufacturing services for others in the field of
biotechnology and pharmaceuticals - First Use: April 30, 2004
Int. Cl. 42 Technology supervision and inspection in the field
of energy distribution networks; metering and monitoring
electric power consumption for electric power providers;
scientific research in the fields of energy transfer, energy
distribution, energy generation and energy storage; monitoring,
diagnostic, and control services for operation failure detection
of electricity generation, transmission and distribution systems,
namely, real-time fault detection and isolation; research and
development services in the field of biotechnology and
pharmaceuticals; computer programming services; computer
software design and analysis services; computer consultation
services; maintenance and installation of computer software;
computer systems and network analysis and design services;
medical diagnostic laboratory services performed for third
parties - First Use: April 30, 2004
Int. Cl. 44 Medical diagnostic image analysis services,
namely, static imaging telepathology combined with cell
image analysis for the purpose of diagnosing cancer and
disease, provided via a password-protected communication
connection on the internet - First Use: December 31, 2010

85747256 05-OCT-2012 4653370 09-DEC-2014 Int. Cl. 40 Manufacturing services for others in the field of
biotechnology and pharmaceuticals - First Use: April 30, 2004
Int. Cl. 42 Technology supervision and inspection in the field
of energy distribution networks; metering and monitoring
electric power consumption for electric power providers;
scientific research in the fields of energy transfer, energy
distribution, energy generation and energy storage; monitoring,
diagnostic, and control services for operation failure detection
of electricity generation, transmission and distribution systems,

28732832.1 - 40 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 41 of 54

Mark Serial No. Filing Date Reg. No. Reg. Date Goods and Services

namely, real-time fault detection and isolation; research and


development services in the field of biotechnology and
pharmaceuticals; computer programming services; computer
software design and analysis services; computer consultation
services; maintenance and installation of computer software;
computer systems and network analysis and design services;
medical diagnostic laboratory services performed for third
parties First Use: April 30, 2004
Int. Cl. 44 Medical diagnostic image analysis services,
namely, static imaging telepathology combined with cell
image analysis for the purpose of diagnosing cancer and
disease, provided via a password-protected communication
connection on the internet - First Use: December 31, 2010

21. All of the registrations for the GE Trademark in paragraph 20 are valid and

subsisting.

22. Most of the registrations listed in paragraph 20 are incontestable pursuant

to 15 U.S.C. 1065.

GES TURBINES AND CONTROL SYSTEMS

23. GE, either directly or through its licensee, also offers many different

products and services relating to gas and steam turbines, including control systems which

are comprised of boards and other parts, which are offered and sold in connection with

the GE Trademark.

24. GEs turbines and control systems provide comprehensive, connected plant

automation and are utilized in a wide variety of critical plants, including oil & gas, wind,

hydro, thermal and nuclear facilities.

25. The control systems are an extremely important component in the operation

of gas turbines and steam turbines.

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Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 42 of 54

26. GEs turbine control systems are designed as a complete integrated control,

protection, and monitoring system for generator and mechanical drive applications of gas

and steam turbines.

27. GEs control systems provide a platform for integrating all power island

and balance-of-plant controls. The hardware and software for these systems are designed

with close coordination between GEs turbine design engineering and controls

engineering to insure the control system provides the optimum turbine performance and

provide a true system solution.

28. GE control components are designed to ensure fail-safe operation; in

other words, if there is a failure of a control component, that will cause the unit that it is

controlling to shut down safely.

29. If a control component is not designed properly, or is degraded or inferior,

and that component fails, it can cause the gas turbine or steam turbine to shut down in an

unsafe manner or not shut down at all, which could cause damage or even injury.

30. Over the years, GE has introduced and used the following versions of the

Mark-branded control systems for gas and steam turbines: Mark I, Mark II, Mark III,

Mark IV, Mark V, Mark VI and Mark VIe. Attached hereto as Exhibit A is a

representative Mark VIe brochure.

31. Some third parties properly and legally repair and sell refurbished and used

parts for GEs control systems but unlike GTC without improperly asserting or

implying that the parts are new or that the company is authorized, licensed, affiliated or

28732832.1 - 42 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 43 of 54

otherwise endorsed or approved by GE. That is, those third parties properly and

accurately promote and advertise their product as used and refurbished, not new and

unmodified, as GTC falsely does.

GTC AND ITS UNLAWFUL ACTIVITIES

32. Upon information and belief, GTC was established in 2001 to supply,

among other products, GE control systems and parts to operators who did not want to

upgrade their legacy GE systems.

33. GTC is not affiliated with or sponsored by GE and has not been authorized

by GE to use the GE Trademark.

34. GTC is not an authorized, licensed distributor of GE.

35. Upon information and belief, GTC is not just repairing and selling GE

replacement parts in a manner that would otherwise be permitted under the law, like other

third parties lawfully do. Rather, GTC it is engaged in the following unauthorized,

impermissible, and illegal activities.

36. GTC infringes and counterfeits the GE Trademark by modifying used GE

products and selling them as new GE products.

37. GTC infringes and counterfeits the GE Trademark by using the following

trademarked slogan that incorporates GEs GE Trademark: The Ultimate Resource for

GE Speedtronic Solutions.

38. GTC infringes and counterfeits the GE Trademark by commissioning and

using labels and packaging that contain counterfeit versions of the GE Trademark.

28732832.1 - 43 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 44 of 54

39. Upon information and belief, GTC has purchased used GE control panels

through numerous means, including but not limited to making purchases off the Internet,

acquiring plant samples, and buying surplus units from operators.

40. Upon information and belief, GTC maintains a large inventory of used GE

controls systems parts at GTCs headquarters and possibly other locations.

41. Upon information and belief, GTC receives customer requests for new

control systems parts, even though GTC is not in a position to sell new GE control

systems for the Mark V and Mark VI as it is not an authorized, licensed GE distributor to

do so.

42. Upon information and belief, GTC washes, cleans, paints, and modifies the

used GE control system parts and in many cases sells them to customers falsely

representing that the parts are new, unmodified, and pristine.

43. Upon information and belief, in some cases the used GE control parts that

GTC is falsely selling as new are damaged, but GTC cleans the parts and applies paint or

labels to cover the damage.

44. Upon information and belief, to further its infringing conduct, GTC has

counterfeit labels and packaging made so that the used and refurbished parts GTC sells

look the same as new GE products.

45. Upon information and belief, GTC has commissioned a company called

Mr. Sign located at 590 Tuckahoe Road, Yonkers, NY to fabricate fake new

28732832.1 - 44 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 45 of 54

nameplates and labels with the GE Trademark and Logo on them, which GTC then

affixes to the refurbished GTC products to make them look like new GE products.

46. Upon information and belief, GTC at times places these plates or labels

over parts of GTCs used control consoles or boards to cover damage, including burns or

scratched areas, in order to conceal the fact that the parts are used.

47. Upon information and belief, GTC has also commissioned a supplier to

manufacture cardboard boxes with the GE Trademark and Logo (again without GEs

authorization), so that when GTC ships the infringing and counterfeit GTC product it can

do so in a counterfeit box that looks new.

48. Upon information and belief, in connection with its goods and services,

GTC has made false claims in its commercial advertising, promotions, and other

communications to customers and potential customers by falsely stating or implying that

GTC is an official distributor of GE.

49. Upon information and belief, in connection with its goods and services,

GTC has made false claims in its commercial advertising, promotions, and other

communications to customers and potential customers by falsely stating or implying that

the GE control boards and parts GTC is selling are new and unmodified, when in fact

they are used, refurbished and modified.

50. Upon information and belief, in connection with its goods and services,

GTC has made false claims in its commercial advertising, promotions, and other

communications to customers and potential customers by falsely stating or implying that

28732832.1 - 45 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 46 of 54

GTC is selling a newer model product, which in fact it is selling an older model products

(e.g., GTC has told customers they are getting a Mark VIe or Mark VI product when in

fact the customer is buying a Mark IV product or has told customers they are getting a

Mark II product when in fact the customer is buying a Mark I product, etc.).

51. Through GTCs commercial advertising and promotion, GTC has

intentionally misrepresented the nature, qualities, and characteristics of its goods,

services, and commercial activities.

52. Through GTCs conduct, GTC has intentionally confused customers as to

the source or affiliation of GTCs goods and services.

53. The GE Trademark has priority over GTCs infringing and counterfeiting

use of GE.

54. The GE Trademark is strong.

55. The appearance of GE (and the GE logo) that GTC uses is the same as, or

a counterfeit of, the GE Trademark.

56. The goods and services that GTC markets and sells in connection with

GE (and the GE logo) are the same or similar as the goods and services that GE sells in

connection with the GE Trademark.

57. Upon information and belief, the trade channels through which GTC

markets and sells its products and service in connection with GE (and the GE logo) are

the same or similar trade channels through which GE markets and sells GEs goods and

services in connection with the GE Trademark.

28732832.1 - 46 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 47 of 54

58. Upon information and belief, GTCs products and services sold in

connection with GE (and the GE logo) are marketed and sold nationwide in the U.S.

(and internationally) to many of the same potential customers and customers to which GE

sells authentic GE products and services.

59. As a result of GEs enormous investment in and use of the GE Trademark,

the GE Trademark has become famous.

60. The GE Trademark became famous long before GTC began using GE.

61. GTCs conduct is likely to cause dilution of the famous GE Trademark,

particularly GTCs products and services offered in connection with GE that do not

meet the quality standards of the GE Trademark and either fail to work or fail in a way

that causes damage.

THE EFFECT OF GTCS UNLAWFUL ACTIVITIES

62. GTCs sale of its goods and services in the United States using the GE

Trademark constitutes use of the GE Trademark in commerce. GTCs sales of its goods

and services using GTCs GE Trademark in New York constitute transacting business in

New York.

63. GTCs unauthorized use of GTCs GE Trademark is likely to cause

confusion, to cause mistake, and/or to deceive customers and potential customers of the

parties, at least as to some affiliation, connection or association of GTC with GE, or as to

the origin, sponsorship, or approval of GTCs goods and services.

28732832.1 - 47 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 48 of 54

64. GTCs unauthorized use of the GE Trademark falsely designates the origin

of its goods and services, and falsely and misleadingly describes and represents facts with

respect to GTC and its goods and services.

65. GTCs unauthorized use of the GE Trademark is likely to cause dilution.

66. GTCs unauthorized use of the GE Trademark enables GTC to trade on and

receive the benefit of goodwill GE built up at great labor and expense over many years,

and to gain acceptance for its goods and services not solely on their own merits, but on

the reputation and goodwill of GE, its GE Trademark and its goods and services.

67. GTCs false statements outlined above that misrepresent the nature,

characteristics, and qualities of GTCs products and services has caused and is causing

harm to GE and relevant purchasers.

68. GTCs unauthorized and illegal conduct outlined above has caused and is

causing GE irreparable harm, as it removes from GE the ability to control the nature and

quality of goods and services provided under the GE Trademark and places the value

reputation and goodwill of GE in the hands of GTC, over whom GE has no control. In

addition, GTCs unauthorized and illegal conduct has caused and continues to cause

irreparable damage to GE as a result of customers who are deceived and confused or who

are likely to be deceived or confused as to the origin, association, connection, or

sponsorship of GTCs products and services offered in connection with GTCs GE

Trademark.

28732832.1 - 48 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 49 of 54

69. GTCs unauthorized and illegal conduct has the potential to cause GEs

customers, and the general public, harm to the extent GTCs products and services do not

meet the necessary quality control standards used by GE or to the extent GTCs

deception causes a customer to use a defective control board or control board that is

different from the control board the customer actually needs to safely control and operate

its turbines and the subsequent failure of the control board causes a gas turbine to fail.

70. Unless the acts of the GTC are restrained and enjoined by this Court, they

will continue, and they will continue to cause irreparable injury to GE and to the public

for which there is no adequate remedy at law.

71. GTC has engaged in the conduct described above willfully, intentionally,

deliberately, knowingly, maliciously, wantonly, oppressively, and with full knowledge

and in reckless disregard of the obvious and inevitable injurious consequences of GTCs

conduct. In using the GE Trademark, GTC has a bad-faith intent to trade on and profit

from GEs vast goodwill and reputation and to confuse and mislead the public.

COUNT I: FEDERAL REGISTERED TRADEMARK


INFRINGEMENT AND COUNTERFEITING

72. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

73. The acts of GTC complained of herein constitute infringement and

counterfeiting of GEs federal registered GE Trademark in violation of 15 U.S.C.

1114(1).

28732832.1 - 49 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 50 of 54

74. In view of the egregious nature of GTCs infringement, this is an

exceptional case within the meaning of 15 U.S.C. 1117(a).

COUNT II: FEDERAL DILUTION

75. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

76. GTCs use in commerce of the GE Trademark causes and is likely to cause

dilution of the distinctive quality of GEs famous GE Trademark, as well as tarnishment,

in violation of the Federal Trademark Dilution Act, 15 U.S.C. 1125(c).

COUNT III: FEDERAL UNFAIR COMPETITION

77. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

78. The acts of GTC complained of herein constitute unfair competition in

violation of the Lanham Act, 15 U.S.C. 1125(a).

COUNT IV: FEDERAL FALSE ADVERTISING

79. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

80. The acts of GTC complained of herein constitute false advertising in

violation of the Lanham Act, 15 U.S.C. 1125(a)(1)(B).

COUNT V: NEW YORK COMMON LAW TRADEMARK INFRINGEMENT

81. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

28732832.1 - 50 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 51 of 54

82. The acts of GTC complained of herein constitute trademark and trade name

infringement in violation of the common law of the State of New York.

COUNT VI: NEW YORK STATE LAW DILUTION

83. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

84. GTCs use in commerce of the GE Trademark has caused and is likely to

cause dilution of the distinctive quality of GEs GE Trademark, in violation of N.Y. Gen.

Bus. Law 360-l.

COUNT VII: VIOLATION OF NEW YORK LAW ON CONSUMER


PROTECTION FROM DECEPTIVE ACTS AND PRACTICES

85. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

86. The acts of GTC complained of herein constitute deceptive trade practices

in violation of N.Y. Gen. Bus. Law 349.

87. GTC has willfully engaged in the deceptive trade practices knowing them

to be deceptive. GE should be awarded treble damages and its reasonable attorneys fees

pursuant to New York General Business Law 349(h).

COUNT VIII: NEW YORK COMMON LAW UNFAIR COMPETITION

88. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

28732832.1 - 51 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 52 of 54

89. The acts of GTC complained of herein constitute unfair competition in

violation of the common law of New York.

COUNT IX: UNJUST ENRICHMENT

90. GE realleges and incorporates all preceding paragraphs, as if fully set forth

herein.

91. The acts of GTC complained of herein constitute unjust enrichment of GTC

at GEs expense.

PRAYER FOR RELIEF

WHEREFORE, GE respectfully prays that the Court enter judgment in favor of

GE against GTC as follows:

A. Grant injunctive relief against GTC and its agents, servants, employees,

attorneys, successors, licensees, parents, subsidiaries, affiliates, and assigns,

and anyone acting in concert or privity with GTC, jointly and severally,

from engaging in the wrongful acts complained of herein.

B. Direct GTC to file with the Court and serve on GE within thirty (30) days

after the service on GTC of such injunction a report in writing under oath

setting forth in detail the manner and form in which GTC has complied

with the injunction;

C. Declare that GTCs infringement and other wrongful acts herein alleged be

determined deliberate, willful, and in conscious disregard of GEs rights;

D. Award GE of all of its actual damages caused by GTCs infringement and

other wrongful acts;

28732832.1 - 52 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 53 of 54

E. Award GE of all of GTCs gross and net sales, revenues, and profits

received or derived by GTC or its affiliates from its use of the GE

Trademark or any other word, image, or logo likely to cause confusion with

the GE Trademark pursuant to 15 U.S.C. 1117, 1125, and other

applicable federal law;

F. Order GTC to deliver to the Court for impoundment and destruction any

and all control boards, parts, signs, plates, boxes, manuals, advertising,

circulars, price lists, signs, banners, business stationary, prints, packages,

labels, containers, freights, cartons, receptacles, wrappers, art work, and

other materials in its possession or custody or under its control that infringe

GEs GE Trademark;

G. Award statutory damages or treble damages to GE, together with costs,

interest, and reasonable attorneys fees as permitted by 15 U.S.C. 1117(a-

c) and New York General Business Law 349(h);

H. Award GE its costs and reasonable attorneys fees in prosecuting this action

as permitted by New York General Business Law 349(h);

I. Award pre-judgment and post-judgment interest as allowed by law; and

J. Grant GE such other equitable and legal relief as the Court deems just and

proper.

28732832.1 - 53 -
Case 7:17-cv-07188 Document 1 Filed 09/21/17 Page 54 of 54
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 1 of 9
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 2 of 9
GE Energy Connections

*
Mark VIe
Integrated Control Solutions
for Today's Connected Plant
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 3 of 9

Advanced performance,
interoperability, and
availability for today's
connected plant
GE's distributed control system solutions are easily
adapted to the constantly evolving requirements of
industries such as power generation, oil and gas, and
chemical processing.
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 4 of 9

For businesses that are A Complete Solution


dependent on decades The Mark VIe control system is a flexible The Mark VIe Distributed Control
platform used in multiple applications. It Solution delivers a seamless,
of uninterrupted machine features high-speed, networked input/ integrated, balance of plant
service, a redundant output (I/O) for simplex, dual, and triple solution designed to perform in
control system that allows redundant systems. Ethernet based I/O the extreme conditions found in
can easily be distributed plant wide across industries such as:
for online maintenance all balance of plant applications. Industry-
is critical. GEs distributed Power Generation
standard Ethernet communications are
control solutions are used for I/O, controllers, and supervisory Oil and Gas
interface to operator and maintenance
designed to provide the stations, as well as third-party systems.
Chemical and Process

high level of availability The ControlST* software suite is used with


Pulp and Paper

and flexibility necessary Mark VIe controls and related systems Mining and Minerals Engineering

for todays most for programming, configuration, trending, Renewables


and analyzing diagnostics. The Distributed
demanding applications. Control Solution (DCS) function library The Mark VIe Distributed
accelerates creation of balance of plant Control Solution offers:
Downtime is one of the greatest
application logic. During runtime the A proven solution
detriments to productivity and
system provides quality, time-coherent
profitability. It is imperative to have Flexible and highly scalable
data in the controllers and at the plant
a system in place that provides only architecture
level for effectively managing control
the highest levels of system reliability system equipment. Enhanced productivity
and availability at all times. To meet and efficiency
Safety is delivered through the Mark VIeS
the needs of todays connected Safety Management Solution. Based on Seamless integration with
industries, GE has combined its the Mark VIe platform, the Mark VIeS is primary control systems
leadership of the Industrial Internet a stand-alone safety control system for Comprehensive design
with its rich history of process control safety-critical applications that conform to and integration
to deliver the Mark VIe Distributed the IEC-61508 standard. The ControlST
Robust maintenance and
Control System (DCS). software suite simplifies maintenance
services offering
while maintaining a unique set of certified
hardware and software blocks.
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 5 of 9

A Comprehensive Approach Flexible and Scalable


for Continuous Operations
Scalable redundancy
Our tightly integrated distributed control solutions
Redundancy is a critical feature in a distributed control system
deliver robust process control with seamless
design, enabling continuous process operation during system
connectivity and automated real-time information
maintenance or repair. The Ethernet backbone of the Mark VIe
management to help you maximize uptime Distributed Control Solution allows each segment of the system
and productivity. to be configured with different levels of redundancy.
A proven solution Controllers can be : Simplex, Dual, or TMR
GE brings decades of domain expertise to the Mark VIe IO network (IONet) Communications can be: Simplex, Dual, or TMR
Distributed Control Solution. The Mark series of controllers has I/O Modules can be: Simplex or TMR
earned a reputation for superior running reliability in thousands
of power generation and infrastructure systems installed Every application has different requirements for redundancy
globally. These proven philosophies are at the heart of the depending on the criticality of the process. The Mark VIe control
integrated Mark VIe Distributed Control Solution. platform provides a wide range of redundancy options for local and
As a global leader in automation and control, GE provides cyber remote distribution.
security management as an inherent feature of the Mark VIe
Communications to basic process control system
control family. It assists with the implementation of an effective
security policy to ensure system confidentiality, integrity, Industry-standard integration tools are available as plant network
availability, and providing real-time change monitoring and gateways and peer-to-peer controller communications for basic
audit capabilities. process control systems (BPCS).

The proven and reliable Mark VIe control platform helps keep Shared IO network with GE Mark VIe BPCS
operations safe and secure through:
Shared IONet permits sharing of data between Mark VIeS I/O
Connected: 100% Ethernet at all levels modules and Mark VIe basic process controllers using an Ethernet
Flexible: Distributed or centralized I/O input/output network. This enables use of a single set of field
instruments for both safety and basic process control, reducing the
Scalable: Designed to accommodate evolving systems
installation and operating costs of your distributed control system.
and applications
Reliable: Configure for simplex, dual, or triple Reliability in harsh environments
redundant operation GE understands that distributed control systems dont just reside in
High Performance: Local process on each module, clean rooms. Thats why the Mark VIe Distributed Control Solution
computing power grows as system expands provides high performance in the extreme conditions found in many
process environments. The processors, network switches, and I/O
Rugged: Hardware rated up to 65C
components are approved for hazardous location, Class 1, Division 2
Secure: Achilles Level 1 certification and the Mark VIe platform can operate in temperatures ranging
from -30 to -65 C without fans or other external cooling. That
means less downtime for your operations.
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 6 of 9

Lifecycle Management Functional safety lifecycle


management support
and Support
For safety applications, Mark VIeS
Safety Management Solution utilizes the
Mark VIe product lifecycle
exSILentia Safety Lifecycle Management
management
Tool to analyze safety instrumented
The Ethernet-based distributed functions (SIFs) and calculate the
architecture of the Mark VIe Distributed safety parameters required for specific
Control Solution enhances connectivity applications. This software helps customers
and improves lifecycle management. It achieve a new level of consistency and
utilizes safe peer-to-peer Ethernet productivity in the design of safety systems.
between controllers and I/O to deliver
When analyzing a Safety Instrumented
enhanced performance and simplify
Function (SIF) with the exSILentia tools,
system design. IONet switches are
the entire SIF is evaluated, encompassing
engineered by GE for long life, extreme
sensors, Logic Solver and Final Element.
environments, and peak performance.
The functional safety parameters for the
Enhanced Productivity Using 100 MB Ethernet at all levels with
Mark VIeS components are incorporated
execution speeds upwards of 40ms,
and Efficiency MarkVIe utilizes safe peer-to-peer
into the logic solver portion of the Exida
safety equipment database, enabling
connections between controllers and I/O
Sophisticated application automation the tools to include these components
to deliver enhanced performance and
tools and seamless data integration in calculating the safety and operational
simplify system design. Hot swap
between the control system, HMI and characteristics for a SIF.
capabilities allow for system maintenance
enterprise Manufacturing Execution
without requiring system re-start or
Systems (MES) enable process efficiencies
configuration downloads, maximizing
during project execution to reduce
process and plant uptime.
delivered cost and improve quality.
Enhanced software usability features
help maintain a cohesive control system Local Network:
strategy across your enterprise.
Field
Controller Switch I/O Module Device

Cat 5 Cat 5 Field Wire


100m (328) 100m (328) 300m(984)
Integration with Basic
Process Control Systems Extended Network:
GE understands the importance of Controller Switch Switch Field
I/O Module
Device
seamless integration between your DCS,
safety and basic process control solutions. Cat 5 Cat 5 Field Wire
The Mark VIe platform offers flexibility, 100m (328) 100m (328) 300m(984)
scalability, and common configuration Cat 5
based standards and operational 100m (328) or
100FX Fiber
interfaces to integrate with basic process 2,000m / 6,600 multi-mode
control systems. 15km, 40km, 80km single mode
The Mark VIe platform enables real-time
visualization by sharing data through the The distributed Ethernet architecture allows for enhanced connectivity and flexibility. Ethernet improves
plant-wide control system, HMIs, data lifecycle management by enabling replacement or upgrade of individual components. The future-proof
architecture of the Mark VIe platform enables a control system lifetime engineered to exceed expectations.
historians, device management systems,
and enterprise trending tools.
Key personnel gain access to critical
operational information, allowing them to
make better, faster decisions to maximize
performance while minimizing risk.
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 7 of 9

Solution Components

Mark VIe controller Mark VIe I/O modules IO network (IONet)


At the heart of the Mark VIe system is the (I/O card & pack) The IO network is a dedicated, full duplex,
controller that includes the main processor Mark VIe I/O modules have three common point-to-point protocol. It supports a
and triplicated Ethernet drivers to components: a termination block for field deterministic, 100 MB communications
communicate with networked I/O, and wiring, a terminal board, and I/O pack(s). network suitable for local and/or
additional Ethernet drivers for the control Modules are DIN rail mounted. Wide distributed I/O modules. IONet switches
network. A set of two or three controllers gauge wiring eliminates marshalling and are a GE design, incorporating extreme
can be used to provide dual or TMR control. lowers costs. Each I/O pack contains two environmental capability with superior
The control logic can be programmed in a IONet ports and a local processor with a performance. Standard network protocols
combination of function block diagrams real-time clock synchronized for 1ms such as Profinet, Profibus and Foundation
(FBD), and relay ladder logic (RLD). A time-stamping in the sequence-of-events Fieldbus can be seamlessly integrated into
real-time operating system executes this (SOE) function available on all discrete the Mark VIe system.
control logic and interfaces with the I/O inputs and outputs. This feature allows
system. In each frame, the online customers to select SOE with the click of Virtual Mark VIe controller
controllers read data from the input a button, without the complexity and For training and validation, simulation of
modules, write data to the output modules, expense of dedicated SOE hardware. I/O the process and associated control can be
and synchronize variables between diagnostics and voting are performed at invaluable.
controllers in a dual or TMR configuration. the pack level.
The Virtual Mark VIe provides a virtual,
Simplex I/O modules have one I/O pack PC-based form of the controller supporting:
mounted on the terminal board; TMR I/O
Execution of application program
modules have three I/O packs mounted to
a common terminal board. I/O redundancy Communication interface with
is a single selection during hardware ToolboxST application
configuration, and is transparent to the Ethernet Global Data (EGD) services
application code.
Process alarm management
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 8 of 9

Total Plant
Total PlantSolution
Solutionwith
withMark VIe
MarkVIe
Mobile Devices Wearables

Mobile Use Customer LAN


Firewall/Router

Plant Data Highway

Software
Applications
EWS Historian Gateway

Engineering
Security ST
Control Room
OSM & OnSite Gateway Unit Data Highway

LS2100e Bently EX2100e Mark VIe EX2100e Mark VIe Mark VIe Mark VIe
Static Nevada Excitation ST Excitation HRSG Utilities EDS
Starter Controls Controls Controls

Mark VIe SIL Generator Generator Mark VIe Water


GT Panel Protection Protection BOP Treatment CEMS T&D
Controls Panel Panel Controls
TC HMI TC HMI

Gas Turbines Steam Turbines Balance of Plant

Industry Codes and Standards


Distributed Control Made Easy Code Standard Mark

The combination of a single board controller and Ethernet-based I/O network CAN/CSA-C22.2 No. 61010-1-12
has enabled the Mark VIeS to support numerous distributed control modes for UL Std. No. 61010-1 (3rd Edition) C US
your plant applications. 165588
EN 61010-1 (3rd edition)

Achilles Level 1 certification,


Flexible - Scalable Architecture: Cost Effective Easy to use: controller security

Advanced technology controller Reduce spare parts inventory DEMKO 12 ATEX,


application dependent
w/ generic IO Reduced maintenance and
Selectable redundancy options training costs ISO 9000

Sequence of Event data for Reliable:


all equipment
30+ years of proven track records Safety System Related Codes
Common Platform:
and Standards
Same H/W & S/W platform as
Code Standard Mark
Turbine-generator
IEC 61508 :
Eliminate turbine to DCS interface, 2010 Parts 1-7 through Exida
reduce wiring, improve start-up EN50402: 2005+A1:
2008 Logic Solver
Case 7:17-cv-07188 Document 1-1 Filed 09/21/17 Page 9 of 9

Product Support
To succeed, businesses today must be able to rely on more than just a product solution. From superior technical support , to proper
implementation of your technology and training where and when you need it most , the services you receive are every bit as important
as the products you put into your facility. Automation & Controls from GE offers a complete array of support services to help you attain
the maximum return on your technology investments.

Technical and Commercial Support Information


Support Website: http://support.ge-ip.com
Submit a support case online at: http://eservice.ge-ip.com

Technical Support Commercial Support

Americas Americas
Online: http://eservice.ge-ip.com Phone: (800) 433-2682 or 780-420-2010
Phone: 1-800-433-2682 Option 1 (Automation), Option 2 (Enter CSN),
780-420-2010 (if toll-free 800 option is unavailable) then Option 1 (Customer Care),
Option 5 (Speak to Advocate)
Email: support.ip@ge.com
Email: customercare.ip@ge.com
Primary language of support: English
Primary language of support: English
Europe, Middle East , & Africa
Online: http://eservice.ge-ip.com Europe, Middle East , and Africa

Phone: +800-1-433-2682 Phone: +800-1-433-2682


(Choose Language> Option 2> CSN>Option 2) Choose Language> Option 2> CSN>Option 2
+420-239-015-850 (if toll-free 800 option is Email: customercare.emea.ip@ge.com
unavailable or dialing from a mobile telephone) Primary languages of support: English, French, German,
Email: support.emea.ip@ge.com Italian, Czech, Spanish
Primary languages of support: English, French, German,
Italian, Czech, Spanish Asia
Phone: +86-400-820-8208
Asia +86 21-3877-7006 (for India, Indonesia and Pakistan)
Online: http://eservice.ge-ip.com Email: customercare.cn.ip@ge.com (Greater China)
Phone: +86-400-820-8208 customercare.apo.ip@ge.com (Rest of Asia)
+86-21-3877-7006 (India, Indonesia & Pakistan)
Email: support.cn.ip@ge.com (China)
support.jp.ip@ge.com (Japan)
support.in.ip@ge.com (Rest of Asia)

www.geautomation.com
GE's Industrial Solutions business is a subsidiary of General Electric. The GE brand and logo are trademarks of General Electric.
2016 General Electric. The GE brand and logo are trademarks of General Electric. * Trademark of General Electric. All other trademarks
are the property of their respective owners. Information provided is subject to change without notice.
09.16 GFA-2104B