Case3:15-cv-01429 Document1 Filed03/27/15 Page1 of 10

1 MARCUS T. HALL (SBN 206495)

WILLIAM SLOAN COATS, III (SBN 94864)
2 DEAN A. MOREHOUS (SBN 111841)
CRAIG C. CROCKETT (SBN 265161)
3 NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
555 Mission Street, Thirty-Fourth Floor
4 San Francisco, CA 94105
Telephone: (415) 814-6161
5 Facsimile: (415) 814-6165
marcus.hall@novakdruce.com
6 william.coats@novakdruce.com
dean.morehous@novakdruce.com
7 craig.crockett@novakdruce.com

8 Attorneys for Plaintiff

Kenu, Inc.
9
10 UNITED STATES DISTRICT COURT
11 NORTHERN DISTRICT OF CALIFORNIA
12 KENU, INC., Case No.
13 Plaintiff, COMPLAINT FOR PATENT
14 INFRINGEMENT, TRADE DRESS
v. INFRINGEMENT, UNFAIR
15 COMPETITION (CAL. BUS. & PROF.
BELKIN INTERNATIONAL, INC., and CODE § 17200), AND COMMON LAW
16 OES 1 through 10, inclusive, UNFAIR COMPETITION
17 Defendants. DEMAND FOR JURY TRIAL
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COMPLAINT
 Case3:15-cv-01429 Document1 Filed03/27/15 Page2 of 10

1 Plaintiff Kenu, Inc. (“Kenu”), for its Complaint alleges as follows:

2 1. Kenu is a San Francisco company that specializes in combining technology, art and
3 design in creating mobile phone products and accessories. One such product is a portable hands free
4 in-car mount for mobile or smartphone devices that attaches to any car air vent (hereafter
5 “AIRFRAMETM”). Kenu’s AIRFRAMETM met immediate success for its elegant design and
6 superior functionality over traditional car mounts that are often bulky or rely on adhesives, which
7 detach over time. Seeking to capitalize on Kenu’s success, competitors have recently begun copying
8 Kenu’s innovative design and distinctive AIRFRAMETM trade dress to “free ride” on the efforts of
9 Kenu. This action seeks to remedy the unauthorized sale of one such knock-off product sold as the
10 “Vent Mount.”
11 THE PARTIES
12 2. Kenu is a corporation organized and existing under the laws of Delaware and having
13 a place of business at 560 Alabama Street, San Francisco, California 94110.
14 3. Defendant Belkin International, Inc. (“Belkin”) is a corporation organized under the
15 laws of Delaware and having a place of business at 12045 East Waterfront Drive, Playa Vista,
16 California 90094, with business activities throughout the world and on the World Wide Web
17 including at www.belkin.com.
18 4. Kenu does not know the true names and capacities of DOES 1 through 10, inclusive,
19 and therefore sues them by these fictitious names. When the true names and capacities are
20 discovered for these DOE defendants, Kenu will seek to amend this Complaint to allege the true
21 names and capacities in lieu of the fictitious names. Kenu is informed and believes that each of the
22 fictitiously named defendants is responsible in some manner for the occurrences alleged in this
23 Complaint.
24 5. On information and belief, defendants are, and at all times mentioned herein were, the
25 alter egos, parents, subsidiaries, agents, partners, associates, joint-venturers, servants, employees,
26 and/or other authorized representatives of each other, and in doing the things herein alleged were
27 acting within the course and scope of their authority, agency, and employment, and with the
28 knowledge, consent, and approval of their fellow defendants.
2
COMPLAINT
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1 JURISDICTION
2 6. This is a civil action seeking damages and injunctive relief for patent infringement,
3 trade dress infringement, unfair competition under California Business and Professions Code
4 § 17200 et seq., and common law unfair competition.
5 7. Pursuant to 28 U.S.C. § 1331, this Court has federal subject matter jurisdiction over
6 Kenu’s claims for patent and trade dress infringement. Further, this Court has subject matter
7 jurisdiction pursuant to the following statutes: 28 U.S.C. § 1338(a) (Acts of Congress relating to
8 patents); 15 U.S.C. § 1121 et seq. (the Lanham Act); and 28 U.S.C. § 1367 (a) (supplemental
9 jurisdiction over state and common-law claims).
10 8. The Northern District of California has personal jurisdiction over Belkin because,
11 among other things, Belkin maintains its corporate headquarters in California, Belkin is engaged in
12 wrongful conduct within the state of California and in this District, including placing into commerce
13 infringing goods via Belkin’s websites including at www.belkin.com and through retailers, and
14 infringing upon Kenu’s patent and trade dress rights in this judicial district. Belkin has maintained
15 substantial, continuous, and systematic contacts with the state of California through its business
16 dealings and activities within and with residents of the state of California. Belkin’s conduct causes
17 injury to and is directed at Kenu and its intellectual property in the state of California and this
18 District. But for Belkin’s conduct, Kenu would not have suffered damage.
19 VENUE AND INTRADISTRICT ASSIGNMENT
20 9. Venue is proper within this District under 28 U.S.C. § 1391(b) and (c) because Belkin
21 transacts business within this District and offers for sale in this District products that infringe Kenu’s
22 intellectual property rights. Pursuant to Local Rule 3-2(c), intellectual property actions are assigned
23 on a district-wide basis.
24 FACTS APPLICABLE TO ALL CLAIMS
25 10. Kenu is a successful mobile phone accessory business that designs, develops, and
26 distributes artistic and functional mobile phone accessories that are one of a kind in today’s
27 marketplace. One such product by Kenu is the AIRFRAMETM, a portable hands free in-car mount
28 for mobile devices.
3
COMPLAINT
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1 11. Representative images of Kenu’s AIRFRAMETM are provided below:

2

6 12. The AIRFRAMETM was released in 2013 and has already received acclaim for the

7 utility and elegant design. The AIRFRAMETM is sold through numerous merchandisers, retailers,

8 and stores nationwide, including Apple Stores, Target, T-Mobile, Sprint, and Staples, to name just a

9 few. Kenu also markets and sells its AIRFRAMETM product on the Internet, including through its

10 website located at www.kenu.com.

11 13. In addition to its common law rights, Kenu sought protection for its intellectual

12 property rights associated with the AIRFRAMETM product by filing for a patent.

13 14. On October 1, 2013, the United States Patent and Trademark Office issued United

14 States Patent No. US D690,707 (the “’707 patent”), entitled “Dashboard Vent Mount for an

15 Electronic Device,” for a portable hands free in-car mount for mobile devices. See attached

16 Exhibit A.

17 15. Representative Figures from Kenu’s patent are referenced below:

18

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22 16. On December 11, 2012, the inventors of the ‘707 patent, Kenneth Minn and David E.

23 Yao, assigned all of their patent rights in the ‘707 patent to Kenu, which has continuously held the

24 rights to the ‘707 patent since that date.

25 17. The trade dress associated with Kenu’s AIRFRAMETM product is distinctive, non-

26 functional, and is owned by Kenu.

27 18. The trade dress associated with Kenu’s AIRFRAMETM product signifies the source of

28 the AIRFRAMETM product to its customers.

4
COMPLAINT
 Case3:15-cv-01429 Document1 Filed03/27/15 Page5 of 10

1 19. As a result of considerable efforts, Kenu’s customers, and the general public, have
2 come to recognize Kenu as an established and successful mobile phone accessory business.
3 20. Kenu’s AIRFRAMETM product is one of a kind.
4 21. Kenu’s AIRFRAMETM product is manufactured with high quality materials designed
5 to maximize product durability and customer satisfaction.
6 22. Kenu’s designs are its own intellectual property. No goods of this design existed
7 prior to Kenu’s designs and patent.
8 23. AIRFRAMETM is Kenu’s most sought after and sold product.
9 24. Kenu makes substantial revenue from the AIRFRAMETM product.
10 25. In or about late 2014, Belkin introduced its Vent Mount product, which competes
11 with Kenu’s AIRFRAMETM in the market for portable hands free in-car mounts for mobile or
12 smartphone devices.
13 26. On information and belief, Belkin manufactures and/or imports, or causes to be
14 manufactured and/or imported the Vent Mount product into the United States and the Northern
15 District of California.
16 27. On information and belief, Belkin owns, controls, and/or manages the website at
17 www.belkin.com.
18 28. Belkin exposes for sale, offers to sell, and sells the infringing Vent Mount, including
19 to residents in the Northern District of California, through the website www.belkin.com, and through
20 third parties including at the following URLs:
21 a. http://amzn.com/B00O5JARCI;
22 b. http://store.apple.com/us/product/HH0J2ZM/;
23 c. http://www.bhphotovideo.com/c/product/1107008-REG; and
24 d. http://www.frys.com/product/8331667.
25 29. On information and belief, Belkin markets and advertises the Vent Mount product
26 throughout the United States and in the Northern District of California using advertisements such as
27 the following:
28 ///
5
COMPLAINT
 Case3:15-cv-01429 Document1 Filed03/27/15 Page6 of 10

1 a. http://www.belkin.com/uk/p/P-F8M879/; and
2 b. https://www.youtube.com/watch?v=t4_FbJb-QX4.
3 30. Kenu purchased the Vent Mount, representative pictures of which are provided
4 below:
5

9 31. The Vent Mount available from Belkin violates Kenu’s patent and trade dress rights.

10 32. Kenu’s ‘707 patent covers the Vent Mount manufactured, imported, exposed for sale,

11 offered for sale, and sold by Belkin.

12 33. The Vent Mount violates Kenu’s trade dress rights in its AIRFRAMETM product by

13 causing confusion among ordinary consumers as to the source, sponsorship, affiliation, or approval

14 of Kenu’s AIRFRAMETM product.

15 34. Representative side-by-side comparisons of the AIRFRAMETM and Vent Mount are

16 provided below:

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COMPLAINT
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COMPLAINT
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1 35. Belkin’s willful and deliberate actions have caused significant harm to Kenu. Kenu
2 has lost customers and revenue due to the illegal and infringing product being put in to the stream of
3 commerce by Belkin.
4 FIRST CLAIM FOR RELIEF
PATENT INFRINGEMENT
5 35 U.S.C. § 271(a)
6 36. Kenu restates and incorporates all previous allegations of this Complaint by reference

7 as though set forth in full.

8 37. Belkin has infringed upon the rights of Kenu’s ‘707 patent by making, exposing for

9 sale, offering to sell, selling, and importing the Vent Mount in the United States.

10 38. Belkin will continue to infringe the ‘707 patent unless enjoined by this Court.

11 39. Belkin’s acts are willful, in disregard of, and with indifference to, the rights of Kenu.

12 40. As a direct and proximate cause of the infringement by Belkin, Kenu is entitled to

13 damages, reasonable royalties and lost profits in amounts to be proven at trial, enhanced damages,

14 and reasonable attorney’s fees pursuant to 35 U.S.C. § 285. Additionally, Belkin is liable to Kenu to

15 the extent of its total profit, but not less than $250, pursuant to 35 U.S.C. § 289.

16 SECOND CLAIM FOR RELIEF

TRADE DRESS INFRINGEMENT
17 15 U.S.C. § 1125(a)(1)

18 41. Kenu restates and incorporates all previous allegations of this Complaint by reference
19 as though set forth in full.
20 42. Belkin has engaged in infringement of Kenu’s trade dress rights in its AIRFRAMETM
21 product by placing into commerce the Vent Mount.
22 43. Belkin has offered and sold the Vent Mount, despite knowledge that the Vent Mount
23 being offered and sold is likely to cause confusion among ordinary consumers as to the source,
24 sponsorship, affiliation, or approval of Kenu’s AIRFRAMETM product.
25 44. Belkin’s acts are willful, in disregard of, and with indifference to the rights of Kenu.
26 45. As a direct and proximate cause of the infringement by Belkin, Kenu is entitled to
27 damages, reasonable royalties and lost profits in amounts to be proven at trial, enhanced damages,
28 and reasonable attorney’s fees pursuant to 15 U.S.C. § 1117.
8
COMPLAINT
 Case3:15-cv-01429 Document1 Filed03/27/15 Page9 of 10

1 THIRD CLAIM FOR RELIEF

UNFAIR COMPETITION
2 CALIFORNIA BUSINESS AND PROFESSIONS CODE § 17200 ET SEQ.
3 46. Kenu restates and incorporates all previous allegations of this Complaint by reference
4 as though set forth in full.
5 47. The above described acts and omissions, including, but not limited to, Belkin’s
6 continued infringement of Kenu’s design patent, and its infringement of Kenu’s trade dress rights,
7 constitute Unfair Competition under Section 17200 et. seq. of the California Business & Professions
8 Code.
9 48. By reason of these wrongful acts and omissions by Belkin, Kenu has suffered and
10 will suffer damage. Additionally, these wrongful acts and omissions by Belkin have caused, and
11 unless restrained and enjoined by this Court will continue to cause, serious irreparable injury and
12 damage to Kenu.
13 FOURTH CLAIM FOR RELIEF
UNFAIR COMPETITION
14 COMMON LAW

15 49. Kenu restates and incorporates all previous allegations of this Complaint by reference
16 as though set forth in full.
17 50. The above described acts and omissions, including, but not limited to, Belkin’s
18 continued infringement of Kenu’s design patent, and their infringement of Kenu’s trade dress rights,
19 constitute Unfair Competition at Common Law.
20 51. By reason of these wrongful acts and omissions by Belkin, Kenu has suffered and
21 will suffer damage. Additionally, these wrongful acts and omissions by Belkin have caused, and
22 unless restrained and enjoined by this Court will continue to cause serious irreparable injury and
23 damage to Kenu.
24 PRAYER FOR RELIEF

25 Wherefore, Kenu prays for judgment as follows:

26 1. Injunctive relief;
27 2. Reasonable royalties in an amounts to be proven at trial;
28 3. Lost profits in an amount to be proved at trial;
9
COMPLAINT
 Case3:15-cv-01429 Document1 Filed03/27/15 Page10 of 10

1 4. Belkin’s total profit, but not less than $250, pursuant to 35 U.S.C. § 289;
2 5. Enhanced damages;
3 6. Kenu’s attorney’s fees and costs as provided by law; and
4 7. Such other relief as the Court deems appropriate.
5 DEMAND FOR JURY TRIAL
6 In accordance with Rule 38 of the Federal Rules of Civil Procedure, Kenu respectfully
7 demands a jury trial of all issues triable to a jury in this action.
8

9 Dated: March 27, 2015 NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
10

11 By: /s/ Marcus T. Hall

Marcus T. Hall
12 William Sloan Coats, III
Dean A. Morehous
13 Craig C. Crockett

14 Attorneys for Plaintiff

Kenu, Inc.
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COMPLAINT
Case3:15-cv-01429 Document1-1 Filed03/27/15 Page1 of 5

EXHIBIT A
 Case3:15-cv-01429 Document1-1 Filed03/27/15 Page2 of 5
IIIIII 1111111111111111111111111111111111111111111
USOOD690707S
11111111111

c12) United States Design Patent (10) Patent No.: US D690, 707 S
Minn et al. (45) Date of Patent: ** Oct. 1, 2013

(54) DASHBOARDVENTMOUNTFORAN (57) CLAIM

ELECTRONIC DEVICE We claim the ornamental design for a dashboard vent mount
for an electronic device, as shown and described.
(71) Applicants: Kenneth Minn, San Francisco, CA DESCRIPTION
(US); David E. Yao, San Francisco, CA
(US) FIG. 1 is an elevation view of the back of the dashboard vent
mount for an electronic device in a retracted setting;
(72) Inventors: Kenneth Minn, San Francisco, CA FIG. 2 is a plan view of the top of the dashboard vent mount
(US); David E. Yao, San Francisco, CA for an electronic device in a retracted setting;
(US) FIG. 3 is an elevation view ofleft side of the dashboard vent
mount for an electronic device in a retracted setting;
FIG. 4 is an elevation view of the front of the dashboard vent
(73) Assignee: Kenu, LLC, San Francisco, CA (US)
mount for an electronic device in a retracted setting;
FIG. 5 is an elevation view of the right side of the dashboard
(**) Term: 14 Years
vent mount for an electronic device in a retracted setting;
FIG. 6 is a plan view of the bottom of the dashboard vent
(21) Appl. No.: 29/437,793 mount for an electronic device in a retracted setting;
FIG. 7 is an isometric view, from the front right, of the
(22) Filed: Nov. 20, 2012 dashboard vent mount for an electronic device in a retracted
(51) LOC (9) Cl. . ... ... ... ... .. ... ... ... ... ... .. ... ... ... ... ... .. . 08-07 setting;
(52) U.S. Cl. FIG. 8 is an isometric view, from the back left, of the dash-
USPC ......................................................... Dl4/447 board vent mount for an electronic device in a retracted set-
ting;
(58) Field of Classification Search
FIG. 9 is an elevation view of the back of the dashboard vent
USPC ................ D14/432, 433, 434, 439, 440, 451,
mount for an electronic device in an expanded setting;
D14/452, 239,217, 224.1, 251,252,253, FIG.10 is a plan view of the top of the dashboard vent mount
D14/457, 458, 459, 460, 461; D6/406.1, for an electronic device in an expanded setting;
D6/406.2, 406.3, 406.4, 406.5, 406.6; FIG. 11 is an elevation view ofleft side of the dashboard vent
361/679.06, 679.21, 679.22, 679.24, 679.26, mount for an electronic device in an expanded setting;
361/679.27, 679.28, 679.3, 679.55, 679.56, FIG. 12 is an elevation view of the front of the dashboard vent
361/709; 248/917-924, 133, 136, 139, 150, mount for an electronic device in an expanded setting;
248/176.1, 188.6; D12/415 FIG. 13 is an elevation view of the right side of the dashboard
See application file for complete search history. vent mount for an electronic device in an expanded setting;
FIG. 14 is a plan view of the bottom of the dashboard vent
(56) References Cited mount for an electronic device in an expanded setting;
FIG. 15 is an isometric view, from the front right, of the
U.S. PATENT DOCUMENTS dashboard vent mount for an electronic device in an expanded
D482,039 S * 1112003 Chen eta!. ................... D14/447 setting; and,
7,272,984 B2 * 9/2007 Fan .............................. 74/89.17 FIG. 16 is an isometric view, from the back left, of the dash-
(Continued) board vent mount for an electronic device in an expanded
setting.
Primary Examiner- Angela J Lee
(74) Attorney, Agent, or Firm- Jeffrey Schox; Peter Miller 1 Claim, 2 Drawing Sheets
 Case3:15-cv-01429 Document1-1 Filed03/27/15 Page3 of 5

US D690, 707 S
Page 2

(56) References Cited D656,940 S * 4/2012 Mcclelland eta!. ......... D14/447

D657,356 S * 4/2012 Wikel .......................... D14/253
U.S. PATENT DOCUMENTS D663,726 S * 7/2012 Gourley ....................... D14/251
D663,735 S * 7/2012 Musselman .................. D14/447
D589,962 S * 4/2009 Maruyama eta!. .......... D14/432 D664,147 S * 7/2012 Zhao eta!. ................... D14/452
D611,478 S * 3/2010 Richardson eta!. ......... D14/447 D671,950 S * 12/2012 Richter ........................ D14/447
D630,222 S * 112011 Lin .............................. D14/447 201110019992 A1 * 112011 Orf ............................... 396/419
D645,033 S * 9/2011 Quongetal. ................ D14/253
D656,931 S * 4/2012 Wikel .......................... D14/253 * cited by examiner
 Case3:15-cv-01429 Document1-1 Filed03/27/15 Page4 of 5

U.S. Patent Oct. 1, 2013 Sheet 1 of2 US D690, 707 S

FIG.1

FIG.3

FIG. 7 FIG. 8
 Case3:15-cv-01429 Document1-1 Filed03/27/15 Page5 of 5

U.S. Patent Oct. 1, 2013 Sheet 2 of2 US D690, 707 S

r:- r~~
FIG. 11 FIG. 12 FIG. 13

FIG. 1.5 FIG. 16

JS 44 (Rev. 12/12) Case3:15-cv-01429 Document1-2
CIVIL Filed03/27/15 Page1 of 2
COVER SHEET
Cand rev (1/15/13)
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
KENU, INC. BELKIN INTERNATIONAL, INC., and DOES 1 through 10, inclusive.

(b) County of Residence of First Listed Plaintiff San Francisco County of Residence of First Listed Defendant Los Angeles
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
See Attachment

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

IV. NATURE OF SUIT
CONTRACT
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from
Proceeding State Court
VI. CAUSE OF
ACTION
VII. REQUESTED IN
COMPLAINT:
Foreign Country
(Place an “X” in One Box Only)
TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment
315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
Liability 367 Health Care/ 430 Banks and Banking
320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
Slander Personal Injury 820 Copyrights 460 Deportation
330 Federal Employers’ Product Liability 830 Patent 470 Racketeer Influenced and
Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations
340 Marine Injury Product 480 Consumer Credit
345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/
350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions
Product Liability 380 Other Personal Relations 864 SSID Title XVI 891 Agricultural Acts
360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 893 Environmental Matters
Injury 385 Property Damage 751 Family and Medical 895 Freedom of Information
362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice 790 Other Labor Litigation 896 Arbitration
CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS 899 Administrative Procedure
440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
441 Voting 463 Alien Detainee or Defendant) Agency Decision
442 Employment 510 Motions to Vacate 871 IRS—Third Party 950 Constitutionality of
443 Housing/ Sentence 26 USC 7609 State Statutes
Accommodations 530 General
445 Amer. w/Disabilities 535 Death Penalty IMMIGRATION
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict
Appellate Court Reopened Another District Litigation
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. § 271, 15 U.S.C. § 1125
Brief description of cause:
Patent infringement, trade dress infringement, and statutory and common law unfair competition
CHECK IF THIS IS A CLASS ACTION DEMAND $ Injunction + CHECK YES only if demanded in complaint:
UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No

VIII. RELATED CASE(S)

(See instructions):
IF ANY JUDGE DOCKET NUMBER

IX. DIVISIONAL ASSIGNMENT (Civil L.R. 3-2)

(Place an “X” in One Box Only) ( ) SAN FRANCISCO/OAKLAND ( ) SAN JOSE ( ) EUREKA
DATE SIGNATURE OF ATTORNEY OF RECORD
March 27, 2015 /s/ Marcus T. Hall
 Case3:15-cv-01429 Document1-2 Filed03/27/15 Page2 of 2
ATTACHMENT TO CIVIL COVER SHEET

Attorneys (Firm Name, Address, and Telephone Number)

MARCUS T. HALL (SBN 206495)

WILLIAM SLOAN COATS, III (SBN 94864)
DEAN A. MOREHOUS (SBN 111841)
CRAIG C. CROCKETT (SBN 265161)
NOVAK DRUCE CONNOLLY BOVE + QUIGG LLP
555 Mission Street, Thirty-Fourth Floor
San Francisco, CA 94105
Telephone: (415) 814-6161
Facsimile: (415) 814-6165
marcus.hall@novakdruce.com
william.coats@novakdruce.com
dean.morehous@novakdruce.com
craig.crockett@novakdruce.com

Attorneys for Plaintiff

Kenu, Inc.