Guy A. Shaked Investments v. Ka Man - Complaint

Case 2:19-cv-10589 Document 1 Filed 12/16/19 Page 1 of 16 Page ID #:1
1 Michele D. Johnson (Bar No. 198298)

Michele.Johnson@LW.com
2 LATHAM & WATKINS LLP
650 Town Center Drive, 20th Floor
3 Costa Mesa, CA 92626-1925
Telephone: +1.714.540.1235
4 Facsimile: +1.714.755.8290
5 Michael A. Morin (PHV to be filed)
Michael.Morin@LW.com
6 Kevin C. Wheeler (Bar No. 261177)
Kevin.Wheeler@LW.com
7 Joelle P. Justus (Bar No. 275244)
Joelle.Justus@LW.com
555 Eleventh Street, N.W., Suite 1000
9 Washington, D.C. 20004-1304
Telephone: +1.202.637.2200
10 Facsimile: +1.202.637.2201
11 Attorneys for Plaintiffs Guy A. Shaked
Investments Ltd and Dafni Hair Products,
12 Ltd.
13 UNITED STATES DISTRICT COURT
14 CENTRAL DISTRICT OF CALIFORNIA
15 WESTERN DIVISION
16
GUY A. SHAKED INVESTMENTS
17 LTD. AND DAFNI HAIR Case No. 2:19-cv-10589
PRODUCTS, LTD.
18 COMPLAINT FOR PATENT
Plaintiffs, INFRINGEMENT
19
v.
20
CHIANG KA MAN, JURY TRIAL DEMANDED
21
Defendant.
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Plaintiffs Guy A. Shaked Investments Ltd. and Dafni Hair Products,
24
Ltd. (“Dafni” or “Plaintiffs”) file this Complaint for patent infringement against
25
Defendant Chiang Ka Man, also known as Charlie Chiang (“Defendant”), who does
26
business in California, and alleges as follows:
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:
1 PRELIMINARY STATEMENT
2 1. As an engineering student at Tel Aviv University in 2012, then-24-year-
3 old Sharon Rabi conducted an experiment that would change her life in ways she
4 could never have expected: she cut her thick, curly hair very short. She bought two
5 straightening irons to help tame her new hairdo, but naturally curly hair combined
6 with the humidity in Israel meant she had to wake up twenty minutes earlier each
7 day. Sharon thought there must be an easier way for women to tackle uncooperative
8 tresses.
9 2. Sharon talked to her father Kobi Guy, also an engineer, and they put
10 their heads together to develop an alternative to the traditional flat iron. What they
11 thought would be a six-month project required five prototypes and years of trial and
12 error before the product was ready. In September 2015, Sharon posted a video on
13 YouTube in which she straightened her (now long) hair with the straightening brush
14 she and her father had created, called the “DAFNI” brush.1
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28 Available at https://www.youtube.com/watch?v=ey5eAZXSGlA (last accessed
Dec. 15, 2019).
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1 3. A radio station in Texas shared the video on Facebook, and according

2 to media coverage it soon garnered over 88 million views across different platforms,2
3 and has more than 120 million views so far.3 For Sharon, the overwhelming
4 response to the video was validation of the effort she put in to developing the DAFNI
5 brush. Forbes Israel recognized Sharon as a top 30 Under 30 Entrepreneur, and
6 Good Housekeeping Beauty Lab Awards named the DAFNI brush as the best “Hot
7 Stylin’ Tool.”4
8 4. Sharon Rabi was driven to find a way to help women who do not have
9 time to spare straightening their hair each morning. As a mother of two, Sharon
10 knew that every minute counts. Able to straighten her own hair in under three
11 minutes with the DAFNI brush, Sharon was eager to share her invention with people
12 across the world. American women on average spend 17 minutes a day on “everyday
13 hairstyles,” using two products and three styling tools.5 And a majority of women
14 complain that styling their hair takes too long.6 The DAFNI brush had the potential
15 to reduce the amount of time (and the number of tools) it takes for these women to
16 a fraction of what it took before.
17 2
Megan Willett, We Tried the brush that can straighten curly hair in minutes –
18 and loved it, Business Insider (Apr. 28, 2016), available at
https://www.businessinsider.com/dafni-brush-review-2016-4 (last accessed Dec.
19 15, 2019).
3
Harriet Pudney, Secrets of a mum and beauty entrepreneur: Sharon Rabi,
20 inventor of the Dafni brush (Aug. 3, 2016), available at
https://www.stuff.co.nz/life-style/beauty/82461939/secrets-of-a-mum-and-beauty-
21 entrepeneur-sharon-rabi-inventor-of-the-dafni-brush (last accessed Dec. 15, 2019).
4
22 See Under 30 Founders Share Their Best Advice to Starting Up, available at
https://www.forbes.com/sites/under30network/2016/06/01/under-30-founders-
23 share-their-best-advice-for-starting-up/#3df50723ff2f (last accessed Dec. 15,
2019); DAFNI, The Original Ceramic Hair Straightening Brush, Wins Prestigious
24 Good Housekeeping Beauty Lab Award, PR News Wire (July 25, 2017), available
at https://www.prnewswire.com/news-releases/dafni-the-original-ceramic-hair-
25 straightening-brush-wins-prestigious-good-housekeeping-beauty-lab-award-
300493338.html (last accessed Dec. 15, 2019).
26 5
See Laura Norkin, Splitting Hairs, InStyle Magazine (Aug. 6, 2018), available at
27 https://www.instyle.com/beauty/splitting-hairs-survey-american-women-and-hair
(last accessed Dec. 15, 2019).
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28 Id.
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1 5. Millions of women can relate to Sharon Rabi’s experience with a

2 haircut in need of assistance. For many, hair products and tools are not a luxury, but
3 a necessity, given the powerful role hair plays in self-identity. In a 2018 survey of
4 1,463 women across the United States, 58 percent of women said their hair was a
5 “big part of their self-expression,” and 81 percent feel most confident when their
6 hair looks great.7 Sharon used her engineering knowledge and innovative thinking
7 to create a new way for women to feel confident in their appearance.
8 6. For decades, women have used flat irons in order to tame frizz (the most
9 common hair complaint)8 and achieve sleek looks. Companies have made minor
10 adjustments to flat irons over the years, but the fundamental design remained the
11 same: two heated plates on hinged arms. The DAFNI brush was a fundamental shift
12 in how heat is applied to the hair, achieving the same effect as the traditional iron in
13 a fraction of the time. The DAFNI brush was so state-of-the-art that knock-off
14 products came to market soon after. The copycats not only sought to profit from
15 Dafni’s patent-protected technology and design, but also by flooding the market with
16 knock-off brushes often made with cheaper materials, they poisoned the market and
17 restricted Dafni’s ability to reach consumers. Dafni brings this suit hoping to rectify
18 the damage caused by infringers like Defendant that continue to profit from Sharon’s
19 and the Dafni family team’s hard work and innovation.
20 NATURE OF THE ACTION
21 7. This is an action under the patent laws of the United States, 35 U.S.C.
22 § 1 et seq., for infringement by Defendant of certain claims of U.S. Patents No.
23 D817,007, 9,578,943, 9,591,906, and 9,877,562 (collectively, the “Patents-in-
24 Suit.”).
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28 Id.
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Id.
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1 THE PARTIES
2 8. Plaintiff Guy A. Shaked Investments Ltd. is a corporation duly
3 organized and existing under the laws of Israel, having its principal place of business
4 at 20, Lincoln St., Rubinstein Bldg. 15th floor, Tel-Aviv, Israel.
5 9. Guy A. Shaked Investments Ltd. is the assignee and owner of the
6 Patents-in-Suit.
7 10. Plaintiff Dafni Hair Products, Ltd. is a corporation duly organized and
8 existing under the laws of Israel, having its principal place of business at 10 Zarchin
9 Street, Raanana, Israel.
10 11. Dafni is the exclusive licensee of the Patents-in-Suit.
11 12. On information and belief, Defendant Chiang Ka Man is a natural
12 person residing at 1413 Matchleaf Avenue, La Puente, California.
13 JURISDICTION AND VENUE
14 13. This Court has subject matter jurisdiction pursuant to 28 U.S.C.
15 §§ 1331 and 1338(a).
16 14. The Court has personal jurisdiction over Defendant because, among
17 other things, upon information and belief: (i) Defendant resides in La Puente,
18 California; (ii) Defendant has done and continues to do business in California; and
19 (iii) Defendant has committed and continues to commit acts of patent infringement
20 in the State of California, including by making, using, offering for sale, and/or
21 selling accused products in this District, and/or inducing others to commit acts of
22 patent infringement in this District.
23 15. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b),
24 1391(c), and 1400(b) because, among other things, on information and belief:
25 (i) Defendant resides in La Puente, California; (ii) Defendant has done and continues
26 to do business in California; and (iii) Defendant has committed and continues to
27 commit acts of patent infringement in the State of California, including by making,
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1 using, offering for sale, and/or selling accused products and services in in this
2 District, and/or inducing others to commit acts of patent infringement in this District.
3 INVENTION OF THE DAFNI BRUSH
4 16. For nearly a century, there was very little innovation in hair
5 straightening technology. The primary option for men and women alike was to
6 sandwich hair between two heated plates and literally iron the hair straight. Over
7 time, the types of metal and temperature controls for flat irons may have changed,
8 but all use the same principle that is inconvenient, unhealthy for hair, and time-
9 consuming.
10 17. In 2012, 24-year-old Sharon Rabi suffered an unfortunate haircut,
11 leaving her thick, curly hair too short and nearly unmanageable. Her only option
12 seemed to be using traditional straightening irons using high temperatures to tame
13 her hair into place, an arduous task in humid Israel. She tried two different
14 straightening irons, but was frustrated at having to wake up early to style shorter
15 hair.
16 18. An engineering student at Tel Aviv University, Sharon decided there
17 must be a better option. Together with her father Kobi Guy, a senior engineer,
18 Sharon spent several years designing, testing, and perfecting a styling tool with the
19 ease of use of a hair brush and more straightening power than a flat iron. The end
20 result was a new type of hair styling tool, a ceramic heated straightening brush,
21 named the “DAFNI” brush, in honor of Sharon’s sister.
22 19. Developing an effective styling brush proved far more difficult than
23 Sharon and Kobi imagined when undertaking the project. What they thought might
24 be a six month project took several years and multiple prototypes to develop the final
25 product. The inventors faced—and ultimately overcame—a number of design and
26 engineering challenges.
27 20. For example, the device needed to provide sufficient heat to hair strands
28 to straighten them, while not damaging the hair during repeated use, a common issue
7
1 with traditional straighteners. Three-dimensional heated elements protruding from

2 a heated plate on the face of the brush allowed more contact between heated surfaces
3 and the hair. This design allows for a lower operating temperature causing less
4 damage to the user’s hair.
5 21. Moreover, the increased heated surface area reduces the amount of time
6 it takes to style the user’s hair. To be effective, traditional flat irons require the user
7 to portion hair into small sections, and run each section through the plates. By
8 contrast, with the DAFNI brush the user can run larger sections of hair at one time.
9 This both reduces the overall time required to achieve the desired look, and reduces
10 the hassle of using clips and other accessories to portion hair before straightening.
11 22. However, even with lower temperatures, the inventors needed to ensure
12 the user’s hand and scalp would not touch the heated elements while using the
13 device. Stiff bristles around the heated surface protect the user’s hand from
14 accidental burns, while also straightening and detangling hair. Likewise, heat-
15 insulating springing bristles on top of the protruding heating elements protect the
16 user’s scalp from accidental contact with heated elements, while at the same time
17 allowing the heating elements to come into close enough contact with hair along the
18 scalp to enable effective styling.
19 23. The aesthetic design of the final product was equally important to the
20 inventors. They invested significant time and resources in developing the overall
21 look and feel of the brush, ensuring it was sleek and stylish, with a “futuristic” feel
22 reflective of the innovative technology at work. The device needed to be
23 recognizable as a hair styling tool, but distinct from traditional brushes with
24 numerous flexible bristles.
25 24. In September 2015, Sharon revealed the brush to the world with a
26 YouTube video that has been reported to have been viewed more than 120 million
27 times. The original DAFNI brush went on sale later in 2015. Dafni has since
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1 developed a smaller version with detachable cord called the DAFNI go, and
2 rechargeable cordless version, the DAFNI Allure.
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12 DAFNI Original DAFNI go DAFNI Allure
13 25. Sharon’s husband, Kobi Rabi, a former fighter pilot in the Israeli
14 military, is the current Chief Executive Officer of Dafni.
15 26. Despite being a revolutionary invention in the field of hair
16 straightening, Dafni has struggled as the company attempts to compete with copycats
17 popping up around the world, disregarding Dafni’s intellectual property rights,
18 undercutting Dafni on price, and in many cases undermining the brand’s growth
19 potential by manufacturing and selling lower quality brushes.
20 PATENTS-IN-SUIT
21 27. Dafni has obtained two design patents and three utility patents for its
22 brushes in the United States.
23 28. On May 8, 2018, the United States Patent and Trademark Office duly
24 and lawfully issued U.S. Design Patent D817,007 (the “D’007 Patent”), entitled
25 “Hair Straightening Brush.” A true and correct copy of the D’007 Patent is attached
26 hereto as Exhibit A.
27 29. On February 28, 2017, the United States Patent and Trademark Office
28 duly and lawfully issued U.S. Patent No. 9,578,943 (the “’943 Patent”), entitled
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1 “Hair Straightening Brush.” A true and correct copy of the ’943 Patent is attached
2 hereto as Exhibit B.
3 30. On March 14, 2017, the United States Patent and Trademark Office
6 hereto as Exhibit C.
7 31. On January 30, 2018, the United States Patent and Trademark office
10 hereto as Exhibit D.
11 DEFENDANT AND THE ACCUSED PRODUCT
12 32. Not long after the DAFNI brush took the internet by storm, the copycats
13 began to appear, including from Defendant. On information and belief, since 2016
14 Defendant has sold the “VETROO” electric hair straightening brush, which copies
15 the look, feel, and straightening technology developed by the daughter/father
16 inventors over the course of several years:
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26 33. On information and belief, Defendant sells its VETROO electric hair
27 straightening brush directly through Amazon.com.
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1 FIRST CAUSE OF ACTION

2 (INFRINGEMENT OF THE D’007 PATENT)
3 34. Plaintiffs incorporate by reference Paragraphs 1-33 as if fully set forth
4 herein.
5 35. Plaintiffs have valid and protectable rights in the D’007 Patent.
6 36. Defendant’s manufacturing, importation, marketing, and sale of the
7 VETROO electric hair straightening brush infringes the D’007 patent.
8 37. Dafni Hair Products loses sales for each of the accused brushes that is
9 sold. But for the availability of accused products, a customer would purchase a
10 DAFNI brush. Plaintiffs therefor seek recovery of all lost profits associated with the
11 sale of accused brushes.
12 38. Alternatively, Plaintiffs seek to recover all of Defendant’s profits on the
13 infringing goods under 35 U.S.C. § 289, or a reasonable royalty.
14 39. Plaintiffs seek recovery of their attorney’s fees.
15 SECOND CAUSE OF ACTION
16 (INFRINGEMENT OF THE ’943 PATENT)
18 herein.
19 41. The ’943 Patent generally relates to a brush with protruding heating
20 elements and spacers to maintain distance between the heating elements and the
21 user’s skin. The asserted claims of the ’943 Patent are generally directed to a
22 hairbrush with a heating plate extending over the fact of the brush; a plurality of
23 heating elements thermally coupled to and protruding from the heating plate,
24 organized in rows along the length of the brush; heating elements offset in from
25 adjacent rows, and heat insulating spacers around the hair treating portion of the
26 brush, and providing space between the user’s scalp and the heating elements.
27 42. Defendant infringes the ’943 Patent by making, selling, and/or offering
28 for sale in the United States, and/or importing into the United States, ceramic brushes
11
1 that meet the elements of the asserted claims. By way of non-limiting example, the
2 VETROO electric hair straightening brush practices the invention of claim 1 because
3 it is a brush with a heating place on the face of the brush with multiple heating
4 elements thermally coupled to and protruding from the plate. The rows of heating
5 elements on the VETROO electric hair straightening brush are arranged in
6 lengthwise, offset rows, surrounding by heat-insulating bristles. Each heating
7 protruding heating element also has a heat insulating spacer projecting outwardly
8 from the heating element.
9 43. Defendant has infringed at least claims 1-4, 8, 9, 11, 12, and 15-21 of
10 the ’943 Patent, pursuant to 35 U.S.C. § 271(a) by making, using, offering to sell,
11 and/or selling in the United States, and/or importing into the United States the
12 VETROO electric hair straightening brush. Upon information and belief,
13 Defendant’s infringement is ongoing.
21 THIRD CAUSE OF ACTION
24 herein.
27 user’s skin. The asserted claim of the ’906 Patent is directed to a method of
28 manufacturing a brush, comprising arranging spacers protruding from the face of the
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1 brush to maintain a distance between the heating elements and the user’s scalp,
2 additional spacers around the heating elements, and a relationship between the
3 density of the spacers and their flexibility to ensure protection of the scalp.
6 that meet the elements of the asserted claims. Defendant practices the invention of
7 claim 18 by manufacturing brushes with multiple spacers to maintain a specific
8 distance between the ends of the heating elements and the user’s scalp, additional,
9 shorter spacers around the heating elements, and a density of spacers designed to
10 ensure space between the user’s scalp and the heating elements when the spacers are
11 flexed.
12 50. Defendant has infringed claim 18 the ’906 Patent, pursuant to 35 U.S.C.
13 § 271(a) by making, using, offering to sell, and/or selling in the United States, and/or
14 importing into the United States the VETROO electric hair straightening brush.
15 Upon information and belief, Defendant’s infringement is ongoing.
23 FOURTH CAUSE OF ACTION
26 herein.
13
1 user’s skin. The asserted claims of the ’562 Patent are generally directed to a
2 hairbrush with a heating plate, a plurality of heating elements monolithic with and
3 protruding from the heating plate arranged in lengthwise rows, heat insulating
4 spacers projecting from a bore in a heating element, and peripheral spacers on at
5 least two sides of the brush.
8 that meet the elements of the asserted claims. By way of non-limiting example, the
9 VETROO electric hair straightening brush practices the invention of claim 1 because
10 it is a brush with a heating place, a plurality of heating elements monolithic with and
11 protruding from the heating plate arranged in lengthwise rows, heat insulating
12 spacers projecting from a bore in the protruding heating elements, and peripheral
13 spacers on all sides of the brush.
14 57. Defendant has infringed claims 1-10 of the ’562 Patent, pursuant to 35
15 U.S.C. § 271(a) by making, using, offering to sell, and/or selling in the United States,
16 and/or importing into the United States the VETROO electric hair straightening
17 brush. Upon information and belief, Defendant’s infringement is ongoing.
25 PRAYER FOR RELIEF
26 WHEREFORE, Plaintiffs Guy A. Shaked Investments, Ltd. and Dafni Hair
27 Products, Ltd. pray for judgment in their favor and against Defendant Chiang Ka
28 Man and specifically for the following relief:
14
1 (a) Entry of judgment in favor of Guy A. Shaked Investments, Ltd. and

2 Dafni Hair Products, Ltd. and against Defendant Chiang Ka Man on all counts;
3 (b) Entry of judgment that Defendant Chiang Ka Man has infringed the
4 Patents-in-Suit;
5 (c) An order permanently enjoining Defendant Chiang Ka Man, together
6 with their agents, servants, employees, those acting in privity with them, and upon
7 those persons in active concert or participation with them, from infringing the
8 Patents-in-Suit;
9 (d) An award of compensatory damages adequate to compensate Plaintiffs
10 for Defendant Chiang Ka Man’s infringement of the Patents-in-Suit, in no event less
11 than a reasonable royalty, in an amount according to proof;
12 (e) An award of disgorgement of Defendant Chiang Ka Man’s profits from
13 sales of the accused products;
14 (f) An award of award of reasonable fees for expert witnesses and
15 attorneys pursuant to 35 U.S.C. § 285 or as otherwise permitted by law;
16 (g) Pre-judgment and post-judgment interest on Plaintiffs’ award, in an
17 amount according to proof;
18 (h) Plaintiffs’ costs; and
19 (i) All such other and further costs and relief as the Court deems just and
20 proper.
21 Dated: December 16, 2019
23 By /s/ Michele D. Johnson
Michele D. Johnson
24 Michael A. Morin
Kevin C. Wheeler
25 Joelle P. Justus
Investments Ltd. and Dafni Hair
27 Products, Ltd.
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1 DEMAND FOR JURY TRIAL

2 Plaintiffs Guy A. Shaked Investments, Ltd. and Dafni Hair Products, Ltd.
3 demand a trial by jury on all issues triable in this action pursuant to Rule 38 of the
4 Federal Rules of Civil Procedure.
5
6 Dated: December 16, 2019
8
9 By /s/ Michele D. Johnson
Michele D. Johnson
10 Michael A. Morin
Kevin C. Wheeler
11 Joelle P. Justus
Investments LTD and Dafni Hair
13 Products, Ltd.
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Case 2:19-cv-10589 Document 1-1 Filed 12/16/19 Page 1 of 6 Page ID #:17
EXHIBIT A
EXHIBIT B
EXHIBIT C
I IIIII I IIIIII Il llll lllll lllll lll l lllll l lll lll l lllll 111 111111 1 111111
US009591906B2
c12) United States Patent (IO) Patent No.: US 9,591,906 B2

Guy-Rabi et al. (45) Date of Patent: Mar.14,2017
(54) HAIR STRAIGHTENING BRUSH (52) U.S. Cl.

CPC ............... A45D 7100 (2013.01); A45D 2/001
(71) Applicant: GUY A. SHAKED INVESTMENTS (2013.01); A45D 20/48 (2013.01); A46B 9/06
LTD., Tel Aviv (IL) (2013.01);
(Continued)
(72) Inventors: Sharon Guy-Rabi, Ra'anana (IL); (58) Field of Classification Search
Yakov Guy, Ra'anana (IL) CPC ........ A45D 2/001; A45D 2/002; A45D 20/48;
A45D 2200/152; A46B 9/06; A46B
(73) Assignee: GUY A. SHAKED INVESTMENTS 15/003; A46B 2200/104; A46D 99/00
LTD., Tel Aviv (IL)
See application file for complete search history.
( *) Notice: Subject to any disclaimer, the term ofthis
(56) References Cited
patent is extended or adjusted under 35
U.S.C. 154(b) by 18 days. U.S. PATENT DOCUMENTS
(21) Appl. No.: 14/401,540 943,321 A 12/1909 Shero
3,760,821 A 9/1973 Weddington
(22) PCT Filed: May 16, 2013 (Continued)
(86) PCT No.: PCT/IL2013/050420 FOREIGN PATENT DOCUMENTS

§ 371 (c)(l), CN 2183694 11/1994
(2) Date: Nov. 17, 2014 CN 1235524 11/1999
(Continued)
(87) PCT Pub. No.: W02013/171750
PCT Pub. Date: Nov. 21, 2013 OTHER PUBLICATIONS
(65) Prior Publication Data International Search Report from Interntional Application No. PCT/
IL2013/050420 dated Aug. 28, 2013.
US 2015/0101139 Al Apr. 16, 2015
Primary Examiner - Rachel Steitz
Related U.S. Application Data (74) Attorney, Agent, or Firm - Dorsey & Whitney LLP
(63) Continuation of application No.
PCT/IL2013/050017, filed on Jan. 6, 2013. (57) ABSTRACT
A brush is provided herein, the brush having heating ele
(30) Foreign Application Priority Data ments dispersed on and protruding from its face and spacers
arranged to maintain a specified distance between protruding
May 17, 2012 (IL) .......................................... 219875 ends of the heating elements and a scalp of a head that is
being brushed. The spacers are dispersed on the brush's face
(51) Int. Cl. at a specified density that assures maintaining the specified
A45D 24/10 (2006.01) distance with respect to a resilience of the spacers.
A45D 7100 (2006.01)
(Continued) 20 Claims, 5 Drawing Sheets
US 9,591,906 B2
1 2
HAIR STRAIGHTENING BRUSH elements may have a cross section that varies in shape, and
heating elements of varying forms may be combined on a
CROSS-REFERENCE TO RELATED single brush.
APPLICATIONS The term "spacer" as used herein in this application refers
5 to any structure arranged to keep a clearance or a specified
This application is a National Phase Application of PCT distance between heating elements of the brush and the scalp
International Application No. PCT/IL2013/050420, Interna of the user's head. Spacers may have any form and may be
tional Filing Date May 16, 2013, claiming priority of PCT positioned on the brush and/or on the heating elements.
Patent Application No. PCT/IL2013/050017, filed Jan. 6, Spacers may be made of any material, preferable a heat
2013, and Israeli Patent Application No. 219875, filed May 10 insulating material. Different types of spacers may be used
17, 2012, all of which are hereby incorporated by reference. at different regions of the brush.
With specific reference now to the drawings in detail, it is
BACKGROUND stressed that the particulars shown are by way of example
and for purposes of illustrative discussion of the preferred
1. Technical Field 15 embodiments of the present invention only, and are pre
The present invention relates to the field of hair heat sented in the cause of providing what is believed to be the
treatment, and more particularly, to brush-like hair straight most useful and readily understood description of the prin
eners. ciples and conceptual aspects of the invention. In this regard,
2. Discussion of Related Art no attempt is made to show structural details of the invention
Hot combs have been used since the late l 9'h century, 20 in more detail than is necessary for a fundamental under
however operational considerations and safety requirements standing of the invention, the description taken with the
have been limiting their applicability. drawings making apparent to those skilled in the art how the
several forms of the invention may be embodied in practice.
BRIEF SUMMARY Before explaining at least one embodiment of the inven-
25 tion in detail, it is to be understood that the invention is not
One aspect of the present invention provides a brush limited in its application to the details of construction and
comprising a plurality of heating elements protruding from the arrangement of the components set forth in the following
a face of the brush, the heating elements dispersed on the description or illustrated in the drawings. The invention is
brush's face at a specified density; and a plurality of spacers applicable to other embodiments or of being practiced or
arranged to maintain a specified distance between protruding 30 carried out in various ways. Also, it is to be understood that
ends of the heating elements and a scalp of a head that is the phraseology and terminology employed herein is for the
being brushed, the spacers dispersed on the brush's face at purpose of description and should not be regarded as lim
a specified density that assures maintaining the specified iting.
distance with respect to a resilience of the spacers. FIGS. lA-lC are high level schematic illustrations of a
These, additional, and/or other aspects and/or advantages 35 brush 100 according to some embodiments of the invention.
of the present invention are set forth in the detailed descrip FIG. lA is a perspective view, FIG. lB is a cross sectional
tion which follows; possibly inferable from the detailed view and FIG. lC is a side view. FIGS. 2A-2C and 3A-3D
description; and/or learnable by practice of the present are high level schematic illustrations of various arrange
invention. ments of heating elements 120 and spacers 130 of brush 100
40 according to some embodiments of the invention. Brush 100
BRIEF DESCRIPTION OF THE DRAWINGS comprises heating elements 120 dispersed on and protruding
from its face and spacers 130 arranged to maintain a
For a better understanding of embodiments of the inven specified distance between protruding ends of heating ele
tion and to show how the same may be carried into effect, ments 110 and a scalp of a head that is being brushed.
reference will now be made, purely by way of example, to 45 Spacers 130 are dispersed on the brush's face at a specified
the accompanying drawings in which like numerals desig density that assures maintaining the specified distance with
nate corresponding elements or sections throughout. respect to a resilience of spacers 130.
In the accompanying drawings: FIGS. lA and lB illustrate flat, essentially one-sided
FIGS. lA-lC are high level schematic illustrations of a brush 100, having a back 91, a handle 90, an operation
brush according to some embodiments of the invention; 50 button 95 and optionally an operation indicator and a heating
FIGS. 2A-2C and 3A-3D are high level schematic illus level selector (not shown). In the cross sectional view of
trations of various arrangements of the heating elements and FIG. lB, heat source 110 is visible, as well as the internal
spacers of the brush according to some embodiments of the structure of elements in handle 90. FIG. lC illustrates a
invention; and cylindrical brush 100 having dispersed heating elements 120
FIG. 4 is a high level schematic flowchart illustrating a 55 and spacers 130. In these embodiments, some of spacers 130
method according to some embodiments of the invention. may be connected on top (126) of some of heating elements
120 (130B) or among heating elements 120 (130C).
DETAILED DESCRIPTION FIGS. 2A and 28 illustrate two configurations of heating
elements 120 and spacer 130 on brush's face 92. FIG. 2A
Prior to setting forth the detailed description, it may be 60 illustrates a dense arrangement of heating elements 120 and
helpful to set forth definitions of certain terms that will be spacer 130 in which there is a high probability of each hair
used hereinafter. 80 contacting at least one heating element 120 and each hair
The term "heating element" as used herein in this appli 80 is likely to be extensively heated. FIG. 28 illustrates a
cation refers to any type of heat conductive element, in less dense arrangement of heating elements 120 and spacers
particular metal (e.g. aluminum) heat conductors. Heating 65 130 in which heating elements 120 are spread apart in
elements may have any shape, e.g. elongated, flat, conical, respect to FIG. 2A. As heating elements 120 are more
have a cross section that is round, elliptic or flat etc. Heating remote from each other, there is a lower probability of each
EXHIBIT D

Guy A. Shaked Investments v. Ka Man - Complaint

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Guy A. Shaked Investments v. Ka Man - Complaint

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Case 2:19-cv-10589 Document 1 Filed 12/16/19 Page 1 of 16 Page ID #:1

1 Michele D. Johnson (Bar No. 198298)

1 3. A radio station in Texas shared the video on Facebook, and according

1 5. Millions of women can relate to Sharon Rabi’s experience with a

1 with traditional straighteners. Three-dimensional heated elements protruding from

1 FIRST CAUSE OF ACTION

1 (a) Entry of judgment in favor of Guy A. Shaked Investments, Ltd. and

1 DEMAND FOR JURY TRIAL

c12) United States Patent (IO) Patent No.: US 9,591,906 B2

(54) HAIR STRAIGHTENING BRUSH (52) U.S. Cl.

(86) PCT No.: PCT/IL2013/050420 FOREIGN PATENT DOCUMENTS

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