Case 2:20-cv-03051 Document 1 Filed 04/01/20 Page 1 of 8 Page ID #:1

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

A Limited Liability Partnership
2 Including Professional Corporations
BRUCE G. CHAPMAN, Cal. Bar No. 164258
3 bchapman@sheppardmullin.com
333 South Hope Street, 43rd Floor
4 Los Angeles, California 90071-1422
Telephone: 213.620.1780
5 Facsimile: 213.620.1398
6 ALONZO & ASSOCIATES
Arlyn L. Alonzo, Cal. Bar No. 185169
7 arlyn@alonzoasso.com
1015 Garnet St.
8 Redondo Beach, CA 90277-3513
Telephone: 310.291.6738
9
Attorneys for Plaintiff
10 SYSONIC ELECTRONICS, INC.
11
12 UNITED STATES DISTRICT COURT
13 CENTRAL DISTRICT OF CALIFORNIA
14
15 SYSONIC ELECTRONICS, INC., Case No. 2:20-cv-03051
16 Plaintiff, COMPLAINT FOR PATENT
INFRINGEMENT
17 v.
JURY TRIAL DEMANDED
18 RACING POWER COMPANY,
19 Defendant.
20
21 Plaintiff Sysonic Electronics, Inc. d/b/a Top Street Performance (hereinafter
22 “Sysonic”), for its complaint against Defendant Racing Power Company (hereinafter
23 “RPC”), alleges as follows:
24 The Parties
25 1. Sysonic is a corporation organized and existing under the laws of the
26 State of California, with its principal place of business at 15050 Shoemaker Avenue,
27 Santa Fe Springs, CA 90670.
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1 2. Doing business as Top Street Performance, Sysonic markets and sells

2 aftermarket automotive accessories and parts in this district, in the State of
3 California, and throughout the United States of America.
4 3. On information and belief, RPC is a corporation organized and existing
5 under the laws of the State of California, having a principal place of business at 815
6 Tucker Lane, City of Industry, CA 91789.
7 4. On information and belief, RPC markets and sells aftermarket
8 automotive accessories and parts in this district, in the State of California, and
9 throughout the United States of America.
10 Jurisdiction and Venue
11 5. This is an action for design patent infringement arising under the Patent
12 Act, 35 U.S.C. § 101 et seq. The Court has subject matter jurisdiction over this
13 action pursuant to, inter alia, 28 U.S.C. § 1331 (federal question) and 28 U.S.C.
14 § 1338(a) (action arising under the Patent Act).
15 6. The Court has personal jurisdiction over RPC because RPC is a
16 California corporation that has done and continues to regularly do business in the
17 State of California.
18 7. Venue is proper in this district pursuant to 28 U.S.C. § 1400(b) because
19 RPC resides in this district and has committed infringement through its regular and
20 established place of business in this district.
21 Background
22 8. Sysonic, doing business as Top Street Performance, is a leader in the
23 field of aftermarket vehicle parts, including ignition coil covers.
24 9. Sysonic’s ignition coil covers are specifically designed to provide a
25 unique and distinctive design that differentiates its products from others.
26 10. On August 4, 2015, United States Patent No. D735,759 (“the ’759
27 patent”) was duly and legally issued by the United States Patent and Trademark
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1 Office. Sysonic is the lawful owner of the ’759 patent. A copy of the ’759 patent is
2 attached as Exhibit A. The ’759 patent remains in full force and effect.
3 11. The ’759 patent covers an ornamental design for an ignition coil cover.
4 12. Sysonic practices the ’759 patent in connection with the
5 commercialization of ignition coil covers, as shown for example below.
6 ‘759 Patent Sysonic Ignition Coil Cover
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13. The Sysonic ignition coil cover is, and has been, marked with the
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number of the ‘759 patent, as shown below.
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14. The Sysonic ignition coil covers have been commercially successful
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with their distinctive design providing differentiation to other competitors’ designs.
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SMRH:4829-9096-0310.1 COMPLAINT FOR PATENT INFRINGEMENT
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1 RPC’s Infringement
2 15. On information and belief, RPC is selling ignition coil covers in
3 competition with Sysonic.
4 16. On information and belief, RPC’s ignition coil cover is an exact copy
5 Sysonic’s ignition coil cover, as shown below.
6
7 Sysonic Ignition Coil Cover RPC Ignition Coil Cover
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17 17. On information and belief, the RPC ignition coil cover design was
18 copied from Sysonic’s ignition coil cover marked with the number of the ’759
19 patent and Sysonic was, as a result, aware of the ’759 patent.
20 18. On January 14, 24 and 26, 2019 RPC was given actual notice by email
21 of the ’759 patent and also of RPC’s infringement of that patent. As a result, RPC
22 was fully aware of the ‘759 patent and its infringement.
23 19. The design of RPC’s ignition coil covers are the same or substantially
24 the same as the design of the ’759 patent. At the least, the designs are so nearly
25 identical that an ordinary observer, giving such attention as a purchaser usually
26 gives, would be deceived by the substantial similarity between the designs so as to
27 be induced to purchase RPC’s products believing them to be substantially the same
28 as the design protected by the ’759 patent, as shown below.

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1
‘759 Patent RPC Ignition Coil Cover
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20. Sysonic has not authorized to RPC to make, use, offer for sale, sell or
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import ignition coil covers that embody the design patented in the ’759 patent.
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21. On information and belief, RPC is willfully and knowingly infringing
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the ’759 patent.
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Count I
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(Infringement of United States Design Patent No. D735,759)
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22. Sysonic incorporates by reference the allegations contained in
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paragraphs 1-21 above.
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23. Sysonic provided constructive notice to RPC of its infringement by
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marking its product with the number of the ’759 patent.
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24. On information and belief, RPC has infringed and continues to infringe
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the ’759 patent by, inter alia, making, using, offering to sell, or selling in the United
24
States, products infringing the ornamental design covered by the ’759 patent in
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violation of 35 U.S.C. § 271.
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25. On information and belief, RPC’s infringement was, and is, willful.
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1 26. RPC’s infringement has damaged and continues to damage and injure
2 Sysonic. The injury to Sysonic is irreparable and will continue unless and until RPC
3 is enjoined from further infringement.
4 Prayer for Relief
5 WHEREFORE, Plaintiff Sysonic, prays for the following relief:
6 A. A judgment entered in favor of Sysonic on its claim that RPC has
7 willfully infringed the ’759 patent;
8 B. An injunction enjoining RPC, its respective officers, directors, agents,
9 and employees and all those in concert or participation with it who receive notice,
10 from making, importing, using, selling, and offering to sell infringing products
11 practicing the ’759 patent and from otherwise infringing, contributing to
12 infringement of, and actively inducing infringement of the ’759 patent;
13 C. A judgment that RPC pay to Sysonic:
14 (1) the extent of RPC’s total profit and revenue realized and derived
15 from its infringement of the ’759 patent, and actual damages to Sysonic in an
16 amount not less than a reasonable royalty for RPC’s infringement;
17 (2) treble damages in accordance with 35 U.S.C. § 284 for RPC’s
18 willful and deliberate infringement.
19 D. An award of costs of this action together with Sysonic’s reasonable
20 attorney’s fees pursuant to 35 U.S.C. § 285 for this case being exceptional;
21 E. An award of interest, including prejudgment interest, on all damages;
22 and
23 F. An award to Sysonic of such further relief as the Court deems just and
24 proper.
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1 Dated: April 1, 2020

2 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
3
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By: /s/ Bruce G. Chapman
5 BRUCE G. CHAPMAN
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Attorneys for Plaintiff SYSONIC
7 ELECTRONICS, INC. d/b/a TOP STREET
8 PERFORMANCE
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1 Demand for Trial by Jury

2 Sysonic hereby demands a trial by jury as to all issues so triable.
3
4 Dated: April 1, 2020
5 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
6
7
By: /s/ Bruce G. Chapman
8 BRUCE G. CHAPMAN
9
Attorneys for Plaintiff SYSONIC
10 ELECTRONICS, INC. d/b/a TOP STREET
11 PERFORMANCE
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EXHIBIT A
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